As noted in a July alert, the U.S. Centers for Disease Control and Prevention (CDC) has proposed new rules to address the public health risks of dog-maintained rabies virus variant (DMRVV) associated with the importation of dogs from overseas. The CDC’s public comment period closes Friday, September 8, 2023. The American Kennel Club (AKC) supports efforts to address the serious public health issues related to the proposal, and is offering additional recommendations, including support for Option 2-less restrictive” in Table 4 Summary Table of Important Changes to Regulatory Requirements.
AKC encourages concerned purebred dog breeders, fanciers, and enthusiasts and dog owners to provide thoughtful comment to CDC here, in support of a rule that includes Option 2 on Table 4 (summary of Important Changes to Regulatory Requirements).
The following sections below provide more in-depth information.
BACKGROUND: AKC supports efforts to ensure that all dogs imported into the United States are fully immunized against rabies; free of infection, parasites, and contagious diseases; and are individually certified as such by a qualified veterinarian. In recent years, however, increasing demand for pets has led to estimated imports of approximately one million dogs annually, many of which have entered the U.S. with falsified, fraudulent or incomplete paperwork.
In 2021, in response to this threat and to documented importations of rabies-positive dogs by rescues into the U.S., CDC temporarily suspended dog imports from countries classified as DMRVV high-risk, began using standardized forms, required titer results that demonstrate the presence of rabies antibodies in dogs, and developed a reservation system for the quick quarantining of dogs coming from high-risk countries that arrived without an adequate proof of titers. In its proposal, CDC notes that these temporary steps proved successful in reducing the numbers of imported dogs being denied entry into the U.S., instances of fraud, the number of sick or diseased dogs entering the U.S., and the number of intergovernmental resources needed to address inadequately-vaccinated dogs.
The CDC’s proposed rule would incorporate the practices used during the temporary suspension period it found effective to better proposed the public’s health from introductions of DMRVV from high-risk countries and reduce potential instances of fraudulent documentation.
WHAT’S PROPOSED: The rule would require all dog importers to submit a CDC Import Submission Form, and require airlines to confirm documentation, provide safe housing, and assist public health officials in determining an animal’s cause of death while in transit. It would also require every dog for import into the U.S. to be microchipped and, with some exceptions for personally-owned pets, require all dogs to be at least six-months of age to be admitted into the U.S.*
CDC also proposes additional requirements for dogs that have been in a high-risk country within six months of importation into the U.S.
- Importers must submit a standardized vaccination form verifying each dog’s vaccination status.
- Dogs that have been in a high-risk country within six months and have a valid U.S.-issued rabies certificate would be required to arrive at a U.S. airport with a CDC quarantine station
- Dogs that have been in a high-risk country within six months and were vaccinated in a foreign country would be required to arrive at a U.S. airport with both a CDC quarantine station and a CDC-registered Animal Care Facility.
Other proposed requirements may be reviewed in the proposed rule.
AKC’S POSITION AND CONCERN: AKC supports the proposal generally, but is also concerned by a proposed change above and beyond existing temporary requirements that would restrict the number of healthy, properly vaccinated personally-owned dogs under six months of age that may be imported. AKC appreciates proposed exceptions to the six-month rule, but is concerned that the means by which such dogs could be imported will disparately impact responsible purebred dog breeders, fanciers, and enthusiasts.
Current CDC rules permit dogs to enter the United States at any port of entry, including at airports, if they are healthy in appearance, have not been in a high-risk country in the past six months, and their importers provide a six-month travel history statement, which covers the entire lifetime of an imported puppy under six months of age. CDC seeks to significantly change this by requiring all dogs to be six months of age before being imported, and justifies the idea because it would align its rules with current USDA importation requirements for commercial dog imports (i.e., those intended for resale) under the Animal Welfare Act. CDC also proposes a limited exception for an owner to import a maximum of three individual personally-owned dogs under six months of age in the same calendar year if arriving in the United States via a land port through Canada or Mexico provided the dogs have not been in a high-risk country since birth.
AKC respectfully disagrees that CDC limits should apply to personally-owned dogs arriving in the U.S. by air. Not only would it take away a means of travel currently available to an importer of a personally-owned dog under six months of age, but it would also reflect a failure to consider the difference in risk profiles between non-commercial importers of personally-owned dogs and commercial importers/distributors who import dogs for further distribution in rescues or retail outlets. AKC believes this section of the proposal does not provide sufficient justification for this rule change beyond what CDC states has already been achieved through the implementation of the temporary suspension.
As CDC notes in the proposed rule, puppies may be effectively vaccinated for rabies by as early as four months of age. While we appreciate CDC’s consideration of the interests of importers of personally-owned dogs with the inclusion of the limited exception, we believe the exception would actually create an otherwise unnecessary financial and logistical burden for importers of personally-owned dogs, shift enforcement burdens onto Canada and Mexico, and require increased CDC and U.S. Customs and Border Protection (CBP) enforcement at border land crossings.
AKC’S RECOMMENDATION/TALKING POINT FOR CONCERNED COMMENTERS: We generally support the proposed rule, with the exception of a one-size-fits-all ban on the import of dogs under the age of six months. A fairer, more efficient system that would go far to effectively protect the public and animal health from exposure or reintroduction of DMRVV would allow for the importation of personally-owned dogs if a dog is four months of age and is fully vaccinated, and the dog has not been in any DMRVV high-risk country during its lifetime/prior to importation. CDC presents this alternative, which AKC supports, as “Option 2-less restrictive” in Table 4 Summary Table of Important Changes to Regulatory Requirements Based on the Provisions of This NPRM and Alternatives Considered of the proposed rule (page 43999). Other requirements proposed that impact the importation of dogs from DMRVV low-risk or -free countries, including microchipping, importer submission of the CDC Import Submission Form, and airline requirements, should still be required and satisfied.
SUBMIT COMMENTS TO CDC: Concerned responsible purebred dog breeders, fanciers, and enthusiasts are strongly encouraged to provide a personalized comment to CDC that highlights the proposed solution including Option 2 -less restrictive above. Commenters may submit comments by going to https://www.regulations.gov/document/CDC-2023-0051-0001 and clicking the blue “Comment” icon near the top left of the page. Comments will be accepted through this Friday, September 8, 2023.
FOR MORE INFORMATION, CONTACT:
Ashley C. Altenburger, J.D. and/or Dr. Emily Pieracci, D.V.M. – CDC’s Division of Global Migration and Quarantine, 1-800-232-4636
AKC Government Relations – 919-816-3720, Doglaw@akc.org