Breeding regulations

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 licencing 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 less opportunity 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 using 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.

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 Breeder, 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 the Assured Breeders 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 licence 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 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.

• 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

Email your local MP - find yours over on the UK parliament website.

If emailing in please include your name and postal address at the end of your email.

Here is a template letter you can use:

Dear [local MP]

I wanted to write to you in my capacity as a dog lover and occasional breeder / home breeder who breeds with health and welfare at the forefront, due to my love of dogs and passion for my breed. Puppies I breed are reared in a loving family home environment and selected for their new homes with the utmost care.

I have serious concerns surrounding some of the recommendations on dog breeding contained within the recently published report by the Environment, Food and Rural Affairs Select Committee on pet welfare and abuse, in particular recommendation 29: The litter licensing threshold for dog breeding should be reduced from three to two per 12-month period.

Reducing the litter licensing threshold is of huge concern to home breeders such as me who breed in low volumes but to a high standard of welfare. When the Licensing of Activities Involving Animals Act 2018 Regulations were introduced and reduced the litter licensing threshold from 5 litters to 3 litters, many lower volume breeders reduced further the number of litters they bred because they were unable to deal with the volume of paperwork and cost associated with licensing.

Reducing the licensing threshold to two litters would, in my view, have a detrimental impact on the supply of responsibly bred puppies. Whilst illegal breeders will continue their operations under the radar, those who may have bred an additional litter within a year – including me – will choose not to, which in turn will fuel the trade of low welfare breeders since we know the demand for puppies will not decline. Breeding is a unique sector; with most breeders registering puppies with The Kennel Club breeding just one or two litters per year.

I share concerns regarding unscrupulous breeders who produce large volumes of puppies with no concern for welfare, and believe that urgent action needs to be taken, but a belief that bringing even lower volume breeders into the licensing regime completely fails to adequately address the problem of high volume, low welfare breeders, and demonises and disincentives' responsible breeders.  The highlighted recommendation to reduce the litter licensing threshold, if taken forward, would likely reduce domestic, low volume, high welfare puppy breeding, while simultaneously enforcing stricter measures around puppy imports, potentially leading to a dangerous bottleneck, where demand is filled en masse by irresponsible and profit-driven breeders operating under the radar.

I would urge you to write to the responsible Minister at Defra to ensure that they do not take on board this poorly thought-out recommendation of the Environment, Food and Rural Affairs Select Committee.

Yours sincerely,

[NAME]