9. Interim conclusions
SAWC observes at this stage:
Need for further information
Evidence gathered for this report has highlighted, above all, the lack of consistent, objective information about the import, capture, breeding, trade, transport, keeping and regulatory monitoring of a wide variety of animals in Scotland in a wide variety of settings.
This interim report is based on information submitted by stakeholders and SAWC is aware that the sources referenced are neither comprehensive nor unanimous. For that reason, SAWC has requested that the Scottish Government facilitate the commissioning of a full independent literature review to inform its final conclusions and recommendations.
The difficulty of formulating an all-encompassing, concise definition helps to illustrate the multi-faceted nature of the sector. The term “exotic pet” is likely to continue in common usage as it is simple and most people believe they have an understanding of what it means.
Differentiation such as between wild-caught and captive-bred animals, and between “kinds” of animals that may competently be kept by hobbyist or private keepers, as opposed to professional or licensed keepers, may have more immediate utility. However, this should not be taken as indicating that all captive-bred animals necessarily enjoy good welfare simply as a consequence of their breeding circumstances or that even experienced keepers are able to fulfil their needs.
For regulatory purposes, while there is potential in the use of “non-domesticated”, it might be clearer and more relevant to focus on a list devised on the basis of the welfare needs of the animals.
SAWC believes that there are significant concerns about the welfare of exotic pets at all stages including their sourcing, breeding, transport and keeping, and that these are supported by scientific and veterinary evidence, even though there are conflicting views in academic sources.
SAWC acknowledges that some keepers are more able to provide for animals’ welfare needs than others.
Objective criteria such as the Five Domains assessment model should be consistently used to assess the welfare of animals and their suitability as pets.
Meeting animals’ welfare needs almost invariably requires the provision of appropriate veterinary care for individual animals. This means:
- Keepers should ensure that they have access to a specialist practice and call on its services whenever an animal is failing to thrive
- Veterinary undergraduate education should include sufficient modules on exotic species medicine, husbandry and welfare.
Note should be taken of the British Veterinary Zoological Society warnings against the breeding, sale or exchange of phenotypic variants (so-called ‘colour morphs’) with hereditary defects known to be associated with welfare problems and this could be incorporated into future Scottish Government licensing regulations.
In the event that further regulation is proposed by the Scottish Government, any limitations on the keeping of different kinds of animal should be based on objective suitability criteria, with animal welfare as a priority.
A number of ethical issues are raised in section 6.9 of this document and SAWC’s final report will be augmented by a section on wider questions surrounding the ethics of keeping non-domesticated animals as pets.
SAWC has identified inconsistency in the extent and nature of record-keeping by local authorities, customs, importers and sellers, etc.
While many local authorities use standard model licensing conditions, these do vary in application and interpretation. In particular, the monitoring of livestock origin records appears inconsistent. SAWC expects that this will be addressed to some extent by the implementation of the Animal Welfare (Licensing of Activities Involving Animals) Regulations 2021 and notes that Scottish Government guidance on these points will be particularly important.
Implementing a positive list would probably be likely to reduce the regulatory burden by reducing the number of species that could be kept.
There appears to be a lack of meaningful regulation of online sales. This is a major area which SAWC has not yet been able to explore in detail and further information is being sourced via the Pet Advertising Advisory Group.
More detailed monitoring of the numbers and species of animals being bought and sold by licensed operators, and of online sales, would appear to be necessary.
Negative lists are unlikely to be recommended due to their lack of flexibility, relative ease of circumvention and the consequent need for repeated updating.
The advantages of a positive-list approach include enforceability, simplicity, clarity and flexibility, all of which in turn help to provide animal welfare benefits. They have become established in a number of European countries and Scotland can benefit from their experience in both compiling lists and implementing their use.
The disadvantages include the complexity of drawing up scientifically robust lists and the misconception that the animals included on a positive list are easy to keep. This is allied to the risk of drawing up a list that is too long.
The “dynamic” approach to listing may assuage some of the above concerns and, importantly, help to ensure that listing is non-discriminatory.
Transitional arrangements in the form of “grandfather provisions” could be agreed, to allow prohibited animals already in private ownership to be kept until they die, but not bred or otherwise replaced.
Listing could form part of a multi-tier licensing approach, with a type of general licence to cover those animals listed as suitable for private keeping, and more specific licences available, when appropriate, for more experienced keepers with the knowledge and facilities to provide adequately for animals with more complex needs.
While SAWC has not formed a final view on the positive-list approach, it believes that there is merit in exploring this further, in order to promote the welfare of non-domesticated species kept as pets in Scotland.