Written evidence submitted by Dogs Trust (PS0010)

 

November 2020

 

  1. About Dogs Trust

 

Dogs Trust is the UK’s largest dog welfare charity. We have a network of 20 rehoming centres across the UK – and one in Dublin – through which more than 14,300 stray and abandoned dogs were cared for last year. We invest substantial resources in information services, community outreach programmes, and education on responsible dog ownership.  Since Dogs Trust was founded in 1891 (formerly National Canine Defence League) we have always campaigned on dog welfare issues, and we played an instrumental role in the introduction of the Animal Welfare Act 2006.

 

  1. Executive Summary

 

 

 

 

 

 

 

 

 

3. Recommendations for Government action on puppy smuggling

 

The illegal puppy smuggling 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. Currently, both commercial and non-commercial pet movements are regulated by EU legislation. With the end of the EU Exit transition period fast approaching, the time is now for Government to act.

 

Our priority recommendations for the Government are:

 

 

We also urge the Government to:

 

 

 

 

4. The extent of the problem of puppy, kitten and other companion animal smuggling; and Government statistics on this issue (including their accuracy and timeliness)

 

4.1. Background

 

For six years, Dogs Trust has been lobbying Government for changes to the Pet Travel Scheme (PETS) after the EU harmonisation of the UK travel rules in 2012 led to a significant increase in underage puppies being imported into Great Britain for sale. The new rules enabled puppies as young as 15 weeks to obtain passports and travel to the UK when previously the minimum age had been 10 months. This means puppies can now enter the country when they are younger and more desirable to potential buyers than older dogs.

 

Unfortunately, these changes resulted in a drastic increase in the number of puppies entering Great Britain for sale. There was a 61% increase in the number of dogs entering Great Britain via PETS in the first year after the relaxation of the controls. However, the increase was even more significant when looking at individual countries. For example, there was a 780% increase in Lithuanian dogs travelling under PETS into Great Britain between 2011 and 2013.

 

Annual Pet Travel Scheme (PETS) figures for dogs travelling into Great Britain

2011 (before changes to PETS)

85,299

2012

139,643

2013

152,075

2014

155,444

2015

164,836

2016

275,876

2017

287,016

2018

307,357

2019

307,263

 

Popular, desirable breeds of dog such as French Bulldogs, English Bulldogs, Pugs, Chow Chows, Dachshunds, Maltese and Pomeranians are increasingly in demand. Ethical breeders in the UK are unable to meet this growing demand and so dishonest importers are able to sell dogs for increasing profits and evade the law to get these dogs to the UK market. The drive to make a profit, even in the face of legislation, should not be underestimated. The great lengths unscrupulous breeders and traders will go in order to sell puppies on to unsuspecting buyers are testament to the vast profits that can be made, with little chance of being caught and the penalties no deterrent.

 

 

4.2. Undercover Investigations

 

Since 2014, Dogs Trust has carried out four undercover investigations to demonstrate the abuse of the Pet Travel Scheme. Through our four undercover investigations, as well as intelligence from 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.

 

 

 

 

4.3. The Puppy Pilot

 

In December 2015, Dogs Trust established the Puppy Pilot to provide care and support for illegally imported puppies seized at the ports during their time in quarantine. By funding the care of these animals and supporting their responsible rehoming, enforcement agencies at the ports have been able to focus on seizures knowing the fate of the puppies is secure with Dogs Trust. To the end of September 2020, the Puppy Pilot had cared for and rehomed some 1,310 puppies. The total market value of these puppies is estimated to be over £2 million[2]. The puppies which have been seized are only the tip of the iceberg, as we have also uncovered significant issues with enforcement of the pet travel legislation.

Through our work on the Puppy Pilot, we are aware of the ever-evolving tactics of importers, facilitated via communicating with one another through online chat rooms. Since December 2015 examples of evolving tactics have included:

More than 1,310 puppies have been seized as part of the Puppy Pilot project, yet, despite the intelligence gathered, only two prosecutions have been taken forward. This is even more concerning considering many of the puppies are imported by repeat offenders.

Our work on the Puppy Pilot has also demonstrated significant issues with enforcement as there is not sufficient out-of-hours and weekend cover at ports by Government agencies, to enable puppies to be seized. Puppy smugglers are therefore easily able to enter the country by travelling outside of usual business hours.

 

4.4. Accuracy of Government Statistics

 

The Pet Travel Scheme statistics are based on data given to the Animal and Plant Health Agency (APHA) by the carriers (ferry companies, Eurotunnel, airlines etc.). We have been concerned about how robust this data is as it has previously varied in data supplied by the Government in response to Parliamentary Questions.

 

In April 2017, Defra responded to PQ number 70622 as follows:

 

Question: Pursuant to the Answer of 22 March 2017 to Question 66537, for what reason the numbers of dogs imported into the UK from each origin country, as presented in Annex A, do not add up to the number recorded on APHA's system of dogs entering the UK non-commercially under the Pets Travel Scheme, as stated in the Answer of 30 January 2017 to Question 62238.

 

Government response: Currently, the Pets Database holds information on pet movements into GB on approved routes gathered by transport companies. Since mid-2015 the Animal and Plant Health Agency (APHA) has been piloting a parallel system to establish the level of accuracy of data available from the Pets Database. This has identified that more dogs are travelling under the Pet Travel Scheme than previously indicated by the Pets Database data, and this number was presented in PQ62238. Based on this finding, APHA is now working on a new permanent system to capture accurately all the required data without placing an unrealistic burden on carriers.

The information that APHA has provided in response to PQ66537 is a true reflection of the information that is held on the Pets Database, as supplied by third parties.

 

Additionally, in 2017 the Government stopped recording the country of origin of dogs travelling under the Pet Travel Scheme. We believe this data is vital to understanding the key countries involved in the trade and any changing trends and were extremely disappointed by the decision to stop recording it.

 

One solution to the challenges presented for data collection, which we have previously discussed with APHA, would be to provide all carriers with microchip scanners which can upload information directly to a central database which captures information such as pets’ microchip numbers, country of origin and date of entry into Great Britain. This would allow data to be captured in real-time, directly as animals are entering the country, and so would prevent the issues we have seen with the accuracy of the data collection. This does not need to be onerous, as the database would not carry any personal information. The introduction of a centrally accessible database would also allow stakeholders, such as animal welfare organisations and Local Authorities, to undertake a risk assessment when animals with foreign microchips come into their care. Knowing when a dog entered the country is crucial to being able to assess their disease risk, particularly if there were a case of rabies identified.

 

 

5. The latest on smuggling, including the impact of COVID-19 on supply and demand, and the effectiveness of enforcement

 

5.1. Impact of COVID-19 on dog prices

 

Demand for puppies has soared since the start of the Coronavirus pandemic, with Google searches for ‘buy a puppy’ increasing by 166% between when lockdown was announced in March and the end of July 2020.[3]

 

Our statistics also show that prices for some of the UK’s most desirable dog breeds have reached record levels in recent months, as some sellers exploit the increased demand for puppies during the pandemic. Our research found that the asking price for some of the UK’s most sought after breeds and some of the breeds most often smuggled into the country – Dachshunds, English Bulldogs, French Bulldogs, Pugs and Chow Chows - shot up between March, when lockdown was announced, and October this year. The data reveals the average price increased by:

 

Percentage increase

Breed

Average price in October

Average price in March

134%

Chow Chows

£2,618

£1,119

73%

Dachshunds

£1,681

£973

49%

English Bulldogs

£2,436

£1,637

70%

French Bulldogs

£2,128

£1,251

78%

Pugs

£1,414

£684

 

 

5.2 Impact of COVID-19 on illegal importation – Government statistics

 

The number of dogs entering the UK via the Pet Travel Scheme dropped dramatically at the height of the COVID-19 restrictions. However, this does not mean imports ceased during this time.

 

Pet Travel Scheme (PETS) figures

January 2019

23,504

February 2019

14,046

March 2019

21,969

April 2019

21,124

May 2019

20,221

June 2019

25,676

July 2019

31,398

August 2019

51,208

September 2019

36,712

October 2019

27,826

November 2019

13,707

December 2019

21,013

January 2020

22,454

February 2020

12,160

March 2020

13,233

April 2020

1,546

May 2020

4,433

June 2020

7,423

July 2020

5,423

August 2020

33,413

September 2020

Not yet available

October 2020

Not yet available

 

Through our work on the Puppy Pilot, we know illegal importers are extremely quick at adapting their tactics to avoid detection. One of the clear trends during the height of the COVID-19 restrictions was a switch from importing dogs under PETS to instead importing them under the commercial legislation, otherwise known as the Balai Directive (Council Directive 92/65/EEC), as commercial transporters were deemed as making essential journeys.

 

Intra Trade Animal Health Certificates (ITAHCs) are certificates used to document trade in animals between EU Member States and are issued for movements under the Balai Directive. Each certificate can cover a number of dogs in a consignment. When animals are transported via this legislation, they are not subject to checks at the border. Instead the Animal and Plant Health Agency (APHA) conduct post-import checks at the point of destination (up to 48 hours after arrival). APHA have previously confirmed that post-imports checks are carried out on less than 10% of consignments. However, during the first coronavirus lockdown, in person post-import checks were stopped entirely. The number of ITAHCs being issued per month continues to increase and is now at record levels, as shown below. Historically the busiest month was October to facilitate the Christmas market.

 

Intra Trade Animal Health Certificates (ITAHCs) figures

February 2019

2,037

March 2019

2,393

April 2019

1,895

May 2019

2,244

June 2019

1,929

July 2019

2,081

August 2019

1,954

September 2019

2,623

October 2019

3,244

November 2019

2,287

December 2019

2,025

January 2020

2,580

February 2020

2,373

March 2020

1,321

April 2020

660

May 2020

3,220

June 2020

3,967

July 2020

4,850

August 2020

3,916

September 2020

5,206

October 2020

5,287

 

 

 

5.3 Impact of COVID-19 on illegal importation – Puppy Pilot statistics

 

Between the start of the first lockdown (23rd March) and the end of September, Dogs Trust rescued 140 puppies that were illegally imported into the country from Central and Eastern Europe. These pups were destined to be advertised online as UK-bred dogs for extortionate prices, sold to unsuspecting buyers. If sold, the estimated market value of these puppies would have been approximately £266,000.

 

As part of the Puppy Pilot, we also rescued 14 heavily pregnant mums between the start of the first Coronavirus lockdown and September 2020. These dogs gave birth to 56 puppies worth around an additional £115,000 to cruel smugglers.

 

Throughout the pandemic, we have also seen a new trend of more illegal importers paying the quarantine fees to get their puppies back, rather than handing them over and avoiding paying the fees. This is driven by the significant increase in dog prices since the start of the pandemic, as explained above, and demonstrates the profit that can be made even after paying to put the puppies through quarantine. Whilst insufficient penalties are available for puppy smuggling, with minimal risk of prosecution, there is little deterrent for deceitful traders.

 

 

6. The impact of recent measures including Lucy’s Law and the Petfished campaign, and what other measures should be taken

 

6.1. Lucy’s Law

 

In April 2020, ‘Lucy’s Law’ was introduced in England, which prohibits commercial third-party sales of puppies and kittens under 6 months old. Dogs Trust is supportive of ending party sales of puppies, as protecting and promoting animal welfare at every step of the breeding and sale process is a significant challenge when puppies are sold through third-party sellers.

 

However, we remain concerned that this legislation only applies to commercial activities, and anyone breeding less than three litters of puppies per year is not captured. Until we have full traceability (registration and licensing of anyone breeding puppies) this practice will continue, if not from overseas then pups illegally bred in the UK. We are also extremely concerned that there is no statutory obligation to prohibit the sale of a puppy or kitten that was bred outside of England, if the breeder of the puppy or kitten outside of England is also the seller in England and is licensed as a business selling animals as pets under Schedule 1 Part 2 of the Licensing of Activities Involving Animals Regulations[4]. For more information, see a statement from the Local Government Animal Welfare Group here: https://localgovernmentanimalwelfare.org/the-third-party-ban/

 

We have already experienced various ways in which unscrupulous sellers have been able to take advantage of this loophole. Through our work on the Puppy Pilot we have seen an increasing trend in the importation of heavily pregnant female dogs from Central and Eastern Europe. Their puppies are then sold in England to buyers who often think they are buying ‘UK bred’ puppies. In this situation, as the seller would also be the breeder, this is not prohibited under Lucy’s Law.

 

We have also received reports of breeders based in England swapping their breeding bitches so they can increase the number of litters bred and sold without increasing the number of breeding bitches stated on their licence. This includes swapping their breeding bitches with pregnant females from outside of the UK. We strongly believe wording should be added to the Regulations with regards dog breeding, to state that the number of litters bred by a breeder each year should not exceed the number of breeding bitches stated on their licence.

 

 

 

 

6.2. Defra’s Petfished campaign

 

In addition to improving the supply of puppies in the UK, it is also important to also address demand. We have long called for a Government-led behaviour change campaign to enable the public to purchase puppies responsibly. For this reason, we have very much welcomed and supported Defra’s ‘Petfished’ campaign.

 

One of the challenges for any campaign aiming to change buyer behaviour is that buying a puppy is an emotional purchase. We recently publicised the findings of our Choosing My Dog study which surveyed 2,908 people who bought a puppy in the past seven years. The survey found that:

 

 

These findings demonstrate the scale of the challenge in any campaign aiming to change puppy buying behaviour, as many people buying a puppy do little research and once they view a puppy, they are likely to walk away with it. However, we welcomed the approach behind Defra’s ‘Petfished’ campaign and recommend the Committee asks Defra about the campaign’s impact to date.

 

6.3. Other measures to be taken

 

Please see our list of recommendations for Government action in Section 3.

 

7. The end of the Brexit transition period and the impact on pet travel requirements, plus the situation regarding the NI Protocol and also the PETS scheme

 

In November 2020, Defra responded to Parliamentary Question number 109477 as follows:

 

Question: To ask the Secretary of State for Environment, Food and Rural Affairs, what progress his Department has made on the future of pet travel between the UK and the EU after the end of the transition period.

 

Response: There will be no change to the current health or documentary requirements for pets entering GB from the EU from 1 January 2021, in the immediate term. This is to ensure a smooth transition.

 

The Department has submitted an application to the European Commission to become a 'Part I' listed third country in relation to non-commercial movement of pet dogs, cats and ferrets from the UK into the EU. Acceptance of this application would mean very similar documentation and health requirements to those that are required now for pet owners and users of assistance dogs travelling to the EU. The Commission is considering our application.

 

The requirements for entry to the EU after the end of the transition period are dependent on the UK's listed status and information on requirements will be communicated via further updates on GOV.UK. It is the duty of a responsible Government to adequately prepare those who travel with pets to the EU under any listing scenario, including in the event that GB becomes an unlisted third country. We issued guidance in early August to ensure that those who wish to travel with their pet on the 1st January 2021 will be able to do so. We have recommended that pet owners visit their vet four months in advance of travel to the EU.

 

We have also asked Defra directly about the impact on pet travel, as well as commercial pet movements, between Great Britain and Northern Ireland and received a similar response. The situation is currently unclear whilst waiting for confirmation of whether the UK will be accepted to be a ‘Part I’ listed third country.

 

This uncertainty is extremely concerning whilst there are now only weeks to go until the end of the transition period at the end of December 2020. Many pet owners may be unaware of the need to visit their vet four months in advance of travel to the EU and it is extremely difficult for organisations which move animals responsibly and legally to plan for changes which may be introduced at extremely short notice.

 

We are also concerned that there will be no immediate change to the requirements for pet animals entering the UK, and no clear plan or timeframe for when the Government will review the UK’s pet travel rules. We have been presenting evidence and calling for Government action on this issue for over 6 years, yet we have seen no significant Government action to date. The end of the Brexit transition period presents a momentous opportunity for the Government to holistically amend the UK’s pet travel rules. We believe the Government must now take action urgently.

 

8. COVID-19 and the impact on the companion animal welfare sector including the finances and demand for services of the charitable sector, and Government support.

 

This unprecedented crisis has had a significant operational and financial impact on the work of Dogs Trust. Like many other charities we are anticipating a significant reduction in overall income as a result of the impact on our fundraising activities, reserves and legacies. At the same time, we are trying to manage the immense strain on our resources as a result of a reduced workforce and not being able to rehome as many dogs due to COVID-19 restrictions, as well as facing increased demand for our services including pet advice and our rehoming and fostering services.

 

8.1. Financial impact

 

Like all charities, Dogs Trust is being hit hard by this crisis. For the five-year period of 2020 – 2024 we have projected a £60 million loss in our budgeted income. This year alone we are projecting a reduction in expected income of around £15 million, which will have a profound impact on our services right across the UK. This is due to the impact on:

 

 

Historically, Dogs Trust has received no Government funding to deliver our lifesaving work. Whilst we have benefited from general business support packages such as retail grants or furlough during the pandemic, the UK Government has not targeted any support directly towards companion animal welfare activity nor has Dogs Trust been eligible for any of the wider charity sector support packages.

 

 

 

8.2. Impact on our services

 

 

November 2020


[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] This is based on averages of the prices displayed on the first pages of adverts for the relevant breeds on Preloved and Gumtree if they had been sold by dealers.

[3] Figures sourced from Propellernet, based on Google searches for “buy a puppy” from week commencing 22nd March 2020 and week commencing 12th July 2020.

 

[4] The Animal Welfare (Licensing of Activities Involving Animals) (England) Regulations 2018

[5] Figures sourced from Propellernet, based on Google searches for “buy a puppy” from week commencing 22nd March 2020 and week commencing 12th July 2020.

[6] https://faunalytics.org/wp-content/uploads/2015/05/straydogsurveysummaryreport2011.pdf

[7] Figures sourced from Propellernet, based on Google searches for “buy a puppy” from week commencing 22nd March 2020 and week commencing 12th July 2020.