In 2023, the European Commission published a proposal for a regulation on the welfare and identification of dogs and cats, which aims to curb puppy mills, illegal dog trade and dog smuggling more effectively. The goal is good, but the means are not in line with the goals. 

In June this year, the European Parliament voted on amendments to the Commission's proposal for a regulation, which has now moved to so-called trilateral negotiations within the EU. The Finnish Kennel Club is concerned that the pressure for harmonization is now directing us to address problems with means that do not best promote the well-being of the entire dog population and do not take into account cultural and local differences within the EU.

To support the monitoring of the welfare of the entire dog population, as much information on the origin of all dogs as possible is needed

The regulation requires that all EU countries have a dog register to which the dog's microchip and owner information are reported. Such a register is of concrete use in preventing puppy mills when the register contains as much information as possible about the backgrounds of all the dogs entered in it (owner, microchip number, possible kennel name, breeder's name, country of origin, date of birth and parents). 

All this information is entered in the registers of the national kennel clubs. Through the registers of the national Kennel Clubs, it is possible to verify the backgrounds of dogs that are in the register for several generations and also to collect health information on dogs used for breeding, family tree information, and information on how dogs are used for breeding. 

The number of pedigree dogs registered in kennel clubs in relation to the total dog population varies greatly in different EU countries. More than 70 per cent of the Finnish dog population is registered by the Finnish Kennel Club, while in some EU countries the percentage may even be less than 10. 

It is also problematic that in the future, dogs can only be identified by a veterinarian. There is a shortage of veterinarians and long distances in Finland, so it is very difficult to implement this requirement. The Finnish Kennel Club has nearly 500 trained identification markers, who have so far identified a significant number of Finnish dogs. Now, with the proposal for an EU regulation, this possibility would be removed. The bill for this is paid by the dog owners.

The proposal for a decree does not sufficiently recognise the model of Nordic dog breeding

According to the proposal for a decree, professional dog breeding would be closely monitored.  A breeder who breeds more than two litters per year would have to have a permit from the authorities, and the authority would inspect his or her farm before granting the permit. Under the Finnish Kennel Club alone, there are almost 700 such breeders. The official veterinary resources will not be sufficient to carry out these inspections. 

In the view of the European Parliament, the regulation would not apply to breeders who breed only one litter per household in an 18-month period if they do not register the litter for sale. A breeder or dog keeper who breeds a maximum of two litters per year would not need permission from the authorities, but a veterinarian acting as an authority could make a welfare inspection visit to him or her once a year without prior notice. 

Especially in the Nordic countries, there is a lot of small-scale breeding under the kennel clubs, which means that the breeder has about one to three litters during the year. A small breeder can closely follow the development of the litter and socialize the puppies well. This is important because dogs play an increasingly important role in society and as family members.

In countries where the number of pedigree dogs registered in kennel clubs out of the entire dog population is large, such as Finland, the new decree in its now planned form would drive down small-scale farming activities. Not all small breeders are ready to become professional dog breeders, if only because the requirements set for such activities in kennel farms are not realistically feasible in small-scale breeding work at home. 

If the new regulation directs European dog breeding in a more commercial direction and towards large units, there is a risk that some of the small-scale breeding work under the Finnish Kennel Club will fade away and cease altogether or move outside organized breeding activities, which will make it more difficult to supervise dog breeding. In the Finnish Kennel Club's view, this does not promote the well-being of dogs. 

The authorities' supervisory resources would probably not be sufficient in Finland 

The proposal for a regulation requires that all EU countries have extensive resources and sufficient official veterinarians at their disposal to monitor the welfare of dogs. In a small country like Finland, it is not sensible, or even possible, to use society's resources to inspect the premises and operations of individual small operators instead of effectively targeting dog puppy owners and puppy mills operating in a grey area. 

Very strict breeding regulations cannot be enforced in the entire dog population

The new decree would define the exaggerated appearance traits affecting the welfare of dogs that should be avoided in the future. By 2030, the regulation would be supplemented by lower-level regulations that would define these breed-specific exaggerated traits more precisely. At the national level, dog breeding could be regulated even more strictly. 

According to the position voted by the European Parliament, dogs with such exaggerated breed characteristics would be prohibited from participating in dog shows, trials and competitions. This would essentially interfere with the opportunity to engage in hobbies with dogs, which in turn directly affects the well-being of dogs. 

From the point of view of dog welfare, different bans in different countries have proven to be very ineffective in practice. There is a risk that the breeding of breeds with exaggerated appearance characteristics will move completely outside of organized dog activities, which will make supervision even more difficult. 

As the challenges of dog breeding differ from one EU country to another, the wisest thing to do would be to ensure that the EU-level policies are not too strict. In practice, these requirements can be controlled largely only with regard to registered pedigree dogs in breeding and hobby activities under the Kennel Clubs. Outside of organized dog activities, it is very difficult to supervise breeding regulations in particular. Legislation that steers dog breeding out of strongly organized dog activities, leaving most of the reproduction of dogs completely out of control in some countries, does not promote the welfare of dogs in practice. 

The views of the national Kennel Clubs should be heard and best practices should be utilised

When preparing dog breeding regulations, it is very important to consult the national kennel clubs. The Nordic Kennel Clubs, in particular, have developed good practices for the management of dog breeding, and in practice they have been able to promote the well-being of dogs very quickly. The most cost-effective way to control dog breeding is under the national kennel clubs. It is not appropriate for the EU to seek to harmonise dog breeding without taking into account the very different starting points of the EU countries. 

Many EU countries have already enacted or are in the process of enacting decrees on restrictions on breeding. In Finland, a working group appointed by the Ministry of Agriculture and Forestry is currently drafting a breeding decree supplementing the Animal Welfare Act, and the Finnish Kennel Club is represented in this working group. The aim of the working group is that the decree can be used to lay down restrictions that apply to the entire dog population, and thus it can genuinely affect the welfare of all dogs. 

More than 230 dog breeds currently have a mandatory health program in the Finnish Kennel Club as a condition for registering a litter. At the moment, unregistered dogs are not required to undergo health examinations and they are not supervised. 

Additional information

Kirsi Sainio
Chair of the Finnish Kennel Club's Scientific Committee
kirsi.sainio@kennelliitto.fi
tel. +358 44 218 4431

Molli Nyman
Chair of the Finnish Kennel Club's Breeders' Committee
molli.nyman@kennelliitto.fi
tel. +358 44 712 3534


Photo: Paula Grekelä/Koiravalokuvausta Lapista