Written evidence submitted by Dogs Trust (PSM0014)

 

  1. About Dogs Trust

 

Dogs Trust is the UK’s largest dog welfare charity.  We have twenty rehoming centres across the UK, through which we care for approximately 15,000 dogs each year. Since Dogs Trust was founded in 1891 (formerly National Canine Defence League), we have always campaigned on dog welfare issues and played an instrumental role in the introduction of the Animal Welfare Act 2006.

 

  1. Executive Summary

 

Following changes to the Pet Travel Scheme (PETS) in 2012, through our four undercover investigations and the establishment of our Puppy Pilot scheme we have found evidence of:

 

To read more about the findings of all four reports please visit https://www.dogstrust.org.uk/puppy-smuggling/ps-media.

 

This illegal trade has a huge impact on the British public, financially, emotionally, and from a public health perspective, as well as on the potential health and welfare of the animals involved. Therefore, we urge the Government to take the following immediate action:

 

 

As pet travel is governed by EU legislation, we also have the following recommendations for post-Brexit action:

 

 

  1. Q1: How many puppies are imported into the UK illegally, including under the Pet Travel Scheme?

 

To better be able to answer this question, we must look more closely at the demand for dogs and how this is met by various sources.

 

To give some context, following relaxation of the rules around the Pet Travel Scheme in 2012, Dogs Trust has carried out four investigations[2] into the illegal importation of puppies via the Scheme. We have exposed widespread abuse of PETS, as outlined above, with commercial dealers in Central and Eastern Europe putting their own financial gain first, with little regard to the welfare of the puppies involved.

 

Sadly, the UK provides an attractive market for the puppy smuggling trade due to the high demand here for desirable breeds, such as French Bulldogs, English Bulldogs, Dachshunds and Chow Chows, and a limited supply of such puppies from reputable breeders in the UK. People are willing to pay huge prices for these particular breeds in the UK, which when coupled with relatively cheap production costs in other countries and a lack of concern for the welfare of the dogs, results in the opportunity to make a significant profit.

 

3.1.            Demand & supply of dogs in UK

 

The Pet Food Manufacturers’ Association (PFMA) estimate that there are around 9 million dogs in the UK[3]. With an average lifespan of approximately 12 years, it can be estimated that there is a demand for approximately 750,000 dogs per year. PFMA figures have shown the UK’s dog population has been stable for a number of years and has recently been estimated to have grown. However, there are limitations with this estimate and the true demand for dogs may differ from this.

 

Sources of dogs in the UK include:

 

Without full traceability of all dogs being bred and sold in the UK, it is extremely difficult to accurately estimate the number of dogs which are being acquired from each of these sources. However, Dogs Trust and other animal welfare organisations have gathered data on some of these sources through Freedom of Information requests and data extraction from online pet adverts.

 

In 2016, Dogs Trust issued a Freedom of Information request to all Local Authorities in England, Wales and Scotland on licensed dog breeders. The findings suggested there were 65,062 puppies born to licensed breeders in 2016. This is a small proportion of the total number of dogs needed to meet an annual demand for 750,000 dogs.

 

In the same year, data was extracted from all adverts regarding dogs for sale on Gumtree, Preloved and UK Classifieds. This data was kindly provided to Dogs Trust by Tech4Pets Ltd and showed that there were 259,510 puppies advertised online in 2016. Thus, there was a large discrepancy in 2016 between the number of puppies born to licensed breeders and those advertised online, which raises questions about the sources of the remaining 194,448 puppies advertised online but not born to licensed breeders.

 

In 2016, Blue Cross also issued a Freedom of Information request to all Local Authorities in England, Wales and Scotland[5]. They received details of:

 

 

However, as the Pet Animals Act applies to the selling of pet animals, not just dogs, this cannot be taken to indicate that all of these premises would be selling dogs.

 

Lastly, in 2016, the Ornamental Aquatic Trade Association (OATA) also issued a Freedom of Information request to all Local Authorities in Northern Ireland as well as Great Britain[6]. The findings of OATA’s report include:

 

 

Whilst dogs are being acquired from various sources, it is not clear how many from each source. However, to summarise:

 

Research is urgently needed in this area and so Dogs Trust’s Canine Behaviour and Research team is currently undertaking two major research projects entitled “UK Pet Dog Population Project: Movement and Sources” and “UK Dog Acquisition Project: Demand and Owner Behaviour”.

 

It is of huge concern that we do not have full traceability in the UK of all dog breeding and selling. Dogs Trust believes that we urgently need an improved, robust system of registration and licensing to tackle unscrupulous breeders and sellers. To ensure full traceability, anyone breeding, selling or transferring the ownership of a puppy (a dog up to 6 months old), regardless of any financial transaction or gain, should be required to at least be registered. In addition to this, anyone breeding, selling or transferring the ownership, regardless of any financial transaction or gain, of more than one litter of puppies should require a licence. It should then be a mandatory requirement for any advert to include the registration or licence number of the seller.

 

3.2.            Illegal imports

 

As already explained, we cannot put a definitive figure on how many puppies, out of the ~477,500 that are unaccounted for each year, are illegally imported. However, we do know that official Defra figures for the number of dogs entering the UK via PETS have increased year on year since the rules around the scheme were relaxed in 2012:

 

Year

Number of dogs imported via the Pet Travel Scheme

2011

85,299

2012

139,643

2013

152,075

2014

155,444

2015

164,836

2016

275,876

2017

287,016

2018

307,357

 

Of these dogs, we do not know how many were puppies because there is no requirement to record the age of dogs entering the UK via the Pet Travel Scheme.

 

To put the numbers into further context there was a:

 

 

Of the number of dogs recorded entering Great Britain via PETS, it’s impossible to know how many are doing so legally or illegally, the reasons for which we will explain further throughout our response.

 

3.3.            The Puppy Pilot

 

In December 2015 Dogs Trust launched its Puppy Pilot, an initiative aimed at disrupting the trade by providing for the quarantine, care and support for any puppies seized at Dover and Folkestone under animal welfare legislation or for being non-compliant under the Non-Commercial Movement of Pet Animals Order 2011 (otherwise known as the Pet Travel Scheme). Until Dogs Trust stepped in, illegally imported puppies were at risk of either being turned away at the borders only to enter the country at another time instead or being put to sleep. Puppies seized under the initiative are quarantined, socialised and habituated, and then rehomed responsibly through our network of rehoming centres.

 

Since December 2015 around 1,000 puppies have been rehomed by Dogs Trust after going through quarantine. The majority of puppies seized (95%) were deemed to be underage. Sadly, more than 4% of the puppies died before we were able to rehome them due to poor health, malnutrition and dehydration.

 

As these puppies were found as a result of random spot checks at Dover and Folkestone, we suspect that they are just the tip of the iceberg, particularly considering the other major UK ports where there are no routine inspections. Of the number of dogs recorded coming into the UK, we suspect that many more are doing so illegally without being caught.

 

It is also worth noting that the numbers of seizures taking place are decreasing. For example, if we look at the month of May for each year since the Puppy Pilot launched we get the following numbers of seizures:

 

Year

No. of seizures

2016

27

2017

17

2018

9

2019

4

 

 

Rather than it being the case that less puppies are being illegally imported via the Pet Travel Scheme, we suspect that seizures simply aren’t taking place, partly due to a lack of resources and intelligence sharing on the ground.

 

Dogs Trust has strong concerns that the number of seizures occurring do not truly reflect the level of illegal activity taking place, partly due to a lack of out-of-hours and weekend cover.

 

Lastly, whilst our investigations have focussed on the illegal importation of puppies via Dover and Folkestone, we are also aware from Operation Delphin that thousands of puppies have travelled from the Republic of Ireland, through Northern Ireland and across to the port of Cairnryan, Scotland. In addition, ferries operate between the Republic of Ireland and the UK, including the port of Holyhead.

 

It’s important to note that following the UK’s exit from the EU, Northern Ireland will still have a land border with an EU Member State. Given that there are no border checks between the Republic of Ireland and Northern Ireland, it is impossible to prove whether a dog originated from the Republic or Northern Ireland, making Belfast to Cairnryan (and similar passages) lucrative routes for individuals involved in illegal importation. Notwithstanding the political issues of the border in Ireland, from this perspective, it would be preferable to treat the island of Ireland as one, although we acknowledge that logistically this would be challenging not to disadvantage citizens of Northern Ireland. If this is not possible, it is imperative that better checks are introduced at the ports in Cairnryan, Holyhead and Fishguard.

 

Furthermore, any new legislation, and any agreement between the Republic of Ireland and the UK, should take this into account to ensure that such routes do not become more lucrative for the puppy trade.

 

In addition, from a disease perspective, we also need to treat the island of Ireland as one biological unit; disease does not recognise nor respect borders.

 

3.4.            Sedation & smuggling of puppies

 

As well as the illegal importation of puppies with falsified documentation, our investigations have uncovered other ways transporters will circumvent the rules of the Pet Travel Scheme. Dogs Trust’s 2017 investigation uncovered a worrying new trend, with vets in Lithuania suggesting people could smuggle pets into the UK i.e. undeclared without obtaining a pet passport at all. One went so far as to sell our investigators sedatives to allow puppies to be sedated at the port.

 

Early in 2018, a litter of ten French Bulldog puppies aged approximately three to four weeks were seized after being discovered (by chance) heavily sedated in a car travelling from Poland. The pups were found hidden in the hollow of the back seat under a pile of blankets and under one of the front seats. Nine of the puppies survived the ordeal despite some health issues and have been responsibly rehomed by Dogs Trust but sadly one died. These puppies were discovered by chance and it’s impossible to say how many more are passing across the border, hidden in vehicles, undetected, in addition to those that are declared but with falsified paperwork.

 

It is clear that the chances of getting caught illegally importing puppies are very low and, even if someone is caught, the penalties are totally inadequate. Thus, the lucrative benefits to this trade far outweigh the risks, and there is no real deterrent to the players involved. We look more closely at the need for further measures to detect smuggled puppies in our response to question 2.

 

To summarise our response to question 1, there’s demand for 750,000 dogs in the UK each year. Of these, ~477,500 puppies are unaccounted for and it is unknown how many of these are from legal or illegal sources. We’re rehomed around 1000 puppies through the Puppy Pilot and suspect these are just the tip of the iceberg.

 

  1. Q2: Are border controls in the UK sufficient to detect puppies being imported illegally, and if not, how should this be achieved?

 

Dogs Trust has strong concerns that border controls in the UK are not sufficient to detect puppies being imported illegally, whether they are declared but are underage with falsified paperwork, or they are hidden in vehicles, undetected.

 

4.1.            Responsibility of checks lies with the carriers

 

Currently it’s the responsibility of the carriers i.e. Eurotunnel and the ferry companies to undertake checks on pets that are travelling, and so challenges are placed on them to identify whether pet passports are fraudulent and whether puppies are over 15 weeks of age (the legal minimum age for travel). There is great variation in the knowledge of the carriers and our experience through our quarantine project is that intelligence sharing between the carriers and APHA is often left to individual relationships.

 

We know from our investigations and through the Puppy Pilot Scheme that illegal transporters are very good at adapting their practices to avoid being detected. For example, in recent times:

 

 

The focus on enforcement of the pet travel legislation must be shifted from the carriers to a qualified animal professional from a Government agency and this should include a requirement for there to be sufficient out-of-hours and weekend cover at ports. It costs an individual on average £15-£20 per dog when entering Great Britain. With 307,357 dogs entering Great Britain via the Pet Travel Scheme in 2018, even factoring in an administration fee, that is a significant amount of money that could be put towards funding a Government agency to undertake the checks.

 

4.2.            No visual checks

 

The EU legislation requires that ‘documentary and identity checks’ are undertaken at the travellers’ point of entry. However, there is no obligation for the carriers to do a visual check of the animals being imported. In current practice, carriers simply ask to see the pet passport, and the transporters of the dog scan the microchip themselves – not necessarily in sight of the carrier, who merely checks to see that the microchip number which appears on the scanner matches that on the passport. Unscrupulous dealers can simply attach a microchip on the puppy’s collar, scan it out of sight of the carrier, and then bin the chip as soon as they enter the country. The puppy can then be implanted with a UK microchip, all traces of its origins hidden from the buyer.

 

In 2015, our second investigation demonstrated the inadequacy of the document checks being done as we successfully illegally imported a toy dog without a visual check at British borders in three out of four attempts. The only reason we did not succeed on the fourth attempt was because the microchip scanner malfunctioned.

 

In our third investigation we again demonstrated the porous nature of our borders by taking a second toy dog on a journey to mainland Europe before successfully importing him back into Great Britain on two out of two occasions – once through Eurotunnel and once on a ferry through Dover – without being identified as a toy. On one occasion, the toy dog travelled on an animal transport vehicle along with other real dogs. On the second journey he travelled in a carrier on the back seat of a car.

 

The microchip was sellotaped to the top of the carrier (a ploy often used by illegal puppy importers so that they can use microchips and passports numerous times) and staff did not check inside the carrier.

 

Currently, we are concerned that the checks taking place are purely an administrative process, with not even basic visual checks of the animals being carried out. As a minimum, we strongly believe the checks at the border should include a visual check to ensure that the pet animal is the same as the animal listed on the pet passport, and is the age stated. Physical checks should also be a requirement where necessary, e.g. if a puppy is suspected of being underage or not matching the information in its pet passport and there should be a requirement for an animal health professional to be on hand to facilitate this.

 

4.3.            Further control measures needed

 

Dogs Trust would also urge the Government to explore further measures that could be implemented at the ports to help detect puppies that are truly smuggled across the border, hidden in vehicles, rather than illegally imported with falsified documentation.

 

For example:

 

a)      Thermal technology

Dogs Trust contacted Innovative Physics Ltd for their thoughts on the use of thermal technology to detect hidden puppies. They provided the following statement:

 

“Innovative Physics Ltd, believes the solution to this problem lies in an understanding of the… needs – an understanding of how and where puppies may be secreted, for instance individually or in litters.

 

Broadly speaking the task comes down to the sensitivity of the detector and the ability to process the signal effectively.

 

A number of industries today have parts or all of the technology available to solve the above. We have knowledge of such technologies in the Defence market – for instance detectors in the nose cones of missiles are infra-red detectors, in the Homeland Security market you will find the overlay of sensor modalities to eliminate false positives – finally in the Medical market in imaging there are many noise supressing and signal enhancing algorithms used. All the above are known to Innovative Physics.

 

The thermal imaging detectors are available today to detect very small heat signatures, thus the solution is more evolutionary rather than revolutionary in terms of the detection of the target. The key to detecting a single puppy comes down to being able to distinguish a small heat signal in a cluttered image. This would lead to the use of enhanced image processing, the use of neural networks and signal processing using Artificial Intelligence to highlight a suspect smuggled animal could be used – enhance the “puppy signature” vs the clutter of other signatures. These techniques are successfully used for noise suppression in other applications like industrial inspection for instance. Contrast imaging techniques could also be used.

 

Another thought is that a multi sensor approach could be utilised – combining different modalities, for instance, highly sensitive microphones looking for heartbeat or whimpering signatures overlaid with thermal imaging and using pattern recognition to look for tell-tale combinations. These techniques are used in applications like radiation imaging.

 

In summary – the evolution of technology can be made to solve the described problem.”

 

b)      Sniffer Dogs

Through discussions with a search dog handler, we believe that sniffer dogs could also be used to detect puppies in cars. Given that there are already dogs trained to find tobacco, drugs, explosives, firearms, live humans and trafficked animals, they could also be trained to find other dogs. We understand that sniffer dogs may not detect every case, however if they can detect most cases, we believe this would significantly improve the chances for any puppies that transporters attempt to illegally import into Great Britain and, importantly, that sniffer dogsthis would act as a deterrent to these criminals.

 

4.4.            No traceability of animals entering Great Britain

 

Dogs Trust has strong concerns about the lack of information recorded about dogs entering Great Britain. One concern is that there has been a change in the way official data on the number of dogs travelling to Great Britain is collected. Previously, when dogs entered Great Britain via PETS, their country of origin was recorded. This allowed us to monitor trends such as the huge increase in the number of dogs travelling from Hungary and Lithuania. Defra’s response to parliamentary question 257572 states:

 

“APHA stopped recording the country of origin of compliant animals imported under the scheme in 2016. Detailed data on non-compliant pet animals, including the country in which the paperwork accompanying the animal was issued, is always collected…

 

Collecting the country of origin data for compliant pet imports has not proved useful in deterring puppy smuggling as it is essentially collecting information on legal movements…”

 

However, the available evidence suggests that not all imports under the Pet Travel Scheme are legal movements. For example, official Government figures show that no dogs were imported commercially from Lithuania to Great Britain under the Balai Directive in 2016 and only two in 2015, yet during our third investigation we found Lithuanian puppies openly for sale on the internet in Great Britain. Given that Government figures also show that 2,271 dogs were imported into the UK from Lithuania via the Pet Travel Scheme in 2015, and 726 in 2016, we have reason to believe that the PETS figures are not only legal imports. Whilst the collection of data on the country of origin may not directly deter puppy smuggling, it is useful for monitoring trends and developments in the trade. We strongly recommend that the Government reverts to collecting this data as soon as possible.

 

There is also currently no requirement to record the microchip numbers or the age of dogs entering the UK. Dogs Trust has long called for a centrally accessible database to log pets’ microchip numbers, their age and date of entry into Great Britain. For non-commercial movements, although pets are travelling with a passport, there is no traceability of that animal entering GB, in terms of when it entered. This information would be critical if there were an outbreak of disease to help identify the level of risk, based on the incubation period of the disease. i.e. a dog that entered GB 6 months ago is going to be at much lower risk of carrying rabies than one which entered 6 weeks ago. A centrally accessible database logging dogs’ microchip numbers, and date of entry, at the point of entry into the country would help welfare organisations to undertake a risk assessment for any stray animals coming into their care  and, in the aforementioned event of a disease outbreak it would enable control measures to be most effective. To demonstrate the importance of knowing the source of a disease outbreak, take, for example, the 2001 outbreak of foot-and-mouth disease. More than 2,000 cases were recorded, it took nine months to bring foot-and-mouth under control, and yet the source of the virus remains unknown with it being impossible to trace exactly how it arrived in the UK. In 2007, a further outbreak showed the lessons learned from that in 2001. A case was confirmed in cattle on a Surrey farm, traced to a faulty drainage pipe at a nearby research facility where the virus was being used in the manufacture of animal vaccines. The scare provoked an immediate robust response and the outbreak was contained[7].

 

When considering the lack of traceability of puppies entering Great Britain, it is also worth noting that Dogs Trust’s fourth investigation found evidence of puppies from an unlisted Third Country being provided with EU passports, largely from Bulgaria and Romania, and brought into EU Member States for sale. Here they essentially become ‘EU-bred dogs’ and are free to be sold on throughout the EU, their original country of birth long forgotten.

 

For the purposes of the pet travel system in the EU, unlisted Third Countries are those, such as Serbia, that have not been accepted for listed status because of less robust veterinary or administrative systems, higher rabies incidence, or because they have never applied. While Serbia is negotiating for EU membership and enjoys close geographic proximity to several EU Member States, in animal transportation and pet travel terms it is considered an unlisted Third Country (due to inadequate methods to treat the prevalence of diseases which pose a danger to animal and human health).

 

Before we launched our fourth report, we had been aware, through discussions with enforcement agencies, of some cases of underage Serbian puppies which had been illegally landed in Great Britain. Given our more stringent rules for importing dogs from Serbia, we wanted to establish the reality of this trade and to investigate the nature and scale of it. We met with eight breeders/dealers from Serbia. Some of the breeders were full scale commercial breeders whilst others were smaller breeders with one or two breeding bitches. We found that it was staggeringly easy to obtain Serbian puppies with EU passports. All large-scale commercial breeders and all bar one of the small-scale breeders included in the investigation offered to obtain EU passports for puppies. One Serbian vet sold our investigators two Bulgarian passports and microchips without even seeing the puppies. A breeder also offered to sell our investigators 10-week-old puppies. If the rules for importing dogs from Serbia to an EU country are met, puppies should be at least seven months of age before they can legally travel. However, for an additional payment they could get Hungarian passports for the puppies which would be pre-filled with the vaccination and vet signatures – the breeder would simply fill in the details of the puppy such as its breed and date of birth.

 

These findings further demonstrate the need for increased cooperation with veterinary regulatory authorities in the countries from which puppies are imported into Great Britain, to crack down on vets supplying fake passports. The UK’s Chief Veterinary Officer has previously written to veterinary counterparts in Central and Eastern European countries, but more work is needed in this area.

 

Through Dogs Trust’s work as founder of the EU Dog & Cat Alliance, we have also been calling for an EU Action Plan to tackle illegal companion animal movement across Europe, involving key stakeholders including the European Commission, European Parliament, Members States and relevant Third Countries, including enforcement agencies and border and veterinary authorities.

 

4.5.            Inadequate penalties for those caught illegally importing dogs

 

To enhance border controls, Dogs Trust urges the Government to introduce more severe punishments for those caught illegally importing dogs into Great Britain. The current maximum sentence under the Order is imprisonment for a term not exceeding three months. Given the animal health and welfare risks associated with offences under this Order, we consider this to be far too low – especially when it is considered that reductions can be given for early guilty pleas as well as the possibility to give suspended rather than custodial sentences.

 

In our report ‘Puppy Smuggling: The Scandal Continues’ it was estimated that the minimum annual turnover for a trader selling 160 puppies per year could be over £100,000. Also, and as mentioned previously, Dogs Trust has rehomed around 1,000 dogs that have been seized at the border through our Puppy Pilot scheme. If we assume an average value of £1,000 per puppy, these dogs would have a street value of £1million. Furthermore, an HMRC taskforce was set up in October 2015 after animal welfare groups expressed concerns that puppies were being reared on a mass scale and sold illicitly in the UK. The taskforce has recovered £5,393,035 in lost taxes from 257 separate cases since its formation[8].

 

It is clear there are huge sums of money to be made from this illegal trade, yet the penalties currently available under the pet travel legislation are totally inadequate and there is very little risk of punishment deterring the criminals involved. Despite the intelligence gathered through the Puppy Pilot scheme, only two prosecutions have been taken forward and these both resulted in a fine rather than a custodial sentence.

 

Currently, it is difficult to take prosecutions forward when puppies are seized and Trading Standards do not have a UK address for the trader. Whilst not a solution, we believe that the introduction of Fixed Penalty Notices would help to address this by enabling on the spot fines to be given to traders. Fixed Penalty Notices could, for example, be given for offences such as giving a false declaration that the animal is being moved as a pet, or for moving an animal with a falsified pet passport. Fixed Penalty Notices should be introduced together with introducing further offences and increased penalties under the Non-Commercial Movement of Pet Animals Order 2011.

 

Dogs Trust urges the Government to introduce Fixed Penalty Notices and increase the penalties under the Non-Commercial Movement of Pet Animals Order 2011 to better reflect the seriousness of these offences.

 

4.6.            Trade in Animals and Related Products Regulations 2011 (TARP)

 

Whilst looking at the issue of checks on non-commercial movements of pet animals, it is worth noting that there has also been an increase in the number of dogs commercially imported into Great Britain. Under the legislation for commercial movements, the Trade in Animals and Related Products Regulations 2011 (TARP), checks on consignments are only required to be undertaken at the place of destination but at present these checks are carried out on less than 10% of consignments. Therefore, it’s very possible that this legislation could be used to illegally import puppies, given that no checks are carried out at the ports. By improving the enforcement of non-commercial legislation, there is a risk of traders shifting towards the commercial legislation with even less stringent checks, and therefore this also needs addressing.

 

It should also be considered that when the ban on third party sales of puppies (under six months) comes into force in April 2020, only dogs over the age of six months should be transported for sale via TARP. However, dogs that are 15 weeks or older will still be allowed to travel via these regulations if the purpose is for rehoming. As there is currently no regulation of rehoming activities in the UK, and post import checks only take place on less than 10% of consignments, Dogs Trust is concerned that third party sellers could continue to use TARP to import puppies for commercial reasons. For these reasons Dogs Trust has also long been calling for regulation of rehoming activities and we go into more detail about this in our answer to question 4.

 

Dogs Trust urges the Government to introduce checks on commercial imports upon entry to Great Britain. These should, as per our recommendations for the Pet Travel Scheme, be carried out by a Government agency and include visual checks of consignments, as well as out-of-hours and weekend cover at the ports. This would circumvent the current abuse of post-import checks; however the new measures should be introduced in a way that does not mean dogs are held for long periods of time at the ports whilst checks are undertaken.

 

4.7.            To summarise, our recommendations for immediate action include:

 

  1. Q3: 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?

 

Whilst the Government can take the immediate actions outlined in our response to question 2 to tackle the illegal importation of puppies into Great Britain, as pet travel is currently governed by EU legislation, Dogs Trust also has recommendations for post EU exit action, namely:

 

5.1.            Reintroduction of the requirement for a rabies antibody titration test before entry into the UK

 

It is well established that not all animals mount an adequate immune response following vaccination against rabies. Mansfield et al. 2004[9] found that 4.12% of dogs and 2.85% of cats tested failed to demonstrate sufficient antibodies against the rabies virus. This study also found that dogs less than six months old had a significantly higher chance of failing a blood test. Klevar et al. 2015[10] showed that a significant proportion (53%) of imported rescue dogs from Eastern Europe failed to demonstrate a sufficient antibody level. Moreover, 41% of the dogs had woefully inadequate antibody levels. We therefore recommend the reintroduction of rabies blood testing before entry into the UK – protecting the UK from the risk of rabies. In our answer to question one we explained that there is a lack of traceability of all dogs being bred and sold in the UK. Given that we do not have an accurate picture of the density and distribution of pet dogs within the UK, it is particularly important that there are robust measures in place to prevent the introduction of rabies here, as the spread of this disease would be difficult to predict and control.

 

5.2.            Reintroduction of a required wait period in line with the incubation period of rabies

 

Under Regulation (EU) No 576/2013 dogs, cats and ferrets entering a Member State from a Third Country or Territory must undergo a rabies antibody titration test. The validity requirements are for the blood test to be carried out at least 30 days after the date of vaccination and for there then to be a 3 month wait period before the pet animal is moved between countries. The average incubation period for naturally occurring rabies in dogs, cats and ferrets varies depending on the reference, with some sources stating 3-8 weeks (Greene, 2012[11]) and others stating 3-12 weeks. To minimise the risk of disease we would support a wait period after the rabies blood test before entry into the UK, which is in line with the incubation period of rabies. Such a wait period would also make it easier to differentiate between adult dogs and those that are too young to legally enter the country. Therefore, by increasing the age at which puppies can enter the country, this would also help to clamp down on the trade.

 

5.3.            Reintroduction of the requirement for dogs and cats to be treated against ticks before entering the UK

 

We recommend that a requirement is reintroduced for dogs and cats to be treated against ticks before entering the UK, to prevent parasites such as Babesia canis and Ehrlichia canis being established into the UK. This could be based on the previous requirement for tick treatment prior to 2012, where pets had to be treated for ticks 24-48 hours before travel. A recent surveillance study of ticks infesting domestic dogs across the UK highlights the importance of appropriate treatment against ticks for dogs travelling outside of the UK. It found that 77% of dogs which had travelled were carrying attached ticks. The importance of tick treatment is also highlighted by the cluster of cases of canine babesiosis which were reported in Harlow and Romford in 2016, as well as more recently in Hertfordshire in 2017. It is further highlighted by the importation of a Hyalomma lusitanicum tick into the UK in 2016, a type of tick which can carry and transfer Crimean-Congo haemorrhagic fever (CCHF) virus to humans.

 

5.4.            Shortening the window for tapeworm treatment before entry into the UK

 

We support the continued requirement for Echinococcus multilocularis tapeworm treatment before entry into the UK but recommend shortening the treatment window from 24-120 hours to 24-48 hours, as previously required. Dogs Trust has two key concerns about the current treatment window:

 

  1. The period within which treatment must be administered before travel is too long and therefore the risk of reinfection after treatment and before travelling is higher. Dogs Trust therefore recommends shortening this window so that treatment must be administered by a veterinarian within a period commencing not more than 48 hours and ending not less than 24 hours before the time of arrival at the end destination.

 

  1. Within the current treatment window, it is possible for a dog, after being treated for tapeworm, to travel from a country where Echinococcus multilocularis is not present to a country where it is, then back again, as long as it is within that 120 hour window following treatment e.g. to France and back for the weekend. This is of serious concern to countries that do not have Echinococcus multilocularis present. This could be addressed by a mandatory requirement for treatment to be administered before leaving the endemic country.

 

Dogs Trust does not consider that re-introducing the above requirements would be too onerous on people travelling legally with their pets, as the requirements were the same, if not stricter, prior to the changes to PETS in 2012. Furthermore, once a dog has had a rabies vaccine and successful titre (blood) test, if the owner keeps up to date with vaccinations, they won’t need to repeat the wait period before each time they travel. Defra have already issued pet travel advice twice ahead of Brexit, encouraging owners to contact their vets at least 4 months before travelling to ensure their pet can travel. If similar repeated advice was to be issued on any new legislation, anyone travelling regularly with their pet should be prepared for these changes in any case. Whilst measures such as reintroducing tick treatment may mean pet owners incur additional costs, this is essential to protect the health of the dogs being transported. The UK could also introduce tightly controlled derogations under any updated pet travel legislation to account for military dogs or assistance dogs that need to travel in case of emergencies.

 

In addition to the above measures, we also recommend:

 

5.5.            Reducing the number of dogs allowed to travel per person

 

Dogs Trust urges the Government to reduce the number of dogs allowed as a non-commercial movement.  The current PETS rules allow up to five pet animals to be moved by one owner or authorised person under the scheme. However, Dogs Trust’s puppy smuggling investigations found that traders were moving up to five animals at a time as a way of side-stepping the additional requirements of the commercial movement legislation. We would therefore recommend that this limit is reduced. For puppies, we recommend that a maximum of two dogs under six months can be moved at a time; whilst families may wish to travel with a puppy it would be rare for them to do so with more than two puppies. For all dogs, including adult dogs, we recommend an overall limit of three dogs. Murray et al. (2010[12]) estimated that the majority of UK households owning dogs had only one dog (73.3%), 18.9% owned two dogs and 4% owned three dogs. Therefore, by setting the limit at three dogs up to 96.2% of families would be able to travel with their pet dogs. The primary impact of this change would be on those abusing PETS, rather than pet owners using the scheme for its intended purpose. For families wanting to travel with four or five dogs, we would suggest that a very tightly regulated exemption could be introduced. We would be happy to work with the government on the wording of such an exemption.

 

5.6.            Introduction of a centrally accessible database for logging of microchip details

 

As previously mentioned, there is also currently no requirement to record the microchip numbers or the age of dogs entering the UK. Dogs Trust has long called for a centrally accessible database, linked to EU database Europetnet, to log pets’ microchip numbers, their age and date of entry into Great Britain. For non-commercial movements, although pets are travelling with a passport, there is no traceability of that animal entering GB, in terms of when it entered and if it did so legally. This information would be critical if there were an outbreak of disease to help identify the level of risk based on the incubation period of rabies. i.e. a dog that entered GB 6 months ago is going to be at much lower risk of carrying rabies than one which entered 6 weeks ago. A centrally accessible database logging dogs’ microchip numbers, and date of entry, at the point of entry into the country would help welfare organisations to undertake a risk assessment for any stray animals coming into their care  and, in the aforementioned event of a disease outbreak it would enable control measures to be most effective. Through our work as founder and secretariat of the EU Dog & Cat Alliance, chaired by Dogs Trust Ireland, we have long been calling for a system for the identification and registration of dogs and cats, which is accessible across the EU, as there is currently very little traceability when animals are moved over borders.

 

5.7.            Introduction of tighter controls for dogs travelling for events and dog shows

 

Currently the Pet Travel Scheme allows a derogation for owners to enter the country with more than 5 dogs at a time if this is specifically to attend dog shows e.g. Crufts if they present a flyer for this. However, without full traceability of dogs entering and leaving the country, Dogs Trust has concerns that the Pet Travel Scheme could be used in this way as a cover to bring dogs in for commercial sale. We recommend the Government reviews these rules around travel for dog shows. We do not consider presentation of a flyer sufficiently robust.

 

5.8.            To summarise, our recommendations for action post-EU exit include:

 

  1. Q4: Will the ban on 3rd party sales of puppies:

 

(i) encourage buyers to source puppies responsibly;

 

Dogs Trust welcomes the ban on third party sales of puppies and kittens that will come into force in April 2020 and detailed in our response to the Government’s 2018 consultation the key benefits of the ban. We remain concerned that the introduction of a ban will not be sufficiently robust if it is introduced as a single measure, given the huge profits to be made in selling puppies, the great lengths that unscrupulous sellers will go to evade the law, and the limited penalties for illegal activity. It is for this reason that we urge the Government to ensure the ban is a success by introducing it as part of a comprehensive package of coordinated measures and with an effective behaviour change campaign.

 

6.1.            In addition to the ban on third party sales, measures should include:

 

 

Regarding encouraging buyers to source puppies responsibly, purchasing a dog is often an emotional decision and we are aware that even when owners have concerns about a breeder or seller operating illegally, they will still go ahead with buying puppies in order to ‘rescue’ them from poor conditions. In addition, the Great British Puppy Survey 2016[13] found that 71.9% of owners whose puppy was sick or died shortly after purchase took no action. We therefore cannot rely on purchasers to report. For this reason, intervention before prospective buyers go to see a puppy is key.

 

Furthermore, we are aware of breeders using stooge bitches (i.e. using a bitch of the same breed as ‘mum’ when she is not) and/or renting homes to purposefully dupe unsuspecting purchasers into thinking they are seeing the puppy with its mother in the (home) environment it was bred in. For example, a case was reported by the Sun[14] in which a cottage was used as a front to give buyers the false impression the pups were born from family pets, when in fact they’d been bred in appalling conditions on a farm just a stone’s throw away from the address given to potential customers.

 

We previously mentioned in response to question 1, that early in 2018 a litter of ten French Bulldog puppies aged approximately three to four weeks were seized after being discovered heavily sedated in a car travelling from Poland. The pups were found hidden in the hollow of the back seat under a pile of blankets and under one of the front seats. Also in that car, in plain view, was an adult female French Bulldog (with a pet passport). She was suspected of being the mum, but the assessing vet doubted this as she had no milk. There were signs that she had had at least one previous litter, so the suspicion was that she was being brought across to act as a fake mum since buyers increasingly ask to see the pups with their mum. The smugglers saw the pups as a disposable commodity and so did not pay the necessary quarantine fees to get them back. However, they desperately wanted the adult female dog back, presumably for future breeding.

 

Even if the new approach involves requiring a seller to show the puppy with its ‘mother’ there is no guarantee that the ‘mother’ displayed at the time of the buyer meeting the puppy is related to the puppy and no easy way for the buyer to definitely verify this or if the ‘home’ environment is the actual place and conditions in which their puppy was bred. Another recently identified trend has been the setting up by a stud dog owner of individual bitches across a network of houses, as a means of producing multiple litters whilst evading the licensing system. This is known as satellite puppy farming, with the focus of those involved being on profit, not welfare.

 

For the above reasons, and as we outlined in our response to the Government’s consultation in 2018 on a ban on the third party selling of puppies and kittens, we recommended that a ban should be supported by a campaign that understands and seeks to influence behaviour change. If it is to be effective it is necessary that the campaign is more than educational, with the focus on long term changes to how people buy a puppy. We do not believe an educational campaign will be sufficient in accomplishing this outcome, as has been seen with other similar campaigns, including encouraging buyers to buy responsibly and urging them to always see the puppy with its mother.

 

Our aforementioned research projects, “UK Pet Dog Population Project: Movement and Sources” and “UK Dog Acquisition Project: Demand and Owner Behaviour”, may be useful to this and we would welcome further discussions, regarding the projects, with the EFRA Committee and the Government. A paper by Katrina Holland of Dogs Trust’s research team, ‘Acquiring a Pet Dog: A Review of Factors Affecting the Decision-Making of Prospective Dog Owners’ may also be useful as it looks at the various factors that might influence prospective owners’ motivators and behaviours[15].

Lastly, we strongly recommend that the ban on third party sales, once it comes into effect, is monitored for effectiveness and properly reviewed alongside the full Licensing of Activities Involving Animals Regulations 2018.

 

(ii) reduce illegal puppy smuggling?

 

Whilst the introduction of a ban on third party sales is intended to prevent puppies and kittens being transported across England to be sold in establishments or premises other than the one in which they have been bred, unless measures are also taken to strengthen and tighten the regulation and enforcement of the Pet Travel Scheme, this measure will not act preventatively for all puppies and kittens for sale in England.

 

The drive to make a profit, even in the face of legislation, should not be underestimated particularly when there are significant gains to be made and paltry penalties. Through our work on the Puppy Pilot, and via the SSPCA’s work on Operation Delphin in Scotland, which focuses on the illegal importation of puppies from Ireland, we are aware of the ever-evolving tactics of importers. It is clear whilst such popular, desirable breeds of dog are sought by consumers, and ethical breeders in the UK cannot meet this growing demand, dishonest breeders will breed dogs for increasing profits and evade the law to get these dogs to market. Sadly, we are well aware that it is not that supply must meet demand; supply will meet demand due to the profits that can be made by unscrupulous dealers.

 

We mentioned in our response to question 2 some of the evolving tactics transporters use to adapt their practices and evade the law. In addition to these, and in relation to a ban on third party sales of puppies, there has been a very worrying development in the importation of heavily pregnant bitches, with the idea being that their puppies can be sold at a younger age as ‘UK born’. One such example is Lola, a heavily pregnant French Bulldog bitch that was transported from Lithuania. Lola was seized due to welfare concerns as it is illegal to transport a bitch in the last 10% of her gestation period. Lola was discovered in a crate in a vehicle by customs officers at Dover. The temperature in the back of the van was unregulated and it had no ventilation. Lola was taken to a Dogs Trust rehoming centre where she gave birth to four puppies, but sadly two of these were stillborn.

 

There are also a number of loopholes which illegal importers could continue to exploit when a ban on third party sales comes into effect, which is why we have consistently called for the ban to be introduced as part of a comprehensive package of coordinated measures. As part of this package, action is therefore also needed in these areas, namely:

 

6.2.            Regulation of rehoming activities

 

Dogs Trust has long been calling for the introduction of regulation of animal welfare establishments (AWEs) as a necessary measure to ensure the success of a ban on the third party selling of puppies and as a means of protecting the welfare of animals within these establishments. Without the introduction of regulation of AWEs we are deeply concerned that the sector could be used as a cover by third party sellers trying to continue their business after the introduction of a ban on their trade.

 

Currently, with no legislation in place, anyone can set themselves up as an AWE, or pose as one, with no regulation of welfare standards. For example, in 2018, in our role as Chair of the Pet Advertising Advisory Group (PAAG), we were made aware of an advertiser on a classified advertising website offering puppies for sale but posing as a rescue centre, using the name of a national rehoming charity. From further investigation it was apparent that the advertiser was unrelated to the charity. Whilst this case was brought to our attention by a member of the public who was concerned that the advertiser was not a rescue organisation having contacted them regarding the puppies, it was easy to take action because the advertiser had chosen to use the name of a national charity. It is clear to see how much harder this might have been to prove if the advertiser had posed as an unknown ‘welfare’ organisation, with the buyer unable to verify their concerns with anybody other than the seller.

 

As another example, it was reported in February 2019 that a bogus dog rescue organisation, Canine Rescue Carlow, was set up in Ireland, by someone who was lifting strays off the street to be used as breeding bitches[16].

 

In addition to our concerns that the sector could be exploited by third party sellers, worryingly there is little to proactively safeguard the welfare of animals involved in the rehoming sector, which can have knock on effects when they are rehomed. We are aware of cases in which animal welfare concerns have been identified in rehoming organisations. A ban on third party sales could potentially compound such issues if the unintended consequence was to create an incentive to use rehoming as a front for selling dogs.

 

We therefore remain deeply concerned that without regulation of AWEs, a ban on the third party selling of puppies and kittens will not be sufficiently robust because this lack of regulation would result in a loophole in the dog and cat trade, allowing anybody wishing to continue their third party sales trade to disguise it as rehoming activity, facilitated by the fact that nobody is required to inspect the welfare of the animals involved.

 

We strongly advocate regulation of AWEs and believe it is essential this is introduced simultaneously with the introduction of a ban on third party sales to prevent the sector from being exploited by third party sellers.

 

6.3.            Ability of local authorities to tackle illicit unlicensed pet sales activity

 

A 2016 report[17] by Blue Cross explored Local Authorities’ ability to enforce the unlicensed trade of animals. Their investigation found that 486 investigations were made into premises suspected of needing a licence throughout 2015 across 378 of 380 Local Authorities in England, Wales and Scotland. Whilst this averages out to two cases per Local Authority, 44 per cent of the Local Authorities stated they conducted no investigations at all in 2015. When questioned on why this was the case, many stated that they lacked the resources to identify and investigate sellers operating solely online.

 

It is also worth noting further findings from Dogs Trust’s project “UK Pet Dog Population Project: Movement and Sources”. The project compiled evidence regarding the number of breeding bitches and licensed breeders within all GB Local Authorities from 2006 - 2016. The research found, that in Carmarthenshire in 2016, there were 2063 breeding bitches and 77 licensed breeders. Within the same Local Authority, there were 2.5 inspectors (where inspections of dog breeding facilities were partly or wholly their role). This equates to 1 inspector being responsible for assessing the welfare standards of 30 breeding establishments and 825 breeding bitches within a single year. It is clear that Local Authorities do not have adequate resources to inspect these kind of establishments, while ensuring appropriate animal welfare standards are met.

 

Dogs Trust’s contact with Local Authority inspectors has also confirmed that a huge enforcement challenge is in identifying breeders and sellers that are operating without a licence. We strongly believe that enforcement can best be improved by ensuring that anyone breeding or selling dogs is captured within a system of registration and licensing, to bring them onto the radar of Local Authorities. As mentioned previously, we recommend the Government introduces a requirement for anyone breeding or selling a litter of puppies to be registered and anyone breeding or selling more than one litter of puppies to be licensed, to provide full traceability across the breeding and sale of dogs.

 

Dogs Trust also strongly believes that Local Authority inspectors need further training in order to be able to effectively enforce legislation relating to animal health and welfare. In the impact assessment for the Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations 2018[18] it is stated that Local Authorities only need two hours of training to be able to fulfil the requirements of the new Regulations. We remain concerned that this will not support Local Authority officials tasked with enforcing the Regulations, meaning that inspections of animal establishments will continue to be conducted by those with no or limited knowledge of animal welfare.

 

We strongly believe that anyone inspecting animal establishments should be qualified in animal welfare and continue to recommend that the Government develops a central unit of appropriately trained inspectors which can be utilised by Local Authorities to carry out inspections of animal establishments. This inspectorate unit would have to have no profit-making commercial interests in order to ensure that the goal is not on profit but on animal welfare. Licence fees should be set by Local Authorities to allow full cost recovery for this.

 

  1. Q5: How could demand in the UK for puppies be better met by domestic breeding?

 

Looking at demand in the UK for puppies in the first instance, as explained in our answer to question 1, the Pet Food Manufacturers’ Association (PFMA) estimate that there are around 9 million dogs in the UK[19]. With an average lifespan of approximately 12 years, it can be estimated that there is now a demand for approximately 750,000 dogs per year. However, there are limitations with this estimate and the true demand for dogs may differ from this.

 

Despite the high demand for dogs in the UK, Dogs Trust cares for around 15,000 dogs every year in our rehoming centres, many of which have been handed over to us because the owners were not fully aware of the challenges of owning a dog. We strongly believe that more needs to be done to raise awareness of the challenges of owning a dog and that doing so is a lifetime commitment. We also need to raise awareness with buyers that if they are going to get a dog this should not be rushed and, if done responsibly, it may take some time. For example, on average a breeder on the Kennel Club’s Assured Breeder Scheme will have 1 litter per year. With there being around 4,300 Assured Breeders, this still only equates to between 21,500-25,800 dogs, based on an average of 5-6 puppies per litter. It is important, in a world where it has become far too easy to buy a dog online at a click of a button, that buyers understand that if they want a responsibly bred dog, they must be prepared to wait for it.

 

Furthermore, it is crucial that buyers are made aware of the health conditions suffered by what are considered ‘desirable’ breeds i.e. breeds that are most often illegally imported, such as French Bulldogs and English Bulldogs. Breeds such as these which have been bred to have flattened faces have been found to greatly increase the risk of debilitating lifelong respiratory conditions, such as Brachycephalic Obstructive Airways Syndrome, leaving dogs chronically short of breath. Great Britain remains a particular target for dealers of these puppies because of the huge prices people are willing to pay for them and the relative cheapness with which they can be produced in certain countries. The breeders and dealers involved are rarely concerned with good breeding practices so it is essential that we continue to increase awareness of the health issues these breeds suffer from and that buyers look beyond what are considered appealing appearances.

 

Looking next at how this demand is met by domestic breeding, we are aware that concern is often expressed about large scale breeders; however small-volume unlicensed breeders are totally unregulated. Although the Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations 2018 has reduced the statutory licensing threshold for dog breeders from five to three or more litters per year, breeders producing fewer than three litters per year generally continue to fall outside of the licensing system (unless they meet the business test) and are therefore more likely to be operating under the radar. It’s important to note that welfare issues can occur in breeding establishments, regardless of their size, hence the importance of a) adequately trained Local Authority inspectors with the skills and knowledge to assess welfare standards and b) an improved, robust registration and licensing system as outlined above.

 

Through this approach, it is important that animal welfare standards are brought up to an acceptable standard in all animal establishments, both large and small, and that there is a process in place for robust inspections. Until this happens, we cannot think about expanding supply from large scale breeders.

 

  1. Additional comments

 

8.1.            International rehoming of dogs

 

Whilst this inquiry focuses on the non-commercial movement of pet animals, it is also worth noting our concerns about importing street dogs from abroad for rehoming purposes, as it ties into some of the issues already mentioned in our response to this inquiry, including the responsible sourcing of dogs by the UK public and ensuring we prevent the spread of disease.

 

Dogs Trust is aware of increasing numbers of dogs entering the UK from abroad for rehoming. From a disease perspective this is a concern, particularly with regards adult dogs. So-called non-endemic diseases, i.e. those found in mainland Europe that we don’t have in the UK, are encountered. It is therefore important that the history of where a dog came from is passed on, particularly to vets. Furthermore, one of these diseases, leishmaniasis, is a particular challenge in that it generally requires lifelong medication, i.e. it is managed rather than cured, and is potentially zoonotic, although we do not currently have the sandfly vector in the UK. This infectious disease, which is not present in the UK, is transmitted by sandflies and, if left untreated, can be fatal. However, symptoms can take years to develop. In January 2019, the Vet Record[20] reported the first case of canine leishmaniasis in the UK without a history of travel to an endemic area, and most likely represents a case of dog-to-dog transmission. The paper could not rule out the possibility that leishmaniasis had adapted to a different vector. According to the report, the patient had been in the owner’s possession since a puppy, had no travel history outside of the UK and had never received a blood transfusion or been used for breeding. However, another dog in the household that had been imported from Spain had been euthanised six months previously due to severe leishmaniosis.

 

Dogs Trust also has concerns about dogs being imported from overseas from a behavioural perspective. A number of these dogs are free roaming (stray), some of which may struggle to adapt to a UK home environment. In short, a free roaming dog is used to making its own decisions. Those choices are removed when it enters a home environment and may be a source of great stress. Therefore, behavioural assessment and ongoing support are important.

 

Given that there’s no regulation of rehoming activities in the UK, there is also a concern that anyone can set themselves up as a rehoming organisation or sanctuary with no licensing or inspection necessary to ensure appropriate animal welfare standards are being met and, in the case of international rescues, that the right support is being offered to adopters.

International rehoming of dogs is a practice which is not sustainable in the long term, as it only provides interim measures rather than addressing the root causes of companion animals living in shelters or being homeless in the country of origin.

 

Dogs Trust believes it is far more effective to work preventatively in the country of origin to minimise the need for rehoming animals abroad, for example, through neutering and educational campaigns

 

Should a situation arise when it is in the animal’s best interest to be rehomed in another country and, after all other domestic options have been exhausted, it is crucial that international rehoming is done legally. International rehoming is classed as a commercial movement and should therefore be carried out following the Balai Directive (Directive 92/65/EEC) as opposed to the Pet Travel Scheme.

 

8.2.            Breeding for extreme conformations

 

We mentioned previously that common breeds illegally imported into Great Britain include French Bulldogs, English Bulldogs, Dachshunds and Chow Chows, and that more needs to be done to make buyers aware of the health conditions suffered by these ‘desirable’ breeds. Alongside increased public awareness Dogs Trust strongly believes that legislative change is needed to tackle this issue, as a fundamental flaw with the Animal Welfare Act 2006 (AWA) is that it does not apply to animals while in foetal or embryonic form. This means that the progeny of animals are not protected by the AWA. As such, it cannot prevent welfare issues relating to dog breeding.

 

Puppies bred with little regard to their conformation or inherited defects may go on to experience health problems for a significant part of their lives. For example, research in 2009 identified that the top 50 most popular breeds of pedigree dogs in the UK are predisposed to over 300 inherited disorders (Asher et al., 2009[21]). Another paper identified that each of the top 50 dog breeds had at least one aspect of their conformation predisposing them to a disorder (Summers et al., 2010[22]). An independent study funded by Dogs Trust (Packer et al., 2015[23]) concluded that breeding for short muzzle length leads to an increased risk of Brachycephalic Obstructive Airway Syndrome in dogs, with risk increasing as the morphology becomes more exaggerated. Dogs Trust would be pleased to provide further evidence to support our position that breeding dogs must be selected on their temperament and physical and genetic health.

Dogs Trust firmly believes that there is sufficient evidence to support the need for such regulations to be made to protect the welfare of breeding dogs and their offspring. The best means of addressing this issue is to impose a duty on the person which takes effect prior to mating. This duty could be phrased as: "any person who selects a companion animal for breeding shall be responsible for having regard to the anatomical, physiological and behavioural characteristics which are likely to put at risk the health and welfare of either the offspring or the female parent". The offence would therefore focus on whether the person responsible had adequately fulfilled this duty prior to mating and would apply to anyone responsible for a bitch which becomes pregnant. The means by which this could be achieved in England is by regulations introduced under the authority of the AWA Section 12 (1), which provides:

The appropriate national authority may by regulations make such provision as the authority thinks fit for the purpose of promoting the welfare of animals for which a person is responsible, or the progeny of such animals.

This measure would (a) give a legal significance to the issue; (b) make breeders accountable for their actions; and (c) enable repeat offenders to be pursued through the courts.

 

September 2019

 

 

 

[1] Murray, W. J., Browne, M. A., Roberts, A., Whitmarsh, T. J. and Gruffydd-Jones, J. K. (2010). Number and ownership profiles of cats and dogs in the UK. Veterinary Record 166, 163-168

[2] https://www.dogstrust.org.uk/puppy-smuggling/ps-media

[3] https://www.pfma.org.uk/pet-population-2018

[4] https://www.thekennelclub.org.uk/registration/breed-registration-statistics/

[5] https://www.bluecross.org.uk/sites/default/files/downloads/Unpicking%20the%20Knots%20report.pdf

[6] https://www.ornamentalfish.org/wp-content/uploads/Pet-Shop-Licensing-Report-2016.pdf

[7] https://www.bbc.co.uk/news/magazine-35581830

[8] https://www.bbc.co.uk/news/uk-48167134

[9] Mansfield, K. L., Sayers R., Fooks A. R., Burr, P. D. and Snodgrass D. (2004). Factors affecting the serological response of dogs and cats to rabies vaccination. Veterinary Record; 154:423-426

[10] Klevar, S., Høgåsen H. R., Davidson R. K., Hamnes I. S., Treiberg Berndtsson L., and Lund A. (2015). Cross-border transport of rescue dogs may spread rabies in Europe. Veterinary Record; 176:672

[11] Greene, C. E. (2012). Rabies and other Lyssavirus infections. In: Infectious diseases of the dog and cat, 4th Edition. Saunders-Elsevier, London, pp.187

[12] Murray, W. J., Browne, M. A., Roberts, A., Whitmarsh, T. J. and Gruffydd-Jones, J. K. (2010). Number and ownership profiles of cats and dogs in the UK. Veterinary Record 166, 163-168

[13] https://naturewatch.org/files/uploads/Great_British_Puppy_Survey_FINAL_1.pdf

[14] https://www.thesun.co.uk/news/uknews/9478447/mums-horror-cockapoodle-die-week-puppy-farm-scam

[15] https://www.mdpi.com/2076-2615/9/4/124/review_report

[16] https://www.irishmirror.ie/man-who-jailed-animal-cruelty-14044234

[17] Blue Cross, Unpicking the Knots: The case for a more cohesive approach to pet welfare legislation (2016)

[18] http://www.legislation.gov.uk/ukia/2018/31/pdfs/ukia_20180031_en.pdf

[19] https://www.pfma.org.uk/pet-population-2018

[20] https://veterinaryrecord.bmj.com/content/184/14/441

[21] Asher, L., Diesel, G., Summers, J.F., McGreevy, P.D. and Collins, L.M. (2009). Inherited defects in pedigree dogs. Part 1: Disorders related to breed standards. The Veterinary Journal 182 (2009) 402-411

[22] Summers, J.F., Diesel, G., Asher, L., McGreevy, P.D. and Collins, L. M. (2009). Inherited defects in pedigree dogs. Part 2: Disorders that are not related to breed standards. The Veterinary Journal 183 (2010) 39-45.

[23] Packer, R.M.A., Hendricks, A., Tivers, M.S., Burn, C.C. (2015). Impact of Facial Conformation on Canine Health: Brachycephalic Obstructive Airway Syndrome. PLoS ONE 10(10): e0137496. doi:10.1371/journal.pone.0137496