PAAG response to DEFRA Animal Welfare Strategy

The Pet Advertising Advisory Group’s (PAAG) goal is to ensure that animals advertised for sale as pets online have a good life, through preventing unethical sales and empowering informed purchasing decisions.
The UK Government’s Animal Welfare Strategy contains some positive steps towards realising this goal, but more needs to be done.

As a cross-sector group bringing together multiple animal welfare organisations, pet-selling platforms and government bodies, PAAG works at the frontline of the online pet sales landscape. The measures set out in the Strategy therefore have direct implications for how effectively we can prevent unethical sales and protect prospective pet owners and animals online.

Pet sales

What’s in the Strategy?

On pet sales, the Government has committed to:

• Working with the sector to support the work that is already underway to encourage responsible sourcing practices by prospective owners
• Working with the sector, animal welfare organisations and local authorities to ensure that the relevant guidance applicable to licensing is clear and proportionate
• Working with pet selling businesses to reduce the administrative burdens they face, including in relation to record keeping requirements
• Promoting consistent and effective enforcement through working with local authorities
• Working with local authorities and supporting them to effectively implement and enforce the primate licensing scheme

What do we think?

Online pet sales have been at the core of PAAG’s work since our formation in 2001. Our Advertising Standards were developed to address the risks associated with pets being sold online, where a lack of regulation can enable unethical and irresponsible breeding and selling practices.

Though we welcome these positive steps forward by the Government, PAAG is disappointed to see that there is no specific mention of online pet sales in the Animal Welfare Strategy. Recent pet acquisition data from PAAG member organisations demonstrates that a significant percentage of pet sales are conducted through online platforms, and we have long called for legislation to properly regulate these sales.

Education is identified as key, but we are disappointed that there are no plans to adopt the Good Practice Codes for Rabbit Welfare which were agreed by stakeholders and APGAW in 2021. England is the only Government not to have official codes for rabbits, who are the third most popular mammalian companion animal.

We will continue to call on the Government to enshrine all of PAAG’s Advertising Standards into UK law to empower informed purchasing decisions and promote the enforcement of ethical practices.

Breeding

What’s in the strategy?

With respect to breeding and extreme conformations, the government has committed to:

• Launching a consultation on Introducing a new registration scheme for all dog breeders to improve traceability and enforcement
• Launching a consultation on improving the health and welfare standards which all licensed breeders of dogs must meet
• Launching a consultation on proposals to bring canine fertility clinics, stud dog and whelping services in scope of the licensing system
• Taking steps to improve the uptake of the pet selling licence by those who sell cats and kittens as pets
• Improving their understanding of the size, scale and current management practices related to cat breeding, and consider any further steps which may improve welfare practices in this sector.

What do we think?

Breeding practices directly impact the types of animals that are advertised for sale online as pets, and PAAG sees the consequences of poor regulation reflected in listings for animals with welfare concerns, such as extreme conformations.

PAAG is pleased to see the potential introduction of a new registration scheme for all dog breeders following consultation, but remains particularly concerned by the lack of commitment to licence the cat-breeding sector. As a member of PAAG, Cats Protection fears that “the government has chosen to leave cats behind in its Animal Welfare Strategy”, and that harmful breeding practices and the extreme conformation of cats and kittens must be tackled through effective legislative measures that are not present within this Strategy .

Despite having evidence to confirm that the business test is not being applied, the government has also failed to address the regulation of breeders of other species, including rabbits, small furries and exotics, which causes further concern. For example, there is no requirement for those breeding and selling rabbits online to be licensed, which has sparked an alarming boom in this area of online pet sales. It is also disappointing to see commitments to ‘consult’, as opposed to taking concrete actions with structured, time-bound goals.

Traceability

What’s in the strategy?

In relation to the traceability of pets as they are sold or rehomed, the Government will:

• Develop a more robust process and improve regulatory oversight of compliant pet microchipping databases, and ensure that all databases meet expected standards.

What do we think?

The effective traceability of pets is essential to combating unethical pet sales, as it allows animals advertised for sale online to be accurately linked to breeders, sellers, and potential unethical import routes.

PAAG is concerned at the omission to reform the microchipping system more broadly, as promised by the previous Government. There are currently over 20 Defra-complaint microchip databases; PAAG supports our member’s calls to condense these into 1 compliant database to improve the traceability of pets and tackle unethical pet sales in the process.

Rehoming

Regarding the rehoming sector, the Government has pledged to:

• Launch a consultation on licensing domestic rescue and rehoming organisations
• Develop the evidence base on welfare issues associated with international rescue and rehoming

What do we think?

Our work also aims to ensure that animals advertised for rehoming online are done so responsibly and ethically.

PAAG is pleased to see measures to better regulate rehoming organisations in the Strategy. However, committing only to a consultation on licensing domestic rescue and rehoming organisations risks delaying much-needed regulation to ensure that all organisations operate ethically. Moreover, there already exists extensive evidence of the welfare issues associated with international rescue and rehoming, thus risking further delays on introducing targeted action to combat these concerns.

There is also concern, given our comments in the breeding and selling section, that nothing is being done to regulate breeders, to ensure that demand meets supply, or that healthy animals are bred and rehomed responsibly. Putting extra demands on rescue organisations instead of breeders does not seem to accurately reflect the problem at hand.

Pet smuggling

What’s in the strategy?

To tackle the smuggling of pets, the Government has committed to:

• Delivering the measures in the Animal Welfare (Import of Dogs, Cats and Ferrets) Act 2025 to close loopholes in our pet travel rules
• Developing secondary legislation to tackle low-welfare imports, and working closely with enforcement bodies and stakeholders to develop appropriate exemptions and robust enforcement processes
• Working with enforcement agencies to strengthen existing enforcement of our pet travel rules and facilitate improved intelligence sharing between agencies

What do we think?

We welcome the Government’s commitment to implementing the Animal Welfare (Import of Dogs, Cats and Ferrets) Act, including the development of secondary legislation and collaboration with enforcement bodies and stakeholders to tackle unethical international imports. We hope that these measures will help to reduce the number of smuggled pets being sold online, with unsuspecting buyers having to face illness or behavioural challenges in their new pets as a result.

Conclusion

Overall, PAAG will work with the Government to aid in the implementation of the Animal Welfare Strategy, drawing on our expertise in online pet advertising. However, we remain concerned by the lack of clear timelines and the potential delays caused by consultation. We will continue to campaign for the UK Government to enshrine all of our Advertising Standards in law, as a vital tool to prevent unethical sales and better protect animal welfare.