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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_e nquiry/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_pup py_sales 6http://www.dogworld.co.uk/story.php/173220/34/celebrity_vet_claims_charities_have__vested_interest__in_third_party_pup py_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