Submission to the Review of the Australian Standards for the Export of Livestock (ASEL) 4.0 – Tranche 2
Submission overview
The Australian Alliance for Animals welcomes the opportunity to comment on the Department's review of bedding-related and minimum feed requirements under ASEL Version 4.0.
Representing six leading animal protection organisations and over 2 million Australians, the Alliance supports the submissions made by Vets Against Live Exports (VALE) and RSPCA Australia. Our submission raises concerns about the evidentiary basis and methodology used in the Department’s review, particularly the heavy reliance on industry-generated data, the limited use of independently verified evidence, and the exclusion of important welfare research and historical oversight reports.
The Alliance argues that the absence of reported welfare problems should not be interpreted as evidence that welfare risks do not exist, particularly where independent monitoring is limited, and key welfare indicators are not routinely assessed. We also raise concerns that the review’s analytical approach may have introduced selection bias by excluding voyage types and periods historically associated with significant welfare concerns.
The submission supports strengthening, rather than weakening, welfare protections for exported animals. This includes maintaining and improving bedding requirements, introducing mandatory ammonia monitoring, reviewing minimum feed standards for all classes of cattle, increasing contingency feed provisions, and improving the assessment of hunger, satiety, and other welfare outcomes during voyages.
Read our submission
In this submission, the Alliance for Animals calls on the Australian Government to undertake further review of the proposed ASEL changes and ensure that livestock export standards are informed by robust, independent evidence and focused on delivering the highest possible animal welfare outcomes.