The straw man of offshoring

I often hear glib statements claiming that tighter regulation of animal use—or a stronger push toward Replacement and new approach methodologies (NAMs)—will drive industry and academia to move their research overseas to countries with lower animal welfare standards. Frankly, this assertion sends my blood pressure soaring. 

For example, in a recent Westminster Hall debate on animal research license non-compliance cases, Sarah Hall, Minister of State for the Home Office, said  

“I am sure that my hon. Friend understands that if we are disproportionate [in our response to regulatory non-compliance] —if that is a risk—then work gets offshored and goes elsewhere, where the systems are not anywhere near as powerful as they are in this country.”

To be clear, a number of these instances of non-compliance resulted in horrendous suffering and, in several cases, death for the animals concerned. This is not about forgetting to file a piece of paper. I have heard this offshoring threat being invoked by a number of scientists, and I heard it restated again at the recent Royal Society conference in London. Clearly, if we say something often enough, people will believe it.

But let’s have a look at the evidence:

Where is non-compliance happening?

If we are reflecting on why we don’t implement harsher penalties for cases of animal license welfare breaches it is important to understand where these are happening. ASRU annual reports summarise total noncompliance cases (146 cases across 45 establishments in 2024) but do not break down results by establishment type (university vs commercial), largely due to confidentiality provisions such as our old friend, ASPA Section 24.  

However, older reports that did include establishment type categories showed that most cases of non-compliance occurred in universities (85% in 2018, the last year for which we have these data). Perhaps this is not surprising, as we know universities also conduct the lion’s share of animal research. Additionally, many cases of non-compliance come to light via self-report, rather than via inspection. It is possible that there are sector-based differences in the likelihood of self-reporting, but there is no evidence for this. 

Industry

So, is there any evidence that, even though it constitutes a smaller number of cases, industry would move its research operations overseas if UK regulatory penalties were more severe? In short, there are no publicly available robust academic studies or government reports showing pharmaceutical or life sciences firms relocating animal work abroad because UK regulators were more punitive on licence noncompliance. None.  

Obviously, a lack of evidence of a phenomenon doesn’t mean it doesn’t exist, just that the research hasn’t been done. However, in the absence of robust analysis, it’s important to note that this huge risk that is so frequently mentioned and is the reason why we should avoid harshly punishing those who cause animals additional unnecessary suffering (which would incidentally often be a criminal offence under the Animal Welfare Act 2006 in other settings), is solely based on anecdotes and opinions.  

Parliamentary inquiries have recorded such views from scientific witnesses—but noted they were anecdotal and not backed by hard data. Remember, there are many reasons why those involved would not welcome stricter regulation and might move operations abroad. My conversations indicate that tax and labour laws are much more likely contributors to siting decisions than the ASPA regulatory framework. 

Why “they’ll just go abroad” doesn’t hold in basic research

In the university context, the argument that stricter UK welfare expectations will push work overseas ignores how ethical governance actually functions. Every UK project involving regulated animal procedures must pass through an Animal Welfare and Ethical Review Body (AWERB) before licensing. AWERBs scrutinise ethical justification, the harm–benefit balance, and adherence to the 3Rs (Replacement, Reduction, Refinement). 

Crucially, if any part of a project is proposed overseas, the work is still expected to meet UK welfare standards under funder and sector guidance (e.g., NC3Rs, UKRI). Researchers and local ethics committees must satisfy themselves that standards abroad do not fall below those expected under UK law and best practice. Moving a study out of the UK does not remove it from scrutiny; funders and institutions can impose safeguards and contractual oversight to uphold UK-level welfare standards. 

Even where there are reasons to collaborate internationally (e.g., access to a specialised model), AWERB review would require researchers to justify why UK-based work isn’t feasible and to show equivalent welfare safeguards (housing, veterinary care, humane endpoints, training, oversight, reporting). Without such justification, projects are unlikely to be supported by AWERB, and Home Office licensing cannot proceed.  

Given that most incidences of non-compliance are self-reported, there is a risk that establishments may self-report less often if penalties were to increase, but with an effective inspection system and an ethical framework where offshoring resulting in lower welfare standards is effectively prohibited, this is irrelevant and should certainly not outweigh the welfare gains and reduced suffering that harsher penalties could provide.  

Do funders care where work is done?

Most UK funders have policies and contractual conditions that prevent work being done overseas under lower welfare standards.  UKRI requires animal research it funds to meet ‘excellent welfare standards’ and will only fund such research if there is no scientifically acceptable non-animal alternative. This applies inside and outside the UK: welfare standards must be no less stringent than UK requirements. Where differences exist, they must be identified early and may require prior approval. The MRC likewise requires best practice in husbandry and welfare and adds additional overseas due diligence questions that local ethics committees must address before submission.  

Put simply: under UKRI/MRC funding rules, you cannot legitimately conduct animal work abroad to take advantage of lower welfare standards.  

Bottom line

Invoking “they’ll just go abroad” as a reason to not enforce stronger welfare standards on UK institutions is a classic straw man argument and fundamentally misrepresents how animal research is governed. Unless data show otherwise, tightening alignment with Replacement and NAMs and enforcing high welfare standards are not pathways to offshoring; they are hallmarks of a responsible research system.  

Personally, given the overall goals of the Replacing Animals in Science strategy, I can see no reason why we do not more frequently remove licenses from individuals or establishments where welfare standards have been seriously breached. I think causing unnecessary and avoidable suffering to the animals we use in labs should warrant a bit more than a stern word. 

But of course, the best welfare is for animals not to be in labs in the first place.