CDC’s New Dog-Importation Rules Rightly Prohibit Imports from Foreign Puppy Mills, but are Broadly Overreaching, Impairing Animal Welfare and Human-Animal Bond

Washington, D.C. — Animal Wellness Action and international dog rescue groups panned new dog importation regulations announced this week by U.S. Centers for Disease Control, calling updates to import rules excessive and costly, especially for pet owners and animal welfare charities in countries without CDC-approved laboratories.  Animal Wellness does, however, support a provision in the new rules to restrict imports of dogs 6 months or younger as a practical barrier to imports of dogs from foreign-based puppy mills.

 The final rulemaking action comes nearly three years after the CDC abruptly shuttered U.S. borders to dogs traveling from 113 countries, widely described as an unwarranted and excessive reaction to the very remote risk of dog rabies. The final rule is set to be published today and become effective Aug. 1.

“The agency’s protocols are too difficult and costly to achieve for Americans who want to travel back to the United States with their animals,”said Jennifer Skiff, director of international for Animal Wellness Action. “The result will be — as it was when the CDC created these rules as “temporary” — the forced abandonment of family pets overseas.”

In a news release sent to media outlets, the CDC summarized the new policy by stating that “all dogs entering the United States must: Appear healthy upon arrival; Be at least six months of age; Be microchipped; and Be accompanied by a CDC Dog Import Form online submission receipt.” 

But the final rule, which is over 300 pages long in the unpublished PDF the CDC made available on May 8, is more complicated and burdensome than the CDC portrays.

While the CDC has made some changes from their proposed rule, such as making it easier for owners of U.S.-vaccinated dogs to re-enter the country after having been to countries with high rabies risk, the rules maintain a regime under which importers — most notably dog-rescue organizations and American owners of foreign-rescued dogs — face substantially greater financial cost and roadblocks to bring dogs to the United States.

On July 14, 2021, during the COVID-19 pandemic, the CDC, citing a zoonotic threat to Americans due to rabies, shut borders to dog imports from more than 100 countries. The decision was apparently driven by just four cases of rabid dogs presented for import to the United States over six years (i.e., less than one dog per year from 2015 through 2021). During that same period, there were 7 million dogs imported without issue. The sudden and poorly justified shutdown of imports caused widespread chaos and confusion for foreign service members, military personnel, and rescue organizations doing life-saving work across the globe.

Over more than two years, the CDC frequently changed its procedures and protocol for dog owners; that ever-shifting regulatory framework made it difficult and costly for importers to bring dogs reliably, safely, and efficiently into the United States. This hardship adversely affected deployed servicemembers and their families, foreign service officers, rescues, and commercial importers. Finally, the CDC proposed a formal rule in July 2023.

Animal Wellness Action and the Center for a Humane Economy have always maintained that the premise for the CDC’s argument is fundamentally flawed.

“While the United States may be free from canine rabies, it has never been — nor likely will ever be — rabies-free. The distinction the CDC makes between canine rabies and other rabies strains, such as the bat variant, is clinically and epidemiologically irrelevant,” said Dr. Thomas Pool, DVM, MPH, senior veterinarian for Animal Wellness Action.

“Thus, the CDC’s emphasis on the eradication of canine variant rabies is a distinction without a difference. It’s misleading to imply that this proposed rule is going to make the people of America substantially safer from rabies,” Pool added.  “Over 99.9 percent of the risk of rabies lies in places other than imported dogs. There is higher risk in livestock, yet clearly our disease prevention protocols in farmed animals are severely lacking, given the rise of avian flu in cattle.”

The rules place an extraordinary financial, administrative, and emotional burden on U.S. citizens and charities working in the more than 100 countries the CDC deems high risk of rabies. Dogs originating from these countries are now required to have a serology titer test from a CDC-approved laboratory that confirms validity of their rabies vaccination.

“The problem is that the CDC doesn’t have approved laboratories in all countries, making it extremely difficult for people to meet requirements with shipping blood samples to other countries with one-to-three monthlong waits reported to get the results,” added Skiff, director of international for Animal Wellness Action. “The alternative is quarantine upon entry into the United States, repeat vaccinations, serology, and kenneling with quoted costs over $5,000, not including airfare.”

The hardest hit by the rules are U.S. animal welfare charities that rescue dogs overseas and import them into the country. Since the CDC implemented the temporary rules in July 2021, organizations have seen import costs to comply with rules rise from $500-to-$5,000 per dog.

Anna Umansky, founder of Sochi Dogs, a charity that imports homeless dogs into the United States for adoption, said the cost burden placed on charities is insurmountable, especially when forced to bring dogs into the country through independently owned quarantine facilities that have no price caps, cost parity or competition.

“It’s not realistic and the costs of these independently owned and run facilities is astronomical,” Umansky said. “We are rescuing dogs from war-torn countries like Ukraine. We’ve brought in 1,000 dogs with a 100 percent clean import record with USDA, CDC, and Border Patrol. The CDC is penalizing the charities who are doing it right. With these rules, we’re not going to be able to continue our adoption program from Ukraine.”

The groups pointed out, however, that one positive impact of the final rule: curbing imports of dogs from non-U.S. breeders, including foreign-based puppy mills from Mexico to Bulgaria. Not only do the mills subject the animals to overcrowded, often filthy conditions, they engage in inbreeding that often result in chronic and hereditary health and wellness issues. These stressed animals are then subject to the rigors of long-distance air travel and an uncertain fate once they arrive in the U.S.

“Puppy mills are a scourge whether in the United States or abroad,” said Wayne Pacelle, president of Animal Wellness Action and the Center for a Humane Economy. “The United States long ago should have banned imports of dogs from foreign puppy mills, so this one provision from the CDC’s rulemaking is a welcome one.”