How do the recent government rules and regulations affect GSDCA members?

USDA Rule on Imported Dogs

In 2008, Congress passed an amendment to the Animal Welfare Act that required APHIS (Animal and Plant Health Inspection Service) to promulgate regulations to restrict imported dogs under 6 months old.  As written, the APHIS Import Dog Regulations cover any dog imported into the United States, including Alaska and Hawaii, from foreign countries and U.S. territories, which are intended for resale.  It stipulates that they must be 6 months old or older.  This does NOT affect those dogs brought in for one’s personal use.  It DOES include those dogs brought in for resale by rehoming groups.  It does NOT cover dogs brought into the U.S. for research or veterinary medical care.

These regulations, unlike the revised Pet Store Regulations, are straightforward and fairly easy to understand.  Any dog that is imported in the U.S. with the intention of being resold, whether by a broker, or from a rehoming organization, must be 6 months old, be up to date on rabies vaccination and possess a current health certificate.  Kevin Shea, APHIS Administrator, writes on the introduction to the final rule, “This rule implements new requirements in the Animal Welfare Act to insure dogs imported for resale are healthy and vaccinated.”

The final rule may be viewed here:

The AWA amendments were originally were developed for individuals traveling abroad with their pets.  It became apparent in the 2000s that these regulations were being misused by the pet industry and rehoming groups for the mass importation of dogs.

An excellent article on the history of the road to 2014 Dog Import Rule is Patti Strand’s article on the NAIA website, ( “NAIA Applauds USDA Rule Protecting Pets and People! USDA Finalizes Sensible Regulations to Prevent the Importation of Sick and Dangerous Dogs for Resale” where she writes:
“Without these new regulations, the US would become the dumping ground for the world’s stray dogs. In 2006, the CDC estimated that 297,000 were imported into the US, about 199,000 of them smuggled across the Mexican border.  Until the finalization of this regulation, and the tightening of confinement agreements there was little in place to stop dogs from entering.”

Updated CDC Rabies Requirements on Imported Dogs:

CDC (Center for Disease Control and Prevention) on July 10, 2014, effective August 11, 2014, issued Issuance and Enforcement Guidance for Dog Confinement Agreements  “This guidance describes the factors that HHS/CDC will consider in deciding whether to issue a dog confinement agreement or deny entry of a dog being imported into the United States that has not been adequately vaccinated against rabies.”

However, all dogs imported into the U.S. must have a Rabies vaccination with the exception of those animals arriving from Rabies Free countries (please see list below).  Those dogs that have never had a rabies shot (pups) must have had the vaccination 30 days prior to import.  Pups must not be vaccinated against rabies before 3 months of age, so the youngest that a puppy can be imported into the U.S. is 4 months old. Very limited approval will be given to dogs without the Rabies vaccination requirements.  That permission must be granted PRIOR to arrival in the U.S. and on a case-by-case basis.  Dogs without the required advance permission might be returned to the country of origin at owner’s expense.

Certain dogs may be imported without rabies vaccinations under limited conditions.

•Dogs that are imported from a rabies free country in which they have lived for at least 6 months: List at the site:
•Dogs are imported for scientific research in which the rabies vaccination would interfere with the study.
•Dogs who are planned for importing and are unable to provide a valid rabies vaccination certificate upon arrival in the United States should contact CDC at This e-mail address is being protected from spambots. You need JavaScript enabled to view it as soon as possible in advance of the dogs’ planned arrival.  Confinement agreements may be approved on a limited and case-by-case basis.  Dogs that are not adequately vaccinated might be denied entry to the United States and returned to the country of origin at their owners’ expense.

These new CDC Rabies vaccination requirements probably means that breeders or puppy buyers will be looking to those Rabies-free countries more closely for new breeding stock or for their new pup.  It also means that those importing dogs should be extremely careful that their health certificates are completely approved by CDC, both as to country of origin and to details.

Canada and CDC’s Rabies Requirements:

Canada’s CKC is communicating with CDC to establish exceptions to the new requirements for CKC members.  Mr. Lance Novak, Executive Director, CKC, in an update to the members, appears confident that an understanding can be reached for CKC members exporting Canadian born pups to the U.S.


After APHIS published the revised regulations for dog breeders, there were hundreds of comments in social media, Yahoo lists and blogs, questioning whether APHIS staff understood the many nuances involved in breeding dogs that most of us do.  What almost everybody could agree on, and there was much more that they couldn’t, was that was that the staff at APHIS needed to know more about non-commercial and hobby breeders.

APHIS listened: they hired Julian Prager, who is eminently qualified, to translate not only non-commercial breeders' unique situations but also the needs of those who rehome.

APHIS subsequently developed the position of Canine Program Advisor in mid July 2014.  Julian Prager, who was hired to fill that position, is a Bulldog breeder and exhibitor, Counselor for the Bulldog Club of America, is a licensed attorney in NY, and is the Legislative Chairman for the Pennsylvania Federation of Dog Clubs.  He has held several Commissioner-level positions in NYC government and was General Counsel and Executive Director of New York City Animal Care and Control. He is also a legal analyst and advisor for NAIA.

Julian announced his APHIS appointment to AKC Delegates at the September 8 Delegates' meeting Legislative Committee.  Here are excerpts from his announcement to an AKC Legislative Liaisons List:

“Small hobby and show breeders have all been concerned about the implications of the revision to the “Retail Pet Store Rule" by APHIS and the implication for that group. APHIS has heard your concerns.  At last year’s NAIA conference, the APHIS Deputy Administrator met with about 20 of us after the session to discuss our concerns and issues.  He committed to work with us to work to resolve these issues.”

“I will be providing APHIS staff with technical guidance on dog issues, assist in training their field staff, participate in developing program information material, conduct outreach and education and, most significantly, work on developing related policies and rules.”

Julian has requested comments and feedback for “assistance in developing clear rules and meaningful exemptions for activities which have a minimal effect on interstate commerce.” He can be reached at This e-mail address is being protected from spambots. You need JavaScript enabled to view it . I hope that you will share your concerns with him.

Finally, I continue to ask the GSDCA Board to finalize what was passed several years ago and to appoint a Legislative Chair and Committee.  In today’s climate, not having a Legislative Committee is a dangerous oversight, which will eventually catch up to our dismay, as all oversights eventually do.

Last Updated on Wednesday, 22 October 2014 19:09