In brief
- All 41 counties and Bucharest stay in restricted zone III, the most severe level. The Union splits the territories hit by African swine fever into three zones, I, II and III, in rising order of restriction. Romania is the only member state entered on the list with its whole territory, and no area of the country appears in zone I or in zone II.
- Romania’s position has not changed at all. The list of the 41 counties and of Bucharest is identical, line by line, with the one in the previous regulation, adopted on 24 August 2026, and with the list in the original annex to Regulation (EU) 2023/594, of 16 March 2023. The amendments made now concern Finland, Hungary and Poland.
- For the pig farmer, this means the door to export is shut. Live animals cannot leave for another member state or outside the Union, any movement requires authorisation from the county veterinary directorate, the official veterinarian has to call at the farm at least once every three months, and fresh meat gets a special mark and circulates only inside Romania.
Published: Official Journal of the European Union, L series, 2026/2094 of 15 September 2026
In force from: 16 September 2026, the day following publication, because that is what Article 2 of the regulation provides
The European Commission has rewritten the European map of African swine fever, and Romania appears on it with its entire territory, in the harshest of the three restricted zones. Annex I to Regulation (EU) 2023/594, replaced in full by the act published on 15 September 2026, divides the areas hit by the disease into restricted zones I, II and III. Romania enters only in Part III of the annex, with 41 counties listed one by one and with a separate entry called „Zona orașului București”, the area of the city of Bucharest. The burden falls on pig farmers across the country, the same people to whom the state opened in August 2026 an aid scheme of 11.9 euro per place for a fattening pig, so that they would keep their housing full.
The counties on the list are, in the order of the annex: Constanța, Satu Mare, Tulcea, Bacău, Bihor, Bistrița Năsăud, Brăila, Buzău, Călărași, Dâmbovița, Galați, Giurgiu, Ialomița, Ilfov, Prahova, Sălaj, Suceava, Vaslui, Vrancea, Teleorman, Mehedinți, Gorj, Argeș, Olt, Dolj, Arad, Timiș, Covasna, Brașov, Botoșani, Vâlcea, Iași, Hunedoara, Alba, Sibiu, Caraș-Severin, Neamț, Harghita, Mureș, Cluj and Maramureș. They are every county in the country. Together with Bucharest, the list covers the whole national territory, with no exception and with no delimitation finer than the administrative boundary of the county.
Part III of the annex covers nine member states: Romania, Greece, Croatia, Lithuania, Italy, Slovakia, Poland, Hungary and Bulgaria. The other eight are entered with localities, communes or game management units, that is with pieces of territory. Romania is the only one listed with the whole country and the only one that opens Part III, at point 1. In the other two parts of the annex, the ones that gather zones I and II, Romania’s name does not appear at all.
The difference between the three zones is not a matter of nuance. Out of a zone I, live pigs may leave, with authorisation, including for another member state and for third countries. Out of a zone II they may leave for other zones II or III in another member state, under harder conditions. For zone III there is no provision that lets live animals cross the border of the country. The three derogations written specifically for zone III, Articles 28, 29 and 30 of Regulation (EU) 2023/594, all speak of movement „within the territory of the same Member State concerned”.
The amendments actually made now concern the north and the centre of the Union. Finland, where the disease has reached wild boar in the Kymenlaakso region, comes out of Annex II and enters Annex I, with a freshly drawn zone I and zone II. In Hungary, an outbreak that appeared in August 2026 among kept pigs on a farm in Baranya County moves the area around the town of Mohács from zone II up into zone III. In Poland, an area in the Kujawsko-Pomorskie region moves up into zone III, while areas in Podkarpackie and Zachodniopomorskie pass from zone I into zone II.
What it changes in practice
For a farmer in any given county, the situation from 16 September 2026 is the same as before, but it is worth reading out clearly once, because the rules of zone III are the least well known of the lot.
The starting point is Article 9(1) of Regulation (EU) 2023/594: the movement of kept pigs is prohibited, both inside the zone and out of it. The ban is not a border formality, it applies between two farms in the same county as well. It can be lifted case by case by the county veterinary directorate, but only after a risk assessment that has to show the risk of spread is negligible, and only for destinations inside the country.
Transport to the slaughterhouse, the most frequent case, is done under Article 30, to a slaughterhouse specifically designated for the immediate slaughter of pigs from zones II and III. On arrival the animals are kept apart from the rest and slaughtered either on a day reserved for them alone or at the end of the working schedule, and the slaughterhouse is cleaned and disinfected before slaughter of other pigs resumes.
The farm sending the animals has to tick off, before any movement, a set of conditions that Articles 15 and 16 describe in detail: the animals stay at least 30 days in the establishment without being moved, an official veterinarian examines them clinically in the 24 hours before departure, the farm applies the reinforced biosecurity measures of Annex III and tests weekly, for detection of the virus, the first two dead pigs older than 60 days in each epidemiological unit. In zone III the official veterinarian’s visit takes place at least once every three months, against at least twice a year in zones I and II.
The meat follows a separate road. Article 12 prohibits fresh meat and meat products obtained from pigs in zones II and III from leaving. The derogation in Article 43 lets them circulate, but only if they were produced in a designated establishment, only if they carry the special mark of Article 47, the one with two additional parallel diagonal lines over the ordinary mark, and only within the territory of Romania. What escapes the ban are meat products treated by heat in accordance with Annex VII to Delegated Regulation (EU) 2020/687, which may go anywhere.
Semen and embryos may leave zone III only inside the country, under the conditions of Article 33: donor animals have to have been kept in an approved centre since birth or for at least three months before collection, and all porcine animals in the centre are tested at least once a year.
For a town hall or a county council, the classification does not depend on there being an outbreak within the locality. The county is in zone III because that is how it appears in the European annex, even if years have passed since the last case of swine fever in that place. The rules on biosecurity, on hunting wild boar and on disposing of carcasses apply the same way everywhere.
What has changed compared with the previous situation
For Romania, nothing. The block of 42 entries, Bucharest and the 41 counties, is word for word the same as in Commission Implementing Regulation (EU) 2026/1961 of 24 August 2026, the act that amended the annexes before this one. It is also identical with the list in the original annex to Regulation (EU) 2023/594, adopted on 16 March 2023 and published in the Official Journal, L series no. 79 of 17 March 2023. Three and a half years passed between that date and 15 September 2026, and in all that time the map of Romania was never retouched.
What has changed elsewhere concerns three states. Finland has reported new outbreaks in wild boar in the Kymenlaakso region and comes out of Part A of Annex II, where it figured with the municipalities of Virolahti and Miehikkälä and with the southern part of the city of Lappeenranta, under an end date of application set at 31 October 2026. Those areas move into Annex I, as restricted zone I and restricted zone II, that is into a permanent regime rather than a provisional one. After that move, Part A of Annex II is left with no listed area at all.
In Hungary, an outbreak of August 2026 among kept pigs on a farm in Baranya County takes into zone III the game management units around the towns of Mohács, Kölked, Lánycsók, Nagynyárád and Sátorhely, plus a few neighbouring areas in Bács-Kiskun County. In Poland, an outbreak in the Kujawsko-Pomorskie region and three further cases in Podkarpackie and Zachodniopomorskie push the affected areas one step up.
Annex I now covers 15 member states and runs to 78 pages, from page 5 to page 82 of the Official Journal. Romania’s entry takes up a little over one page of them.
The technique of lists by zone is not used only inside the Union. On 23 September 2026, six circles with a radius of 10 kilometres in South Dakota, North Dakota and Minnesota left the lists from which the Union may import poultry and hatching eggs, after highly pathogenic avian influenza was confirmed there.
Advantages and disadvantages
What it improves
- The map is updated at Union level, not by each state on its own, so a buyer in Germany or in Spain looks in a single document to find out what regime applies to the farm offering him goods.
- The county by county list is easy to read for someone without legal training: there is no need to identify game management units or cadastral codes, as happens with the entries for Hungary or Poland.
- The stability of the list removes planning uncertainty. A farmer drawing up his budget for 2027 knows his classification will not change from one month to the next.
- Heat treated meat products stay outside the ban, which leaves open the only real commercial door for processors in Romania.
- The act enters into force the day after publication, with no transition period, which quickly closes the windows of risk created by the outbreaks in Finland, Hungary and Poland.
What remains a problem
- Classification at the level of a whole county does not distinguish an area with active outbreaks from one where the disease has not appeared for years. A farm in a clean corner of the country bears exactly the same restrictions as one next to an outbreak.
- Because Romania has no zone I and no zone II, the derogations the regulation builds around those zones cannot apply here. Article 28(1) and Article 29(1) remain, in practice, a dead letter.
- The export of live pigs is closed, and fresh meat circulates only domestically and only with the special mark, which takes it out of the competition on the single market.
- The quarterly visit by the official veterinarian and the weekly testing of dead animals mean a fixed cost that the small farm carries harder than the industrial unit.
- The annex says nothing about the criteria by which an area might come down from zone III to zone II, although the base regulation provides for periodic reviews. A farmer has no way of finding out what has to happen for the situation to change.
- The amendment is made by replacing the annexes in full, with no table of correspondence. Anyone who wants to see what has actually changed has to compare 78 pages with another 78.
Practical advice
- Ask the county veterinary directorate for authorisation before any movement of animals, including between two farms of the same owner in the same county. The ban in Article 9 does not go by borders, it goes by zones.
- Plan the delivery to the slaughterhouse at least 30 days ahead. The condition in Article 15, that the animals must not have been moved in the previous 30 days, is lost if you bring into the same housing pigs from a farm that does not meet the same conditions.
- Check in good time whether the slaughterhouse you are sending to is designated for the immediate slaughter of pigs from zone III. An ordinary slaughterhouse cannot take the consignment, whatever papers you hold.
- Keep the register of weekly tests on dead animals older than 60 days up to date. Their absence blocks authorisation of the movement even if the farm is clean.
- Do not promise a buyer in another member state fresh Romanian pork. The special mark with two diagonal lines limits it to domestic circulation, and the product that can cross the border is the heat treated one.
- If you sell semen, check that the donor animals have been in the approved centre since birth or for at least three months and that the annual testing of the whole stock in the centre is documented.
Frequently asked questions
What does restricted zone III mean, in short?
Has my county just entered zone III?
Is there any area of Romania in zone I or in zone II?
Can I take my pigs to a slaughterhouse in another county?
Can I still export live pigs to another state of the Union?
What happens to the meat and the salami?
From when does the new annex apply?
Who checks on the spot?
What would have to happen for Romania to leave zone III?
Errors and inconsistencies in the published text
- Part B of Annex II is missing entirely. Article 7(2) of Regulation (EU) 2023/594 requires that, on the first and only outbreak among kept pigs in a member state previously free of the disease, the area be listed as a restricted zone, comprising protection and surveillance zones, „in Part B of Annex II”, and paragraph (3), point (b), of the same article refers to it in the same way. Annex II in the form replaced now has only Part A. In the original version of the regulation, from March 2023, Part B existed, with its table of headings. A member state in the situation described by Article 7(2) has nowhere to be listed.
- Annex I, Part III, point 1, the Romanian entries. In the English version the 42 Romanian entries are reproduced in Romanian, as administrative names, and the spelling is not consistent inside the same list. Most read „Județul”, with the comma below the letter t, but „Judeţul Mehedinţi”, „Judeţul Olt” and „Judeţul Dolj” use the cedilla instead, a different character, and the last entry reads „Județul Maramureş”, with the two forms in the same name. „Județul Suceava” is the only line that lacks the comma closing every other one. The annex is the document by which the regime of a farm is established, so a search on the official spelling in the register does not return all 41 counties, and an authority matching the list mechanically against the national nomenclature finds four entries that do not correspond.
- Part A of Annex II names Finland, but no longer lists any area and any date. The heading still reads „Areas established as infected zone in Finland as referred to in Article 1”, it keeps the column „Date until applicable”, and the single row beneath says „All areas are listed in Parts I and II of Annex I”, with no locality and no date. Article 8(2), (3) and (4), however, ties concrete obligations, among them the ban on dispatching pigs and products to other member states and to third countries, to the zones „listed in Part A of Annex II”. The reader cannot establish from the text whether Finland still has an infected zone to which those obligations apply.
Editorial analysis
The interest of this act lies not in what changes, but in what does not. The 42 lines about Romania are the ones from 16 March 2023, the date of Regulation (EU) 2023/594, and the annex is amended often: the last time on 24 August 2026, for Bulgaria, Hungary, Italy and Poland, and now again, eighteen days later, for Finland, Hungary and Poland. The Romanian list has passed untouched through all those retouches. That may mean the epidemiological situation really has not moved, but it may equally mean that nobody has asked for it to move, because the act does not say what would trigger a review.
The legal consequence of listing in a single block only shows when the annex is set beside the articles of the base regulation. Article 28(1) allows pigs to be taken out of a zone III, in exceptional animal welfare situations, to an establishment in a zone II or, where there is no zone II in that state, in a zone I. Article 29(1) allows immediate slaughter at a slaughterhouse in a zone II, failing that in a zone I, and in the last resort outside the restricted zones. Both provisions assume the member state has something other than zone III. Romania does not. There is no zone I in the country, no zone II and no patch outside the restricted zones, so both derogations are inapplicable here, even though on paper they exist for everyone. What is left for a Romanian farmer is Article 28(2), movement inside zone III, and Article 30, the slaughterhouse inside the same zone.
The second thing that comes out of the comparison is the relationship between the two rhythms. The act enters into force on 16 September 2026, the day after publication, so the obligation of the addressee is instant. The map that generates the obligation, however, has not been revised for Romania in three and a half years. A regime conceived as temporary, which Article 1 of Regulation (EU) 2023/594 describes as applicable „for a limited period of time”, works in Romania as a permanent one.
Six days later the Commission rewrote both annexes again: in Regulation (EU) 2026/2135 the Romanian list stays identical, while Lithuania leaves zone III.
What should be changed
- Publication of a consolidated version marking the differences. The annex is replaced in full at every amendment, with no table of correspondence. A file showing which line came in and which line went out would spare national authorities and farmers the comparison of 78 pages with another 78.
- Public criteria for moving down from one zone to another. The act says what the classification is based on, but not what has to be demonstrated in order to come out of it. A threshold expressed in months without outbreaks and in numbers of negative tests would turn zone III from a state of affairs into a target a member state can work towards.
- Delimitation below county level for the states listed in a block. Romania is the only one entered with its entire territory. Classification by smaller administrative units, as is already done for Hungary and Poland, would free the areas without outbreaks from costs that nothing justifies.
- Reinstating Part B of Annex II and correcting the heading in Part A. As long as Article 7(2) refers to a part that no longer exists, the mechanism for listing the first outbreak in a disease free state has no support in the annex.
- Using the official names of the administrative units, spelled consistently. The annex writes „Bistrița Năsăud” without the hyphen, identifies the capital by the phrase „Zona orașului București” although the administrative unit is called municipiul București, and mixes two sets of Romanian diacritics in the same list. The annex is the document by which the regime of a farm is established, so the names in it ought to match those in the official nomenclature.
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, 2026/2094 of 15 September 2026 82 pages PDF, 1.6 MB the act starts on page 71
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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.