Dear Members of the European Parliament, 

We, the undersigned, firmly urge you to support the mandatory identification and registration (I&R) of all dogs and cats in the EU. A measure the European Parliament has repeatedly asked for through many Resolutions. Still, the proposal for a “Regulation on the welfare of dogs and cats and their traceability”, now sitting with AGRI and ENVI, only suggests a limited level of I&R, failing to remedy the problem. This was somewhat improved by the Council, whose mandate requires I&R for any dog or cat sold or given away. Several Member States pushed for I&R in the text, as a horizontal rule for all dogs and cats. Because animal microchipping, and the registration of the chip's number in a database to those responsible for the animal is a simple, low-cost, established measure. For dogs it is mandatory in 24 Member States. For cats - whose trade is booming - in 8. Despite efforts, the response was that it was legally impossible. Yet, the Commission’s written answer to Priority question P-000282/2025 now confirms that horizontal I&R is possible under Article 114 TFEU, that is, with Article 43(2) TFEU, legal basis to the proposal[i].

We strongly believe I&R must apply to all dogs and cats: if ‘private pets’ (those allegedly not sold or given away) remain uncovered, illegal breeders will keep acting as private people and sell animals that are not traceable to them, just as they do now.

Such illegal trade happens both domestically, within countries, as well as cross-border, through the exploitation of loopholes in EU law. Under EU law, private people can cross borders with their pet dogs or cats if these are chipped (without a registration obligation) and have a Passport. Whereas when dogs or cats cross borders for trade, additional rules apply: they must come from registered breeding and selling places, undergo a prior clinical and identity check, hold a health certificate issued by an official vet, and have their movement pre-notified and approved via the Commission’s TRACES system. These make breeders and traders identifiable, accountable. Yet, in absence of an EU rule for dogs and cats to be registered to their owner, rogue traders can, at a control, claim the animals they move are their private pets. This way they bypass said rules, effectively smuggling pets across borders, while control authorities cannot check, through a registered chip, if the animals are really linked to them. An unregistered animal means the breeder/seller cannot be found. All this is at the expense of animal health and welfare, responsible breeders, consumers, disease traceability, and public finance.

It is known that illegal trade involves breeders acting as small-scale ones or as private people, whilst operating on a scale. The Commission is aware of this. In 2018 its “Coordinated Control Plan on the online sales of cats and dogs’’ reported “Inconsistency between activities and trader’s status (..) i.e. private owner selling more than ten dogs/cats per year’’[ii]. In 2023 its “EU Enforcement Action on the Illegal Trade of Cats & Dogs” found that the problem of movements for trade masked as private ones “(…) despite measures taken, it persists. This practice is not only used as part of an organised network of activities, but is also common among smaller breeders to avoid health requirements, registration in TRACES and skipping the need to provide traceability information (…) enabling individuals to earn untaxed income by not declaring goods for commercial purposes’’[iii]. And that “(…) it is essential that enforcement authorities operate within a streamlined and predictable regulatory framework, equipped with the necessary means, including technological, that would provide for cross-border access to reliable traceability information on individual animals, allowing them to perform their duties as efficiently as possible.”[iv].

Today 79% (4.75 million dogs, worth over €3.6 billion) of all dogs put in the market annually comes from unknown sources. If I&R only applies to ‘openly’ traded animals, this will perpetuate the problem. For it is unrealistic to expect illegal breeders and sellers to comply with a law that leaves such a loophole, with a rule only binding traders but not private people. Unless I&R becomes the norm, making all dogs and cats traceable, it will be business as usual for them.

The law must encompass all dogs and cats, as there is someone behind every traded, lost, or abandoned animal. I&R, wherein the involvement of veterinarians is crucial, establishes this link, reliably, holding owners accountable. This is critical for animal health and welfare, as well as disease control and public finances, as the cost of caring for stray animals-particularly cats-places a significant burden on municipalities.

Thank you for your attention and consideration of our suggestion. We much hope to your support.

Sincerely,

The undersigned signatories

[i] Answer given by Mr Várhelyi on behalf of the European Commission, 13.03.2025, to Parliamentary question - P-000282/2025(ASW) Parliamentary question | Answer for question P-000282/25 | P-000282/2025(ASW) | European Parliament

[ii] European Commission, Directorate-General for Health and Food Safety, The EU coordinated control plan for the official controls on online sales of dogs and cats: Analysis of the results (2019) https://food.ec.europa.eu/system/files/2019-09/aw_other_euccp_dogs-cats-analysis.pdf page 2

[iii] European Commission, Directorate-General for Health and Food Safety, EU enforcement action on the Illegal trade of cats & dogs (2023) https://food.ec.europa.eu/document/download/1c729e23-42b8-4c8c-bb8d-89992f9fb577_en? filename=agri-fraud_report_Illegal-trade_cats-dogs.pdf page 14[iv] Ibid page 21

[iv] Ibid page 21