Avian Flu 2026: EU restrictions for poultry producers and what they must do now

Key data

If you operate a poultry farm, market live birds, poultry products or eggs within the EU, this decision affects you from 17 September 2026. Implementing Decision (EU) 2026/2109 amends the annex to Decision 2023/2447 and redefines which areas of European territory are subject to emergency measures for highly pathogenic avian influenza (HPAI) outbreaks.

The change is significant: protection, surveillance and restriction zones are updated to reflect the current epidemiological situation. This means that facilities that were not previously affected may now be, and vice versa. The first action is to verify whether your location is listed in the revised annex.

What does this regulation establish?

Decision 2026/2109 amends the annex to Implementing Decision (EU) 2023/2447, which is the reference regulatory framework for emergency measures against highly pathogenic avian influenza in the EU. The amendment updates three types of geographical zones:

• Protection zones: areas immediately surrounding confirmed outbreaks, with the strictest restrictions.
• Surveillance zones: outer perimeter to protection zones, with reinforced movement controls.
• Additional restriction zones: broader areas subject to specific preventive measures.

Within these zones, operators must comply with restrictions on:

• Movement of live birds between farms and outside the zones.
• Marketing and transport of poultry products (poultry meat, offal, by-products).
• Movement and marketing of eggs for consumption and incubation.

The regulation enters into force with retroactive effect on 17 September 2026, one day before its publication in the EU Official Journal, underscoring the urgency of the epidemiological situation.

Economic and operational impact

The consequences for affected operators are direct and can be immediate:

• Paralysis of movements: restrictions on live birds and products can disrupt the supply chain immediately, affecting delivery contracts and commercial commitments already signed.
• Loss of access to export markets: operators in restricted zones may see their exports blocked both within the EU and to third countries that recognize EU zones as a sanitary reference.
• Compliance costs: enhanced biosecurity, additional document management, possible diagnostic tests and coordination with veterinary authorities generate direct operational costs.
• Risk of sanctions: non-compliance with movement restrictions can result in administrative sanctions and suspension of activity authorizations.

For operators outside affected zones, the regulation is also relevant: they must verify the origin of supplies they receive and ensure that their suppliers are not located in restricted zones, to avoid liability for receipt of goods with prohibited movement.

Who does it affect?

• Poultry producers (chicken farms, turkeys, ducks, laying hens) whose facilities are located within the updated protection, surveillance or restriction zones.
• Poultry slaughterhouse operators that receive birds from affected areas or are located within them.
• Marketers and distributors of poultry products and eggs in restricted zones.
• Transport and logistics companies that operate routes that cross or have origin/destination in restriction zones.
• Importers and exporters of live birds and poultry products that operate with affected Member States.
• Veterinary authorities and animal health services of Member States, responsible for implementing and monitoring measures.
• Spanish operators: Spain could be affected if any of its regions are included in the updated annex. It is essential to verify the annex of Decision 2026/2109 to confirm whether there are delimited Spanish zones.

Practical example

A broiler chicken farm located in a region that has been included in the surveillance zone of the updated annex receives notification from veterinary authorities. From that moment on:

• It cannot move live birds outside the zone without express authorization from the competent authority.
• Eggs for incubation are subject to movement restrictions, which may affect contracts with incubators outside the zone.
• It must strengthen biosecurity measures and record all movements of personnel and vehicles on the farm.
• If it violates movement restrictions and transports birds without authorization, it is exposed to administrative sanctions and possible suspension of its activity authorization.

If that same farm has supply contracts with a slaughterhouse located outside the restricted zone, it will need to renegotiate timelines or seek alternative solutions within the zone until restrictions are lifted by authorities.

What should companies do now?

1. Consult the updated annex of Decision 2026/2109 in the EU Official Journal to verify whether own facilities or key suppliers fall within any of the delimited zones (protection, surveillance or restriction).
2. Contact the competent veterinary authority of the corresponding autonomous community or Member State to receive specific instructions on applicable restrictions and procedures for authorizing movements.
3. Review current supply and delivery contracts to identify possible breaches arising from movement restrictions and activate force majeure clauses if applicable.
4. Strengthen biosecurity protocols on farms, regardless of whether inside or outside affected zones, as a preventive measure in light of outbreak evolution.
5. Verify the origin of supplies received to ensure that suppliers are not located in zones with active movement restrictions, thus avoiding liability for receipt of goods with unauthorized transport.
6. Document all actions taken in compliance with emergency measures, as documentary traceability is key in case of inspection or claim.

Official source

Consult full regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602109