Dear Adrian Burder,
When the EFRA Committee recommended banning the third party sale of dogs (legally licensed as pet shops, irrespective of premises) it was a hugely progressive step towards improving the welfare of potentially millions of dogs in the UK. Having considered all the evidence before them, the Committee recognised that the “process of selling through a third party seller has an unavoidable negative impact upon the welfare of puppies” and decided that it is “important that animal welfare standards are ensured across all breeders.”
Interestingly the concept of a ban on the sale of puppies in pet shops is not a new one. And whilst you have referred to it as a ‘knee-jerk’ reaction, it was in fact Dogs Trust that called for a ban in 2009 – highlighting the link between the battery farming of puppies and their sale through retail outlets.
It is therefore not only sad, but deeply confusing as to why you no longer campaign for a ban, but even more concerning is that now you believe preventing the sale of puppies through pet shops is not in the best interests of animal welfare and is a “knee-jerk response to the huge numbers of illegally imported and so-called puppy farmed dogs for sale in the UK”.
Disturbingly it has become apparent that based on this belief, Dogs Trust, the UK’s largest dog welfare charity, has actually advised the Government against banning third party sales. This has come as something of a shock to dog lovers in the UK, many of whom are your loyal supporters.
In a written question, Justin Tomlinson MP asked DEFRA “what the evidential basis was for the conclusion that a ban on third party sales of puppies would lead to the creation of an illegal market.” In response George Eustice, The Minister of State, Department for Environment, Food and Rural Affairs stated that “Evidence was also presented to the recent EFRA Committee inquiry by Blue Cross, and The Dogs Trust on the annual demand for puppies and the risks of applying such a ban.”
In recently issued statements that aim to justify your position, you have used words such as ‘believe‘ and ‘fear’. Dogs Trust’s concerns about a ban appear to be based on assumptions about what ‘may‘ happen or what the consequences ‘could mean‘.
Justin Tomlinson asked “what the evidential basis was” and George Eustice told him “evidence was presented” – but the problem is that belief, fear and assumptions do not constitute evidence.
We have some questions to help us and the British public better understand Dogs Trust’s position on third party sales of dogs and puppies and particularly, what evidence you have to prove it is in the best interests of animal welfare to continue to allow the commercial third-party sale of puppies away from their place of birth.
Does Dogs Trust have evidence that pet shops can be suitable places for the sale of puppies?
Why does Dogs Trust believe it is possible to increase enforcement of a robust regime of licensing and inspection but not a ban on commercial third party puppy sales?
Your aversion to a ban appears to be primarily based on a view that it is necessary to satisfy the demand for puppies. “The simple fact is that there are too few puppies to meet demand in the UK.”
How can Dogs Trust claim there are too few puppies to meet demand when it has revealed that 37,000 dogs remain unclaimed in Council pounds and a “massive 54% increase in dogs handed over” to its rehoming centres over the Christmas period, of which over a third were puppies?
Does Dogs Trust have any suggestions for increasing the number of ‘responsible breeders’ or reducing demand?
Does Dogs Trust believe some purchasers will have no option but to buy a puppy from licensed third party sellers because there are not enough ‘responsible breeders’?
You advocate “a robust regime of licensing and inspection for breeders backed with increased enforcement of the law“.
Does Dogs Trust have evidence to show that the welfare of the dogs involved in the commercial puppy trade can be ensured if sold AWAY from their place of birth?
Can Dogs Trust provide specific examples where inspection and regulation has successfully improved the lives of dogs in commercial dog breeding establishments that supply puppies to third parties such as pet shops?
Does Dogs Trust still consider that seeing a puppy interacting with its mother is critical in having a puppy that is well socialised as it moves through its life and how would Dogs Trust ensure ‘transparency’ in third party sales if purchasers never see the puppy’s mother or assess the condition of the breeding establishment?
In fact, rather than providing answers or assurances that you have reached your conclusions on the basis of solid evidence, your statements aiming to explain your view on banning third party sales merely raise more questions.
Does Dogs Trust believe that continuing to allow puppies to be sold by commercial third party traders will mean that puppies are bought for life, not just for Christmas?
We have put all our questions in these review documents.
Julia Carr BSc (Hons), Founder Canine Action UK