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

Improving the Puppy Trade

Experts, stakeholders and consumers who recommended improvements, predominently focused on consumers, breeders, traders and official agencies. Consequently, suggestions often incorporated a multi-strategy and multi-agency approach. For example, one focus group participant argued: " the whole canine industry needs more regulation and that's the seller's side of it. The buyer's side needs education" [ FG4]. Another argued that: "All these things depend on like how much we as a society really care, because it can be stopped, it just takes investment, kind of by everybody [ FG13]. Experts took a broader, more international, perspective when making their recommendations, while consumers and stakeholders focused their suggestions on improvements to the domestic trade. What follows is an overview of the recommendations suggested by all participants to improve the puppy trade - focusing on consumer behavior, breeders and traders and then regulation and enforcement.

Consumer Behaviour

Tackling consumer demand was deemed essential for a successful puppy trade. Participants suggested this could be done by educating and advising consumers and decreasing demand for specific types of dogs:

And it's a case of informing people, therefore. Just making sure that they either stop demanding those breeds because it is not good for the breed itself, or stop people from spreading the word that, "Hey, this is a really fashionable dog. Look at me and my cute Pug." It's hard to cut demand [ FG11] .

Both experts and consumers suggested this would not be easy to achieve. Participants acknowledged that not all buyers are open to changing their behaviour, consequently, any attempt to provide advice and education must be targeted at the right people and in the most effective manner. Some consumers suggested consumers should be required to demonstrate their knowledge - through a " doggy driving licence" [ FG5] or " dog ownership certificate" (Germany may have an example course) [ FG4]. This suggestion was supported by experts and professionals. Most consumers focussed on educating buyers about the trade, for example:

1. the national press, bus shelters and other popular platforms such as the internet or TV soap operas for informing the general public on the dangers and abuse in the puppy trade [ FG1; FG2; FG15; FG21]. Furthermore, these would be more effective with celebrity endorsements from credible people such as 'Paul O' Grady', 'Martin Clunes', 'David Attenborough' or 'Ricky Gervais' and provide hard-hitting images and 'scare tactics' detailing the reality of the puppy industry:

There definitely needs to be more public awareness. I sat and did my research and even I got caught [ FG14].

There's a lot of hard hitting advertising campaigns out there now for drink driving, drug use, all that sort of thing, but see having something like a puppy, a wee Staffie, for instance, in a puppy farm, somebody takes it, and you show it through its life, becoming a really aggressive dog because that's what happens. Something like that would really hit hard [ FG16].

I think if you show a time-lapse of this dog being bred, all the puppies there, all in a nice clean bed and then eight weeks down the line the bed is a mess and then she's got a new litter of puppies and the bed is still a mess and then eight weeks down the line she's got a new litter and the bed just gets muckier and muckier. But the puppies still look good [ FG21].

2. An increase in documentaries which expose the illegal puppy trade and help consumers purchase in an informed manner, such as " The Right Puppy", " Choose the Right Puppy" [ FG13; FG17].

3. Experts and stakeholders suggested an urgent need for education to focus on helping consumers locate their puppy. Consumers argued for an increase in offical advertisements and education online [ FG10], as consumers felt there was no guaranteed websites available [ FG27] for advice and guidance:

If it was a government thing, that would certainly help, but I suppose really what you are talking about would be if you are looking for a puppy, what you do is you go into Google and the first thing that will come up on the search thing is that it is a government thing which then directs you to this website [ FG16].

If you went on Google and one of the first things that came up was a gov.uk website. You'd think, oh well, that looks official, let's have a look at that one for some advice first [ FG23].

4. Accessible and reliable information on the requirements of owning a puppy/dog to ensure consumers are aware of the effort and responsibilities. One focus group participant suggested making a video available or to facilitate prospective buyers spending a day with a puppy to understand the impact it will have on your life [ FG30]. For the same reasons, another FG participant suggested prospective buyers go to a training class with another dog to experience how difficult owning a dog can be [ FG4].

5. The use of a simple acronym that promotes a small number of steps to help consumers buy their puppy, as consumers are overwhelmed by the amount of information available [ FG1]. A small portion of consumers used the puppy packs available from NGOs, which detail the questions to ask breeders, but found this to be too detailed and embarrassing to ask [ FG28]. A shorter guide may make this information more accessible to the general purchasing public.

6. A list of people who consumers could go to for advice or information [ FG1; FG13], ( e.g. veterinarians, NGOs). One focus group discussed the merits of setting up a voluntary online group - such as 'borrow my doggie' but as a source for people who want help in choosing their puppy [ FG23].

7. Mandatory dog awareness classes for owners [ FG19]. In particular, education in the classroom (as part of the national curriculum) was proposed by a number of participants, as children can have a substantial impact on the purchasing process and are the next generation of buyers [ FG22]. This was also supported by experts.

8. Clearer guidelines on how to report a suspicious sale or purchase [ FG23] for all consumers, including help lines and report lines.

9. A standard guide price for dogs: " This is what you can expect to pay. I know a few Cockapoos who are anything [from] about 300 to like 2,000. It's a massively ridiculous price range" [ FG24].

Impulse buying was recognised by all consumers as particularly problematic as consumers who are educated may still make an impulsive and emotional decision in buying a puppy. Consequently, consumers proposed steps to avoid or delay the purchase: get a recommendation for a breeder, bring a vet or other professional with you, never buy on first viewing the puppy, view the puppy frequently before buying, don't bring the full amount of money when first viewing the dog - only bring enough for a deposit to ensure you do not take the puppy there and then, use a well-recognised breeder rather than the internet to locate your puppy, view the documentation in advance of purchase, view the puppy with the mother and in his/her home, have a list of questions with you when visiting and ask these prior to meeting the puppy, and put a puppy contract in place.

When survey respondents were asked to comment on strategies proposed to change consumer behavior, the suggestions thought to reduce consumer purchases 'a lot' were better traceability of animal from birth to sale, stopping online sales, mandatory registration for all breeders and traders and more effective enforcement of existing legislation and protocols. Those deemed less likely to reduce purchases from the illegal puppy trade were a mandatory cooling off period and a compulsory puppy information pack (Table 18).

Table 18: Influences on Consumer Purchasing Behaviour

*49 respondents

Question 34 - How, if at all, would any of the changes, listed below, reduce puppy buyers purchase of illegally bred and traded puppies?	Would reduce a lot	Would reduce	No impact	Would reduce a little	Would not reduce at all
Legal sanctions/prosecution (purchasers)	26	18	3	2	0
Legal sanctions (suppliers)	32	14	2	1	0
Wider legal changes	27	19	3	0	0
Stop third party sales	24	16	8	0	0
Stop online sales	35	8	5	1	0
Pop-ups with information attached to online sales	21	21	6	2	0
Mandatory cooling-off period after purchase of puppy	15	13	18	1	1
Internet advertisement guidelines ( PAAG) made mandatory	21	15	10	2	0
Education in schools	25	17	5	1	0
Prohibit sales from abroad	17	18	7	5	2
Mandatory registration for all breeders and traders	34	10	2	1	0
Better traceability of animal from birth to sale	36	8	4	1	0
More effective enforcement of existing legislation and protocols	34	12	3	0	0
Compulsory Puppy Information Pack	13	19	13	0	4
Make it easier to identify legal, responsible breeders	28	15	6	1	0
National register of pets and their owners on entry to the UK	31	11	5	2	1

In response to the question on the best methods of communicating with the public, survey respondents also felt that Television campaigns would be the most effective followed by celebrity endorsements and radio campaigns. Other suggestions included information through pet supply stores, vets' practices and rescue centres as well as advertisements through social media, like Facebook (Table 19).

Table 19: Consumer Information Approaches

Question 35 - Which of the approaches listed below, designed to provide consumer information, do you think would be most effective at preventing illegal puppy trading?	Very effective	Effective	Neither effective nor ineffective	Ineffective	Very ineffective
Information on government websites	5	15	22	5	2
Newspaper campaigns	18	23	6	1	0
Radio campaigns	20	21	6	2	0
Television campaigns	30	15	3	1	0
Celebrity endorsements	25	16	7	1	0

*49 respondents

Participcants in one focus group strongly argued that to make an impact on demand, it is crucial to help consumers to make smarter and more ethical purchasing choices, and to forcefully promote the dogs in need of homes - those in animal recues [ FG23]. Another agreed, explaining: I never knew there was a Vizsla rescue centre, and if some of these centres were advertised more, people might go to them rather than go to puppy farms et cetera [ FG1]. Other focus group participants recommended consumers become more involved in preventing the illegal trade, suggesting involvement in petitions to the government and Facebook forums against the irresponsible trade [ FG2].

Breeders and Sellers

Among experts, professionals and consumers, those responsible for the trade were seen to have a key role in improving the puppy trade. For some consumers, those responsible for the trade involved all people who breed a litter " even if you do one litter" [ FG2]. Specifically, they felt occasional breeders needed to be more informed about the potential problems and responsibility of breeding from their dog; " there is so much involved with breeding. It is exhausting" [ FG16]. Thereby, consumers called for a re-classification of what constitutes a breeder. In line with this, consumers argued that breeders needed to be more accountable for the current condition of the trade [ FG9]. For example, one FG participant recommended legitimate breeders being heard more and engaging in public debate and in consultations. In particular, a number of consumers argued that KC breeders needed to be better represented online ( e.g. better websites) in order to demonstate the benefits for consumers in buying from them:

…you know I was saying breeders have crappy websites but in future they won't, you know? In future they probably will have better websites and that, actually, I think will start to help as breeders like are more in the public eye and putting out ... why do I charge the prices I charge? How do I break those down, you know? What are the standard things that I do? What do I look for in an owner for one of my dogs, you know? [ FG13].

Another focus group suggested there needs to be a public database of all breeders, which highlights reputable breeders and is regularly checked [ FG22].

In terms of breeders' responsibilities, consumers suggested breeders should play a significant role in educating and supporting consumers and thereby supporting their dogs. This could involve a number of strategies:

1. Ensure all puppies are vet checked and it is mandatory that purchasers are supplied with an official form from the vet confirming there are no obvious health problems, the puppy has been vaccinated, microchipped and wormed and is of a certain age [ FG7].

2. Ensure all puppies are registered in advance by breeders in order to receive a number to advertise the puppies. Consumers should be able to check basic breeder details through a central website [ FG4].

3. Place the onus on breeders to educate prospective owners and to give lifelong support to their dogs [ FG4]. To do so breeders should be happy to support consumers with advice and recommendations, even if they are not purchasing their dogs [ FG5]. To provide a breeder contract/agreement in place with the buyer which means the buyer can return the dog if they could not look after it [ FG29] or the consumer had problems [ FG26]

4. Breeders are required to vet buyers and if they do not fit the criteria, the breeder needs to refuse to sell them the dog [ FG8]. Many consumers expected to be 'interviewed' by the breeder/seller, and failure to do so implied the seller did not care for the dog's welfare [ FG23]:

I would have liked an interview on getting an animal rather than, "Okay, so she's here, you can take her next week". I would have liked her to say to me, "Are you suitable for me to give you a living creature?" and I didn't get that and I would have liked that [ FG29].

5. It is important to point out that both experts and consumers were aware of the possible problems resulting from turning consumers away. That is, if they cannot get a puppy from a legitimate source, they will go to less reputable breeders [ FG5]. This issue was previously identified by experts with regard to rehoming rescue dogs.

6. Require breeders to demonstrate they are up to date and use best breeding practice, evidenced by research. For example, one breeder [ FG6] recommends the Military Superdog Programme, which requires a more hands-on approach to handling and socialising young puppies in order to reduce stress in the dogs and mother. Another consumer mentioned the use of 'puppy culture' and 'puppy enrichment' classes from four weeks old:

And it's just raising the criteria, we're asking the breeders, and as you raise that criteria if the breeders are then going to that level then obviously the buyers are going to start looking for that level as well [ FG8].

Case Study 5 details an example of a breeder who engages in many of these positive behaviours, which she argues justifies the higher price charged for her puppies and should be required of any person selling a dog.

Case Study 5: Suggested Breeder Requirements

First, the breeder only advertises her puppies on her personal website, the KC website and Champ Dogs, not on generic online advertisement providers. Second, consumers must complete a questionnaire and discuss their requirements with the breeder in order for her to shortlist applicants. Third, all puppies are KC registered, microchipped and first vaccinated. Fourth, when the puppies are eight weeks old, the purchasers are brought to her premises for a two hour "Puppy Right Start" session, in order to pick up their puppy. These sessions are used to advise consumers on how to take care of their puppy, provide them with the necessary details, answer any questions and to create a supportive community among the prospective owners. Breeders should be required to complete a form when handing puppies to their new owners, to record who the puppy has been registered to/purchased by [ FG16].

It is important to note that although recognised breeders could provide a strong voice for public education, consumers recognised that it was not necessarily in their interest to take the time to do so, as they were not reliant on the general public for their puppy sales.

Regulation and Enforcement

In terms of regulation and enforcement, participants focused on changes to legislation, better traceability and enforcement strategies. Changes to formal regulations supported by experts and stakeholders involved significant changes - such as, banning trade from outside the UK [ FG12], banning online advertisements and third party sales [ FG5] and formalising regulation of the online trade. Other suggestions were alterations - such as, increasing the age at which pups can be passported, sold and neutered (Sweden and the Netherlands may have regulation that can be useful to compare) and/or introducing fixed penalty notices, for example, on the spot fines for overseas carriers with incorrect paperwork. Consumers supported an increase to the age at which pets can travel and formal regulation of online trade. As mentioned, one focus group suggested a ban on online sales:

You shouldn't be able to buy a puppy online. Make it illegal… not finding a puppy, buying a puppy. You can't just go and [buy them but] you would want the breeders to be able to promote themselves online, of course [ FG17].

Both stakeholders and consumers argued there was also a need to penalise those who buy puppies from illegitimate sources [ FG2; FG12], as is the case for those who purchase fake or pirated goods [ FG11]. However, many argued that the focus should be on enhancing trader standards and policing traders, rather than consumers:

…it's not about the public so much, it's about the breeders. You've got to make sure they're legit because then it doesn't matter how inexperienced the purchaser is, the breeder is up to standard [ FG1].

A variety of suggestions were posited to achieve this:

1. Develop an independent agency who is responsible for monitoring sellers and their documentation, " almost like Scottish Quality Assurance …It's like when you buy a car you get a V5…" [ FG1]. Another consumer suggested this should look:

kind of like a school where you can actually see the inspection report, to have open inspection reports so that you see the breeder and you can see the most recent inspection report and when it was done…and you can see how they did and if they failed they have to be inspected again within six months, but they're not allowed to sell any puppies until they've been re-inspected… I know there's a lot of resources associated with that though [ FG28].

2. Develop a registered association of puppy sellers, " you're not allowed to sell a puppy unless you're part of a trade association. Like Corgi gas fitters" [ FG17]. With this approach the government " signpost consumers to approved breeders, not just registered breeders" [ FG4]. Furthermore, it provides breeders with the necessary incentive to raise standards. In line with this, one focus group participant who works in an LA indicated they were looking at expanding their Trusted Trader scheme (used for home improvement traders) to animal breeders and boarders to enhance consumer confidence in the sector [ FG5] - see Case Study Six below. Consumers, experts and stakeholders suggested an alternative to this approach the KC Assured Breeder Scheme - see Case Study Seven below.

3. Make sellers aware that they will be monitored and investigated by the HMRC, with all online advertisements requiring a tax reference [ FG27].

You know the way we have fraud lines and things like that? Do you think something like that would be good that was directly linked to the HMRC? Would you feel inclined to ring them and let them know about the people you have been dealing with [ FG4]?

4. Put in place punishment that is certain, severe and deters irresponsible traders:

…more prosecution, more stronger prison sentences or fines or better punishment when these crimes are uncovered [ FG24].

…but maybe if it was more publicised when there are these big fines or when there are prosecutions and when there are confiscations…It doesn't really make big news, does it? [ FG27].

5. Shut down websites that are repeated offenders in permitting irresponsible online trade [ FG12]. Require websites facilitating trade to vet advertisements prior to publication [ FG13] and role out PAAG Minimum Standards as the formal requirement for online trade [ EI1; EI2; EI11; EI12].

6. Provide a legal impetus for key NGOs to enforce the legislation, enter traders premises and carry out checks [ FG8] - an option strongly supported by some experts [ EI4].

7. Enhance traceability across the UK and EU (like the system in Ireland where in order to get a Balai permit the traders must first have a MODR equivalent). According to experts this will make traders more accountable. Linked to this, experts and consumers argued for a centralised microchipping database and professional microchipping only [ FG22; FG27] and others argued for professionals to be accountable (eg veterinarians) if they fail to register microchips to the breeders [ FG5].

8. Regular and unannounced inspections by LAs [ FG21].

9. Provide appropriate funding and staff to enforce the regulations [ FG5]: "I think it's all down to enforcement, and I don't think there is enough funding for enforcement". Resources, or lack thereof, were identified as the chief limitation on enforcement, in response to this, one focus group suggested LAs look for help from other professionals: " they need to work out how they're going to police it, whether it's getting vets, dog trainers you know, to sign up to help" [ FG1]. In line with this, one focus group suggested funding an NGO that is already looking directly at what breeders do [ FG16] to carry out enforcement duties.

Case Study Six: LA Trusted Traders Scheme

To become involved in the Trusted Traders Scheme, breeders and boarders would need to apply and comply with a set of criteria - for example, demonstrate " they trade fairly and legally, and whether they have the right procedures in place if things go wrong…If they actually exist, for a start. Plenty people have a trading address and they don't even trade from that address, so that's a good start". The current Trusted Trader scheme is funded through a housing grant and overseen by a dedicated person. The scheme would work similarly to the Good Garage scheme, in that consumers would provide feedback, " so it is an opportunity for people to make a decision based on what other customers before them have experienced". In addition traders can be removed from the scheme, for example, " because they've not been able to provide us with an updated insurance policy for this year, or because there have been complaints, or not willing or able to resolve them" [ FG24].

Case Study Seven: KC Assured Breeder Scheme

The Assured Breeder Scheme standards meet all local authority licensing requirements and place additional requirements on breeders in terms of health ( e.g. relevant mandatory health screening tests), welfare ( e.g. bitches must not be bred from if they are over 8 years old or if they have previously produced more than 3 litters and members must commit to lifetime rehoming), socialisation (a plan must be in place and provided information on future socialisation and exercise), information to buyer (buyers must be provided with a contract, information on the complaints procedure, and written advice on immunisation as well as on worming, feeding and grooming and veterinary treatment carried out). Every member is visited prior to breeding or registering litters and inspected every three years or more frequently (on a risk assessed basis). Assessors are located across the whole of the UK. The training of Assessors is overseen by UKAS (United Kingdom Accreditation Service), who also annually audit the assessors. The KC would inspect assured breeders and pass inspection reports on to LAs, along with a nominal registration fee. This would save LAs from needing to do inspections and would avoid financially motivated breeders to remain in/join the Scheme [ EI12]

One focus group [ FG18] considered:

"the kennel club assured breeder scheme is obviously a great idea. The breeders could earn different badges based on different targets they had met so that prospective buyers could see these. Breeders also had to undergo home checks every couple of years to retain their assured status. I think this idea could be rolled out in places other than the kennel club if there was another central governing body to control this. Also a comprehensive and up to date website could be put together and publicised to prospective buyers with information on what health tests puppies should have had for each breed and what buyers should expect of their breeders"

The study participants proposed a broad range of suggestions that may prove useful in reducing the irresponsible and illegal puppy trade. In the next section, we summarise and propose recommendations and solutions based upon the data collected.

Summary of Respondent Suggestions for improving the puppy trade

1. Creation of a scheme that requires consumers to attend training/awareness classes prior to their puppy purchase and/or issue buyers a 'driver's licence' or 'owner's certificate' after demonstrating their knowledge of caring for a puppy.

2. Develop a single 'go-to' website or website application which contains: a list of registered or approved breeders/sellers, a list of professionals who can give advice on purchasing a puppy, videos about caring for and raising a puppy, guidelines on how to report suspicious sales and purchases including access to a helpline, guidelines on the prices of puppies, and an acronym checklist to make the scrutiny of the puppy and seller at the time of purchase simpler and less time consuming.

3. Wide-scale education campaign, which would include changes to the national curriculum to teach children about animal welfare issues and a public awareness campaign in the national press and other forms of media with a celebrity endorsement to bring attention to the problem.

4. Require all breeders and sellers to have the puppies vet checked, that they be registered, that they vet the buyer and issue them a contract, and that they provide evidence of up to date practices such as enrichment and socialisation activities.

5. Establish a voluntary online and in-person support group that can provide guidance on purchasing and raising a puppy and who are willing (for a fee) to accompany people when visiting puppies for sale.

6. Create an independent agency to monitor breeders and sellers online and off-line, rather than rely on LAs and other organisations who have competing priorities and lack specialisation.

7. Increase prosecutions and sanctions for puppy trade violations.

8. Develop Trusted Trader Schemes or link into the KC Assured Breeder Scheme to monitor and improve the standards of breeding and enhance transparency.

9. Ensure the HMRC is more involved in monitoring commercial breeders and traders, in particular of online advertisements leading to sale.

10. Increase funding for enforcement agencies ( e.g. LA) responsible for regulation and/or expand enforcement powers to NGOs or adopt other multi-agency approaches to increase unannounced inspections and overall enforcement.

11. Improve traceability of puppies by enhancing breeder/seller and consumer responsibility in updating registation and by providing a central database for the microchip data in order to identify prevelence and trends in the puppy trade.

12. Require all puppies be vet checked prior to purchase and make it mandatory that sellers supply purchasers with an official form from the vet confirming there are no obvious health problems, the puppy has been vaccinated, microchipped and wormed and is of a certain age.

13. Require registration of all sellers and all puppies to be registered by breeders in advance of their advertisement online. Consumers should be able to check basic breeder details through a centralised website.