Dear Pet Industry Federation,
In your recent article 'Politics and Puppies' on the Pet Industry Federation (PIF) website, your chief executive Nigel Baker has finally provided the official industry response to last September's backbench debate on the sale of puppies in pet shops.
He generously recognises the achievement of myself and supporters of PupAid's campaign in significantly surpassing the 100,000 signatures needed to trigger the debate.
Possibly Mr Baker and Pet Industry Federation had not anticipated such a tremendous groundswell of public opinion on this issue but the impending event forced Pet Industry Federation into action and a week before the debate, Pet Industry Federation circulated an email to MPs urging them not to support a ban on puppies sold in pet shops.
It was this astonishing move that prompted supporters of the PupAid campaign to give the Pet Industry Federation "quite a bashing", because buyers have long been advised (by every UK animal welfare organisation) to see puppies interacting with their mothers, and this is probably one of the few requirements for prospective dog owners that stakeholders (with the sole exception of Pet Industry Federation) always agree on.
Pet Industry Federation's stubborn insistence that "the sale of puppies in pet shops is acceptable when it is done well" isolates the organisation as a lone voice sticking to its outdated notions and seems incompatible with the ideals set out in its own Charter, in particular article 7: "Promote best practice in animal welfare by observing the Five Welfare Needs'.
There are an infinite number of reasons why selling puppies in pet shops falls well short of meeting the 'Five Freedoms,' enshrined in the Animal Welfare Act 2006. They have been more than sufficiently highlighted over the years to leave no doubt that the practice has no place in the UK today; and the focus on the issue brought about by the PupAid campaign forced even Pet Industry Federation to finally "take a careful look internally".
The result is not, disappointingly an acknowledgement of the problems and a change of heart to bring the Pet Industry Federation in line with all other respected bodies, even a golden opportunity taken to remove the most impulsive way of buying a pup thus reducing abandonment and numbers of rescue dogs; but instead an attempt to confer a seal of approval on pet shops who ignore public opinion and scientifically based welfare principals - by selling puppies.
Mr Baker states that the "PupAid campaign had failed to take the whole context into account, or provide an adequate solution to the issues" but this accusation is far more applicable to the Pet Industry Federation, as clearly banning the sale of puppies without their mums would solve many of these issues, especially making it almost impossible for pet shops to sell puppies.
It's unlikely Pet Industry Federation's Quality Audit will mean that puppies are "sold well" through Pet Industry Federation Member pet shops for the simple reason that this is most likely an impossible aspiration.
The whole context of the issue is that factory farmed puppies are removed at an early age from their mothers and sold hundreds of miles away through a third party whose motivation is not "concern for their puppies' wellbeing" but making a profit.
Producing mentally and physically well-balanced, healthy puppies that are going to be fit for purpose as family pets is usually a low priority on the agenda of those involved in the trade and the Audit does not and indeed could not alter this fact.
Responsible breeders, for example Kennel Club Assured Breeders, who proudly ensure that they do everything in their power to rear vigorous, happy puppies are equally determined to see those puppies placed in suitable homes, and by definition find the concept of delegating that duty to a third party completely abhorrent.
Mr Baker commends the PupAid campaign for highlighting the abuse of breeding dogs at some establishments but he makes no correlation between this problem and the sale of puppies in pet shops.
The Audit does not seem to provide any means of ensuring that pet shops are not perpetuating the abuse by selling the offspring of these miserable animals. Simply insisting that puppies are only sourced from licensed breeders in the UK is far from sufficient, as we know only too well how some licensed breeders have standards that barely meet the licensing criteria and could never meet the provisions of the Animal Welfare Act 2006.
The Pet Industry Federation's logic for trying to improve the way puppies are sold through pet shops rather than conceding to accept a ban, seems to be based on the belief that being 'licensed, inspected, and open to public scrutiny' makes pet shops OK, and even preferable to private sellers.
DEFRA disagrees and advises buyers to see the puppy with its mother, but confusingly still maintains that the current system is sufficient to "ensure that animal welfare standards are being applied" in pet shops. (The Pet Animals Act 1951 has no provisions for ensuring normal behaviour and protection from fear and distress and therefore cannot ensure animal welfare standards are being applied.)
Most (but not all) local authorities appreciate that the five sentences forming the main provisions of the Pet Animals Act do not provide anything like adequate criteria for determining the suitability of premises to be licensed as a pet shop.
In an effort to increase regulation and improve animal welfare, successive generations of 'model guidelines' have been developed for local authorities. However, the latest of these published in 2013, are still only described as 'basic minimum' guidelines and even Pet Industry Federation apparently agrees they are insufficient for puppy vendors, hence the development of their own Quality Audit.
In recognising that local authority licensing by itself is inadequate, the Pet Industry Federation's desire to protect the pet shop trade in puppies seems illogical. Of even more concern though is the organisation's apparent incomprehension of the many facets of the third party trade in puppies, a poor reflection on a trade body purporting to represent the industry.
The term 'pet shop' is applicable in law to anyone carrying on a business of selling animals as pets, and therefore any person buying in puppies for resale is required to hold a pet shop licence, irrespective of whether they are operating from their private home, a puppy farm, or 'traditional high street premises'.
A pet shop licence is also a requirement for intermediaries acting as dealers, who sell puppies wholesale to other dealers or final outlets, therefore Mr Baker's use of the word 'retailers' does not appear to accurately reflect the range of 'pet shop' situations in existence i.e. along the supply route from puppy farm to customer.
The other issues highlighted in the article (the influx of puppies from Europe and internet sales) are intrinsically linked to pet shops too. Anyone importing puppies into the UK from Europe for resale must have a pet shop licence, meaning that a whole range of issues associated with this practice can be directly aligned to the sale of puppies from 'pet shops'.
The widespread use of the internet to advertise puppies is probably directly attributable to the recent escalation in third party sellers that are not operating from 'shop' premises, although many hold a pet shop licence.
It is hoped that in the interests of transparency and constructive discussion, the Pet Industry Federation will be now be prepared to release the full details of the Audit for scrutiny. On the basis of the limited information in Mr Baker's article, it does not appear that any of these measures are especially profound or groundbreaking and many will already be a requirement of local authority licensing criteria. Hardly an "enormous step forward" then.
There is now overwhelming scientific evidence that selling puppies through third party outlets has a detrimental effect on their welfare (not to mention the welfare of their parents) and therefore no basis for maintaining that buying from licensed, regulated premises protects consumers (and dogs) from poor practice - quite the reverse in fact!
The ultimate question for Mr Baker and his Pet industry Federation is just who they are trying to protect if not puppies or owners, and why do they continue to expend their efforts in allying themselves to a trade which certainly seems to bring both their organisation and industry into disrepute?
Marc Abraham BVM&S MRCVS, Founder PupAid
Julia Carr BSc (Hons), Founder Canine Action UK