Dear Sir or Madam,
I write to you in response to the consultation on the proposal to ban the third-party sales of pets in England. I am a small-scale breeder of Poodle (standard) producing about one litter per year for the purposes of breed conservation and for canine sports such as agility and working trials. I have been breeding since 2013 and I have never broken even in this 'business'.
I am supportive of a ban on the third party sale of puppies, but have some concerns I would like to draw your attention to about potential consequences were this to be implemented.
As a breeder who provides lifetime support to my puppies' owners, I feel the relationship between the breeder of the dog and the owner is vital. It is very important that the breeder be informed of any health conditions that develop in dogs they have bred, so that they can warn other owners and are aware of what issues might be present in their bloodline and can make careful breeding decisions to reduce the risk going forward. It is also important that if the owner's circumstances change and they can no longer keep the dog, that it is returned to the breeder so a suitable new home can be found. The owner also benefits from the support given by the breeder if there is ever a problem with the dog, since the breeder is experienced and knowledgeable about their bloodline and what problems might occur. If puppies are sold by third parties, buyers acquire dogs in the absence of this supportive relationship, and owners are deprived of specialised support and breeders are deprived of necessary information about the health of their bloodlines.
My biggest concerns about the implementation of the ban would be the effect on the breeding and importation of dogs for what is termed 'retail rescue' and the potential impact on persons who for whatever reason need to rehome an older dog and lack the support of a breeder. Traditional 'rescues' that take in dogs whose owners can no longer care for them are in decline. Often rescue organisations will only accept abandoned dogs or dogs who have been confiscated as part of a welfare prosecution. Many organisations such as the RSPCA have become politicised and are becoming more like animal rights lobbyists than animal welfare organisations. I am concerned that if the sale of any pet animal by a person other than the breeder were to be banned, some people who could no longer care for their pets would have nowhere to turn, and this would result in an increase in abandonment and euthanasia of otherwise healthy animals. One way to mitigate this would be to use the microchip legislation to force breeders to accept back animals they have bred. But in the case of irresponsible breeders who have no intention of offering lifetime support, this could also result in returned animals being euthanised or dumped.
In addition to this, as a conservation breeder, I will sometimes rehome my own adult dogs to carefully selected people if it should turn out dogs I have are not suitable for breeding, or if when they have finished breeding I feel they would benefit from a quieter home with fewer dogs. Sometimes these might be dogs I have acquired from other people, and in the search for unrelated dogs I sometimes import dogs from abroad. It would be impractical for me to have to return these dogs rather than matching them with suitable families. I would suggest that third party sales only be banned for dogs under a year of age.
In the past few years there has been a huge increase of 'rescues' importing dogs and selling them. A lot of these ventures appear to be profitable businesses. The dogs themselves are often sourced from puppy farms, foreign meat markets, or even found on the streets in foreign countries, with the marketing angle being that people buy these dogs because they feel sorry for them and their horrible origins. Such dogs can have serious issues resulting from their poor start in life and often do not make good pets. The welfare implications of owning such dogs are probably worse than buying dogs from domestic puppy farms, and there is a serious risk of diseases being imported. If there is a problem with stray dogs in other countries, trap, neuter, release programmes and finding homes for dogs in their own country should be pursued. I feel that because of this, there needs to be a serious examination of the law on imports of dogs and its enforcement. As a breed conservationist I also feel that this must be done in a way so it does not adversely impact breeders carefully importing dogs from high-welfare breeders abroad to use in their own breeding programmes, as having access to this source of new genetics is vital to the gene pools of many breeds.
Additionally, the government has recently been focusing on promoting the licensing system. I would like to stress that, in my opinion, the best breeders produce only one or two litters a year and invest a great deal of work into raising their dogs and offer the best post-sales support, and are unlikely to be licensed. I would like to see more recognition of the importance of small hobby breeders in breed conservation, and the quality of dogs they produce being the highest available to puppy buyers.
In summary, I request that included in this legislation should be measures to address:
1. Making it possible for persons with a genuine reason to privately rehome an older animal to do so.
2. Preventing the importation of dogs to sell, including under the guise of rescuing. People should only be allowed to import dogs to own for themselves, and all imported dogs should be able to be traced to a breeder in their country of origin as necessary biosecurity.
3. Acknowledging the quality and importance of small hobbyist breeders dedicated to conserving historic breeds and producing fewer than three litters a year, as opposed to commercial breeders producing large numbers of litters every year for profit.
Thank you for taking the time to read my concerns.