First, we provide an overview of the scale and value of the puppy trade in the UK, highlighting the structure and actors along the supply chain and the impact of the trade.
Scale and value
As mentioned, the scale of the puppy trade is difficult to estimate. And the illegal trade is particularly difficult to address due to its hidden nature, the inconsistent data collection and sharing, the multiple regulatory frameworks and agencies, and limited law enforcement capacity, very little of which is specialised. The two—legal and illegal—are also intertwined and difficult to untangle. Thus, when speaking of scale and value it is hard to distinguish between legal and illegal. For example, one interviewee indicated that when the Irish government trade database recorded approximately 3,000 puppies as being transported commercially to the UK, he was able to “directly follow over 52,000 pups to the UK every year and that was the ones we knew about” (Wyatt et al. 2017b). As stated, it is not clear which of these are legal and which are not. Another example comes from the Dogs Trust (2018). A Hungarian puppy dealer detailed the weekly exportation of approximately 400 puppies from just his hometown, suggesting a trade of 20,000 puppies a year from one village. With an average price of £1400 per puppy, the annual turnover is £28 million. In this case, the trade was considered illegal because of the lack of registration and welfare. RSPCA inspector Briggs, from the special operations unit, has argued that criminals are driven by immense profits, with in-demand ‘handbag’ dogs “bought in Eastern Europe for as little as £20 ($29) and sold for as much as £1200 ($1700) in the UK, allowing even small-scale operators to make thousands of pounds every week” (Parkinson 2016: no page). Even though the exact amount of illegal trade is unknown, the Biocrime project which documents the trade of animals across the Austrian-Italian border found 53% of pets traded across the border had no documentation (Eurogroup for Animals 2020). Thus, there is the possibility that the illegal portion of the puppy trade is as, if not more substantial, than the legal trade.
Structure and actors
The puppy trade has numerous stages and within these stages there are a variety of activities undertaken by a diverse group of actors (see Table 1). Portions of the trade may be all, or a mixture of:
legal regulated trade (in compliance with the complex interplay of local level governance and international regulations on breeding, rearing, movement, trade, selling and the welfare of the dogs)
legal unregulated trade (below the threshold requiring domestic regulation)
illegal trade (non-compliant with international and national regulations).
The legal (both regulated and unregulated) and illegal trade of puppies are multi-stage processes. According to the data, those profiting from the puppy trade are a mixture of individuals selling occasional litters, hobby breeders, and small and large commercial enterprises. Across these groups, there are examples of good practice (such as complying with online advertising minimum standards, and vetting perspective buyers), evidence of unscrupulous breeders and traders (e.g. irresponsible breeding, rearing, and sales practices) and illegal activities (such as importing commercial dogs as pets, evading taxes, or using fraudulent pet passports). Experts described illegal actors as non-compliant individuals, organised crime groups and ancillaries (e.g. for transport). While it is not currently possible to identify the extent or specific roles occupied by OCGs in the trade, experts indicated actors in the illegal trade are becoming increasingly organised and sophisticated in their operation and existing crime groups are moving into the puppy trade. The diversity of actors adds to the difficulty in identifying the nature (and prevalence) of the legal and illegal trades. Those who are legitimate can easily become non-compliant, while those who purposefully smuggle and organise the illegal trade can use the legitimate trade to do so (e.g. laundering dogs).
To breed and sell puppies, actors must plan which dogs to buy and where to house them. Although regulations differ across the EU, if breeding enough dogs and acting legally, most likely the breeder must obtain a license or permit. Inspections by local authorities and veterinariansFootnote 5 would also likely be involved at this stage (2 and 3 in Table 1). To commercially sell these puppies across the EU the regulationsFootnote 6 require the premises of origin to be a registered business. In the UK, licensed breeders are required to breed within the determined limitations of their establishment and welfare of individual mother dogs and provide a set standard of care and welfare. Non-compliance is evident in the illegal domestic trade, however, similar abuses among international breeding establishments is not necessarily illegal as there is no UK control over the breeding rates and conditions of puppies arriving from these establishments. The aforementioned IBF (2015) study found significant inconsistencies in licensing requirements and levels of compliance across EU member states. The possession of a licence or a registered business is no guarantee of legality or appropriate animal welfare standards. Our study respondents (i.e. experts, stakeholders and consumers) indicated limited enforcement resources resulted in poor licensing compliance and provided substantial opportunities for illegal trade. Further, in the UK, where it is possible to breed puppies unregulated (e.g. under the legal threshold of three litters a year) it is possible to trade illegally under the guise of unregulated legal trade.
To transport puppies internationally (Stage 4), either commercially or as companion animals, veterinarians must complete a health certificate (ITAHC) or a pet passport [PETS].Footnote 7 Covert investigations by NGOs repeatedly identified many veterinarians in Eastern European countries who were paid to forge paperwork to facilitate the movement of puppies too young to legally travel. This research revealed inadequate and few checks at the borders, infamously evidenced by the ability to repeatedly import a stuffed, rather than a live, puppy into the UK (Dogs Trust 2014, 2018). During this stage of the (il)legal trade, transportation companies and their workers should encounter the puppies, dealers and persons transporting them. This may be airlines, but more commonly involves ferry companies or agencies operating tunnels and other border crossings (i.e. Eurotunnel between France and England). To avoid commercial checks, widespread abuse of PETS, implemented in 2012 to facilitate companion animals travelling with their owners across EU borders, was consistently identified by experts. As each person in a vehicle can travel with up to five companion animals, it has become a viable mechanism for illegal commercial sales. Furthermore, the movement of companion animals under PETS is not recorded, permitting offenders to make repeated journeys with different dogs without being identified. The increase in commercial imports to the UK, during COVID-19 restrictions on non-commercial movement across borders, supports this premise. While the movement of dogs to England and Wales under PETS declined by 88% in May (compared to previous years), the movement of commercial dogs, measured by Intra Trade Animal Health Certificates (ITAHC) (issued between March and October 2020) rose by 87% (on numbers for May to September 2019)—the highest number of ITAHCs issued monthly since records began (RSPCA 2020). Whereas 5 years ago most puppies were being transported in vans, it is now thought that cars, being less conspicuous, are increasingly being used to transport puppies internationally throughout Europe (Eurogroup for Animals 2020). Experts in our research identified a fluid network of offenders, who were swift to respond to enforcement changes.
Stage 5—advertising—may overlap with previous stages as puppies are advertised before being born, early in their lives, or when they are ready to be transported—creating an on-demand process. Advertisements may be placed from outside of the destination country of the puppies. For instance, we found that advertisements even with local addresses in Scotland could be for puppies bred out of the country, but being sold by local third-party people, who had not bred the puppies (Wyatt et al. 2017a, b). In response to UK awareness campaigns, local sellers used fake houses and female dogs to allow consumers to view puppies in their ‘home’ with their ‘mother’. That way during Stage 6—selling—consumers visiting perspective puppies do not suspect the puppy has come from out of the country and/or a puppy farm. Furthermore, the seller is not re-traceable due to their frequent movements from rented accommodation. While UK legislation has recently become more robust (e.g., Lucy’s Law), requiring all online advertisements from businesses to provide crucial information for traceability and prohibiting third-party sales, this is not adequately enforced, and the latter does not currently apply to international trade. Although the income from all regulated legal puppy sales should be reported to the relevant tax authority, the recent HMRC figures detailed above indicate considerable tax evasion.
Impact and implications
The puppy trade requires the systematic exploitation of dogs. Within the UK regulated trade minimum standards of welfare and treatment can reduce some of these harms, while the harms experienced by dogs in the illegal and irresponsible trade are pervasive, diverse, and serious (Dogs Trust 2018; Eurogroup for Animals 2020). The impact begins at the point of origin and is evident at every stage in the trade, including post-purchase. Harms to the non-human animals include, but are not restricted to, inappropriate breeding (with exaggerated features or with inherited disorders that compromise welfare), health (no or inappropriate veterinary care, removal from mother too early, exposure to diseases, premature death), living (unsanitary, cramped and noisy housing, poor care, undernourishment, inability to express natural behaviours, no socialisation with other dogs or people) and transportation conditions (inappropriate housing, long journeys without access to food, water or breaks, without appropriate vaccinations to avoid disease transmission), and abandonment and euthanasia (due to poor compatibility with owners, long term health problems and/or behavioural problems).Footnote 8 The (il)legal commercial exploitation of millions of non-human animals causes extensive and persistent suffering, with little recognition of animal sentience. This is despite extensive scientific basis evidencing they are sentient and can and do experience pain and pleasure. Within the illegal trade, animal welfare is frequently sacrificed as profits are likely, even when a large percentage of animals die pre- or post-sale, because of these conditions:
if you’ve got 40 … and three happen to die they’re just getting kicked out at a lay-by… if I pick up 100 and I only end up with 50 I’m still going to make a good profit out of it” [EI4].
the cost of production is so low they’re willing to take a chance and bring a hundred pups over and maybe getting ten of them alive... and they’ll still make it worth their while [EI5].
Arguably, as puppies are traded as commodities, the legal trade does not need to provide for the sentience of their ‘products’, ensuring it is easy for the legal and illegal trades to blur. As Lynch et al. (2013) argue, the harms implicit in the puppy trade can be explained by the political economic context of consumer culture.
Negative impact extends well beyond the puppies (and their mothers) in the trade; experts argued it has an effect on the state of the nation’s dogs’ health with: known diseases outbreaks, the potential introduction of new diseases, and long term behavioural and health issues resulting from inappropriate breeding, rearing, transportation and socialisation of puppies. These issues in turn impact the financial stability of the legitimate puppy market, consumers, government agencies, NGOs, and the UK public, which have to contend with the health (zoonotic diseases—see also Zucca et al 2020) and social consequences of the illegal trade, as well as try to respond to it. The involvement of OCGs in the trade presents increased and new serious consequences, including illicit gains financing other serious criminality. This is exacerbated by the increased distance between consumer and breeder. The rural isolated location of puppy farms and their flow to urban centres, often in other countries, ensures that welfare and public health issues are largely invisible to consumers (Maher and Wyatt 2019). The growth in third-party and online sales establishes further distance between consumers and the lived experiences of puppies in the trade.
Criminal actors exploit legislative loopholes, enforcement capabilities and consumer detachment to manipulate and hide behind the legal trade. As indicated above, each stage of the legal regulated trade requires paperwork, documentation and/or regulation of some sort—a license, a veterinarian check, a paperwork/microchip check at the border and more recently online in the UK. Evidence suggests paperwork can be easily forged, or fraudulent versions used to make the trade appear legal and that the puppy has the proper documentation, treatments and age to be sold. Consequently, since 2015 (UK) Border Force have recognised the possible involvement of OCGs in puppy trade networks. This has been echoed by key NGOs and transport carriers, who have reported the “sheer number of illegal puppies—one in every tenth car” and “widespread and organised criminal network and activity” (APHA 2017: no page). Nonetheless, due to the diverse nature of the illegal trade, especially embedded within the legal trade, meeting records from a 2016 RSPCA and DEFRA organised workshop identified “there are still huge unknowns in how the criminal networks operate” (APHA 2017: no page). The puppy trade, in both its legal and illegal forms, is organised, but this does not necessarily mean OCGs are involved. The next section unpacks these connections drawing on the conceptualisation of OCGs by EUROPOL.