The Cease Animal Research Grants Overseas (CARGO) Act of 2025 amends the Public Health Service Act to stop the National Institutes of Health (NIH) from awarding any federal support for activities that use live animals unless the animal research physically occurs in the United States (including D.C. and U.S. territories). The amendment inserts an explicit, overarching prohibition into Section 495 of the Public Health Service Act and reorganizes existing subsection lettering to accommodate the change.
The measure targets NIH-funded foreign animal research on the grounds of oversight and animal welfare, citing roughly $2.2 billion in foreign animal research funding from 2011–2021 and asserting gaps in inspection and self-reporting by foreign institutions. For institutional officials, grant managers, and compliance officers, the bill would require rethinking subcontracting, partner selection, and project design where any live-animal work has previously occurred overseas.
At a Glance
What It Does
The bill adds a new subsection to Section 495 of the Public Health Service Act that forbids the NIH from awarding any support (explicitly listing grants, contracts, cooperative agreements, and technical assistance) for research that uses live animals unless the animal work takes place within the United States. It also redesignates existing subsection lettering to accommodate the insertion.
Who It Affects
The ban directly affects NIH program officers, U.S. principal investigators who partner with foreign labs, foreign institutions that currently receive NIH funds for animal work, institutional animal care and use committees (IACUCs) involved in NIH-funded projects, and compliance officers responsible for awards and subawards.
Why It Matters
The bill closes a pathway for NIH-funded animal research to be carried out under foreign oversight, raising compliance and infrastructure implications for U.S. investigators and institutions that rely on international collaborations or unique foreign facilities or species. It also creates an operational enforcement question for NIH about how to treat multi-site and subcontracted projects.
More articles like this one.
A weekly email with all the latest developments on this topic.
What This Bill Actually Does
The core of the CARGO Act is simple in language and consequential in effect: NIH may not provide federal support for any activity or program that uses live animals for research unless the animal research occurs in the United States. The text is not limited to traditional grants; it explicitly covers contracts, cooperative agreements, and even technical assistance.
The Act then defines "United States" to include the several States, the District of Columbia, and U.S. territories and possessions, making the prohibition geographically broad but confined to U.S. jurisdiction.
Practically, the new prohibition operates as a hard location requirement. If any part of a research activity funded by NIH involves the use of live animals and that animal use would take place outside U.S. territory, NIH could not award the funding.
That affects not only foreign institutions as direct awardees but also U.S. awardees that plan to subcontract or collaborate with foreign partners who would perform animal work. The text contains no express carve-outs, exceptions, or grandfathering language for ongoing awards, nor does it define "uses live animals," leaving interpretive questions about tissue work, ex vivo studies, and managed specimen transfer.The bill is inserted into existing statutory language by altering subsection lettering in Section 495; this is more than housekeeping because it creates an overriding "notwithstanding any other provision" statement that stands at the front of the section.
The legislative findings explicitly frame the change around a decade of NIH funding to foreign organizations (cited as approximately $2.2 billion for 2011–2021) and concerns about inspection and self-reporting abroad. Because the prohibition is absolute in scope as written, grantees and NIH program staff would need to re-scope projects, renegotiate collaborative arrangements, or relocate animal components to domestic facilities to remain eligible for NIH support.
The Five Things You Need to Know
The bill inserts a new subsection (a) into Section 495 of the Public Health Service Act (42 U.S.C. 289d) that flatly prohibits NIH from awarding any support for research that uses live animals unless the animal research occurs in the United States.
The statutory ban explicitly covers "any support (including any grant, contract, cooperative agreement, or technical assistance)," broadening the prohibition beyond grants to contracts and other funding instruments.
The bill defines 'United States' to include the several States, the District of Columbia, and any U.S. territory or possession, making U.S. territories eligible locations for animal work under the prohibition.
There is no express exception, grandfather clause, or implementation timeline in the text; the prohibition is framed 'notwithstanding any other provision,' signaling immediate primacy over conflicting statutory language.
To accommodate the inserted prohibition the bill redesignates the existing subsections of Section 495 (a)–(e) as (b)–(f), a technical change that can affect cross-references in regulations, grant terms, and related statutes that cite those subsections.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short title
Identifies the Act as the "Cease Animal Research Grants Overseas Act of 2025" or the "CARGO Act of 2025." This is a formal naming provision with no operational effect, but it signals the bill's policy focus—ending NIH support for animal research performed outside U.S. jurisdiction.
Congressional findings
Sets out the legislative rationale: it cites approximately $2.2 billion in NIH-funded foreign animal research from FY2011–FY2021 and asserts that NIH does not inspect foreign organizations and relies on self-reporting for animal welfare oversight. Those findings are not operative law but shape statutory construction and administrative interpretation, providing context NIH and courts would consider when construing the new prohibition.
Textual insertion of funding prohibition
Adds a new subsection that bars NIH from awarding any support for activities that 'use live animals' unless the animal research occurs in the United States, explicitly listing award instruments (grants, contracts, cooperative agreements, technical assistance). The provision's phrasing—especially the catch-all 'any support' and the lack of definitional detail for 'uses live animals'—creates a broad ban that applies to a wide range of NIH-funded activities.
Geographic scope
Clarifies that 'United States' includes the States, D.C., and U.S. territories and possessions. This prevents an argument that territories are excluded and makes domestic territories potential locations for relocating animal work. For award managers, this matters when assessing site eligibility and when U.S. institutions propose placing animal work in a territory rather than the continental U.S.
Subsection redesignation and cross-reference impact
The bill also performs a series of cross-reference edits: it adjusts multiple internal citations and redesignates former subsections (a)–(e) as (b)–(f). Those edits are technical but important—existing regulations, guidance documents, and award terms that cite the pre-amendment subsection lettering may need prompt updating to avoid confusion or misapplication of rules.
This bill is one of many.
Codify tracks hundreds of bills on Healthcare across all five countries.
Explore Healthcare in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Animal welfare organizations: The ban reduces the channel through which NIH funds can be used for animal research abroad, aligning federal funding policy with organizations that seek stronger, U.S.-based oversight of animal welfare.
- U.S.-based animal research facilities and their administrators: Reduced foreign competition for NIH animal-research dollars could increase available funding and collaborative opportunities for domestic vivaria and their investigators.
- NIH compliance offices and oversight staff (potentially): A geographically limited funding universe narrows the set of foreign bodies NIH must attempt to monitor, which could simplify oversight priorities if NIH shifts toward focusing on domestic inspections and enforcement.
Who Bears the Cost
- Foreign research institutions and collaborators: Entities outside U.S. jurisdiction that currently receive NIH funding for animal-based work would lose access to NIH dollars and the partnerships that flow from them.
- U.S. investigators who rely on foreign partners or facilities: Principal investigators who subcontract animal work overseas or who study species or conditions uniquely accessible abroad will need to redesign studies, find domestic alternatives, or forgo NIH support.
- NIH program offices and grant administrators: Staff will face an administrative burden to review awards for compliance with the new geographic rule, re-evaluate pending awards with foreign animal components, and update guidance, review criteria, and contract language.
- Institutions needing to build domestic capacity: Universities and private labs may face capital and operating costs to move animal work back to U.S. facilities or to expand domestic vivarium capacity to replace foreign partners.
Key Issues
The Core Tension
The bill pits two legitimate goals against each other: strengthening animal-welfare oversight and ensuring taxpayer-funded research meets U.S. standards versus preserving scientific collaboration, access to specialized foreign facilities or species, and efficient cross-border research. Solving one side—placing all animal work under U.S. jurisdiction—imposes real costs and logistical barriers that may slow or shift scientific progress.
The bill leaves several operational and interpretive gaps that will matter in implementation. It does not define key terms such as 'uses live animals' or 'research'—ambiguities that affect whether work with primary tissues, biological samples derived from animals, ex vivo experiments, or shipping of live animals back to the U.S. is covered.
The absence of a transition or grandfathering clause creates immediate compliance questions for awards already under way that include foreign animal components.
On the administrative side, the statute's broad 'any support' language and redesignation of subsection lettering create ripple effects across NIH guidance, grant solicitations, interagency agreements, and existing contracts. NIH must decide whether to treat multi-site projects with mixed domestic and foreign components as ineligible, or whether it can structure awards so that all animal work is demonstrably performed within U.S. territory.
The bill also forces programmatic trade-offs: fields that depend on unique foreign species, specialized biosafety facilities, or collaborative cohorts risk scientific delays or loss of continuity if those activities cannot be reestablished domestically at short notice.
Try it yourself.
Ask a question in plain English, or pick a topic below. Results in seconds.