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International Law News

International Law News, Winter 2022

CDC Ban on Dogs from Over One Hundred Countries

Aine Dillon

Summary

  • In June 2021, The Centers for Disease Control and Prevention (CDC) announced without notice, a temporary suspension of the importation of dogs from over one hundred countries defined as "high-risk for dog rabies."
  • This decision came on the heels of a worldwide pandemic and was an attempt to keep dog and human populations of the U.S. healthy; however, it severely hinders the work of many reputable international rescue organizations attempting to bring dogs into the U.S.
  • This ban makes it harder, and sometimes even impossible, for soldiers, diplomats, and U.S. citizens living abroad to bring their companion animals home.
CDC Ban on Dogs from Over One Hundred Countries
Ryan Jello via Getty Images

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This past June, the Centers for Disease Control and Prevention (CDC) announced without notice, a temporary suspension of the importation of dogs from over one hundred countries defined as “high-risk for dog rabies.” This decision came on the heels of a worldwide pandemic and was an attempt to keep dog and human populations of the U.S. healthy; however, it severely hinders the work of many reputable international rescue organizations attempting to bring dogs into the U.S. Additionally, this ban makes it harder, and sometimes even impossible, for soldiers, diplomats, and U.S. citizens living abroad to bring their companion animals home.

Rabies

Rabies is a disease that causes progressive, fatal inflammation of both the brain and the spinal cord. It is one of the deadliest zoonotic diseases, as it is almost always fatal once clinical signs appear. The disease accounts for an estimated 59,000 human deaths globally each year, of which 98% are from the canine rabies virus variant.

Otherwise known as dog rabies, the canine rabies variant is highly transmissible between dogs. Dogs in the U.S. are required to be vaccinated for rabies every year. Forty to sixty dogs in the U.S. each year are infected with the wildlife variant, likely from exposure to a wild animal such as a raccoon or bat.

Although the U.S. eradicated the dog variant in 2007, the CDC is concerned about the possibility of dog rabies being reintroduced to the U.S. due to the increasing number of imported dogs arriving with inadequate or fraudulent rabies vaccination records. The reintroduction of dog rabies back into the U.S. would be both devastating and costly to the public.

CDC Decision

On June 14, 2021, the CDC released a “Notice of Temporary Suspension of Dogs Entering the United States from High-Risk Rabies Countries.” Effective exactly one month later, the importation of dogs from countries classified as high-risk for dog rabies was largely prohibited. The suspension also extended to dogs traveling from other countries if they had been in one or more of the high-risk countries within the last six months. The CDC stated that, “[d]ue to the unprecedented global response to the Coronavirus Disease 2019 (COVID–19) pandemic and limited availability of public health resources at the federal, state, and local level, this action is necessary to protect the public health against the reintroduction of canine rabies virus variant (CRVV) into the U.S. and to ensure the welfare of dogs being imported into the U.S.”

This action, although aimed at achieving an important and widely supported cause, affects healthy dogs looking for their forever homes in the U.S., and the important work that rescue organizations do worldwide.

During the pandemic, there was an increase in adopted animals. The ASPCA conducted a study that estimated that one in five U.S. households acquired a cat or dog since the beginning of the pandemic. Some shelters even emptied, which may have increased the reliance on imported animals from other countries.

Reasons for the Ban

Along with the announcement of its ban, the CDC released some reasoning and data. In 2020, more than 450 dogs arrived in the U.S. with falsified or fraudulent rabies vaccination records, a 52 percent increase compared with the previous two years. Further exacerbating the problem, throughout the COVID-19 pandemic, fewer flights resulted in delayed return trips for dogs denied entry into the U.S. One affected dog died at the Chicago O'Hare International Airport when its importer was found to have falsified the vaccination records of eighteen German shepherds. The dogs were kept in a warehouse with no food or water for an estimated seventy-two hours before being released, and in that timespan, one dog died while many others became severely ill.

The CDC’s explanation cited three instances where dogs imported into the U.S. since 2015 later tested positive for rabies. In all three instances, the rabies vaccination certificates prepared in the exporting country were deficient, and subsequent serologic testing showed that the dogs were unvaccinated or had been improperly administered the vaccine. A fourth case occurred after the CDC sent their announcement to the Federal Register for publication. However, to put these cases in perspective, the CDC’s own estimates demonstrate that before the suspension was instituted, between 60,000 and 100,000 dogs were imported annually from “high-risk” countries without any indication of a rabies problem.

The CDC’s reasoning also pointed to the cost of rabies infected dogs being imported into the U.S. The CDC estimated that the “importation in 2019 of a single dog with rabies cost more than $400,000 for the public health investigations and rabies post-exposure prophylaxis (PEP) of exposed persons.” Further, the CDC estimates that the “cost of care for people exposed to rabid dogs to cost between $215,386 and $508,879 per importation event.” The CDC argued that with the increased public health costs associated with the COVID-19 pandemic, an outbreak of dog rabies would also be very costly, especially in light of the increased importation of dogs during the pandemic and fewer flights leaving the country to return dogs imported in noncompliance with the requirements.

Pursuant to the ban, the CDC established an entirely new Dog Import Permit process, primarily for government personnel returning to the U.S. on an “extremely limited basis.” The permit application requires importers of personal companion dogs to make a one-time application to import a maximum of three dogs. For the dogs to be eligible for an import permit, they must be at least six months old, microchipped, have a valid rabies vaccination certificate, and obtain a valid post-vaccination serologic titer test from an approved laboratory. Significantly, the CDC expressly states that imports for the purpose of adoption or other transfers of ownership are ineligible for an import permit, therefore prohibiting rescue organizations from applying for these permits.

From July 14, 2021, to January 7, 2022, dogs with an import permit who are traveling from one of the listed high-risk countries may enter through eighteen approved airports. After January 7, 2022, only approved ports of entry will be allowed, and only three airports are currently listed: John F. Kennedy International Airport (JFK), Los Angeles International Airport (LAX), and Atlanta International Airport (ATL). If they want to return to the U.S. with their dogs, U.S. citizens and legal permanent residents must obtain a permit and enter the country through one of these airports.

The countries affected by this ban are countries that are defined by the CDC as “high-risk.” High-risk is determined by the “presence and geographic distribution of the [dog rabies] virus and by low quality of or low confidence in the country’s surveillance systems and its dog vaccination programs.” The CDC keeps a list on their website of the 113 currently listed countries considered high-risk for importing dog rabies into the U.S. Some countries currently listed include China, Vietnam, Kenya, Haiti, and Afghanistan.

Animal Rescue Groups’ Opposition

Many animal rescue groups have strongly opposed the ban because it hinders their ability to rescue dogs from many countries, including countries where dogs are sold for their meat. For example, Big Dog Ranch Rescue from Florida has rescued 700 dogs from China that would have been sold into the meat trade for human consumption. Additionally, responsibility for the few documented instances of imported dogs who subsequently tested positive for rabies should be placed on the foreign authorities who failed to property complete the dogs’ rabies certificates, and not on the rescue organizations themselves. With the new ban, organizations like Big Dog Ranch Rescue will no longer be able to unite dogs with potential owners in the U.S. Additionally, many of these rescue organizations not only bring dogs to the U.S., but promote dog adoption in their home countries and aid animal welfare efforts in these countries as well.

Advocates have suggested alternatives to the outright ban. For example, China Rescue Dogs rescues dogs from the Chinese meat trade, and once the dogs are brought to the U.S., they are quarantined for thirty days and vaccinated. China Rescue Dogs is asking the CDC to recognize rescue operations like theirs and requesting that they be deemed eligible to apply for an import permit under the new CDC program. An alternative approach is for the U.S. to adopt the dog rabies protocol used across the world. This would include testing every dog that enters the U.S. for antibodies (rabies titer testing). This testing protocol would not only ensure that the dog received the vaccine, but that the vaccine was effective.

Following the ban’s announcement, fifty-seven bipartisan members of the U.S. House of Representatives (thirty-five democrats and twenty-two republicans) sent a letter to the leadership of the CDC, urging the agency to rescind the suspension of dogs from these countries. The letter points to the recent Yulin “dog meat” festivals that have exhibited inhumane practices of abuse and slaughter. The letter also points to China’s lack of enforcement against the killing of dogs for meat. Representative Ted Deutch stated:

“The CDC ban does not recognize the complexities of international dog rescue transport.” The letter also asserts that a total ban is not necessary to keep dog populations in the U.S. healthy.

Impacts of the Ban

Other advocates are concerned for soldiers and diplomats working abroad, whom the ban also impacts. Although these workers can apply for import permits, many are worried about the feasibility of obtaining the necessary paperwork and testing for their companion dogs. Further, if the proper paperwork is not filed correctly, the importer of the dog must pay the airfare to transport the dog back to their country of origin, whether or not they have plans for the dog’s care once returned.

A number of areas of active U.S. military presence abroad, including Afghanistan, Djibouti, Georgia, Iraq, Jordan, Kenya, and Saudi Arabia are listed as high-risk countries by the CDC. Many soldiers living abroad, who have created bonds with their dogs, will not be able to bring them home to the U.S. The requirement of applying for an import permit six weeks before the dog’s anticipated U.S. entry is simply impossible for many military workers, and many of the countries in which they are stationed may not have a CDC-approved laboratory.

Diplomats living abroad are also impacted by the ban. Obtaining the proper paperwork and required testing can be very difficult, and even impossible, for some U.S. personnel serving in high-risk countries. Some of the countries listed do not have laboratories approved by the CDC, making it even harder for U.S. citizens and legal permanent residents traveling home from those countries to obtain the necessary paperwork. Following the ban’s announcement, many current and former diplomats are left to seek out a stranger to care for their animals while their family dog is barred from entering the U.S.

Conclusion

Although the objective is laudable, the CDC’s Temporary Suspension unnecessarily bans healthy dogs hoping to come into the U.S. for a better life and to escape their potential sale into illicit markets. It also hinders the important work that rescue organizations carry out abroad. The possibility of canine rabies entering the U.S. would be devastating; however, banning dogs from 60 percent of the world is overreach. Dog Import Permits should be available to animal rescue organizations like China Rescue Dogs, and to importers who follow all of the CDC’s criteria for proper vaccination, confirmed by serologic testing as embodied in the agency’s new Dog Import Permit Program. Further, the CDC should consider using a rabies testing protocol like that employed by the European Union, which requires antibody testing to ensure that the vaccine has been properly administered and has resulted in effective protection against the virus.

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