Bringing any dog into US gets more complex on Aug. 1

Veterinarians scramble to understand what's needed under new rabies prevention rule

Published: June 19, 2024

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Photo by Dr. Danelle Capobianco
Boone, an 8-year-old bluetick coonhound who lives in Buffalo, New York, has a nice view of the Niagara Falls International Rainbow Bridge, which connects the United States and Canada. After Aug. 1, a new rule for entry into the U.S. will make crossing the border more complicated for Boone and other dogs.

In the middle of the busy summer travel season, public health authorities in the United States will institute a strict new rule to reduce the risk of rabies entering the country with dogs from any international location.

The rule, from the U.S. Centers for Disease Control and Prevention, is scheduled to take effect Aug. 1. It applies to all dogs, whether domestic pets heading home from a short jaunt with their families to Canada or Mexico; dogs competing internationally in shows or sports; or dogs being purchased from a breeder or put up for adoption by a rescue organization operating abroad.

The multifaceted regulation is complicated, but the gist for dogs vaccinated in the U.S. is that their rabies shot must have been given by a veterinarian who is accredited by the U.S. Department of Agriculture or a doctor in the same practice as an accredited veterinarian. At least 28 days must pass after vaccination before a rabies certificate can be issued by an accredited veterinarian. Then, the certificate must be separately endorsed by the USDA at a cost of $38 per dog.

For dogs vaccinated outside of the U.S., their paperwork must be endorsed by an "official veterinarian" in their home country. Asked who official veterinarians are, a CDC spokesperson told the VIN News Service that the designation is for each country to determine.

Significantly, no dog under 6 months of age will be allowed to travel into the country at all. Although puppies can be fully vaccinated against rabies at 4 months, the agency says the 6-month threshold makes it "easier to estimate the age of dogs based on examination of their teeth, enabling CDC to better identify falsified and fraudulent documentation," among other reasons.

To ensure that the paperwork applies to the right animal, the rule requires that entering dogs be implanted with a particular type of identifying microchip, and the chip must be in place before the dog's most recent rabies vaccination. The chip must be compliant with the International Organization for Standardization (ISO), indicated by a 15-digit number and operating at a frequency of 134.2 kHz. The chip number must be recorded on an entering dog's papers. If a dog has a microchip that's not ISO-compliant, it will need a second chip that is.

For USDA-accredited veterinarians only, the CDC is offering a one-hour webinar on June 27 at 5 pm Eastern time on the new regulations, according to agency spokesperson David Daigle. A notice from the USDA to veterinarians about the session states that if the limited space fills up, "CDC will offer additional trainings throughout the summer as needed."

In brief

The purpose of the exacting requirements is to crack down on fake documentation of vaccinations against rabies, a virus that is deadly to all mammals. The CDC reports a sharp increase in 2020 of foreign-vaccinated dogs coming from countries with a high risk of canine rabies virus being found with false documents. The jump was 52% — 450 dogs versus 300 in each of the previous two years. For context, the total number of foreign-vaccinated dogs arriving from high-risk countries was 32,530.

The U.S. was declared free of the dog-maintained rabies virus variant (DMRVV) in 2007, but since then, the pathogen has surfaced in the country in several cases involving imported dogs.

A recent incident involved one dog in a group of 26 that was imported from Egypt in 2019 by a rescue organization in Kansas, according to an official account. The animals were flown to Toronto and entered the U.S. through Port Huron, Michigan. About three weeks later, while in foster care, the dog developed signs of rabies. It was euthanized shortly after, but not before it bit a veterinary technician.

That incident was the third rabies case in four years in a dog from Egypt, according to the account published in the CDC's Morbidity and Mortality Weekly Report. Egypt is one of about 110 countries deemed at high risk for canine rabies.

Mild 'panic' and confusion over how to comply

Owing to concerns about imported rabies, the American Veterinary Medical Association supports the new rule. AVMA president Dr. Rena Carlson says in a news post that the organization "is pleased to see the implementation of this new rule that will help protect public health and positively impact canine health and welfare."

Dr. J. Scott Weese, an infectious diseases veterinarian at the University of Guelph's Ontario Veterinary College, expects the rule to be effective in some respects but less so in others, with a potential even for negative repercussions.

In countries at low risk for rabies, Weese said, the rule will do more to curb trafficking of puppy-mill dogs than rabies. "The main rabies benefit will be making it harder to quickly move dogs imported from a high-risk country to a low-risk country, and then [to] the U.S.," he said by email. "There's some benefit of that but a lot of collateral damage."

Explaining the anticipated collateral damage, Weese said, "Beyond the hassle and cost issues, we have significant animal health concerns for border communities where it is common that the closest vet clinic, emergency clinic or specialist is across the border." He pointed out that the rule will make it challenging for dog owners to obtain cross-border care and preclude it for dogs younger than 6 months.

Many veterinarians, while supporting the rule's goal, similarly question the complicated, broad-brush approach as they scramble to figure out what they need to do to help clients be compliant — and to be compliant themselves.

Dr. Jeanne Fournier, a veterinarian with a practice about 20 miles from Canada, in Lockport, New York, crosses the border frequently with her dogs for sporting events and casual outings. Fournier said she was "in a small state of panic" when she learned about the rule.

"It's freaking insane," she said. "Nobody who has to be involved with this had any idea this was coming."

Scouting for information, Fournier posted last month to a message board of the Veterinary Information Network, an online community for the profession and parent of VIN News. Scores of veterinarians in Canada and the U.S. joined the conversation, expressing confusion and misgivings.

Dr. Rebecca Lemmon, a practitioner in Colorado, posted: "We have lots of clients that travel to Mexico frequently, and to say that everyone is freaking out is putting it lightly. I have been poring through the new requirements, which are clear as mud, and my head is spinning."

Dr. Danelle Capobianco, a practitioner who lives in Buffalo, New York, within walking distance of Canada, said she frequently sees dogs in cars queued for the crossing.

"If this [rule] goes into effect as it is written (and it is enforced) that will change. ..." she predicted. "[F]or many people who live in one country/work in another, have their primary vet on the other side of the border, summer houses that they go to on weekends, or participate in dog sports, it's going to be a mess."

USDA accreditation details and questions

Fournier was prompted by the pending rule to renew her USDA accreditation, which she had let lapse because she found writing international health certificates to be a nuisance. She said she was able to reinstate the credential in a matter of days.

Now she is struggling to understand exactly what she needs to do to issue rabies certificates for dogs that were vaccinated by other veterinarians. 

The CDC's technical instructions state: "In the event the USDA-accredited veterinarian that vaccinated the dog is unavailable or if the veterinarian is not a USDA-accredited veterinarian, a USDA-accredited veterinarian may certify the form if: (1) A valid, in-person, veterinary-client-patient relationship (VCPR) as defined by the American Veterinary Medical Association exists with at least one veterinarian currently in the practice in which the USDA-accredited veterinarian practices medicine; and (2) The dog's information (breed, sex, age, microchip) and vaccination history can be verified using the practice's existing medical records."

Fournier said she can establish a VCPR by examining a dog in person and can obtain its medical records directly from the practice where it was vaccinated, thereby incorporating them into her practice's records. That being the case, could she certify the dog's vaccination without having to revaccinate the dog?

VIN News asked Daigle at the CDC but was unable to elicit a clear answer. He did say that if an unaccredited veterinarian were to vaccinate a dog and become accredited afterward, the earlier shot would not be valid for entry. The veterinarian administering the shot, he said by email, "must be accredited at the time of the vaccination."

There is no charge for obtaining accreditation, but it takes time. The National Veterinary Accreditation Program website says that candidates must complete 14 online training modules and pass quizzes on each, then attend an orientation. An official with the program estimated it could take three to six weeks or longer to complete the process and noted that USDA state offices vary in how they provide the orientation — some doing it in person on specified dates, others online.

According to the agency, about 70,000 veterinarians in the country are accredited. At least 97,000 veterinarians were in the U.S. workforce in 2023, including veterinarians not in clinical practice, AVMA statistics show. That indicates a solid majority of veterinarians have the necessary credentials to complete rabies certificates acceptable for entering the country.

The USDA maintains a searchable database of accredited veterinarians, although several veterinarians in the VIN discussion said they're accredited but not listed. The agency did not reply to a question about the database's accuracy.

Working through the logistics

How frequently do traveling dogs enter the U.S. in a given period? No one counts. In fact, although travelers currently must carry proof of an up-to-date rabies vaccination in order to cross the border to and from Canada with their dogs, the paperwork isn't necessarily checked.

With the new rule, the CDC will know how many dogs accompany human travelers.

Requirements for entry are heaviest for dogs coming from countries categorized as high risk for canine rabies, but there are still hurdles to jump for those coming from countries deemed at low risk — including Canada and Mexico — and that were vaccinated outside the U.S.

In one respect, the process is easier than for U.S. dogs. Foreign dogs from low-risk countries need either a Certification of DMRVV-Free or Low-Risk Country form or a Certification of Foreign Rabies Vaccination and Microchip form, which can be completed by any licensed veterinarian. The form must then be endorsed by an official veterinarian of the country.

Asked who constitutes an official government veterinarian, CDC spokesperson Daigle said: "CDC does not maintain a list of official government veterinarians for countries outside the U.S. Please work with a local veterinarian in the country of export to identify the location of an official government veterinarian."

In addition to a certificate, foreign dogs from low-risk countries must have documentation of valid rabies serology (a blood test demonstrating the animal is immunized against rabies) or veterinary records indicating the animal has been in the low-risk country for the past six months.

What constitutes acceptable veterinary records? VIN News asked Daigle, offering two possibilities as examples: having a record of an annual veterinary exam nine months before entry? Or having records of exams one month and 13 months before entry?

Daigle replied, "Yes, both of these examples would be sufficient for entry," adding that the records should show the name of the veterinarian, name of the veterinary clinic, clinic address, phone number, date of care and dog's microchip number.

Apparently recognizing the complexity of the rules, the CDC provides three different travel checklists for dogs — one for U.S.-vaccinated dogs, one for dogs that have been only in low-risk or rabies-free countries for the past six months, and one for dogs from high-risk countries with a foreign vaccination.

In all instances, the agency recommends taking the first step on the checklist at least 60 days before travel. Meanwhile, the agency has not posted everything needed to comply. A CDC Dog Import Form that must be submitted for all traveling dogs will not be available until July 15 — two weeks before the rule takes effect.

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