EU Animal Health Legislation Removes Authority of Aquatic Animal Health Professionals | Current problem


The Animal Health Act (AHL) of the European Union (EU) officially came into force about a year ago, on April 21, 2021. This new law focuses on transmissible animal diseases and amends and repeals certain aspects related to animal health.

Despite its entry into force a year ago, a transitional period has been granted by the EU authorities regarding the issuance of the associated Health Certificate (HC) to ensure a smooth transition from TRACES Classic procedures to TRACES NT. TRACES stands for the trade and export control system, to which the stakeholders connect for the issuance of the necessary certificate. It allows operators in the sector to issue the appropriate sanitary and phytosanitary certificates (the latter required for plants) and other official documents necessary for imports, exports and intra-European movements of animals (including fish and invertebrates water), plants and goods.

During the operation of TRACES Classic, health certificates were signed by an aquatic animal health professional. However, under TRACES NT, the CH can no longer be signed by an aquatic animal health professional but must be signed by an official veterinarian. At first glance, this may seem like a simple and uncomplicated change, but it is not.

Since the new AHL has been under discussion, Ornamental Fish International (OFI) and the European Pet Organization (EPO) have repeatedly raised concerns with European authorities regarding the requirement that the CH be signed by an official veterinarian rather than by an aquatic. animal health professional, as was the case until now.

According to Nathalie Gamain, Head of European Affairs at OFI in Brussels, the new requirement:

• “(would represent) significant additional costs and administrative burdens for companies exporting to the EU, which could, in some cases, make the export of live fish economically unviable.

• Where exports to the EU continue, they are likely to incur additional costs for EU businesses as the cost will be passed on to them in the price of the fish they import. It is very important to take into account that most of the fish intended for the aquatic ornamental trade are imported into the EU from third countries.

• With such a requirement, it is also very important to consider the status of the veterinary profession for aquatic ornamental plants. As we well know, fish veterinarians are not so numerous. Requiring that all exports to the EU be signed by an official veterinarian could therefore create significant delays in the transport of ornamental fish due to the additional workload of veterinarians, with consequent welfare implications.

On 13 December 2021, OFI and EPO wrote to the Directorate-General for Health and Food Safety of the European Commission to express their above concerns. In its response, the C reconfirmed that: “consignments entering the Union must be accompanied by an animal health certificate issued by an official veterinarian of the third country or territory of origin, specific to the particular species and category of animals, germinal products and products of animal origin and their intended use.

Thus, despite the requests and explanations of the OFI and the EPO, the change will be maintained and aquatic animal health professionals will no longer be able to sign the CHs, this obligation now falling exclusively to official veterinarians.

The species in question to which the above applies are listed in the Annex to Commission Implementing Regulation (EU) 2018/1882 (see further reading). I checked this appendix, and there is only one species that directly concerns the ornamental aquatic industry: the koi (Cyprinus carpio). Goldfish (Carassius auratus) and several other species more or less relevant to the aquarium/pond trade, e.g. tench (Tinca tinca), walking catfish (Ictalurus spp.) and red swamp crayfish (Procambarus clarkia), which are currently banned in Europe – are also listed, but in column 4, which exempts them from this requirement. In effect, this means that the certification of goldfish, tench and crawler catfish will continue to be treated as it has been until now, i.e. “in accordance with the national rules of Member State of destination”, but the health certification of koi will require the signature of an official veterinarian.

It remains to be seen whether this will remain the case or whether the continued representations from OFI and EPO will bear fruit and whether aquatic animal health professionals will once again be allowed to sign CHs. In the meantime, we can expect koi prices to rise as the extra costs I outlined above start to bite. We also look with great concern to see if the welfare of these fish will be impacted by the inevitable delays that the new requirements will cause.


Nathalie Gamain: Latest news on EU animal health law, OFI Journal, issue 98, February 2021.

John Dawes is an international consultant to the ornamental aquatics industry. He has authored and/or edited over 50 books and contributed over 4,000 articles to hobby, business and academic publications. He is editor-in-chief of OFI Journal and consultant for AquaRealm, the trade show that took place in June 2017 in Singapore.


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