Pets and the shadow economy

The dark side of the pet business: puppy mills and illegal imports

Illegal commercial activity involving pets can be divided into two phenomena: puppy mills and illegal imports of pets.

Puppy mills refer to the regular breeding of cats or dogs for sale in which the needs of the animals are neglected to maximise profit. A puppy mill can be located in Finland or abroad. In a puppy mill, puppies and kittens are not provided with appropriate nutrition and care in cramped and dirty conditions, which causes them suffering. Pets that grow in such a mill also often suffer from various health problems and infectious diseases (such as parvovirus and various parasites). Some of these diseases are zoonotic, which means that they can be transmitted from animals to people and vice versa and/or spread into the environment. Due to their health problems and infectious diseases, the puppies and kittens that are handed over at a young age may become seriously ill or die soon after handover. At the time of handover, the puppy or kitten may look healthy upon visual inspection, and the seller frequently does not fulfill their duty to notify the recipient of its sickness or injury (Animal Welfare Act 247/1996, 2:14). In such cases, the buyer may make a report to the police about fraud if s/he has been deceived about the actual origin, health or other significant matters concerning the animal (Criminal Code of Finland, 36:1). In practice, puppy mills always involve animal welfare offences (Criminal Code of Finland, Chapter 17 Animal Welfare Offences).

Illegal imports of pets means that pets are imported without fulfilling the requirements that have been laid down in the EU and national legislation. In addition to national legislation, the basic requirements concerning pet movement are laid down in, for instance, the ‘Pet Movement Regulation’ (EU) No 576/2013 and ‘Implementing Regulation’ (EU) No 577/2013. The EU Pet Movement Regulation seeks above all to prevent the spread of rabies and echinococcosis, animal diseases communicable to animals and humans. Under the criminal law of Finland, importing a pet in contravention of regulations meets the characteristics of smuggling (Criminal Code, 46:4). Related criminal offences may typically include forgery (Criminal Code, 33:1), fraud (Criminal Code, 36:1) or causing danger with regard to the spread of a animal disease (Criminal Code, 44:4a). Illegally imported pets often originate from puppy mills in another member state or third country, in which case the characteristics of the aforementioned animal welfare offences may be met. Puppy smugglers are individuals or groups of importers that import large numbers of puppies to another country in contravention of regulations.

Typical characteristics of illegal imports

Pets are imported into Finland both legally and illegally from third countries and the EU/EEA. Pets are imported by private individuals as their own hobby animals and pets (non-commercial movement) and by various organisations or individuals for eventual handover in Finland (commercial imports). The purpose of commercial pet imports is always to sell or otherwise hand over the pet in Finland. Notably, private individuals who transport their own pet into the country but do not travel themselves within five days of the arrival of their pet have to import their pet in accordance with the commercial requirements.

As pets are also imported legally in large quantities and the import requirements vary by country of origin, it can be difficult for the buyer of a puppy to determine if the pet has been imported illegally.

If you are buying a puppy, pay attention to at least the following:

• Age of the puppy: Illegal imports often involve young dogs that have just reached the age of adoption (normally 7-8 weeks old).
• Breed of the puppy: Smugglers favour small and popular breeds.
• Sale: Smugglers favour online shops and platforms where sales are made quickly. Smugglers want to sell the puppies before the symptoms of infectious diseases and any health problems become apparent.
• Seller: Does the advertisement include the full name and contact information of the seller?
• Handover: All pet handovers that do not take place at the seller’s home are out of the ordinary.
• Means of sale: Cheap price, preference for cash, urgency and an irregular place of sale and handover method are the most typical indicators of illegal imports.
• More information https://www.ruokavirasto.fi/en/private-persons/lemmikki--ja-harraste-elaimet/frequently-asked-questions-about-animal-welfare/checklist-for-buying-a-pet-online/

Read more about the Finnish Food Authority´s Checklist for buying a pet online [.fi]›

The methods used by puppy smugglers change fast. Earlier, the typical method was to hand over the pet at the harbour or at a petrol station, railway station or other such location with good transport connections. Nowadays, however, the puppy might be handed over at the seller’s home, where the puppy’s ‘fake mother’ may be presented to the buyer. In such cases, the puppy is sold as Finnish and as having been born in Finland. The buyer may discover that the puppy was actually imported from another country only after paying for it and accepting it. These days, such puppies are no longer necessarily cheap, either. Sellers of illegally imported pets might ask for the usual – or even a higher – price for the breed in question.

Number of imported pets is on the rise

The number of imported pets has risen substantially in the last ten years. The largest numbers of pets imported to Finland are from Russia, Spain, Estonia, Romania, Lithuania, France, Hungary and Serbia.

In recent decades, Estonia has been one of the major channels for pet imports to Finland. Dogs born in Estonia and the rest of the EU are imported to Finland through Estonia – but so, too, are dogs born in Russia, Ukraine or other third countries that have been illegally imported into Estonia. The pet business goes where the markets are.

Illegal importers of pets care about profits – not the welfare of the animals

The purpose of illegal pet imports is to seek monetary gains. The importer can save on costs by raising the pets at the lowest possible cost, often in puppy mills set up solely for this purpose. The importer also saves on costs by not administering the required rabies shots and medication, forging import documentation and bypassing veterinary inspections at the border (border control fees) for pets from third countries. The supervisory authorities are frequently given forged documents that are intended to demonstrate that the pet fulfils import requirements or that the pet was actually born in the EU.

Smugglers increasingly often copy their methods from organised crime. Typically, smugglers employ intermediaries: for instance, an Estonian operates a puppy mill in Estonia, another party transports the pets to the target country, and a third sells the pets in the target country. These operators usually break legislative requirements at every stage of the chain. In addition, puppy smugglers change their area of operations and methods quickly if the supervisory authorities get on their trail. Illegally imported pets are for the most part sold via cash transactions, which makes it more difficult to identify the seller as well as assess and trace the monetary gains from puppy sales. In online marketplaces, pet sellers often use a fake identity or give only their first or last name, prepaid phone numbers and other contact information that changes from one ad to another.

Illegal pet imports can yield substantial monetary gains. In the cases that have come to the attention of the supervisory authorities, the number of puppies imported by individual importers may be as high as 500 – 1,000 per year. If the average selling price of a puppy in Finland is EUR 350, this generates taxable annual income of EUR 175,000–350,000 for the seller. The monetary gains obtained from pet sales are well illustrated by the verdict of the Helsinki District Court in a pet smuggling case on 10 May 2019 (R 18/2256, not in legal force). In this case, the Estonian perpetrator was sentenced to forfeit a total of EUR 94,000 in criminal proceeds from pet smuggling to the state. This smuggler had imported a total of 500 pets in the period from 2014 – 2016.

The risk of being caught is often relatively small compared to the value of the imported pets. The seizure and potential loss of one imported lot is not a sufficient sanction to deter a puppy smuggler. According to some estimates, pet smuggling and sales have become the third largest business in organised crime, after weapon and drug smuggling.

Illegal pet imports cause costs for society

Illegal pet imports result in growing costs for society each year. A bite from an illegally imported pet is one of the most common reasons for starting rabies prophylaxis treatment in humans. This treatment is generally started in cases where a person is bitten by a pet from an area where rabies occurs, as once the symptoms manifest, rabies always leads to death in humans and there is no treatment.

Rabies prophylaxis medication costs about EUR 2,100 per patient. In 2018, prophylaxis treatment was administered to 46 people due to suspected rabies in the Helsinki and Uusimaa Hospital District alone. The costs of rabies prophylaxis treatment thus amounted to almost EUR 100,000 in the Helsinki and Uusimaa Hospital District.

Co-operation between the authorities plays a key role in monitoring the illegal pet trade

Commercial imports of pets from outside the EU are monitored by the Finnish Food Authority and non-commercial movement from non-EU countries are monitored by Customs. In Finland, pet imports and movement from within the EU internal market are monitored by the Regional State Administrative Agencies. The supervisory authorities organise “pet raids” in harbours and airports every year. In addition, the Finnish Food Authority and Customs monitor movements of pets from third countries as part of their ordinary monitoring operations at border control points/airports/harbours and other border crossing points. However, as illegal pet imports involve considerable criminal activity, greater co-operation and information exchange between the authorities and member states is required. Co-operation in Finland has been intensified between the supervisory authorities, Tax Administration, Police and prosecutors.

Consumers can influence pet smuggling with their choices

Consumers and individual puppy buyers have the greatest influence on reducing puppy mill activity and illegal pet imports. A consumer’s best means of promoting responsible pet sales is to buy their pet from a reputable and reliable breeder – information is available on the Internet sites of breed associations, for instance. Bying a pet should always be a well thought through decision. There are often waiting lists for purchasing a puppy of a popular breed. The buyer should visit the breeder of a puppy that is being sold as Finnish to have a look at the puppy at least twice before the adoption age and also see the mother nursing the puppies. A good breeder – whether s/he raises pure or mixed breeds – also wants to ensure that the puppy will be a good fit for its new home and family circumstances. The authorities recommend making the payment for a puppy to a bank account. If the seller says that the pet was imported from the EU, the buyer must demand to inspect a TRACES certificate as well as check the pet passport for information on the pet and the vaccines it has been given. A pet imported for sale from outside the EU should at least have a Common Health Entry Document (CHED) as proof of veterinary border control. More information on import requirements is available on the Internet site of the Finnish Food Authority [.fi]›.

When making a purchase decision, the consumer should keep in mind that a cheap puppy might turn out to be anything but cheap. In the case dealt with by the Helsinki District Court mentioned above, the buyer of an illegally imported puppy incurred a total of EUR 4,060 in costs from the purchase of the puppy, vet visits, intensive care and cremation. The purchase price was EUR 350. The puppy lived for less than two weeks after handover.