Consultation outcome

Summary of responses and government response

Updated 15 December 2025

Introduction

From 23 June until 18 August 2025, Defra, Scottish Government and Welsh Government undertook a joint consultation on draft Pathway Action Plans (PAPs) for invasive non-native species (INNS). The consultation was conducted predominantly using Citizen Space, UK government’s online consultation tool, and was supplemented by email communication.

This document provides a ‘summary of responses’ received during the consultation as well as the 3 ‘governments response’. 

The analysis presented in the ‘summary of responses’ is based on the formal responses to the consultation, which were received through Citizen Space and by email. The 3 governments have also taken into account all views expressed in other discussions, to develop their response.

Background

Five PAPs have been developed by working groups established by the GB Non-native Species Secretariat. They cover 6 of the priority pathways:

• angling
• recreational boating
• horticulture (covering the pathways ‘horticulture’ and ‘horticultural hitchhikers’)
• pets
• zoos and aquaria

The development of the draft PAPs has involved extensive engagement with partners and other organisations. Each PAP contains a full set of actions intended to specifically target the risks determined to be present in each priority pathway.

The PAPs do not change legislation or create burdens or prohibitions.

This consultation provided the opportunity to gather wider feedback on the actions within each PAP. There was an overall aim of making necessary revisions to the PAPs to make them as comprehensive as possible. This consultation was therefore a final step in developing the PAPs prior to publication.

Summary of responses - overview

Number of responses

66 responses were received, 57 via Citizen Space, 8 via email and 1 by letter.

Of the respondents:

• 7 categorised themselves as an individual
• 53 were responding on behalf of an organisation, of which 20 were representatives of an NGO, 5 were from a public body and 9 were from a sector trade body or membership organisation

Option chosen	Total Citizen Space (online)	Total email/letter	All formats total
NGO	13	5	18
Sector trade body/trade organisation	9	0	9
Individual	7	0	7
Public body	3	2	5
Academic	4	0	4
Local Authority	4	0	4
Research organisation	3	0	3
Ecologist	2	0	2
Landowner/occupier	2	0	2
Other	10	2	12

In the consultation we asked respondents to categorise themselves based on their interest in INNS. Respondents could choose more than one interest. All respondents chose at least 1 interest, 15 respondents selected 4 or more different interest areas.

Option	Citizen Space total
Horticulture	22
Angling	20
Boating	19
Pets	17
Zoo	13
Marine	13
Botanical garden	12
Aquarium	12
Species interest group	11
Hobbyist	7
eNGO	6
Rescue center	4
Other (please specify)	14

A list of organisations who responded to the consultation is set out in Annex 1. Five respondents stated they wished for their response to be kept confidential, so the names of the organisations listed by these respondents have been omitted.

We also asked which location their response relates to. Respondents could choose more than one option.

Option	Total	Percent
Great Britain	31	47%
England	23	35%
Wales	18	27%
Scotland	10	15%
Other (please state, where)	2	3%

Methodology

A standard set of pathway-specific questions was asked which are a mix of multiple choice and free-text responses for each of the PAPs. These questions focussed on what the respondents would change or improve about the specific PAP. Respondents were asked if they were content with the PAP and could choose what aspect they thought could be improved from a list including text or action needing improving, missing text or action or other issue. They then had the chance to write in a free text box what they wanted changed, improved or deleted. A full list of all the questions asked is in Annex 2.

The ‘yes’ and ‘no’ responses and the multiple-choice responses have been quantified.

Due to the qualitative nature of the comments a thematic analysis was conducted. Each response was analysed for the cross-cutting recommendations across all of the PAPs. We then looked at the comments which related specifically to the content and actions for each pathway for recommendations of more specific updates to the text. The responses to each question were summarised to produce the overall summary of responses.

Headline messages

Overarching themes

Many responses mentioned overarching themes which apply across all of the PAPs. These could be divided into 4 categories. These are:

1. Structure

Many respondents reflected the need for consistency of structure between the PAPs. This included comments about contents pages, subheadings dividing text, use of bold typeface, expanding acronyms, creating a table of actions. A key suggestion was that the structure of the draft PAPs produced most recently could be replicated through the whole series.

Several mentioned the need for the PAPs to cross reference each other so readers are aware that actions relevant to them may appear in more than one PAP (for example, the Boating and Angling PAPs).

There were also comments about the need to reduce the length of each document to make them more succinct. Some respondents also suggested that documents in the PAP annexes could be removed and links inserted instead. They suggested this would help with both the length of the documents and in ensuring that the PAPs and supporting documents were more easily kept up to date.

Key quotes:

“To encourage widespread uptake, where possible, the final PAPs should be formatted consistently. For example, the Angling PAP includes a table (annex 3) outlining the key actions for each angling stakeholder to reduce accidental spread through angling activity. A similar table should be included for each PAP to help outline best practice approaches for different stakeholders.”

“Guidance and best practice documents…should be separate standalone documents which the PAP references and links to (as with the Zoos PAP).”

2. Governance

Many respondents described wanting the PAP actions to be SMART (specific, measurable, achievable, realistic, timebound) with agreed delivery milestones and timescales, clear ownership, and stronger language to convey a greater sense of purpose.

It was also suggested that there is a need for broader scope in terms of the stakeholders involved, both in terms of subject matter (the need for better coverage of invertebrates, for example), but also for better representation from different parts of Great Britain. This included suggestions of Wales and Scotland based organisations, and in some cases, of more regional groups.

Several respondents asked for a way of tracking the progress against actions. Suggestions included using a dashboard. It was also suggested that each action should make clear which objective it delivers against.

Key quotes:

“It would be useful to make clear where progress against a particular action can be tracked.”

“The actions should be ranked by priority level and given timeframes to be delivered and monitored by a responsible body.”

“Monitoring the implementation of the PAP could be strengthened, …progress would be better tracked over time in a systematic way e.g. using a dashboard that is updated. If no progress is made, then the effectiveness of the PAP needs to be reviewed.”

“A standardised template should be produced to capture the progress made by the group towards the different actions, and this should be made publicly visible to improve accountability and information sharing.”

3. Delivery

Another emerging theme was about the delivery of PAPs.

This included feedback on questioning if the correct stakeholders are involved to cover different interest groups and all areas of Great Britain. It was also suggested that there is a need for more regional organisations to be co-ordinated (for example, within Wales).

It was also suggested it should be made clear who is expected to deliver each action, including how organisations must work together, co-operating and dividing up tasks to avoid duplication of effort. For the PAPs covering angling and boating, there was discussion of having catchment focused delivery models.

Feedback also queried if the resources are in place to drive delivery. This included discussion about the costs to operators, the lack of incentives for acting and the lack of consequences if guidance and best practice is ignored.

It was also suggested that more effort is needed on INNS. It was not always clear what these comments referred to, but it is clear that some stakeholders feel that more needs to be done to progress the actions in the PAPs.

Key quotes:

“Funding to support the implementation of the PAPs is referred to directly within the GB Strategy which states it will ‘complete the suite of PAPs for priority pathways, ensuring that they are delivered and resourced’. We urge that dedicated funding is provided to ensure adequate implementation, with the working groups informing funding prioritisation to support PAP delivery.”

“For the majority of actions, there is little incentive (and in fact a disincentive in terms of cost) for operators or boat owners to follow best practice and there is a lack of consequences for not doing so.”

4. Communication and awareness raising

Overall, there were many comments about communications and awareness raising made across all the PAP responses. While communications and awareness raising are contained as actions in all the PAPs as currently drafted, it is clear that this is perceived as an issue by stakeholders. These comments were about:

• more effort being needed on awareness raising
• the need to use existing structures, stakeholders and groups to spread and promote the messages about INNS, including local NGOs and citizen science groups
• the need to reach more people with messages and campaigns, including the need to target consumers in specific sectors

It was also clear that some stakeholders are unaware of the process for reporting INNS, so this needs to be more widely communicated (see ‘out of scope’ section).

Additionally, some comments were supportive of current awareness raising.

5. The Non-native Species Inspectorate (NNSI)

Responses on the Boating, Angling and Zoos PAPs all included comments about the need for these PAPs to reflect the fact that the NNSI now exists. This was an expected outcome, as these PAPs were written before the NNSI was established, and the newer PAPs already contain actions which relate to the NNSI. The feedback received suggested that NNSI should be involved as an actor in general, that new actions which are led by the NNSI are added and that certain actions should be updated to reflect the role of the NNSI.

Horticulture PAP contains references to the NNSI, and comments suggest that this should be updated from ‘pilot NNSI…’ to remove pilot, since the NNSI is now established.

Key quotes:

“out of date…having been written before the NNSI was established.”

“Actions should be added…to recognise the role of the Non-Native Species Inspectorate (NNSI) in raising awareness of invasive species and tackling pathways of spread. This includes their role in undertaking voluntary checks for non-native species on recreational equipment.”

Out of scope responses

Each PAP received several comments that were out of scope and have therefore not been written up as part of this response. PAPs are documents which help to co-ordinate actions around a pathway of introduction and are not intended to introduce regulation. Actions which are wholly within the responsibility of government are covered by the GB Non-Native Species Strategy.

Five respondents made suggestions to develop, improve or speed up the process of laying legislation. However, the focus of the consultation is to develop the PAPs without the use of further regulation. We acknowledge that stakeholders see a need for further legislation to control INNS or wish for proposed legislation to be speeded up, but we will not be addressing this issue further in this document.

Some respondents asked for a clearer reporting mechanism or online tool for reporting INNS and for a well- resourced response process. A number of reporting mechanisms already exist such as the Non-native species information portal (NNSIP), which is funded by government, as well as INNS Mapper and Local Environmental Record Centres. In addition, eradication responses are run by government for new incursions of INNS according to a risk assessment and prioritisation process. It is clear that stakeholders are not always aware of these mechanisms, so this is an area which needs better communication.

Responses specific to each PAP

Below are responses that were specific to each PAP:

Angling PAP

To the question ‘Are you content with the actions within this PAP?’ 15 respondents answered no, 28 answered yes and 14 did not answer. Of the 9 letter responses, 5 provided feedback specific to the Angling PAP portion of the survey.

Question 12: ‘If no, what do you think could be improved?’ Respondents could choose more than one answer.

Option	Total	Percent
Text could be improved	18	27%
Action could be improved	13	20%
Missing action	9	14%
Missing text	6	9%
Other	5	8%

There were 19 responses in Citizen Space and a further 5 via email to the question ‘Please provide details of the changes you would make to this PAP or anything else you think is important.’ Key themes emerged from the remaining responses, with some crossover between them.

Bait

Several responses commented on action 14, which is about an assessment of the risks posed by moving bait for marine angling. This assessment has been carried out by Cefas since the PAP was drafted and can therefore be updated. It was also suggested a new action should be added which addresses the risks of spreading INNS with the movement and use of live bait.

Key quote:

“The Cefas draft comprehensive assessment of the risk posed by moving bait associated with marine angling was presented in 2020. It is recommended that this action is amended to implement the recommendations of the report. It is also recommended that a code of conduct for bait digging is developed to promote best practice to the angling community.”

Rod licences

Action 5 which is about Check, Clean, Dry (CCD) messaging being printed on rod licences was brought up by more than a quarter of the respondents on the Angling PAP, including the Environment Agency who issue rod licences. Rod licences are now issued electronically meaning the action is no longer relevant. Respondents suggested it should either be removed or possibly amended to say that CCD messages will be emailed to applicants when they are issued their electronic licence.

Key quote:

“Since the Angling PAP was developed, the Environment Agency has transitioned to issuing digital licences and no longer provides physical rod licence cards. To fulfil Action 5 and ensure the ‘Check, Clean, Dry’ message continued to reach the angling community, we recommend incorporating the Check Clean Dry logo or wording that communicates these measures within the digital email version of the licence.”

Need for a broader representation from across Great Britain

There were many comments about broadening the scope of representation on the Angling PAP working group. There were several comments about the need for more inclusion of Scottish and Welsh organisations, and the fact that Scotland and Wales are not properly represented by some of the bigger Angling and waterways organisations in the working groups (the Angling Trust, for example, only covers England).

It should be noted that a Scottish Angling PAP has been drafted separately by Scottish Government and will be consulted on in due course. Inshore Fisheries and Conservation Authorities (IFCAs) (England only) were mentioned as having a statutory duty to manage sea fisheries resources, including angling activities. Their role in promoting awareness and biosecurity among the angling sector was highlighted as a useful link that could be made through the PAP working group.

Key quotes:

“The PAP seems to have poor representation from anglers in Wales.”

“There is a lack of Welsh representation in organisations. Neither Angling Cymru nor Fishing in Wales are referenced as partners in the PAP.”

Broader scope: different types of angling

Several consultees mentioned that the PAP is too focussed on freshwater and felt that it needed to be more engaging of sea anglers. Comments included that it is not clear which actions relate to freshwater, marine, or both and that actions and annexes (code of conduct and biosecurity guidance) are focussed on freshwater.

New actions were suggested to:

• promote biosecurity measures specific to marine shore and boat-based fishing, including the cleaning and drying of waders, boots, and saltwater angling equipment
• require biosecurity planning for large-scale sea angling competitions and festivals

There were also responses about the differences between types of angling and specifically the differences between a river angler versus a still water angler and how these different activities need to be considered when writing guidance.

Key quotes:

“Generally, it is not clear which actions relate to freshwater, marine or both – it also needs to be clarified that the annexes (code of conduct and biosecurity guidance) are very much focussed on freshwater. These should also encompass relevant messages for marine anglers or make clear that the same biosecurity principles apply to both.”

“I felt that the text needs to be more engaging of sea anglers too and emphasising the issue of travelling between similar water bodies such as estuaries.”

Actions that were highlighted as out of date or requiring improvement were: 5, 6, 8, 10A, 12, 13 and 14, and annexes 4 (GB code of practice for angling), 5 (Agreed biosecurity guidance/plan for fisheries owners in GB) and 6 (List of priority species to keep out). The feedback on these annexes was that they need updating with more recent information, and it is suggested that they should be linked with a URL so that as lists or advice are updated it remains linked and relevant.

Boating PAP

To the question ‘Are you content with the actions within this PAP?’ 19 respondents answered no, 26 answered yes and 12 did not answer and did not complete further sections of the Boating PAP portion of the survey. Of the 9 letter responses, 5 provided feedback specific to the Boating PAP.

Question 9: ‘If no, what do you think could be improved?’ Respondents could choose more than one answer.

Option	Total	Percent
Action could be improved	14	21%
Text could be improved	13	20%
Missing action	6	9%
Missing text	6	9%
Other	7	11%

There were 28 responses to the question: ‘Please provide details of the changes you would make to this PAP or anything else you think is important.’ Some responses were supportive with no further action suggested. Key themes emerged from the remaining responses, with some crossover between them.

Wider scope of the vessels covered in the Boating PAP

Several respondents described the need for the definition of a ‘vessel’ to include a wider range of watercraft such as inflatable boats, paddleboards, wing-foils, jet-skis and e-Foils, as well as trailers and associated equipment for these types of boats. These are increasingly popular forms of leisure craft, usually owned by individuals and removed from the water immediately to a vehicle for transport after use, increasing the risk of spreading INNS. Responses also called for bespoke biosecurity guidance relating to the various equipment listed.

Concerns were raised about the number of inflatable craft being sold each month by online retailers, and the fact that they are often purchased by inexperienced users and used on inland sites with no managed access. This is a group which therefore maybe wholly unaware of any biosecurity advice. Such craft are also probably often removed from the water and packed away wet, allowing waterborne INNS and eggs to remain in the folds. There were therefore suggestions of additions to the PAP in the form of actions which target manufacturers and retailers of such vessels and provide bespoke educational materials to target users of inflatables and wing-foils.

There were also some responses which asked for equipment including wetsuits, bootees or wellies to be included within guidance as this is another way that users of leisure craft can transfer INNS.

At the other end of the spectrum, there were also suggestions for specific actions to develop advice for the users of larger vessels (larger than 10 tonnes), which cannot be regularly removed from the water for cleaning.

Key quote:

“It is important to explicitly include paddleboards and inflatables…within the scope of recreational watercraft. These items are commonly owned and transported by individuals rather than hired locally, increasing the risk of cross-site contamination.

Inflatables are typically deflated and rolled or folded for transport, creating warm, dark, and damp microenvironments that are highly conducive to harbouring INNS, particularly eggs and seeds. Their inclusion in biosecurity guidance is essential.”

Disposal of debris

Several respondents asked for improvements in the text and actions which are about washing vessels and equipment to include the disposal of the debris and wash-down water. This is to ensure that once cleaning has taken place, INNS are not washed directly into a pristine waterbody.

Key quote:

“…more should be made of the need to clear up, remove and responsibly dispose of the debris from hull cleaning at ‘scrubbing piles’ etc. after each operation by the vessel owner and managed by the scrubbing grid owner.”

Marine focus

Stakeholders expressed concerns that they felt that the actions focussed on freshwater and that marine INNS risks were not reflected in enough detail in the Boating PAP.

Suggestions included that marine boating needed its own separate PAP, or a separate section on marine boating INNS risks within the Boating PAP alongside additional actions to reflect the risks and realities of boating activity in the marine environment.

Key quotes:

“Improve cleaning advice for marine areas. Most of the advice is focused on freshwater. There should be more guidance for sea users, especially about hull cleaning and antifouling.”

“…many of the actions listed are not appropriate or far less effective in a marine setting…”

“It is important that the PAPs consistently reflect marine INNS risks across boating, angling, and coastal tourism pathways to mitigate this risk.”

Actions which were highlighted for requiring improvement were: 9, 11, 12A, 14, 15.

There were also comments about annex 2 (code of conduct for recreational boating) needing to be updated and clearly referenced in the text.

Horticulture PAP

To the question ‘Are you content with the actions within this PAP?’ 24 respondents answered yes while 15 said no and 18 did not answer. Of the 9 letter responses, 4 provided feedback specific to the Horticulture PAP portion of the survey.

Question 15: ‘If no, what do you think could be improved?’ respondents could choose more than one answer:

Option	Total	Percent
Text could be improved	14	21%
Action could be improved	14	21%
Missing action	8	12%
Missing text	6	9%
Other	11	17%

There were 24 responses in Citizen Space and a further 4 via email to the question ‘Please provide details of the changes you would make to this PAP or anything else you think is important.’ A wide range of horticulture specific recommendations were made but not all of them fell within the scope of the PAP. Key themes emerged from the remaining responses, with some crossover between them.

Raising awareness

A number of respondents stressed the importance of raising awareness amongst horticultural traders and the general public. Suggestions included improved awareness raising at the point of sale in garden centres on invasive plants and soil contaminants, improved messaging for overseas travellers at the border (for example, ferry ports), a call for greater inclusion of relevant groups and bodies in the PAP to capture the widest range of interests and ensuring there is a well-known process for reporting INNS by all involved in the horticulture trade.

Key quote:

“Increasing public awareness of the ecological consequences of allowing invasive plants to escape garden boundaries is vital.”

Online sales and borders

Several respondents wanted additional actions to cover investigation of unregulated online markets, including social media sales, given the risks posed by the sale of invasive species and contaminated soils.

There was also a suggestion to require engagement with authorities in Northern Ireland and the EU to ensure alignment and sharing of information.

Key quote:

“Action 2 should incorporate regular working with colleagues in Northern Ireland and EU Member states.”

Plant labelling

There were a number of suggestions for the development of a better plant labelling system to ensure that consumers understand what they are buying and how to plant and dispose of it correctly. This included suggestions that a consultation with industry take place about making improvements to existing plant labelling requirements, that up-to-date lists of invasive non-native plants including current names, common names and incorrect names are made available to retailers.

Key quote:

“Accurate and informative labelling is critical—both in terms of correct plant identification and clear indication of invasive potential.”

Hitchhikers

One respondent felt that the Horticulture PAP needs to be strengthened in relation to invertebrate hitchhikers, stating that an objective should be added to proactively identify and prevent invertebrate INNS from establishing in horticultural supply chains and domestic gardens.

They also suggested a new action to develop systematic monitoring protocols for invertebrate INNS in horticultural imports, including training for Plant Health and Seeds Inspectorate (PHSI) and NNSI staff in invertebrate identification and establishment of rapid response protocols. This respondent, alongside one other, further commented that action 14 (NNSI and PHSI to raise awareness of hitchhikers) should be enhanced to include training provision in the horticultural industry for identification of invertebrate hitchhikers and the actions that need to be taken should these be found.

Key quote:

“[There should be] mandatory training for horticulture industry staff in identifying invertebrate hitchhikers, not just plant pests. Many invasive invertebrates can establish from horticultural imports and spread to natural habitats.”

Pets PAP

To the question ‘Are you content with the actions within this PAP?’ 23 respondents answered yes, 14 said no and 20 did not answer. Of the 9 letter responses, 3 provided feedback specific to the Pets PAP portion of the survey.

Question 21: If no, what do you think could be improved? Respondents could choose more than one answer.

Option	Total	Percent
Text could be improved	12	18%
Missing action	8	12%
Action could be improved	9	14%
Missing text	7	11%
Other	5	8%

There were 20 responses via Citizen Space and 3 by email or letter to the question ‘Please provide details of the changes you would make to this PAP or anything else you think is important’.

Several of these responses were supportive, with no further recommendations suggested. Key themes emerged across the responses, with some crossover between them.

Public engagement and awareness

Many respondents highlighted the importance of public education to raise awareness of the risks of pet releases and escapes. There were comments on the role of the pet sector in educating and advising pet owners of the risks, with some respondents stating that this should be a requirement for the pet trade.

Key quote:

“Actions 4 and 6 should include a clear plan for ensuring that the provision of consistent and high-quality information to potential pet owners is a requirement for those trading in pet animals…”

The online pet trade

Respondents raised concerns about the substantial and expanding online sale and exchange of pets. Recommendations were made to review the risks posed and to implement measures to minimise them. Examples include actions to make major online platforms more accountable, enhanced enforcement capability, and utilising technology to improve oversight.

Key quote:

“The current Pet PAP significantly underestimates the risks posed by online pet sales, which have expanded dramatically in recent years…online sellers often operate without regulatory oversight, proper species identification, or biosecurity awareness”.

Species risk and management

Respondents thought there should be greater focus on identifying potentially invasive species. Invertebrates were highlighted as a particular risk with the risk from reptiles, amphibians and fish also raised.

Some respondents recommended that a positive list of species that can be traded as pets should be considered.

Detailed actions for aquarium water disposal, live feed biosecurity, and substrate management were recommended.

Greater awareness of the risks of keeping some animals in garden ponds and outdoor enclosures was also recommended.

Some of these recommendations are already under development and additional guidance is being prepared.

Key quote:

“…a positive list of species that can be traded as pets, based on them being assessed as very low risk for invasiveness (among other criteria), would provide a far more precautionary approach and should be considered…species considered high risk should not be traded or kept”.

Re-homing and reporting

There were recommendations to promote responsible rehoming of unwanted pets. Guidance was also requested on what to do if escaped or released pets are found in the wild, including recommendations for an easy reporting option. Some of these recommendations are already under development and additional guidance is being prepared.

A number of respondents raised concerns about the lack of capacity in the rescue sector for rehoming non-native species and new actions were suggested such as humane euthanasia protocols and government support for the rescue sector. This area of concern is largely outside the scope of the Pet PAP.

Key quote:

“Add an action to promote responsible rehoming. People should be shown safe ways to give up unwanted pets instead of releasing them.”

Zoos PAP

To the question ‘Are you content with the actions within this PAP?’ 13 respondents answered no, 25 answered yes and 19 did not answer and did not complete further sections of the Zoo PAP portion of the survey. Of the 9 letter responses, 1 provided feedback specific to the Zoo PAP portion of the survey.

Question 18: ‘If no, what do you think could be improved?’ Respondents could choose more than one answer.

Option	Total	Percent
Text could be improved	12	18%
Action could be improved	11	17%
Missing action	7	11%
Missing text	4	6%
Other	6	8%

There were 17 responses to the question: ‘Please provide details of the changes you would make to this PAP or anything else you think is important.’ Several responses were supportive but added no detail of improvements they would make. Several key themes emerged from the remaining responses, with some crossover between them.

Update to the ‘Secretary of State’s Standards of Modern Zoo Practice’ (SSSMZP)

Respondents highlighted the fact that the Zoo PAP is out of date and no longer reflects the recently updated and published ‘Secretary of State’s Standards of Modern Zoo Practice’ (2025). As a result, the whole PAP will need to be reviewed alongside the new SSSMZP document.

Key quote:

“it is out of date, for example apparently having been written…before changes to zoo governance/regulation, especially the publication in May 2025 of the ‘Standards of modern zoo practice for Great Britain.’”

Handling and disposal of materials used in animal husbandry

Some stakeholders suggested additional action on producing guidance on how to safely handle, move and dispose of waste materials, to avoid the transfer of pathogens, eggs or larvae into the wild. This included calls for guidance on the need to control the use of live food so that it cannot escape.

Key quote:

“The PAP must address the issue of the safe disposal of waste materials. This is a particular issue for reptiles and amphibians…”

Awareness and understanding

Some stakeholders reflected the widely different size, scope and purpose of different zoo and aquaria organisations. This led to comments about whether all types of zoo or aquaria are represented by the sectoral bodies, how well they are engaged with INNS messaging and how well they are complying with existing guidance, of which there is a wide variety.

Suggestions were made about improving INNS training for zoo inspectors, improving guidance for the industry, improving public awareness raising by the industry and ‘auditing‘ of zoos against the existing guidance. Some of these suggestions are already happening or outside the remit of the Zoo PAP document.

Key quote:

“A new action could be to audit zoos on how well they have implemented the measures and what their challenges have been.”

Actions which were highlighted for requiring improvement were: 6, 7, 8 and 11.

There were also comments about the annexes 2 (Agreed Zoos Guidance (on escapes etc.) for England and Wales) and 5 (UK Code of Practice for Zoos), including that these could be merged, and that annex 5 could include reference to ‘Be Plant Wise’ campaign.

Government response and next steps

We are grateful to all the individuals and organisations who responded to this consultation.

Overarching comments on the suite of PAPs, as set out above, will be addressed and as the PAPs are revised they will be made consistent with one another in structure, formatting and style. Out of date information will be replaced, and where appropriate linked to external sources to ensure information referred to in each PAP remains relevant (such as the horizon scanning list).

To address points raised around communications and awareness raising with respect to the PAPs, we will be tasking the PAP working groups to engage with the GB Invasive Non-native Species Media and Communications working group to help develop stronger communication and awareness plans for each PAP. We will also be asking the GB INNS Media and Communications working group to consider how best we can improve communications and awareness around the PAPs as a whole, including their promotion and implementation.

The UK and Devolved Governments have anonymised and summarised all the comments received on the detail of the PAPs. These anonymised, summarised results will be shared with the PAP working groups for their expert consideration. Once the working groups have looked at the feedback of this consultation, any required modifications based on the responses from the consultation will be made to each of the PAPs.

PAP working groups will be encouraged to make actions SMART where appropriate, so that actions are clear and achievable, with identified owners or delivery mechanisms, co-ordination and where possible timelines for planned progress. In addition, it will be necessary for working groups to consider what mechanism can be used to demonstrate how actions within the PAPs are progressing and highlighting successes.

Once the PAPs have been updated, they will be signed off by the working groups and then the GB INNS Programme Board before final publication, which is expected to be by the end of 2026.

Annex 1

List of all the organisations who responded

• Afonydd Cymru
• Amphibian and Reptile Conservation Trust
• Angling Scotland Ltd, Migratory Fish Committee, for Scottish Anglers National Association (game), Scottish Federation of Sea Anglers and Scottish Federation for Coarse Angling Association
• Angling Trust
• Arboricultural Association
• Bristol Veterinary School, University of Bristol
• British and Irish Association of Zoos and Aquariums
• British Association of Landscape Industries
• Broads Authority
• Buglife
• CABI
• Countryside Alliance
• Dumfries and Galloway Council
• Elwy Invasive Plants Group
• Environment Agency (Fisheries)
• Hampshire and Isle of Wight Wildlife Trust
• Hants Invasive Plants Group
• Inland Waterways Association, UK
• Institute of Fisheries Management
• International Herpetology Society
• Kernock Park Plants Ltd
• London Wildlife Trust
• Marine Biological Association
• Marine Management Organisation
• Merman Conservation Expeditions Ltd
• National Centre for Birds of Prey
• Natural England
• Natural Resources Wales
• Ornamental Aquatic Trade Association (OATA)
• Pembrokeshire Coast National Park Authority
• Portsmouth Reptile and Amphibian Society
• Responsible Reptile Keeping
• River Ely INNS Partnership Group
• Royal Horticultural Society
• Royal Yachting Association
• Scottish Animal Welfare Commission
• Scottish Canals
• Scottish Exotic Animal Rescue (SC041507)
• SEA LIFE Park
• South Devon National Landscape Estuaries Partnership
• South East Water
• South West Water
• Southern Water
• Tees Rivers Trust
• Tirweddau Cymru - Landscapes Wales
• Transport for Wales
• Tweed Forum
• Tyne Rivers Trust
• United Utilities
• Wales Plant Health Evidence and Advisory Group
• Wildlife and Countryside Link

Annex 2

Questions asked in the consultation

Introductory questions

Q1. Would you like your response to be confidential? 

• Yes
• No 

If you answered Yes to this question, please give your reason. 

Q2. What is your name?

Q3. What is your correspondence address? Please provide an email address or telephone number unless unable to. If you enter your email address then you will automatically receive an acknowledgement email when you submit your response.

Q4. Please tell us in what capacity you are responding to the consultation by selecting from the following: 

• individual
• research organisation
• sector trade body or membership organisation
• ecologist
• academic
• planning consultant
• developer or builder
• local authority
• public body
• non-governmental organisation
• landowner or occupier 
• other (please state)

Q5. If responding on behalf of an organisation, please provide the name of the organisation you are responding for.

Q6. Please indicate your specific areas of interest in responding to this consultation: 

• boating 
• angling 
• marine 
• horticulture 
• zoo 
• pets 
• botanical garden 
• aquarium 
• eNGO 
• rescue centre 
• hobbyist 
• species interest group 
• other (please specify) 

Q7. Please indicate which location your response relates to, selecting from the following:

• Great Britain 
• England
• Scotland
• Wales
• other (please state, where)

PAP questions

For each PAP the following questions were asked:

Q8. Are you content with the actions within this PAP?

• Yes
• No 

Q9. If no, what do you think could be improved? 

• missing action 
• action could be improved 
• missing text 
• text could be improved 
• other 

Please refer to Q10 to expand on any changes. 

Q10. Please provide details of the changes you would make to this PAP or anything else you think is important. 

Please refer to actions by number, and mention if it should be deleted, changed (and how so), or suggest additional actions.