“This isn’t just about finance and consumer detriment. This goes deeper,” says CTSI Lead Officer for Animal Health & Agriculture Stephanie Young when I ask her why the illicit puppy trade is such a serious problem. “It’s about compromised animal welfare and the emotional aspect that people get tied into when they buy a puppy.”
Among the many unexpected consequences of the COVID-19 pandemic has been the surge in sales of puppies, predominantly via social media and online marketplaces. While many of these dogs are supplied by responsible, licensed breeders who prioritise the health and wellbeing of the animals in their care, there has also been an uptick in the activities of a more cynical type of trader.
“Over the past year, we have received over 300 reports about this across our intelligence database,” says Diane Bryson, Strategic Intelligence Analyst at Trading Standards Scotland (TSS). “The illicit puppy trade and animal welfare are the most documented complaint, with the majority referring to puppies which have been purchased by consumers and have subsequently fallen ill, or they relate to suspicions that the pup has been bred on a puppy farm.
“The current demand for dogs is outstripping the legitimate supply. This has been exacerbated even more by COVID-19. The marketplace has become infiltrated with intensive breeding establishments, illegal importation and unlicensed and undisclosed businesses.”
The problem is by no means restricted to Scotland. According to Young, “I’d go as far to say it’s a problem across Europe. People who are not licensed breeders are selling dogs, and a lot of imports are coming in from Europe and being placed on the market for sale here.”
Last year the Government introduced ‘Lucy’s Law’ in England. Named after a Cavalier King Charles Spaniel who was rescued from a puppy farm where she was subjected to appalling conditions, the legislation requires anyone purchasing a puppy to buy from a registered breeder or adopt from a rescue centre. If a trader sells puppies or kittens without a licence, they could receive an unlimited fine or be sent to prison for up to six months. The law will also come into effect in Scotland and Wales in September, and is ‘on track’ to be introduced in Northern Ireland.
The tighter rules and increased sentencing are a step in the right direction but, true to form, criminals have paid little heed.
“With puppy breeding and pet shop sales, the mum has to be with the pups when they are being sold.” Young says. “But one of the things that we’re seeing now is dummy bitches being put with these puppies, when actually that bitch isn’t the mum to those pups.
“This also gives cause for concern with regards to the rise thefts of puppies or dogs that we’ve seen across the UK in recent months. What are these dogs being used for? Are some of these bitches being bred from, or are they being used to make it look like they’re the mums to some of these pups which are coming in from puppy farms abroad?”
Career criminals
In many cases, the trade is part of wider criminal activity of the most serious kind. “As with other types of illegal trading, there is a link between the illicit trade in puppies and serious organised crime, which includes things like illegal drugs, money laundering and tax avoidance,” says Bryson.
“This is international organised crime, and the penalties are not the highest for the crimes that are being committed,” says Young. “It’s a high-value product that’s being brought in and placed on the market with a very low-value penalty. The only way you can really stop some of this is either to look at the way the offences are drafted, or to place more responsibility on the individuals who are fuelling this demand – to say stop and think. There’s got to be responsibility put on them in relation to where they’re obtaining these dogs from.”
Mike Flynn, Chief Superintendent at the Scottish SPCA, agrees that despite Lucy’s Law, many of the sentences handed out are not tough enough. “If you’re caught coming into the UK with £20,000 worth of drugs, you are going to go to jail. If you come in with £20,000 worth of pups, which is the exact same profit, you might get a £500 fine because you’ve ‘saved them from some horrible place in Ireland’.”
Flynn also agrees that consumers themselves have a responsibility to prevent the illicit puppy trade. “People really have to be aware and just stop the impulse buying. A little bit of homework could have helped some people avoid being caught out.
“It’s all down to the public’s lack of willingness to spend time finding a reputable breeder and being stupid enough to hand over £2,000 to somebody in a car park when all they’ve got is a mobile number. A lot of the people we’re dealing with are using burner phones, and maybe sell three or four litters through numbers that you’ll never trace.
“In March we seized about 20 pups from five different premises in Glasgow, where certain people from Ireland were renting properties and inviting people to come and buy pups. You go three days later, and they’re gone.”
Putting a price on suffering
Many of the puppies which are either bred in the UK or brought in from overseas by criminals suffer from health problems which severely affect their quality of life and lead to financial and emotional detriment for their owners.
“In one incident, there was a Cocker Spaniel that had been advertised online for £450,” says Bryson. “The pup was purchased by the consumer but became unwell shortly after. It was confirmed by the vet that the pup was suffering from canine parvovirus and it died shortly afterwards. The consumer ended up with bills of over £1,800.
“Further intelligence showed that several other pups that had been sold on social media by the same dealer became ill with parvovirus, and on one other occasion the pup had died. This is a pattern we are seeing at the moment.”
“One of the worst cases I’ve seen personally was a woman who paid £2,500 for an English Bulldog,” says Flynn. “Within five weeks she’d spent £4,500 in vet’s fees, and the last payment was to have the dog put to sleep because it just couldn’t be helped. When she contacted us, she said her son will never want another dog – he had fallen in love with this one and just watched her die.
“The last figures I got showed a 157% increase in people complaining to us about welfare issues,” he adds. “[The puppies have] all got welfare problems and those can be physical, and immediately apparent, or they can be psychologically damaged. That’s when you get a lot of problems after three to six months.”
Puppy farms present an animal welfare threat that reaches far beyond the dogs they produce, says Young. “In relation to animals coming in from abroad, there’s also a rabies risk; those animals are not being correctly vaccinated and haven’t had the anti-rabies vaccination. That exposes the country to a disease risk. You cannot put a price on the country coming down with rabies, you can’t put a price on animal welfare, and you can’t put a price on the emotional impact on individuals. Anybody who’s had a dog or pet knows that it becomes a member of the family.
“People will pay a couple of thousand pounds for a puppy potentially and on top of that, they might have to pay thousands more in veterinary fees, because that animal suddenly becomes sick. And that animal may never actually be right. Its health has been compromised because of the way that it’s been either transported into the UK, or the way that it’s been bred.”
Joined-up enforcement
The scale of the problem requires a multi-faceted approach, with different organisations – including trading standards – joining forces.
“The SSPCA has been working heavily to combat the illegal puppy trade through Operation Delphin for the past five years,” says Flynn. “This involves ourselves, HMRC, Police Scotland, TSS and the Irish SPCA. Traditionally, our biggest problem was pups coming in from Ireland and Northern Ireland. That did drop at the beginning of COVID, but it’s started to come back again. There’s also been an increase in the amount of pups and adult dogs coming in from Spain and Cyprus, and particularly recently from Romania.”
“Being able to approach this problem from a different angle provides an opportunity for TSS to work alongside key partners like the SSPCA, local authorities and Police Scotland to tackle the perpetrators,” says Bryson. “We can do that through consumer education as well as enforcement action, and also through a coalition of intelligence.”
David MacKenzie, CTSI Lead Officer for E-Commerce, sees the illicit puppy trade as part of a wider problem facing trading standards in the digital age. “Platforms which introduce the buyer and seller to each other but don’t actually enable the purchase to be made, present the opportunity to further this particular trade,” he says.
“A key thing right across e-commerce is that we absolutely do need cooperation from the platforms. We’re talking about mega firms based in California, but we’re also talking about businesses based in the UK, where there are web operations that can enable legitimate sales of puppies to happen. But they’ve got to be making the right checks on the sellers. We would certainly urge them to make those checks and prohibit anybody who’s dodgy in any way.
“For some of the smaller-scale cases, it may be appropriate to simply disrupt. All of these platforms have forms where you can report illegal activity. I don’t see any problem with trading standards using them in the same way that a member of public could use them. I think we need to be versatile and we need to be creative in the way we deal with this.”
Public support
Part of the reason the illicit puppy trade is so difficult to stamp out is that the animals being sold aren’t mere commodities. When a potential buyer sees a helpless puppy being held in the most dire conditions, they may well feel a responsibility to take it out of that situation in the misguided belief that they are ‘rescuing’ it – and most likely handing over a significant amount of money in the process.
That only exacerbates the problem though, as Flynn observes. “It’s a story we’ve heard many times,” he says. “One guy told me that the place the dog was being kept was absolutely stinking and he couldn’t leave it there, so he handed over the money. Obviously the pup became sick. But surprisingly, he couldn’t even give us the registration of the seller’s vehicle. It just beggars belief.
“People aren’t helping the situation by buying these pups; what they should be doing is reporting their concerns so we can try and do something about it.”
While puppies themselves may not be standard commodities, when it comes to taking the criminals to task, the tools available to trading standards are essentially the same as for any other form of illicit trading.
“There are many aspects of this that are covered by the Consumer Protection Regulations in the same way any other goods and services are,” says Bryson. “Misrepresentation is a key area; we have seen pups being advertised for sale online as home-bred, only for the customers to later determine that the pup may have a foreign microchip or develop diseases synonymous with puppy farms, like parvovirus.
“There are also puppies which have been advertised for sale online by breeders who falsely claimed to be Kennel Club registered, or sellers failing to inform consumers that they are actually traders rather than a private seller.
“The TSS team has worked on a case in which the individuals involved were bringing large numbers of dogs from Ireland and selling them within Scotland. The subjects made misleading statements, claiming the dogs were bred by them personally within Scotland. There has also been misrepresentation by the sellers about the breed of the dog – consumers were being misled into thinking they were buying one breed and ending up with another breed completely.”
“The offences that we have across the UK are exactly the same with regards to misleading the consumer,” says Young. “We’ve got fraudulent activity in the way that some of these animals have been sold; quite often there’s fraudulent documentation with regards to the certificates or pedigree certificates.
“There’s a whole host of activity that sits behind this but the key thing is that it’s driven by supply and demand.”
