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

Nature

Experts suggested failures to legislate and regulate the legal trade appropriately (discussed in Suggestions below) facilitates and encourages the illegal trade. Furthermore, this provides a crossover between the nature of the legal and illegal trade. This can occur due to loopholes - for example, as mentioned above, under PTS it is legal to bring up to five dogs with you to the UK from abroad. Consequently, three people in one vehicle can transport up to 15 dogs, but is not identified as commercial trade. Although this falls within the letter of the law, the transportation of 15 dogs is likely to be for commercial purposes and is clearly inconsistent with the spirit of the law. Furthermore, in licensing UK breeders, after the initial inspection, regulation is neither consistent nor certain according to the experts, which exposes dogs to harms similar to, or in some cases worse than the illegal trade:

These dogs, these animals need human interaction and then nobody goes near it for another year, by which time, all the nice wee fancy beds are all returned to wherever they were borrowed from and the dogs are on sawdust. It's all an illusion at the beginning…we know that when annual inspections come round for the re-licensing, they're pre-announced, so things are, in some cases, tidied up, overstock are moved out and hidden. It all goes on [in the legal trade] [ EI6].

The problems identified in the illegal trade are not, according to the experts, specific to Scotland or the UK more generally, it is a European-wide issue: " we are secretariat for XXX ^[9] , so we have members from most EU member states, over 60 members now from across the EU and again, they're experiencing these issues as well" [ EI2]. In terms of the nature of the puppy trade, it is important to distinguish the domestic UK trade from that from abroad.

Imports

The key overseas trade routes identified by experts are detailed in Figure 3. These include ports in England (that is, Dover and the Channel Tunnel) for Central and Eastern European trade and ports in Wales (Holyhead, Fishguard/Pembroke) and the border in Northern Ireland (across the border) for Irish trade. While there was some mention of mainland European trade also coming through Ireland to avoid enforcement elsewhere, this was seldom identified in practice. However, one veterinary expert expressed his concern that this illegal trade could escalate as a result of the UK leaving the EU - as the Irish border becomes the 'soft' option for puppies traded from mainland Europe to the UK. Specific breeds were linked to different entry points - " all your bull breeds are coming from eastern Europe, French bulldogs and the like, and all your cockapoos, cavapoos, cavachons; they're all coming from Irish puppy farms" [ EI4].

Figure 3: Main International Trade and National Distribution Routes identified by Experts

Puppies entering the UK at these points are then distributed across the country to key locations, predominently large cities linked to the national trade, as detailed in Figure 3. Consequently, puppies entering Scotland and England may be arriving from Ireland or mainland Europe. While puppies entering Northern Ireland and Wales, in the main, have arrived from Ireland.

The surveyed stakeholders understanding of how illegal puppies enter Scotland was consistent with the expert testimony. Their answers are relevant to the UK as a whole (Question 19), suggesting there are cross-country distribution networks in place. The ferry from Northern Ireland to Scotland was identified as the main route (41 respondents) with other routes being ferries from Ireland to Scotland (39 respondents) [although there are currently no direct ferries from Ireland to Scotland], ferries from the continent to England (35 respondents), from Ireland to Wales and through the Channel Tunnel. Although not identified by the experts, (Question 19a), survey participants indicated that planes from Eastern Europe were also routes of smuggling.

Experts explained that the nature of these distribution networks has changed as the trade has become more organised and sophisticated.

So puppies are basically coming in from Central and Eastern Europe, but that's your starting point, but these puppies will be distributed right across the country. The individuals involved are becoming very clever…Certainly we're aware that some of the service stations down in Kent are being used for the transfer of puppies, not necessarily to owners, but you know, people bringing puppies across so they then start to… they're effectively using a distribution network to get them across the country [ EI2].

For example, there has reportedly been a move towards consumers unknowingly 'preordering' puppies online prior to traders importing them from Eastern Europe, thereby, there is no need to hold or care for the puppies in the UK. Puppies, originally brought in from Ireland in a large variety of litters and then kept at a location until they were sold online, are now brought over with their mothers or show dogs or sent to UK owners of specific female breeds to hold and sell the puppies to members of the public:

they're even bringing over show bitches, so you get a litter of pups with a bitch that's probably got nothing to do with the litter, so that if somebody visits your house you've actually got a west highland terrier bitch and west highland terrier pups. So every time you kind of close one angle they're finding another one [ EI4] .

This is in reaction to the recommendations from NGOs to consumers to view puppies with their mother and check for repeated mobile numbers online. Consistent with this change, our online advertisements analysis found little evidence of repeat sellers, with only 18 people likely to be repeat sellers based upon their contact details. As the information shared by sellers on the seven websites was inconsistent ^[10] , it is impossible to know with any accuracy about the selling patterns of individuals selling puppies through these sites.

Offenders were idenfitied by some focus group participants, survey respondents and an interviewed expert by stereotypes such as " gypsy", " traveller" or " Irish traveller". Experts identified a range of offenders involved in the trade: a) non-compliant or "hobby" breeders who breed or trade dogs in excess of the regulations or fail to care for their welfare in accordance with the regulations, b) organised crime groups " who view pups as a low risk: high yield commodity" and c) " ancillary individuals who facilitate this trade in a number of ways - transportation of the animals for example" [ EI10]. These variations add to the difficulty in identifying the nature (and prevalence) of the illegal and legal trades. Those who are legitimate can easily become non-compliant, while those who purposefully smuggle and organise the illegal trade can use the legitimate trade to do so ( e.g. laundering dogs).

Vans and other large vehicles ( e.g. horse boxes) were identified by experts to be the common modus operandi to smuggle large numbers of puppies. Cars were also used, along with misusing the PTS scheme to 'legitimately' bring in five puppies and covertly smuggle others ( e.g. in the spare wheel cavity in a car). Surveyed stakeholders' (Question 20) answers were also consistent with the experts; puppies were identified to be hidden in domestic vehicles (48 respondents) and hidden in business cargo (44 respondents). Respondents also indicated that PTS passports could be faked (33 respondents) and illegal puppies could be mixed in with legal puppies (27 respondents). In other cases, the puppies were said to enter the country with the correct PTS paperwork, but under the guise of personal pets, who were intended for sale. To avoid attention at the ports, more recently, an individual was identified bringing in puppies as a foot passenger with the intension of selling them in the UK. The modus operandi in the illegal international trade are diverse and fluid, with offenders rapidly adapting their procedures and transit routes in response to enforcement and consumer behaviour: " Once we've closed a loophole they'll find another one" [ EI4].

A crucial opportunity for enforcement occurs at the port; once in the UK it is more difficult for enforcement agencies to identify and respond to the trade:

but once we get into the UK and start to trace things it can be very, very difficult, and quite often, unless they're actually stopped at the port, quite often we don't hear about a lot of these cases until the puppy's been taken to a vet or it's ended up in quarantine [ EI2] .

Consequently, the international trade seamlessly becomes part of the UK domestic trade. While the majority of experts focused on this international trade as of paramount concern, this was not to say the nature of the domestic trade is unproblematic. Rather, the international trade is directly linked to the issues identified in the domestic trade.

Domestic Trade

Puppy farms and industrial-scale breeding establishments were identified by experts in the UK, linked to Wales and Northern Ireland respectively (one FG participant campaigns against several in the north-east of England [ FG23]), but not Scotland:

"What you would class as traditional puppy farms virtually do not exist in Scotland, it's mainly dealers bringing in other stuff" [ EI4].

"Well I'm not aware that we have any farm you know, puppy farms actually in our area… I'm pretty sure we don't have, because there's huge welfare issues there for the pups you know, there's constant breeding of dogs do you know" [ EI3].

This is interesting as the majority of stakeholders in the online survey reported an increase or a significant increase in puppy farms (see above). This disparity may be due to experts and stakeholders defining 'puppy farms' differently, or because experts are more focused on the 'bigger' picture of the international trade. Nonetheless, experts recognised the nature of the domestic trade is problematic due to issues of registration, which involve breeding without a licence, breeding excessively and non-compliance with licence and welfare requirements. With specific regard to Scotland, puppy farms and traditional 'pet shops' were of less concern, rather the licensing and welfare conditions in which most puppies were bred were seen as inherently problematic as was the inability to licence and regulate all puppy sellers. This was repeated in the focus groups with many participants wanting stricter regulation to ensure appropriate welfare conditions. Interestingly, one expert suggested the domestic trade was not being enforced as it may impact negatively on the demand from the illegal international trade:

"so if we work extensively on puppy farms, then potentially online trade might go up, and there might be more opportunities to smuggle in from perhaps Eastern European or Irish puppy farms" [ EI1] .

Stakeholders recognised both national and international illegal breeding establishments (Question 16), with Ireland identified as the top location (46 respondents) followed by Romania (37 respondents), Scotland (36 respondents) and Northern Ireland (35 respondents). Illegal suppliers (Question 17) were also thought to be predominantly from Ireland, England (43 respondents), Scotland (41 respondents), Wales (40 respondents) and then Northern Ireland (37 respondents). Interestingly, these respondents thought these suppliers were mostly part of an organised network (43 respondents), but some also acted opportunistically (30 respondents) and as part of their legitimate business (20 respondents). This again suggests a crossover between legal and illegal trade. One respondent commented that illegal suppliers are " casual, ill-informed backstreet 'breeders'" (Questions 18 and 18a). In contrast, one LA expert indicated that one-off (accidental breeders) were not identified as a problem in complaints from consumers.

The internet was consistently referred to when discussing the modus operandi in the domestic trade, with all experts agreeing that it is the main vehicle for unscrupulous breeders and traders to advertise puppies. By way of a snapshot of the domestic trade in Scotland, the online monitoring of the puppy trade revealed puppies advertised for sale throughout Scotland. The only areas where no sellers were identified were the Shetland and Orkney Islands. The greatest numbers of advertisements were placed by sellers located in Glasgow, North Lanarkshire, Fife, West Lothian and South Lanarkshire respectively. The pattern appears to be that puppies in Scotland are sold in and around urban areas, particularly Glasgow. Figure 4 below presents details of the number of advertisements identified by LA area.

Figure 4: Number* of online advertisements identified by Scottish Local Authority area

*1,497 total advertisements of an approximate 4,074 puppies, over a 12-week period (Oct 2016) on seven websites.

A number of expert NGOs detailed how their analysis of the online trade helped identify the nature of the domestic trade. For example, one NGO was able to match advertisements from unscrupulous traders by comparing the contact details (for example mobile phones, images). Another indicated she watched for sales of specific breeds:

I used to keep an eye on online ads, and because Bichons … became a beacon for me so if ever I saw an ad for Bichons I would scrutinise them and …I would find that Bichons weren't the only breed so this day I phoned up, I said, "I'd like to come and see the pups". "Which pups?" "Oh", I said, "Which pups have you got?" and you know, I got given a list [ EI6].

Dogs in the Trade

As previously discussed, experts identified the flexibility and changing nature of the trade. One notable change identified was the nature of the dogs involved. Pedigree dogs have always been desirable - " 25 years ago then it probably was German shepherd, Rottweilers, Dobermans in terms of that sort of dog" [ EI2]. Current trends lean towards pedigree toy ( e.g. French bulldogs) and fashionable crossbreeds; "until fairly recently over 70% of the puppies were bulldogs, French bulldogs, pugs, so all those popular breeds, closely followed by dachshunds" [ EI2]. Focus group participants also commented on the changing nature of puppy buying - from people willing to wait for litters to be born of pure bred and working dogs, to people hastily buying 'designer dogs' from websites. Internet advertisement monitoring supported expert and consumer comments, with, as mentioned, the four most commonly advertised breeds being small or toy dogs (see Table 5 below). Over 25 percent of advertisements were for four breeds alone.

Table 5: Most commonly advertised breed types*

Breed Type	Number of advertisements for breed	Percentage of total advertisements (n = 1497)
French Bulldog	153	10.2%
Pug	88	5.9%
Bulldog	82	5.4%
Chihuahua	82	5.4%
Percentage of total advertisements advertising these four breeds	26.9%

*1,497 total advertisements of an approximate 4,074 puppies, over a 12-week period (Oct 2016) on seven websites

Also popular, but less frequently advertised, breeds include:

• Labrador Retriever (n-54/3.6%)
• Yorkshire Terrier (n-51/3.4%)
• Border Collie (n-49/3.3%)
• Pomeranian (n-43/2.9%)
• Jack Russell Terrier (n-39/2.6%)
• Cocker Spaniel (n-35/2.4%)

A total of 31 (2.1%) adverts did not include clear information about breed. A total of 353 advertisements advertised non-pedigree and crossbreed dogs (23.5% of all advertisements). A wide variety of crossbreeds were identified, with the most common being 'fashionable crosses' such as 'cockapoos', 'chorkies', and 'labradoodles'. A total of 335 (22.4%) advertisements claimed the puppies for sale were KC-registered. Table 6 below presents details of the number of puppies for sale for the most commonly advertised breeds.

Table 6: Number* and percentage of the most popular breed of puppies advertised in relation to all puppies advertised

Breed Type	Number of puppies of relevant breed advertised	Breed of puppy as a percentage of total puppies advertised (n = 1497)
French Bulldog	390	9.6%
Bulldog	279	6.9%
Pug	230	5.7%
Labrador Retriever	189	4.6%
Chihuahua	167	4.1%
Border Collie	163	4.0%
Jack Russell Terrier	161	3.9%
Yorkshire Terrier	130	3.2%
Cocker Spaniel	86	2.2%
Pomeranian	83	2.1%
Total	1878	46.3%

*1,497 total advertisements of an approximate 4,074 puppies, over a 12-week period (Oct 2016) on seven websites

Signs of the Illegal Puppy Trade

For many focus group consumers, the first indicator that their puppy had come from the illegal trade was when they did not receive the expected paperwork ( KC registration and/or health checks of the parents) or when they visited their vet. Several focus group participants related experiences of taking newly purchased puppies to the vet soon after bringing them home because the puppy was poorly or to confirm the puppies' age, vaccinations, and micro-chip. Often a veterinarian was the first person to query the origin of the puppy:

Many of the reports are sick puppies and the vet telling the buyer that what they have been told about the puppy is untrue. Some people don't report it because they think it is just a case of bad luck to get a sick puppy. They don't put two and two together that something was wrong with where they got the puppy from [ EI12].

Not always because they're ill or dying you know, they've been promised paperwork and they don't get it, or if they've been to the vet, their own vet to get boosters or whatever and the vet has said, "Well look, it's not the age it's supposed to be", or whatever, it's something that clicks you know, the bells ringing with them generally [ EI3] .

In order to help develop recommendations for consumers, a series of multipart questions (21, 22 and 23) in the online survey asked stakeholders what they felt were indicators at the buying stage that a puppy was from the illegal trade. In terms of seller behaviour, the most significant indicators were meeting the seller away from their home, not seeing the puppies' parent(s) and the seller selling several breeds of dogs (see Table 7). Focus group participants also seemed mostly aware that these were suspicious behaviours.

Table 7: Signs of the illegal puppy trade identified by survey respondents

Question 21 - At the point of sale, are any of the items below a sign that a puppy has been illegally bred or traded?	Always a sign	Frequently a sign	Sometimes a sign	Rarely a sign	Never a sign
The buyer is not able to see the puppies parent/s	21	24	4	0	0
The seller suggests meeting the buyer away from their home	24	23	2	0	0
The seller offers several breeds of puppy for sale	22	23	4	0	0
The seller mentioned a waiting list and/or planed future litters	2	9	20	13	5
Incomplete or no papers	15	21	12	1	0
The seller makes 'too many promises 'about the puppy ( e.g. temperament, ultimate size, weight and health)	9	18	15	7	0
The seller does not request that the puppy is returned to them if the purchase does not work out	10	24	13	1	1

*49 respondents

Upon observing the place where the puppies are living and the puppies themselves, the most important indicators of the illegal trade were the puppies appearing younger than the seller indicated, the puppies having parasites, being underweight and/or having a skin conditions.

A majority of our focus group participants were aware of an illegal trade, with some feeling well educated on the topic:

I thought that it would just be one in every 20 breeders would be a puppy farmer but…it's more like one in three could potentially be a puppy breeder or smuggler [ FG29] .

However, they thought many consumers were not aware, educated or choose to ignore the signs as their priority was simply to purchase a puppy. This was supported by a smaller portion of participants who admitted knowing very little about the illegal puppy trade. For example:

I wouldn't have known. You would think everybody who wants to raise puppies does it out of love, but in a market that big, you've got people who are doing it just for money [ FG14] .

There is also an element of head in the sand, because it's so awful I don't want to know any more so I don't try and find any more [ FG28] .

An expert similarly suggested that consumers do not want to know about these issues as they are too distressing; but " how are [they] ever going to know what these animals are suffering? You have to look at it" [ EI6].

As previously indicated, some focus group participants found it difficult to distinguish the legal versus illegal trade and so had little concrete understanding of the law. There was general awareness throughout the focus groups that, at the point of purchase, signs of illegality or irresponsibility were: not seeing the mother and to a lesser degree the father, puppies not socialising with their litter-mates, and obvious signs of being unhealthy or unclean (faecal stains, fleas, ticks, and matted hair). Yet others said:

I wouldn't have said I knew what to look for, but I kind of realised that I'd probably have a gut feeling of what was right and what was wrong [ FG1] .

Those who looked for signs of an illegal and irresponsible element to the puppy trade, knew of its existence from television documentaries, the news and charity information campaigns.

With regard to puppy smuggling specifically, stakeholders indicated the presence of diseases uncommon to the UK as well as having an uncommon vaccination record were significant signs, however, the description of the purchasing process by clients was the most telling information on the origin of the puppy (see Table 8).

Table 8: Signs of illegal puppy smuggling identified by survey respondents

Question 23 - What are the signs a puppy has been smuggled?	Always a sign	Frequently a sign	Sometimes a sign	Rarely a sign	Never a sign
Presence of a foreign microchip	7	25	10	4	1
Uncommon vaccination record	8	26	15	0	0
Presence of diseases/illnesses ( e.g. parvovirus), suggesting poor welfare conditions	9	23	17	0	0
Presence of uncommon diseases or parasites to the UK	16	21	9	2	0
Owners description of purchase	14	24	9	2	0

*49 respondents

Price was suggested by some focus group participants as one reason why other people do not do more research prior to purchase, as people simply looked for the cheapest puppy. Interestingly, cheap puppies were not viewed as a clear indicator of the illegal trade by most experts or stakeholders. While many consumers mentioned ignoring the cheapest puppies in an effort to avoid negative elements of the trade, paying a significant amount did not necessarily guarantee the puppy's origin or health. The summary of the costs for Kennel Club ( KC) registered breeders, compared to their 'gold standard' Assured Breeder Scheme ( ABS) provided by two experts [ EI8] provides some indication of the cost of breeding responsibly and the profits available from the illegal trade. Table 9 details the costs of breeding a litter (and cost per pup) of two popular dog breeds (with different health considerations and thereby health requirements). A KC registered Labrador and French Bulldog pup on average would cost £193 and £195 to breed, while an ABS breeder would spend £286 and £254 respectively. These figures, when compared to the approximate cost of a puppy from the research's online advertisement data - £817.88, provides some sense of the profits available for legal and illegal breeders.

Table 9: Comparative costs of breeding KC registered and ABS registered puppies

Breeder	Item	Cost (£)
		ABS Member £ cost per litter	Non ABS Member £ cost per litter
Labrador [litter of 7 pups]	Required Health test - Hip x-rays	250	0
	Required Health test - BVA charge for scoring	115	0
	Required Health test - BVA/ KC Eye test	40	0
	Recommended* Health test - DNA test - prcd- PRA	170	0
	Recommended Health test - DNA test - Elbow grading	63	0
	Puppies Vet check	50	0
	ABS Membership fee	60	0
	Litter registration [£14/£16 per pup]	98	112
	Advertising FAP service	0	20
	Microchipping [£20 per pup]	140	140
	Other ( e.g. food/care) [it is not possible to accurately determine all the additional costs incurred by breeders, this figure is based on the puppy remaining with the breeder for 8 weeks, with an average dog costing £1000 per year for feed/care. There are likely to be higher costs for ABS than non- ABS due to the quality of food and improved care provided, so this figure should be seen as a conservative estimate for ABS members	1077	1077
	Total £ per litter	2,003	1,349
	Total per puppy	286	193
French Bulldog [litter 4 pups]	Recommended Health test - BVA/ KC Eye test	40	0
	Recommended Health test - DNA test - HC- HSF4	50	0
	Recommended Health test - DNA test - DM	50	0
	Participation in French Bulldog Club Health Scheme	35	0
	Vet check (for puppies)	30	0
	ABS Membership fee	60	0
	Litter registration [£14/£16 per pup]	56	64
	Advertising FAP service	0	20
	Microchipping [£20 per pup]	80	80
	Other ( e.g. food/care) [it is not possible to accurately determine all the additional costs incurred by breeders, this figure is based on the puppy remaining with the breeder for 8 weeks, with an average dog costing £1000 per year for feed/care. There are likely to be higher costs for ABS than non- ABS due to the higher quality of food and improved care provided, thereby this figure should be viewed as a conservative estimate for ABS members	615	615
	Total £ per litter	1,016	779
	Total per puppy	254	195

* Recommended tests are not optional, while registration is possible without them, compliance is monitored. Only these tests are specifically required for ABS. However, there are other recommended health tests, which may be conducted by ABS members, at an additional cost (for example, DNA tests - CNM (£48), EIC (£60), HNPK (£48), SD2 (£48) for Labradors).

The nature of the illegal and irresponsible puppy trade is varied and dynamic. It also blends into the legal trade, particularly at the domestic level, which makes it difficult to identify as well as to comprehensively characterise. It appears that a range of offenders are involved ( i.e. legitimate businesses, registered breeders, hobby breeders, more organised crime groups) and thus a multi-faceted strategy to target these diverse strands is most likely needed.

Summary of Respondent Suggestions regards the Nature of the Puppy Trade

1. The ports provide a crucial opportunity for enforcement as once puppies are in the UK it is more difficult for enforcement agencies to identify and respond to the trade, thereby enforcement at the ports must be a priority, with appropriate resources provided to respond to the scale of the problem.

2. The internet facilitates puppy sales to consumers; failure to regulate the advertisement of puppies online faciliatates the illegal and irresponsible international and domestic trade. Thereby, stronger enforcement of the online trade is required, as is the need to make it more difficult for consumers to purchase their puppies from online advertisements (as is done, for example, with the purchase of knives and prescription drugs or gambling online).

3. It is important for enforcement agencies to recognise the different types of trade and offenders in the trade, in order to tailor their response to each (for example, organised crime groups and opportunistic occasional offenders)

4. Problems in the nature of the domestic trade makes the international illegal trade possible. In order to respond to the growing international trade, it is crucial to first evaluate the domestic trade and ensure it is appropriately regulated and enforced.