Audible response

Consultation on a preliminary proposal for a delegated act concerning the establishment of rules for official controls of vessels transporting animals and ports of exit

Danish Ports thanks for the opportunity to submit a consultation response regarding the The EU Commission's draft for the establishment of rules for official control of ships for animal transport and ports of exit.

General comments
Danish Ports welcomes the European Commission's proposal for increased control of ships for animal transport and ports of exit. However, it is important to Danish Ports that the stricter rules are clear and precise in terms of who is responsible for the control and that the rules do not impose unnecessary burdens on the ports. At the same time, it is important to clarify who is the competent authority in Danish ports in relation to the stricter rules.

Specific comments
For Danish Ports, it is important to clarify who is responsible for the increased control and at whose expense. Article 2 of the act presents a requirement that official veterinarians and technicians must inspect the ship before it can be approved. Here, it should be clarified who is responsible for calling in official veterinarians and technicians and at whose expense.

Article 3 of the act states that applications for authorization of ships must be submitted to the competent authority at least three months before the expected inspection date. Here it should be clarified who is responsible for sending such an application and at whose expense.

Article 4 of the act introduces additional requirements for loading the animals onto the ship, including a risk analysis of the transport. Here it should be clarified who is responsible for presenting a risk analysis - and to what extent and at whose expense. As well as a clarification of what is meant by the competent authority at the point of departure.

Article 5 of the act proposes that the competent authorities must document the inspection of the ship with image and video documentation. Here it should be clarified who is responsible for carrying out image and video documentation and at whose expense.

Article 6 of the act states that there must be an official veterinarian on board during the ship's first voyage after it has been approved. Here it should be clarified who is responsible for ensuring that there is an official veterinarian on board during the ship's first voyage and at whose expense.

Article 7 of the act requires that checkpoints must be available in the port or in the immediate vicinity of the port. Here it should be clarified who is responsible for setting up checkpoints in the port or in the immediate vicinity of the port and at whose expense.

All in all, Danish Ports welcomes the EU Commission's proposal for increased control of ships for animal transportation and ports of exit. However, further clarification of the above points will be crucial for the handling of the rules in Danish ports.

Danske Havne is available if further dialog or clarification is needed.