VDH statement on the current EU proposal for a regulation on the welfare of dogs and cats and their traceability

The Verband für das Deutsche Hundewesen (VDH) e.V. is the leading umbrella organization of pedigree dog breeding clubs and dog sports associations that pursue exclusively non-commercial purposes.

The VDH currently has 186 member clubs, representing around 600,000 dog owners. In additionto the controlled breeding of healthy pedigree dogs that are suitable for everyday use,the VDH is committed to ensuring that dogs are kept in a species-appropriate and responsiblemanner. Through their membership of VDH member clubs, breeders, athletes and dogowners in the VDH voluntarily follow strict rules in the breeding and keeping of dogs that gobeyond the provisions of the Animal Welfare Act and the Animal Welfare Dog Ordinance ofthe Federal Republic of Germany. Maximum and minimum requirements regarding the use ofdogs for breeding, strict health requirements and behavioural tests are just a few examples.

The VDH has been committed to combating the illegal puppy trade for years and is aco-founder of the Working Group on Puppy Trafficking (AG), which was founded in 2011 withthe aim of raising public and political awareness of the problem of the increasing puppytrade and the impending consequences. The working group is a joint initiative of FOUR PAWS– Foundation for Animal Welfare, TASSO e.V., the German Kennel Club (VDH), the GermanAssociation against Animal Abuse (bmt), the Society for Animal Behavioural Medicine andTherapy, the German Veterinary Association for Animal Welfare and the German AnimalWelfare Association.


General evaluation

The VDH represents the interests of all dog owners in Germany and therefore welcomes theendeavour to create Europe-wide, uniform standards for the breeding and keeping of dogs.The VDH shares the EU Commission's assessment of the illegal puppy trade and welcomesthe proposed measures such as EU-wide compulsory registration and legally binding andcontrolled minimum standards for the breeding and keeping of dogs.However, from the VDH's point of view, there is a need to clarify and adapt the proposedrules in several points. Before we go into more detail below, we would like to take this opportunityto briefly outline which regulations we believe should be improved:

  • Article 1: The scope of the regulation is limited to animals kept and bred in breeding establishments. In our view, the majority of the rules should apply to all dog breeders in the EU.
  • Article 3: Some definitions of terms should be improved.
  • Article 4: The demarcation criteria for whom the regulation applies are not optimally formulated. Furthermore, as noted above, the majority of the regulations should apply to all dog breeders, regardless of the size of the breeding establishment.
  • Article 6, No. 3: The current wording allows for interpretations that would make any dog breeding impossible (prohibition of breeding with carriers, prohibition simply on the basis of morphological characteristics).
  • Article 9: Mandatory expertise should apply equally to all dog breeders.
  • Article 11 i. V. m. Annexes: The general requirement to feed all adult dogs twice a day cannot be scientifically justified and disregards the individual feeding needs of dogs.
  • Article 12, No. 3 in conjunction with definitions of terms: In its current form, the regulation prohibits any accommodation of dogs in kennels and other boxes, even for a short period of time. It should be defined from what period of time it is to be assumed that a dog is being kept in a kennel or other box.
  • Article 13: The proposed minimum age for breeding is not suitable for all dog breeds.
  • Article 17: A Europe-wide identification and registration requirement for dogs is absolutely necessary. This should not only apply to dogs kept in breeding establishments and other facilities. In addition to veterinarians, other trained personnel should also be authorised to carry out the identification.