EU updates international trade rules on vaccination against highly pathogenic avian influenza

11/ 08/ 2026

The European Union continues to improve its animal health legislation, adapting it to current epizootic challenges. The new provisions on vaccination against highly pathogenic avian influenza (HPAI) introduce a more flexible approach to international trade and could provide an important reference point for further updates to Ukrainian legislation. On 23 July this year, the previously adopted Delegated Regulation (EU) 2026/1052 was published. The document will enter into force on 12 August and represents a logical continuation of Delegated Regulation (EU) 2023/361. The Regulation amends Delegated Regulation (EU) 2020/692, which establishes animal health requirements for the entry into the EU of live animals, germinal products and products of animal origin. In particular, it clarifies the requirements for HPAI vaccination programmes that third countries must implement when exporting to the European Union. Unlike previous approaches, current EU legislation does not regard vaccination as an automatic barrier to international trade. Under the updated rules, vaccination must form part of an official programme providing for an appropriate risk assessment, epizootic surveillance, laboratory controls, traceability and other biosecurity measures, as well as compliance with the requirements of Delegated Regulation (EU) 2023/361. In addition, vaccination programmes must ensure effective differentiation between vaccinated and infected birds in accordance with the DIVA (Differentiating Infected from Vaccinated Animals) principles. In practice, the EU has moved from the question of whether vaccination should be permitted to the question of how vaccination should be organised to ensure an adequate level of biosecurity without creating unjustified barriers to trade. This approach has already been put into practice in certain EU countries. In particular, France is implementing a national vaccination programme against highly pathogenic avian influenza, combining vaccination with epizootic surveillance, laboratory controls and a traceability system in line with current recommendations from the European Commission, EFSA and WOAH. The need to review approaches to HPAI prevention is also driven by the epizootic situation in Europe. According to the latest EFSA report, during spring 2026 alone, 186 outbreaks of highly pathogenic avian influenza among poultry and more than 760 cases among wild birds were reported in EU countries. Poland, which borders Ukraine, remains one of the most affected countries in Europe, highlighting the need for continued preparedness for possible virus introduction. In light of these developments, the European Business Association considers it appropriate to launch an expert discussion on updating the national regulatory framework for the prevention and control of avian influenza in line with current EU legislation, WOAH recommendations and EFSA scientific findings. In particular, it would be advisable to: review the current Instruction on the Prevention and Elimination of Avian Influenza; assess current approaches to vaccination; ensure the possibility of the advance assessment and state registration of veterinary immunological products. Timely updates to the regulatory framework and the harmonisation of Ukrainian approaches with European practices will contribute to enhancing biosecurity, protecting the poultry sector and preserving the industrys export potential.

On 23 July this year, the previously adopted Delegated Regulation (EU) 2026/1052 was published. The document will enter into force on 12 August and represents a logical continuation of Delegated Regulation (EU) 2023/361.

The Regulation amends Delegated Regulation (EU) 2020/692, which establishes animal health requirements for the entry into the EU of live animals, germinal products and products of animal origin. In particular, it clarifies the requirements for HPAI vaccination programmes that third countries must implement when exporting to the European Union.

Unlike previous approaches, current EU legislation does not regard vaccination as an automatic barrier to international trade. Under the updated rules, vaccination must form part of an official programme providing for an appropriate risk assessment, epizootic surveillance, laboratory controls, traceability and other biosecurity measures, as well as compliance with the requirements of Delegated Regulation (EU) 2023/361. In addition, vaccination programmes must ensure effective differentiation between vaccinated and infected birds in accordance with the DIVA (Differentiating Infected from Vaccinated Animals) principles.

In practice, the EU has moved from the question of whether vaccination should be permitted to the question of how vaccination should be organised to ensure an adequate level of biosecurity without creating unjustified barriers to trade.

This approach has already been put into practice in certain EU countries. In particular, France is implementing a national vaccination programme against highly pathogenic avian influenza, combining vaccination with epizootic surveillance, laboratory controls and a traceability system in line with current recommendations from the European Commission, EFSA and WOAH.

The need to review approaches to HPAI prevention is also driven by the epizootic situation in Europe. According to the latest EFSA report, during spring 2026 alone, 186 outbreaks of highly pathogenic avian influenza among poultry and more than 760 cases among wild birds were reported in EU countries. Poland, which borders Ukraine, remains one of the most affected countries in Europe, highlighting the need for continued preparedness for possible virus introduction.

In light of these developments, the European Business Association considers it appropriate to launch an expert discussion on updating the national regulatory framework for the prevention and control of avian influenza in line with current EU legislation, WOAH recommendations and EFSA scientific findings. In particular, it would be advisable to:

review the current Instruction on the Prevention and Elimination of Avian Influenza;
assess current approaches to vaccination;
ensure the possibility of the advance assessment and state registration of veterinary immunological products.

Timely updates to the regulatory framework and the harmonisation of Ukrainian approaches with European practices will contribute to enhancing biosecurity, protecting the poultry sector and preserving the industry’s export potential.