Audible response

Consultation on the proposal for an implementing act laying down rules for the collection, storage and sharing of information related to official controls of vessels transporting live animals

Danish Ports thanks for the opportunity to submit a consultation response regarding the EU Commission's The EU Commission's draft for establishing rules for the collection, storage and sharing of information related to regulatory controls of ships transporting live animals.

General comments
For Danish Ports, it is important 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 costs and burdens on the ports.

Specific comments
For Danish Ports, it is important to clarify who is responsible for the increased control and at whose expense. Article 2(3) of the act requires the European Commission to give the competent authorities in the Member States access to the database in question. Here it should be clarified who the competent authority is, including whether it is a port or a national authority.

Article 2(4) of the act requires Member States to designate a national contact point for the establishment of an electronic database. Here it should be clarified how such a contact point is to be understood.

Article 2(5) of the act states that each Member State is responsible for the data and information submitted by users operating under its jurisdiction. Here it should be clarified who is responsible for this, including whether it is ports or a national authority.

Article 3 of the act introduces a requirement for Member States to submit ship approval certificates to the electronic database. It should be clarified who is responsible for submitting these approval certificates, including whether it is a port or a national authority. 

Article 4 of the act requires Member States to report inspections of vessels transporting live animals to the electronic database as soon as possible. Here it should be clarified who is responsible for reporting these inspections, including whether it is a port or a national authority.

Clarification of the above points will be of great importance for the handling of the rules in Danish ports.

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