To – Center for Disease Control

It has come to our attention that CDC has implemented a change to the entry requirements for young dogs entering the US. Included in this change is the requirement that all dogs, including puppies, be vaccinated for rabies a minimum of one month before entry to the US.

We understand that the CDC is working to ensure that Rabies is not brought across US borders. It is however, unclear how this new protocol will improve the existing regulation when dealing with Canadian dog importation. The current system requires up to date rabies vaccinations for all dogs over the age allowable for rabies vaccination. That would include all dog over the age of five months. This system has worked well between our two countries and there has never been a case of rabies transmitted by a companion animal crossing the border. By reducing the age to four months for Canadian puppies, there will be unintended consequences with no advantage in the protection of public health. Canada is unique in the world in its relationship with the United States. Our common border is long, largely unattended and allows the free movement of wild animals. The two countries partner in almost all industries, including pet travel, and our publics benefit from that trade.

The Canadian puppies bred by responsible small scale breeders are well socialized, individually identified by tattoo or microchip and carefully raised. The purebred dog industry is highly regulated in Canada and falls under the governance of the federal government’s Animal Pedigree Act. This Act requires careful management of the purebred dog population, including animal husbandry. The genetic diversity of our dog population in Canada and the US is based on the free movement of purebred dogs between the two countries. Breeders partner to improve dog health, to maintain diversity and to improve breeding stock. Limiting access of puppies will detrimentally impact this activity to the level that many breeders will no longer be able to continue. There will be impacts on pet families since people do not want to begin their puppy socialization at five months so will look to alternatives available, including commercially bred (puppy mill) young puppies. There will be negative impacts on breeders since puppies raised for breeding, show or field must be in their ultimate home as early as is possible to begin the process of training and socialization so will be unable to take older puppies, thus reducing genetic diversity within the US as well as in Canada. Purebred dog breeders will be negatively impacted since few are able to house and properly care for puppies beyond the age of eight to nine weeks. North American puppy mills will be much less impacted, as they do not expend the same level of care. Poorly socialized dogs are more likely to bite, and are more often surrendered to shelters for behavioural problems.

As an alternative to the rabies vaccination protocol now espoused by CDC, the following requirement could be effected - In the case of Canadian puppies, the Canadian international health certificate, completed by a Veterinarian, be required for each pup under the age of five months, ensuring that the pup is healthy. In addition, it would be possible to stipulate that only one or perhaps two pups could be imported at a time. Persons wishing to import larger numbers of pups would need to follow the Rabies vaccination requirement, and not import pups younger than four months.

It is requested that the CDC waive the rabies restriction for Canadian puppies under the age of five months being exported to the US. There has never been a case of rabies reported in the US emanating from a Canadian puppy. There is no increase in rabies in Canada. There is no increase in rabies in the US that has been attributable to Canadian dogs or Canadian wildlife. A valid veterinary health certificate would better protect the American public than the new protocol effected by CDC.