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Animal welfare groups have cast doubt on government plans to introduce three types of licences to control dog breeding, claiming the move won't protect animals.
Critics say that the rules, designed to keep a check on commercial dog breeders, are not enforceable.
Professional pet breeders have been operating under the government radar by calling themselves hobby breeders.
In some instances, such breeders have been found keeping animals in poor living conditions and forcing dogs to mate so often that some fell ill.
To bring hobby breeders under control, the Agriculture, Fisheries and Conservation Department wants to issue three types of licences.
The first is for genuine hobby breeders, who will be allowed to keep a maximum of four mother dogs; the second is for those who have more than four mother dogs; and the third is aimed at those who want to breed their dogs once and sell the offspring.
The department told breeders and animal groups earlier this month that the licences will make stipulations on space, ventilation, lighting, exercise time and mating.
But while animal welfare groups laud the department's good intentions, they say the conditions will be hard to enforce.
One requirement is for breeders to allow the animals to exercise for at least 30 minutes a day.
"We asked how the government would know if the dogs are exercised. They told us breeders will be required to fill in a logbook, stating whether they have done so," Cheung Yuen-man of Animal Earth said. "But the breeders could write anything in the logbook. It is impossible to verify the records."
Another rule is that dogs should not be forced to mate so often that it would amount to inhumane treatment. But, given that animals do not speak, this could also be hard to verify.
Cheung added that keeping tabs on hobby breeders who keep animals at home would be particularly difficult, and noted that without setting a limit on the number of licences given out, the government would risk running short of resources to implement the law.
She was also concerned that the dogs would be dumped at shelters when they are retired, as the code does not forbid breeders from doing so.
"Some breeders sell animals under the disguise of adoption. If the restrictions are too lax, what the breeders are doing will be legitimised without improving animal welfare," she said.
Breeding should be professionalised, she said, noting that overseas breeders normally need to pass exams on medical care for dogs.
Mark Mak Chi-ho, of the non-profit-making Veterinary Service Society, said nine animal welfare groups are requesting a complete ban on hobby breeders.
"It is not a trade which must exist … giving out licences to inexperienced breeders contravenes animal welfare," he said.
But other groups, such as the Society for the Prevention of Cruelty to Animals, said it was too early to dismiss the code.
Fiona Woodhouse, the SPCA's deputy director of welfare, said that because the breeding trade escaped regulation under a legal loophole, it was important to introduce a licensing system as a first step.
"Not doing anything will not help the situation," she said.
But she did not endorse calls to ban home breeding, instead focusing her concern on commercial breeders who keep five or more dogs.
"Generally, around the world, people are against large-scale puppy farming. Living in a cage is not the best thing for the welfare of that dog," she said. "There should be a limit on the number of dogs they can keep."
A department spokeswoman said licensing will enable the department to develop an extensive database of animal breeders for conducting regular visits and inspections, which will help ensure the puppies for sale are raised under appropriate conditions.
It is estimated that there will be around 30 licences given to people keeping five or more mother dogs, and a few hundred for those who have up to four.
Aside from checking breeders' logbooks, regular and surprise inspections - including health checks on dogs - will be conducted. The department will also act on complaints from the trade and the public.
Proposed Code Of Practice
- For owners of four dogs, their flat should fulfill a size requirement: 9.29 square metres (100 square feet) for each small dog and 23.23 square metres (250 square feet) for a big dog.
- For owners of five dogs or more, each small dog should have an individual sleeping area of not less than 1.1 square metres. It should not be less than 3.5 square metres for large dogs.
- Dogs should be exercised for at least 30 minutes every day.
- Mother dogs should give birth between the ages of 18 months and six years old, and have no more than three litters within two years.
- DNA samples will be collected from the dogs' parents and their offspring.
- Details such as microchip number, vaccines administered and information of parents must be recorded for each dog.
- All dogs should undergo a veterinary examination no more than 30 days prior to being offered for sale.
Source: Agriculture, Fisheries and Conservation Department