If you’ve recently been researching how to move your pet into or through the European Union, you’ve probably noticed something doesn’t quite add up.
Many pet owners, veterinarians, and pet relocation professionals began hearing about significant changes to EU pet health certificates in the spring of 2026. Naturally, we did what anyone would do — we went looking for the legislation itself. The regulation behind these changes is Commission Delegated Regulation (EU) 2026/131 of 20 January 2026, which supplements Regulation (EU) 2016/429 and sets the animal health requirements for non-commercial movement of pet dogs, cats, and ferrets into the EU. It applies from 22 April 2026, and its new certificate format becomes mandatory for non-commercial travel from 1 October 2026 (commercial-movement certificates follow a separate schedule under a related regulation, EU 2026/848, transitioning from 17 October 2026). Like many others in the industry, we read it carefully. Then we read it again.
And if you decide to read it yourself, you may come away with the same question we did: where exactly are the new operational requirements airlines are enforcing actually coming from? Because while the legislation updates the legal framework for pet travel, it doesn’t plainly explain many of the practical changes airlines and border authorities have started applying. That’s what makes this situation so unusual.
What We’re Seeing in Practice
The first reports we heard came from Lufthansa. Shortly afterward, similar requirements began appearing for pets entering the European Union through Germany and the Netherlands, particularly via Frankfurt and Amsterdam, including shipments handled by KLM. To date, we haven’t found an official explanation from the European Commission, Germany, the Netherlands, Lufthansa, or KLM that clearly connects these operational requirements to specific wording in Regulation (EU) 2026/131. What we do know is that the practical reality of moving pets has changed.
The Biggest Change
For years, the distinction between a commercial and non-commercial EU health certificate has depended, per the European Commission’s own guidance, on whether the owner travels within five days of the pet’s arrival — either before or after, with a written declaration attached to the certificate confirming it. That’s the interpretation most veterinarians, pet shippers, and government agencies have worked with.
Today, at least for pets traveling from the United States through Germany or the Netherlands, that’s no longer the interpretation we’re consistently seeing applied. Instead, the practical guidance has become much simpler: if the pet owner isn’t traveling on the same flight as the pet, expect to use a commercial health certificate. Could there be exceptions? Absolutely. Could future guidance clarify or even change this interpretation? Certainly. But based on the combined experience of many IPATA pet agents, this approach has consistently resulted in the smoothest outcomes for pets traveling through these routes.
How We Arrived at This Conclusion
One question we’ve been asked repeatedly is: if the legislation doesn’t clearly say this, why is everyone now using commercial health certificates? The answer is the combined experience of many IPATA pet agents. This wasn’t a conclusion reached after reading a single paragraph of Regulation (EU) 2026/131 — it was reached after observing what actually happened to pets moving through the system.
In the months following the new legislation, IPATA pet agents across the industry began reporting similar experiences. Some pets were refused at booking because the paperwork didn’t match the airline’s interpretation of the requirements. Others experienced delays or were held at transit points — particularly in Frankfurt — even though the owner was traveling within the traditional five-day window that had historically qualified for a non-commercial health certificate. As these experiences accumulated across multiple countries, airlines, and relocation companies, a consistent pattern emerged: shipments that moved through Germany and the Netherlands without issue were those prepared with a commercial health certificate whenever the owner wasn’t traveling on the same flight. That’s why this recommendation has become the current best practice.
This wasn’t about using clients’ pets as test cases — quite the opposite. Every IPATA pet agent wants pets to arrive safely, on time, and without unnecessary stress. Unfortunately, whenever regulations are introduced without clear operational guidance, there’s often a period where airlines, government agencies, veterinarians, and pet relocation professionals are all working to understand how those regulations will actually be applied. Some pets were undoubtedly affected during that transition, not because anyone wanted that, but because the practical interpretation of the rules hadn’t yet settled. Today, the industry has a much clearer understanding of what works in practice. While we still hope for additional clarification from the European authorities, our recommendations are based not only on the published legislation but also on the collective experience of IPATA pet agents, veterinarians, airlines, and successful pet movements over the past several months.
Why This Matters
Using a commercial health certificate isn’t simply a matter of checking a different box. Commercial health certificates operate under a much tighter timeline than non-commercial certificates, and the endorsement window leaves far less room for delays, appointment availability, or unexpected paperwork issues. At the same time, because many more shipments are now moving under commercial certificates, USDA endorsement offices are handling increased demand. Planning ahead has become more important than ever.
One More Example
Another area where we’ve seen a disconnect between published guidance and operational reality involves pets simply transiting through the European Union. The USDA currently explains that pets merely transiting the EU on their way to a non-EU destination generally do not require an EU transit health certificate, which may accurately reflect USDA’s interpretation of the regulations. However, we’ve continued to see airlines request transit documentation for these same journeys. Whether that’s due to airline policy, local interpretation, or operational procedure, the practical outcome for the pet owner is the same: a shipment can still encounter delays if those expectations aren’t met. The published legislation, government guidance, airline requirements, and border procedures don’t always align perfectly.
Before You Decide Which Certificate to Use
Every pet’s journey is different. The airline matters. The transit airport matters. The destination country matters. Whether you’re traveling on the same flight as your pet matters. And sometimes the practical application of the rules matters just as much as the regulations themselves. That’s why we don’t recommend relying solely on this article — or any article on the internet — to decide which health certificate to prepare. Instead, discuss your specific itinerary with an experienced pet relocation agent, who can evaluate your travel plans and explain which documentation is appropriate for your particular journey based not only on the written regulations but also on how those regulations are currently being interpreted by airlines and border authorities. Our goal isn’t to replace professional advice — it’s to explain why so many pet owners have found themselves confused by the changes introduced during 2026.
Final Thoughts
If there’s one takeaway from this article, it’s this: read the legislation, read the official guidance, and ask questions — but before your pet travels, speak with someone who works with these requirements every day. The law is important. The guidance is important. But when your pet is standing at the airline counter, it’s the documentation accepted by the airline and the authorities handling your shipment that determines whether the journey proceeds smoothly. Right now, that’s where the real story is.
Related reading: Why You Need a USDA Accredited Vet for International Pet Travel, Beyond the Health Certificate: Why Pet Agents Matter
Planning a move with your pet? Get a free quote from Transcon Pet Movers and we will check the documentation path against your dates, your routing, and who is flying with your pet.