Understanding CDC’s New Rule for Bringing Dogs into the United States

Earlier this week, the United States Centers for Disease Control and Prevention (CDC) published a new rule for the importation of dogs into the United States. The rule, which becomes effective on August 1, 2024, will require all dogs to be at minimum six months of age prior to import into the U.S.

The American Kennel Club (AKC) supports the aims of import regulations that seek to protect pet and public health, including those that seek to protect the United States from reintroduction of DMRVV (canine rabies). However, AKC is disappointed that the new rule is overly broad and disparately impacts purebred dog enthusiasts who import a personal animal or collaborate internationally, or dog event competitors that travel internationally. AKC will continue to share our concerns with CDC, and encourages those who believe they will be impacted negatively by the rule to share concerns with CDC at cdcanimalimports@cdc.gov.

Why is CDC doing this?  

Through its new rule, CDC is seeking to prevent and deter the importation of dogs carrying DMRVV (canine rabies) and other diseases or pathogens that threaten public health. Recent cases of such imports have been associated with falsified or fraudulent rabies vaccinations and/or other required health and import documentation. In 2020, CDC observed a 52% increase in the number of dogs that were ineligible for admission into the U.S. due to falsified or fraudulent documentation. The CDC’s new rule cited several cases of rabies-positive dogs being imported into the U.S. by, or on behalf of, animal rescue groups that presented with documentation for those dogs that had been falsified.

Unfortunately, many of the dogs with falsified paperwork were claimed as personal pets (not for transfer/resale), to fraudulently exploit a U.S. Department of Agriculture (USDA) exemption that allows personal pets with demonstrated immunity to canine rabies to enter the U.S. before six months of age. Except for this exemption and several others, current law requires all dogs entering the U.S. for transfer (sale, adoption, etc.) to be at least six months of age.

In the final rule, CDC estimates that, in addition to the human toll, the importation of one rabies-infected dog costs federal, state, and local governments $270,000 for conducting public health investigations and administering rabies medications to exposed persons. That number jumps to $11.6 million if an exposure results in one human death.

Understanding the New Requirements 

The new requirements are not legislation. Legislation requires passage in Congress and being signed into law by the President. Instead, the requirements are part of a final administrative rule promulgated under the CDC’s existing legal authority to take administrative action to protect public health. There are numerous examples of this type of action in recent years, including the establishment of bans on imports from certain countries during the COVID-19 crisis. Here is a one-pager explaining the key differences between the legislative and regulatory processes.

The CDC considered two factors to be of utmost importance for protecting public health as related to importing dogs into the U.S.: The dog’s vaccination status and its country of origin.

Effective August 1, 2024, all dogs imported into the U.S. are required to:

(1) Appear healthy upon arrival,

(2) Be at least six months of age,

(3) Have an ISO-compatible microchip implanted for identification purposes, and

(4) Be accompanied by a CDC Dog Import Form online submission receipt (no cost).

There are additional requirements for the following:

• A dog entering the US from a rabies-free or low-risk countrymay enter the U.S. at any U.S. port. It also must be accompanied by written documentation that the dog has resided or otherwise been only in rabies-free or low-risk countries for the six months before attempted entry into the U.S.
• A U.S.-vaccinated dog entering the US from countries considered high-risk for rabies must be accompanied by a Certification of U.S.-issued Rabies Vaccination form, and may enter the U.S. at any U.S. port.
• A foreign-vaccinated dog from a high-risk country must have a reservation with a CDC-registered Animal Care Facility, be accompanied by a Certification of Foreign Rabies Vaccination and Microchip form and a CDC Dog Import Form online submission receipt, and titer results from a CDC-approved laboratory. Dogs without titer results will be required to quarantine. These dogs may only enter the U.S. at airports with a CDC quarantine station and a CDC-registered Animal Care Facility.
• A U.S.- or foreign-vaccinated dog from a rabies-restricted country must be accompanied by a completed Certification of Foreign Rabies Vaccination and Microchip form and a CDC Dog Import Permit, and enter the U.S. only at airports with a CDC quarantine station and a CDC-registered Animal Care Facility. This is a limited exception for service and government-owned animals; otherwise dogs from a rabies-restricted country are not permitted to enter the U.S.

AKC Concerns: Disparately Impacting Purebred Dog Breeders and Competitors

Rabies is a devastating virus that is nearly 100% fatal once clinical symptoms appear. AKC recognizes and supports the vital importance of protecting U.S. public and animal health, including our status as a DMRVV-free country. AKC also recognizes CDC’s goal of reducing opportunities for fraud that threaten this status, and the need to improve efficiency for the importation of dogs. AKC appreciates that the rule does improve and streamline some import documentation.

Unfortunately, CDC’s approach does not recognize that law-abiding importers importing only a personal-owned dog represents a different risk profile than those importing dogs intended for transfer. The cases of rabies-positive dogs that have been imported into the US (as cited by CDC and noted above) were all related to fraud associated with the importation of dogs for resale. In developing its new rule, CDC did not differentiate between the public health risks represented by a law-abiding dog owner importing a personally owned animal that will reside with and be cared for by a documented individual, versus entities importing large quantities of dogs for unknown final consumers and that are already violating certain import requirements.

CDC’s new rule also neglects to recognize the value of international collaboration among sportsmen and breeders of purebred dogs, particularly in preserving breeds at risk of extinction. For example, under the rule in effect through July, puppies that have reached four months of age and were vaccinated at three months of age, therefore considered fully vaccinated against rabies, may be imported by U.S. dog enthusiasts to begin training and assess future breeding quality. It also fails to recognize that some event competitors may temporarily travel between the U.S. and Canada, both of which are canine rabies-free countries, to compete with their dogs at events sanctioned by AKC or the Canadian Kennel Club.

Problematic international animal rescue importations that were based on falsified or fraudulent documents resulted in the importation and distribution of rabies-positive dogs among the general population of the U.S. Conversely, purebred dog enthusiasts who import a personal animal or collaborate internationally, or dog event competitors that travel internationally, were not responsible for those importations and are not proven to create similar threats to the health of either the American public or our animals. CDC’s new rule nevertheless imposes new requirements and restrictions on these breeders and competitors, which AKC views as disparately impacting them.

Resources

• Understanding CDC’s New Rule for Bringing Dogs into the United States (AKC) (downloadable PDF of this document) – https://s3.amazonaws.com/cdn-origin-etr.akc.org/wp-content/uploads/2024/05/17151420/Understanding-CDCs-New-Rule-For-Bringing-Dogs-into-the-United-States.pdf
• Key Differences Between the Legislative & Regulatory Processes - https://s3.amazonaws.com/cdn-origin-etr.akc.org/wp-content/uploads/2024/05/17174031/The-Difference-Between-the-Legislative-Regulatory-Process.pdf
• AKC’s Regulatory Resources page - https://www.akcgr.org/regresources/.
• New CDC Rule - https://www.govinfo.gov/content/pkg/FR-2024-05-13/pdf/2024-09676.pdf.
• Bringing a Dog into the United States (CDC) - https://www.cdc.gov/importation/bringing-an-animal-into-the-united-states/dogs.html.
• From August 1, 2024, Onward: What Your Dog Needs to Enter the United States (CDC) - https://www.cdc.gov/importation/bringing-an-animal-into-the-united-states/dogs-entering-us-after-august-1.html.
• From August 1 Onward: Required Documents for Bringing a Dog into the United States (CDC) - https://www.cdc.gov/importation/bringing-an-animal-into-the-united-states/required-forms-for-importing-dog-united-states.html.
• List of High-Risk Countries for Dog Rabies (CDC) - https://www.cdc.gov/importation/bringing-an-animal-into-the-united-states/high-risk.html.
• FAQs on CDC Dog Importations (CDC) - https://www.cdc.gov/importation/bringing-an-animal-into-the-united-states/faqs-about-high-risk-dog-ban.html.

Next Steps

AKC will continue to share our concerns with CDC about the disparate impact that will be experienced by purebred dog enthusiasts who import a personal animal and by owners who travel internationally or regularly transit land borders with their dogs, and continues to encourage those who believe they will be impacted negatively by the new CDC dog import rules to express their concerns directly to CDC at cdcanimalimports@cdc.gov.

AKC will also continue to provide updates on federal regulatory actions as developments warrant.  For more information, contact AKC Government Relations at doglaw@akc.org.

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Posted by Liz on May 17 2024. Filed under Breaking News, Current Articles, Featured. You can follow any responses to this entry through the RSS 2.0. Both comments and pings are currently closed.