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Page 1: BACKGROUND: INDECISION...“seriously concerned for the welfare of puppies being sold” at a licensed pet shop. lue ross has given several reasons why it believes a ban on third party
Page 2: BACKGROUND: INDECISION...“seriously concerned for the welfare of puppies being sold” at a licensed pet shop. lue ross has given several reasons why it believes a ban on third party

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BACKGROUND: INDECISION

In September 2014, Blue Cross stated it was 1“backing the Pup Aid campaign, spearheaded

by celebrity vet and animal welfare campaigner Marc Abraham, to ban the sale of puppies

and kittens in pet shops.” It warned the public “don’t be tempted to buy” because the

animals often “have been produced in intensive breeding operations” which are “free

from any sort of husbandry.” It explained that “Pet supermarkets are prime retail outlets

for selling commercially bred puppies and kittens, and life on the shop floor is no place for

these young animals either” because “spending the first few weeks and months of life in a

shop environment means these pets miss out on positive early life-forming experiences.”

Blue Cross was concerned that “putting pets on display can also encourage people to make

impulse purchases”.

However, during 2016, Blue Cross has repeatedly altered its position on a ban on the third party sale of puppies (through licensed pet shops) sometimes changing from explicitly supporting the proposal:

On 11th May 2016, in a 2Dog World article entitled ‘Charities respond to claims of

U-turns and mixed messages at EFRA enquiry’ Blue Cross chief executive Steve Goody

said “his charity fully supported a ban on the sale of puppies in pet shops.”

On 1st December, 2016 Blue Cross released their 3‘Unpicking the Knots: the case for a more cohesive approach to pet welfare legislation’ report. In the report, Blue Cross state “We would like to see a total ban on pet shops selling puppies and kittens.”

1 https://www.politicshome.com/opinion/blue-cross/66472/puppies-and-kittens-arent-pet-shop-stock 2http://www.dogworld.co.uk/story.php/157991/34/charities_respond_to_claims_of_u_turns_and_mixed_messages_at_efra_enquiry/b3ce6c711f17f4849781a03907e878da 3 https://www.bluecross.org.uk/sites/default/files/downloads/Unpicking%20the%20Knots%20report.pdf

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BACKGROUND: INDECISION

Then claiming that a ban wouldn’t work, within the space of just a few weeks:

On 27th May 2016, in a Politics Home article entitled 4‘To solve the puppy trade

problem, we need to be pragmatic’ Blue Cross state “A ban on this type of

selling would likely force third party selling underground and would fail to

tackle the problems.”

On 11th January 2017, in a 5Dog World article entitled ‘Celebrity vet claims

charities have ‘vested interest’ in third-party puppy sales’ Blue Cross deputy chief

executive Steve Goody said “A ban on third-party sales would not solve the

problem of poor welfare standards in breeding and would be impossible to

enforce.”

QUESTION 1: Why has Blue Cross repeatedly changed its position on the sale of puppies in pet shops when it hasn’t

altered its opinion on the issues arising as a result of the trade?

LATEST POSITION STATEMENT

Blue Cross’ 6latest position (January 2017) is that a ban would risk causing more problems than it solves, even

though the charity’s 2016 investigation into the licensed pet trade revealed “shocking findings” and Blue Cross was

“seriously concerned for the welfare of puppies being sold” at a licensed pet shop.

Blue Cross has given several reasons why it believes a ban on third party selling is not “the most effective way to

tackle and improve the breeding and sale of dogs and puppies”:

It wouldn’t improve breeding welfare standards

It would be impossible to enforce

It would drive the trade underground

It would result in a deficit of puppies

Exemptions for charities might create a loophole

(Dog World 11th January 2017)

4 https://www.politicshome.com/news/uk/environment/opinion/blue-cross/75457/solve-puppy-trade-problem-we-need-be-pragmatic 5http://www.dogworld.co.uk/story.php/173220/34/celebrity_vet_claims_charities_have__vested_interest__in_third_party_puppy_sales 6http://www.dogworld.co.uk/story.php/173220/34/celebrity_vet_claims_charities_have__vested_interest__in_third_party_puppy_sales

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BLUE CROSS RECOMMENDATIONS

In its report 7‘Unpicking the Knots: the case for a more cohesive approach to pet welfare legislation’, Blue Cross

has made a number of recommendations “to improve the welfare of pets being used for breeding and sale.”

Although these recommendations constitute a radical overhaul of pet licensing and despite stating the charity would

like to see a “total ban on pet shops selling puppies and kittens”, a ban has not been recommended. Instead Blue

Cross has proposed a “registration and licensing system for anyone breeding or selling animals” as “the most

effective way to tackle and improve the breeding and sale of dogs and puppies.”

Blue Cross explains the licensing system would:

Involve more stringent requirements

Be risk-based

Require mandatory inspections

The system would be underpinned by regular training of enforcement officers and would be funded by licence fees,

scaled according to the perceived risk but covering the costs of inspection and enforcement. It would be supported

by a publicly accessible database of licence holders.

QUESTION 2: Why does Blue Cross believe that its licensing proposal would avoid the problems that it suggests

may arise from a ban on third party selling?

Blue Cross states that “The report brings to light serious concerns about the ability of local authorities to enforce

welfare laws with the resources and training available to them.”

QUESTION 3: Why is Blue Cross satisfied that the welfare failings highlighted in its report are primarily caused by

inadequate resources for enforcement and insufficient training?

OBJECTIONS RAISED TO A BAN ON THIRD PARTY SELLING

WELFARE OF BREEDING DOGS

Blue Cross doesn’t believe a ban would improve dog breeding standards. The issue of poor welfare in licensed

breeding establishments was highlighted during its investigation.

In the video 8‘What Lies Ahead’ accompanying the report, an agricultural barn is described as “a perfect example of puppies being bred on a commercial scale” and the Blue Cross inspector states “obviously, we were unable to get in.” Yet in its guidance for buying a puppy, Blue Cross advises prospective owners ‘how to spot a good breeder’ including “Has a clean and safe area in their home for puppies and their mum”.

QUESTION 4: If commercial breeders do not allow potential purchasers access to the breeding establishment (because puppies are sold off site) does Blue Cross feel that licensing inspections alone can provide a sufficient level of scrutiny to protect the welfare of breeding dogs?

7 https://www.bluecross.org.uk/sites/default/files/downloads/Unpicking%20the%20Knots%20report.pdf 8 https://www.bluecross.org.uk/unpicking-knots

This review seeks to examine the recommendations made in the Blue Cross report (and other recently

published statements from the charity) against the concerns it has raised about a ban. It will consider the

concerns that Blue Cross has specifically highlighted about the sale of puppies in pet shops and the puppy

trade in general and ask if the recommendations made by the charity can address these issues.

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QUESTION 5: Does Blue Cross believe that enabling prospective purchasers to ‘meet the puppy’s family members’ affords an additional layer of protection for the welfare of breeding dogs?

QUESTION 6: Does Blue Cross have evidence to reassure people purchasing puppies from third parties that the welfare of breeding dogs is ‘adequately protected’ if the breeder is licensed against ‘additional conditions’ such as the Animal Welfare (Breeding of Dogs) (Wales) Regulations 2014?

The investigation raised concerns that “breeders of pups sold at the premises had not been questioned about their breeding practices by the person selling them.” Blue Cross explains “Without vetting a breeder, a seller of puppies cannot check that the whole canine family is well cared for or healthy enough to breed.” However, right underneath this comment is the statement: “Good breeders will not allow their puppies to be sold in pet shops”.

QUESTION 7: Does Blue Cross believe that breeding dogs will be healthy and well cared for if the breeders allow their puppies to be sold in pet shops?

ENFORCEMENT

Blue Cross believes a ban on third party selling “would be impossible to enforce.” The report emphasises that

“Government is keen to only implement laws that are enforceable”, however its investigation raised “serious

concerns about the ability of local authorities to enforce welfare laws with the resources and training available to

them.” Blue Cross states that model licence conditions “could go further” but despite the recommendation for

Government mentioning “more stringent requirements,” the only suggested update to the Pet Animals Act 1951

(described as ‘outdated’) is the specific inclusion of ‘online sales’. This implies that Blue Cross considers that the

failings which have been identified are primarily due to inadequate enforcement (arising from a lack of resource and

insufficient officer training) rather than any deficit in regulatory requirements.

QUESTION 8: Does Blue Cross feel that the 2013 Model Licence Conditions for Pet Vending if properly enforced, can ensure “high levels of welfare” for puppies with particular regard to meeting the socialisation requirements highlighted in the report?

Blue Cross recommends “As has been done in Wales, we would like to see legislation implemented which requires breeders to put in place enrichment and socialisation plans for pets. However, correct training is essential so that officers make a proper assessment of these plans when submitted by breeders as part of the licensing process.”

QUESTION 9: Does Blue Cross feel that properly assessing breeders’ enrichment and socialisation plans is sufficient to ensure that these plans are put into practice? Blue Cross suggests that a barrier to better enforcement of existing regulation is the lack of resource and funding available, yet has recommended a massive increase in licensing to cover anyone breeding or selling animals.

A total ban on the third party selling of puppies would compel breeders to sell puppies directly to the

public and would therefore significantly increase the level of scrutiny of breeding establishments. The

greater the number of puppies being sold, the greater the level of scrutiny. A level playing field for all

breeders drives competition and breeders that fail to meet public expectation will not be as successful,

providing a significant incentive for improvement. Selling directly also ensures that breeders receive the

entire income from puppy sales rather than just a portion and the additional revenue may encourage

investment into the business.

When looking to improve conditions in breeding establishments, it is absolutely essential to eliminate the

market which demands and sustains the mass production of dogs with little regard for their welfare.

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The report proposes that licence fees should be set to cover the costs of inspection and enforcement, based on a sliding scale of perceived risk.

QUESTION 10: Has Blue Cross calculated the cost of ‘full-scale’ enforcement action against licensed premises and would all licence fees need to be set at a level to cover the entirety of this (should it be necessary)?

QUESTION 11: Has Blue Cross determined a process for risk assessment based on factors other than the nature and scale of the activity? (E.g. history of compliance and numbers of complaints).

The majority of puppies in Britain are bred by unlicensed (exempt) breeders and the report raises “overwhelming concerns about the vast scale of the unlicensed pet trade” and suggests that “The scale of the unlicensed and invisible trade makes this a serious welfare concern.”

QUESTION 12: To ensure that licensing all sellers is a proportionate and effective solution, has Blue Cross conducted any research into the type, prevalence and trends of welfare issues in the unlicensed dog breeding sector?

QUESTION 13: Has Blue Cross considered the potential effectiveness of an educational rather than regulatory approach for breeders/sellers it perceives to be ‘low risk’?

Blue Cross states that licence fees would provide local authorities “with more money to proactively investigate both welfare concerns in current premises and the enormous problem with unlicensed premises operating across the UK.”

QUESTION 14: Has Blue Cross calculated the cost of identifying and taking action against unlicensed sellers?

Under the Pet Animals Act 1951, any person engaged in the activity of selling dogs (which they haven’t bred) as a business must already by law be licensed as a pet shop, so Blue Cross’ recommendations do not alter the existing regulatory requirement for third party sellers. The report states “it’s evident that the successful implementation of the act with regards to online sellers relies on the honesty and integrity of those selling pets to come forward and apply for a licence.”

QUESTION 15: Does Blue Cross feel its recommendations would be successful if the majority of online sellers do not have sufficient honesty and integrity to come forward and apply for a licence?

QUESTION 16: If relatively few of those selling pets come forward and apply for a licence, does Blue Cross suggest it is practical to investigate large numbers of unlicensed sellers - and would sufficient funding be available to take effective enforcement action?

The report mentions that local authorities only have a statutory duty to deal with animal licensing and stray dogs but doesn’t mention that they have no statutory duty to enforce the Animal Welfare Act 2006.

QUESTION 17: Does Blue Cross advocate placing a statutory duty on local authorities to enforce the Animal Welfare Act?

Blue Cross states that where inspecting officers identify “serious welfare concerns” within the parameters of existing model licence conditions, a specified timescale should be set for changes to be made before a licence is issued.

QUESTION 18: If the “serious welfare concerns” are not remedied within the specified timescale, what further action would be taken?

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UNDERGROUND

Blue Cross recommends that “local authorities must be empowered to revoke licences to prevent unnecessary suffering”. Blue Cross cites the importance of making “breeders and sellers more visible and traceable” but revoking the licence effectively bans the seller from operating legally, thus removing the “means of ensuring welfare”.

QUESTION 19: Has Blue Cross considered measures to protect the welfare of animals on premises where licenses are removed or not granted (e.g. young puppies awaiting sale)?

Blue Cross recommends that “those making a profit from selling or breeding pets – regardless of the scale of the income – are brought into the licensing framework” that “mandatory inspections should be conducted on all licensed premises” and that “local authorities should match licence fees to the actual cost of investigation.”

QUESTION 20: How would Blue Cross ensure that this level of financial outlay and intrusion does not act as a deterrent – driving sellers to find more diverse/obscure approaches to rehoming animals to avoid being licensed?

QUESTION 21: Does Blue Cross believe the requirement for licensing itself can be sufficiently well enforced?

The investigation found that very few local authorities “revoked a licence or refused to issue a licence despite welfare concerns.” Apart from identifying unlicensed sellers, the report makes no mention of existing or proposed penalties for non-compliance.

QUESTION 22: Other than withholding or removing a licence, what action does Blue Cross recommend local authorities pursue against sellers found to be operating with a serious breach of the licence conditions?

DEFICIT OF PUPPIES

Blue Cross claims there may not be “enough ‘good’ breeders to meet the very high demand for puppies in the UK”. This directly conflicts with earlier comments from the charity; “There are thousands and thousands being abandoned and a lot of that is about the oversupply and overbreeding.” “The pet market is already saturated. The number of irresponsible breeders is growing and supply is far outweighing demand. In the last five years, Blue Cross has seen a 44 per cent increase in the number of unwanted and abandoned puppies needing our help.” Blue Cross also highlighted some issues with over-supply in its 2015 Annual Report; “Due to irresponsible breeding, illegal imports and impulse purchasing, the number of unwanted pets available far outweighs demand. Illness and disease is increasingly common as a result of these practises. Modern lifestyles mean pets are available to buy online at the click of a button without any research into care and welfare requirements.”

QUESTION 23: Does Blue Cross feel it is necessary or desirable for “the very high demand for puppies” to be met?

Simple legislation is far easier to enforce than complex regulation. Currently there is a situation where it is

almost impossible to “see the wood for the trees” as illegal unlicensed dealers are ‘masked’ by the

presence of licensed third party sellers. Classified website providers and some local authorities have

demonstrated that it is possible to identify high volume sellers and take appropriate action. The evidence

for this has been included in the report (see Kettering p30, Gumtree p31 and Ipswich p34). The police and

the RSPCA already have demonstrable success with recent prosecutions of those engaged in the illegal

trade and this is frequently initiated by purchasers and members of the public reporting suspicious

behaviour or welfare concerns. The simple act of criminalising third party puppy selling and increasing

public awareness will improve prompt identification of illegal sellers. It also provides a mandate for

classified website providers to expel illegal dealers and notify enforcement agencies. The associated

elements of the trade – tax avoidance, public health risks, fraud etc. – are additional incentives for

enforcement action to be taken. Prohibiting third party selling will result in the process becoming too

difficult and therefore unattractive for all but the most determined criminal element – who would probably

also evade any attempt at regulation.

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QUESTION 24: What evidence does Blue Cross have to support the view that “there may not be enough good breeders to meet the very high demand for puppies”?

Blue Cross suggests that if the demand for puppies cannot be met by ‘good’ breeders “there’s a risk that a ban would also cause the illegal puppy trade to flourish”.

QUESTION 25: Is Blue Cross concerned that banning third party selling would result in a deficit of legitimately available puppies?

QUESTION 26: Has Blue Cross conducted any research into purchasing behaviour of puppy buyers to support the inference they might go ‘underground’ to seek ‘illegal traders’ if they were unable to source a puppy legitimately?

QUESTION 27: Does Blue Cross believe that if ‘good’ breeders are unable to meet the very high demand, the shortfall in puppies should be supplied by licensed and regulated third party sellers?

EXEMPTIONS FOR CHARITIES

Blue Cross has suggested there are similarities between the commercial third party sale of puppies and the work of

rehoming organisations, including Blue Cross. “The analogy for that, potentially, could be the welfare sector, where

you have welfare organisations like Blue Cross, the RSPCA, Battersea and the Dogs Trust that are re homing puppies

in a legitimate way based on the processes that sit behind the transference of ownership of those particular

animals.”

QUESTION 28: Why does Blue Cross consider that the commercial third party trade in puppies (i.e. actively purchasing animals with the express purpose of selling them on for a net profit) is comparable with the work of rehoming charities (i.e. obtaining abandoned or relinquished animals passively and rehoming them with no net profit resulting from the process)?

Blue Cross believes that “Possibly, if you were able to demonstrate that there was a robust process that sat behind the licensing and the enforcement piece, it might be a more legitimate outlet.” And “That, significantly, is what is missing from the pet trade at the moment from our perspective.”

Blue Cross (along with other charities) has repeatedly stated there is an oversupply of puppies which far

outweighs demand and this ready availability results in high numbers of unwanted and abandoned pets. It is

therefore highly unlikely that banning third party puppy sales would have anything other than a positive

impact – reducing the number of poorly bred puppies on the market. Genuine responsible breeders will

ensure that they have good homes lined up before breeding a litter and are therefore likely to adjust their

breeding plans accordingly. Arguably, flooding the market with puppies originating from puppy farms in the

UK and Europe will reduce the number of puppies being bred by responsible breeders as there are fewer

good homes available, and the demand for puppies could be inflated due to the ease of making impulse

purchases. Responsibly bred dogs are also likely to live longer and therefore reduce the number and

frequency of ‘replacement’ purchases.

Clearly there is a further case for reducing the oversupply of puppies as a reduction in availability may

encourage more people to consider rehoming a rescue dog. It is extremely unlikely that eliminating sales

through third parties will result in a dog supply crisis and ‘meeting demand’ cannot justify the continuation

of third party selling with all the inherent welfare issues that are associated with it. Puppy buyers do not

want to have a puppy ‘at any cost’ and this must be respected by eliminating the supply carrying the

highest risks.

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QUESTION 29: Does Blue Cross believe that with a ‘robust process’ in place, pet shops and third party sellers could be regarded with the same legitimacy as rehoming charities?

Blue Cross is concerned that a ban allowing “Any exemptions for rehoming charities could open a loophole for

unscrupulous breeders to set themselves up as ‘rescue organisations”.

QUESTION 30: If such a conflict does exist, has Blue Cross investigated the viability of a workable legal exemption before concluding that it could create a ‘loophole’?

Blue Cross recommends that “those making a profit from selling or breeding pets – regardless of the scale of the

income – are brought into the licensing framework” and that “a scheme that requires anyone breeding or selling any

pet to have a licence and meet set standards when it comes to welfare is vital.”

QUESTION 31: Does Blue Cross suggest that its recommendations for licensing should be also applied to rehoming charities, if their activities are insufficiently different from third party traders to enable a workable legal exemption?

OPINION ON PET SHOPS

Blue Cross has repeatedly highlighted concerns about the sale of puppies in licensed pet shops alongside the report

and prior to the investigation; “they can compromise a pet's welfare”.

The following comments have recently been made by Blue Cross specifically in relation to issues associated with the

sale of puppies through pet shops:

IMPULSE PURCHASING

“impulse purchase from a pet shop”

“they can lead to people buying them on impulse.”

QUESTION 32: How does Blue Cross intend to ensure that selling puppies in licensed pet shops will not “lead to people buying them on impulse?”

SOURCED FROM PUPPY FARMS/IRRESPONSIBLY BRED

“irresponsibly bred”

“Good breeders will not allow their puppies to be sold in pet shops”

“Pet shop pups often come from puppy farms”

“‘puppy farms’ where little care is taken over the welfare of the puppies or their mothers and fathers.”

QUESTION 33: What measures does Blue Cross propose to ensure that pet shops are supplied by “good breeders”?

LACK OF SOCIALISATION/BEHAVIOURAL PROBLEMS

“problems later on in its life like separation anxiety and different behavioural traits as well”

“They’ve not had that socialisation in those early weeks which is just crucial for being in a family environment.”

“poorly bred and poorly socialised puppy who will struggle to cope with life.”

“do not allow puppies to develop the life skills they need”

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“ten to 12 weeks inside a shop environment and missing out on a crucial socialisation period that should have prepared him for later life”

“not been exposed to all the things a pet dog should consider normal and safe during a very sensitive period in his

puppyhood.”

“they risk the puppy growing into a dog who struggles to cope with life and is fearful of new things.”

QUESTION 34: Can Blue Cross explain how making “breeders and sellers more visible and traceable” will ensure

that puppies sold through pet shops receive “socialisation in those early weeks which is just crucial for being in a

family environment?”

QUESTION 35: How will the licensing system recommended by Blue Cross ensure that puppies sold by third party sellers are “exposed to all the things a pet dog should consider normal and safe during a very sensitive period in his puppyhood.”

HEALTH PROBLEMS

“often suffer from serious life-threatening problems”

“Scampi became sick”

QUESTION 36: Is Blue Cross confident that “serious life threatening problems “can be prevented by introducing

“standardised ways of working” and “regular and appropriate training for licensing officers”?

INAPPROPRIATE ENVIRONMENT

“A pet shop environment is not a suitable one for pet dogs to spend their early weeks of life.”

“an environment totally unsuitable for puppies.”

“we believe they are wholly inadequate places for puppies to be.”

QUESTION 37: Why does Blue Cross believe that an “effective registration and licensing system” can ensure that a pet shop environment is “suitable for pet dogs to spend their early weeks of life?”

CAN’T SEE MOTHER/PARENTS

“taken away from their mothers too young”

“not shown their parents”

QUESTION 38: Would Blue Cross consider “parents were absent” and “no adult dogs could be seen” sufficient reasons for a “trained workforce to revoke or deny a licence on animal welfare grounds?”

Selling puppies through third parties licensed as pet shops results in circumstances that are inherently

detrimental to the welfare of puppies. Some of these issues have been raised by Blue Cross, and include

impulse purchasing; sourcing puppies from irresponsible breeders/puppy farms; mental trauma and

inadequate socialisation; increased risk of disease and barren pens in non-domestic premises. This is not

an exhaustive list of the irrevocable problems created by the trade, but illustrates the impossibility of

improving it to the point where it will not have a serious negative impact on the welfare of puppies. If

third parties are licensed to sell puppies, these problems will continue to persist.

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ACCOUNTABILITY

Blue Cross states that “Anyone breeding or selling a pet must be held fully accountable for the welfare of pets in their care” and claims that an “effective licensing and registration system” would “make breeders and sellers more visible and traceable, improving animal welfare and offering greater protection for the public when buying a puppy.” Blue Cross believes “This is the only way to ensure that potential pet purchasers have some sort of recourse when they buy a sick animal.”

QUESTION 39: If puppies are sold through a licensed third party seller, does Blue Cross believe that traceability to the breeder through the “effective licensing and registration system” should – or could ensure that all those involved in the chain are “held fully accountable”?

ADVICE TO PURCHASERS

Blue Cross has stated that its “priority is a reform of animal welfare legislation” leading to “an effective and properly

enforced system of licensing for all breeders and sellers of pets” to “ensure the public a safe way of choosing a good

breeder when buying a pet.” The charity has “put together some top advice to help you find a healthy puppy who will

bring you a lifetime of happiness.”

The advice on ‘Buying a Puppy’ provides tips on ‘How to spot a good breeder’ which include:

Has a clean and safe area in their home for puppies and their mum Puppies and mum are obviously happy in the environment they are kept in Encourages you to meet other members of the litter’s family so you can be sure about temperament Can tell you all about the socialisation they’ve been doing, e.g. taking them in the car, meeting lots of people

of all ages, meeting other animals, playing etc.

The charity also provides some ‘warning signs’ and recommends purchasers ‘walk away’ from breeders who:

Won’t let you, or makes excuses about why you can’t, meet the puppy’s family members including mum and littermates

Offers to meet you in a public place such as the street, a service station or railway station to hand over the puppy. Or, offers to drop the puppy off at your home.

Watch mum and puppies interacting together to make sure they are happy. If they don’t appear happy, or if you’re not allowed to see the litter with mum – walk away.

Other advice given on the Blue Cross website suggests that purchasers “don’t forget to meet at least the mum and check that the parents and litter are healthy and that the breeder’s priority is the pet’s happiness.” The underlying message from Blue Cross is that “meeting the mother is vital”.

QUESTION 40: Does Blue Cross suggest that “an effective and properly enforced system of licensing” would ensure that purchasers can safely choose a good breeder, even if it isn’t possible to “see the litter with mum” or reassure themselves that puppies have been raised in a “clean and safe area” in the breeder’s home?

If puppies are sold directly from the breeder to the final purchaser it becomes far easier to locate where

problems have occurred, e.g. the point of origin of disease. Where more than one party is involved in the

supply chain, accountability becomes challenging, as pinpointing where a problem developed in the chain is

far more difficult and may even be impossible if one factor compounds another. Local authorities are

extremely reluctant to divert resources to investigate outbreaks of disease, particularly beyond the area of

their own jurisdiction and therefore sellers are rarely able to be held accountable, far less the original

breeder. The only way to ensure full accountability is to limit the supply chain to breeder and purchaser.

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The Buying Advice incorporates a section on ‘Pet Shop Puppies’ which has also been included in the case study

‘Scampi’s Story.” This concludes with the statement “Please don’t buy puppies from pet shops.” However Blue Cross

suggested that “We would like to see that thorough reform of the regulation and the processes that sit behind it, and

then we would be prepared to consider reviewing our position on the sale of puppies through pet shops.”

QUESTION 41: Under the measures it has recommended, would Blue Cross advise potential owners that pet shops are appropriate sources from which to obtain a responsibly bred puppy?

IMPORTED PUPPIES

Blue Cross states that “increasing numbers of poorly bred puppies” are being imported from Europe “to meet public demand, with many of those sellers also likely to be unlicensed.” It highlights that “Many enter the country crammed into cages in the back of vans without proper access to food or water” and observes that this severely compromises the health and welfare of the puppies and the “conditions create the perfect environment for the spread of disease.” Blue Cross also points out that “being bundled into a van for a long journey across the continent means the welfare of these vulnerable youngsters is neglected at a vitally important stage in their development.”

QUESTION 42: Does Blue Cross believe that there is a need for the “already-flooded market” to be increased by puppies imported from potentially unlicensed breeders in Europe?

QUESTION 43: Is Blue Cross confident that the Welfare of Animals (Transport) Regulations ensure that the health and welfare of puppies sold through licenced third parties is not “severely compromised” during transportation to the point of sale?

Blue Cross suggests that “a robust and efficient enforcement system is essential to stop the flow of illegally imported, sickly puppies” and wants to see “every passported animal properly checked when entering the UK”.

QUESTION 44: Does Blue Cross feel that “checking every passported animal when it enters the UK” would be sufficient to ensure that “the welfare of these vulnerable youngsters” is not “neglected at a vitally important stage in their development”?

QUESTION 45: Does Blue Cross that agree that “With no means of ensuring the welfare of the pets in this invisible trade” until they reach UK borders, “buyers would be even more at risk of ending up with ill pets bred in poor conditions”?

QUESTION 46: Does Blue Cross feel “legislation that makes a real difference” can protect the welfare of pets sold in the UK, but bred in Europe?

It may become difficult for charities or even the Government to advise buyers to see puppies with their

mother in the place where they were born, if revised regulations are intended to ensure that all breeders

and sellers are operating to the same standards of welfare and are therefore equal in terms of merit. In

particular, explicitly warning purchasers away from certain suppliers may be regarded by those businesses

as defamation and could lead to a legal challenge. If revised regulations imply that seeing puppies with their

mother is no longer necessary, this must be supported by research to confirm that puppies’ welfare will not

be adversely affected, to give reassurance to purchasers and the public. However, if it is still considered

appropriate to guide puppy buyers towards/away from licensed sources then it suggests the measures have

been insufficient to protect the welfare of animals sold under these circumstances. The public should not

need to be warned against buying a puppy from a source that is licenced under a properly enforced system,

but it would seem a retrograde step to remove this established advice.

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OTHER ISSUED RAISED IN THE REPORT

Blue Cross states that “Without a visible high street presence, online sellers remain out of sight and out of reach of the authorities”.

QUESTION 47: How does Blue Cross suggest that ‘online sellers’ are identified and tackled, if they do not have a “visible high street presence”?

Blue Cross is concerned that the internet is “enabling unregulated sales to take place online”.

QUESTION 48: What evidence does Blue Cross have to indicate that a significant number of puppies and dogs are being sold online - as opposed to advertised?

QUESTION 49: Has Blue Cross investigated the potential for existing consumer laws and advertising regulations to regulate the advertising/sale of pets online and pets sold by breeders exempt from licensing?

In its report, Blue Cross states that “terms such as ‘hobby breeder’ included within the Pet Animals Act can be interpreted very differently by differing authorities, meaning that across the country some sellers are licensed and others not.”

QUESTION 50: Is Blue Cross able to specify where the term ‘hobby breeder’ appears in either the Pet Animals Act or the Breeding of Dogs Acts?

Blue Cross states “We are concerned by the significant lack of investigation into suspected unlicensed premises by local authorities” and has provided figures in the report to support this problem. No statistics have been included to indicate the response rate that local authorities have to reported instances of unlicensed selling activity.

QUESTION 51: Does Blue Cross have any figures for the number of reports of unlicensed breeding activity to compare against the number of investigations made by local authorities?

Blue Cross recommends “As has been done in Wales, we would like to see legislation implemented which requires breeders to put in place enrichment and socialisation plans for pets. However, correct training is essential so that officers make a proper assessment of these plans when submitted by breeders as part of the licensing process.”

QUESTION 52: Has Blue Cross carried out an evaluation of the success of the Animal Welfare (Breeding of Dogs) (Wales) Regulations 2014?

SUMMARY

The report ‘Unpicking the Knots’ is accompanied by Blue Cross video ‘What Lies Ahead’. Following a visit to a

licensed pet shop offering puppies for sale, the Blue Cross representative states, “We certainly at Blue Cross believe

that puppies should not be sold in pet shops and we would advocate for a ban.”

QUESTION 53: If Blue Cross “would advocate for a ban,” why has this not been included in the recommendations?

If legally imported under the commercial import regulations (the Balai Directive), puppies bred in Europe

could still legitimately be sold through licensed pet shops in the UK under Blue Cross’ recommendations.

Prohibiting the sale of puppies through third party outlets will ensure there is no legal outlet for

commercially imported puppies in the UK. This will mean that illegal consignments of puppies are more

easily identified and will reassure purchasers that puppies sold in the UK have been bred to meet UK

standards of care.

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The representative continues that as “the current legislation allows for this to happen…we’re going to push for as

good standards as possible”

QUESTION 54: If Blue Cross believes that “puppies should not be sold in pet shops”, why is it pushing for “as good standards as possible” rather than pushing for a ban?

QUESTION 55: Does Blue Cross consider that “as good standards as possible” will be more effective at protecting the welfare of puppies sold through licensed pet shops than prohibiting the practice entirely?

Blue Cross asks “If you knew the mother of your puppy had been forced to bear several litters over several years, had likely never seen a vet, and the documents claiming she was healthy were probably falsified, would you put your money into this supply chain?”

QUESTION 56: Does Blue Cross believe the registration and licensing system will effectively prevent the public “putting money into this supply chain”?

Blue Cross claims its recommendations will “ensure pet welfare is prized above profit.”

QUESTION 57: Does Blue Cross feel that commercial third party sellers – who purchase puppies specifically to sell them on as quickly as possible for financial gain – can be compelled to prize welfare above profit?

Blue Cross states that “puppies are suffering in horrible conditions” and that “puppies and their parents right here in the UK, are living victims of a nightmare trade.” The charity describes the undercover footage of BBC Panorama’s ‘Puppy Dealers Exposed’; “battery farmed pets, kept in darkness, protected from the stone-cold floor only by a thin layer of sawdust - if they were lucky” and points out that “for the most part, it’s totally legal.” It claims that banning third party selling would not help “the canine victims of this vicious and inhuman trade” and instead recommends looking “beyond the ideals” to a “more pragmatic” solution which it claims is a “robust and efficient system where all sellers must register on a central database… inspected by a trained workforce which is empowered to revoke or deny a licence on animal welfare grounds.”

QUESTION 58: Does Blue Cross believe that a system of licensing and inspections that allow this “vicious and inhuman trade” to remain “totally legal” is a more pragmatic solution than “a ban on this type of selling”?


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