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CDC Extends its Suspension of Dog Imports from 110 Countries and Issues Proposed Rule to Amend Quarantine Regulation

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By: Administrator  Date: 07/10/2023 Category: |

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Summary Rule and Alert

On July 10th, the U.S. Centers for Disease Control and Prevention (CDC) published a notice of proposed rulemaking to address the public health risk of dog-maintained rabies virus variant (DMRVV) associated with the importation of dogs into the country. In parallel, CDC also extended the temporary suspension of dog imports from DMRVV high-risk countries through July 31, 2024.

Comments must be submitted by September 8, 2023. You may submit electronic comments, identified by Docket No. CDC–2023–0051 at: https://www.regulations.gov/document/CDC-2023-0051-0001.

Summary of Proposed Requirements

HHS/CDC proposes the following requirements for all imported dogs arriving by air, land, or sea:

• A microchip;
• Six-month minimum age requirement for admission;
  • Exception included for an owner to import a maximum of three personal pet dogs under six months of age in the same calendar year (Jan-Dec) if arriving via a land port through Canada or Mexico if the dog has not been in a DMRVV high-risk or restricted country.
• Importer submission of a CDC import form (online form that includes the importers’ contact information and information related to each dog being imported) via a CDC-approved system prior to travel to the US; and
  • Importer must present receipt of completed form upon arrival at U.S. port; importers arriving by air must present receipt to airline prior to boarding.
• Airlines to confirm all required import documentation, provide safe housing, and assist public health officials in determining animal cause of death.

HHS/CDC proposes varying vaccination and port of entry requirements for imported dogs based on the rabies status of their country of export and location of rabies vaccination. See summary charts below:

 

 

HHS-CDC proposes new requirements for U.S. airlines, including:

• Prior to boarding, must confirm importers have receipt confirming submission of a completed CDC Import Submission Form.
• Must confirm that the dog posses all required import documentation based on the country of origin prior to accepting the dog for transport.
• Ensure dogs from DMRVV high-risk countries will be arriving to a designated U.S. airport with a CDC quarantine station (if U.S. vaccinated) or a U.S. airport with a quarantine station and CDC-registered Animal Care Facility (if foreign vaccinated) and that the importer posses a reservation with the Animal Care Facility.

Key Highlights From CDC

“…Internationally, there has been significant growth within the companion animal breeding industry with increasing international trade. Multiple international and U.S. investigations have identified importations of puppies that were too young to meet rabies vaccination requirements. In addition, there is growing evidence that criminal networks are becoming involved in the lucrative dog trade, and the illegal puppy trade was reported to have increased during the pandemic. Because imported dogs will typically encounter multiple people, pets, and other animals throughout their journey—beginning at the airport in the country of departure and continuing with the airline, through the U.S. port, and pet adoption and pet socialization process—an increase in inadequately vaccinated dogs likewise increases the risk of human and animal exposure…”

“…The significant increase in the number of dogs from DMRVV high-risk countries arriving with incomplete, inadequate, or fraudulent rabies vaccination documentation observed in 2020 and 2021 coincided with increased interest in purchasing dogs from the international rescues and breeders during the COVID-19 pandemic…Since 2021, the demand for puppies and rescue dogs has remained high. The trend in purchasing and rescuing dogs from abroad has been noted in many countries, including the United States…”

“…Historically, approximately 60 to 70 percent of CDC’s dog entry denials (or about 200 cases annually) have been based on fraudulent, incomplete, or inaccurate paperwork. However, between January 2020 and July 2021 (i.e., during the COVID-19 pandemic, prior to the temporary suspension), CDC documented more than 1000 instances of incomplete, inadequate, or fraudulent rabies vaccination certificates for dogs arriving from DMRVV high-risk countries. These cases resulted in dogs being denied entry into the United States and ultimately returned to their country of origin…”

“…HHS/CDC also proposes to require that all dogs arriving from any country, including dogs returning to the United States after traveling abroad, be properly microchipped with an International Standards Organization (ISO)-compatible microchip prior to travel into the United States. The microchip information would be included on importation documents to help ensure that dogs presented for admission are the same dogs as those listed on the rabies vaccination records…”

“…Microchips are already used globally and required for importation in many DMRVV-free countries. Microchips are recommended by the international veterinary community and animal rescue and welfare organizations to reunite lost animals with their owners and ensure the veterinary records for an animal can be linked to the animal. The microchip requirement will also promote greater confidence in the information recorded on the rabies vaccination records. CDC has documented several instances of importers attempting to present records of vaccinated dogs that became ill or died before travel as the vaccination records for dogs that lacked appropriate veterinary paperwork, presenting the original dogs’ vaccination records for the replacement dogs and attempting to import the unvaccinated dogs into the United States without detection…”

“…Because microchips are not currently required for entry into the United States and the dogs in question were not microchipped, the public health investigation to confirm the identity of these dogs was both resource intensive and challenging. Further, during CDC’s temporary suspension of dogs entering the United States from DMRVV high-risk countries, CDC documented that 99 percent (>20,000) of permit applications received were for dogs that had microchips implanted prior to the announcement of the suspension. Microchips are frequently used by pet owners and required for international transit by many foreign countries. Therefore, CDC’s proposed requirement would have minimal impact on dog importations, although costs to some importers would still be incurred..”

“…CDC and U.S. Customs and Border Protection (CBP) have documented importations every year in which flight parents transport dogs for the purpose of resale, adoption, or transfer of ownership that do not meet CDC’s entry requirements. These flight parents often claim the dogs are their personal pets to avoid U.S. Department of Agriculture (USDA) Animal Care entry requirements and potential tariffs or fees under CBP regulations. Even when well-meaning, these importers jeopardize public health, as many of them do not know the history of the animals they are transporting. Deterring individuals who serve as flight parents from supporting fraudulent dog importations has proven difficult despite the existence of CBP penalties relating to aiding unlawful importations and fraudulent conduct. See 19 U.S.C. 1592 and 19 U.S.C. 1595a…”

“…In 2020, CDC observed a 52 percent increase in the number of dogs that were ineligible for admission due to falsified or fraudulent documentation, as compared to 2018 and 2019 (450 dogs compared to the previous baseline of 300 dogs per year). This troubling trend continued in 2021, with an additional 24 percent increase of dogs ineligible for admission in just the first half of the year, compared to the full 2020 calendar year (January-December) (approximately 560 dogs with falsified or fraudulent documentation)…”

“…In parallel with the publication of this NPRM, CDC has published an extension of the temporary suspension through July 31, 2024. A suspension remains necessary to protect the public’s health against the reintroduction of DMRVV into the United States because there is a continued threat posed by dogs from DMRVV high-risk countries that are unvaccinated or inadequately vaccinated against rabies. This continued threat is due to various factors, including: a high volume of dogs being imported into the United States contemporaneous with insufficient veterinary controls in DMRVV high-risk countries to prevent the export of inadequately vaccinated dogs, inadequate veterinary supply chains for vaccines and related materials, and persistent workforce capacity shortages, particularly in DMRVV high-risk countries that export dogs to the United States. This NPRM proposes to incorporate practices used during the temporary suspension period that CDC found effective to better protect the public’s health from introductions of DMRVV from high-risk countries and reduce potential instances of fraudulent documentation. The NPRM outlines a framework and set of operations that CDC believes would mitigate the need for suspending dog imports from high-risk countries should these procedures be adopted…”

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