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Publication - Research publication

Sourcing of pet dogs from illegal importation and puppy farms 2016-2017: scoping research

Published: 9 Nov 2017
Directorate:
Agriculture and Rural Economy Directorate
Part of:
Farming and rural, Research
ISBN:
9781788514132

The report describes research into the scale of the trade in imported and illegally bred puppies.

Contents
Sourcing of pet dogs from illegal importation and puppy farms 2016-2017: scoping research
Recommendations and Proposed Solutions

Recommendations and Proposed Solutions

What follows are the authors' recommendations and proposed solutions set out in the same order as the rest of the report: prevalence, nature, understanding consumer behaviour and regulation. This is followed by a summary of our recommendations as related to the two research questions and with suggestions on a timeframe for undertaking the recommended actions.

Prevalence

It is difficult to estimate both the numbers of puppies who are irresponsibly or illegally bred and sold and the numbers of breeders and sellers overall as well as those who are acting unscrupulously or illegally. An important step forward in better understanding the prevalence of the problem is the development of a process to accurately record both the legal and known illegal trade. This would need to be widely accessible and shared between formal and informal agencies and stakeholders. In connection to this, some anonymised formal data should be shared in the public domain to assist in educating consumers and stakeholders about the prevalence of the irresponsible and illegal puppy trade. One way of achieving this is to copy the format of the European Union - Trade in Wildlife Information eXchange ( EU- TWIX). An NGO, TRAFFIC, has a dedicated staff member that receives and collates all the information and intelligence data from across the EU from law enforcement agencies. This can then be shared across the countries through a central point and also can sanitise information to share more widely. This could be a format to work within the UK, but expanding those able to report information and intelligence to NGOs and charities.

Nature

Evidence suggests the puppy trade is a fluid market, thereby resources and organisations need to be flexible in responding to market shifts. Fluidity in the puppy trade is facilitated by the different types of trade (that is, legal regulated, legal unregulated, illegal and irresponsible) and the variety of offenders in the trade (for example, organised crime, ad-hoc, legitimate commerical traders). Although the illegal domestic and international trade coexist, each requires a different responses. Consequently, further research is required to identify the nature of the domestic and international trade, for example to identify which aspects of the trade are linked to serious organised crime or otherwise legitimate commerical businesses. Enforcement at ports and internet advertising are key areas which are influenced by current shifts in the market. With regards to ports, it should be a priority to provide efficient and effective resources and staff at the ports to repond to the number of puppies entering the UK illegally. This is essential as once puppies enter the country it is very difficult for enforcement agencies to identify and respond to the illegal trade. With regard to the internet as the chief medium for consumer purchases, a combined approach is required - to make it more difficult to purchase puppies from online advetisements and to enforce sellers, breeders and consumers responsibility.

Understanding Consumer Behaviour

As mentioned above, the internet is the principal source of information as well as the main conduit for consumers to purchase their puppies. This provides multiple opportunities for potential interventions. First, the PAAG Minimum Standards for advertising pets online should be considered for all advertisements. Linked to this, a pop-up warning could precede any detailed advertisement to try to help decrease impulse buying. Further pop-ups could be used to direct consumers to a dedicated 'go to' website or website application (see below) or to a link where they must confirm details, such as their age. Clearly, regulation of the internet is very difficult and has the potential to displace illegal and irresponsible trade to other websites potentially located in other countries, which cannot be regulated. Therefore, it is essential that regulatory and monitoring measures be introduced in partnership with websites and underpinned with robust evaluation to ensure the measures implemented are having the desired result. Ideally, evaluation would be undertaken by an independent party. Second, a single 'go-to' website should be developed that contains information vital for improving consumer understanding and behaviour. This could include a list or link to registered or approved breeders/sellers included in the proposed Trusted Traders Scheme of LAs. These breeders and sellers would be registered or approved through a scheme put in place by the LA or by a mulit-agency initiative (see Regulations below). Another section on the website would be a list of professionals ( i.e. veterinarians and so forth) who can give advice and support. The list would be made up of volunteers willing to answer questions and potentially to accompany people when visiting/purchasing puppies. This website would also provide specific guidance as to how to report suspicious activity and provide a contact number or helpline for reporting suspicious or illegal behaviour. Furthermore, there would be useful videos on how to choose, find and raise a puppy. Other valuable information would be a price guide for the different breeds of puppies. Additionally, a simplified checklist (taken from the Puppy Contract) or acronym guide to use when at the breeder's or seller's place would help consumers remember to ask the right questions.

Third, there needs to be wide-scale education about the irresponsible and illegal puppy trade. This could be included in the part of the national curricula that teaches children about animal welfare issues. The RSPCA, SSPCA and Dogs Trust and Kennel Club aleady provide materials that could be used, such as the Puppy Contract and Puppy Plan. Additonally, there should be a public awareness campaign involving the national press, social media, and TV programmes - soap operas and documentaries - with celebrity endorsements to bring attention to the problem. Not only would such a wide-scale education programme help consumer behaviour, it would also make LAs and businesses aware of the prevalence and nature of the irresponsible and illegal puppy trade and potentially enhance their understanding of the importance of allocating resources to reduce the trade.

Regulation

As a starting point, there should be a review of all legislation related to the breeding, sale and international transit of dogs. This would entail analysis of domestic breeding regulation as well as international imports. Such a review is particularly necessary in light of the UK leaving the European Union. For instance, the PTS scheme currently provides loopholes in regards to the number of dogs each person may travel with (five), the age of entry and it provides very limited tracability of the dogs. PTS would be improved by allowing fewer dogs (three), monitoring the entry and exit of owners and their dogs, requiring registration of microchips and raising the age at which dogs can travel. Linked to PTS is the current untapped potential of mandatory microchips for UK dogs. Microchipping could be used for traceability of movement and sales in addition to locating lost dogs. Consideration should be given to a centralised UK database that records all microchiped dogs and places responsibility on both sellers and owners to update microchip data, such as the Irish MODR system or the mechanism in place for tracking livestock and horses. Although microchip data can be requested by the various offical government agencies, this has not been done to produce statistics which could help identify the prevalence, nature and trends in the UK puppy trade. Should database providers be required to share and collate this data annually, this would provide clarity on the scale of the trade and the resources required to regulate it. To enhance tracability, the data from these databases need to be shared with European, as well as other, trade partners. Overall, domestic and international regulations need to have stronger animal welfare components. As mentioned, the options available to 'dispose' of animals seized and those waiting potentially for months or years for a court case must be reviewed.

As outlined above, the online advertising of puppies needs to be better regulated, such as making the PAAG Minimum Standards mandatory for all online advertisement providers. Part of improving sellers' behaviour regarding online advertisements would be to increase the involvement of HMRC in monitoring the tax returns of puppy advertisers online.

Regulation can be further improved by implementing schemes for both the sellers and the buyers. Suitable sellers and breeders could be voluntarily registered as part of a LA Trusted Traders Scheme, modelled on existing assured breeder or other trade schemes. The sellers and breeders taking part would then be required to present evidence to the LA that they have vet checked the puppies, vetted the buyer, provided the buyer with a contract and are up to date on practices such as enrichment and socialisation of the puppies. People buying from these traders can then post reviews and recommendations on the website of the scheme. For the buyers, there could be a scheme for them to attend training/awareness classes prior to purchase. This would qualify as their vetting in regards to the Trusted Traders Scheme. Undoubtedly, this would require more resources, but LAs participating in this research indicated it may be possible as part of their existing schemes.

An evaluation of the current resources available for responding to the puppy trade in terms of the agencies responsible for enforcing the regulations, the number of staff available and the financial and other resources (for example, quarantine facilities) needed to respond is necessary. Once this is determined, it may be possible to estimate what further resources are needed based upon estimation of the scales of the irresponsible and illegal trade (see literature review Appendix II). By ensuring the necessary capacity and training for enforcement is available, regulations will have the 'teeth' to prevent, deter and punish offenders in the trade. LAs should consider prioritising this issue so that more resources can be identified and allocated. Alternatively, these schemes could be part of a multi-agency partnership headed by an independent agency. Such a partnership should also entail increased enforcement, including more unnannounced inspections. Overall, punishment and sanctions should be increased when there are violations. This could be provided for through greater use by enforcers of the broader legislation and sanctions available to respond to the illegal puppy trade, including tax evasion and proceeds of crime laws. As part of a legislation review process the government could issue definitive legislation and sentencing guidelines for criminal justice and enforcement agencies.

Recommendations

The following is a summary of our recommendations. They are not set out in order of priority but in order of the two main research questions: 1) what can be done to enhance our understanding of the nature, extent and value of the UK puppy trade and 2) what improvements can be made at each part of the trade to help prevent the international illegal trade of puppies and unregistered puppy farms? It is important to note that the recommendations refer individually to Scotland, England, Wales and Northern Ireland and to all four devolved parliaments/assemblies [identified as " UK gov" below], in acknowledgement that a consistent approach to many of the recommendations is essential in order to respond to the national and international trade. In recognition of the difficulty in responding to some of the recommendations, a suggested timescale is provided: short (quick fixes), medium (within the next twelve months) and long (one to three years) term. As the resources available to respond to the puppy trade are currently limited, the authors recognise the need for further funding for enforcement agencies to facilitate the recommendations below. It should be noted that Defra are currently undertaking a review of the licensing system for dog breeding and sales in England, which may address a number of the issues highlighted above and fulfil the recommendations proposed in this report. However due to the timing and focus of this project the new licensing proposals have not been accounted for here.

1) Recommendations to further our understanding of the nature, extent and value of the UK Puppy Trade

Action

Organisation

Timescale

Collate existing data on the scale and value of the trade, trade offences and related harms (example databases are listed on page 21 of the report) to provide a more accurate estimate of both the legal and known illegal trade. This would require cross-agency anonymised data-sharing, which could be collated by one agency.

UK gov/ NGOs

Medium-Long

Expand the benefits of mandatory UK microchipping to assist in tracking dogs from birth through transportation/sale. To facilitate "cradle to grave" traceability a centralised UK-wide microchipping database could be developed whereby all approved database providers are required to annually report their figures and/ or all approved providers are required to contribute to Europetnet [for example, the Microchipping of Dog Regulations [ MODR] in Ireland only authorise providers that are full member of Europetnet, thereby, traceability is easier across the EU and Europetnet has the capacity to generate a single report on the trends, nature and scale of the puppy trade (for example, the number of puppies bred/brought to the UK, puppies age and breed, the keeper information, licensed keepers/breeders in each LA).

UK gov

Medium-Long

Publish an annual summary of data (as above, but with sensitive information removed), which provides an overview of the legal and known illegal trade. Share widely in order to enhance awareness and responses across all stakeholders, in particular consumers.

UK gov/ NGOs

Medium-Long

Increase the ability to monitor online advertisements through the use of PAAG Minimum Standards, such as requiring sellers to provide licence number on advertisements. Irresponsible and illegal sellers should be more easily identified through their failure to adhere to these guidelines. Enhance formal monitoring by enforcement agencies (for example, LAs) through proactive spot checks for compliance and trial purchases. This would facilitate the quantification of the online legal and known illegal trade providing more robust estimates of the overall trade. Require online advertising providers to share the number and nature of non-compliant advertisements with appropriate government agency to assist agencies intelligence gathering. This is already being considered in England (see Appendix VII)

UK gov

UK gov

UK gov/online providers

Medium

Provide funding and support to further develop multi-agency partnerships (such as Operation Delphin), which would help facilitate cross-agency data sharing. These partnerships should be developed at both the local and national level.

UK gov

Short

Fund further empirical research to evaluate trends in the puppy trade (for example, on prosecutions, convictions and sanctions)

UK gov/ NGOs

Short - Medium

2) Recommendations to improve each stage of the Puppy Trade: breeding, transportation, sale, ownership and enforcement.

Evaluate the resources available for regulating the puppy trade in terms of the enforcement agencies responsible, the number of staff (for example, to carry out inspections) and the financial and other resources (for example, quarantine facilities) necessary to do so. This should be done once reliable prevalence data are available, ensuring the necessary capacity and training for enforcement is available.

Provide funding and support to further develop multi-agency partnerships in order to enhance enforcement, avoid duplication and reduce costs through shared resources. These partnerships should be both developed locally and nationally.

UK gov

UK gov

Medium-Long

Short

Evaluate and consider strategies used across the EU to enhance the traceability of breeders and traders (for example, centralisation of microchipping databases, the onus on buyers to provide ID and both buyer and seller to contact the microchipping database provider to change details after sale in Ireland (see page 53 for further details); the use of both a microchipping database and national register for dogs in Sweden).

UK gov

Medium

Consult key stakeholders on the national and international legislation which regulates the puppy trade, to evaluate 'fitness for purpose' in line with the contemporary puppy trade - this is particularly important with regard to PTS (number of dogs and mandatory registration of microchips), third party sales, online advertisements and the licensing conditions and enforcement of breeding establishments. The recent EFRA (2016) consultation on 'Animal Welfare in England: domestic pets' is a good example of stakeholder consultation regards the puppy trade (see Appendix VII).

Wales, Scotland & Northern Ireland

Med

Enhance regulation of online trade related sales through the use of PAAG Minimum Standards for online providers, such as requiring sellers to provide license number on advertisement. Require UK online advertising providers to share the number and nature of non-compliant advertisements with enforcement agencies ( LA) and LAs to carry out proactive spot checks and perform trial sale purchases online This would enhance both formal and informal monitoring of traders and consumer ability to evaluate both online advertising sites and traders. Develop a strategy to clarify PAAG requirements for sellers and consumers to enable responsible trading and buying.

Evaluate and consider strategies used across the EU to enhance the traceability of online traders and their puppies (for example, use of tax codes on puppy advertisements in France).

UK gov

UK gov & online advertising providers

UK gov

Medium

Review the use of broader legislation and sanctions to respond to the illegal puppy trade, including tax evasion and proceeds of crime laws, which provide further scope for enforcement and punishment. Using existing processes ( e.g. Law Commission review) to issue definitive legislation and sentencing guidelines for criminal justice and enforcement agencies.

Review the penalties in place in puppy trade regulations to ensure these act as a deterrent.

UK gov

UK gov

UK gov

Medium

Review animal welfare within the import control legislation, with particular consideration given to the 'disposal' and confiscation/quarantine of puppies in the trade and the role of enforcement agencies in animal welfare.

UK gov

Short - Med

Create and provide enforcement agencies with easy to follow practical guides ( e.g. flow chart examples provided in Appendix VIII) on responding to the illegal puppy trade.

Clarify and share the process for reporting the illegal trade for consumers and other stakeholders, with the use of simple Flow Charts (See Appendix VIII) to direct people through the correct process and to the appropriate agency (these could be made available on the suggested 'go to' website).

UK gov

UK gov

Short

Develop a reliable online resource and/or website/mobile application, which is promoted by all stakeholders as the 'go-to' website/app for advice and guidance on puppy purchasing. Consumers require a reliable tool to traverse the online marketplace, at present the variety of sources and inconsistent information causes confusion. Online providers could be encouraged to divert buyers to this site prior to viewing the complete advertisement. This resource should link consumers directly to the relevant enforcement agencies to report irresponsible and illegal trade, possibly in partnership with Crimestoppers for instance. This source may be facilitated through an existing website with dedicated link for the puppy trade, where a Steering Committee of stakeholders agree to the content.

UK gov/ NGOs/ stakeholders

online advertising providers

Short-Medium

Develop a national strategy to enhance awareness and education around the puppy trade. This can be achieved through formal and informal education. Formal education establishments should be encouraged to include this in their lesson plans. Media (social/television) programmes with celebrity endorsement can informally raise attention and understanding of the illegal and irresponsible trade and thereby reduce consumer demand or redirect it to other sources (such as dog rehoming centres). The effectiveness of such campaigns should be assessed by further research on public attitudes and behaviour.

UK gov/ NGOs/ stakeholders

Short - Long

Develop an independent Trusted Traders Scheme, which is based on best practice identified in existing schemes (for example, the KC's Assured Breeder Scheme or government endorsed trade schemes such as TrustMark, BuywithConfidence), to provide consumers with an evidence-based list of breeders and traders with whom they can purchase with confidence. It may be useful to use existing processes to create and pilot the scheme in three councils initially to monitor impact.

UK gov

Medium

Provide funding for further research which focuses on consumer demand, the role of social media, and mechanisms introduced in other countries, which have resulted in the reduction of illegal and irresponsible puppy trading.

UK gov/ NGOs

Short


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