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

Appendix II: Literature Review

Scoping Research on the Sourcing of Pet Dogs from Illegal Importation and Puppy Farms 2016-2017

Deliverable 1: Literature Review

Author: Dr Jennifer Maher, University of South Wales

Submitted: January 2017

Submitted by Tanya Wyatt & Paul Biddle, Northumbria University and Jennifer Maher, University of South Wales

Introduction

Dogs are the most popular companion animal in the UK; for many they offer companionship and support and a special emotional bond. For others, however, dogs are a lucrative source of income. Evidence from key national and international animal welfare non-government organisations [ NGO] ( PDSA 2016; Dogs Trust 2014, 2015; Royal Society for the Prevention of Cruelty to Animals [ RSPCA] 2016a, b; International Fund for Animal Welfare [ IFAW] 2012; Four Paws International 2013) supports stakeholder (such as the British Veterinarians Association [ BVA] 2014) concerns that illegal and irresponsible puppy breeding and trade is escalating. Central to these concerns are the large-scale industrial and international commercial breeders now characteristic of the breeding industry: effectively a sea-change in UK puppy trade.

Since the introduction of PETS (2012), which relaxed the requirements for importing companion animals to the UK, the commercial and non-commercial movement and trade of companion animals from Europe has increased significantly (Dogs Trust 2014). Simultaneously, stakeholders have identified UK-bred puppies coming from large-scale legal and illegal breeding establishments. The development of industrial-style puppy breeding establishments (often referred to as 'puppy farms' or 'mills', and canine commercial breeding establishments [ CBE]) suggest that: first, legitimate and registered breeders cannot provide enough puppies to satisfy UK consumer demand; second, puppies have become a lucrative and vigorous commodity for trade - both nationally and internationally; and third, the nature of the trade has changed significantly, with fewer puppies now being sold from pet shops (less than 5% according to the RSPCA, 2016a), the majority purchased online or from classified advertisements. Problems inherent in puppy breeding and sales are extensive and encompass all parts of the trade, including commercial breeding, selective breeding, online and international trade, and trade at markets and from third parties (Calder 2014).

The harmful consequences of these changes are widespread - impacting the breeding dogs, their progeny, animal health and welfare, dog traders, consumers, public health and the economy. Holzer (2009:2) identifies puppy mills as "by far, the most inhumane kind of dog breeding that exists today in the United States [ US] and elsewhere in the world". According to Yeates and Bowles (2017) the harms associated include poor care, poor mate-selections and non-compliance with laws designed to maintain a standard of animal welfare (Animal Welfare Act 2007) and minimise disease transfer (Balai Directive - council directive 92/65/ EEC ^[11] ). These harms cause animal welfare problems in the short term (for example, infectious disease) and in later life (for example, behavioural issues and inherited health disorders). Consequently, Burger (2014) and McMillan (2011) found puppies raised in these establishments are more likely to suffer from illnesses and be poorly socialised. According to an EU study 42 percent of legitimate dog traders identified the illegal trade as the main threat to their business ( IBF International Consulting et al. 2015). Consumer behaviour is key to the irresponsible and illegal nature of the current trade - specifically, without capricious and impulsive buyers demanding young 'fashionable' dogs, large-scale commercial breeding establishments and illegal trade would not be profitable. Adjustments to consumer demand will directly impact on the nature and scale of supply.

There are no accurate figures available on the scale or value of the legal or illegal puppy trade, a concern that is raised consistently in both academic and official literature (Yeates and Bowles 2017; Dogs Trust 2015). Academic, official and NGO sources have provided estimates based on available statistics, with particular focus on the online trade. This literature review begins by providing an overview of the prevalence and nature of the puppy trade, before focusing on the literature which helps explain consumer demand and behaviour. An evaluation of current responses to the trade follows, focusing on both informal and formal strategies. Thereafter, the review identifies the widespread consequences of non-compliance and non-regulation. In conclusion, the recommendations offered by key stakeholders are considered. Where possible, this literature review will provide information specific to Scotland.

The Prevalence and Nature of the Puppy Trade

Legal and Illegal Puppy Trade

According to Pet Food Manufacturing Association's 2016 analysis, eleven million (that is, 40 percent of) UK households have one or more companion animals. The current companion animal population stands at 57 million, of which dogs make up approximately 24 percent (n=8.5 million). Within Scotland 22 percent of households have a dog, with an average of 1.5 dogs per household. More broadly, figures available from European Union [ EU] member states on companion animal ownership and trade (European Commission 2013) indicate there are more than one hundred million owned dogs and cats across the EU. One EU study conducted in 12 member states identified 60.8 million dogs and 66.5 million cats, which provided an annual industry revenue of €1.3 billion euros ( CAROcat 2015). The importation of dogs was valued at approximately €21 million euros. The UK is identified as one of the key consumers of this trade. However, estimates vary greatly on the scale of the UK trade, for example, the RSPCA (2016a) suggest it is between 700,000 and 1.9 million animals per year. Yeates and Bowles (2017) more recently suggest between 500,000 and 1.5 million dogs come onto the UK market each year. In Northern Ireland [ NI] alone, puppy breeding is worth £160 million pounds ( BBC Scotland 2015). Although similar statistics are not available for other parts of the UK, according to the Department for Environment Food and Rural Affairs [ DEFRA] (2016), animal related establishment licensing (for example, 2,300 licensed pet shops, 650 licenses dog breeders) comprises the fourth largest group of business licenses issued by local authorities in England and Wales.

In addition to the legal regulated trade, there is a legal unregulated trade, that is, those who breed less than five litters of puppies a year in England and Scotland (and less than three in Wales and NI). Again, it is impossible to accurately estimate scale and value. There is also a buoyant UK illegal puppy trade. Trade is illegal if it breeches regulations, including: Breeding more than five/three litters a year without a license or excessively breeding bitches or selling puppies at less than eight weeks of age (Breeding of Dogs Act 1973 (England and Scotland); Breeding and Sale of Dogs (Welfare) Act 1999 (England and Scotland); Animal Welfare (Breeding of Dogs) (Wales) Regulations 2014; The Welfare of Animals (Dog Breeding Establishments and Miscellaneous Amendments) Regulations ( NI) 2013).

Importing puppies from unregistered premises, without the correct paperwork, treatment or transport conditions (Balai Directive 92/65/ EEC; PETS Regulation 576/2013). Selling puppies without a sales license (Pet Animals Act 1951; Licensing of Animal Dealers (Scotland) Regulations 2009; Pet Shop Regulations ( NI) 2000). Animal welfare requirements on the appropriate treatment and conditions in which dogs should be kept (Animal Welfare Act 2006 (England and Wales); Animal Health and Welfare Act (Scotland) 2006; Welfare of Animals Act ( NI) 2011). Failure to declare income from the puppy trade (Taxes Management Act 1970; Finance Act 2008; Customs & Excise Management Act ( CEMA) 1979).

Fraudulently selling a puppy (The Supply of Goods and Services Act 1982).

It is difficult to differentiate the legal and illegal trade as both the legal trade and non-commercial movement of companion animals provides opportunities for the illegal trade. IBF International Consulting et al. (2015) suggest discrepancies in EU market data and TRACES ^[12] registered trade (intra- EU sales of 46,000 dogs per month compared to 20,779 registered dogs on TRACES a year) provide some indication of the scale of the illegal trade. Under-reporting on the TRACES system is supported by data from Belgium, which recorded up to eight times more introduced dogs from countries of origin than were recorded in the TRACES database in 2012 ( TRACES recorded some 155,000 dogs, including 26,000 puppies, introduced from the Czech Republic, Hungary, the Netherlands and Slovakia). Yates and Bowles (2017) take a similar approach to appraise the scale of the UK market: based on an estimated population of nine to ten million dogs who have an average life-span of 12 years, just over 700,000 dogs are needed annually in the UK to replace those who die. By removing the number of puppies whose sources are known (for example, DEFRA (2012) identified 560,000 puppies were born in England) from those estimated to be coming onto the market (.5-1.5 million), an estimate of the illegal and unregulated trade is possible. The profits recorded from the illegal trade may also be useful to estimate on the scale of the trade. For example, RSPCA prosecutions indentified criminal operations profiting from £8,000 to £40,000 a week from the illegal puppy trade, with one providing an annual turnover of approximately £2 million.

The aforementioned study by CAROcat (2015) reveals that only 13 percent of companion animals purchased in Europe come from professional breeders, although they recognise this estimate is problematic as several countries do not provide a legal definition for a 'professional breeder'. A Four Paws International report (2013) described the Czech Republic, Hungary, Poland, Romania and Slovakia as key puppy production countries, while the Netherlands was identified as a likely "transit country" due to its weaker puppy trade legislation (when compared to neighbouring countries such as Germany). The UK, alongside most Western European countries, were identified as key consumer countries with high market value for puppies. Their report argues that the cheap importation of puppies from production countries creates market distortions which can drive down the profit available to legitimate breeders and enhance the profits for illegitimate traders. For example, the profit available for traders bringing one Chihuahua to Germany is estimated to be €763.80 euros (approximately €15,000 for 20 and €210,000 for 260 puppies). Dogs Trust (2014) reported a significant rise in the international puppy trade to the UK with the implementation of PETS (2012). In the first year, the number of dogs entering the UK via PETS rose by 61 percent. The majority arrive from Eastern European countries and Ireland. Between 2011 and 2013 the number of dogs recorded 'legally' entering the UK under PETS from Lithuania and Hungry increased by 780 percent and 663 percent respectively. According to evidence presented in the Commons Debates (8 ^th Mar 2016: Column 29 WHX) in 2015, 93,424 dogs were imported into the UK from the EU. The RSPCA reported estimates of 30,000 dogs imported from illegal farms in Romania, Hungary, Poland and Lithuania, and 40,000 from Ireland ( RSPCA 2016a). According to Defra, in 2012 just 2.5 percent of those dogs entering under the PETS scheme were found to be non-compliant with PETS. Dogs Trust argue this number is inconsistent with the numbers reported in the illegal puppy trade, suggesting the majority of puppy smuggling goes undetected. Prior to PETS the minimum age of entry for dogs to the UK was 10 months, which prohibited the movement of young puppies and prevented the legal trade providing opportunities for the illegal trade. The sale of puppies from industrial-scale breeding establishments abroad is possible due to a buoyant online marketplace in the UK and other EU member states (for example, Germany and Italy).

Online Puppy Trade

The internet has become a major platform for the commercial sale of animals, in particular dogs, over the last decade. Increasingly, people are looking to the internet to easily access a variety of breeds and instantaneously purchase their puppy. Popular online platforms include specialised purchasing sites (for example, pets4homes), generic buy and sell sites (for example, Gumtree) and social media sites (for example, Facebook). When the majority of legislation across the UK was introduced to regulate puppy breeding and sales, the dominant role of the internet in this trade was not foreseen. Consequently, there is limited regulation online which permits anonymous unethical third party sellers and commercial breeders to sell directly to the public. Puppies available online usually demand a lower price, as evidenced by the Four Paws International (2013) report. Figure 1 identifies the average selling price for dogs direct from pedigree breeders, pet shops and internet platforms.

Figure 1. Average Selling Price of Dogs in Hungry, Slovakia, Austria and Germany

(Reproduced from Four Paws International (2013:5))

While literature on the online puppy trade is sparse, online platforms are recognised by many organisations to be central to the facilitation of irresponsible and illegal puppy trade (for example, Calder 2014; RSPCA 2016a; PDSA 2015, 2016). According to the PAW report ( PDSA 2016, see also 2015), 91 percent of companion animal owners (n=3,869) and 96 percent of veterinary professionals (n=673) surveyed believed online pet advertising and sales should be regulated. This would likely have a significant impact on the puppy trade as 50% of companion animal owners in this study would consider getting a companion animal from an online advert on a classified website. IFAW (2012) conducted an investigation into online puppy advertisements in the US and in just one day, on nine websites, well over 733,000 puppies were advertised for sale. The advertisements featured dozens of breeds, and prices ranging from $1 to thousands of dollars for a single puppy. They identified nearly 10,000 advertisements from the six dedicated puppy seller websites-representing approximately 10% of total advertisements on these sites. As a conservative estimate, they indicated that 62% of the advertisements were "likely puppy mill" sourced. In line with the Four Paws International (2013) report, the holiday season was identified as a peak time for online puppy advertisements.

In 2001 the UK Pets Advertising Advisory Group [ PAAG] (2016a), made up of animal welfare organisations, trade associations and veterinary bodies, was developed in response to growing concerns regarding the irresponsible advertising of companion animals for sale, rehoming, and exchange. PAAG argue the extensive use of online platforms in companion animal sales has attracted unscrupulous breeders and dealers and has facilitated consumer impulse buying. Backed by the Government, PAAG have developed minimum standards which classified websites should meet when advertising companion animals ( PAAG 2016b). In 2014 they conducted two 'snapshot' moderation studies of UK companion animal online advertisements ^[13] , with a particular focus on assessing the ability of online companion animal advertisers to implement the minimum PAAG standards and to self-regulate their advertisements. Between January and June 2014 PAAG volunteers looked at approximately 70,000 advertisements, which equated to 81% of the total advertisements available on selected sites ( PAAG 2015a). Sites reported for not meeting the minimum standards decreased from 20 percent to an average of 4-6 percent during this period, suggesting websites were making improvements to their practices. However, these improvement reached a plateau and during the second moderation (October, November, and December 2014), conducted on approximately 3,700 advertisements, declined (9.7 percent (n=359) were reported for minimum standard breaches). In conclusion, their report notes that despite PAAG support few websites consistently meet the minimum standards and cannot be trusted to self-regulate.

Most recently, concern over irresponsible online trade has focused on social media platforms such as Facebook. PAAG's (2015b) snapshot study to assess the use of Facebook to sell animals, found 930 closed groups in a 24 hour period. PAAG volunteers were accepted as members of 230 groups, the majority of which focused on one species (60 percent of these on dogs). The majority - 58 percent (n=134 groups) - were in breach of PAAG minimum standards, in particular advertising without a photograph or providing age information.

Jones (2010) argues the increased use of online platforms to purchase puppies has correspondingly spurred a jump in the number of US puppy mills. IFAW (2012) concurs that the:

anonymous and unmonitored nature of online sales [through online advertisements] has also opened the door for unscrupulous breeders-who emphasize profit over animal welfare-to skirt existing laws designed to protect dogs from these inherently cruel high-volume operations, commonly known as "puppy mills."

Industrial-scale puppy farms are kennelling facilities where puppies are produced in large numbers for commercial sale, in conditions consistent with commonly farmed animals (McMillan et al. 2011). Evidence suggests that the conditions prevailing in these establishments are injurious to the health and welfare of these dogs (see page 17 for further discussion). The anonymity characteristic of online advertisement and sales platforms make these a logical choice for illegal and irresponsible breeders and traders. They benefit by reducing the face-to-face contact with consumers, which conceals the poor conditions in which puppies are bred. Yeates and Bowles (2017) use rational choice theory to explain how this trade is facilitated by: (a) a lack of guardians for the animals and purchasers (with weaknesses in consumer and animal protection legislation); (b) the presence of suitable victims (that is, vulnerable animals and unwitting consumers); and (c) offenders' strong motivation for financial gain. Developments in online trade exacerbate the problems inherent in the puppy industry, including negative animal and human health, economic and environmental consequences (see 'The Impact of Non-compliance and Non-regulation in the Puppy Trade' for further details).

Understanding Consumer Behaviour in the Puppy Trade

The thriving UK consumer market for puppies makes it a key location for supply and movement of legal and illegal puppy trade. Key agencies have identified that there is a shortage of legitimate breeders to supply current UK demand (Yeates and Bowles 2017). Nonetheless, every year local authorities across the UK kill thousands of unclaimed stray dogs who cannot find a home. According to the Dog Rescue Federation 2014 Survey of local authorities 105,931 stray dogs were handled (year ending September 2014), of which 6,515 were 'put to sleep' (see PTS category in Table 1) and the outcome was unknown for a further 12,000. Despite the availability of these 'rescues', many consumers choose to purchase a puppy. Better understanding of how consumers make their purchase decisions, and how to influence them, is needed.

Table 1: Overall number and percentage of stray dogs and the outcome for these dogs across the UK

United Kingdom	Dogs Handled	Outcomes							Error - Over reported
		RTO	Rescue	Pound	Rehomed	PTS	Unknown	Total
England	86782	45045	19399	9960	4434	5474	6470	91052	4270
Scotland	3838	2394	933	113	207	112	163	3922	84
Wales	8618	3554	2157	1284	713	424	507	8639	21
Northern Ireland	6693	2602	1642	823	768	505	478	6818	125
Total	105931	53595	24131	12180	6122	6515	7885	110431	4500
Percentage of dogs handled		48.53%	21.85%	11.03%	5.54%	5.90%	7.15%	100.00%

(Reproduced from the Dog Rescue Federation 2014 Survey (2014:3))

The importance of animal companions to the lives and experiences of consumers is recognised in marketing literature (Aylesworth et al. 1999; Holbrook and Woodside 2008:1); the emotional bond between consumers and their animal companions is central to associated marketing and "goes far beyond anything covered by the usual observations concerning "fantasies, feelings, and fun" (Holbrook and Hirschman, 1982) or "possessions as extensions of the self" (Belk, 1988)". The decision to purchase a puppy is emotionally driven and influenced by a range of factors including fashion, family, friends and prior experiences with dogs ( RSPCA 2016b). For example, the influence of fashion on consumer choices is ubiquitous in UK society. Ghirlanda et al. (2014) evaluated the impact of mass media on the popularity of dog breeds, finding an increase in ownership of breeds featured in movies, for up to 10 years after release. The popularity of these breeds correlated with the estimated number of viewers during a movie's opening weekend. These findings demonstrate that although puppy trends may seem erratic, it is sometimes possible to identify specific underlying causes and respond to these. In line with Ghirlanda et al.'s findings, the RSPCA (2012) identified three factors which created the impulse to purchase a puppy: nature, culture and cultural shift. Nature refers to the ability of puppies to eclipse rational thought. For example, in their 2016(a) report the RSPCA identified the 'cute' factor (strongest between the ages of six and sixteen weeks) provides a powerful motivation for purchasing a puppy. Accurately ageing young puppies is difficult, which allows illegitimate sellers to lie about their age and advertise them to consumers at their most marketable age . Culture applies to the positive ingrained messages and images which drive consumers to make specific breed purchases. Cultural shift refers to consumers' views of breeds as brands and their belief that dogs are consumable objects which are replaceable .

Puppies, unlike other consumable products in law, are recognised as having a unique relationship with humans, which is translated in legislation into duties of care. This unique relationship is also recognised by consumer behaviour scholars who provide an interesting perspective and understanding of human-companion animal consumption. A special issue of the Journal of Business Research devoted to 'Animal Companions, Consumption Experiences, and the Marketing of Pets' presents a typology which encapsulates the main ways in which animal companions enrich consumer lives. The article highlights a difference between the consumption of companion animals and objects, with the former regarded as 'good for consumers'. Animal companions are 'good' for consumers as they contribute aspects of value: 'economic' (for self-oriented extrinsic ends); 'hedonic ' (appreciated intrinsically for their own sake); social (consumption used to influencing the responses of others); and altruistic (an ethical or spiritual influence viewed as an intrinsic end in itself) (Holbrook and Woodside 2008). In a similar manner, Aylesworth et al. (1999) refers to 'categorisation theory' and 'extended self theory' to explain human-companion animal consumption - suggesting consumers develop categorisations which influence how different dogs impact on our perceptions of ourselves and thereby on purchasing behaviour.

Whereby companion animals may uniquely benefit consumers, Ahuvia (2007) and Beverland et al. (2008), using Buberian concepts, argue most consumers are not 'good' for companion animals. Buber (1923) regards interpersonal relationships as either 'I-Thou' or 'I-It', with the highest forms of relationship being I-Thou (Ahuvia 2007). Through this relationship each individual is treated as intrinsically valuable, rather than as a tool to achieve some other goal (as in I-It relationships). Beverland et al. (2008) refer to this as intrinsic (I-Thou) and extrinsic (I-It) ownership - with the latter identified as the 'dark side of pet ownership' due to the negative impact on the companion animals. Using this approach Beverland et al. (2008) and Ahuvia (2007) advance our understanding of companion-animal and status-oriented consumption. Specifically, these concepts are useful for understanding the motivations of consumers in the puppy trade and their willingness to support irresponsible breeding or selling and to ignore or neglect expert advice when choosing a puppy. Of particular interest is the understanding that:

extrinsic pet consumers (a) place a high value on their dogs being cute; (b) choose small dogs, which they like to hold and cuddle; (c) like to buy their dogs clothing and toys; (d) believe that the dogs should do as they are told; (e) believe that it is the owner's job to mould and shape the dog's character; and (f) see their dogs as innocent to the dangers in the outside world and, hence, vulnerable and in need of restrictive rules for their own protection … In contrast, intrinsically motivated dog owners (a) like larger dogs that have a more mature persona; (b) tend to see their dogs as being much closer to their existential equals; (c) praise their dogs for being intelligent and believe that their dogs understand a good deal of human speech; (d) assume that the dog is able to fend for itself out of the home; and (e) believe that to maintain the right kind of relationship with the dog, they must respect its wishes and not expect it routinely to do whatever they say (Ahuvia 2007:498).

Kristen (2009) suggests the harms experienced in the puppy trade are directly connected to consumer's often misplaced desires and beliefs. For example, beliefs around the characteristics of certain breeds or the desire to buy an expensive breed more cheaply. These beliefs form four types of human-companion animal relationships: master-slave, employer-worker, parent-child, and friend-friend. The harms associated with the first three are evident in the growth of industrial-style puppy farms, the increased development of abnormalities and deformities through selective and irresponsible breeding, and the number of companion animals abandoned or surrendered each year to shelters. Further research would be useful in identifying if consumers involved in the different relationship types (for example, intrinsic or master-slave) are more or less likely to impulse-buy or use online platforms to facilitate their purchase.

According to Burger (2014), increasing public awareness on the harms of the illegal puppy trade and educating consumers on where and how puppies are bred and sold may decrease demand for puppies and specific puppy breeds, and create a market of consumers willing to pay more for better conditions (as with free-range foods). If consumers, for example, demanded evidence that puppies are bred humanely and ethically prior to purchase, breeders would be pressured to either comply or lose profits. However, education and awareness may not be enough. According to an RSPCA study on 7,272 adults aged 16-64, one in five puppy owners (defined as those who acquired a puppy in the past two years) surveyed no longer had their dog (University of Bristol 2011; RSPCA 2012).

Furthermore, almost a third of owners spent less than a day researching the breed prior to making the purchase, two-thirds bought a puppy from the first litter they viewed, less than half viewed the mother, while only one in five received advice from a vet and nearly a quarter of the owners (24 percent) based their decision mainly on appearance . These findings reveal that many consumers are capricious and impulse buyers. In conclusion, the RSPCA report suggests there is a need to interrupt and challenge consumers' nostalgic and brand oriented views of dogs, in particular, before they reached 'consideration phase'. Furthermore, it is crucial to offer support to consumers who have already purchased a dog, to prevent the dog being abandoned or relinquished ( RSPCA 2012).

Regulation of the Puppy Trade

Responses to the puppy trade involve both official and nonofficial agencies and approaches - from educational and preventative measures to punitive instruments. These responses apply to agents at different stages of the trade (that is, breeders, transporters and traders) and consumers.

Informal

Key reports detail the undertakings of NGOs to educate consumers and enhance compliance. This is evident in the literature provided by the RSPCA (2012; 2016a; 2016b), Dogs Trust (2014; 2015), PDSA (2015; 2016), Four Paws International (2013) and Eurogroup for Animals (Calder 2014). For example, the RSPCA's 'Get Puppy Smart' campaign helps consumers make the right decision in choosing a happy and healthy puppy (University of Bristol 2011). UK NGO's also provide a central role in regulation, through enforcement of policy and legislation, and facilitating partnership work and multiagency enforcement operations (such as Operation Delphin - Scottish SPCA 2016). In the absence of legislation to regulate the online trade, NGO PAAG (2016a) has developed a set of Government-endorsed minimum standards with which to advise and assist leading UK classified websites. One minimum standard, for example, directs these websites to display advice on many aspects of companion animal ownership, including warning messages about suspected illegal imports. Similar efforts are apparent in other EU member states, as NGO Four Paws (2013) Germany has collaborated with eBay classified online ads in order to raise consumer awareness of illegal puppy trading. Since most of the irresponsibly bred and imported puppies are now sold via online advertisements, these responses are crucial.

Formal

Yeates and Bowles (2017) provide a detailed overview and evaluation of the UK legislation relevant to the puppy trade, which is detailed below in Table 2. Dogs transported within the EU must comply with the Balai Directive (Council Directive 92/65/ EEC), PETS (Regulation 576/2013 & 2016/429), Regulation ( EC) No1/200536 and International Air Transport Association [ IATA] (2016) Live Animal Regulations (for air transportation). EU regulations are enforced through various UK legislation (for example, Animals and Animal Products (Import and Export) Regulations 2004, Welfare of animals (Transport) (England) Order 2006).

Table 2: Summary of the main legislation relating to the trade, sale and breeding of dogs in the UK

Issue	Legislation	What it does	How effective is it at dealing with the trade?	Consequences
Breeding of Puppies	Breeding of Dogs Act 1973 (England and Scotland) Breeding and Sale of Dogs (Welfare) Act 1999 (England and Scotland) Animal Welfare (Breeding of Dogs) (Wales) Regulations 2014	Sets conditions for licensing of commercial dog breeding establishments; dogs cannot be sold before eight weeks of age.	Enforcement is a challenge; it allows issuing of licenses for any dog breeders but it is only mandatory for those breeding five or more litters (England) or there or more litters (Wales) a year.	Puppy dealers do not have to be licensed if they are buying rather than breeding but sell commercially bred dogs.
Identification of Dogs	Microchipping of Dogs (England) Regulations 2014 Microchipping of Dogs (Wales) Regulations 2015 Microchipping of Dogs (Scotland) Regulations 2016 Dogs (Licensing and Identification) regulations (Northern Ireland) 2012	Makes it compulsory to identify a dog from eight weeks and ensure that its details are kept up to date.	About 20 percent of dogs are not microchipped yet and it will be a challenge to ensure details are updated; enforcement will be a challenge as it is not seen as a priority area for local authorities and they have not been provided with any extra resources to do so.
International trade	Health status in commercial trade covered by Directive 92/65/ EC Health status in non-commercial by PETS Regulation 576/2013 OJ L178/128.6.2013 Transport conditions covered by regulation 1/2005 OJ L3.1 5.1.2005	Sets rules on numbers, certification, age and vaccination of dogs traded between countries. Sets conditions on the times, feeding and watering of puppies being transported commercially.	Enforcement is a challenge; illegal trade occurring through PETS being used by commercial dealers and rescue organisations; challenges with fraud and illegal declaration of puppy age. The transport times are limited to 24 hours before a break is required and do not seem to be enforced.	Dogs that are not microchipped, too young or not vaccinated coming into the UK from Ireland and continental Europe; disease, behaviour and health risk of puppies being sold.
Sales of puppies/dogs	Pet Animals Act 1951 Licensing of Animal Dealers (Young Cats and Young Dogs) (Scotland) Regulations 2009 Pet Shop Regulations (Northern Ireland) 2000	Sets up a licensing scheme for pet shops and sale of pet animals; the Scottish law aims to regulate the trade in young cats and dogs.	Enforcement is a challenge; updates under the Animal Welfare Act have been postponed so dealing with the internet is challenging.	Puppy dealers should use a pet shop license to sell even though they don't have a pet shop.
Welfare/ cruelty	Animal Welfare Act 2006 (England and Wales) Animal Health and Welfare Act (Scotland) 2016 Welfare of Animals Act (Northern Ireland) 2011	The framework law to ensure good animal welfare and prevent unnecessary suffering. Further information in the Welfare of Dogs Code of Practice in the relevant countries.	The law provides a good framework; enforcement is done through the police in Northern Ireland, SSPCA and Procurator Fiscal in Scotland and local authorities and the RSPCA in England and Wales.

(Reproduced from Yeates and Bowles (2017: 28))

In summary:

Under PETS the conditions for the non-commercial movements of pet animals were relaxed. Up to 5 companion animals may travel with owners with a valid PET passport (issued by an authorised vet) that contains proof of their identity, anti-rabies vaccination and other relevant disease preventive health measures. Anyone importing a puppy under PETS with the intention of selling it is operating illegally.

The Balai Directive harmonises the commercial trade in dogs and imposes more stringent controls on importers. Dogs imported to be sold must be declared to authorities (through a TRACES certificate), come from a recognised (registered) breeding place; be identified and vaccinated as per PETS rules. The European Commission manages the TRACES database, providing certification and tracking which helps competent authorities in each member state enforce EU regulations.

Under Council regulations ( EC) No 1/2005 transporters must be registered to move dogs across borders and provide suitable transport conditions.

The IATA Live Animal Regulations provide the worldwide standard for handling and transporting live animals by commercial airlines in a safe and humane manner.

In addition to urgent demands to regulate the online trade, the literature also emphasises the need for harmonised EU animal welfare legislation which addresses the welfare concerns of companion animals. As detailed above, current EU legislation only concerns the transport of dogs in connection with an economic activity or where their movement or trade poses an animal or public health risk. The failure to implement harmonised welfare legislation results in fewer enforcement options to tackle the variety of problems surrounding breeding and trade of puppies from production counties. Linked to this, the Eurogroup for Animals argues that there is a worrying lack of traceability across Europe of responsible commercial practices, as well as responsible ownership ( CAROcat 2015). Traceability is not possible due to the absence of an EU-centralised identification and registration system for dogs.

As Yeates and Bowles encapsulate in Table 2, there are significant problems in the compliance and enforcement of UK and EU regulations. A recent DEFRA (2016) consultation on animal breeding and selling regulations indicates these are outdated, inflexible, incompatible with current welfare legislation and cumbersome for both enforcers and businesses. The key problems raised by respondents to the consultation were: inconsistencies in enforcement and resource limitations; increased financial (or other) incentives to breed illegally due to enhanced licensing conditions; difficulty revoking licenses; too few (particularly random unannounced) inspections; no regulation of online sales; and no strategy in place to reduce consumer impulse buying ( DEFRA 2016). DEFRA has published guidance for companion animal owners to help them avoid buying an illegally imported puppy, however there has been no move to formally regulate online trade. A formal strategy is required as NGO reports suggest illegal traders adapt their procedures (such as using a bank of mobile phones to ensure a different contact number is used for each breed) to deceive consumers and undo efforts to educate them (Calder 2014).

A study authorised by the European Commission on the welfare of dogs (and cats) in EU commercial practices, involved a survey of almost 30,000 key stakeholders from the twelve member states which comprise 85 percent of the EU dog population ( IBF International Consulting et al. 2015). The majority of national competent authorities reported high compliance (value 5) with relevant national welfare legislation, as detailed in Table 3. The UK, however, reported high non-compliance. Broader national opinion on compliance with transportation legislation identified non-compliance (value 1) in three of the five countries (where data was available), as detailed in Table 4. Information was not available for the UK, while other member states indicated non-compliance due to poor communication between stakeholders. Non-compliance by member states provides opportunities and loopholes for the illegal trade. In response, 36 percent called for better implementation and enforcement of existing standards, which would be best implemented by relevant competent authorities or the EU.

Table 3: Level of compliance with national legislation on the welfare of dogs and cats reported by competent authorities

	Case study Member State
	BE	DE	ES	FR	HU	IT	NL	PL	RO	SE	SK	UK
Compliance rating	5	5	1	6	5	6	4	1	NA	4	5	1

(1= no compliance, 7= full compliance; NA = not applicable).
(Reproduced from IBF International Consulting et al. (2015:31))

Table 4: Level of compliance with national legislation on the transport of dogs and cats by general national opinion

	Case study Member State*
	BE	DE	ES	FR	HU	IT	NL	PL	RO	SE	SK	UK
Compliance rating	NA	1	1	5	NA	5	NA	NA	NA	1	NA	NA

*1= no compliance, 7= full compliance; NA = not applicable.
(Reproduced from IBF International Consulting et al. (2015:28))

Highlighting the problem with PETS enforcement, Dogs Trust (2014) imported a soft toy puppy into the UK multiple times using a fake passport and microchip. Their subsequent study (2015) identified similar inadequacies in the checks conducted by carriers (as required by DEFRA) on dogs entering the UK. In particular, these studies emphasised the inadequacy of current practice, which requires the carriers to only check the passport and microchip number, rather than conduct sight checks and scan the dogs themselves. Illegal traders can use microchips not implanted in the dog, and then, post entry implant a UK microchip to conceal all traces of a dog's international origin. Vier Pfoten/Four Paws [Four Paws] (2016) also confirm the current system can be used to deceive consumers as to the 'real' origin of the puppy they purchase, and the conditions in which it was bred, as the nationality of the passport cannot guarantee the puppies country of origin. UK Chief Veterinary Officer, Gibbens ( BVA 2014), argues it would require a huge input of resources to boost current administrative checks with physical checks. Rather, he suggested the new PETS requirements should enhance compliance with rabies regulations, prevent passport fraud and permit traceability back to the issuing vet in the country of origin.

Further concerns are raised on the use of TRACES to enable enforcement. As previously noted, inconsistencies in TRACES and marketing records of member states are evident ( IBF International Consulting et al. 2015). This discrepancy may be facilitated by database recording procedures. Dogs are categorised under 'other mammals' and thereby unidentifiable on the system (Four Paws 2016). It is notable that TRACES is significantly more efficient at monitoring and enforcing the movement of animals intended for human consumption. A similar rigorous system could be developed for the puppy trade. Further, while the use of TRACES is compulsory for the competent authority of the EU member states of departure, checks are not mandatory for other authorities. Four Paws (2016) also warns the expansion of TRACES (in 2008 to 76 states), without the respective expansion of resources to enforce movement, may have in fact reduced the effective and usefulness of the system.

Further responses to enhance enforcement and compliance were noted in other member states. The Italian Ministry of Health recognised the increasing illegal movement of puppies (and kittens) from Eastern Europe to Italy (Ferri 2013). In response, the Ministry developed two new operational tools: the procedural manual for the implementation of inspections in the EU movement of dogs and cats and the "Law ratifying and implementing the European Convention for the protection of companion animals, and internal adaptation standards" (Law no. 201/2010). The latter, identifies penal and administrative punishment for the illegal commercial trade and non-commercial movement of companion animals, ranging from €100 to €2,000 euros. Those found guilty of puppy smuggling may be detained for 3 to 12 months and fined €3,000 to €15,000 euros (Ferri 2013). Belgium bans the sale of imported dogs and provide an online listing of authorised breeders ( IBF International Consulting 2015). Belgium, alone, requires the registration of all puppy breeders, including hobby breeders.

It is noteworthy that Jones (2010) raises very similar concerns (archaic legislation with gaping loopholes, poor animal welfare protection, unregulated puppy mills and online trade, and enforcement budget and personnel constraints) in the regulation and enforcement of the US puppy trade.

The Impact of Non-compliance and Non-regulation in the Puppy Trade.

The substantial growth in the commercialisation of dogs has had far reaching consequences for animal welfare, due to irresponsible genetic selection, mutilations and inhumane disposal, and behavioural and physical abnormalities linked to industrial-style puppy farming. Further problems result from non-compliance by member states, enforcement agencies and puppy breeders and traders, and non-regulation of key issues innate in the puppy trade, such as animal welfare, online trade and traceability. Non-compliance and non-regulation result in well documented animal and human health, environmental, and economic/financial consequences, as detailed below.

Animal Health

Animal welfare problems are evident at every stage of the puppy trade due to the financial incentive for many non-professional ^[14] breeders to cheaply produce and quickly bring to market and sell 'popular' breeds. Problems start with the choice of breeding dog (for example, with genetic diseases), the breeding and rearing of the puppies, transportation to markets and sale. According to data from France, professional breeders spend significantly more than non-professional breeders to bring their puppy to market (€762 euros per puppy compared to less than €260 euros), with the greatest difference in cost resulting from medical treatment (vaccination, basic care, qualify food) and compliance with legal practices (registration and identification, pet passport, breeding certificate and taxes) ( CAROcat 2015). Further research from the UK Kennel Club (2013 survey) found 94 percent of puppies bought direct from a professional breeder were reported as having good overall health. However, almost one in five puppies bought via social media or the internet died before they were six months old and twelve percent of puppies purchased this way had serious health problems that required expensive on-going veterinary treatment from a young age (Kennel Club 2013). Poor, severe or chronic health and behaviour problems are repeatedly documented in animals bred in unsuitable environments (Yeates and Bowles 2017). Calder (2014) identifies three studies which support this link: Lockwood (1995), Appleby et al. (2002) and McMillan et al. (2011) suggest canine commercial (or non-domestic) breeding establishments can be associated with higher rates of health and behaviour problems in dogs. McMillan et al. (2011:86) found "dogs in these facilities are routinely housed for their entire reproductive lives in cages or runs, and provided with minimal to no positive human interaction or other forms of environmental enrichment". A total of 1,169 former CBE breeding dogs, who had been living in their adoptive homes for an average of 2 years, were included in the study. When compared with a convenience sample of similar dogs, former CBE dogs were reported as showing significantly higher rates of health problems, fear (both social and non-social), house-soiling, and compulsive staring and significantly lower rates of aggression (toward strangers and other dogs), trainability, excitability and energy.

Transportation facilitates further harms, as evidenced by the many underage puppies entering and being sold in the UK ( BVA 2014). Underage puppies do not have a fully developed immune system and cannot regulate their own body temperature. Consequently, the stress of travelling can result in hypoglycemia, which is exacerbated by factors such as intestinal parasites, vomiting and diarrhoea ((Ministero degliAffari Esteri (Ministry of Foreign Affairs) 2011). An inquiry by the Italian Veterinarian Council (Four Paws International 2013) found over half of 'controlled' puppies were unwell, infected with endoparasites (34 percent), parvovirus (23 percent), and fungal infections (17 percent), while 10 percent carried distemper. This level of infection may be due to a biological phenomenon called 'microbisme', which according to veterinarians can occur when a large amount of healthy animals are transported or housed together.

Human Health

Although the UK is currently free from terrestrial rabies (Goddard et al. 2012), human health concerns largely focus on the risk of rabies being introduced through the illegal puppy trade. The risk posed by EU dogs under the current PETS rules is low, according to UK Chief Veterinary Officer Gibbons ( BVA 2014), however he warns that puppies for sale entering under the PETS regime is "going to be bad for the risks, especially for Echinococcus [tapeworm], and it's going to be bad for puppy welfare and it's going to be bad for the people who buy the puppies" ( BVA 2014:552). Goddard et al.'s (2012:1781) support this by concluding that although the risk of rabies entering the UK was low, with ether the UK PETS or EU policy, the level of risk "is highly sensitive to noncompliance with the regulations".

A more common harm to human welfare stems from the distress experienced by some consumers who are required to meet the financial and emotional costs of caring for a puppy with severe health and behavioural issues, and possibly euthanasia of their recently acquired companion ( RSPCA 2016a).

Environmental

An outbreak of rabies or other controlled disease or parasite may require the culling of UK wildlife or domestic animals ( DEFRA 2011), a negative and expensive environmental impact. Environmental harm may be more likely to result from irresponsibly-managed industrial-scale commercial puppy breeding establishments. A study by Gill (2013) on the environmental impact of a US puppy mills, found pathogens such as bacteria, viruses, and parasitic protozoans in dog faeces, may be present in concentrations harmful (that is, more than 80,000 per 100 litres of water) to waterways and humans. Although there is no research available on UK puppy farms, these types of establishments are growing. Thereby, environmental harm should be considered a significant impact of non-compliance and non-regulation of breeding establishments.

Economic/Financial

Due to the scale of the legal puppy trade and associated businesses and profits in the UK and EU, non-compliance and non-regulation can have substantial economic impact. As previously argued, the availability of cheap puppies from Eastern European member states distorts prices in consumer countries (such as the UK), and consequently legitimate UK breeders and traders cannot compete in the market (Four Paws International 2013). This will also impact on businesses providing (health or registration) services in the puppy trade. CAROcat (2015) estimated a loss of €312 million euros annually in government income from unpaid taxes for such services. Similarly, the RSPCA (2016a) suggests the illegal trade cost the UK Government millions in undeclared income . These unpaid taxes and illegal profits may fuel other serious and organised crime, for example, trade companies involved with Eastern European breeders were linked to the mafia and police (Four Paws International 2013).

Recommendations

In recognition of the issues identified in the puppy trade and the problems relating to regulation of the trade, many authors provide recommendations for an enhanced response to the legal and illegal puppy trade. Recommendations focused on the European Union (and member states), UK government agencies, consumers and agents involved in the trade. This report concludes by summarising the recommendations for each of these stakeholders.

EU/Europe

Improve animal welfare legislation. The FECAVA (2011) urged the EU to recognise the importance of companion animal welfare as a relevant issue for EU legislation, and to include references to companion animals in the second Animal Welfare Action Plan. Respondents to the IBF survey supported further action from the EU on animal transport and animal welfare ( IBF International Consulting 2015). Their preferences were for enhanced enforcement and implementation of legislation, in addition to information and education campaigns.

Mandatory identification and registration of dogs across the EU with data held in a central database. An EU-wide compatible identification and registration system for dogs would facilitate identifying the scale of the puppy market, enhance responsible breeding, trade and ownership of dogs, reduce health risks and the number of abandoned and euthanized dogs, and enable transparency in the puppy trade to reduce non-compliance and enhance enforcement. While member states have compulsory and non-compulsory identification and registration systems, according to Four Paws (2016), FECAVA (2011) and IBF (2015) the databases and traceability systems are not uniform across the EU. To facilitate the level of traceability required for enforcement, an access point at the European level to all the national databases is required.

Harmonise, standardise and improve TRACES entries with regard to dogs. Four Paws (2016) maintain member states should be required to harmonise, standardise and improve TRACES data entry (that is, transponder numbers, tattoo numbers, passport numbers, registration numbers, licence plates) and record the total number of checks carried out concerning the non-commercial movement of companion animals. Furthermore, they argue for compulsory training of an adequate number of personnel and specialist agents to increase the number of TRACES checks carried out.

Enhanced communication between member state competent authorities on detected non-compliance in the movement of dogs. Enforcement and transparency would be enhanced if competent authorities in destination member states were required to inform the competent authority of the country of dispatch of instances of non-compliance ( CAROcat 2015).

UK Government Agencies

Provide clarity on the scale of the UK puppy market. The RSPCA (2016b) identify the lack of clarity on the scale of the UK puppy market as a key issue requiring urgent attention.

Provide additional funding and training for enforcement personnel. The RSPCA (2016b) argue the need for greater surveillance at ports to identify and prosecute illegal puppy dealers, training for local authorities on new micro chipping legislation and licensing of puppy breeding and selling, and adequate budgets for response demands. IFAW (2012) recommend the Government increase funding in order to adequately enforce regulation of puppy sales online. Competent authorities should be trained to verify the age of a puppy when it is vaccinated (Four Paws 2016). More generally, Dogs Trust (2014) urge enhanced training for all front-line staff.

Provide additional opportunities for multi-agency work. Dogs Trust suggested key enforcement agencies, such as APHA, DEFRA and Trading Standards, provide further focus on agency availability and multi-agency cooperation (Dogs Trust 2014). Currently a great deal of multi-agency work is led by NGOs (Scottish SPCA 2016).

Enhance current licencing and movement regulations. The RSPCA (2016b) support: model license conditions (which detail consistent standards and practice) for puppy breeding and selling to provide greater harmonisation between local authorities; the need for anyone selling a puppy to be licensed; an increase to eight weeks for the age at which a puppy can be sold and reduce the threshold for a breeding licence to two litters or more. Overall there was support from the DEFRA (2016) consultation to update the licensing system for animal establishments (including breeders). Support from the 1,709 key stakeholder respondents involved: a single animal establishment licence (70.5%); the requirement of model conditions by local authorities; (71%); prohibiting the sale of puppies below the age of eight weeks (90%); a statutory licensing threshold for breeders at three or more litters of puppies a year (64%); to remove calendar-year restrictions on licenses (83%); prohibiting the transfer of licenses to new owners (61%); and requiring license owners to notify Local Authorities of major changes to the premises or scale of activities (94%). Dogs Trust (2014) recommend enhancing movement legislation, for example, not permitted movement of dogs into the UK before 6 months of age.

Develop further legislation to regulate online advertisement of dogs. IFAW (2012) declare the government should promulgate regulations that effectively address industrial-scale breeders using the internet and remove advertisements from illegal breeders. A review of legislation to tackle the problem of online advertising is urgently required to enable enforcement, according to PAAG (2015a). The aforementioned PAAG advertising standards should be made mandatory for all UK online advertisements.

Enhance relevant agency powers to investigate offenders. Further powers are needed for agencies to investigate the credentials of puppy dealers' and access data to support prosecution. 72 percent of respondents to DEFRA's (2016) consultation support powers of entry for Local Authorities. Four Paws (2016) argue relevant government agencies should investigate the credentials of any company moving dogs internationally and provide tax numbers of these organizations to the EU. The use of other legislation (for example, fraud) was also suggested to prosecute offenders.

Enhance penalties for non-compliance. Dogs Trust (2014) suggest introducing a fixed penalty charge for those apprehended illegally bringing dogs into the UK for both commercial and non-commercial offenders (as identified in the Italian enforcement approach). Holzer (2009) suggested similar strict administrative regulations and penalties for US breeders, facilitators and commercial retail sellers.

Investment in targeted educational programmes. Dogs Trust (2014) argue the need for official agencies to target consumers purchasing puppies online rather than relying on welfare charities to carry out this work. IFAW (2012) also emphasise the importance of educating consumers about the cruelty inherent in irresponsible and illegal breeding and trading to encourage consumers to source puppies from more reliable and appropriate sources. A strategy is required to interrupt and challenge consumers' nostalgic and brand oriented views of dogs, in order to prevent impulse and trend buying ( RSPCA 2012). The UK Chief Veterinary Office ( BVA 2014:1 ) underlined the need to develop a strategy to stop people buying cheap puppies, suggesting this is "a message that we all have a responsibility to carry".

Consumers

Mobilise consumers to monitor and reject internet sales platforms. PAAG (2015a) emphasise the importance of mobilising the public to monitor online advertisement platforms to facilitate enforcement and to reject those sites which do not offer adequate information, advice and guidance to enhance compliance among breeders and traders.

A mandatory cooling-off period for consumers. DEFRA (2016) recommend a mandatory cooling-off period for consumers purchasing a puppy to reduce impulse buying.

Enhanced consumer protection laws and advice. Holzer (2009) suggests generous provisions are needed to encourage consumers to 'sue' irresponsible traders.

Market Traders

Encourage online platforms to provide transparency and refuse advertisements from irresponsible and illegal breeders. Encourage advertising websites to strengthen efforts to identify and block irresponsible and illegal breeders from using their sights to post puppies for sale. Online platforms could provide more transparency for consumers looking to buy a puppy online by giving clear information on the puppy breeder or dealer and introducing a pop-up warning (about breeders) page on the puppy advertisement (Four Paws 2013).

In summary, the recommendations indicate there are many opportunities for improvement. Essential responses to the puppy trade include enhanced consumer knowledge, guidance and empowerment; enhanced licensing and movement laws and regulation of online advertisements and sales, harmonisation of EU animal welfare legislation, improved resources to enable current and enhanced measures at UK and EU-level, mandatory and enhanced recording and traceability across the EU, and further collaboration between key stakeholders.

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