Thursday, June 14, 2012

ALERT - USDA proposal to regulate hobby breeders

The Humane Society of the US recently submitted a petition on the "" website asking the Federal government to crack down on "puppy mills". In response to the over 30,000 signatures on that petition, USDA/APHIS is considering revising their rules.
Currently, anyone who sells pets at retail is exempt from USDA licensure requirements. That means if you are a hobby breeder or a pet store selling pets directly to the public, you do not need a license from the USDA. Only those breeders who sell pets at the wholesale level currently need a USDA license.
The new rule, however, would revise the definition of "retail seller".
If you:
  • Have MORE than four intact female animals, and 
  • ADVERTISE over the internet, in the newspaper or over the telephone, and
  • Don't arrange for each buyer to visit your place of business to see the pet before or immediately after the purchase, then
You would no longer be considered an exempt retail seller, and under the new proposal would be required to be licensed and inspected by USDA.
Needless to say, this would be devastating to most serious hobby breeders. However, the USDA is accepting public comments on this proposed new rule. ALL comments will be read and considered. We call upon all pet owners to contact the USDA either on-line or by mail and inform them of your concerns over this proposal.
Be sure to have your comments e-mailed on line or sent by mail by July 16th. Note that letters sent by mail MUST be received on or before July 16th to be considered.
The link that will take you to the "submit comments" page is:

Do not send form letters. All form letters that are the same but signed by different individuals are considered ONE letter, no matter how many are received by APHIS. Your personal comment is important, even if it is only a sentence or two. A long letter is not necessary. You may comment more than once.
When commenting on line, please note that there is a time limit (approximately 20 minutes) that you can keep the "submit comments" page open. If you want to take time to compose your letter, then it is most efficient to draft it in a word program and then cut and paste it onto the comment section.  
In writing your letters or comments, you may wish to use some of the following talking points:
  • It would be cost-prohibitive for me to have to build a USDA-compliant kennel. I would be unable to continue breeding.
  • I prefer to raise pets in my home for optimal socialization. I do not wish to keep them in a kennel.
  • This proposal would be harmful to my rare breed. Buyers are usually distant and rarely visit the premises during a sales transaction.
  • I am selective in the homes I approve for my puppies; I sell few pets locally, and must advertise and ship. This proposal would hinder my ability to find the best homes for my pets.
  • This new rule would be financially devastating to me. I cannot afford thousands of dollars to build a kennel facility to come into USDA compliance.
  • Requiring me to allow strangers into my home exposes my animals to contagious diseases. These can be fatal, particularly for young puppies and kittens.
  • Strangers entering my home makes me vulnerable to criminals who could target me for robbery or other crimes.
  • Strangers entering my home can include animal rights activists who are philosophically opposed to any pet breeding. These extremists may likely file unsubstantiated complaints against me, claiming authority by having entered my home.
  • Rescue groups often rely on use of a foster home network. They could not comply with USDA requirements and would be forced to cease operations. Crippling rescue groups would cause shelter intakes and deaths to rise.
  • This proposal is government overreach.
  • This proposal is a violation of my right to privacy.
  • As a pet owner, I am concerned about my future ability to purchase a well-bred, well-socialized pet for a reasonable price.
  • I am concerned about the future availability of service dogs, such as guide dogs for the blind. These dogs must be exposed to a variety of social situations and external stimuli. If serious hobby breeders are forced to keep their dogs and puppies in kennels, those dogs will not be suitable for service work.
  • As a hobby breeder who works away from my home, I cannot comply with the APHIS requirement to be available for unannounced inspections. I would be forced to quit breeding or face thousands of dollars in fines for noncompliance with this rules.
There are undoubtedly many more concerns with this new proposal. You may return to the page and comment as many times as you wish.
The AKC is also gathering signatures on a petition to send to USDA.
As of today, June 14, 2012, there are over 31,000 signatures on the AKC petition….a nice counter to the HSUS anti-breeder petition. Please do sign the AKC petition also, but remember, your signature on a petition is NOT a substitute for your official, personal comment to the USDA on their website. Both are helpful, but your personal comment to the USDA is ESSENTIAL to defeat this proposal.
Thank you for taking a few moments out of your day to post a comment to the USDA and to sign AKC's petition.
Sincerely yours,
Officers and Board of Directors
California Federation of Dog Clubs
*****Cross-posting encouraged******


  1. This comment has been removed by the author.

  2. spot on with this write-up, i like the way you discuss the things. i'm impressed, i must say. i'll probably be back again to read more. thanks for sharing this with us.

    Lee Shin


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