The Centers for Disease Control and Prevention (CDC) has issued its final rule that it hopes will reduce public health risks of the dog-maintained rabies virus variant (DMRVV) associated with the importation of dogs into the United States. The final rule addresses the importation of cats as part of overall changes to the regulations affecting both dogs and cats, but the final rule does not require that imported cats be accompanied by proof of rabies vaccination and does not substantively change how cats are imported into the United States.
In this final rule, CDC aligns U.S. import requirements for dogs with the importation requirements of other DMRVV-free countries by requiring proof of rabies vaccination and adequate serologic test results from a CDC-approved laboratory. Requirements that need to be met for dogs to be imported include: a microchip, six-month minimum age requirement for admission, and importer submission of a CDC import form. The rule also requires airlines to confirm documentation, provide safe housing for animals, and assist public health officials in determining the cause of an animal’s illness or death.
The final rule was published in the Federal Register on May 13 and is effective August 1, 2024.
AVMA article: https://www.avma.org/news/dog-import-requirements-strengthened-prevent-canine-rabies-return
Here are some resources released by the CDC:
https://www.cdc.gov/importation/bringing-an-animal-into-the-united-states/dogs.html
NYSVMS does not directly advocate to federal agencies. AVMA leads the advocacy efforts guided by the House of Delegates from each affiliated State and Specialist veterinary medical association.
The AVMA welcomed the updated regulation, as it has been working with Congress on legislation, such as the Healthy Dog Importation Act, to reduce the number of unhealthy dog imports into the U.S.
“The AVMA continues to support the CDC’s efforts to improve dog importation standards and is pleased to see the implementation of this new rule that will help protect public health and positively impact canine health and welfare,” said Dr. Rena Carlson, AVMA president. (AVMA)
We have received the following background information from AVMA.
There was a great deal of conversation around the issues CDC, Customs and Border Patrol, and USDA were facing with dog imports over 2 years and a proposed rule was published last summer with a comment period that ran from 07/10/2023 until 09/18/2023. On May 13th CDC published its final rule that included not only the regulations, but also their rationale for adopting them, and their responses to those who had commented on various issues. You can read the (100+ page) Federal Register notice on the final rule here: https://www.federalregister.gov/documents/2024/05/13/2024-09676/control-of-communicable-diseases-foreign-quarantine-importation-of-dogs-and-cats
CDC has also posted a synopsis here: https://www.cdc.gov/importation/bringing-an-animal-into-the-united-states/dogs-entering-us-after-august-1.html.
CDC divides dogs into categories of those coming from low-risk and high-risk countries, provides requirements for each, and also includes time-delimited charts to walk people through the steps. They also have a bot that can be used.
There are no exemptions for U.S. land borders and to import a dog from Canada you need the following:
- Needs to be at least six months old
- Has to have an ISO-compatible microchip
- Needs to be healthy
- Needs to have a CDC Dog Import Form receipt (CDC says this form can be completed right before travel [they even reference while “in line” at the border crossing]; owner fills this out)
- Needs to have either the Certification of U.S.-Issued Rabies Vaccination Form or a USDA-endorsed export health certificate (apparently both are valid for the duration of the U.S.-administered rabies vaccination, whether that’s a 1-year vaccine or 3-year vaccine)
- Needs to arrive at the location listed on the import form
CDC also provided their rationale for why they treated arrival across land borders the same as arrival via air and here is a summary:
CDC and U.S. Customs and Border Protection (CBP) indicate they have documented numerous instances in which importers transported dogs from a dog-maintained rabies variant virus (DMRVV) high-risk country to either Canada or Mexico and then made claims that their dogs had not been in a DMRVV high-risk country. CDC worked with CBP and the airlines and was able to confirm the importers had traveled with the dogs from a DMRVV high-risk country and were attempting to avoid U.S. entry requirements. CDC originally proposed a limited exemption for dogs under six months old, primarily to reduce the burden on travelers who frequently travel across the U.S. and Canada/Mexico borders and choose to travel with young dogs, but withdrew this exemption after considering comments on the final rule.
If it were possible for dogs under six months of age to enter via land border crossings, CBP and CDC believed this could create a significant burden on customs officers at these crossings because more importers would attempt to enter the United States in this way. This also could potentially lead to dogs from DMRVV high-risk countries arriving in the United States via land borders to circumvent HHS/CDC entry requirements.
Given that CDC has no registered Animal Care Facilities at land border crossings this creates a potentially dangerous situation for dogs that must be held pending determination of their admissibility, because neither CDC nor CBP have safe housing options at land ports of entry. Although data suggest more dogs enter the United States by air than by land each year, extrapolated data from 2006 estimated that 287,000 dogs entered the United States through land border crossings that year. CDC indicates it does not have recent data to confirm the volume of dogs crossing at land borders, but unofficial statements from CBP officers stationed at land border crossings suggest the volume remains high.
Ultimately, CDC removed the exemption to create a uniform standard for all dogs, help ensure U.S.-land borders are not overwhelmed with dog importations, and reduce the risk of importers fraudulently claiming that their dog has not been in DMRVV high-risk country.
Why is there no carve-out for importation from Canada?
The following section is another communication received from AVMA. Some of it duplicates the points made above but also goes into more detail.
CDC and U.S. Customs and Border Protection (CBP) indicate they have documented numerous instances in which importers transported dogs from a dog-maintained rabies variant virus (DMRVV) high-risk country to either Canada or Mexico and then made claims that their dogs had not been in a DMRVV high-risk country. CDC worked with CBP and the airlines and was able to confirm the importers had traveled with the dogs from a DMRVV high-risk country and were attempting to avoid U.S. entry requirements. CDC originally proposed a limited exemption for dogs under six months old, primarily to reduce the burden on travelers who frequently travel across the U.S. and Canada/Mexico borders and choose to travel with young dogs, but withdrew this exemption after considering comments on the final rule. If it were possible for dogs under six months of age to enter via land border crossings, CBP and CDC believed this could create a significant burden on customs officers at these crossings because more importers would attempt to enter the United States in this way. This also could potentially lead to dogs from DMRVV high-risk countries arriving in the United States via land borders to circumvent HHS/CDC entry requirements. Given that CDC has no registered Animal Care Facilities at land border crossings this creates a potentially dangerous situation for dogs that must be held pending determination of their admissibility, because neither CDC nor CBP have safe housing options at land ports of entry. Although data suggest more dogs enter the United States by air than by land each year, extrapolated data from 2006 estimated that 287,000 dogs entered the United States through land border crossings that year. CDC indicates it does not have recent data to confirm the volume of dogs crossing at land borders, but unofficial statements from CBP officers stationed at land border crossings suggest the volume remains high. So, ultimately, CDC removed the exemption to create a uniform standard for all dogs, help ensure U.S.-land borders are not overwhelmed with dog importations, and reduce the risk of importers fraudulently claiming that their dog has not been in DMRVV high-risk country.
Regarding the issue with dogs needing to be six months of age to be imported, CDC has provided rationale for that decision and I have extracted comments from the final rule that address this (apologies that this response is so lengthy, but CDC spends a lot of time discussing this in the final rule). I have also included the references as cited in the rationale for their decision.
CDC received comments in support of the six-month age requirement from individuals concerned about animal welfare and from public health and animal health organizations and agencies. CDC also received numerous comments opposing the six-month age requirement for dogs as too old. The latter commenters, who included representatives of the airline industry, breeders, breed enthusiasts, and trade groups, variously stated that dogs should be allowed entry at 12 weeks of age (the earliest age at which dogs can be vaccinated against rabies), 16 weeks of age (the earliest age at which the vaccine is considered effective), or any age (if arriving from a DMRVV low-risk or DMRVV-free country).
In the final rule, CDC indicates its belief that establishing a six-month age requirement for all dogs will assist in protecting public health, while simultaneously improving safety and providing welfare benefits for young animals subjected to stressful travel environments in which their health could be compromised. CDC disagreed with comments suggesting that dogs should be admitted into the United States if younger than six months. CDC indicated the purpose of the age requirement in the context of dogs arriving from DMRVV high-risk countries is to ensure 1) that imported dogs are old enough to be vaccinated for rabies; 2) that the vaccination has time to be effective and confer immunity on the dog; 3) that protection is verifiable; and 4) that there is an appropriate waiting period after drawing the titer to ensure the dog does not develop symptoms of rabies. They indicated that it is not sufficient that a dog be old enough to be vaccinated; there must be sufficient time for immunity to develop and authorities must be able to verify immunity. CDC has also documented cases of importers moving dogs too young to be vaccinated effectively from DMRVV high-risk countries to DMRVV-free or DMRVV low-risk countries to avoid rabies vaccination requirements. Therefore, CDC is also requiring that dogs from DMRVV-free or DMRVV low-risk countries be at least six months old to prevent importers from trying to circumvent CDC’s requirements by moving dogs from DMRVV high-risk countries through DMRVV-free or DMRVV low-risk countries.
The World Organization for Animal Health (WOAH) has established vaccine and titer standards and set seven months as the minimum age for importation of dogs from DMRVV high-risk countries.151 Countries following WOAH standards do not allow entry of dogs younger than seven months if following vaccine and titer timeline recommendations. Many rabies vaccines are licensed for use in dogs on or after 12 weeks of age and laboratories suggest titer collection occur 30 days after initial rabies vaccination. WOAH’s standards call for importation to occur a minimum of 90 days after titer collection (i.e., their earliest age for importation is seven months of age). The CDC’s final rule departs from the WOAH standard to provide additional flexibility and less burden to importers without compromising public health goals. CDC agrees that vaccine administration must follow manufacturer’s guidelines (i.e., with vaccination occurring on or after 12 weeks of age) and that a 30-day period between vaccination and titer collection is essential to ensure the animal has developed an adequate antibody response to vaccination. However, based on available scientific evidence,152 CDC concluded that a 30-day waiting period (rather than WOAH’s 90-day waiting period) between titer collection and travel is sufficient for monitoring the dog to ensure it does not develop signs of rabies.
CDC says it also established a six-month age requirement for all dogs because it can be difficult for veterinarians to determine with specificity whether a dog has reached the age at which it can be fully protected by the rabies vaccine before six months of age. Veterinarians rely on dental patterns to age dogs. However, it is difficult to accurately assess the age of dogs that are between four and six months old due to variability in an individual dog’s dental eruption patterns.153 Dogs lose all their deciduous teeth by six months of age making it easier to accurately assess the age of a dog. CDC has documented over 1000 cases of importers providing vaccine records that falsely stated the dog was over six months of age, but upon examination, the dog presented was much younger (often 6-8 weeks of age). Because the rabies vaccine is not considered effective in dogs under 12 weeks of age, these puppies were not protected against rabies and presented a threat to the families that purchased or adopted them. By requiring all dogs to be at least six months of age, CDC indicates it can better confirm that the dog presented matches the documentation presented, particularly the age listed for the dog, and that the dog is old enough to have been adequately vaccinated for rabies. The six-month requirement for all dogs also aligns with USDA importation rules, eases enforcement of the vaccination requirements, and reduces opportunities for fraud.
CDC states that setting the minimum age for importation below six months would undermine the ability of authorities to ensure dogs are fully, effectively, and verifiably vaccinated. A 12- or 16-week age requirement for importation would require potentially compromising the full 28-day development of immunity and/or risk importation of a rabid dog because screening fully for signs of rabies was not done. Screening for rabies can be difficult in puppies because they can often exhibit dyskinetic or uncoordinated movement as part of their normal growth and development. These awkward movements can also be seen in rabid dogs and may be mistaken in young puppies for normal movement patterns. Contrary to some common misconceptions, puppies are susceptible to rabies and rabies has been diagnosed in young puppies. For these reasons, the final rule sets six months as the appropriate minimum age for dog importation.
There were also comments that a six-month minimum age requirement for all imported dogs could lead to the decline of specialty breeds. Commenters stated that breeders in other countries would not want to house and care for dogs bred for resale for six months due to increased cost. Additional commenters said dogs need to be socialized with their owner prior to six months of age. CDC disagreed with these comments. First, USDA already prohibits the importation of dogs under six months of age for commercial purposes, which includes any transfer of ownership; therefore, the comment that breeders need to be able to import dogs under six months of age is invalid because it is already prohibited. CDC’s age requirement is aligning with a currently existing regulatory requirement from a partner Federal agency. CDC’s requirement is not new and therefore, there is no new or additional burden on commercial dog importations (i.e., dogs imported for rescue, resale, or transfer of ownership). Additionally, CDC notes that a six-month age requirement aligns more closely with WOAH requirements for the international movement of dogs and that 67% of DMRVV-free countries require dogs to be at least six months of age for importation.155 Furthermore, because dogs under six months of age are sexually immature and cannot be used for breeding, delaying their importation will not negatively impact their use as breeding animals. Second, although the primary public health reason for requiring a six-month age limitation for importation has been described above, CDC notes that socialization of puppies may be done overseas at the breeding facility or another overseas location such as a kennel or foster family prior to the dogs arriving in the United States. Additionally, the rule will likely better ensure the health of dogs during international travel to the United States, which is stressful for young animals and can result in illness and death. As noted above, the six-month age requirement for importation helps protect the health and safety of all dogs. CDC further notes that breeders and commercial importers effectively adapted to changing import requirements during the temporary suspension and that this rule adopts many of those same practices.
CDC further notes that separating puppies from the mother and littermates when they are too young may adversely impact dogs’ behavior and socialization.156,157 In CDC’s view, separating the puppies from their mothers and littermates has the potential to affect their social and mental development greatly and negatively and this risk outweighs the possible associated costs. CDC has also documented hundreds of cases where puppies under eight weeks of age (who are not yet protected against rabies due to their age) have been imported for resale. Although CDC acknowledges that some breeders may choose to change their operations based on CDC’s dog import requirements, CDC believes the public health benefits of this change outweigh the theoretical possibility of some specialty breeders choosing to import fewer dogs into the United States.
References provided by CDC for the above rationale are listed below.
151 WOAH Terrestrial Manual 2023, chapters 3.1.18 and 8.15.7.
152 Smith TG, Fooks AR, Moore SM, Freuling CM, Muller T, et al. Negligible risk of rabies importation in dogs thirty days after demonstration of adequate serum antibody titer. Vaccine 2021; 39 (18): 2496-2499.
153 Roccaro, M., & Peli, A. (2020). Age determination in dog puppies by teeth examination: legal, health and welfare implications, review of the literature and practical considerations. Veterinaria Italiana, 56(3), 149–162.
154 McQuiston JH, Wilson T, Harris S, Bacon RM, Shapiro S, et al. Importation of dogs into the United States: risks from rabies and other zoonotic diseases. Zoonoses and Public Health; 2008: 1-6.
155 Internal CDC data. Accessed January 30, 2024.
156 McMillan FD. Behavioral and psychological outcomes for dogs sold as puppies through pet stores and/or born in commercial breeding establishments: Current knowledge and putative causes. Journal of Veterinary Behavior. 2017;
19: 14-26.
157 Pierantoni L, Albertini M, Pirrone F. Prevalence of owner-reported behaviors in dogs separated from the litter at two different ages. Vet Record. 2011; 169: 468.
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