In brief

  • The map of restrictions in Greece has doubled in two months. The new annex lists 66 outbreaks of foot and mouth disease, each with its protection zone and its surveillance zone, against 30 outbreaks in the annex of 23 July 2026 and 17 in the initial version, of 1 April 2026. All of them are in the same regional unit, Lesbos, and the date until which the measures apply moves from 1 October to 31 December 2026.
  • The decision has a single addressee, Greece, and does not apply to the other Member States. Article 2 says that the decision is addressed to the Hellenic Republic, and the title states that only the Greek text is authentic. That is why it has no article on entry into force: it takes effect on notification to Greece, not through the usual period of 20 days from publication.
  • For Romania the effect is indirect and narrow, and this article does not inflate it. The name of the country appears nowhere in the act, Romania has no outbreak of foot and mouth disease and no Romanian area falls within any restricted zone. What changes for Romanian farmers, hauliers and importers concerns only the goods and the animals that leave Lesbos or pass through it.
Act: Commission Implementing Decision (EU) 2026/2148 of 21 September 2026 amending Implementing Decision (EU) 2026/820 concerning certain emergency measures relating to foot and mouth disease in Greece (notified under document C(2026) 6793) (Only the Greek text is authentic) (Text with EEA relevance)
Published: Official Journal of the European Union, L series, 2026/2148 of 23 September 2026
Takes effect: on notification to the Hellenic Republic, under Article 297(2) of the Treaty on the Functioning of the European Union; the date of notification is not published, so the public marker remains 23 September 2026, the day it appeared in the Official Journal of the European Union

The European Commission has rewritten for the third time the list of zones in which Greece must keep foot and mouth disease under control, a viral disease that strikes cattle, sheep, goats, pigs and the other even-toed ungulates. It is the same mechanism by which the Union draws the map of other serious diseases, for instance the one that keeps the whole of Romania in the harshest restricted zone for African swine fever. The difference, and it matters a great deal, is that the act of 23 September 2026 is a decision addressed to a single State, not a regulation applicable across the Union.

Commission Implementing Decision (EU) 2026/2148 was adopted in Brussels on 21 September 2026 and published on 23 September 2026, over 16 pages. It has a single substantive article: the annex to Implementing Decision (EU) 2026/820 is replaced in full by the new annex. Nothing changes in the rules of conduct, only the list of areas and the dates until which the measures stay in place.

The count, made row by row in the annex, shows 66 outbreaks, each identified by a reference number from the European animal disease notification system, from GR-FMD-2026-00108 through to GR-FMD-2026-00196. Each outbreak has a protection zone, that is the circle with a radius of 3 kilometres around the affected establishment, and a surveillance zone, the circle with a radius of 10 kilometres from which the protection zone is subtracted. That gives 66 protection zones and 66 surveillance zones. On top of them comes a single further restricted zone: „the rest of the regional unit of Lesbos”, that is everything left of the administrative subdivision that takes in the island in the north of the Aegean Sea. All 133 areas carry the same end date, 31 December 2026.

A single regional unit is affected. In Greece, the regional unit is the second-level administrative subdivision, the one that comes closest to the Romanian county. The rest of the country does not appear in the annex, and mainland Greece is not touched by any of the 133 areas.

What the act calls emergency measures are the measures the Commission may take under Article 259(1) of Regulation (EU) 2016/429, the European animal health law. They come into play when an outbreak of a serious disease appears in a Member State, and the Commission either approves, or replaces, or supplements what the national authority has already done, precisely so that trade across the Union does not seize up. They are not permanent rules: they are adopted quickly, on the opinion of the Standing Committee on Plants, Animals, Food and Feed, and they are rewritten whenever the situation on the ground changes.

What it changes in practice

The new act contains no rule of conduct. The rules sit in Delegated Regulation (EU) 2020/687, which supplements the animal health law, and the decision only says where and until when they apply. Article 21 of the delegated regulation obliges the competent authority to establish at once, around the affected establishment, a restricted zone made up of a protection zone, a surveillance zone and, where necessary, further restricted zones. The radii are nobody’s choice: Annex V to the delegated regulation fixes, for foot and mouth disease, 3 kilometres for the protection zone and 10 kilometres for the surveillance zone. Those exact figures appear in each of the 66 rows of the annex.

Inside these zones the prohibition in Article 27 operates, read together with the table in Annex VI: movements of kept animals of the species concerned by foot and mouth disease, out of establishments located in the restricted zone, are prohibited. Products obtained from those animals fall under the same prohibition, with the exceptions in Annex VII, which lists the products regarded as safe in relation to the disease. On top of that, Article 2 of Implementing Decision (EU) 2026/820 adds a prohibition of its own, the one that matters most to a trading partner outside Greece: animals of the species concerned cannot leave the further restricted zone for a destination outside its outer perimeter. Since the further restricted zone covers the rest of the regional unit, the practical result is that no animal of the species concerned can leave Lesbos, whatever part of the island it is in.

The temporal part is what the act actually changes. The delegated regulation provides for minimum durations only. Annex X gives the protection zone for foot and mouth disease 15 days, plus another 15 days during which the lighter measures, those of surveillance, apply in the same zone. Annex XI gives the surveillance zone 30 days. The periods do not run from confirmation of the outbreak: Article 39(1) allows the measures to be lifted only once the minimum period has passed and only where the affected establishment has undergone preliminary cleaning and disinfection and the animals in all the establishments in the protection zone have passed clinical examinations with favourable results. For the surveillance zone, Article 55 additionally requires visits with favourable results by official veterinarians to a representative number of establishments.

On top of these minimums, the decision sets a floor of its own: the measures apply „at least until” the dates in the annex. With 31 December 2026 entered in all 67 date entries, no zone on Lesbos can be lifted earlier, however good the results from one particular establishment may look. From the adoption of the decision to that date there are 101 days, and from publication, 99.

For Romania, the measure of the effect can honestly be written in a few lines. The act does not name the country anywhere, Romania has no outbreak of foot and mouth disease and no Romanian area falls within any zone. What changes concerns only the relationship with Lesbos: a Romanian importer cannot receive live cattle, sheep, goats or pigs from there until at least 31 December 2026, and products obtained from animals in the protection and surveillance zones circulate only within the limits of the derogations in the delegated regulation. A Romanian haulier with runs to the island falls under the rules on cleaning and disinfection of means of transport in the same regulation. The National Sanitary Veterinary and Food Safety Authority (ANSVSA) carries out the checks at destination, as with any consignment coming from a restricted zone.

There is one further link, less visible but real for a State that exports live animals. Recital (6) of the decision says that the measures are necessary also in order to prevent unnecessary disturbance of trade within the Union and to avoid unjustified barriers being imposed by third countries. Translated into practice: the strict delimitation of the zones is precisely the instrument that keeps the Greek outbreak separated from the rest of the European market. When the delimitation holds, a buyer outside the Union has no reason to close the border to Romanian animals. When it does not hold, the first to pay are the exporters in the States free of the disease.

Finally, Romania takes part in this act even though it is not its addressee. The decision was adopted on the opinion of the Standing Committee on Plants, Animals, Food and Feed, a committee made up of the representatives of the Member States, and Romania has a seat in it. The act is imposed on Greece, but it is decided jointly.

What has changed compared with the previous situation

The comparison is with the annex that has been replaced, the one put into Implementing Decision (EU) 2026/820 by Implementing Decision (EU) 2026/1839, adopted on 23 July 2026 and published on 28 July 2026. There were 30 outbreaks there, with reference numbers from GR-FMD-2026-00064 through to GR-FMD-2026-00139, so 30 protection zones and 30 surveillance zones, plus the same further restricted zone. The date until which the measures applied was 1 October 2026, a single date for all of them.

Counting by reference numbers shows what happened between the two texts. Of the 30 outbreaks listed in July, only 10 still appear now: 00108, 00127, 00130, 00132, 00133, 00135, 00136, 00137, 00138 and 00139. The other 20 have left the annex, a sign that the establishments concerned have gone through the preliminary cleaning and disinfection that recital (4) speaks of. In their place, 56 new outbreaks have come in, with numbers from 00140 upwards. The balance: 66 outbreaks listed, that is more than twice as many as in July, arrived at through 56 entries and 20 departures.

The second indicator is the highest reference number. In April 2026 it had reached 00017, in July 00139, and now 00196. Between 23 July and 21 September, that is in 60 days, the Greek system has allocated at least 57 more outbreak numbers for foot and mouth disease, almost one a day.

The third is the time horizon. The initial version of the annex, of 1 April 2026, kept the measures until 15 May 2026. The July annex took them to 1 October 2026. The present one takes them to 31 December 2026, 91 days further than the previous one and 230 days further than the initial version provided. Counted from the first act in this episode, Implementing Decision (EU) 2026/732 of 20 March 2026, the restrictions on Lesbos will have lasted at least 286 days.

Small things have changed too, and they say something about the way the annex is written. The April 2026 version had no „Administrative division” column; it appeared only in July, with the word „Lesbos” on every row. The further restricted zone was described in April, in the Romanian edition, in Romanian, „Restul teritoriului unității regionale Lesbos”, and from July on it is left in English, like the descriptions of the 132 circles. The end date was written until now with the year in four digits, „15.5.2026” and „1.10.2026”. In the new text, the 66 entries in the first table read „31.12.26”, while the 67th, that of the further restricted zone, reads „31.12.2026”.

One thing has not changed at all: the legal framework. Regulation (EU) 2016/429 and Delegated Regulation (EU) 2020/687 remain untouched, and Articles 1 and 2 of Implementing Decision (EU) 2026/820, which contain Greece’s actual obligations, are not amended. Only the annex changes, that is where and until when.

Advantages and disadvantages

What it improves

  • The restrictions stay shut inside a single island regional unit, instead of being extended to the whole country. That is precisely the mechanism that protects live animal exporters in the other Member States, Romania included.
  • The departure of 20 outbreaks from the annex shows that the mechanism works both ways: an establishment that has been through cleaning, disinfection and checks leaves the list, it does not stay there out of inertia.
  • The text is short and clear in its operative part: one article replacing the annex, one article naming the addressee. The reader does not have to reassemble the rule out of ten point-by-point amendments.
  • The reference numbers of the outbreaks are published, so the course of the epidemic can be followed from one act to the next, with no need for press releases.
  • The decision was adopted two months after the previous one and published two days after adoption, a pace that keeps the text close to the reality on the ground.

What remains a problem

  • All 133 areas get the same end date, even though recital (4) says that the duration is adapted according to the dates of cleaning and disinfection of each affected establishment. That individual adaptation is nowhere to be seen in the annex.
  • The areas are described only by geographical coordinates, in English, in a text published in Romanian. A farmer or a haulier cannot find out from the act which zone he is in, without a map the act does not provide.
  • The act does not give the date of notification, even though the taking of effect hangs on it. The reader has the date of adoption and the date of publication, but not the one that counts in law.
  • The annex is rewritten in full at every amendment, with no table of differences. To find out what has changed, two lists of dozens of rows of coordinates have to be compared.
  • In the same annex, 66 entries write the year in two digits and the 67th in four, which makes an automatic check of the text needlessly hard.

Practical advice

  1. If you bring live animals from Greece, check the regional unit of origin before signing the contract, not at loading. No animal of the species concerned can leave Lesbos until at least 31 December 2026, and the prohibition comes from Article 2 of Implementing Decision (EU) 2026/820, not from the transport rules.
  2. For products of animal origin, read Annex VII to Delegated Regulation (EU) 2020/687 before assuming that the goods are blocked. That is where the products regarded as safe in relation to the disease are listed, and they do not fall under the general prohibition.
  3. Do not confuse the protection zone with the surveillance zone. The first is the 3-kilometre circle and has the strictest regime; the second is the ring out to 10 kilometres, with lighter obligations. A document that uses them as synonyms is a document you cannot rely on.
  4. If you have regular runs to the island, put the cleaning and disinfection of the vehicle on the drivers’ checklist, with written proof. The check at destination is made on documents, not on statements.
  5. Follow the L series of the Official Journal of the European Union for the acts amending Implementing Decision (EU) 2026/820. From March 2026 until now there have been at least five texts in this chain, and the end date has moved every time.
  6. Report to the county sanitary veterinary and food safety directorate any suspect consignment coming from the affected area, even if the documents look in order. European prohibitions are applied through the national authority, and that authority acts on a report, not of its own motion.
  7. Do not read conclusions about the situation in Romania out of this act. The act concerns Greece exclusively, and the health status of Romanian herds is to be followed from the notices of the National Sanitary Veterinary and Food Safety Authority, not from the annex to a decision addressed to another State.

Frequently asked questions

What is foot and mouth disease and what does it strike?
It is an infectious viral disease affecting animals of the orders Artiodactyla and Proboscidea, that is cattle, sheep, goats, pigs, deer and, among exotic animals, elephants. It is not a human disease, but it spreads very fast between animals and stops consignments moving and exports going out, which is where the heavy losses for farmers come from.
Does Romania have any restricted zone because of this act?
No. The name of Romania appears nowhere in the decision, and all 133 areas in the annex are in the regional unit of Lesbos, in Greece. Romania has no outbreak of foot and mouth disease and does not appear in any of the acts in this chain, from Implementing Decision (EU) 2026/732 of March 2026 onwards.
Why does the act have no article on entry into force?
Because it is a decision with an addressee, not a regulation. Under the third subparagraph of Article 297(2) of the Treaty on the Functioning of the European Union, decisions addressed to an addressee are notified to that addressee and take effect on notification. The usual period of 20 days from publication applies to regulations and to decisions with no addressee indicated, not to an act of this kind.
What does it mean that only the Greek text is authentic?
That the version legally binding on the addressee is the Greek one, because the act is addressed to Greece and is notified to it in its own language. The Romanian version appears in the Official Journal of the European Union and is official publication, but if there were a difference between the two wordings, the Greek one would decide. With a regulation the position is different: there all the language versions are equally authentic.
How many zones are there, in fact, and until when do they apply?
66 protection zones, circles with a radius of 3 kilometres, 66 surveillance zones, circles with a radius of 10 kilometres less the protection zone, and one further restricted zone covering the rest of the regional unit of Lesbos. All of them carry the same date, 31 December 2026, and the formula in the act is „at least until”, so lifting them earlier is not possible.
Can I bring meat or milk from Greece?
From outside the restricted zones, yes, with no bearing from this decision. From the protection and surveillance zones on Lesbos, only if the product falls within the categories regarded as safe in relation to the disease, listed in Annex VII to Delegated Regulation (EU) 2020/687, or if it benefits from a derogation granted by the Greek authority. The check is made on the health certificate accompanying the consignment.
How long should a protection zone last, under the general rule?
Annex X to Delegated Regulation (EU) 2020/687 provides for foot and mouth disease a minimum of 15 days, followed by another 15 days during which the surveillance measures apply in the same zone. The surveillance zone has a minimum of 30 days, under Annex XI. The periods run, however, only after the preliminary cleaning and disinfection of the affected establishment and after clinical examinations with favourable results, and a Commission decision may set, as here, much longer periods.

Editorial analysis

The annex reads like a list of 66 circles scattered over an island. Drawn out, they look entirely different. We took the coordinates of the 66 centres and measured them: they all fit inside a rectangle of roughly 25 by 18 kilometres, and the two furthest outbreaks, 00139 and 00191, are 29.5 kilometres from each other. Out of the 2,145 possible pairs, 738 are pairs of protection zones that overlap, that is have their centres less than 6 kilometres apart. The geometric consequence is that the 66 circles of 3 kilometres do not form 66 separate patches, but only two blocks stuck together: one of 62 outbreaks and one of 4, separated by 9.2 kilometres, a distance the circles of 10 kilometres cover anyway. The area covered by the block of protection zones is around 410 square kilometres, against 1,866 if the circles had been isolated. In other words, what the annex presents as a collection of scattered incidents is, on the ground, a single compact zone. That shape is not visible if you read the act from beginning to end, because the annex gives nothing but points.

The second observation concerns the distance between the method announced and the result written down. Recital (4) says that the duration of the measures is adapted on the basis of the information supplied by Greece, above all „the dates of the preliminary cleaning and disinfection of the affected establishments”. That adaptation ought to produce different deadlines, because the establishments were cleaned on different dates. In the annex, all 67 date entries carry the same one. Outbreak 00108, the oldest of those still on the list, already appeared in the annex adopted on 23 July 2026, so it was confirmed at the latest by then; its protection zone will have lasted at least 161 days, against the minimum of 15 days in Annex X to the delegated regulation, to which the 15 days of surveillance measures are added. Outbreak 00196, the newest, gets exactly the same deadline. The likely explanation is practical, a single date being easier to administer than 66, but then the recital describes something other than what the annex does, and the older establishments bear a regime sized for the newer ones.

The third observation concerns the care taken over the text, and here the small things add up. The descriptions of the 133 areas are in English, in an act published in Romanian: a Romanian haulier who opens the Official Journal of the European Union in his own language finds a column he cannot read. The deadline is set with the year in two digits in the 66 entries of the first table and in four digits in the 67th, even though the two tables sit in the same annex and carry the same date. Outbreaks 00176 and 00177 have identical coordinates, down to the last decimal, so two rows of the annex describe exactly the same protection zone and exactly the same surveillance zone; it is not a legal contradiction, since the result is the same, but it is a redundancy that makes any check harder. The reference numbers run from 00140 to 00196 without a break, with a single exception, 00148, which appears neither in the July annex nor in the present one; the act does not say why, and it cannot be found out from the text. Lastly, the table heading refers to „Article 1”, a correct reference for anyone who knows that the annex is read as part of Implementing Decision (EU) 2026/820, but a confusing one for anyone reading the act of 23 September 2026 on its own, because there Article 1 says only that the annex is replaced.

One observation of substance remains, and it concerns Romania more than the content of the annex. This act is the model on which work would be done here too. If foot and mouth disease appeared in a Romanian establishment, the Commission would adopt a decision addressed to Romania, notified, taking effect from notification, with the annex written in geographical coordinates and with the statement that only the Romanian text is authentic. The difference from a regulation is not a formal one: a regulation applies to everyone and is read by everyone, a decision of this kind binds a single State, and the others read it in order to know where goods no longer come from. It is worth watching how quickly such acts are adopted and how precisely the zones are delimited, because on the day the addressee were us, that speed and that precision would decide our losses.

What should be changed

  • Each outbreak should get its own end date, not a common one. Recital (4) already promises adaptation according to the dates of cleaning and disinfection; applied, it would take the older establishments out of the restrictions weeks or months earlier, without weakening the regime around the newer outbreaks.
  • The annex should give the boundaries as drawn, not the centres alone. A map published together with the act, or at least the names of the localities included, would make the zone legible for the farmer and the haulier who have to comply with it, instead of a pair of coordinates nobody can turn into ground on the move.
  • The description of the areas should be translated into the language of the edition. In a text printed in Romanian, the only column that says where the rule applies is in English, while in the April 2026 version the same column was in Romanian, so translation is possible and has been done before.
  • The act should state the date of notification. Effects are produced on notification, and the addressee knows that date; publishing it would give the other States, and operators, the exact date from which goods can no longer move.
  • Amendments to the annex should be accompanied by a table of differences. A single page with the outbreaks added and those removed would spare every addressee the comparison of two lists of dozens of rows of coordinates and would show at a glance which way the epidemic is going.
  • The date format should be the same in every entry. The year in four digits everywhere removes a needless ambiguity and makes the text automatically verifiable, which matters in an annex rewritten every two months.

Original text of the legal act

The text below is reproduced in Romanian, the official form of publication.

The full text, as published in the Official Gazette of Romania

Official Journal of the European Union, L series, 2026/2148 of 23 September 2026 16 pages PDF, 623 KB

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This article is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed attorney or tax advisor.