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

Executive Summary

Background and context

Dogs are the most popular companion animals in the UK ^[1] ; for many people, they offer companionship, support and a special emotional bond. For others, however, dogs are a lucrative source of income ^[2] . Evidence from key national and international animal welfare non-government organisations [ NGO], supports stakeholder (such as the British Veterinary Association [ BVA] 2014) concerns that the illegal and irresponsible puppy breeding and trade are escalating. Central to these concerns are the UK and international large-scale commercial breeders and the largely uncontrolled third party online traders who now appear to dominate the puppy trade: effectively creating a sea change in UK puppy trade.

The aim of this report is to present existing and new empirical evidence on the scale, nature and value of the illegal and irresponsible puppy trade, with a particular focus on the role of breeders, traders, consumers and enforcement agencies in the trade. We aimed to answer two central questions:

• What are the nature, extent and value of legal and illegal puppy sales in the UK?
• What improvements can be made at each part of the trade to help prevent the international illegal trade of puppies and unregistered puppy farms?

In order to answer these research questions and thus propose interventions and solutions to improve the status quo, a mixed-methods research design was employed consisting of a literature review, collection and analysis of 12 weeks of online puppy advertisement data in Scotland, data collection from Trading Standards Scotland and TRACES (the Trade Control and Expert System), 12 expert interviews, 53 stakeholder surveys and 40 focus groups including a total of 160 puppy owners.

Prevalence and nature of the trade

The UK puppy trade is made up of legally regulated, legally unregulated, illegal and irresponsible breeding and sales. It is difficult to distinguish these different types of trade, thereby making it impossible to accurately quantify the scale of the UK puppy trade. Estimates of the value of the trade, the total numbers of puppies bred and sold, or the number of active breeders and sellers and those who are acting unscrupulously or illegally are problematic. A snapshot of the online trade found almost 1,500 advertisements of puppies for sale in Scotland from seven websites over a 12 week period. This equated to at least 4,074 puppies estimated to be worth over £3.3 million with the average price per puppy £817.88. Extrapolating this amount to an entire year indicates the value of the puppy trade in Scotland is a conservative £13 million considering the snapshot only monitored seven websites. According to the empirical data, those profiting from the puppy trade are a mixture of individuals selling litters, hobby breeders, and small and large commercial enterprises. Across these groups, there are examples of good practice (such as complying with PAAG minimum standards, vetting perspective buyers), evidence of unscrupulous breeders and traders (for example, irresponsible breeding, rearing and sales practices) and illegal activities (such as importing commercial dogs as pets or using fraudulent passports). The irresponsible and illegal trade was identified across the UK, although the geographic location of each country resulted in different trends in each (for example, Wales and Scotland were the point of destination for trade from Ireland, while England receives trade from mainland Europe).

International trade through UK ports and trade facilitated through the internet were two areas identified in the data, which provide avenues for decreasing the irresponsible and illegal puppy trade and increasing the accuracy of data regarding the prevalence and nature of the trade. Both the existing literature and interviewees assert that further understanding of the prevalence and nature of the problem is essential in order to respond appropriately. This could be accomplished through the development of a process which collates and makes better use of available databases and more accurately records both the legal and known illegal trade.This would need to be widely accessible and shared between formal and informal agencies and stakeholders. Clarity on the value of the legal and illegal trade should assist enforcement agencies such as Local Authorities [ LAs] to allocate appropriate resources to monitor and enforce the trade - the limitations of current resouces were emphasised throughout the literature and the empirical data. Furthermore, puppy consumers present a critical opportunity for addressing the nature and prevalence of this trade. First time buyers and people acting on impulse or with limited research often inadvertently fuel and engage in the illegal and irresponsible trade. However, even conscientious consumers may purchase from unscrupulous traders due to the complex, fluid and grey nature of the market. Consumers would benefit from formal data (with sensitive information removed) being shared in the public domain. This would help to assist in educating consumers and stakeholders about the prevalence and nature of the irresponsible and illegal puppy trade, to enable them to circumvent these aspects of the trade.

Consumer behaviour in the trade

The internet is the principal source of information, as well as the main conduit for consumers purchasing puppies. Interviewed consumers reported being overwhelmed and confused by the scale of the online trade, but nonetheless believed purchases through online advertisements to be more reliable and regulated than is the case. While the internet is the main conduit for the illegal and irresponsible trade, it also provides multiple opportunities for potential interventions. Both existing literature and interviewees suggest that formal regulation and monitoring (rather than the current ad-hoc approach or self-monitoring) of websites advertising puppies (and other live animals) for sale, will positively impact on consumers' and traders' behaviour. The Electronic Commerce ( EC Directive) Regulations 2002 indicates that some level of regulation is required of all online advertising sites, refered to within as an 'information society service', however, it is important to recognise that there are extensive limitations in regulating websites outside of the UK who can (and do) offer puppies for sale to UK consumers. The internet can facilitate a single 'go-to' website or web application to assist in improving consumer purchasing experiences and behaviour. This could entail accurate information about breeders/sellers, advice and support on how to purchase and raise a puppy, and an avenue to report suscpicious sales. At present there are many websites (such as those provided by NGOs and government agencies) which provide assistance and advice and some online advertising agencies provide links to these, however, consumers were uncertain which one to use, especially when faced with conflicting information.

Overall, there is a need for wide-scale education on the irresponsible and illegal puppy trade. For example, the national curriculum provides opportunities to discuss animal welfare needs (such as the five freedoms) with young people, focus on responsible purchasing of puppies during these sessions would help educate the consumers of tomorrow. While schools and teachers could be encouraged to include this in their lesson plan, it is important to ensure such educational measures are evaluated to ensure they are influencing responsible purchasing and ownership. Both consumers and stakeholders referred to media programmes as a key source of their understanding of the illegal puppy trade. Thereby, consumer awareness can be enhanced through further campaigns involving the national press, social media, and TV programmes (such as soap operas and documentaries) with celebrity endorsements. These mediums must highlight the animal welfare and personal harms characteristic of the trade, the criminality involved in the trade and how to be a responsible consumer. Furthermore, informing consumers of their purchasing rights will help them to report illegal and irresponsible behaviour in the trade. It is essential for consumers to understand the significant consequences of the trade in order to motivate them to engage responsibly.

Responses to the trade

Current responses to the illegal and irresponsible puppy trade consist of formal legislation and informal programmes undertaken by law enforcement, NGOs and other stakeholders. While some responses are UK-wide (such as the Pet Travel Scheme [ PTS] and Operation Delphin) most formal regulation and informal programmes are individually focused on Scotland, England or Wales (or combination thereof - see page 14 for overview of relevant legislation). Both the existing literature and empirical data question the ability of current legislation and enforcement to respond to the aforementioned seachange in the puppy trade. These concerns are in part due to 'out of date' legislation (for example, The Pet Animals Act 1951) and inconsistencies between devolved sale and trade regulations. With regard to the latter, the puppy trade is not only a national, but an international problem, which would benefit from a united approach from within and without the UK. Weaknesses in one location (for example, the Irish and Northern Irish boarder) will negatively impact on the whole UK trade. The UK exit from the European Union provides an opportunity to review international legislation related to the trade. The Environment, Food and Rural Affairs Committee (England) has recently commissioned a review of the regulations relating to companion animal welfare, including the breeding and sale of pets (House of Commons 2017). A similar review would be useful in Scotland, Wales and Northern Ireland to identify regulations which need to be updated in line with changes to the nature of the trade. For instance, although the commercial sale of puppies is regulated in Scotland, England, Wales and Northern Ireland, both the literature and empircial data identifies this is not enforced with regard to online advertisements for sale, that is, there is little (or no) enforcement of non-licensed online traders. Although anyone selling puppies as a business requires a license (under the Pet Animals Act 1951), enforcement is usually focused on fixed premises. Online sales, according to the majority of interviewees, are not similarly monitored and enforced. Furthermore, online sellers are not currently required to provide their licensing details as part of their advertisement. According to DEFRA (personal correspondance) the ongoing review of the animal activities licensing system will update the licensing system in England and emphasise that online sellers are required to comply with these conditions - including providing licensing details on advertisements. A similar review across the UK would be beneficial. PTS regulations also provide openings for the illegal trade with regard to the number of dogs each person may accompany (up to five) and the limited traceability processes for dogs arriving from overseas. For example, while PTS requires dogs to be microchipped, the regulations do not require registration of the microchip, thereby preventing traceability. While compulsory microchipping and registration is regulated across the UK, each country authorises different database providers. There is a perception that a single centralised UK database (ideally feeding into an EU database) would facilitate a fuller movement recording system, of the sort that exists for cattle and sheep.

Animal welfare can be compromised at each stage of the trade, including post sale or seizure. Harms include, but are not restricted to, inappropriate breeding (sometimes to produce particular physical features), living and transportation conditions, health and behavioural problems and abandonment and euthanasia post purchase. In order for traders to cut costs, animal welfare is frequently sacrified; profits are enhanced even when a large percentage of animals die as a result of these conditions. According to interviewees, informal responses to the trade often have the greatest impact on these welfare harms. Formal responses, in contrast, can inadvertantly exacerbate welfare problems, for example, puppies can be 'disposed of' when seized, spend months in quarantine or years in kennelling facilities awaiting trial of their owners. Enhancing the welfare of victims of the trade must be central to the responses in place. Both the existing literature and empircial data identify the licensing and inspection of breeders and sellers as laissez-faire in most LAs, suggesting there is little protection for dogs involved and many opportunities for the development of unregistered puppy farms. Many LAs have experienced financial and staff cuts and do not have the resources necessary to prioritise inspections and/or investigations. In some areas, such as Scotland, NGOs assist formal agencies with enforcement - significant benefits have been identified where such multi-agency partnerships exist. While other partnerships - such as between DEFRA and some carriers at English ports - were viewed by respondents as ineffective. Prosecutions and sentencing using the current puppy trade regulations were viewed as inadequate. The rewards available from engaging in the illegal trade are not consistent with the penalties in legislation, consequently they are unlikely to act as a deterrent. Furthermore, the number of convictions across the UK for puppy trade offences were believed to be inconsistent with the nature and scale of the illegal trade. Further use of legislation and sanctions, for example, focusing on tax evasion and organised crime, was believed to be a 'more robust' response to serious and frequent offenders. Finally, consumers, are pivotal in the puppy trade, in particular, responses must work to reduce the size of the market, through reducing consumer demand, enhancing consumer awareness and decreasing opportunities for illegal sellers to engage with consumers.

A detailed summary of recommendations arising from this report may be found at Recommendations and Proposed Solutions.