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

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.