The Kennel Club believes that dog breeding should be regulated and that more breeders should be brought into the licensing scheme to uphold the health and welfare of dams and their puppies. We believe, however, that any measures imposed on breeders must be proportionate, easily and fairly enforced, and based on an element of self-regulation appropriate for breeders who are members of UKAS-accredited breeding schemes.
We have consistently engaged with policymakers to advocate for better enforcement of breeding regulations and for measures which more easily enable puppy buyers to identify responsible breeders.
It is our belief that collaboration is the key to improving enforcement and maintaining high standards of breeding. See our Collaboration is Key breeding reports below to find out more about breeding regulations in England, Scotland, and Wales:
The Kennel Club's Collaboration is Key report
In October 2018, the Government introduced new regulations for dog breeding, the most drastic of which was a reduction in the litter threshold for which a dog breeding licence is required. Anyone breeding three or more litters and selling at least one puppy in a 12-month period must obtain a licence from their local authority, rather than the previous five litters or more per year. A key element of the new regulations is the business test, which stipulates that those breeding one or two litters in a 12-month period will be required to obtain a licence if they are deemed to be ‘breeding dogs and advertising a business of selling dogs’.
Other measures included within the regulation have been designed to further assist puppy buyers in identifying good breeders and to ensure breeders are operating in a responsible manner. These include a star rating system, designed to reward high-performing breeding establishments, risking rating to determine whether the breeder is a low-risk or high-risk operator, and guidance on the minimum welfare standard that all licensed breeders will be required to meet.
Read our detailed explanation of the English regulations.
Impact on supply
Following the introduction of the regulations in England in 2018, the number of licences issued increased by 76%. Low-volume breeders have been disproportionately targeted by the licensing requirements however, with 40% of the licences issued to one to two litter breeders between April 2019 and April 2020. Given that the intention behind the new regulations was to ensure that high-volume breeders are operating responsibly and safely, it is disappointing to see low-volume breeders – who often do not have the resources or finances to meet the extensive requirements – overrepresented in the figures.
Each year, The Kennel Club registers approximately one third of puppies bred in the UK – around 250,000 puppies per year. Following the introduction of the licensing regulations in England, 18,000 fewer puppies were registered with The Kennel Club, meaning that the domestic dog market saw a total shortfall of approximately 75,000 puppies. We have heard from many low-volume breeders who plan to either reduce the number of litters they breed per year or stop breeding altogether as a direct result of the burdensome licensing requirements they must now meet.
Given that 87% of breeders registered with The Kennel Club breed one to two litters per year, a significant reduction in their breeding activity prompts a number of concerns regarding the dog breeding sector and the market supply. Prospective puppy buyers will now have fewer opportunities to buy from reputable, responsible breeders who have raised their puppies in a loving home environment, as the gap in the market is filled by unethical, low-welfare puppy importers and puppy farmers.
Determining whether a breeder who breeds fewer than three litters per year meets the criteria set out in a business test is a complex process which can be interpreted in a different way depending on the local authority. Whether low-volume breeders will require a licence is a postcode lottery, with some local authorities telling breeders that they will require a licence if they advertise even one puppy for sale. The reliability of this enforcement method is questionable, given that 65% of breeders do not rely on advertising pups for sale due to having waiting lists and over 80% of those advertising use non-commercial websites.
For those breeding three or four litters in a 12-month period, the licensing system is too complex, bureaucratic, and expensive. It places the same burden on those who breed three litters within a year as high-volume breeders.
The Kennel Club's proposals
We have consistently called upon policymakers to remove the business test element of the regulations. Not only would this remove the ambiguity as to whether a one or two litter breeder is a ‘business’, it will also mean that local authorities are better able to focus their limited resources to ensure that high-volume breeders – many of whom are still operating under the radar – are breeding responsibly and are fully licensed.
We also encourage breeders to join The Kennel Club’s Assured Breeders scheme, which gained independent accreditation from UKAS over a decade ago and effectively self-regulates around 4,000 breeders. The scheme requires breeders to make use of breed-specific health tests and preventative health measures, whilst also ensuring puppies are checked by a veterinarian prior to sale. The Government recognised our Assured Breeders scheme within the 2018 regulations, stipulating that membership of the scheme can count towards compliance history – which feeds into the star rating and risk rating element – in the absence of a licence. With local authorities desperately under-resourced and unable to license three times the number of breeders that they had to previously, we believe the regulations should be amended so that scheme members are regulated under the Assured Breeders scheme rather than by local authorities. Given the high standards set by the scheme, this will ensure that the health and welfare of the bitch and her puppies is maintained, and that the breeders operate in a responsible way.
What is The Kennel Club calling for?
- Government must simplify the dog breeding regulations by removing the business test in order to encourage low-volume, high-welfare breeders to breed litters and to increase domestic supply
- Government should fully embed the Assured Breeders scheme into the 2018 regulations, allowing the scheme to self-regulate its members
The Scottish Government is currently reviewing existing breeding regulations and drafting new requirements for breeders. Currently, there are only 101 licensed dog breeders in Scotland – less than 65% of the number which should be registered with their local authority based on our own registration data.
We believe that a more practical and better resourced licensing system in Scotland would improve animal welfare and health. As such, we believe that the Scottish Government should include the following requirements in its new regulations:
Reduction of the litter threshold
We believe, in the interest of animal welfare, it is essential for new regulations to include a reduction in the litter threshold for which a dog breeding licence is required. Reducing the licensing requirements to three or more litters a year will subject more breeders to welfare inspections, thus promoting responsible breeding and improving animal welfare standards.
Simplification of the licensing system
We would like to see the licensing system simplified, following the reduction of the litter threshold to three litters in a year. We believe this should be the sole criteria for licensing. Following the implementation of the business test alongside the lowering of the litter threshold to three or more litters in England, we have seen a significant reduction in the number of puppies bred. One to two litter breeders feel unable to meet the demands of the regulations and, due to the over-complicated nature of the business test, are understandably confused as to whether they required a licence. Subsequently, large numbers have been discouraged from breeding. With different local authorities interpreting the business test in various ways, a postcode lottery licensing system has developed. Given the high demand for puppies, it is likely that any domestic decrease in supply will instead be met by puppy importers and puppy farmers, which raises grave concerns for animal welfare.
According to The Kennel Club’s Puppy Awareness Week survey data (2018), 20% of people who buy a puppy do not see the puppy with its mother and 31% do not see its breeding environment. This suggests there is a strong possibility that such puppies would have been bred by puppy farmers. It is vital that puppies are not separated from their mothers before the age of 8 weeks, which we believe should be a legal requirement.
We also believe that early socialisation should be a regulatory requirement due to its importance. Poor socialisation can impact puppies’ overall health and development, potentially causing anxiety, stress and aggressive behaviour which new owners may struggle to deal with.
The updated breeding regulations introduced in Wales in 2015 set a clear licensing threshold and sought to raise animal welfare standards to a realistic level. We welcomed this legislation as it was straightforward for both breeders and local authorities to understand; however, we remain concerned about how these rules are being enforced.
When the regulations were passed, we estimated that there would be a threefold increase in the number of licensed breeders in Wales; however, only 219 dog breeders are licensed annually by local authorities, according to Welsh Government data. This is less than a quarter of the number that they should be licensing based on our own registration data, which shows 282 Welsh breeders requiring a licence. We are also concerned that 50% of local authorities carried out five or fewer inspections on dog breeding premises in 2016-17. As such, we believe it is important for The Kennel Club’s Assured Breeders scheme to be incorporated into the licensing framework: the scheme currently has the capacity to carry out 5,000 inspections per annum which would improve animal welfare in conjunction with the continuous monitoring and checks the scheme carries out.
To find out more about how the Assured Breeders scheme could work in practice in Wales, please read our updated breeding report for Wales. It is essential that the Welsh Government tightens its regulations and focuses on improving enforcement in order to promote responsible breeding and curb high levels of puppy farming in the nation.