Written evidence submitted by the Blue Cross (PSM0011)

1. How many puppies are imported into the UK illegally, including under the EU Pet Travel Scheme?

In January 2012, the pet travel rules in the UK were harmonised with the rest of the European Union (EU) to allow for easier pet travel. Figures released by Defra show imports of dogs to Great Britain via the Pet Travel Scheme (PETS) have increased every year: in 2018 307,357 animals, up from 287,016 in 2017[1] and from 85,299 in 2011.[2] Blue Cross believes these figures are still likely to be a vast underestimation of the actual number of dogs entering the UK because we know many sellers are bringing puppies in with no paperwork and are simply not declaring the animals on entry; transporters will also often falsify documentation and inadequate checks will not identify this. As a result, we submit it is impossible to determine how many puppies are imported illegally.

The PETS scheme, which was designed to allow owners to travel with their pets for non-commercial reasons, is now clearly abused by commercial dealers of puppies to make large profits. In a series of reports, Dogs Trust has revealed how unscrupulous dealers are widely abusing PETS to import puppies to Great Britain and make hundreds of thousands of pounds. In its latest report[3] it showed how puppies bred in Serbia – an unlisted Third Country – were being brought into the EU, provided with Hungarian and Bulgarian passports and microchips, and transported as EU dogs to be sold to unsuspecting members of the public. In the British Veterinary Association's (BVA) Spring 2018 Voice of the Veterinary Profession survey, three in ten (29%) companion animal vets reported seeing puppies in the previous year that they were concerned had been brought into the country illegally.

In recent years, the increased popularity of brachycephalic breeds, such as pugs and French bulldogs, has created a market that cannot be met by domestic breeders. The 2018 Dogs Trust report found that that 63% of puppies intercepted at the British border, as part of the Puppy Pilot scheme, between December 2015 and July 2018 were French Bulldogs, Pugs, English Bulldogs and Dachshunds. The popularity of these breeds has led to even poorer breeding practices, puppy farming in sometimes appalling conditions and illegal importation of puppies which further negatively impacts on the welfare of these animals.

The puppy farms in which these puppies are born, together with the frequently appalling conditions in which they are transported, leave a legacy of severe physical and behavioural problems. It is also important to note that that pet smuggling is not restricted to puppies – cats and kittens are also being smuggled illegally into the UK. 

Blue Cross submitted a Freedom of Information request to Local Authorities (LAs) and found, in 2016, there were 816 premises licensed under the Breeding and Sale of Dogs (Welfare) Act 1999.[4] Given the huge demand for puppies, it is clear that the supply will never meet the demand.

2. Are border controls in the UK sufficient to detect puppies being imported illegally, and if not, how should this be improved?

It is clear from the abuse of the PETS that the current border controls are inadequate and are failing to deter determined puppy smugglers from importing them illegally into the UK.  One of the fundamental problems is that checks at the UK border are often conducted by the carriers (ferry companies, Eurotunnel) themselves rather than official Government agencies. The people who carry out checks for the carriers have limited knowledge and are inadequately trained in recognising the signs of illegal importation. Another major problem is that there is no requirement to conduct even basic visual checks.

Blue Cross argues that increased spot checks by government agencies, which can significantly disrupt movement of goods and people, are essential if puppy smuggling is to be tackled effectively; there should also be adequate staffing at weekends and evenings to reduce opportunities to circumvent the spot checks. This should be accompanied by increased sufficiently resourced cross-border and cross-agency collaboration, sharing intelligence and information on suspected smugglers and routes into the UK.

The numbers of illegally smuggled puppies considerably the risk of a disease outbreak, including rabies, the tapeworm Echinococcus multilocularis, and babesiosis. The lack of traceability of these dogs will mean we have no information on the source of any such outbreak and, therefore, the chances of successfully tackling it will be diminished.

There are a couple of examples already in operation that could provide templates for future action:

Operation Delphin is a collaboration between enforcement agencies and animal welfare organisations including the RSPCA, SSPCA, HMRC and Animal Health and Plant Agency (APHA) which seeks to tackle illegal puppy smuggling across the UK and the Republic of Ireland. Since its inception in 2016, it has resulted in a number of major successes: in November 2016, nearly 100 puppies were seized after they were attempted to be transported from Dublin to Holyhead;[5] in May 2018, 27 pups, believed to have been farmed in the Republic of Ireland, were seized in the Scottish port of Cairnryan.[6]

Dogs Trust’s Puppy Pilot scheme, launched in 2015, was established to aid the interception of dogs seized by APHA at the ports and provides care and rehabilitation before finding them new homes.

The penalties for being engaged in illegal puppy smuggling are derisory: the current maximum sentence under the Non-commercial Movement of Pet Animals Order 2011 is imprisonment for three months, far too lenient for this type of criminal activity which as such a disastrous impact on the health and welfare of the puppies involved. Longer sentences are essential to provide any meaningful deterrent and to match the gravity of this vile trade.

3. After EU Exit, should the UK introduce tougher controls on pet imports? How would these be balanced against the needs of people legally transporting pets across borders?

Blue Cross recognises that there is a legitimate trade in pets and that breeders have to bring in dogs to refresh the gene pool; however, it is clear that the PETS is simply not working and is being easily circumvented and abused. As Blue Cross is all too aware, effective enforcement is always a major problem in animal welfare issues.

Blue Cross believes that strengthened legislation, strictly and consistently enforced, is needed to provide for effective regulation. Stricter punishments for those who are caught illegally smuggling puppies is also essential to encourage compliance and acts as a deterrent; at the moment, the potential gains of illegal puppy smuggling far outweigh the potential costs of being caught. The Animal Welfare (Sentencing) Bill, which would have increased sentences for the worst cases of animal cruelty to five years, could have applied to the cruelty and suffering caused by illegal puppy smuggling. Sadly, this bill failed to complete all its stages before Parliament was prorogued on 9 September. Blue Cross would urge the government to reintroduce the Bill in the Queen’s Speech; as the Bill has cross-party support, it could pass through its parliamentary stages relatively quickly and, once enacted, provide a deterrent for those who participate in this abhorrent activity.

The need for tougher controls is also economic: illegal smuggling of pets is costing the exchequer a significant amount of money in illegal and undeclared revenue. The HMRC taskforce, initiated in 2015, has recovered £5,393,035 in lost taxes from 257 separate cases since its formation.[7]

The tougher controls that could be introduced include:

• Raise the minimum age for imports from 15 weeks to 6 months
• Reintroduce rabies blood testing before entry into the UK
• Reintroduction of mandatory tick treatment

4. Will the ban on third party sales of puppies: (i) encourage buyers to source puppies responsibly; and (ii) reduce illegal puppy smuggling?

i) Blue Cross does not believe the ban on third party sales will have the desired impact, both on consumer behaviour and illegal puppy smuggling. One of the key problems we feel needs to be addressed to deal with the problems surrounding the breeding and sale of puppies is consumer behaviour. We know far too many consumers are ill informed not only pre-purchase but also when problems do develop with their animals at a later date. With demand for puppies and kittens at an all-time high, it is easy to see how unethical breeders and traders are able to take advantage of unwitting members of the public and sell large numbers of poorly bred animals.

In order to reduce the number of irresponsible and unethical breeders and dealers, we need to ensure that consumers have the correct information about how to buy an animal safely and the potential pitfalls of making an impulse purchase. We know that there are responsible owners out there who are receptive to the information Blue Cross, and other charities, regularly disseminate on how to buy an animal safely; it is clear however that there are large numbers of people who are not receptive to this advice and we need to work together with government to find innovative ways to reach these groups of people.

We believe that there needs to be investment in a public education/ behaviour change campaign to try and better educate and inform consumers on safe ways to purchase animals and inform them of the lifetime commitment they are taking on when they get a dog.  This is something the Scottish Government have been doing as part of their Buy a Puppy Safely campaign.

ii) We know that many of the claims in favour of a ban on third party sales have suggested that it will essentially end licensed puppy farming - we do not believe this will be the case. We know some puppy farms do sell through third party sellers but we also know that puppies are also sold directly to the public. We believe that a ban on third party sales will not significantly impact the number of large-scale operating licensed breeders.

We don’t think a ban on third party sales would go far enough to have a meaningful effect and could cause the illegal puppy trade to flourish. This type of ban would not place any legal requirements on breeders to uphold good welfare standards either. With no means of ensuring the welfare of the pets in this invisible trade, buyers would be even more at risk of ending up with sick pets bred in poor conditions. Additionally, any exemptions for rehoming charities could open up a loophole for unscrupulous breeders to set themselves up as ‘rescue organisations’.

Introducing an effective registration and licensing system would make breeders and sellers more visible and traceable, improve animal welfare and offer greater protection for the public when buying a puppy.

Why registration and licensing would work best:

•              Changing the law to require anyone who breeds a pet to be licensed would make the breeder known and visible to law enforcers so they can be inspected. Making it illegal to sell any pet without a licence makes the law transparent and easy for the public to follow.

•              Inspections of breeders by trained enforcers would mean the welfare needs of the animals (under the Animal Welfare Act 2006) can be checked, and failings acted on to protect the animals being bred from and sold

•              A legal requirement to state clearly the licence number on all adverts for the sale of animals, and linking the number to a central and transparent database of licensed breeders, would allow the public and authorities visibility of the breeder, make it easy to report poor animal welfare, and give buyers increased consumer power should anything go wrong

•              These measures would result in improved health and welfare for pets

5. How could demand in the UK for puppies be better met by domestic breeding?

Fundamentally, the main problem is that the public demand for puppies in the UK far outstrips the number of puppies being well bred in this country. The illegal puppy smugglers know that they can make money because the demand is there. As outlined in the answer to question 4, Blue Cross submits that changing consumer behaviour through public education and communication campaigns is one way to limit demand for puppies. We are encouraged that the government intends to “launch a campaign focused on helping the public understand how to responsibly source a puppy or kitten in early 2020.”[8] We hope this is properly resourced and pays particular attention to hard to reach demographics. Blue Cross, and other animal welfare charities, also provide advice and information on sourcing and purchasing puppies responsibly.

Breeders who are members of The Kennel Club Assured Breeder Scheme are committed to maintaining high standards for the health and welfare of their puppies. Currently, there are not enough Assured Breeders to meet demands, so more needs to be done to encourage breeders to join the Scheme.

September 2019