In January, 2021, the European Union (EU) adopted legislation to protect livestock and animals that enter or transit the EU in order to prevent and eradicate disease. This law also “allows greater use of new technologies for animal health activities – surveillance of pathogens, electronic identification and registration of animals (1)” according to the European Commission. The Animal Health Law otherwise known as Regulation (EU) 2016/429, applies also to the movement of companion animals like dogs, cats, small mammals, reptiles and the like. This is why, if your pet’s itinerary calls for transiting the EU and it is flying as air cargo, this law will apply and it is important that you understand it.

What is air cargo service?

There are 3 classes of service available that live animals can fly under on a commercial airline. Some commercial airlines may not offer all three services. They may offer only one or two or they may not be pet friendly at all. That is why it is important to research airline pet policies before booking your pet’s travel.

1. In-cabin – your pet is a small cat or dog (or sometimes small bird or other pet) flying in the cabin with an adult paying passenger in an airline-compliant pet carrier.
2. Checked Baggage – your cat or dog under 75-80 lbs (or sometimes other animal) flying in the cargo hold whose itinery is connected with an adult paying passenger on the same flight
3. Manifest Air Cargo – for very large pets and otheranimals flying unaccompanied or flying to countries that require that live animals enter as air cargo (UK, New Zealand, Australia, Hong Kong, South Africa, etc.)

Currently, the Animal Health Law applies to all air cargo transports; however, the law will apply also to in-cabin and checked baggage transports in April of 2026. Depending on how you route your pet’s trip and whether your route involves a country that is classified as an Unlisted Third Country by the EU, this law will have significant impacts on how your pet is prepared to travel.

What is a transit?

A transit is when your pet remains on the same airline in and out of a layover airport. If the flight numbers on your itinerary remain the same on your itinerary on both legs of your trip, then your pet will remain on board the same aircraft. This is an uncommon occurance, especially if the layover is in the airline’s hub airport, but it does happen. As long as your pet does not need to depart the aircraft, then this new regulation will not apply. If your pet must change aircraft when transiting, as it will in most cases, then the new regulation will apply, even if your pet is staying on the same airline.

What is a layover?

A layover is when you have a non-direct flight, and your pet will be changing aircraft in the layover airport. If your pet is changing airline companies in the layover airport, (Lufthansa to Brussels Airlines, for example), then your pet will need to clear customs and enter the layover country to check it on the next airline. The reason for this is because airlines do not interline pets between airline companies. The new regulation will absolutely apply in this case. Your pet will need all documentation required to enter the layover country.

Comfort Stops

Your airline may mandate a comfort stop (kenneling) for any pet whose itinerary exceeds a certain length of time in the cargo hold. This mandate will vary from airline to airline depending on the animal welfare regulations in the country in which they are based; however, as an example, most US-based airlines limit the flight time for pets 8-9 hours. Airlines based in Asia are longer. The transit time can start at tender (check-in) time through recovery (which could be up to 2 hours after arrival at the layover airport or final destination). Basically, the amount of time your pet will spend in its crate. You should work with your airline regarding comfort stops if your pet’s trip will be lenthy. If your airline requires a comfort stop, then this new regulation will apply if the comfort stop takes place in an EU airport.

My pet is flying as air cargo and will be stopping at an EU airport. What documents will my pet need to conform to the new regulations?

If your pet’s itinerary includes only rabies-controlled countries, then your pet will need the following documentation to transit or layover in the EU:

• all required documentation for your destination country
• proof of microchip implanted on or before rabies vaccination
• current rabies vaccination
• Endorsed EU Health Certificate for the layover country
• Tapeworm treatment (UK, Ireland, Finland, Malta and Norway)

If your pet’s flight plan originates, has transit, layover or comfort stop in or your pet terminates in a country classified by the EU as high-rabies, then, in addition to the above documents, your pet will need proof of a rabies titer test with results greater than 0.5 IU/ml administered more than 3 calendar months prior to travel. If your pet is traveling to a high-rabies country and will be returning to your country with a layover in the EU, you should get the test done before leaving the for your trip.

Let’s look at some examples.

EXAMPLE #1: Your pet is flying from YYZ (Toronto) > CDG (Paris) with Air France, then CDG (Paris) > AMS (Amsterdam) with KLM then returning AMS > CDG > CDG > YYZ

Requirements for YYZ > CDG > AMS

1. All documents required for entering France including the Commercial or Non-Commercial EU Health Certificate for France (valid for 10 days after issuance)
2. Proof of microchip implanted at the same time or before rabies vaccination
3. Proof of current rabies vaccination

Your pet will be able to use the same health certificate to enter the Netherlands that was used to enter France.

Requirements for AMS > CDG > YYZ

1. All documents required for entering France including a Commercial or Non-Commercial EU Health Certificate (new certificate)
2. Proof of microchip implanted at the same time or before rabies vaccination
3. Proof of current rabies vaccination

EXAMPLE #2: Your pet is flying JFK (New York) > FRA (Frankfurt) > BOM (Mumbai) then returning BOM > FRA > JFK:

REQUIREMENTS FOR JFK > FRA > BOM

1. All documents required for entering India
2. Proof of microchip implanted at the same time or before rabies vaccination
3. Proof of current rabies vaccination
4. Commercial or Non-Commercial EU Health Certificate for Germany (valid for 10 days from issuance)

REQUIREMENTS FOR BOM > FRA > JFK

1. Import Permit (unless proof of current rabies vaccination in administered in the US is available)
2. Proof of current rabies vaccination
3. Export Health Certificate from India
4. Proof of microchip implanted at the same time or before rabies vaccination
5. Commercial or Non-Commercial EU Health Certificate for Germany (new certificate)
6. Rabies Titer Test administered 3 months prior to transiting in Germany

All EU health certificates issued for transit as well as entry must be endorsed by the government agency in the departing country that is responsible for the import and export of live animals. Generally, veterinary services is a division of the Department or Ministry of Agriculture. Exporters should submit both the health certificate for the transit or layover country (marked TRANSIT) as well as the health certificate for the destination country. The certificate numbers for both forms on the health certificates should be the same, if required. Consignee information should also be the same including the destination address.

EU health certificates are only valid for 10 days after issuance, so, very likely, a new certificate will need to be issued in the departing country when returning home.

Remember that currently this new regulation applies for all pets transiting the EU as air cargo, even if both transit or layover country and destination country are located in the EU. Pet owners who cannot fly with their pet or flying with their pet to any country that requires pets to enter as air cargo should be aware of these new requirements for EU transits, layovers or comfort stops in the European Union.