CRS INSIGHT Prepared for Members and Committees of Congress

INSIGHTi

CDC’s Updated Dog Importation Rule

January 15, 2025

On August 1, 2024, the Department of Health and Human Services (HHS) Centers for Disease Control and Prevention’s (CDC’s) final rule on the import of dogs into the United States (42 C.F.R. §§71.50-51) went into effect. These revised regulations are meant to bolster prevention of the introduction of dog- maintained rabies virus variant (DMRVV) into the United States. The updated rule revises the requirements for all dogs arriving in the United States, as well as specific requirements that vary based on where a dog has traveled and received its rabies vaccine. Regulations aimed at controlling rabies from imported dogs have existed since at least 1956.

In 2007, CDC declared that the United States had eliminated DMRVV, meaning there was no ongoing virus circulation in the country. DMRVV circulates in some other countries and causes 99% of human rabies cases globally. Rabies is usually fatal to humans unless immediate care is provided through post- exposure prophylaxis (PEP). According to CDC, the importation of a single infected dog could reintroduce the virus into the country and may pose “a significant public health risk,” potentially leading to “the loss of human and animal life and consequential economic impact.”

The revised rule follows CDC’s temporary suspension of dog importation from high rabies-risk countries starting in June 2021, when U.S. rabies control resources were diverted for COVID-19 pandemic response. This suspension also introduced standardized forms and testing requirements. Before the suspension, CDC had observed a rise in imported dogs with falsified rabies vaccination documentation, including a 52% increase in 2020 and a 21% increase in early 2021. Following the suspension, CDC documented fewer instances of fraudulent rabies vaccination documentation and fewer sick and dead dogs arriving in the country. The updated rule adopts a similar framework as implemented during the suspension, expanding it to include dogs from DMRVV-free and low-risk countries.

Overview of the Revised Rule

CDC’s updated requirements revise rules in place since 1985 (42 C.F.R. Part 71) and are based in Public Health Service Act (PHSA) statutory authorities that allow CDC, by delegation from the HHS Secretary, to make and enforce regulations to prevent the introduction of communicable diseases into the United States.

Congressional Research Service

https://crsreports.congress.gov

IN12485

Congressional Research Service 2

Table 1 compares the previous and updated CDC rules for importing dogs into the United States, highlighting requirements such as documentation, microchipping, rabies vaccination, designated airport arrivals, and veterinary oversight.

Table 1. Comparison of Previous and Updated CDC Rules on Dog Entry Requirements

PREVIOUS RULE UPDATED RULE

• Must have a rabies vaccination certificate (form was not standardized), with some exemptions

• Must appear healthy on arrival

• Some requirements for at least 30 days of confinement for recently vaccinated dogs, certain dogs under six months of age, or dogs that appear sick

• Six-month age requirement for commercial imports and adoption per regulations of the Animal Welfare Act

• Must have completed CDC Dog Import form

• Must appear healthy on arrival

• Must be at least six months of age

• Must have International Organization for Standardization (ISO)-compatible microchip implanted on or before the date the most recent rabies vaccine was administered

• Airline must confirm documents and other requirements

• Airline creates air waybill for tracking dog

Dogs vaccinated in the United States

• Must have obtained certification from a USDA- accredited veterinarian prior to travelling

Dogs vaccinated in a foreign country

• Vaccination and microchip form must be endorsed by a government official in the exporting country

• Must have valid rabies serology titer results from a CDC-approved laboratory or be quarantined on arrival for up to 28 days

• Must arrive at a U.S. airport with a CDC quarantine station and a CDC-registered Animal Care Facility (limited exemptions for service animals)

• Must undergo veterinary examination and revaccination on arrival

Source: CRS analysis of 42 C.F.R. §§71.50-51, 89 Federal Register 41726, and cdc.gov web pages. Notes: Per 42 C.F.R. §71.51(a), high rabies-risk country means “a country determined by the Director as having high risk for DMRVV transmission based on factors such as the presence and geographic distribution of the virus, or low quality of or low confidence in rabies surveillance systems or dog vaccination programs.” See CDC’s website for a list of DMRVV high- risk countries.

Enforcement

If denied admission based on the factors described in Table 1, a dog may be required to return to the country of departure. Importers who violate the final rule—including violations based on fraudulent documentation—may be further subject to PHSA’s existing penalties, including fines and imprisonment. CDC may also request that U.S. Customs and Border Protection take enforcement actions against violators such as through fines, citations, or penalties.

Congressional Research Service 3

IN12485 · VERSION 1 · NEW

Relationship with Other Requirements

The updated CDC rule intersects with Animal Welfare Act (AWA) regulations enforced by the U.S. Department of Agriculture’s (USDA’s) Animal and Plant Health Inspection Service (APHIS). While CDC focuses on human public health by requiring measures such as rabies vaccination, microchip implantation, and quarantine procedures, APHIS regulations under AWA address the welfare of dogs imported for commercial sale or adoption. These new CDC requirements, such as the six-month age minimum prior to importation, align with AWA’s standards for animal care. APHIS imposes extra requirements for travelers with pet dogs if they are arriving from countries affected by foot and mouth disease or New World screwworm.

Policy Discussion

CDC’s cost-benefit analysis highlighted several benefits of rabies control. For example, CDC estimated that a single imported rabid dog could result in average costs of $270,000 for disease control efforts, such as investigations and PEP. CDC also estimated the associated costs of compliance, noting that importers are expected to bear 87% of these expenses. Some Members of Congress have expressed concern about the burden of regulatory compliance for certain groups, including residents in border communities and those engaged in recreational activities involving dogs. In July 2024, CDC “clarified and simplified” certain requirements for dogs that have spent the prior six months in dog rabies-free or low-risk countries, reducing required documentation to the CDC Import Form only, valid for six months and multiple reentries. Congress may continue to monitor the rule’s implementation and determine its potential public health benefits and associated burdens.

Author Information

Eleni G. Bickell Analyst in Agricultural Policy

^{Kavya Sekar}

Analyst in Health Policy

Disclaimer

This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan shared staff to congressional committees and Members of Congress. It operates solely at the behest of and under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other than public understanding of information that has been provided by CRS to Members of Congress in connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in its entirety without permission from CRS. However, as a CRS Report may include copyrighted images or material from a third party, you may need to obtain the permission of the copyright holder if you wish to copy or otherwise use copyrighted material.