Government Interpretation Of WATOK Raises Industry Concerns
The Shellfish Association of Great Britain (SAGB) has issued an information statement on crustacean welfare, as the UK government prepares to publish long-awaited guidance on how the Welfare of Animals at the Time of Killing regulations are to be applied to decapod crustaceans.
The statement comes amid growing uncertainty across the fishing industry, processing sector and hospitality trade about what practices will be deemed lawful once Defra clarifies its interpretation of existing legislation. The SAGB said it recognises that “to ensure maximum condition is maintained all shellfish need to be treated with respect throughout the supply chain, for welfare, economic and quality reasons”.
Crustaceans, including crabs and lobsters, were formally recognised as sentient animals under the Animal Welfare (Sentience) Act 2022. As a result, they now fall within the scope of the Welfare of Animals at the Time of Killing Act 2015 in England, with similarly worded regulations in Wales and Northern Ireland.
Legal Position Clear, Practical Guidance Still Absent
While the law already prohibits causing “avoidable pain, distress or suffering” during killing or restraint, the SAGB highlighted that the government has so far failed to provide practical guidance on what this means for commercial operators or consumers.
The association pointed to Defra’s Animal Welfare Strategy for England, published in December 2025, which states that the department intends to “publish guidance on which methods of killing decapods are compatible with the existing welfare at time of killing legal requirements, including by clarifying that live boiling is not an acceptable killing method”.
The SAGB noted that until this guidance is issued, uncertainty remains across the supply chain, particularly for smaller operators.
Likely Scope Of Defra Guidance Under Scrutiny
Although Defra has not confirmed the final content of the guidance, the SAGB said it expects conscious boiling, freezing, chilling or ice baths prior to cooking to be ruled incompatible with WATOK.
The association believes the only acceptable methods likely to be recommended will be electric stunning to render animals insensible before cooking, or mechanical killing prior to cooking. This would include double spiking of crabs and full-length body splitting of lobster-type crustaceans, including langoustines and crawfish.
The SAGB also expects the guidance to apply only to onshore dispatch of larger crustaceans, rather than to prawns or shrimps.
International Context Highlights UK Divergence
The statement placed the UK approach in an international context, noting that only a small number of countries have formal crustacean welfare regulations. These include nationwide controls in New Zealand, Switzerland, Austria and Norway, alongside limited regional rules in parts of Italy, Australia and Canada.
By contrast, the SAGB said neither the United States nor the European Union recognises crustaceans as animals under their animal welfare legislation, meaning there are no equivalent controls on handling, dispatch or killing in most EU states.
Impact Expected On Small Businesses And Hospitality
The SAGB stressed that most large UK processors already use electronic stunning equipment prior to cooking and processing, and that major retailers have not sold live crustaceans for many years.
As a result, the association warned that the primary impact of Defra’s guidance is likely to fall on small-scale fishmongers and the hospitality and catering sector, rather than on industrial processors.
The SAGB said it had been heavily involved in engagement with Defra during the development of the guidance, but expressed concern that its core objectives were set in advance. It also said it had pushed Defra to carry out an impact assessment on the financial consequences for the fishing industry, which has been completed on a de minimis basis but has yet to be published.
Support And Equipment Discounts Offered
In its statement, the SAGB confirmed it remains available to provide advice, help and support to members affected by the changes. It also said it has negotiated significant discounts on stunning equipment for its members, anticipating increased demand once the guidance is issued.
The association said the information statement will be updated once Defra publishes its final guidance, leaving the fishing community waiting to see how strictly existing law will be enforced in practice.
