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CDC Dog Import Final Rules Effective Aug 1, 2024

The Centers for Disease Control and Prevention (CDC) is implementing a final rule to enhance regulations on the importation of dogs and cats to mitigate the public health risks associated with dog-maintained rabies virus variant (DMRVV). Effective August 1, 2024, the rule mandates microchipping, proof of rabies vaccination, and submission of a CDC Dog Import Form for all imported dogs, while cats will not require proof of vaccination. This regulatory change aims to prevent the reintroduction of rabies into the U.S. and address issues of fraudulent vaccination documentation.

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0% found this document useful (0 votes)
7 views311 pages

CDC Dog Import Final Rules Effective Aug 1, 2024

The Centers for Disease Control and Prevention (CDC) is implementing a final rule to enhance regulations on the importation of dogs and cats to mitigate the public health risks associated with dog-maintained rabies virus variant (DMRVV). Effective August 1, 2024, the rule mandates microchipping, proof of rabies vaccination, and submission of a CDC Dog Import Form for all imported dogs, while cats will not require proof of vaccination. This regulatory change aims to prevent the reintroduction of rabies into the U.S. and address issues of fraudulent vaccination documentation.

Uploaded by

Ambuj Srivastava
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
You are on page 1/ 311

This document is scheduled to be published in the

Federal Register on 05/13/2024 and available online at


https://federalregister.gov/d/2024-09676, and on https://govinfo.gov

Billing Code: 4163-18-P

DEPARTMENT OF HEALTH AND HUMAN SERVICES

42 CFR Part 71

[CDC Docket No. CDC-2023-0051]

RIN 0920-AA82

Control of Communicable Diseases; Foreign Quarantine: Importation of Dogs and Cats

AGENCY: Centers for Disease Control and Prevention (CDC), Department of Health and

Human Services (HHS).

ACTION: Final rule.

SUMMARY: The Centers for Disease Control and Prevention (CDC), in the Department of

Health and Human Services (HHS), issues this final rule to provide clarity and safeguards that

address the public health risk of dog-maintained rabies virus variant (DMRVV) associated with

the importation of dogs into the United States. This final rule addresses the importation of cats as

part of overall changes to the regulations affecting both dogs and cats, but the final rule does not

require that imported cats be accompanied by proof of rabies vaccination and does not

substantively change how cats are imported into the United States.

DATES: This final rule is effective August 1, 2024.

FOR FURTHER INFORMATION CONTACT: Ashley C. Altenburger, J.D., Division of

Global Migration Health, Centers for Disease Control and Prevention, 1600 Clifton Road, NE,

MS H16-4, Atlanta, GA 30329. Telephone: 1-800-232-4636. For information regarding CDC

operations and importations: Dr. Emily Pieracci, D.V.M., Division of Global Migration Health,

Centers for Disease Control and Prevention, 1600 Clifton Road, NE, MS H16-4, Atlanta, GA

30329; Telephone: 1-800-232-4636.


SUPPLEMENTARY INFORMATION: This rule is organized as follows:

I. Executive Summary

a. Purpose of this Regulatory Action

b. Summary of Major Provisions

c. Costs and Benefits

II. Public Participation

III. Background

a. Legal Authority

b. Regulatory History

IV. Summary of the Final Rule

V. Alternatives Considered

VI. Summary of Public Comment and Responses

VII. Required Regulatory Analyses

a. Executive Orders 12866, 13563, and 14094

b. The Regulatory Flexibility Act

c. The Paperwork Reduction Act

d. National Environmental Policy Act (NEPA)

e. Executive Order 12988: Civil Justice Reform

f. Executive Order 13132: Federalism

g. The Plain Language Act of 2010

I. Executive Summary

A. Purpose of this Regulatory Action

Through this final rule, HHS/CDC is revising its regulation at 42 CFR 71.51 to prevent

the reintroduction and spread of dog-maintained rabies virus variant (DMRVV) in the United

States. HHS/CDC is also revising 42 CFR 71.50, which contains definitions applicable to animal
importations under 42 CFR part 71, subpart F. The United States was declared DMRVV-free in

2007.1 The importation of just one dog infected with DMRVV risks re-introduction of the virus

into the United States; such a public health threat could result in the loss of human and animal

life and consequential economic impact.2, 3, 4 The rabies virus can infect any mammal, and, once

clinical signs appear, the disease is almost always fatal.5 A DMRVV-infected dog can transmit

the virus to humans, domestic pets, livestock, or wildlife. Importing inadequately vaccinated

dogs from countries at high risk of DMRVV (high-risk countries)6 involves a significant public

health risk to people who directly interact with those dogs. This rule also includes requirements

for dogs from DMRVV-free and low-risk countries to confirm that the dog has not been in a

high-risk country during the six months before arriving in the United States. In 2019, the

importation of a DMRVV-infected dog cost the affected State governments more than $400,000

U.S. dollars (USD) for the ensuing public health investigations and rabies post-exposure

prophylaxis (PEP) treatments administered to exposed persons.7, 8

Through this final rule, HHS/CDC also seeks to prevent and deter the importation of dogs

with falsified or fraudulent rabies vaccine documentation. In 2020, CDC observed a 52 percent

increase in the number of dogs that were ineligible for admission due to falsified or fraudulent

documentation, as compared to 2018 and 2019 (450 dogs compared to the previous baseline of

300 dogs per year out of an estimated 32,530 foreign-vaccinated dogs arriving annually from

1 Centers for Disease Control and Prevention. US Declared Canine-Rabies Free.


https://www.cdc.gov/media/pressrel/2007/r070907.htm. Accessed June 1, 2023.
2 World Bank (2012). People, Pathogens and Our Planet: The Economics of One Health. Retrieved from

https://openknowledge.worldbank.org/handle/10986/11892. Accessed December 19, 2023.


3 Raybern, C et al. Rabies in a dog imported from Egypt-Kansas, 2019. MMWR Morb Mort Wkly Rep 2020; 69 (38):

1374-1377.
4 Jeon S, Cleaton J, Meltzer M, et al. Determining the post-elimination level of vaccination needed to prevent re-

establishment of dog rabies. PLoS Neg Trop Dis 2019; 13 (12): e0007869.
5 Fooks AR, Banyard AC, Horton DL, Johnson N, McElhinney LM, Jackson AC. Current status of rabies and

prospects for elimination. Lancet 2014;384:1389–99.


6 A complete list of countries with high risk of DMRVV is available at “High-Risk Countries for Dog Rabies.”

https://www.cdc.gov/importation/bringing-an-animal-into-the-united-states/high-risk.html. Accessed June 8, 2023.


7 Raybern, C et al. Rabies in a dog imported from Egypt-Kansas, 2019. MMWR Morb Mort Wkly Rep 2020; 69 (38):

1374-1377.
8 Centers for Disease Control and Prevention (2022). Rabies Postexposure Prophylaxis. Retrieved from

https://www.cdc.gov/rabies/medical_care/index.html.
DMRVV high-risk countries as reported in Section VIIA).9,10 This troubling trend continued

from January through June 2021, prior to the implementation of the temporary suspension in July

2021,11 with an additional 24 percent increase of dogs ineligible for admission in just the first

half of the year, compared to the full 2020 calendar year (January-December) (approximately

560 dogs with falsified or fraudulent documentation).12 This final rule will also support CDC’s

efforts to improve data collection related to dog importation, including tracking the total number

of dog importations which CDC has been unable to do previously across all ports and for all

importations.

The use of a single false rabies vaccination certificate (RVC)13 or other rabies vaccination

document as part of a larger shipment of multiple dogs raises suspicion that the rabies

vaccination documents for the remaining dogs may also be false. This is not an uncommon

occurrence14 and creates an additional burden on CDC and State health departments to track, test,

and evaluate the remaining dogs in the shipment.

CDC has documented numerous importations every year in which flight parents15,16

transport dogs for the purpose of resale, adoption, or transfer of ownership that do not meet

CDC’s entry requirements. These flight parents often claim the dogs are their personal pets to

9 Centers for Disease Control and Prevention. Quarantine Activity Reporting System (version 4.9.8.8.2.2A). Dog
importation data, 2018-2020. Accessed: 15 February 2021.
10 Pieracci EG, Wallace R, Maskery B, Brouillette C, Brown C, Joo H. Dogs on the move: Estimating the risk of

rabies in imported dogs in the United States, 2015-2022. Zoonoses and Public Health 2024; 00:1-9 DOI:
10.1111/zph.13122.
11 Temporary Suspension of Dogs Entering the United States from High-Risk Rabies Countries. Federal Register,

86 FR 32041 (June 16, 2021).


12 Centers for Disease Control and Prevention. Port Health Activity Reporting System (version 4.9.8.8.2.2A). Dog

importation data, January 1, 2021- July 14, 2021. Accessed: 01 October 2021.
13 Centers for Disease Control and Prevention. What is a valid rabies vaccination certificate? Available at:

www.cdc.gov/importation/bringing-an-animal-into-the-united-states/vaccine-certificate.html.
14 Centers for Disease Control and Prevention. Port Health Activity Reporting System (version 4.9.8.8.2.2A). Dog

importation data, 2018-2021. Accessed: 26 March 2024.


15 “Flight parent” means any person transporting one or more animals on behalf of an importer for purposes of

resale, adoption, or to transfer ownership. A flight parent is typically solicited through social media and may be
compensated (including through goods and services, e.g., complimentary airplane ticket, paid baggage fees, other
paid fees) or be uncompensated. Flight parents must possess all required Federal licenses or registrations to transport
animals.
16 Centers for Disease Control and Prevention. Port Health Activity Reporting System (version 4.9.8.8.2.2A). Dog

importation data, 2018-2021. Accessed: 15 April 2024.


avoid U.S. Department of Agriculture (USDA) Animal Care17 entry requirements and potential

tariffs or fees under CBP regulations. Even when well-meaning, these importers jeopardize

public health, as many of them do not know the history of the animals they are transporting.

Deterring individuals who serve as flight parents from supporting fraudulent dog importations

has proven difficult despite the existence of CBP penalties relating to aiding unlawful

importations and fraudulent conduct. See 19 U.S.C. 1592 and 19 U.S.C. 1595a.

The documented increase in fraudulent vaccine documentation and importers

circumventing dog import regulations was shortly followed by the emergence of the coronavirus

disease 2019 (COVID-19) pandemic. Many public health resources were redirected to the

COVID-19 response, reducing the availability of resources to respond to dog importation issues.

In light of this confluence of events, in June 2021, CDC published a temporary suspension of

dogs entering the United States from DMRVV high-risk countries.18 The temporary suspension

created a system that, among other things, implemented the use of standardized forms, required

test results demonstrating the presence of rabies antibodies in dogs, and developed a network of

animal care facilities authorized by CDC for the purpose of allowing for the immediate

quarantine of dogs from DMRVV high-risk countries arriving with inadequate proof of test

results. During the temporary suspension, CDC has documented decreased instances of fraud,

fewer dogs being denied admission into the country, and fewer sick and dead dogs arriving in the

United States from both DMRVV high-risk and DMRVV-free and low-risk countries, all of

which have resulted in fewer Federal and State agency resources devoted to addressing issues

related to inadequate rabies vaccination and/or documentation. This final rule implements a

similar regulatory framework, expanded to dogs from DMRVV-free and low-risk countries,

based on the documented successes of the temporary suspension.

17https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/usda-animal-care-overview.
18Temporary Suspension of Dogs Entering the United States from High-Risk Rabies Countries. Federal Register,
86 FR 32041 (June 16, 2021).
B. Summary of Major Provisions

In this final rule, HHS/CDC aligns U.S. import requirements for dogs with the importation

requirements of other DMRVV-free countries by requiring proof of rabies vaccination and

adequate serologic test results from a CDC-approved laboratory. The final rule requires for all

dog imports: a microchip, six-month minimum age requirement for admission, and importer

submission of a CDC import form (CDC Dog Import Form). The rule requires airlines to

confirm documentation, provide safe housing for animals, and assist public health officials in

determining cause of animal illness or death.

B.i. Requirements for all dogs

Per this final rule, HHS/CDC requires that all dogs arriving from any country, including

dogs returning to the United States after traveling abroad, be microchipped with an International

Standards Organization (ISO)-compatible microchip prior to travel into the United States. The

microchip information must be included on importation documents to help ensure that dogs

presented for admission are the same dogs as those listed on the rabies vaccination records or

other documents. CDC has documented several instances of importers attempting to present

records of vaccinated dogs as the vaccination records for dogs that lacked appropriate veterinary

paperwork in an attempt to import the unvaccinated dogs into the United States without

detection.19 Because microchips were not required for entry into the United States at that time

and the dogs in question were not microchipped, the public health investigations to confirm the

identity of those dogs were both resource-intensive and challenging. Microchips are used

frequently by pet owners and required for international transit by many foreign countries,

including for importation in many DMRVV-free countries. Microchips are also recommended by

the international veterinary community and animal rescue and welfare organizations to reunite

19Centers for Disease Control and Prevention. Port Health Activity Reporting System (version 4.9.8.8.2.2A). Dog
importation data, 2018-2020. Accessed: February 15, 2021.
lost animals with their owners and ensure that the veterinary records for an animal can be linked

to the animal.20 Further, during CDC’s temporary suspension of dogs entering the United States

from DMRVV high-risk countries, CDC documented that 99 percent (>20,000) of permit

applications received were for dogs that had microchips implanted prior to the announcement of

the suspension. Therefore, CDC’s requirement has minimal impact on dog importations,

although costs to some importers may still be incurred.

To address concerns about importations of puppies that are too young to be properly

vaccinated against rabies, through this final rule, HHS/CDC requires that any dog arriving in the

United States be at least six months of age. Dogs cannot be vaccinated effectively against rabies

before 12 weeks of age and are not considered fully vaccinated until 28 days after vaccination.21

Establishing a six-month minimum age requirement for the import of dogs aligns with current

USDA requirements for commercial dog imports under the Animal Welfare Act and will better

protect the public’s health from rabies.22

In this final rule, HHS/CDC also requires all dog importers to submit a CDC Dog Import

Form (i.e., an online form that includes the importers’ contact information and information

related to each dog being imported) via a CDC-approved system prior to travel to the United

States. This requirement would apply to all imported dogs (including dogs arriving from

DMRVV-free and DMRVV low-risk countries) arriving in the United States by air, land, or sea.

Upon arrival at a U.S. port, importers must present a receipt confirming they submitted a

completed CDC Dog Import Form; additionally, importers arriving by air must present the

receipt to the airline prior to boarding. The receipt contains the information submitted on the

CDC Dog Import Form, which allows government officials to verify that the details from the

20 American Veterinary Medical Association. Microchipping FAQ. https://www.avma.org/resources-tools/pet-


owners/petcare/microchips-reunite-pets-families/microchipping-faq. Accessed June 1, 2023.
21 National Association of State Public Health Veterinarians. Compendium of animal rabies prevention and control,

2016. JAVMA 2016; 248 (5):505-517.


22 7 U.S.C. 2148.
CDC Dog Import Form match the dog being presented for entry. CDC’s import submission

system is a free online system. Requiring documentation for all imported dogs allows CDC to

track the total number of dog importations (including the number imported from DMRVV high-

risk countries), something CDC has been unable to do previously.

To improve vaccination verification systems and deter fraud, CDC’s required forms (not

including the electronically submitted CDC Dog Import Form) need to be endorsed by official

government veterinarians in the country of export. Importers should contact their local

veterinarian who can submit the required form to an official government veterinarian in the

exporting country. Importers may also use the USDA pet travel website or IPATA website to

contact a pet shipper to request assistance.23,24

All dogs arriving by air are required to have an air waybill (AWB). An AWB is a legally

binding document issued by a carrier to a shipper or importer that details the type, quantity, and

destination of the goods (i.e., dogs) being carried. It serves as a tracking number that can assist

Federal agencies in monitoring the dog throughout the lifecycle of the dog’s travel from the

point of origin to the final destination. Additionally, a bill of lading serves as undisputed proof

of shipment, and it represents the agreed upon terms and conditions for the transportation of the

goods. All commercial airlines and many private cargo aircraft are capable of generating AWB.

Additionally, CDC has successfully piloted the generation of AWB for dogs transported as hand-

carried or excess baggage with several foreign air carriers during the temporary suspension to

ensure air carriers can generate AWB for dogs transported as hand-carried or excess baggage.

23 USDA Pet Travel. www.aphis.usda.gov/pet-travel/us-to-another-country-export.


24 International Pet and Animal Transportation Association. www.ipata.org.
B.ii. Requirements for dogs from DMRVV-free or DMRVV low-risk countries

This final rule further permits dogs imported from DMRVV-free or DMRVV low-risk

countries to arrive at any U.S. port.25 In lieu of a CDC vaccination form, which is required for

dogs imported from DMRVV high-risk countries, these importers may instead provide proof

(examples outlined in paragraph (u)) that the dogs have been in DMRVV-free or DMRVV low-

risk countries only during the six months prior to arriving in the United States.

TB.iii. Requirements for dogs from DMRVV high-risk countries

Per this final rule, HHS/CDC requires all importers of dogs that have been in a DMRVV

high-risk country within the last six months, regardless of whether foreign- or U.S.-vaccinated,

to submit a standardized vaccination form verifying the rabies vaccination status of the dog. This

final rule permits dogs that have been in a DMRVV high-risk country in the past six months and

have a valid U.S.-issued rabies vaccination form to arrive at any U.S. port. For dogs that have

been in a DMRVV high-risk country in the past six months, and were vaccinated in a foreign

country, this final rule requires that the dog arrive at a U.S. airport with a CDC quarantine station

(also known as a port health station) and a CDC-registered animal care facility (ACF).

HHS/CDC is removing the current requirement for a valid RVC in 42 CFR 71.51(c) and

replacing it with new rabies vaccination forms for dogs imported from DMRVV high-risk

countries. The rabies vaccination forms include the rabies vaccination status of the dog and other

required information similar to the previous valid RVC requirement. However, unlike the

previous requirement for a valid RVC, the rabies vaccination forms are standardized.

The rabies vaccination form for foreign-vaccinated dogs from DMRVV high-risk countries

must also be endorsed by a government official in the exporting country, as an added measure to

prevent falsification. The name for the rabies vaccination form to fulfill this requirement for

25U.S. Port means any seaport, airport, or border crossing point under the control of the United States. 42 CFR
71.1(b).
foreign-vaccinated dogs from DMRVV high-risk countries was shortened from CDC Import

Certification of Rabies Vaccination and Microchip Required for Live Dog Importations into the

United States as proposed in the notice of proposed rulemaking (NPRM) to Certification of

Foreign Rabies Vaccination and Microchip. The requirement for this standardized form helps

ensure that foreign-vaccinated dogs imported from DMRVV high-risk countries meet CDC entry

requirements prior to traveling to the United States and allows for follow-up with the exporting

country’s government officials if repeated import violations occur.

Under this final rule, importers of U.S.-vaccinated dogs, including dogs that have been in a

DMRVV high-risk country within the last six months, may arrive at any U.S. port. Prior to

traveling out of the United States with a U.S.-vaccinated dog that will be present in a DMRVV

high-risk country, the dog owner must obtain a form titled Certification of U.S.-issued Rabies

Vaccination that must be completed and signed by a USDA-Accredited Veterinarian. The name

for this rabies vaccination form was shortened from Certification of U.S.-issued Rabies

Vaccination for Live Dog Re-entry into the United States as proposed in the NPRM to

Certification of U.S.-issued Rabies Vaccination. CDC is partnering with USDA to utilize the

USDA export process to verify an animal was vaccinated in the United States. This form must

be endorsed by a USDA Official Veterinarian prior to the dog’s departing the United States and

must be presented by the importer to the airline to board the dog on its return flight to the United

States. The importer must also present this form when requested to do so by U.S. government

officials upon arrival. By having USDA-accredited veterinarians certify documents before export

from the United States, CDC can confirm the dogs were previously vaccinated in the United

States. The use of this form decreases the likelihood of missing or incomplete vaccination

documentation because it includes all required information in a standardized format and relies on

USDA’s existing veterinary accreditation system for animal exportation. This form will also

reduce instances of fraud or falsification because it can be verified by any U.S. government

agency online through USDA’s website after the USDA official veterinarian certifies the
document. Dogs from DMRVV high-risk countries arriving with this form are not subject to the

requirement for veterinary examination (unless ill, injured, or exposed), revaccination,

confirmation of adequate rabies serologic tests, and/or post-vaccination quarantine at a CDC-

registered ACF.

HHS/CDC is requiring importers of foreign-vaccinated dogs that have been in a DMRVV

high-risk country within the last six months to enter the United States through an airport with a

CDC quarantine station and a CDC-registered ACF. The importer must have a reservation at the

CDC-registered ACF and have their dog(s) undergo a veterinary exam and revaccination with a

USDA-licensed rabies vaccine at the CDC-registered ACF. The importer must obtain a rabies

serologic test from a CDC-approved laboratory for their foreign-vaccinated dogs demonstrating

adequate titer levels. Importers of foreign-vaccinated dogs that have been in a DMRVV high-risk

country within the last six months who cannot obtain serologic test results prior to importation

are required to have their dog remain under quarantine at the facility for 28 days after

revaccination or until confirmation of adequate rabies serologic test from a CDC-approved

laboratory is obtained, whichever occurs first.

CDC is requiring the use of CDC-registered ACF as opposed to community veterinary clinics

because 1) ACF are trained to quarantine animals, and to observe and report abnormalities in

quarantined animals to CDC; 2) ACF undergo, at a minimum, an annual inspection to ensure

compliance with CDC regulations; 3) ACF are experienced in pet transportation and trained to

meet requirements established by airlines, exporting countries, and U.S. importation

requirements; and 4) ACF are bonded facilities that have special equipment and insurance for

goods (i.e., dogs) that are awaiting clearance into the United States.

B.iv. Exemption for foreign-vaccinated service dogs at U.S. seaports

In this final rule, HHS/CDC is allowing foreign-vaccinated service dogs that have been in a

DMRVV high-risk country within the last six months to enter the U.S. at a U.S. seaport if the
dog is at least six months of age; has a microchip; has a complete, accurate, and valid

Certification of Foreign Rabies Vaccination and Microchip form; and has sufficient and valid

titer results from a CDC-approved laboratory. To be considered a valid service dog, the dog must

meet the definition of a “service animal”26 under 14 CFR 382.3 and accompany an “individual

with a disability”27 as defined under 14 CFR 382.3. This exemption is limited to foreign-

vaccinated service dogs entering the United States via seaports and is not available to foreign

vaccinated dogs entering via air or at land ports. Under this final rule, airlines must confirm that

foreign vaccinated dogs, including foreign vaccinated service dogs meet all CDC requirements

prior to allowing dogs to board an aircraft. Therefore, CDC had determined that a special

exemption for foreign-vaccinated service dogs arriving via air is not needed because airlines

must confirm that these dogs meet all CDC requirements prior to arrival. Under such

circumstances, an individual with a disability can choose to remain with their service animal and

seek to rebook their flights after all CDC requirements have been met. Similarly, CDC has

determined that a special exemption for foreign vaccinated service dogs is not needed at land

ports because if the dogs do not meet all CDC requirements for entry, the dogs will be denied

entry to the United States. Under these circumstances, the individual can choose to remain with

26Under 14 CFR 382.3, Service animal means “a dog, regardless of breed or type, that is individually trained to do
work or perform tasks for the benefit of a qualified individual with a disability, including a physical, sensory,
psychiatric, intellectual, or other mental disability. Animal species other than dogs, emotional support animals,
comfort animals, companionship animals, and service animals in training are not service animals for the purposes of
this part.”
27 Under 14 CFR 382.2, Individual with a disability “means any individual who has a physical or mental impairment
that, on a permanent or temporary basis, substantially limits one or more major life activities, has a record of such an
impairment, or is regarded as having such an impairment.
As used in this definition, the phrase: (a) Physical or mental impairment means:
(1) Any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the
following body systems: neurological, musculoskeletal, special sense organs, respiratory including speech organs,
cardio-vascular, reproductive, digestive, genito-urinary, hemic and lymphatic, skin, and endocrine; or
(2) Any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental
illness, and specific learning disabilities.
The term physical or mental impairment includes, but is not limited to, such diseases and conditions as orthopedic,
visual, speech, and hearing impairments; cerebral palsy, epilepsy, muscular dystrophy, multiple sclerosis, cancer,
heart disease, diabetes, mental retardation, emotional illness, drug addiction, and alcoholism.”
their dogs on the non-U.S. side of the land border and then seek admission after all CDC

requirements have been met. CDC further notes that there are fewer available ACFs close to land

ports and allowing an exemption for foreign vaccinated service animals at land ports would be

operationally impracticable. Regarding the exemption for service animals entering via seaports,

CDC believes that this exemption would most likely be used by individuals with disabilities

traveling with their service animals on board cruise ships and that these individuals would

presumably be visiting the United States for a very short period of time before reboarding the

ship (e.g., under circumstances where an individual with a disability is participating on a shore

excursion). Based on the limited amount of time that these service animals will be spending in

the United States and the fact that cruise operators maintain their own vaccination requirements

for service dogs, CDC believes that the rabies risk presented by foreign-vaccinated service dogs

temporarily visiting the United States via cruise ship is low. The volume of foreign-vaccinated

service dogs arriving from high-risk countries on board non-cruise sea vessels is also believed to

be very small, compared to the number of foreign-vaccinated service dogs arriving from high-

risk countries entering the US via land and air which presents a greater public health risk and the

need for enforcement of the requirements without an exemption.

B.v. Requirements for dogs from DMRVV-restricted countries

The final rule also authorizes HHS/CDC to prohibit or otherwise restrict the importation of

dogs into the United States from certain countries that have a history of exporting dogs infected

with DMRVV or have demonstrated a lack of appropriate veterinary controls to prevent the

exportation of rabid dogs. HHS/CDC will maintain a “List of DMRVV-Restricted Countries”

from which the importation of dogs into the United States would be prohibited on CDC’s

website; however, HHS/CDC is not including any countries on this list at this time. Additions or

removals of countries will be announced in notices published in the Federal Register and would

include a timeline for implementation. CDC retains the ability to allow certain importers to apply

for and for CDC to issue CDC Dog Import Permits on an extremely limited basis for dogs that
have been in a DMRVV-restricted country in the six months prior to their importation into the

United States (e.g., for dogs imported for scientific purposes, for use as a service animal for

individuals with disabilities,28 or in furtherance of an important government interest).

B.vi. Requirements for airlines

The final rule further requires that an airline, prior to accepting a dog for transport, confirm

that the dog possess all required import documentation based on the country of origin. Airlines

must also ensure that foreign-vaccinated dogs from DMRVV high-risk countries are entering the

United States only through a designated U.S. airport with both a CDC quarantine station and a

CDC-registered ACF and that the importer possesses a reservation with the CDC-registered ACF

for examination, vaccination, and quarantine (if required). Air carriers are required to create bill

of lading (e.g., air waybill (AWB)) for all dogs entering the United States via air, including dogs

transported as cargo, hand-carried and checked-baggage. As needed, CDC will coordinate with

the airline regarding transport of the dog to the CDC-registered ACF. These regulatory actions

help ensure that dogs arriving in the United States from DMRVV high-risk countries are

adequately protected against rabies and do not pose a public health threat.

The final rule requires that airlines return dogs or cats denied admission to the country of

departure within 72 hours after arrival, unless the animal is ill or injured and CDC has approved

delaying the return of the animal. The responsibility for a dog or cat pending admission into the

United States or awaiting return to the country of departure has been a point of confusion for

many airlines, resulting in delayed care and improper housing for numerous animals. Delays in

returning dogs to their countries of departure also potentially threaten U.S. public health by

exposing people to dogs with unknown rabies vaccination status. HHS/CDC requires that the

airline that flew a dog or cat to the United States must arrange for and ensure transportation,

28Emotional support animals are not recognized as service animals. U.S. Department of Transportation. Service
Animals. https://www.transportation.gov/individuals/aviation-consumer-protection/service-animals, last updated
June 9, 2021.
housing, and care until the animal is either returned to the county of departure or cleared for

entry into the United States.

This final rule also includes a provision regarding dogs and cats that die en route to the

United States or that die while detained pending determination of their admissibility. This

provision is primarily directed at airlines and requires that they arrange for transportation of

deceased dogs and cats and for necropsy requiring gross and histopathologic examination and

any subsequent infectious disease testing based on the findings. The importer is responsible for

all costs associated with transportation, necropsy and testing and providing the CDC quarantine

station29 with the final necropsy report and all test results. The airline is also required to notify

the CDC quarantine station of jurisdiction30 prior to transporting a dead dog or cat for a necropsy

to determine whether rabies testing is required. These measures will help CDC rule out foreign

animal diseases of public health concern31 as a potential cause of death, enable CDC to take

responsive measures as needed, and will protect both animal and human health. The provisions

of this paragraph may also be applied to other carriers transporting such dogs and cats in the very

rare event when the death of a dog or cat occurs en route to the United States, or the animal dies

while detained pending determination of admissibility.

The final rule requires airlines to confirm prior to boarding a foreign-vaccinated dog from a

DMRVV high-risk country that the dog is scheduled to arrive at an approved U.S. airport and the

importer has documentation confirming a reservation at the CDC-registered ACF. This ensures

that CDC and USDA can follow up with airlines more easily to confirm animals are being

properly handled (e.g., not left in cargo warehouses for prolonged periods of time that endanger

the health of the animal). Additionally, to address concerns relating to the movement of dogs or

29 CDC quarantine stations are also known as U.S. Port Health Stations.
30 CDC quarantine station jurisdictions, available at: www.cdc.gov/quarantine/quarantine-stations-us.html.
31 U.S. Department of Agriculture. Notifiable Diseases and Conditions.

https://www.aphis.usda.gov/aphis/ourfocus/animalhealth/nvap/NVAP-Reference-Guide/Animal-Health-Emergency-
Management/Notifiable-Diseases-and-Conditions.
cats that are sick or dead upon arrival, HHS/CDC requires airlines to arrange transportation of all

sick or dead animals (regardless of vaccination status and country of origin) to a CDC-registered

ACF or, under certain conditions, to another CDC-approved veterinary clinic as soon as possible.

The final rule requires airlines to transport healthy-appearing animals that are denied

admission and awaiting return to their country of departure, or are awaiting a determination as to

their admissibility, to a CDC-registered ACF within 12 hours. CDC acknowledges that

extraordinary circumstances, such as extreme weather, may delay the transport of animals

beyond the 12-hour window. Under such circumstances, CDC will work closely with airlines to

address these rare and unforeseen events while ensuring the safe handling of animals. CDC also

will work with importers who arrive at unapproved U.S. ports based on circumstances beyond

their control (e.g., re-routing of their flight due to extreme weather). CDC quarantine station staff

are available 24 hours a day to assist streamlined coordination and processing of dog and cat

importation at U.S. ports and provide coverage for geographic areas beyond the U.S. port in

which the CDC quarantine station is located.

B.vii. Other requirements and summary

HHS/CDC is establishing requirements for businesses that wish to become CDC-registered

ACF. Requirements include a USDA intermediate handlers registration and approved by CBP to

act as a CBP-bonded facility with an active Facilities Information and Resource Management

System (FIRMS) code. This ensures dogs and cats receive appropriate veterinary care and are
housed in a way that prevents the spread of infectious diseases while protecting the safety of the

animals. CDC-registered ACF must be located within 35 miles of a CDC quarantine station.

The requirements HHS/CDC is finalizing for dog importation into the United States are

summarized below in Table E1. Since HHS/CDC is not substantially changing cat importation

requirements, Table E1 does not apply to cats.

Table E1. Summary table of finalized importation requirements for dogs based on
vaccination status and country of origin

Requirements for Admission

Age ISO- Documentation Approved U.S.


Compatible Ports
Microchip
U.S.-Vaccinated At least six Yes Valid Certification All U.S. ports
Dog from months of age of U.S.-issued
DMRVV High- Rabies Vaccination
Risk Country form and CDC
Dog Import Form
receipt
Foreign- At least six Yes Reservation with a Only U.S.
Vaccinated Dog months of age CDC-registered airports with a
from DMRVV Animal Care CDC quarantine
High-Risk Facility, station and a
Country Certification of CDC-registered
Foreign Rabies Animal Care
Vaccination and Facility*
Microchip form,
CDC Dog Import
Form receipt, titer
results from a
CDC-approved
laboratory (dogs
without titer results
will be required to
quarantine)
Dog from At least six Yes There are no All U.S. ports
DMRVV-Free months of age vaccination
or DMRVV requirements;
Low-Risk however, requires
Country written
documentation that
the dog has resided
or otherwise been
only in DMRVV
low-risk or
DMRVV-free
countries during
the six months
prior to the
attempted entry
and CDC Dog
Import Form
receipt
U.S.- or At least six Yes CDC Dog Import Only U.S.
Foreign- months of age Permit for limited airports with a
Vaccinated Dog groups of dogs CDC quarantine
from DMRVV- (e.g., service station and a
Restricted animals, CDC-registered
Country government-owned Animal Care
animals) Facility

* All service dogs entering at U.S. seaports must be six months of age, have an ISO-

compatible microchip, have a receipt confirming submission of a CDC Dog Import Form, and

have both a valid Certification of Foreign Rabies Vaccination and Microchip and sufficient and

valid titer results from a CDC-approved laboratory. Service dogs that meet these requirements

will not be required to be examined and revaccinated at an ACF.

The forms HHS/CDC is requiring per this final rule for dog importation into the United

States are summarized below in Table E2. Since HHS/CDC is not substantially changing cat

importation requirements, Table E2 does not apply to cats.

Table E2. Summary table of forms required from importers of dogs based
on vaccination status and country of origin
Form Dog from U.S.- Foreign- Dog from
DMRVV-free Vaccinated Vaccinated DMRVV-
or DMRVV Dog from Dog from Restricted
Low-Risk DMRVV DMRVV Country
Country High-Risk High-Risk
Country Country*

CDC Dog Required Required Required Required


Import Form
Certification Not Required Required N/A Required**
of U.S.-issued
Rabies
Vaccination

Certification Not Required N/A Required Required**


of Foreign
Rabies
Vaccination
and
Microchip
Application Not Required Not Required Not Required Required
for Special
Exemption for
a Permitted
Dog Import

* Importers of foreign-vaccinated dogs from DMRVV high-risk countries will also be

required to provide additional information to the ACF to make a reservation for their dog prior to

arrival in the United States.

** Importers of dogs from DMRVV-restricted countries are required to have either a valid

Certification of U.S.-issued Rabies Vaccination form or a valid Certification of Foreign Rabies

Vaccination and Microchip form.

The documentation HHS/CDC is requiring be presented at the U.S. port upon arrival for dog

importation into the United States is summarized below in Table E3. Because HHS/CDC is not

substantially changing cat importation requirements, Table E3 does not apply to cats.

Table E3. Summary table of required documentation to be presented at U.S.


port upon arrival for dogs based on vaccination status and country of origin
Documentatio Dog from U.S.- Foreign- Dog from
n to be DMRVV-free Vaccinated Vaccinated DMRVV-
Presented at or DMRVV Dog from Dog from Restricted
U.S. Port Low-Risk DMRVV DMRVV Country
Upon Arrival Country High-Risk High-Risk
Country Country
CDC Dog Required Required Required Required
Import Form
Receipt
Written Required N/A N/A N/A
documentatio
n that the
animal has
resided or
otherwise
been only in
DMRVV-free
or DMRVV
low-risk
countries
during the six
months prior
to the
attempted
entry
Certification Not Required Required N/A Not Required
of U.S.-issued
Rabies
Vaccination
Form

Reservation Not Required Not Required Required May be


with a CDC- required
registered
Animal Care
Facility
CDC Dog N/A N/A N/A Required
Import Permit

C. Costs and Benefits

CDC conducted an analysis to estimate the distributions of costs and benefits incurred with

the final rule relative to regulatory baseline. The provisions of this final rule are not likely to

have an effect on the economy of $200 million or more in any one year, although there is
considerable uncertainty around the number of dogs imported at baseline, including the number

of dogs imported from DMRVV high-risk countries.

The requirements of this final rule will address the market inefficiency in which dog

importers do not account for the potential detrimental impacts to public health that may result

from the importation of ill dogs, especially dogs infected with DMRVV. The worst-case scenario

would include the reintroduction of DMRVV into the United States. Federal regulation is

necessary to mitigate the risk of importing infected dogs. Federal action allows this risk to be

addressed prior to dogs’ arrival in the United States and for dogs to be evaluated, revaccinated,

and possibly quarantined (if required) in controlled conditions after their arrival in the United

States. The primary public health benefit is a reduction in the risk of importing dogs infected

with DMRVV. The regulatory changes in this final rule are expected to affect the following

categories of interested parties and implementing partners:

• Importers of dogs from countries that are DMRVV-free or are low risk for DMRVV;

• Importers of dogs from countries that are at high risk of DMRVV;

• Airlines and other carriers;

• CBP;

• CDC;

• USDA; and

• State and local public health and animal health departments.

The provisions in the final rule incorporate different requirements for dogs imported from

DMRVV high-risk countries than those imported from DMRVV-free or DMRVV low-risk

countries. The annualized and present value estimates of monetized costs and benefits over the

10-year period from 2024 through 2033 using three percent and seven percent discount rates are
summarized below. The annualized, monetized costs (2020 USD) of the final rule are estimated

to be $59 million (range: $13.1 to $207 million) using a three percent discount rate; the estimated

monetized costs using a seven percent discount rate are largely the same.

Most monetized costs are expected to be incurred by importers (87 percent of costs is the

most likely estimate). The estimated monetized costs are about three times greater for importers

of dogs from DMRVV high-risk countries compared to importers of dogs from DMRVV-free or

low-risk countries. The requirements in the final rule estimated to result in the greatest increase

in costs for importers of dogs are those associated with the veterinary examination and

revaccination against rabies at a CDC-registered ACF for foreign-vaccinated dogs from

DMRVV high-risk countries in section 71.51(k), costs for titer testing of foreign-vaccinated dogs

from DMRVV high-risk countries, additional costs associated with the CDC Dog Import Form

requirement, the minimum age for imported dogs, and the microchip requirements for all

imported dogs. Other costs include 1) an expected reduction in the number of dogs imported

from DMRVV high-risk countries, 2) the requirement to arrive at one of six U.S. airports with

CDC-registered ACF (required for foreign-vaccinated dogs arriving from DMRVV high-risk

countries), and 3) the requirement to obtain a Certification of Foreign Rabies Vaccination and

Microchip form or a Certification of U.S.-issued Rabies Vaccination form with certification by

an official government veterinarian for all dogs from DMRVV high-risk countries. Dogs

imported from DMRVV-free or low-risk countries would also require a document certified by an

official government veterinarian, but HHS/CDC will allow a greater number of potential

documents as specified in 42 CFR 71.51(u).

Airlines are estimated to incur about 7.0 percent of the estimated annualized costs associated

with the final rule. Most airline costs would result from ensuring that all transported dogs comply

with the new requirements in the final rule, the costs associated with creating bills of lading or a
CDC-approved alternative for all imported dogs, and from a small reduction in the number of

dogs transported. Airline costs may be passed along to dog importers.

HHS/CDC is estimated to incur about 3.3 percent of the annualized, monetized costs (most

likely estimate) associated with the provisions of this final rule. Most CDC costs would be

associated with the oversight of animal care facilities, which must be approved by and registered

with CDC, and the establishment of a laboratory proficiency testing program to support serologic

testing for foreign-vaccinated dogs imported from DMRVV high-risk countries.

CBP is expected to incur about 3.0 percent of the annualized costs (most likely estimate)

associated with the provisions of this final rule. Most CBP costs would result from additional

screening time at U.S. ports for dogs from DMRVV-free or low-risk countries.

The annualized monetized benefits of the provisions in the final rule are estimated to be

about $1.8 million (range: $0.75 to $3.6 million) using a three percent or seven percent discount

rate. Most benefits will accrue to importers (47 percent of the most likely estimates) and to CBP

(30 percent of the most likely estimate). Some of the benefits estimated for both importers and

CBP will result from reduced time spent on screening dogs from high-risk countries at U.S. ports

because fewer dogs will be imported with the requirements included in the final rule. The

requirements in the final rule are estimated to reduce the amount of time required to verify

admissibility per U.S.-vaccinated dog from DMRVV high-risk country at U.S. ports because

rabies vaccination documentation forms will be standardized. The provisions in this final rule are

also estimated to reduce the number of dogs arriving ill or dead and the number of dogs denied

entry, with benefits estimated for importers, airlines, and CDC. USDA is expected to receive

payments commensurate with its cost to provide the Certification of U.S.-issued Rabies

Vaccination form for U.S.-vaccinated dogs traveling internationally.

The wide range between the lower-bound and upper-bound cost and benefit estimates

demonstrates that there is considerable uncertainty in these results. At present, the number of
dogs imported into the United States is neither accurately nor completely tracked by any data

system, and the uncertainty in the cost and benefit estimates reflect uncertainty in both the total

number of dogs imported and the number of dogs imported from DMRVV high-risk countries, as

well as the cost of the new requirements in the final rule. The net annualized, monetized costs

(total cost estimate – total benefit estimate) were estimated to be about $57 million per year

(range: $12 to $203 million) using a three percent discount rate. The annualized estimates were

relatively unaffected by using a seven percent discount rate.

Because the estimated costs for foreign-vaccinated dogs from DMRVV high-risk countries

are much higher than costs for other dog imports, importers may choose to import dogs from

DMRVV-free or low-risk countries instead of from DMRVV high-risk countries. In addition,

individuals who travel from the United States to DMRVV high-risk countries with their pet dogs

for long-term visits may take the additional step to have their dogs revaccinated with a three-year

rabies vaccine prior to departure, which would allow up to three years for return to the United

States with a Certification of U.S.-issued Rabies Vaccination. These changes should result in

lower overall costs than the above estimates for the final rule in which HHS/CDC assumed

individuals would be unable to change the countries from which dogs are imported into the

United States.

The importation of just one dog infected with DMRVV risks reintroduction of the virus into

the United States, which could result in loss of human and animal life and substantial public

health response costs. The social cost of the consequences associated with the importation of a

single DMRVV-infected dog is estimated to be $270,000 (range: $210,000 to $510,000) for

conducting public health investigations and administering rabies PEP to exposed persons. The

primary public health benefit of the provisions in the final rule is the reduced risk that a dog with

DMRVV will be imported from a DMRVV high-risk country. The above estimate of the cost of

importation of a dog with DMRVV does not account for the worst-case outcomes, which include

1) transmission of rabies to a person who dies from the disease, and 2) ongoing transmission to
other domestic and wildlife species in the United States. The cost of reintroduction could be

especially high if DMRVV spreads to other species of U.S. wildlife. Re-establishment of

DMRVV in the United States could result in costly efforts over several years to eliminate the

virus again. The costs to contain any reintroduction would depend on the time period before the

reintroduction was detected, the wildlife species in which DMRVV was transmitted, and the

geographic area over which reintroduction occurred.

An increase in human deaths from DMRVV could occur following the reintroduction of

DMRVV to the United States, as the risk of exposure would increase. Human deaths from rabies

continue to occur in the United States after exposures to wild animals, and there have been eight

deaths among U.S. residents bitten by rabid dogs while traveling abroad in DMRVV high-risk

countries since 2009. HHS/CDC uses the value of statistical life (VSL) to support quantifying

benefits for interventions that can result in mortality risk reductions. HHS recommends using a

central estimate of $11.6 million and a range of $5.5 to $17.7 million (2020 USD). HHS/CDC is

unable to estimate the potential magnitude of the mortality risk reduction associated with the

final rule. Based on the central VSL, averting five human deaths per year would mean the

benefits of the final rule would exceed its costs.

HHS/CDC and other Federal government agencies do not know with precision the number of

dogs imported each year or the countries from which the dogs originate. More comprehensive

data on where dogs are imported from may benefit public health investigations. Arrival data on

animals exposed to a dog with DMRVV on U.S.-bound flights, for example, would expedite

follow-up of exposed dogs in the United States. The lack of data received from implementing the

current regulation also inhibits the Federal government’s ability to target interventions for dogs

imported from specific countries. Of note, the COVID-19 pandemic diverted resources from and

weakened rabies control programs in some DMRVV high-risk countries, increasing the risk that

imported dogs may be infected with DMRVV. The provisions of this final rule will be of
particular public health benefit in light of the ongoing resource concerns for global rabies

vaccination campaigns in the wake of the pandemic.

These data would also benefit agencies such as USDA’s Animal and Plant Health Inspection

Service (APHIS), which have an interest in regulating dog imports with the intent of reducing the

risk of introduction of diseases that may affect U.S. livestock. For example, in 2021, APHIS

issued a Federal Order that established additional post-entry requirements on dogs for resale

imported from countries with ongoing African swine fever transmission, which poses a

significant risk to U.S. pork producers. The potential economic benefits of reducing the risk of

the importation of African swine fever could be significant; in fact, a 2019 outbreak in China

was estimated to have total economic losses equivalent to 0.78 percent of China’s gross domestic

product. Thus, some of the requirements in this final rule may mitigate the risks of introduction

and transmission of diseases that impact livestock in addition to reducing the risk of importing

dogs infected with DMRVV.

The monetized cost estimate has increased considerably relative to the estimates included

in the NPRM. The primary reasons for the increase in cost include:

• The fees charged by ACF have increased relative to CDC’s preliminary estimates.

• Some U.S. ports require that dogs needing follow-up care at ACF arrive as cargo.

This requirement was not anticipated by HHS/CDC and will increase costs for

importers of foreign-vaccinated dogs from DMRVV high-risk countries who

otherwise would have chosen to transport their dogs as hand-carried or checked

baggage. The fee charged for cargo shipments are highly variable.32,33 The future

costs associated with this rule will depend on U.S. port policies that are subject to

change. The average cost for the follow-up visit at ACF is estimated to be $900

32http://www.airline-pet-policies.com/united-airlines-pet-policy.php. Accessed 15 Nov 2023.


33Katie Morrell (March 3, 2021) How Much Does It Cost To Fly With Your Dog on a Plane? Dailypaws.com
https://www.dailypaws.com/living-with-pets/pet-travel/how-much-does-it-cost-to-fly-a-dog-on-a-plane. Accessed:
06 February 2022.
(range: $500 to $1,300 per dog). The average costs associated with shipping dogs

as cargo is estimated to be $2,000 (range: $1,500 to $2,500) 34 compared to an

average of $300 (range: $200 to $400) for dogs shipped as hand-carried or

checked baggage.35 Under the regulatory baseline, HHS/CDC assumes 25%,

range: 17% to 50% of dogs going to ACF are shipped as cargo. With the final

rule, HHS/CDC assumes that 60% of dogs going to ACF, range: 60% to 70% of

dogs will be shipped as cargo.

• The cost estimate for foreign-vaccinated dogs from DMRVV high-risk countries

to re-route travel destinations to arrive at authorized U.S. ports with ACF was

increased.

• The costs associated with the requirement for proof that a dog has been only in

DMRVV low-risk or DMRVV-free countries have increased because HHS/CDC

added more examples of the types of proof required. Each type of document

requires certification by a USDA or official government veterinarian in the

exporting country. Examples include: a) a valid foreign export certificate from a

DMRVV-free or DMRVV low-risk country that has been certified by an official

government veterinarian in that country; b) a USDA export certificate if the

certificate is issued to allow the dogs to travel to a DMRVV-free or DMRVV

34 Feathers and Fur Express (2023) How much does it cost to fly a pet/s internationally?
https://ffexpresspets.com/international-pet-shipping-costs/. Accessed November 10, 2023. Note that the costs
reported in this reference include cargo shipping costs to Germany, the United Kingdom, Japan, and Australia. The
reference includes costs for small and large dogs shipped to each country. Costs are much higher for larger dogs or
for dogs shipped over longer distances. The highest costs were for Australia, which may be more representative of
shipping costs from DMRVV high-risk countries in Africa. The European costs may be similar to shipping costs for
dogs imported from DMRVV high-risk countries in Europe or Central America or South America. The costs for
Japan may be similar to costs for DMRVV high-risk countries in Asia. The simple average cost across the four
countries and dog sizes is $1,931 in 2023 USD. This would correspond to $1,622 in 2020 after adjustment with the
consumer price index: https://www.bls.gov/data/inflation_calculator.htm. The most likely estimate is increased to
$2,000 in case the costs to importers from DMRVV high-risk countries would be higher than for the countries for
which data are available. This increase from $1,600 to $2,000 would also allow some importers to choose to hire
shippers to facilitate the importation process or brokers to support customs clearance. The need to hire shippers may
be reduced by the need to visit CDC-registered ACF, who may be able to review documentation in advance of
arrival when reservations are made.
35 http://www.airline-pet-policies.com/united-airlines-pet-policy.php. Accessed 15 Nov 2023.
low-risk country, c) a valid Certification of Foreign Rabies Vaccination and

Microchip form if completed in a DMRVV-free or DMRVV low-risk country, or

d) a valid Certification of U.S.-Issued Rabies Vaccination form. These documents

are often required for individuals to travel internationally with their pets but are

not required for travel to Canada or Mexico. These documents may be used as

long as they specify travel to or from the country from which a dog is imported.

Individuals who frequently travel to and from Canada and Mexico (or any other

country) can obtain a valid Certification of U.S.-Issued Rabies Vaccination form,

which will remain valid for multiple trips for up to three years corresponding to

the duration of protection for dog rabies vaccines.

• CDC increased the estimated costs associated with shipping blood samples to

CDC-approved laboratories for serological testing based on a number of

comments from individuals suggesting their shipping costs were higher.

• CDC changed the requirement for importing dogs from DMRVV-free or low-risk

countries such that no dogs less than six months may be imported at land borders.

This will increase costs for individuals who wish to travel with their young dogs

to or from Canada and Mexico.

• CDC increased the estimated costs to airlines by 100% for dogs imported from

DMRVV-free or low-risk countries and by 50% for dogs imported from DMRVV

high-risk countries to account for a number of comments suggesting that costs to

airlines should be higher than the estimates included in the NPRM analysis.

Some of the cost estimates for the final rule have also decreased due to changes made

between the NPRM and the final rule. These include:


• The costs to importers of U.S.-vaccinated dogs from DMRVV high-risk countries were

reduced because the final rule will not require that such dogs arrive at U.S. ports with

CDC quarantine stations.

• The costs for serological testing for foreign-vaccinated dogs from DMRVV high-risk

countries were reduced because CDC plans to implement a policy that only one

serological test will be required during the lifetime of such dogs as long as they remain

current with their rabies vaccinations.

II. Background
a. Legal Authority

The primary legal authority supporting this final rule is section 361 of the Public Health

Service Act (PHS Act) (42 U.S.C. 264). Under section 361, the Secretary of HHS (Secretary)

may make and enforce such regulations as in the Secretary’s judgment are necessary to prevent

the introduction, transmission, or spread of communicable diseases from foreign countries into

the United States and from one State or possession into any other State or possession.36 It also

authorizes the Secretary to promulgate and enforce a variety of public health regulations to

prevent the spread of communicable diseases, including through inspection, fumigation,

disinfection, sanitation, pest extermination, destruction of animals or articles found to be sources

of dangerous infection to human beings, and other measures. Since at least 1956, Federal

quarantine regulations (currently found at 42 CFR 71.51) have controlled the entry of dogs and

cats into the United States.37

In addition to section 361, other sections of the PHS Act relevant to this final rule are

section 362 (42 U.S.C. 265), section 365 (42 U.S.C. 268), section 367 (42 U.S.C. 270), and

36 Although the statute assigns authority to the Surgeon General, all statutory powers and functions of the Surgeon
General were transferred to the Secretary of HHS in 1966, 31 FR 8855, 80 Stat. 1610 (June 25, 1966), see also Pub.
L. No. 96-88, sec. 509(b), October 17, 1979, 93 Stat. 695 (codified at 20 U.S.C. 3508(b)). The Secretary has retained
these authorities despite the reestablishment of the Office of the Surgeon General in 1987.
37 See 21 FR 9870 (Dec. 12, 1956).
section 368 (42 U.S.C. 271). Section 362, among other things, authorizes the Secretary to

promulgate regulations prohibiting, in whole or in part, the introduction of property from foreign

countries or places, for such period of time and as necessary for such purpose, to avert the

serious danger of introducing communicable disease into the United States. Section 365 provides

that it shall be the duty of customs officers and of Coast Guard officers to aid in the enforcement

of quarantine rules and regulations.38 Through this statutory provision, U.S. Customs and Border

Protection (CBP) within the Department of Homeland Security (DHS) provides critical

assistance in enforcing Federal quarantine regulations at U.S. ports. Section 367 (42 U.S.C. 270)

also authorizes the application of certain sections of the PHS Act to air navigation and aircraft to

such extent and upon such conditions as deemed necessary for safeguarding public health and

authorizes the promulgation of regulations.

Section 368 of the PHS Act provides that any person who violates regulations

implementing sections 361 or 362 is subject to imprisonment of not more than one year, a fine,

or both. Pursuant to 18 U.S.C. 3559 and 3571, an individual may face a fine of up to $100,000

for a violation not resulting in death and up to $250,000 for a violation resulting in death.

HHS/CDC may refer violators to the U.S. Department of Justice for criminal prosecution. To

implement section 368, HHS/CDC would request assistance from other departments and

agencies to address violations.

Through this final rule, HHS/CDC is also including new language advising individuals

and organizations that it may request that DHS/CBP take additional action pursuant to 19 U.S.C.

1592 and 19 U.S.C. 1595a. Specifically, CDC may request that DHS/CBP issue additional fines,

3842 U.S.C. 268(b). The terms “officer of the customs” and “customs officer” are defined by statute to mean, “any
officer of the United States Customs Service of the Treasury Department (also hereinafter referred to as the
“Customs Service”) or any commissioned, warrant, or petty officer of the Coast Guard, or any agent or other person,
including foreign law enforcement officers, authorized by law or designated by the Secretary of the Treasury to
perform any duties of an officer of the Customs Service.” 19 U.S.C. 1401(i). Although this provision refers to the
Secretary of the Treasury, the Homeland Security Act transferred to the Secretary of Homeland Security all “the
functions, personnel, assets, and liabilities of . . . the United States Customs Service of the Department of the
Treasury, including the functions of the Secretary of the Treasury relating thereto . . . [,]” 6 U.S.C. 203(1), such that
reference to the Secretary of the Treasury should be read to reference the Secretary of Homeland Security.
citations, or penalties to importers, brokers, or carriers whenever the CDC Director (Director)

has reason to believe that an importer, broker, or carrier has violated any of the provisions of this

section or otherwise engaged in conduct contrary to law. HHS/CDC stresses that it does not

administer Title 19, and decisions regarding whether to issue such fines, citations, or other

penalties would be entirely at the discretion of DHS/CBP and subject to its policies and

procedures. Notwithstanding, HHS/CDC believes it important to include this language to advise

individuals and organizations that it may request that DHS/CBP pursue such actions.

Through this final rule, HHS/CDC is also including new language advising individuals

and organizations that it may request that the U.S. Department of Justice investigate, and based

on the results of such investigation, prosecute, potential violations of Federal law arising under

its dog importation regulations. This includes potential violations of 18 U.S.C. 111 which

prohibits persons from forcibly assaulting, resisting, opposing, impeding, intimidating, or

interfering with government employees in the conduct of or on account of their official

government duties and 18 U.S.C. 1505 which prohibits disrupting agency proceedings. See, e.g.,

United States v. Schwartz, 924 F.2d 410, 423 (2d Cir. 1991) (holding that a U.S. Customs

Service interview of defendants for purposes of determining whether to seize potentially illegal

arms was an “agency proceeding” under 18 U.S.C. 1505).

HHS/CDC further clarifies that there is no agency policy of using the “least restrictive

means” (as that concept is typically understood and applied in cases involving interests protected

by the U.S. Constitution) regarding animal importations under 42 CFR part 71. “The Due

Process Clause of the Fourteenth Amendment imposes procedural constraints on governmental

decisions that deprive individuals of liberty or property interests.” Nozzi v. Hous. Auth. of City of

Los Angeles, 806 F.3d 1178, 1190 (9th Cir. 2015). However, “[d]ue process protections extend

only to deprivations of protected interests.” Shinault v. Hawks, 782 F.3d 1053, 1057 (9th Cir.

2015). Because individuals have no protected property or liberty interest in importing dogs or

other animals into the United States, it is HHS/CDC’s policy to not employ a constitutional
analysis of “least restrictive means” in regard to animal imports under 42 CFR part 71. See

Ganadera Ind. V. Block, 727 F.2d 1156, 1160 (D.C. Cir. 1984) (“no constitutionally-protected

right to import into the United States”); see also Arjay Assoc. v. Bush, 891 F.2d. 894, 896 (Fed.

Cir. 1989) (“It is beyond cavil that no one has a constitutional right to conduct foreign commerce

in products excluded by Congress.”).

b. Regulatory Background

On July 10, 2023, HHS/CDC published an NPRM to update 42 CFR 71.50 and 71.51

within its Foreign Quarantine regulations to address the risk to public health from the

importation of dogs and cats into the United States. The provisions contained within the NPRM

were designed to enhance HHS/CDC’s ability to prevent the importation and spread of dog-

maintained rabies virus variant (DMRVV) into the United States and interstate by implementing

requirements that are used throughout other rabies-free countries and are recommended by

animal health organizations (e.g., World Organisation for Animal Health). CDC evaluates and

updates the DMRVV high-risk country list every year and generally posts the updated list on

CDC’s website39 by April 1. For this annual country risk assessment, CDC subject matter experts

review publicly available data, including data from international organizations (including the

World Health Organization (WHO); the WHO Rabies Bulletin – Europe; the Pan-American

Health Organization, and the World Organisation for Animal Health (WOAH)); published

government reports; scientific publications; and outbreak report alerts such as ProMED,40 as well

as information provided by national and international rabies experts. HHS/CDC will also review

the information and re-assess a country’s status when presented with additional substantial data

to support canine rabies-free status by a foreign country’s officials. Lastly, CDC has published

39 Centers for Disease Control. DMRVV high-risk country list. Available at: www.cdc.gov/importation/bringing-an-
animal-into-the-united-states/high-risk.html.
40 The Program for Monitoring Emerging Diseases (ProMED) is a program of the International Society for

Infectious Diseases and is available at https://promedmail.org/.


the criteria for how it determines a country’s classification as a high-risk, low-risk and DMRVV-

free country in peer-reviewed journal articles which are publicly available.41,42 Because of an

ongoing risk of reintroduction of DMRVV due to insufficient veterinary controls in countries

where DMRVV is still endemic and in parallel with the publication of the NPRM on July 10,

2023, CDC published an extension of the temporary suspension of dogs from DMRVV high-risk

countries.43 Today’s final rule has no effect on the temporary suspension, which expires on July

31, 2024. This final rule will go into effect August 1, 2024.

III. Summary of the Final Rule

Changes to 71.50

Section 71.50(b) contains definitions applicable to animal importations under subpart F

of 42 CFR part 71. The definitions contained in paragraph (b) are of general scientific

applicability and thus would apply to different animal imports, not just dogs and cats. After

considering public comment received to the NPRM, HHS/CDC is adding the following

definitions to 42 CFR 71.50(b): Authorized veterinarian, cat, dog, histopathology, in-transit

shipments, microchip, necropsy, official government veterinarian. CDC is replacing the

definition for “in-transit” with the definition “in-transit shipments,” as proposed in the NRPM.

This final rule also adds a new paragraph at 42 CFR 71.50(c) that addresses the legal

severability of provisions found in 42 CFR part 71 subpart F – Importations. Because the

provisions relating to importations under subpart F are designed to protect the public’s health

from various communicable disease threats, HHS/CDC intends that these provisions have

41 Henry RE, Blanton JD, Angelo KA, Pieracci EG, Stauffer K, et al. A country classification system to inform
rabies prevention guidelines and treatment. Journal of Travel Medicine, 2022;29(4):taac046. doi:
10.1093/jtm/taac046. PMID: 35348741.
42 Minhaj FS, Bonaparte SC, Boutelle C, Wallace RM. Analysis of available animal testing data to propose peer-

derived quantitative thresholds for determining adequate surveillance capacity for rabies. Scientific Reports 2023;
13: 3986.
43 Extension of Temporary Suspension of Dogs Entering the United States from High-Risk Rabies Countries.

Federal Register, 88 FR 43570 (July 10, 2023).


maximum legal effect. Accordingly, HHS/CDC is adding language to ensure that, if this subpart

is held by a reviewing court of law to be invalid or unenforceable by its terms, or as applied to

any person or circumstance, the provision be construed so as to continue to give the maximum

effect to the provision permitted by law. If a reviewing court should hold that a provision is

utterly invalid or unenforceable, then HHS/CDC intends that the provision be severable from

Subpart F and not affect the remainder or the application of the provision to persons not similarly

situated or to dissimilar circumstances.

Changes to 71.51

Under this final rule, and after considering public comment received to the NPRM,

Section 71.51(a) now contains definitions that are specifically applicable to the importation of

dogs and cats under this section. HHS/CDC is adding the following definitions: animal, CDC-

registered Animal Care Facility, Certification of Foreign Rabies Vaccination and Microchip,

CDC Dog Import Form, Certification of U.S.-issued Rabies Vaccination, Certification of Dog

Arriving from DMRVV-free or DMRVV Low-risk Country, conditional release, confinement,

DMRVV, DMRVV-free countries, DMRVV high-risk countries, DMRVV low-risk countries,

DMRVV-restricted countries, flight parent, importer, SAFE TraQ, serologic testing, USDA-

Accredited Veterinarian, and USDA Official Veterinarian. In response to public comment, CDC

has modified the definition of importer and added definitions for “flight parent” and

“Certification of Dog Arriving from DMRVV-free or DMRVV Low-risk Country,” definitions that

were not in the NPRM. CDC has also added a definition for CDC Dog Import Permit, and

modified and shortened the names of the required rabies vaccination forms. CDC is removing the

current definition for Valid rabies vaccination certificate in 42 CFR 71.51 because other rabies

vaccination forms will now be required. CDC is also moving the definitions for cat and dog from

71.51(a) to 71.50(a).
In 71.51(b) through 71.51(d), HHS/CDC is finalizing the section as proposed with the

exception that U.S.-vaccinated dogs may enter through any U.S. port. CDC has a high degree of

confidence in USDA-licensed rabies vaccines administered in the United States; therefore, the

risk of a U.S.-vaccinated dog importing rabies when returning to the United States is very low.

CDC also has confidence in DMRVV-free countries that have declared themselves to be free of

canine rabies using WOAH’s self-declared validation process in which their surveillance and

vaccination data are available for external review. 44 Additionally, CDC has confidence in

DMRVV-free and low-risk countries which demonstrate adequate surveillance capacity and

vaccination control measures in accordance with CDC published metrics, but have not pursued a

WOAH self-declaration status.45,46 HHS/CDC is reducing the burden on importers of U.S.-

vaccinated dogs by allowing greater flexibility to be admitted through any U.S. port and is

finalizing as proposed the ability of importers of cats and dogs from DMRVV-free and low-risk

countries to be admitted through any U.S. port.

(b) Authorized U.S. airports for dogs and cats.

Section 71.51(b) is finalized as proposed with the exception that HHS/CDC is allowing

U.S.-vaccinated dogs to enter through any U.S. airport if the dog is six months of age,

microchipped, and accompanied by a valid Certification of U.S.-issued Rabies Vaccination form

and CDC Dog Import Form receipt. Dogs that have been only in DMRVV-free or DRMVV low-

risk countries during the last six months and all cats may also enter through any U.S. airport.47

44 World Organisation for Animal Health. Self-declared Disease Status. Available at: www.woah.org/en/what-we-
offer/self-declared-disease-status/.
45 Minhaj, F.S., Bonaparte, S.C., Boutelle, C. et al. Analysis of available animal testing data to propose peer-derived

quantitative thresholds for determining adequate surveillance capacity for rabies. Sci Rep 13, 3986 (2023).
https://doi.org/10.1038/s41598-023-30984-3
46 Henry RE, Blanton JD, Angelo KA, Pieracci EG, Stauffer K, et al. A country classification system to inform

rabies prevention guidelines and treatment. Journal of Travel Medicine, 2022;29(4):taac046. doi:
10.1093/jtm/taac046. PMID: 35348741.
47 There are no vaccination requirements for dogs that have been only in DMRVV-free or DRMVV low-risk

countries during the last six months.


Foreign-vaccinated dogs that have been in any DMRVV high-risk country within the last six

months must enter through a U.S. airport with a CDC quarantine station and an ACF.

(c) Authorized U.S. land ports for dogs and cats.

Section 71.51(c) has been finalized as proposed with the exception that HHS/CDC is

allowing U.S.-vaccinated dogs that have been in a DMRVV high-risk country in the past six

months to enter through any U.S. land port if the dog is six months of age, microchipped, and

accompanied by a valid Certification of U.S.-issued Rabies Vaccination form and CDC Dog

Import Form receipt. Dogs that have been only in DMRVV-free or DRMVV low-risk countries

during the last six months and all cats may enter through any U.S. land port.

(d) Authorized U.S. seaports for dogs and cats.

Section 71.51(d) has been finalized as proposed with the exception that HHS/CDC is

allowing U.S.-vaccinated dogs that have been in a DMRVV high-risk country in the past six

months to enter through any U.S. seaport if the dog is six months of age, microchipped, and is

accompanied by a valid Certification of U.S.-issued Rabies Vaccination form and a CDC Dog

Import Form receipt. Dogs that have been only in DMRVV-free or DRMVV low-risk countries

during the last six months and all cats may enter through any U.S. seaport.

HHS/CDC is finalizing as proposed the prohibition of entry into the United States

through a U.S. seaport for unvaccinated or foreign-vaccinated dogs that have been in a DMRVV

high-risk country within the last six months with an exception for dogs meeting the definition of

a “service animal” under 14 CFR 382.3. This final rule allows entry if a foreign-vaccinated dog

that has been in a DMRVV high-risk country within the last six months accompanies an

“individual with a disability” as defined under 14 CFR 382.3. The dog must meet all other CDC

requirements for admission of a foreign vaccinated dog from a high-risk country, including that

it be microchipped, at least six months of age, have a valid Certification of Foreign Rabies
Vaccination and Microchip form, a valid serologic titer from a CDC-approved laboratory, and a

CDC Dog Import Form receipt.

(e) Limitation on U.S. ports for dogs and cats.

Section 71.51(e) is finalized as proposed with the exception that HHS/CDC is clarifying

that CBP will prescribe the time, place, and manner in which dogs are presented upon arrival at a

port of entry, which may include prohibiting dogs from being presented within the Federal

Inspection Station. This provision of the final rule also explicitly authorizes the CDC Director to

limit the times, U.S. ports, and/or conditions under which dogs or cats may arrive at and be

admitted to the United States based on an importer’s or carrier’s failure to comply with the

provisions of this section or as needed to protect the public’s health. If the CDC Director

determines such a limitation is required, the CDC Director will notify importers or carriers in

writing of the specific times, U.S. ports, and/or conditions under which dogs and cats may be

permitted to arrive at and be admitted to the United States. This provision is applicable to all

U.S. ports, including land, sea, and air.

(f) Age requirement for all dogs.

Section 71.51(f) is finalized as proposed with the exception that HHS/CDC removed the

exemption for importers to import up to three dogs under six months of age at U.S. land borders

if arriving from DMRVV-free or DMRVV low-risk countries. This provision of the final rule

requires that all dogs arriving into the United States (regardless of whether from DMRVV-free,

DMRVV low-risk, or DMRVV high-risk countries) at air-, land-, and seaports be, at minimum,

six months of age. As explained in further detail below, HHS/CDC originally proposed a limited

exemption for dogs under six months old primarily to reduce the burden on U.S. travelers who

frequently travel across the U.S. and Canada/Mexico borders and choose to travel with young

dogs. However, upon further consideration and careful evaluation of the comments received,
HHS/CDC has removed the exemption proposed in the NPRM to create a uniform standard for

all dogs, ensure U.S.-land borders are not overwhelmed with dog importations, and reduce the

risk of importers fraudulently claiming that their dog has not been in DMRVV high-risk country.

(g) Microchip requirements for all dogs.


Section 71.51(g) is finalized as proposed with the exception that HHS/CDC is clarifying

that an imported dog’s microchip must have been implanted on or before the date the most recent

rabies vaccine was administered. Rabies vaccines administered prior to the implantation of an

imported dog’s microchip are invalid. HHS/CDC is making this clarification to ensure that the

dog receiving the rabies vaccine is properly identified by the microchip. Through this final rule,

HHS/CDC is requiring that all dogs have an International Standards Organization (ISO)-

compliant microchip prior to arrival in the United States or prior to traveling out of the United

States and returning.

(h) CDC Dog Import Form for all dogs.

Section 71.51(h) is finalized as proposed. This provision of the final rule requires that

importers submit a CDC Dog Import Form (OMB Control Number 0920-1383; expiration date

04/30/2027) (formerly referred to as the CDC Import Submission Form) via a CDC-approved

system for each imported dog. The CDC Dog Import Form must be submitted to CDC prior to a

dog’s departure from the foreign country. The CDC Dog Import Form receipt must be presented

to the airline prior to boarding and to Federal officials upon arrival.

(i) Inspection requirements for admission of dogs and cats.

Section 71.51(i) is finalized as proposed. This final rule requires that dogs and cats may

be denied admission if an importer refuses to consent to required inspection, examination,

diagnostic testing, or disease surveillance screening.


(j) Examination by a USDA-Accredited Veterinarian and confinement of exposed dogs and cats

or those that appear unhealthy.

Section 71.51(j) is finalized as proposed with minor reorganization of the paragraph. This

final rule requires that, in the event a dog or cat arrives ill, is denied admission, or is exposed to a

sick animal in transit,48,49 the airline must arrange for confinement in an ACF or CDC-approved

veterinary clinic (if an ACF is not available or is unable to adequately care for the ill or injured

animal) and transport to the facility in a way that does not expose transportation personnel or the

public to communicable diseases. This provision may also be applied to other carriers

transporting dogs and cats in the rare circumstances where it is necessary for public health

reasons to require that the carrier arrange for examination and confinement. The importer bears

the expenses of transportation, confinement, examination, testing, and treatment. The final rule

further clarifies an airline’s responsibilities in the event an importer abandons a dog or cat. If an

importer fails to pay for such expenses, then the animal may be considered abandoned, and the

airline will be required to assume financial responsibility.

(k) Veterinary examination, revaccination against rabies, and quarantine at a CDC-registered

animal care facility for foreign-vaccinated dogs.

Section 71.51(k) is finalized as proposed with the exception that the paragraph name has

been modified to reflect all the required components of the paragraph. However, the

requirements within the paragraph have not changed. HHS/CDC is clarifying that suspected or

confirmed communicable diseases need only be reported to CDC. Additional notification of

Federal, state, and local public health partners will be done by CDC. HHS/CDC now requires

48 National Association of State Public Health Veterinarians. Compendium of animal rabies prevention and control,
2016. JAVMA 2016; 248 (5):505-517.
49 Manning SE, Rupprecht CE, Fishbein D, et al. Human rabies prevention—United States, 2008: recommendations

of the Advisory Committee on Immunization Practices. MMWR Recomm Rep 2008;57(RR-3):1–28.


that all foreign-vaccinated dogs arriving from DMRVV high-risk countries have a valid

Certification of Foreign Rabies Vaccination and Microchip form and undergo veterinary

examination and revaccination against rabies at an ACF upon arrival. The importer is responsible

for making a reservation and all arrangements relating to the examination, revaccination, and

quarantine (if quarantine is required) of dogs with an ACF prior to the dogs’ arrival in the United

States.

Airlines must deny boarding to dogs if the importer fails to present a receipt of the

completed CDC Dog Import Form (OMB Control Number 0920-1383; expiration date

04/30/2027) and confirmation of a reservation at an ACF. The costs of examination, vaccination,

and quarantine (if required) are the responsibility of the importer and not the United States

Government. Animals that are abandoned before meeting requirements outlined below become

the legal responsibility of the airline.

This final rule further requires that the dogs remain in the custody of an ACF until all of

the following requirements are met:

• Veterinary health examination by a USDA-Accredited Veterinarian for signs of disease.

Suspected or confirmed communicable or foreign animal diseases would be required to

be reported to CDC and may delay release of the animals.

• Confirmation of microchip number.

• Confirmation of age through dental examination by a USDA-Accredited Veterinarian.

• Vaccination against rabies with a USDA-licensed rabies vaccine and administered by a

USDA-Accredited Veterinarian.

• Verification of adequate rabies serologic test from a CDC-approved laboratory. To be

considered valid, serologic tests must be drawn prior to arrival within an established

timeframe and display results within parameters as specified in CDC technical

instructions.50 Dogs that arrive without an adequate rabies serologic test results from a

50 CDC technical instructions are posted on CDC’s website at www.cdc.gov/dogtravel.


CDC-approved laboratory will be housed at the ACF for a 28-day quarantine following

administration of the USDA-licensed rabies vaccine or until an adequate rabies serologic

test from a CDC-approved laboratory is confirmed.

(l) Registration or renewal of CDC-registered animal care facilities.

HHS/CDC is finalizing section 71.51(l) as proposed with the exception that CDC may

conduct inspections of ACF which will be guided by the USDA Animal Welfare regulation

standards (9 CFR parts 1, 2, and 3) and other standards outlined in CDC’s Technical Instructions

for CDC-registered Animal Care Facilities. Failure to adhere to standard operating procedures

(SOP) requirements as outlined in USDA Animal Welfare regulation standards or CDC’s

Technical Instructions for CDC-registered Animal Care Facilities would constitute grounds for

not registering or renewing an ACF’s registration.

Per this final rule, HHS/CDC is requiring that an animal care facility register with and

receive written approval from CDC, USDA, and CBP to submit their facility application before

housing any imported live dog in the United States. The applicant must provide written SOP

outlining how CDC’s regulatory requirements will be met and the health and safety of animals

and staff will be ensured. A copy of all Federal, State, or local registrations, licenses, or permits

will also be required to be submitted to CDC. Additionally, HHS/CDC requires the facility to

have a USDA intermediate handlers registration (and any other licenses or registrations required

by USDA) and a FIRMS code issued by CBP.

This section has been finalized as proposed with the clarification that an ACF must be

located within 35 miles of a CDC quarantine station. The facility is subject to inspection by CDC

at least annually and required to renew their registration every two years. Animal health records,

facilities, vehicles, or equipment to be used in receiving, examining, and processing imported

animals are also subject to inspection.


(m) Record-keeping requirements at CDC-registered animal care facilities.

Section 71.51(m) is finalized as proposed with the exception that the section references a

document other than a bill of lading if the airline has been granted a waiver to the bill of lading

requirement under paragraph (dd). The waiver to the bill of lading requirement is discussed more

fully in explanation text to section (dd). Per this final rule, HHS/CDC requires that any ACF

retain records regarding each imported animal for three years after the distribution or transfer of

the animal. Records must be uploaded into CDC’s System for Animal Facility Tracking during

Quarantine (SAFE TraQ) and completed prior to the animal’s release from the facility.

HHS/CDC is clarifying that records for necropsy results should be uploaded into SAFE TraQ

within 30 days of an animal’s death. Each record must include:

• The bill of lading (or other alternative documentation if the airline has been granted a

waiver under paragraph (dd)) for each shipment;

• The name, address, phone number, and email address of the importer and owner (if

different from the importer);

• The number of animals in each shipment;

• The identity of each animal in each shipment, including name, microchip number, date of

birth, sex, breed, and coloring;

• The airline, flight number, date of arrival, and port of each shipment; and

• Veterinary medical records for each animal, including:

▪ Certification of Foreign Rabies Vaccination and Microchip form (OMB

Control Number 0920-1383; expiration date 04/30/2027) and rabies

serology obtained before arrival in the United States (if applicable);

▪ The USDA-licensed rabies vaccine administered upon arrival;

▪ Veterinary exam records upon arrival and while in quarantine;

▪ Rabies serology performed while in quarantine in the United States (if

applicable); and
▪ All diagnostic test, histopathology and necropsy results performed during

quarantine (if applicable).

The facility is required to maintain these records electronically and allow CDC to inspect the

records.

(n) Worker protection plan and personal protective equipment (PPE).

Section 71.51(n) is finalized as proposed with the exception that HHS/CDC is noting that

procedures for reporting suspected or confirmed communicable diseases associated with

handling animals in facility workers must be reported to CDC within 48 hours. This requirement

was included in the NPRM in paragraph (q) and has been moved to paragraph (n) for clarity.

Today’s final rule requires that an ACF establish and maintain a worker protection plan with

standards comparable to those in the Occupational Safety and Health Administration’s

Recommended Practices for Safety and Health Programs51 and the National Association of

Public Health Veterinarians (NASPHV) Compendium of Veterinary Standard Precautions for

Zoonotic Disease Prevention in Veterinary Personnel.52 Such a worker protection plan must

include rabies pre-exposure prophylaxis consistent with CDC guidance53 for workers who handle

imported animals with signs of illness or in quarantine, and for staff who perform necropsies of

imported animals; post-exposure procedures that provide potentially exposed workers with direct

and rapid access to a medical consultant; and procedures for documenting the frequency of

worker training, including for those working in the quarantine area. As part of the worker

protection plan, a facility must also establish, implement, and maintain hazard evaluation and

worker communication procedures that include descriptions of the known communicable disease

and injury hazards associated with handling animals, the need for PPE when handling animals

51 https://www.osha.gov/safety-management.
52 http://www.nasphv.org/Documents/VeterinaryStandardPrecautions.pdf.
53 CDC. Rabies pre-exposure prophylaxis recommendations. Available at: www.cdc.gov/rabies/prevention/pre-

exposure_vaccinations.html.
and training in the proper use of PPE, and procedures for disinfection or safe disposal of

garments, supplies, equipment, and waste.

(o) CDC-registered animal care facility standard operating procedures, requirements, and

equipment standards for crating, caging, and transporting live animals.

Section 71.51(o) is finalized as proposed and requires that equipment standards for

crating, caging, and transporting live animals must be in accordance with USDA Animal Welfare

regulation standards (9 CFR parts 1, 2, and 3) and International Air Transport Association

standards.54 Animals must not be removed from crates during transport, and used PPE, bedding,

and other potentially contaminated material must be removed from the ground transport vehicle

upon arrival at the ACF and disposed of or disinfected in a manner that would destroy potential

pathogens of concern.

(p) Health reporting and veterinary service requirements for animals at CDC-registered animal

care facilities.

Section 71.51(p) is finalized as proposed with the exception that HHS/CDC may allow

veterinarians to confirm the age of a dog using alternative methods approved by CDC, such as

ocular lens examination or radiographs. Additionally, HHS/CDC is clarifying that if an animal is

suspected of having a communicable disease, it must be immediately isolated and CDC-

registered ACF must implement infection prevention and control measures in accordance with

industry standards and CDC technical instructions. HHS/CDC is clarifying that suspected or

confirmed communicable diseases need only be reported to CDC and not to other public health

entities. Additional notification of Federal, State, and local public health partners will be done by

International Air Transport Association. Live Animals. https://www.iata.org/en/programs/cargo/live-animals.


54

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CDC. HHS/CDC also notes the paragraph name has been modified to reflect all the required

components of the paragraph. However, the requirements within the paragraph have not

changed. Today’s final rule establishes health reporting requirements for all dogs evaluated at an

ACF. Under this provision, a facility must provide the following services for each dog from a

DMRVV high-risk country with a foreign-issued rabies vaccine upon arrival and ensure each

animal meets CDC, USDA, and State and local entry requirements prior to release from the

facility:

• Veterinary examination by a USDA-Accredited Veterinarian within one business day of

arrival;

• Verification of microchip and confirmation that the microchip number matches the

animal’s health records;

• Verification of animal’s age via a dental examination (or other CDC-approved method);

• Vaccination against rabies using a USDA-licensed vaccine; and

• Confirmation of an adequate serologic test from a CDC-approved laboratory OR

completion of a 28-day quarantine after administration of the USDA-licensed rabies

vaccine.

This provision also requires that the facility notify CDC within 24 hours of the

occurrence of any morbidity or mortality of animals in the facility. Any animal that dies during

transport or while in quarantine at a ACF is required to undergo a necropsy and diagnostic

testing to determine the cause of death. An animal that arrives ill or becomes ill while at the ACF

must be examined by a USDA-Accredited Veterinarian immediately and must undergo

diagnostic testing to determine the cause of illness prior to release from the facility. Suspected or

confirmed communicable diseases in animals must be reported to CDC within 24 hours of

identification.

(q) Quarantine requirements for CDC-registered animal care facilities.


Section 71.51(q) is finalized as proposed with the exception that HHS/CDC is clarifying

that quarantined animals must be housed in such a manner that they do not expose other

quarantined animals or non-quarantined animals (including animals other than dogs or cats).

Additionally, animals in quarantine may not be housed together even if they were transported as

part of the same shipment. After consideration of public comments, this final rule establishes

requirements for the quarantine area at ACF to ensure animals are safely housed and do not

present a public health risk to humans or other animals. These requirements include security

measures within the facility to prevent unintended public exposure to quarantined animals,

limited access to animal quarantine areas, monitoring animals for signs of any communicable

illness, and timely notification of CDC of animals that becomes ill during quarantine.

Additionally, suspected or confirmed communicable diseases in animals or facility workers must

be reported to CDC. ACF must also establish standard operating procedures for safe handling

and necropsy of any animal that dies in quarantine.

(r) Revocation and reinstatement of a CDC-registered animal care facility's registration.

Section 71.51(r) is finalized as proposed with the exception that it explicitly references

the ability of the Secretary to review a CDC revocation of an ACF registration if the Secretary so

chooses. The Secretary has authority to act as final arbiter and review the CDC Director’s

decisions relating to animal importations if the Secretary so chooses.

Section 71.51(r) establishes procedures to revoke an ACF’s registration if the Director

determines that it has failed to comply with any applicable provisions of this section, including

failure to abide by the facility’s standard operating procedures, USDA Animal Welfare

regulation standards (9 CFR parts 1, 2, and 3), or the International Air Transport Association

standards.55 Under the terms of this provision, CDC will send the facility a notice of revocation

International Air Transport Association. Live Animals. https://www.iata.org/en/programs/cargo/live-animals.


55

Accessed June 7, 2023.


stating the grounds upon which the proposed revocation is based. If the facility contests the

revocation, the facility may file a written response to the notice within five business days. All the

grounds listed in the proposed revocation will be deemed admitted if the facility does not

respond within five business days, in which case CDC’s notice of revocation will constitute final

agency action, unless the Secretary, within one business day, decides to excuse the facility’s

failure to respond on a timely basis.

If a facility’s response is timely, the Director will review the registration, the notice of

revocation, and the response. As soon as practicable after completing the written record review,

the Director will issue a decision in writing that shall constitute final agency action, unless the

Secretary, within one business day, decides to review the Director’s decision. The Director will

provide the facility with a copy of the written decision. The Director, in the Director’s discretion,

may reinstate a revoked registration after inspecting the facility, examining its records,

conferring with the facility, and receiving information and assurance from the facility of

compliance with the requirements of this section.

(s) Requirement for the Certification of Foreign Rabies Vaccine and Microchip form to import a

foreign-vaccinated dog from DMRVV high-risk countries.

Section 71.51(s) is finalized as proposed with the exception that HHS/CDC shortened the

name of the form to the Certification of Foreign Rabies Vaccine and Microchip (OMB Control

Number 0920-1383; expiration date 04/30/2027). Through this final rule, HHS/CDC is requiring

a new, standardized rabies vaccination form for all foreign-vaccinated dogs that have been in any

DMRVV high-risk countries within the last six months. In addition to details about the dog,

importer, and veterinarian, the form must be completed by an Authorized Veterinarian that

examined the dog in the exporting country and certified by an official government veterinarian

attesting that the authorized veterinarian is licensed or authorized to practice veterinary medicine
in the exporting country. The authorized veterinarian and the official government veterinarian

must further attest that the information listed on the form is true and correct.

(t) Requirement for Certification of U.S.-Issued Rabies Vaccination Form for importers seeking

to import U.S.-vaccinated dogs from DMRVV high-risk countries.

Section 71.51(t) is finalized as proposed with the exception that HHS/CDC shortened the

name of the form to the Certification of U.S.-Issued Rabies Vaccination (OMB Control Number

0920-1383; expiration date 04/30/2027). HHS/CDC now requires that U.S.-vaccinated dogs re-

entering the United States from DMRVV high-risk countries be accompanied by a Certification

of U.S.-issued Rabies Vaccination Form. The form must be completed by a USDA-Accredited

Veterinarian and endorsed by a USDA Official Veterinarian prior to the dog departing the United

States. People who leave the United States with their dogs without first obtaining this form will

be required to have their dogs re-enter the United States as if they are foreign-vaccinated dogs

and be required to meet all the requirements as outlined in section (s) for the dogs to be eligible

for re-entry from a DRMVV high-risk country.

(u) Requirement for proof that a dog has been only in DMRVV low-risk or DMRVV-free

countries.

Section 71.51(u) is finalized as proposed with the exception that, based on public

comment, CDC is now including a list of acceptable documents importers may provide to

confirm a dog has been only in DMRVV low-risk or DMRVV-free countries during the last six

months before arriving in the United States. This list includes a valid USDA export certificate, a

valid foreign export certificate, a valid Certification of Dog Arriving from DMRVV-free or

DMRVV Low-risk Country form, or other records or documents satisfactory to the Director.

Importers may also provide proof of rabies vaccination, which is recommended but not required
for dogs arriving from DMRVV-free or DMRVV low-risk countries, using the Certification of

Foreign Rabies Vaccination and Microchip form or the Certification of U.S.-Issued Rabies

Vaccination form. All forms must be endorsed by an official government veterinarian to be

considered valid. Certification of Foreign Rabies Vaccination and Microchip forms must be

endorsed by an official government veterinarian in a DMRVV-free or DMRVV low-risk country

to be used as proof that a dog has been only in DMRVV low-risk or DMRVV-free countries.

Importers should contact their local veterinarian who can submit the required form to an official

government veterinarian in the exporting country. Importers may also use the USDA pet travel

website or IPATA website to contact a pet shipper to request assistance.56,57 The list of

acceptable documents is also located on CDC’s website. This final rule requires that dogs

imported from DMRVV low-risk or DMRVV-free countries be accompanied by appropriate

written documentation demonstrating that they have been only in DMRVV low-risk or DMRVV-

free countries during the last six months. The documentation must also confirm that the dog is at

least six months of age and is microchipped. There have been no changes made for cat rabies

vaccination importation requirements. Instead, CDC continues to recommend that importers

comply with State or Territorial requirements for rabies vaccination in cats and dogs from

DMRVV-free or DMRVV low-risk countries.

(v) Denial of admission of dogs and cats.

Section 71.51(v) is finalized as proposed with the exception that HHS/CDC may

additionally deny entry to an animal if an importer refuses to comply with CDC-required

diagnostic tests to rule out communicable diseases. Diagnostic tests are crucial to determine the

cause of an illness and ensure the animal does not pose a public health threat. This section also

references alternative documentation to a bill of lading if the airline has been granted a waiver to

56 USDA Pet Travel. www.aphis.usda.gov/pet-travel/us-to-another-country-export.


57 International Pet and Animal Transportation Association. www.ipata.org.
the requirement that it create a bill of lading for dogs prior to the dogs’ arrival in the United

States.

This section outlines the categories of dogs and cats that are inadmissible to the United

States. CDC will coordinate with CBP to enforce this action whenever CDC determines that an

animal is inadmissible. This includes:

• Any dog arriving from a DMRVV low-risk or DMRVV-free country without written

documentation that the dog has been only in DMRVV low-risk or DMRVV-free

countries during the six months prior to the attempted entry, or if the CDC Director

reasonably suspects fraud.

• Any dog that is not accompanied by a receipt confirming that a CDC Dog Import Form

has been submitted to CDC through a CDC-approved system.

• Any dog arriving by air for which a bill of lading, including an air waybill, has not been

created by the airline prior to the dog’s arrival in the United States (regardless of the

value of the shipment) unless the airline transporting the dog has been granted a waiver

pursuant to paragraph (dd) and the airline’s handling and transport of the dog is

consistent with the terms of that waiver.

• Any unvaccinated or foreign-vaccinated dog arriving at a U.S. land port that has been in a

DMRVV high-risk country within the last six months prior to the attempted entry.

• Any unvaccinated or foreign-vaccinated dog arriving at a U.S. seaport that has been in a

DMRVV high-risk country within the last six months prior to the attempted entry, except

for a dog qualifying as a service animal that is otherwise admissible under section (d).

• Any foreign-vaccinated dog that has been in a DMRVV high-risk country within the last

six months and does not arrive at a U.S. airport with a CDC quarantine station and an

ACF.

• Any animal imported by an importer who refuses to comply with the requirement (if

applicable) for the animal to undergo disease surveillance screening, veterinary


examination, revaccination, diagnostic testing, provide proof of sufficient rabies serologic

tests, or quarantine at an ACF upon arrival.

• Any dog that has been in a DMRVV high-risk country within the last six months and

arrives without a valid Certification of U.S.-Issued Rabies Vaccination form or a valid

Certification of Foreign Rabies Vaccination and Microchip form.

• Any foreign-vaccinated dog imported from a DMRVV high-risk country that arrives

without a reservation at an ACF.

• Any dog from a DMRVV-restricted country that arrives without a valid CDC Dog Import

Permit.

• Any dog imported from a DMRVV high-risk, DMRVV low-risk, or DMRVV-free

country if the CDC Director reasonably suspects fraud in any documentation required for

admission or if such documentation is otherwise untruthful, inaccurate, or incomplete.

• Any dog or cat, regardless of country of departure, that poses a public health risk,

including dogs or cats that appear unhealthy upon arrival or demonstrate signs or

symptoms of communicable disease.

• Any dog arriving in the United States that is under six months of age.

• Any dogs arriving in the United States without a microchip or without their microchip

number documented on the importation paperwork required by CDC.

(w) Dogs and cats awaiting an admissibility determination or return to their country of departure.

HHS/CDC has split section 71.51(v) as written in the NPRM into two sections for ease of

reading and greater clarity. Section 71.51(w) is a new paragraph, but the final requirements in

section 71.51(w) were included in the NPRM under section 71.51(v). These requirements are

finalized as proposed with the exception that based on public comment CDC is changing the

timeframe for airlines to transport a healthy animal to an ACF or another CDC-approved facility
(if an ACF is not available) from 6 hours to 12 hours. However, airlines must arrange to

transport an obviously ill or injured animal immediately.

Animals arriving by air must be held in an ACF or another CDC-approved facility (if an ACF

is not available) pending an admissibility determination or pending return to their country of

departure if denied admission. As finalized, airlines must transport healthy animals to a ACF or

other CDC-approved facility (if an ACF is not available) within 12 hours of arrival.

An airline must immediately report an obviously ill or injured animal (e.g., the animal is

unable to stand, has difficulty breathing, is bleeding, has broken bones or disfigured limbs, or is

experiencing seizures, vomiting, or discharge from the nose, mouth, or eyes) arriving into the

United States to the CDC quarantine station of jurisdiction. As finalized, the airline must

immediately arrange to transport an obviously ill or injured animal to an ACF or veterinary clinic

as directed by HHS/CDC.

Animals arriving by sea that are denied admission must remain on the vessel while

awaiting return to the country of departure.

(x) Disposal or disposition of dogs and cats denied admission or abandoned prior to admission

that were transported to the United States.

Section 71.51(x) is finalized as proposed. HHS/CDC has developed an operational

framework primarily applicable to airlines regarding how dogs denied admission will be handled

by carriers and importers. HHS/CDC clarifies that airlines must provide housing for animals

awaiting return to their country of departure at an ACF or a CDC-approved animal facility if an

ACF is not available. Airlines are required to return animals denied admission to the country of

departure within 72 hours of arrival, regardless of carrier or route. This is to ensure airlines do

not leave animals in warehouses unattended for prolonged periods of time. Airlines are able to

request extensions for an animal’s return in the event the animal is not medically fit for travel.

This operational framework provides that importers are responsible for all associated costs
relating to the housing, care, and treatment of a dog or cat denied admission pending return to its

country of departure. However, if an importer fails to pay any costs or fails to comply with any

requirements, the animal will be considered abandoned, and the relevant carrier would be

required to assume responsibility.

Under this framework, in instances where a dog or cat is fatally ill or injured, the

importer or airline may choose a humane euthanasia option in accordance with the standards of

the American Veterinary Medical Association58 performed by a licensed veterinarian. The

importer or airline must notify CDC and CBP in writing of this decision. This decision does not

relieve the importer or airline of the obligation to obtain and report results of necropsy or

diagnostic testing required by CDC.

In the case of dogs and cats denied admission to the United States upon arrival at a U.S.

seaport, the vessel’s master or operator would be required to reembark the animal immediately

and return it to its country of departure on the next voyage. In the case of dogs and cats denied

admission to the United States upon arrival at a U.S. land port, the importer or carrier would be

required to immediately return it to its country of departure.

HHS/CDC does not expect the above operational framework relating to housing, care,

and treatment of a dog or cat denied admission to be applied on a routine basis to carriers or

importers arriving with dogs or cats at U.S. land or seaports because the circumstances leading to

a delay in returning a dog or cat to its country of departure are not typically present at these U.S.

ports. However, HHS/CDC acknowledges that there may be rare and unforeseen circumstances

where it may be necessary to apply such procedures. Accordingly, HHS/CDC has added

language authorizing it to apply these provisions in circumstances where a dog or cat is denied

entry at a U.S. land or seaport and cannot be immediately returned to its country of departure

(e.g., because it is unfit to travel). Section 71.51(x) is finalized as proposed.

58 https://www.avma.org/resources-tools/avma-policies/avma-guidelines-euthanasia-animals.
(y) Appeals of CDC denials to admit a dog or a cat upon arrival into the United States.

Section 71.51(y) is finalized as proposed with the exception that it explicitly references

the ability of the Secretary to review a CDC decision to deny admission to dogs and cats if the

Secretary so chooses. The Secretary has authority to act as final arbiter and review the CDC

Director’s decisions relating to animal importations if the Secretary so chooses. This section

outlines the appeal process for importers of dogs and cats in the event their animals are denied

admission to the United States upon arrival.

Because denial of admission to dogs and cats under these limited circumstances is likely

to occur at a port, HHS/CDC requires that any appeal be submitted to CDC within one business

day so as not to unnecessarily prolong the appeal process and allow for expedited decision-

making regarding whether an animal should be returned to its country of departure. Instructions

on how to submit an appeal are included in the regulatory text. Pending a determination

regarding the appeal the animal will remain the legal responsibility of the carrier. The Director

will issue a written response to the appeal, which shall constitute final agency action, unless the

Secretary, within one business day, decides to review the Director’s decision.

(z) Record of death of dogs and cats while en route to the United States and disposition of dead

animals.

Section 71.51(z) is finalized as proposed. The requirement that carriers maintain a record

of sickness or death for any animals that die during transit is longstanding. Through this final

rule, HHS/CDC will now require necropsy and diagnostic testing for any dog or cat that dies en

route to the United States or at a U.S. port prior to admission to determine the cause of death.

Consistent with current requirements, carriers would be required to report deaths to the CDC

quarantine station of jurisdiction. HHS/CDC is including these amendments to ensure it can

detect, provide referrals to appropriate agencies, and respond to potential communicable disease

importation risks in a timely manner. Importers are responsible for the costs unless they abandon
the animal, in which case the airline or master or operator of a vessel will assume responsibility

for the costs.

(aa) Abandoned shipments of dogs and cats.

Section 71.51(aa) is finalized as proposed. Through this final rule, HHS/CDC is

providing an operational framework primarily applicable to airlines for when a dog or cat would

be considered abandoned prior to admission and thus require the carrier to assume responsibility

for the shipment.

The provisions of Section 71.51(aa) may also be applied to other carriers transporting

such dogs and cats in the rare circumstances where the dog or cat is abandoned by the importer at

a U.S. land port or seaport and other options are not available.

(bb) Sanitation of cages and containers of dogs and cats.

Section 71.51(bb) is finalized as proposed. This section requires that cages or other

containers of animals arriving in the United States be cleaned and disinfected or the animals

removed and placed in clean containers if the cages or other containers constitute a

communicable disease risk.

(cc) Requirements for in-transit shipments of dogs and cats.

Section 71.51(cc) is finalized as proposed. Under today’s final rule, CDC’s definition of

an “in-transit shipment” now aligns with that of the USDA. This provision further clarifies that

dogs and cats can only be considered in-transit if they are transported as cargo and not as hand-

carried baggage or checked baggage. In-transit shipments may only be transported as cargo.

HHS/CDC is also clarifying that a microchip is not required for dogs that are transported by

aircraft and are being transited through the United States if retained in the custody of the airline.
(dd) Bill of lading and other airline requirements for dogs

Section 71.51(dd) has been finalized as proposed with the exception that airlines that lack

the technical ability to generate a bill of lading (including an air waybill (AWB)) to transport

dogs may request a waiver from CDC and provide a SOP outlining how they will ensure care for

any ill, injured, or abandoned animals or animals denied entry in the absence of an AWB. This

final rule requires that airlines create a bill of lading accounting for all live dog imports through a

U.S. airport, regardless of whether the dogs are transported as cargo, checked baggage, or hand-

carried baggage, or otherwise accompany a traveler arriving in the United States on their person.

As a condition of granting a waiver to the bill of lading requirement, HHS/CDC may

require the airline to work with a broker to file the appropriate paperwork and identify suitable

housing accommodations (such as an ACF or a local kennel approved by CDC and CBP) for any

dogs detained pending admissibility. The SOP must include the location of an ACF or other

suitable alternative approved by CBP and CDC prior to transport of animals. HHS/CDC may

require the airline to submit documentation outlining a timetable and steps that will be taken to

develop the technical capacity to generate an AWB (or another suitable alternative to an AWB)

to transport dogs. CDC has provided additional details for airlines seeking exemption for the

AWB requirement in technical instructions available on CDC’s website at

www.cdc.gov/dogtravel.

Section 71.51(dd) also requires that airlines confirm that all importers have a receipt of a

completed CDC Dog Import Form prior to boarding. For U.S.-vaccinated dogs that have been in

a DMRVV high-risk country within the last six months, CDC requires that airlines confirm that

importers have a valid Certification of U.S.-issued Rabies Vaccination form. For foreign-

vaccinated dogs that have been in a DMRVV high-risk country within the last six months,

airlines must confirm that importers have a reservation at an ACF. For dogs from DMRVV-free

or DMRVV low-risk countries, HHS/CDC will require that airlines confirm that the importer has

documentation as outlined in paragraph (u) showing that the dog is over six months of age, has a
microchip, and has been only in DMRVV-free or DMRVV low-risk countries within the last six

months.

Finally, section 71.51(dd) requires that a representative of an airline transporting live

dogs into the United States be on-site at the U.S. airport and available to coordinate the

entry/clearance of the dogs with Federal government officials until all live dogs transported on

an arriving flight into the United States have either been cleared for admission, arrangements

have been made to transport the dogs to an ACF or other facility (e.g., veterinary clinic or

kennel) approved by CDC pending admissibility determination, or arrangements have been made

for return of dogs not meeting CDC entry requirements.

(ee) Order prohibiting carriers from transporting dogs and cats.

Section 71.51(ee) is finalized as proposed. This final rule outlines procedures for the

CDC Director to issue an order revoking a carrier’s permission to transport live dogs and cats

into the United States if a carrier has endangered the public health of the United States by acting

or failing to act to prevent the introduction of DMRVV, as would occur by failing to comply

with the provisions of this section.

(ff) Prohibition on imports of dogs from DMRVV-restricted countries.

Section 71.51(ff) is finalized as proposed. This section of the final rule explicitly states

that HHS/CDC may prohibit or otherwise restrict the import of dogs into the United States from

certain countries that have repeatedly exported rabid dogs to any country or that lack adequate

controls to monitor and prevent the export of dogs to the United States with falsified or

fraudulent rabies vaccine credentials, invalid rabies vaccination forms, or other fraudulent,

inaccurate, or invalid exportation/importation documents. Such a prohibition or other restriction

will remain in place until there is sufficient evidence for CDC to be assured that adequate

controls have been established to prevent the reintroduction of DMRVV into the United States,
including preventing the use of falsified or fraudulent vaccine credentials. To implement this

provision HHS/CDC will maintain a list of DMRVV-restricted countries. The list will be

maintained on CDC’s website at www.cdc.gov/importation/bringing-an-animal-into-the-united-

states/high-risk.html and updated annually. Amendments to the list of DMRVV-restricted

countries will be published as a notice in the Federal Register. HHS/CDC may allow the

importation of certain categories of dogs from DMRVV-restricted countries, such as service

animals or government-owned animals.

(gg) Request for issuance of additional fines or penalties.

Section 71.51(gg) is finalized as proposed with the exception that CDC is adding

language informing the public that it may also refer potential violations of Federal law to the

U.S. Department of Justice for investigation, and based on the results of such investigation,

prosecution. Specifically, CDC may refer a matter to the U.S. Department of Justice if the

Director has reason to believe that an individual or organization has violated Federal law,

including by forcibly assaulting, resisting, opposing, impeding, intimidating, or interfering with a

U.S. government employee while engaged in or on account of the performance of their official

duties in violation of 18 U.S.C. 111, by obstructing an agency proceeding in violation of 18

U.S.C. 1505, or by otherwise engaging in conduct contrary to law. This provision also serves to

inform the public of actions that CDC may take to request DHS/CBP assistance in enforcing

HHS/CDC’s dog and cat importation requirements. HHS/CDC stresses that it does not

administer Title 19, and decisions regarding whether to pursue enforcement actions under Title

19 would be entirely at the discretion of DHS/CBP and subject to its policies and procedures.

IV. Alternatives Considered

In developing this final rule, HHS/CDC considered more and less costly policy

alternatives. The provisions included in the final rule were determined to minimize the cost and
burden of the regulatory provisions while protecting and reducing risks to the public’s health. To

reduce the costs associated with the provisions of the final rule, many requirements only apply to

dogs imported from DMRVV high-risk countries, and some apply only to dogs vaccinated

outside the United States imported from DMRVV high-risk countries.

Table 1 summarizes alternatives to selected requirements expected to be associated with

most of the monetized costs and benefits for this rule relative to the current status quo. A

quantitative analysis of the costs and benefits is available in an Appendix found in the

Supplemental Materials tab of the docket and summarized in Section VII(A).


Table 1. Summary table of important changes to regulatory requirements based on the
provisions of this final rule and alternatives considered

final rule Current Option 1- Option 2- Justification


requirement requirements59 Higher-cost Lower-cost
alternative alternative
(baseline)

§ 71.51(f) DMRVV high- Dogs must be at Dogs must be at For dogs


risk countries: least seven least four requiring titers,
Dogs must be at Dogs must be at months of age months of age to the six-month
least six months least four regardless of arrive via minimum age
of age to be months of age country of origin aircraft requirement
imported into (based on the or type of regardless of ensures that the
the United earliest age at conveyance country of time between
States. which a dog origin, which is titer collection
could be the youngest age and travel is
considered fully a dog may be sufficient for
vaccinated considered fully monitoring the
against rabies) vaccinated dog to ensure it
against rabies. does not develop
No requirement signs of rabies.
for DMRVV- No age limit for The increased
free or DMRVV dogs imported at age requirement
low-risk land ports will result in
countries since fewer public
rabies health
vaccination investigations of
documentation dogs found to be
is not currently ill or to have
required for died60 during air
these dogs travel and
improve health
and safety for
dogs being
transported. The
6-month versus
4-month age
requirement will
also make it
easier to
estimate the age
of dogs based on
examination of
their teeth,
enabling CDC to
better identify
falsified and
fraudulent
documentation.61
This age
requirement will
Table 1. Summary table of important changes to regulatory requirements based on the
provisions of this final rule and alternatives considered

final rule Current Option 1- Option 2- Justification


requirement requirements59 Higher-cost Lower-cost
alternative alternative
(baseline)

also improve
alignment with
USDA import
requirements (7
CFR 2148) for
dogs imported
for resale.

§ 71.51(g) No dog- All dogs must be Allow use of This requirement


identification implanted with tattoos or other is needed to
All dogs must requirement microchips and dog-identifying confirm that
have a other than a have tattoos for technology arriving dogs
microchip description on identification instead of match their
regardless of the rabies purposes requiring paperwork
country of origin vaccination microchips because CDC
documentation has documented
a dramatic
increase in the
number of dogs
arriving with
falsified rabies
vaccination
documentation.
The microchip
requirement will
allow for
matching
microchip
information
(obtained by
scanning the
dog) with the
microchip
number
documented on
the dog’s proof
of rabies
vaccination.
59The current requirements do not take account of the temporary suspension of dogs from DMRVV high-risk
countries, because it is a temporary measure.
§§ 71.51(h) and No requirement Require Only require This requirement
(dd)
60
for dog importers to use dogs from will help Federal
Roccaro, M., & Peli, A. (2020). Age determination in dog puppies by teeth examination: legal, health and welfare
importers to the more costly DMRVV high- agencies detect
Require review ofsubmit
implications, the literature and practical considerations. Veterinaria Italiana, 56(3), 149–162.
data with CBP formal risk countries to dogs that move
https://doi.org/10.12834/VetIt.1876.9968.2
importers to
Table 1. Summary table of important changes to regulatory requirements based on the
provisions of this final rule and alternatives considered

final rule Current Option 1- Option 2- Justification


requirement requirements59 Higher-cost Lower-cost
alternative alternative
(baseline)

submit advance CDC and no entry submit data via a from DMRVV
data included in requirement for requirements CDC-approved high-risk to
the CDC Dog airlines to create system and DMRVV low-
Import Form for a bill of lading require airlines risk countries to
each dog via a for all live dog to create a bill of avoid U.S.
CDC-approved imports lading for all requirements.
system and live dog imports This requirement
require airlines will also support
to create a bill of Federal
lading for all agencies’
live dog imports targeting of
interventions for
dogs arriving
from countries
presenting
significant risks
to human or
animal health.

§ 71.51(t) Rabies vaccine Require Require At present, the


certificates are Certification of veterinarians to information on
Require required for U.S.-issued fill out the rabies
standardized dogs imported Rabies Certification of vaccination
rabies from DMRVV Vaccination U.S.-issued documents is not
vaccination high-risk form be Rabies standardized;
information countries and do endorsed by a Vaccination different formats
using a CDC not need to be USDA Official Form, but do not are used in
form: entered into a Veterinarian for require different
Certification of standardized all dogs leaving certification by countries and
U.S.-issued form or the U.S. with USDA Official even within the
Rabies endorsed by a planned re-entry Veterinarian U.S. Lack of a
Vaccination USDA Official into the U.S., standardized
Veterinarian regardless of format may lead
form that is
destination to dogs from
endorsed by a
DMRVV high-
USDA Official risk countries
Veterinarian for arriving at a U.S.
dogs originating port with rabies
in the United vaccination
States and documentation
wanting to re- that does not
enter the U.S. align with
61 Roccaro, M., & Peli, A. (2020). Age determination in dog puppies by teeth examination: legal, health and welfare
after traveling to current CDC
implications, review of the literature and practical considerations. Veterinaria Italiana, 56(3), 149–162.
requirements
https://doi.org/10.12834/VetIt.1876.9968.2
Table 1. Summary table of important changes to regulatory requirements based on the
provisions of this final rule and alternatives considered

final rule Current Option 1- Option 2- Justification


requirement requirements59 Higher-cost Lower-cost
alternative alternative
(baseline)

a DMRVV high- and subsequent


risk country entry denials.
The requirement
for certification
by a USDA
Official
Veterinarian is
an added layer
of security
against
fraudulent
documentation.
This provision
will also align
the United States
with
import/export
requirements
commonly
required in other
countries.

§ 71.51(k) No follow-up Require In lieu of This process will


examination or veterinary requiring better align U.S.
Requirement for revaccination examination and follow-up at a requirements
veterinary required revaccination for CDC-registered with existing
examination and all dogs Animal Care requirements of
revaccination imported from Facility, allow other DMRVV-
against rabies at DMRVV high- dogs imported free countries.
a CDC- risk countries, from DMRVV This requirement
registered including dogs high-risk for veterinary
Animal Care with valid U.S.- countries that examination and
Facility for issued rabies were vaccinated revaccination
foreign- vaccination outside the will reduce the
vaccinated dogs certificates United States to risk of dogs
from DMRVV visit any potentially
high-risk licensed U.S. infecting people,
countries; no veterinarian for other domestic
requirement for examination and animals, or
dogs imported revaccination wildlife with
from DMRVV- DMRVV and
free or DMRVV potentially other
low-risk communicable
countries or diseases or
Table 1. Summary table of important changes to regulatory requirements based on the
provisions of this final rule and alternatives considered

final rule Current Option 1- Option 2- Justification


requirement requirements59 Higher-cost Lower-cost
alternative alternative
(baseline)

U.S.-vaccinated diseases which


dogs from impact livestock
DMRVV high- in the United
risk countries. States.
The laboratory
testing
requirements in
§ 71.51(k)(7)(v)
are addressed
separately
below.

§ 71.51(k)(7) No laboratory Serologic test Allow serologic This laboratory


testing from a CDC- test results for testing provision
Foreign- requirement for approved dogs imported will better align
vaccinated dogs dog imports laboratory with from DMRVV U.S.
from DMRVV from any a longer, e.g., high-risk requirements
high-risk country 90-day waiting countries with with existing
countries must period before foreign-issued requirements of
have serologic entry for dogs rabies other DMRVV-
test results from vaccinated vaccinations free countries
a CDC-approved outside the from any that require
laboratory with United States laboratory (i.e., laboratory
a waiting period, and arriving not limited to confirmation
or such time from DMRVV CDC-approved because rabies
period as high-risk laboratories) vaccination
specified in countries or all documentation
CDC technical dogs imported alone is
instructions, from DMRVV considered
before entry, or high-risk insufficient as
be quarantined countries require proof of rabies
for 28 days after serologic test immunity.
revaccination results However, this
with a USDA- requirement is
licensed rabies still less
vaccine restrictive than
many DMRVV-
free countries
because there is
no serologic test
requirement for
Table 1. Summary table of important changes to regulatory requirements based on the
provisions of this final rule and alternatives considered

final rule Current Option 1- Option 2- Justification


requirement requirements59 Higher-cost Lower-cost
alternative alternative
(baseline)

U.S.-vaccinated
dogs.

§§ 71.51(b) and No U.S. port For all dogs Allow foreign- This requirement
(c) requirement from DMRVV vaccinated dogs is intended to
high-risk imported from ensure dogs
U.S.-vaccinated countries, limit DMRVV high- denied entry or
dogs imported entry to U.S. risk countries to placed on hold
from DMRVV port with CDC- enter at any U.S. have safe
high-risk registered port with a CDC housing
countries may Animal Care quarantine locations
enter through Facilities. Six station (also available and
any U.S. port. U.S. ports known as a CDC CDC oversight.
Foreign- currently have port health This will reduce
vaccinated dogs facilities that station) and the risk that dogs
from DMRVV meet this allow U.S.- pending or
high-risk standard. vaccinated dogs denied entry will
countries must from any be placed in
arrive at a U.S. country to enter cargo
port with a CDC at any U.S. port warehouses or
quarantine other unsafe
station (also locations while
known as a port awaiting CDC
health station) determination or
and CDC- return to their
registered countries of
Animal Care origin. This
Facility. Such requirement will
facilities must also ensure
have an active appropriate
custodial bond veterinary
and a FIRMS follow up for
code issued by foreign-
CBP, and a vaccinated dogs
USDA from DMRVV
intermediate high-risk
handlers countries.
registration. Six
U.S. ports
currently have
facilities that
meet this
standard.
Table 1. Summary table of important changes to regulatory requirements based on the
provisions of this final rule and alternatives considered

final rule Current Option 1- Option 2- Justification


requirement requirements59 Higher-cost Lower-cost
alternative alternative
(baseline)

HHS/CDC determined that the set of lower-cost alternatives would likely not have a

significant impact on reducing the risk of dogs being imported with DMRVV compared to the

regulatory baseline. The requirements in the final rule would more effectively reduce this risk. If

the age requirements were reduced, importers may be more likely to attempt to circumvent CDC

rules to move dogs from DMRVV high-risk to DMRVV-free or low-risk countries prior to

importation into the United States. It is difficult to age dogs under six months62, and CDC has

documented cases of fraud involving the movement of dogs under six months of age from

DMRVV high-risk countries to DMRVV-free and DMRVV low-risk countries to avoid rabies

vaccination requirements. By requiring all dogs to be at least six months of age, CDC can better

confirm that the dog presented matches the documentation presented, particularly the age listed

for the dog, and that it is old enough to be adequately vaccinated for rabies. This age requirement

also more closely aligns with the WOAH standard for dogs from high-risk countries that states

dogs should be imported 90 days after a serologic sample has been drawn.63

In addition, transporting dogs under six months of age under conditions with unstable and

fluctuating air temperatures, such as those present in the cargo area of a plane, may subject these

young animals to adverse events (illness or death) because young animals cannot regulate their

62 Roccaro, M., & Peli, A. (2020). Age determination in dog puppies by teeth examination: legal, health and welfare
implications, review of the literature and practical considerations. Veterinaria Italiana, 56(3), 149–162.
https://doi.org/10.12834/VetIt.1876.9968.2

63 WOAH Terrestrial Manual 2023, chapters 3.1.18 and 8.15.7.


body temperature as efficiently as adult animals.64 International travel often results in prolonged

time between feeding and watering of animals leading to potential adverse events (illness and

death) in young animals due to physiologic stressors associated with or exacerbated by low blood

glucose levels, low oxygen environments (such as the cargo area of a plane), dehydration, and

the stress of travel.65 This could result in more ill and dead dogs arriving on flights (reducing the

benefits estimated for the final rule). CDC would lack data on the total number of dogs imported

into the United States and would have less data to conduct public health investigations in the

event that a sick dog is imported from DMRVV-free or low-risk country. In the absence of

official certification of the Certification of U.S.-issued Rabies Vaccination form, CDC believes it

would be much easier for importers of dogs from DMRVV high-risk countries to present

fraudulent documentation of U.S. rabies vaccination. It would be more difficult for CDC to

verify the identity of dogs arriving with tattoos instead of microchips (increasing the risk of

fraudulently imported dogs). Microchips are also already widely used throughout the world and

are a WOAH standard for the international movement of animals.66

Follow-up examination and revaccination of dogs by any U.S.-licensed veterinarian

would be less costly in comparison to services provided by CDC-registered ACF; however, this

would increase the public health risk associated with foreign-vaccinated dogs from DMRVV

high-risk countries. CDC would have limited capacity to follow up with importers to ensure that

the dogs had been appropriately examined and revaccinated in a timely manner. Prior to the

examination, the dog could come into contact with additional people and potentially other pets or

wildlife. Finally, staff at CDC-registered ACF will operate according to CDC regulations and

guidance to minimize the risk of disease transmission to humans and other animals.

64 Hardy J. Physiology of temperature regulation. Physiologic reviews 1961: 41; 521-606.


65 Jahn K, Ley J, DePorter T, Seksel K. How Well Do Dogs Cope with Air Travel? An Owner-Reported Survey
Study. Animals (Basel). 2023 Oct 4;13(19):3093. Doi: 10.3390/ani13193093. PMID: 37835699; PMCID:
PMC10571552.
66 WOAH Terrestrial Manual 2023, chapters 3.1.18 and 8.15.7.
CDC would have very limited oversight of the laboratories conducting serological tests.

Importers would also find it easier to obtain fraudulent serological tests from laboratories that are

not approved by CDC or may get inaccurate test results from unapproved laboratories. If CDC

allowed foreign-vaccinated dogs to arrive at any U.S. port with a CDC quarantine station (also

known as a CDC port health station), the government (i.e., CBP and CDC) would not be able to

ensure that the dogs had been cleared by a CDC-registered ACF prior to admitting the dogs into

the United States. In summary, the lower-cost alternatives would result in significantly less costs

for importers and airlines but would also significantly limit the ability of CDC to prevent the

importation of inadequately vaccinated dogs from DMRVV high-risk countries. CDC has

observed that many importers have tried to circumvent CDC requirements for dog importation

and the provisions in this final rule are chosen to mitigate these risks. The lower-cost alternatives

would lead to a significantly increased risk that dogs infected with DMRVV would be imported.

CDC did not select any of the higher-cost alternatives described above because most of these

alternatives do not address the highest-risk category of imported dogs, i.e., foreign-vaccinated

dogs from DMRVV high-risk countries. As a result, the public health benefits associated with

these higher-cost alternatives would not decrease the risk to the public health sufficiently to

balance the costs of these alternatives. CDC has not observed any DMRVV infections among

U.S.-vaccinated dogs imported from DMRVV high-risk countries or among dogs imported from

DMRVV-free or low-risk countries. In addition, CDC can obtain the data it needs from the

lower-cost CDC import data submission system and does not require a tattoo in addition to a

microchip to confirm the identity of imported dogs. Because of the limited public health benefit

relative to the additional costs, HHS/CDC believes the requirements in the final rule address the

risks associated with imported dogs infected with DMRVV or other exotic pathogens more cost

effectively than the alternatives.

VI. Summary of Public Comments and Responses


On July 10, 2023, HHS/CDC published a NPRM proposing to amend the current foreign

quarantine regulations at 42 CFR 71.50 and 71.51 to provide additional clarity and safeguards to

address the public health risk of DMRVV associated with the importation of dogs into the United

States (88 FR 43978). In the NPRM, HHS/CDC specifically requested public comment on the

following:

• A limited exception to accommodate personal pet owners who travel by land

between the U.S. and Canada or Mexico.

• The proposed requirement that airlines transport and assume responsibility (if the

importer abandons the animal) for necropsy of dogs and cats that die en route to

the United States or that die pending an admissibility determination. Necropsy

would include gross and histopathologic examination and any subsequent

infectious disease testing based on the findings.

• The proposed requirement for the rabies vaccination form for foreign-vaccinated

dogs to be certified by a foreign government official in the exporting country, as

an added measure to prevent falsification.

• The proposed public health standards and evidence used to maintain a list of

DMRVV-restricted countries and the length of time or conditions to be met before

a country is added to or eligible for removal from the list. Additionally, how the

list will be maintained and whether publication on CDC’s website and through

Federal Register notices would be sufficient to adequately inform importers.

• The potential costs to carriers of dogs arriving by land or sea (as opposed to

airlines) to comply with the requirements proposed in the NPRM.

• Estimates of the number of dogs any small individual entity currently imports

annually or the average number of imported dogs across entities.

• Estimated thresholds for the number of imported dogs from DMRVV high-risk

countries per firm at which NPRM costs (if finalized as proposed) would exceed
two percent of revenue during the first year of implementation of the proposed

requirements.

During the public comment period, HHS/CDC received 2,106 comments from

individuals, groups, organizations, and the airline industry. This included one comment from a

group of organizations involved in animal rescue that included 118,312 signatures.

The following is a discussion of public comments received that are applicable and within

the scope of the regulation.

A. Comments on Necessity of the Rule

Numerous commenters made general remarks either supporting or opposing the

importation requirements. In the following paragraphs, we discuss and respond to such

comments.

Comment: HHS/CDC received comments from several agencies and organizations that

supported many of the provisions proposed in the NPRM and adopted in this final rule. These

comments generally recognized the significant public health threat posed by the importation of

rabid dogs. Most of the supportive comments were submitted as part of a write-in campaign,

which stated that the proposals in the NPRM would “add much needed safeguards to protect

animals and the public from the introduction of rabies via imported dogs.” These entities were

particularly supportive of the six-month age minimum for dog importation, microchip

requirement, greater veterinary oversight, and verification of animals’ rabies documentation.

Other commenters supported the proposals in the NPRM because they believe the requirements

would help prevent imported dogs from introducing diseases into the U.S. dog population.

Organizations involved in veterinary medicine supported the updated dog importation

requirements outlined in the NPRM. Organizations and individuals involved in purebred dog

activities (e.g., breeding) generally supported many of the provisions in the NPRM except for the
six-month age requirement. Associations and government entities involved in protecting public

health and animal health generally supported the proposal.

Response: HHS/CDC agrees with the comments that suggest this action and specific

requirements are necessary for continued control of DMRVV from imported dogs. This includes

specific provisions including the six-month age minimum for dog importation, microchip

requirement, greater veterinary oversight, and verification of animals’ rabies documentation,

which are discussed in further length below.

Comment: CDC received numerous comments that the rule was unnecessary because

DMRVV was not a serious problem in the United States. Commenters noted that no person has

died from rabies in the United States during the past 20 years, that CDC should instead focus on

wildlife rabies which they considered a greater risk than DMRVV and is already present in the

United States, and that the rule was overcompensating for rare events (citing the low number of

imported rabid dogs and the uncommon occurrence of rabies in dogs in the United States).

Response: CDC disagrees with these comments and considers DMRVV a serious threat

that requires effective controls to prevent its re-introduction into the United States. Rabies is one

of the deadliest zoonotic diseases and accounts for an estimated 59,000 human deaths globally

each year.67 Over 98 percent of those deaths are due to DMRVV.68 The rabies virus can infect

any mammal and, once clinical signs appear, the disease is almost always fatal.69 The close

relationship between dogs and people means there is a direct public health risk to individuals that

interact with inadequately vaccinated dogs imported from countries at high risk of DMRVV. Of

67 World Health Organization (2018). WHO Expert Consultation on Rabies (WHO Technical Report Series 1012).
Retrieved from https://www.who.int/publications/i/item/WHO-TRS-1012.
68 Hampson K, Coudeville L, Lembo T, et al.; Global Alliance for Rabies Control Partners for Rabies Prevention.

Estimating the global burden of endemic canine rabies. PloS Negl Trop Dis 2015;9:e0003709.
https://doi.org/10.1371/journal.pntd.0003709.
69 Fooks, A. R., Banyard, A.C., Horton, D.L., Johnson, N., McElhinney, L.M., and Jackson, A.C. (2014) Current

status of rabies and prospects for elimination. Lancet, 384(9951), 1389-1399. Doi: 10.1016/S0140-6736(13)62707-
5.
note, DMRVV has been highly successful at adapting to new host species, particularly wildlife,

that can further transmit the virus.70

The goal of the revised regulation is to update and strengthen the U.S. dog importation

system to maintain effective control of DMRVV. From 2015-2022, the incidence rate of

DMRVV-infected dogs imported into the United States from DMRVV high-risk countries was

approximately 16 times higher (range, 13.24–19.36) than the annual incidence of domestically

acquired endemic rabies variants among the U.S. domestic dog population.71 This is a disease

with near 100% mortality in infected people. There is no treatment available for persons ill with

rabies. As rabies kills approximately 59,000 people, mainly children, per year globally from dog

bites, HHS/CDC is committed to preventing the reintroduction of DMRVV into the United

States.

DMRVV is still a serious public health threat in the more than 100 countries where it

remains enzootic.72 Although the U.S. Government does not track the precise total number of

dogs imported each year, CDC previously estimated that approximately 1 million dogs are

imported into the United States annually, of which 100,000 dogs are from DMRVV high-risk

countries.73 This estimate was based on information provided by airlines, CBP, and a public

health study conducted at a U.S.-Mexico land border crossing.74 The re-establishment of

DMRVV in the United States would near certainly result in human death, cost millions of

dollars, and require years of dedicated State and Federal efforts to eliminate the virus again.

70 Velasco-Villa A, Mauldin MR, Shi M, et al. The history of rabies in the Western Hemisphere. Antiviral Res.
2017;146:221-232. Doi:10.1016/j.antiviral.2017.03.013.
71 Pieracci EG, Wallace R, Maskery B, Brouillette, Brown C, Joo H. Dogs on the move: Estimating the risk of rabies

in imported dogs in the United States, 2015-2022. Zoonoses and Public Health 2024; 00:1-9 DOI:
10.1111/zph.13122.
72 Hampson K, Coudeville L, Lembo T, et al.; Global Alliance for Rabies Control Partners for Rabies Prevention.

Estimating the global burden of endemic canine rabies. PloS Negl Trop Dis 2015;9:e0003709. https://
doi.org/10.1371/journal.pntd.0003709.
73 HHS/CDC. Guidance Regarding Agency Interpretation of “Rabies-Free” as It Relates to the Importation of Dogs

Into the United States. 84 FR 724,724-730 (Jan. 31, 2019).


74 McQuiston, J.H., et al., Importation of dogs into the United States: risks from rabies and other zoonotic diseases.

Zoonoses Public Health, 2008. 55(8-10): p. 421-6.


The consequences of failure to control DMRVV importations remain extraordinary and

significant. In 1988, when DMRVV found in Mexico began spreading in U.S. coyote

populations, it spread to wildlife and dogs in Texas where DMRVV had been previously

eliminated. Two people died and the subsequent re-elimination of DMRVV cost $56 million (in

2023 USD) and required over 10 years of effort.75, 76 The experience of other countries also

speaks to the importance of maintaining continued effective control of DMRVV importation. For

instance, Malaysia recently experienced the reintroduction of dog rabies with significant

consequences for the country, including 59 human deaths since the outbreak began.77

Regarding commenters’ assertion that HHS/CDC should focus on wildlife rabies as

posing a greater threat than DMRVV, there is an important distinction between rabies variants

circulating in wildlife species (including foxes, raccoons, skunks, and bats) in the United States

and DMRVV, which has not been endemic in the United States since 2007. Through mutation

DMRVV is highly adaptable to new hosts. One DMRVV-infected dog infecting one animal in

the wild is not of major concern. However, if the DRMVV mutates within that wild animal, the

wild animal can create an entirely new rabies variant that can spread across the U.S. Indeed, five

out of eight wildlife variants within the U.S. originated through DMRVV infection. DMRVV

thus risks exponentially increasing the risk to human and animal life. 78

Comment: HHS/CDC received more than 200 comments that the proposed rule was

unnecessary given the rarity of DMRVV importations and that no one in the United States has

died from DMRVV from an imported dog in more than 20 years. Fourteen commenters claimed

that “this rule is overcompensating for rare events,” citing the low number of imported rabid

dogs or the uncommon occurrence of rabies in dogs in the United States. Another comment

75 Thomas, S., Wilson, P., Moore, G., Oertli, E., Hicks, B., Rohde, R., Johnston, D. (2005). Evaluation of oral rabies
vaccination programs for control of rabies epizootics in coyotes and gray foxes: 1995-2003. Journal of the American
Veterinary Medicine Association, 227(5),785-92. Doi: 10.2460/javma.2005.227.785.
76 Sterner, R., Meltzer, M., Shwiff, S., Slate, D. (2009). Tactics and Economics of Wildlife Oral Rabies Vaccination,

Canada and the United States. Emerging Infectious Diseases, 15(8), 1176-1184. Doi: 10.3201/eid1508.081061.
77 Sarawak records 9 rabies deaths so far this year. The Straits Times. May 16,2023.
78 Velasco-Villa A, Mauldin MR, Shi M, et al. The history of rabies in the Western Hemisphere. Antiviral Res.

2017;146:221-232. Doi:10.1016/j.antiviral.2017.03.013.
claimed that a response to a Freedom of Information Act request revealed that there has not

actually been an increase in dogs with rabies entering the country, so these proposed changes are

discriminatory and arbitrary. The commenter stated that over a million dogs are imported into the

United States every year and only 3 imported dogs have been found to be infected with rabies

since 2015.

Response: While DMRVV importations remain uncommon and thankfully no one in the

United States has died from rabies following exposure to an imported dog in the last 20 years,

HHS/CDC disagrees that the recent success in preventing deaths from imported rabies means

that the United States should not update its regulations to ensure the continued effectiveness of

its dog importation requirements.

Specifically, updates to dog importation requirements are necessary to 1) adapt to

increased fraud in importations of dogs; 2) avoid the severe disruptions and health risks posed by

the re-introduction of DMRVV into the United States; and 3) stay ahead of growing gaps in

rabies control efforts, both abroad and in the United States.

Addressing Increasing Fraud

HHS/CDC continues to document a marked increase in fraud committed by importers of

dogs from DMRVV high risk countries.79,80,81,82,83,84,85 Internationally, there has been significant

79 Centers for Disease Control and Prevention. Quarantine Activity Reporting System (version 4.9.8.8.2.2A). Dog
importation data, 2021-2024. Accessed: 26 March 2024.
80Centers for Disease Control and Prevention. Dog Import Permit Application System. Dog permit importation data,

2021-2024. Accessed: 26 March 2024.


81 Pieracci, E., Williams, C., Wallace, R., Kalapura, C., Brown, C. U.S. dog importations during the COVID-19

pandemic: Do we have an erupting problem? PloS ONE,16(9), e0254287. Doi: 10.1371/journal.pone.0254287.


82 Kaila M, Marjoniemi J, Nokireki T. Comparative study of rabies antibody titers of dogs vaccinated in Finland and

imported street dogs vaccinated abroad. Acta Vet Scand 2019; 61:15.
83 Maher J, Wyatt T. European illegal puppy trade and organized crime. Trends in Organized Crime. 2021; 24(4)

506-525.
84Zucca P, Rossman MC, Osorio JE, Karem K, De Benedictis P, Haifsl J, et al. The ‘bio-crime model’ of cross-

border cooperation among veterinary public health, justice, law enforcements, and customs to tackle the illegal
animal trade/bio-terrorism and to prevent the spread of zoonotic diseases among human population. Frontiers in
Veterinary Science. 2020; 7: 1-13.
85 Cocchi M, Danesi P, DeZan G, Leati M, Gagliazzo L, et al. A three-year biocrime sanitary surveillance on

illegally imported companion animals. Pathogens. 2021; 10(80):1-12.


growth within the companion animal breeding industry with increasing international trade.86

Multiple international and U.S. investigations have identified importations of puppies that were

too young to meet rabies vaccination requirements.87, 88, 89, 90 There is growing evidence that

criminal networks are becoming involved in the lucrative dog trade, and the illegal puppy trade

was reported to have increased during the pandemic.91, 92, 93

Additionally, reports of international movement of animals with missing microchips, no

proof of rabies vaccination, or underage dogs with fraudulent vaccination records have been

documented in the United States and abroad.94, 95 A rabies serological (antibody) titer is an

estimation of an immune response against rabies virus (either through exposure or vaccination).

While there is no “protective” titer against rabies virus, survival against rabies virus infection is

often more likely to occur the higher the animal’s titer at the time of infection.96 The World

Organisation for Animal Health considers a level of 0.5 IU/mL a “passing” antibody titer level.

A 2015 study found that 53% of imported rescue dogs arriving in Norway with rabies

86 Maher J, Wyatt T. European illegal puppy trade and organized crime. Trends in Organized Crime. 2021; 24(4)
506-525.
87 Pieracci, E., Williams, C., Wallace, R., Kalapura, C., Brown, C. U.S. dog importations during the COVID-19

pandemic: Do we have an erupting problem? PloS ONE,16(9), e0254287. Doi: 10.1371/journal.pone.0254287.


88 Zucca P, Rossman MC, Osorio JE, Karem K, De Benedictis P, Haifsl J, et al. The ‘bio-crime model’ of cross-

border cooperation among veterinary public health, justice, law enforcements, and customs to tackle the illegal
animal trade/bio-terrorism and to prevent the spread of zoonotic diseases among human population. Frontiers in
Veterinary Science. 2020; 7: 1-13.
89 Cocchi M, Danesi P, DeZan G, Leati M, Gagliazzo L, et al. A three-year biocrime sanitary surveillance on

illegally imported companion animals. Pathogens. 2021; 10(80):1-12.


90 Houle MK. Perspective from the field: Illegal puppy imports uncovered at JFK airport. 2017. Available at:

www.cdc.gov/ncezid/dgmq/feature-stories/operation-dog-catcher.html.
91 Maher J, Wyatt T. Rural-urban dynamics in the UK illegal puppy trade: trafficking and trade in man’s best friend.

International Journal of Rural Law and Policy. 2019; 9 (2): 1-20.


92 Zucca P, Rossman MC, Osorio JE, Karem K, De Benedictis P, Haifsl J, et al. The ‘bio-crime model’ of cross-

border cooperation among veterinary public health, justice, law enforcements, and customs to tackle the illegal
animal trade/bio-terrorism and to prevent the spread of zoonotic diseases among human population. Frontiers in
Veterinary Science. 2020; 7: 1-13.
93 British Broadcasting Corporation. Illegal puppy trade warning as sales boom during the COVID pandemic. 18

NOV 2020. British Broadcasting Corporation News.


94 Pieracci, E., Williams, C., Wallace, R., Kalapura, C., Brown, C. U.S. dog importations during the COVID-19

pandemic: Do we have an erupting problem? PloS ONE,16(9), e0254287. Doi: 10.1371/journal.pone.0254287.


95 Zucca P, Rossman MC, Osorio JE, Karem K, De Benedictis P, Haifsl J, et al. The ‘bio-crime model’ of cross-

border cooperation among veterinary public health, justice, law enforcements, and customs to tackle the illegal
animal trade/bio-terrorism and to prevent the spread of zoonotic diseases among human population. Frontiers in
Veterinary Science. 2020; 7: 1-13.
96 CDC. Rabies Serology. Available at:

www.cdc.gov/rabies/specific_groups/hcp/serology.html#What%20Does%20A%20Rabies%20Virus%20Titer%20Me
an?
vaccinations administered at least 21 days before arrival had titers less than 0.5 IU/mL.97

Nineteen percent of dogs in the study had titers less than 0.1 IU/mL, “raising concerns as to

whether they had been vaccinated against rabies at all.”98 A study of over 20,000 dogs imported

into Italy between 2006 and 2012 found 13% of imported dogs had titers less than 0.5 IU/mL,

raising similar doubts about compliance with vaccination requirements.99 A Canadian study

conducted between October 2021 and November 2022 found that nearly half (32/67; 47.8%) of

imported rescue dogs had titers less than 0.5 IU/mL and 34% (23/67) had no detectable rabies

titer, despite all dogs having been imported within one month with a current rabies vaccination

certificate.100 Importers are increasingly resorting to falsifying the ages of dogs and submitting

certificates for other animals while also submitting titer results from other animals or changing

the titer results of the dogs being imported. This increase in instances of fraudulent rabies

vaccination documents combined with increases in international dog movement presents an

ongoing and significant risk of importation of DMRVV.

For instance, in 2015 a rabid dog was part of a group of eight dogs and 27 cats imported

from Egypt by an animal rescue group. The dog had an unhealed leg fracture and began showing

signs of rabies four days after arrival. Following the DMRVV diagnosis, animal rescue workers

in Egypt admitted that the dog’s rabies vaccination documentation had been intentionally

falsified to evade CDC entry requirements.101 As a result of this single importation, public health

officials recommended that 18 people receive rabies PEP, seven dogs underwent a six-month

97 Klevar S, Hogasen HR, Davidson RK, Hammes IS, Treiberg Berndtsson L, LundA. Cross-border transport of
rescue dogs may spread rabies in Europe. The Veterinary Record. 2015; 176 (26): 672.
98 Id.
99 Rota Modari E, Alonso S, Mancin M, De Nardi M, Hudson-Cooke S, Veggiato C, et al. Rabies vaccination:

higher failure rates in imported dogs than those vaccinated in Italy. Zoonoses and Public Health 2022; 64 (2): 146-
55.
100 Weese S. Rabies titers in dogs imported into Ontario, Canada (2021-2022). Abstract submitted to Canadian

Association of Veterinary Epidemiology and Preventative Medicine (CAVEPM) Conference 2023.


101 Sinclair JR, Wallace RM, Gruszynski K, et al. Rabies in a dog imported from Egypt with a falsified rabies

vaccination certificate—Virginia, 2015. MMWR Morb Mort Wkly Rep 2015;64:1359–62. https://doi.
Org/10.15585/mmwr.mm6449a2.
quarantine, and eight additional dogs housed in the same home as the rabid dog had to receive

rabies booster vaccinations and undergo a 45-day monitoring period.102

In 2017, a flight parent imported four dogs from Egypt on behalf of an animal rescue

organization. One of the dogs appeared agitated and bit the flight parent prior to the flight. A

U.S. veterinarian examined the dog one day after its arrival and tested the dog for rabies. A

rabies test showed that the dog was positive for DMRVV.103 Public health officials

recommended that at least four people receive rabies PEP, and the remaining three dogs

underwent quarantine periods ranging from 30 days to six months. An investigation revealed the

likelihood of falsified rabies vaccination documentation presented on entry to the United

States.104

In 2019, 26 dogs were imported into the United States from Egypt by a rescue

organization. All dogs had rabies vaccination documentation and serologic documentation

indicating the presence of rabies antibodies in response to immunization, based on results from

an Egyptian government-affiliated rabies laboratory. However, one dog developed signs of

rabies three weeks after arrival and later tested positive for DMRVV. The resulting public health

investigation raised suspicions that the rabies vaccination documents and serological test results

had been falsified for all 26 dogs in the shipment, because 18 dogs in the shipment lacked

serologic evidence of vaccination when re-tested in the United States. As a result, 44 people

were required to receive PEP and the 25 other dogs imported on the same flight underwent re-

vaccination and quarantines that ranged from four to six months. The rabid dog had been

released into an individual’s home because of its false paperwork and subsequently had contact

102 Quarantine periods for animals exposed to rabies can vary between 30 days to six months based on several
factors, including vaccination history, serologic titers or prospective serologic monitoring results, or jurisdictional
requirements.
103 The diagnosis of rabies requires laboratory confirmation on the basis of a positive result for the direct fluorescent

antibody test performed on CNS tissue collected post-mortem. National Association of State Public Health
Veterinarians. Compendium of animal rabies prevention and control, 2016. JAVMA 2016; 248 (5):505-517.
104 Hercules Y, Bryant NJ, Wallace RM, et al. Rabies in a dog imported from Egypt—Connecticut, 2017. MMWR

Morb Mort Wkly Rep 2018;67:1388–91. https://doi.org/10.15585/mmwr.mm6750a3.


with an additional 12 dogs, all of which had to be revaccinated and undergo quarantine periods

ranging from 45 days to six months.105 The public health investigations and administration of

rabies PEP to exposed persons in this case cost more than $400,000 in State resources.106, 107 As a

result of the rabid dog importations that occurred in 2015, 2017, and 2019, CDC issued a

temporary suspension for dogs entering the United States from Egypt.108,109

In June 2021, 33 dogs and one cat were imported into the United States from Azerbaijan

by an animal rescue organization. All dogs had rabies vaccination documents that appeared valid

upon arrival in the United States. Three days after arrival, one dog developed signs of rabies.

CDC confirmed the dog was infected with DMRVV known to circulate in the Caucasus

Mountains region of Azerbaijan. The remaining rescue animals exposed to the rabid dog during

travel were quickly dispersed across nine states, leading to what is believed to be the largest,

multi-state, imported rabid dog investigation in U.S. history.110 Eighteen people received PEP to

prevent rabies because of exposure to the rabid dog. CDC performed the test known as the

“Prospective Serologic Monitoring” test on the remaining dogs and the public health

investigation revealed that improper vaccination practices by the veterinarian in Azerbaijan

likely contributed to the inadequate vaccination response documented in 48 percent of the

105 Raybern, C et al. Rabies in a dog imported from Egypt-Kansas, 2019. MMWR Morb Mort Wkly Rep 2020; 69
(38): 1374-1377.
106 Id.
107 Centers for Disease Control and Prevention (2022). Rabies Postexposure Prophylaxis. Retrieved from

https://www.cdc.gov/rabies/medical_care/index.html.
108 84 FR 20628 (May 10, 2019).
109 CDC implemented this suspension because of the lack of veterinary controls available in Egypt to prevent the

exportation of rabid dogs. With limited exceptions, CDC began requiring a CDC Dog Import Permit and
documentation of the dog’s rabies serologic tests from World Organisation for Animal Health (WOAH)-approved
laboratories for eligible importers. Since these permit and serologic test requirements were implemented, no rabid
dogs have been imported from Egypt.
110 Whitehill F, Bonaparte S, Hartloge C, et al. Rabies in a Dog Imported from Azerbaijan- Pennsylvania, 2021.

MMWR Morb Mortal Wkly Rep 2022; 71: 686-689.


imported animals, including the rabid dog.111 The 33 exposed animals were revaccinated and

placed in quarantine for periods ranging from 45 days to six months.112

Avoiding Disruption of DMRVV Re-Introduction

The disruption to public health associated with even a single rabid dog importation can be

significant. For every imported rabid dog, an average of 20 people and 21 animals receive post-

exposure prophylaxis (PEP) or undergo vaccination and quarantine, respectively, resulting in a

substantial disruption to State and local public health services, a considerable cost burden to

states, and a significant toll on the physical and mental health of exposed persons and animals.

To manage even one instance of DMRVV exposure, State public health officials must

immediately pivot from routine or less life-threatening responses and initiate multiple actions,

some of which are extensive. First, the State health department must initiate an in-depth

investigation to locate all persons and animals who were exposed to the rabid dog from the 10

days prior to the dog showing symptoms until the dog dies or is euthanized. In many instances,

multiple health departments are involved and, based on the results of the investigation, CDC may

be required to notify the World Health Organization pursuant to the International Health

Regulations. Next, State health departments must conduct a rabies risk assessment of all

individuals affected to determine if they need post-exposure prophylaxis (PEP), and if they are

determined to be at risk, to administer post-exposure prophylaxis. Finally, if any of the

individuals were scratched or bitten, they may also need wound care, tetanus boosters, and/or

antibiotics.

CDC estimates a range of costs for public health investigations and subsequent cost of

care for people exposed to rabid dogs to be between $210,00 and $510,000 per importation

111 Centers for Disease Control and Prevention (2021). CDC responds to a case of rabies in an imported dog.
Retrieved from https://www.cdc.gov/worldrabiesday/disease-detectives/rabies-imported-dog.html.
112 Whitehill F, Bonaparte S, Hartloge C, et al. Rabies in a Dog Imported from Azerbaijan- Pennsylvania, 2021.

MMWR Morb Mort Wkly Rep 2022; 71: 686-689.


event, as summarized in Section VI.113, 114 This cost estimate does not include the cost to

evaluate, vaccinate, test, and quarantine exposed animals. This cost estimate also does not

account for the worst-case outcomes, which include: 1) transmission of rabies to a person who

dies from the disease; and 2) ongoing transmission to other domestic and wildlife species in the

United States. Finally, these costs do not include the cost of re-eliminating DMRVV if it were to

be re-established in the United States, making this estimate an underestimate of the total cost

associated with an imported rabid dog.

It bears noting that while the cost of public health investigations and administering PEP is

borne by public health departments, the individuals who are the subjects of the investigations and

who may receive PEP will experience great disruption and physical and emotional burden: rabies

PEP can be painful (specifically, rabies immunoglobulin administered at the site of the wound)

and protracted; DMRVV is 99% fatal in humans, a statistic certain to engender fear and anxiety;

and the need to quarantine exposed pets can create a sense of great disruption and concern.

Finally, DMRVV becoming re-established in the United States would result in costly

efforts over many years to eliminate the virus again. The extraordinary cost of re-introduction of

DMRVV is demonstrated by an instance of reintroduction that occurred in Texas, where

DMRVV had been previously eliminated. The reintroduction resulted in several human deaths;

the subsequent re-elimination of DMRVV cost $56 million (in 2023 USD) and required over 10

years of effort.115, 116

Addressing Potential Gaps in Rabies Control

113 Raybern, C et al. Rabies in a dog imported from Egypt-Kansas, 2019. MMWR Morb Mort Wkly Rep 2020; 69
(38): 1374-1377.
114 CDC. Guidance Regarding Agency Interpretation of “Rabies-Free” as It Relates to the Importation of Dogs Into

the United States. 84 FR 724 (Jan. 31, 2019).


115 Thomas, S., Wilson, P., Moore, G., Oertli, E., Hicks, B., Rohde, R., Johnston, D. (2005). Evaluation of oral

rabies vaccination programs for control of rabies epizootics in coyotes and gray foxes: 1995-2003. Journal of the
American Veterinary Medicine Association, 227(5),785-92. Doi: 10.2460/javma.2005.227.785.
116 Sterner, R., Meltzer, M., Shwiff, S., Slate, D. (2009). Tactics and Economics of Wildlife Oral Rabies

Vaccination, Canada and the United States. Emerging Infectious Diseases, 15(8), 1176-1184. Doi:
10.3201/eid1508.081061.
The rule is further necessitated by two new threats to rabies control efforts domestically

and abroad, which could increase the risk of the re-introduction of DMRVV in the United

States—drops in vaccination coverage among U.S. dogs and disruptions to rabies control

programs in high-risk countries.

The risk of re-introduction of DMRVV is compounded by potential gaps in rabies

vaccine coverage among U.S. dogs. Researchers recently documented canine vaccine hesitancy,

which is defined as “a dog owners’ skepticism about the safety and efficacy of administering

routine vaccinations to their dogs,” in 53% of the U.S. population. Rabies vaccination in pets

creates a protective barrier between people and wildlife infected with rabies by disrupting the

virus transmission chain. Declines in canine rabies vaccination rates increases the chance of

people being exposed to and infected with the rabies virus.

This perspective among dog owners could lead to decreases in rabies vaccination

coverage in pets, creating a potential susceptible pet population primed for DMRVV re-

introduction.117 Canine vaccine hesitancy has specifically been associated with rabies non-

vaccination. While existing importation regulations have been instrumental in decreasing and

preventing the importation of rabid dogs, updates to these regulations, as provided for in the final

rule, are necessary to sustain and advance effective control of DMRVV.

The COVID-19 pandemic also negatively impacted global canine rabies vaccination

campaigns, which have yet to recover. Successful canine rabies control requires canine mass

vaccination coverage equal to or greater than 70% of a country’s dog population.118,119 Achieving

pre-pandemic vaccination rates for countries that were moving toward canine rabies control and

117Motta, M., Motta, G., Stecula, D. (2023). Sick as a dog? The prevalence, politicization, and health policy
consequences of canine vaccine hesitancy (CVH). Vaccine, 41: 5946-5950.

118 Coleman PG, Dye C. Immunization coverage required to prevent outbreaks of dog rabies. Vaccine. 1996
Feb;14(3):185-6. Doi: 10.1016/0264-410x(95)00197-9. PMID: 8920697.
119 Zinsstag J, Dürr S, Penny MA, Mindekem R, Roth F, Menendez Gonzalez S, Naissengar S, Hattendorf J.

Transmission dynamics and economics of rabies control in dogs and humans in an African city. Proc Natl Acad Sci
U S A. 2009 Sep 1;106(35):14996-5001. Doi: 10.1073/pnas.0904740106. Epub 2009 Aug 17. PMID: 19706492;
PMCID: PMC2728111.
elimination prior to the COVID-19 pandemic could take years to recover, and some countries

may require even longer periods of time to attain pre-pandemic vaccination levels. During the

COVID-19 pandemic, canine rabies vaccination campaigns were disrupted in many high-risk

countries, which resulted in an increase in canine and human rabies cases.120,121 This disruption

to canine vaccination campaigns has been contemporaneous with other factors, including: a high

volume of dogs being imported into the United States, insufficient veterinary controls in

DMRVV high-risk countries to prevent the export of inadequately vaccinated dogs, inadequate

global veterinary supply chains for vaccines and related materials, and persistent workforce

capacity shortages, particularly in DMRVV high-risk countries that export dogs to the United

States.

A survey of global, regional, national, and local partners from the network of the United

Against Rabies Forum122 and rabies practitioners found that the global COVID-19 pandemic

impacted rabies control efforts in many high-risk countries during 2020. The study authors

reported that dog vaccinations were administered as planned in just four percent of the countries

for which data were available. Around half of respondents reported that funds for rabies control

were diverted to COVID-19 activities. Respondents who reported diversion of rabies control

funds to COVID-19 responses further reported that animal rabies vaccines and dog vaccination

campaigns were often the first rabies control activities to be cut.123

120 Kunkel, A., Jeon, S., Joseph, H., Dilius, P., Crowdis, K., Meltzer, M., Wallace, R. (2021). The urgency of
resuming disrupted dog rabies vaccination campaigns: a modeling and cost-effectiveness analysis. Scientific
Reports, 11, 12476. Doi:10.1038/s41598-021-92067-5.
121 Raynor, B., Díaz, E,, Shinnick, J., Zegarra, E., Monroy, Y., Mena. C.,... Castillo-Neyra, R.(2021). The impact of

the COVID-19 pandemic on rabies reemergence in Latin America: The case of Arequipa, Peru. PLoS Neglected
Tropical Diseases, 15(5), e0009414. doi:10.1371/journal.pntd.0009414.
122 A forum supported by the Food and Agriculture Organization of the United Nations, the World Organisation for
Animal Health, and the World Health Organization (the Tripartite), which takes a multi-sectoral, One Health
approach bringing together governments, vaccine producers, researchers, non-governmental organizations and
development partners to end human deaths from dog-mediated rabies.
123 Nadal D, Abela-Ridder B, Beeching S, Cleaveland S, Cronin K, Steenson R and Hampson K (2022). The
Impact of the First Year of the COVID-19 Pandemic on Canine Rabies Control Efforts: A Mixed-Methods Study of
Observations About the Present and Lessons for the Future. Front Trop Dis 3:866811.doi: 10.3389/fitd.2022.866811
Global veterinary workforce capacity and veterinary supply chain shortages that have led

to delayed or disrupted care for dogs (and other pets), and that were exacerbated by the COVID-

19 pandemic, still remain today. The lack of veterinarians, veterinary technicians, and other

animal care staff who are available to provide care for dogs prior to travel, combined with a lack

of veterinary supplies such as drugs and vaccines, increase the likelihood dogs imported into the

United States may pose a public health threat.124, 125, 126, 127 Challenges with rabies vaccine

administration, distribution, potency, quality, and storage in many countries also contribute to

inadequate protection against rabies prior to the pandemic; these challenges continue as public

health infrastructure recovers post-pandemic.128, 129, 130, 131

Comment: CDC received comments stating that the current regulation for dogs and cats

is sufficient or that CDC should keep its current importation system in place. Because the

commenter did not elaborate on what they meant by the term “current importation system,” CDC

assumes that this refers to requirements under the temporary suspension.

Response: CDC disagrees that current regulations are sufficient to prevent the

reintroduction of DMRVV into the United States. CDC notes that its Federal quarantine

regulations (currently found at 42 CFR 71.51) controlling the entry of dogs and cats into the

United States have not been substantively updated in decades. The final rule includes many

improvements in terms of public health protection against the reintroduction of DMRVV over

124 https://www.theatlantic.com/health/archive/2022/07/not-enough-veterinarians-animals/661497/.
125 https://www.agcanada.com/2021/07/is-the-veterinarian-shortage-real-or-
regional#:~:text=A%20perceived%20global%20shortage%20of%20veterinarians%20is%20creating,for%20the%2
0quality%20of%20care%20they%20can%20offer.
126 https://www.thebusinessresearchcompany.com/report/companion-animal-veterinary-vaccines-global-market-

report.
127 https://7news.com.au/lifestyle/pets/aussie-dog-owners-warned-of-national-vaccine-shortage-as-deadly-bacterial-

disease-spreads-c-8568550.
128 Hu RL, Fooks AR, Zhang SF, Liu Y, Zhang F. Inferior rabies vaccine quality and low immunization coverage in

dogs in China. Epidemiol Infect. 2008; 136: 1556-63.


129 Yale G, Sudarshan S, Taj S, Patchimuthu GI, Mangalanathan BV, et al. Investigation of protective level of rabies

antibodies in vaccinated dogs in Chennai, India. VetRecord. 2021; 8: e8.


130 Whitehill F, Bonaparte S, Hartloge C, et al. Rabies in a Dog Imported from Azerbaijan- Pennsylvania, 2021.

MMWR Morb Mortal Wkly Rep 2022; 71: 686-689.


131 Rota Modari E, Alonso S, Mancin M, De Nardi M, Hudson-Cooke S, Veggiato C, et al. Rabies vaccination:

higher failure rates in imported dogs than those vaccinated in Italy. Zoonoses and Public Health 2022; 64 (2): 146-
55.
the current regulations. Among other things, the final rule removes the current requirement for a

valid rabies vaccine certificate in 42 CFR 71.51(c) and replaces it with standardized rabies

vaccination forms that better prevents importers from submitting fraudulent rabies

documentation. The use of standardized forms also helps ensure that foreign-vaccinated dogs

imported from DMRVV high-risk countries meet CDC entry requirements prior to traveling to

the United States and allows for follow-up with the exporting country’s government officials if

needed. The final rule further requires pre-arrival rabies serologic testing, as well as

revaccination, examination, and, in some cases, quarantine upon arrival at a CDC-registered

ACF for foreign-vaccinated dogs from DMRVV high-risk countries. Additionally, the final rule

requires that all dogs be microchipped at the time of admission. Microchips are a widely used

method of confirming the dogs’ identity and help prevent importers from fraudulently presenting

dogs for admission that do not match the dogs’ accompanying health records. Finally, the

provisions in this final rule are estimated to reduce the number of dogs arriving ill or dead, which

should in turn conserve agency resources by diminishing the need for CDC to conduct public

health investigations to rule out whether the dogs may have died of a zoonotic disease of public

health concern, including DMRVV.

CDC also disagrees that it should maintain the same system in place as it used during the

temporary suspension. Beginning in June 2021, CDC published a temporary suspension of dogs

entering the United States from DMRVV high-risk countries. The temporary suspension created

a system that, among other things, implemented the use of standardized forms, required titer test

results demonstrating the presence of rabies antibodies in dogs, and authorized a private network

of ACF allowing for the immediate quarantine of dogs from DMRVV high-risk countries

arriving with inadequate proof of titers. Although this final rule implements a similar regulatory

framework based on the documented successes of the temporary suspension, there are important

differences. Unlike during the temporary suspension, the final rule does not rely on CDC issuing

CDC Dog Import Permits for foreign-vaccinated dogs from DMRVV high-risk countries. Rather,
the final rule relies on the network of private ACF to examine, revaccinate, and quarantine (if

necessary) foreign-vaccinated dogs from DMRVV high-risk countries. The final rule adopts this

system instead of the permit system used during the temporary suspension because issuing

permits costs CDC more in terms of personnel and IT services. By replacing the permitting

system for foreign-vaccinated dogs from DMRVV high-risk countries with a system of ACF,

CDC anticipates a reduction in costs and staff time associated with dog importation because the

importer will bear the costs of examination, revaccination, and quarantine (if needed) at an ACF.

During the temporary suspension CDC also continued to document attempts by importers

to submit fraudulent documentation to receive a CDC Dog Import Permit. CDC recognized there

is limited value in reviewing paperwork alone because physical inspection of animals in

combination with a review of paperwork submitted by importers has a greater likelihood of

allowing CDC to detect both fraudulent paperwork and communicable diseases of concern in

dogs. For example, in 2002-2023, ACF found several ticks on imported dogs. Investigation by

CDC and USDA determined these were novel, exotic ticks that had never been found in the

Western hemisphere. The health impacts of these ticks on people, livestock, wildlife, and pets are

unknown because they have not been studied previously. Physical examination of dogs, which is

crucial for rabies detection, at the ACF was also instrumental in detecting and preventing the

introduction of these novel ticks in the United States.

Comment: HHS/CDC received comments that the NPRM is not needed because U.S.

states already regulate rabies control within the United States.

Response: HHS/CDC disagrees with these comments. Although U.S. States establish

requirements relating to rabies vaccination and control within their own jurisdictions, it is

HHS/CDC’s role to regulate the importation of dogs into the United States from foreign

countries. The final rule should reduce the burden on state, local, and territorial public health and

animal health agencies and support U.S. State requirements. As noted above, a single

importation of a DMRVV-infected dog can cost affected State governments hundreds of


thousands of dollars for the ensuing public health investigations and rabies post-exposure

prophylaxis (PEP) treatments administered to exposed persons. The cost to State and local

governments can balloon significantly in the case of worst-case outcomes, which include: 1)

transmission of rabies to a person who dies from the disease; and 2) ongoing transmission to

other domestic and wildlife species in the United States.

There have been significant challenges for State and Federal agencies in enforcing or

verifying vaccination requirements in internationally imported animals. In 2021, the importation

of a rabid dog resulted in a ten-state multi-agency investigation to locate all people and animals

exposed to the rabid dog. It was the largest investigation of an imported rabid dog, to date, and

required immense resources and time from multiple states to complete. Furthermore, HHS/CDC

received comments from Federal, State, and Local government agencies in support of this rule.

State and local government agencies expressed support for requiring veterinary examination,

revaccination, and quarantine (if needed) of dogs on arrival to reduce the burden on these

agencies. These commenters also noted that these practices would also reduce the public health

risk that imported dogs pose to U.S. communities, domestic pets, and wildlife and would

improve the government’s ability to identify dogs with diseases or external parasites before they

enter the United States.

This final rule will reduce the enforcement burden on jurisdictions and help to ensure all

foreign-vaccinated dogs are vaccinated with a USDA-licensed vaccine on arrival, thereby

reducing the public health risk of these dogs and bringing the dogs into compliance with rabies

control requirements.

Comment: One commenter asserted the rule was unnecessary because the increase in

numbers of imported dogs was due to the COVID-19 pandemic and the pandemic has now

ended.
Response: CDC disagrees with this comment because demand for dogs from abroad has

remained high since the pandemic. Further, the pandemic disrupted rabies control programs in

high-risk countries, a trend that persists today and increases the risk of DMRVV importations.

Since 2021, the demand for puppies and rescue dogs has remained high. The trend in

purchasing and rescuing dogs from abroad has been noted in many countries, including the

United States.132, 133, 134, 135 Internationally, there has been significant growth within the

companion animal breeding industry with increasing international trade.136 Multiple international

and U.S. investigations have identified importations of puppies that were too young to meet

rabies vaccination requirements.137, 138, 139, 140 In addition, there is growing evidence that criminal

networks are becoming involved in the lucrative dog trade, and the illegal puppy trade was

reported to have increased during the pandemic.141, 142, 143 Because imported dogs will typically

encounter multiple people, pets, and other animals throughout their journey—beginning at the

airport in the country of departure and continuing with the airline, through the U.S. port, and pet

132 Pieracci, E., Williams, C., Wallace, R., Kalapura, C., Brown, C. U.S. dog importations during the COVID-19
pandemic: Do we have an erupting problem? PloS ONE,16(9), e0254287. Doi: 10.1371/journal.pone.0254287.
133 Wynne E. Dog lovers find prices rise steeply amid COVID-fueled demand. Australian Broadcasting Corporation

News. 20 May 2021.


134 Morgan L, Protopopova A, Birkler RID, Itin-Shwatz B, Sutton G, Gamliel A, et al. Human-dog relationships

during the COVID-19 pandemic: booming dog adoption during social isolation. Humanities and Social Science
Communications. 2021; 7(150): 1-11.
135 Velez M. I adopted my dog Cannoli from overseas. It’s easier than you think. 9/20/2020. Available at:

http://www.thedailybeast.com/i-adopted-my-dog-cannoli-from-overseas-its-easier-than-you-think.
136 Maher J, Wyatt T. European illegal puppy trade and organized crime. Trends in Organized Crime. 2021; 24(4)

506-525.
137 Pieracci, E., Williams, C., Wallace, R., Kalapura, C., Brown, C. U.S. dog importations during the COVID-19

pandemic: Do we have an erupting problem? PLoS ONE,16(9), e0254287. doi: 10.1371/journal.pone.0254287.


138 Zucca P, Rossman MC, Osorio JE, Karem K, De Benedictis P, Haifsl J, et al. The ‘bio-crime model’ of cross-

border cooperation among veterinary public health, justice, law enforcements, and customs to tackle the illegal
animal trade/bio-terrorism and to prevent the spread of zoonotic diseases among human population. Frontiers in
Veterinary Science. 2020; 7: 1-13.
139 Cocchi M, Danesi P, DeZan G, Leati M, Gagliazzo L, et al. A three-year biocrime sanitary surveillance on

illegally imported companion animals. Pathogens. 2021; 10(80):1-12.


140 Houle MK. Perspective from the field: Illegal puppy imports uncovered at JFK airport. 2017. Available at:

www.cdc.gov/ncezid/dgmq/feature-stories/operation-dog-catcher.html.
141 Maher J, Wyatt T. Rural-urban dynamics in the UK illegal puppy trade: trafficking and trade in man’s best friend.

International Journal of Rural Law and Policy. 2019; 9 (2): 1-20.


142 Zucca P, Rossman MC, Osorio JE, Karem K, De Benedictis P, Haifsl J, et al. The ‘bio-crime model’ of cross-

border cooperation among veterinary public health, justice, law enforcements, and customs to tackle the illegal
animal trade/bio-terrorism and to prevent the spread of zoonotic diseases among human population. Frontiers in
Veterinary Science. 2020; 7: 1-13.
143 British Broadcasting Corporation. Illegal puppy trade warning as sales boom during the COVID pandemic. 18

NOV 2020. British Broadcasting Corporation News.


adoption and pet socialization process—an increase in inadequately vaccinated dogs likewise

increases the risk of human and animal exposure.144

HHS/CDC received 118,312 signatures from supporters of international dog rescues,

suggesting the demand for dogs and the desire to import dogs from DMRVV high-risk countries

remains high. Additionally, a recent report published in 2022 found that retail pet stores and

shelters/rescues provide less than 15% of the puppies needed to meet annual U.S. demand. The

report suggests that the importation of dogs may be one of the main ways to supply the current

demand for dogs in the United States.145

B. General Comments on Burden

Comment: Most of the 200 comments stating that the rule was unnecessary also made

some type of assertion that the rule was generally excessive or too burdensome, without citing

specific requirements of the rule that the commenters believed were excessive or too

burdensome.

Response: HHS/CDC address comments about the burden of specific provisions of the

rule (e.g., titer and quarantine requirements) in more detail below. Regarding the claim that the

rule is generally too burdensome, HHS/CDC disagrees. As noted above, the risk of DMRVV

importation is a high-consequence event and increased fraud, the severe disruptions posed by

DMRVV re-introduction, and new gaps in domestic and international rabies control efforts

demand an update of U.S. dog importation requirements to ensure continued effective DMRVV

control. Further, the requirements of the rule itself align U.S. importation requirements with the

best practices advanced by WOAH, and the practices of member countries (including the United

States). In fact, this final rule is less burdensome than WOAH standards and the requirements of

144 Centers for Disease Control and Prevention. Quarantine Activity Reporting System (version 4.9.8.8.2.2A). Dog
importation data, 2018-2020. Accessed: February 15, 2021.
145 Pet dog supply and demand in the United States. 2022. Available at: wellbeingintl.org/pet-dog-supply-and-

demand-in-the-united-states/.
many other DMRVV-free countries, which reflects HHS/CDC’s considered efforts to reduce the

burden of the rule on importers while advancing best public health and importation practices.

WOAH has long recognized the risk of rabies to human and animal health. WOAH has

led the development of longstanding international animal movement standards to ensure that

dogs imported from DMRVV high-risk countries are vaccinated, have an adequate antibody titer,

appear healthy at the time of importation, and undergo a sufficient waiting period before

importation (or quarantine after arrival) to ensure they do not develop signs of rabies. WOAH’s

Terrestrial Manual146 states that all dogs, cats, and ferrets from rabies-endemic countries should

meet the following standards for international movement:

• Receive an international veterinary certificate prior to travel which confirms

administration of a rabies vaccine and a rabies antibody titer collected and tested

in accordance with the WOAH Terrestrial Manual;

• Undergo examination the day prior to shipment to ensure the animal is not

showing signs of rabies;

• Are permanently identified (e.g., microchip) with the identification number listed

on the certificate;

• Are vaccinated against rabies in accordance with manufacturer’s

recommendations with a vaccine that was produced in accordance with the

WOAH Terrestrial Manual;

• Have a titer test conducted not less than 3 months and not more than 12 months

prior to travel, with a titer test result ≥0.5 IU/mL; or

• Are kept in a Federal quarantine station for six months prior to shipment.

Seventy-one percent of rabies-free countries meet or exceed the WOAH standards for the

international movement of dogs from rabies-endemic areas whereas the current HHS/CDC

146 WOAH Terrestrial Manual 2023, chapters 3.1.18 and 8.15.7.


regulation for the importation of dogs and cats (42 CFR 71.51) does not align with WOAH

standards.147 This final rule adopts many but not all WOAH standards. HHS/CDC carefully

considered the WOAH standards when drafting the final rule. Consultation with rabies subject

matter experts and review of peer-reviewed literature allowed HHS/CDC to identify several

areas in which HHS/CDC could reduce the burden on importers while protecting public health.

The HHS/CDC requirements outlined in this final rule are less burdensome than WOAH

standards in the following ways:

• HHS/CDC is not requiring cats or ferrets meet the standards outlined by WOAH as

HHS/CDC is not aware of any previous reports of imported rabid cats or ferrets.

• HHS/CDC is not requiring examination of dogs the day before travel and is allowing a

longer time period between examination and travel to assist importers in submitting all

required documentation to the airlines in a timely manner to make flight reservations;

• HHS/CDC is not requiring the use of rabies vaccines manufactured in accordance with

the WOAH Terrestrial Manual as this would exclude individuals from importing dogs

from most DMRVV high-risk countries due to lack of availability of these high-quality

vaccines;

• Peer-reviewed findings suggest a shorter waiting period is adequate to prevent the

importation of a rabid dog that is incubating rabies at the time the titer is collected.148

CDC will publish the length of the waiting period in technical instructions. The technical

instructions will be based on the latest scientific information and may be updated in the

future based on new scientific information and advancements in veterinary medicine

related to vaccination and titer testing.

• HHS/CDC is not requiring a six-month quarantine prior to shipping an animal without a

titer as most countries do not have this capacity. Instead, HHS/CDC has identified CDC-

147 Unpublished data (C. Williams, CDC). October 24,2023.


148 Smith TG, Fooks AR, Moore SM, Freuling CM, Muller T, et al. Negligible risk of rabies importation in dogs
thirty days after demonstration of adequate serum antibody titer. Vaccine 2021; 39 (18): 2496-2499.
registered Animal Care Facilities that can provide quarantine services after arrival for

dogs unable to receive a titer prior to shipment.

HHS/CDC is not requiring a quarantine period of six months and is instead requiring 28-

days based on peer-reviewed findings, if the importer does not have rabies serologic test

results.149 This represents a significantly lower time and cost burden for importers.

C. Comments on Exemptions for Certain Groups

Comment: HHS/CDC received various comments suggesting that certain categories of

importers or types of dogs should not be subject to specific provisions of this rule, referenced as

“exemptions” here. These commenters proposed that the final rule should exempt 1) U.S.

government (USG) employees and military members (both routinely and during emergencies); 2)

certain U.S. citizens; 3) certified rescue organizations; 4) U.S.-based rescue organizations; 5)

breeders; and 6) certain types of dogs such as specific dog breeds, service dogs, government-

owned dogs, dogs used in research, U.S.-vaccinated dogs, and personal pets. Many commenters

noted that all of the rabid dogs imported into the United States since 2015 were imported by

rescue organizations; thus they contended that imposing requirements on other types of importers

was not necessary. Commenters suggested that HHS/CDC implement different import

requirements for different importers and tailor its requirements based on the risk profile of the

importer, and that CDC add definitional terms to distinguish between different types of importers

(e.g., pet owners, rescue groups). Other comments suggested creating a separate registration or

inspection system for commercial importers or rescue organizations or limiting the number of

dogs imported by rescue organizations.

Response: HHS/CDC disagrees with these comments. The final rule is designed to

address and reduce the risk of the importation of a dog with DMRVV. That risk exists based on

two factors: 1) the likelihood that an animal was exposed to DMRVV; and 2) whether the animal

149 Smith TG, Fooks AR, Moore SM, Freuling CM, Muller T, et al. Negligible risk of rabies importation in dogs
thirty days after demonstration of adequate serum antibody titer. Vaccine 2021; 39 (18): 2496-2499.
was sufficiently vaccinated to protect against infection. Based on these factors, available

evidence, and CDC’s experience with importations, a dog’s recent presence in a high-risk

DMRVV country and the dog’s vaccination status (U.S.- versus foreign-vaccinated) are the best

ways to evaluate the risk that an imported dog may have DMRVV. An importer’s statement

regarding the intended use of the dog (e.g., show dog, personal pet); the dog’s breed; whether it

is a service animal or working dog; the nationality of the importer; and the importer’s occupation

do not provide useful evidence for evaluating the risk of DMRVV presented by that animal.

While it is accurate that since 2015 dog rescue organizations have imported four dogs for

adoption that were subsequently found to be rabid, differentiating between commercial dog

importations and dogs imported as personal pets is operationally impracticable and increases

opportunities for fraud. For example, CDC has documented many importers who claimed to own

the dogs they were importing as personal pets, but upon further investigation by CBP, USDA,

and CDC it was determined that they were transporting the dogs for resale or on behalf of a

rescue organization. These importers admitted to being flight parents and misrepresented that

they were the personal owners of the dogs. They confirmed that they were unable to verify the

vaccination history or health status of the dogs they were transporting. Many had just met the

dogs for the first time at the airport on the day the flight departed. In 2017, a dog with rabies was

imported by a flight parent who was bitten during the flight and could not attest to the legitimacy

of the dog’s rabies vaccination paperwork.150 CDC suspected the paperwork was falsified

because the dog developed rabies and died.

False claims of ownership raise public health concerns because the importer does not

know the true health history of the dog and cannot accurately attest to their vaccination status

and rabies exposure history. This creates an increased risk of a rabid dog being imported and

these fraudulent claims also place importers at risk of exposure to rabies and other zoonotic

Hercules Y, Bryant NJ, Wallace RM, et al. Rabies in a dog imported from Egypt—Connecticut, 2017. MMWR
150

Morb Mort Wkly Rep 2018;67:1388–91. https://doi.org/10.15585/mmwr.mm6750a3.


diseases of concern. Applying standardized importation requirements for dogs based on their

vaccination status and recent presence in a high-risk country grounds the rule’s requirements in

the factors that actually determine DMRVV risk, helps ensure dogs are adequately protected

against rabies, and minimizes the risk of human exposure to rabies. Additionally, creating

different importation requirements for pets and rescue dogs could also create confusion and

increase the regulatory burden for airlines and the transportation industry who would be

responsible for documenting and ensuring that the importer is not misrepresenting the purpose of

the import.

Differentiating importation requirements based on the type of importer has also proven

impracticable based on CDC’s recent experience implementing the temporary suspension on

importation of dogs from DMRVV high-risk countries. On June 16, 2021, HHS/CDC announced

that temporary suspension to protect the public’s health. Through the temporary suspension,

CDC implemented requirements for importers of dogs from DMRVV high-risk countries. From

July 14, 2021, to June 9, 2022, CDC issued CDC Dog Import Permits on a limited basis, for

persons permanently relocating to the United States, importers of government-owned working

dogs, or owners of service animals to alleviate the potential burden of the temporary suspension

for these categories of importers.

On June 10, 2022, HHS/CDC modified the temporary suspension to allow commercial

importations of dogs from DMRVV high-risk countries through ACF. On July 10, 2023,

HHS/CDC extended the temporary suspension without modifications through July 31, 2024,

because of a continued risk of reintroduction of DMRVV due to insufficient veterinary controls

in DMRVV high-risk countries to prevent the export of inadequately vaccinated dogs and

veterinary supply chain and workforce capacity shortages that have persisted since the global

COVID-19 pandemic.

During the period of the temporary suspension, HHS/CDC attempted to differentiate

between personal pets and commercial dog imports and received hundreds of applications from
commercial importers claiming to be importing dogs as personal pets. Although CDC was able

to identify some of these cases and revoke dog import permits for ineligible importers, doing so

was difficult and required extensive communication between CDC and other port partners such

as CBP and USDA. As this experience shows, the stronger approach provided for in this final

rule is to tailor importation requirements based on factors with a relationship to DMRVV risk,

namely the country of origin and the dog’s vaccination status (U.S.- versus foreign-vaccinated),

as opposed to the category of importer (e.g., commercial importer) or type of dog (e.g., personal

pet). Further, this approach conserves Federal agency resources that would otherwise be used in

investigating and responding to potential instances of fraud.

In sum, basing importation requirements on a dog’s vaccination status and its potential

exposure to DMRVV (i.e., whether it has been recently been in a high-risk DMRVV country) is

the best way to evaluate the DMRVV risk of an imported dog; basing requirements on the

purpose of the importation, occupation or nationality of the importer, or the breed or working

status of the dog would be an ineffective means for evaluating DMRVV risk, would increase

incentives for fraud in the ways mentioned above, and be difficult to implement. Because

HHS/CDC is not basing importation requirements on the type of importer, there is no reason for

the final rule to define specific categories of importer (e.g., pet owner, rescue organization,

commercial importer).

Comment: HHS/CDC received over 400 comments from U.S. Government (USG)

employees and members of the U.S. military objecting to the proposed rule. Some of these

commenters stated that these groups should be given special exemption to import dogs without

meeting some or all of the proposed requirements. Other commenters stated that they believed

that the proposed rule was specifically targeting USG employees. Some of these commenters

asserted that the proposed rule is unnecessary because USG employees and military members are

less likely to commit fraud and purportedly provide a higher standard of care for their dogs when
compared to other dog owners, thereby negating the rabies risk. Commenters noted potential

financial burdens and hardships when having to route through ports with ACF or having to pay

for titers.

Response: HHS/CDC disagrees that USG employees and members of the U.S. military

should be exempt from any or all importation requirements. CDC has no data to support the

proposition that dogs owned by USG employees or members of the U.S. military are better cared

for than other dogs or that individuals in these groups are less likely to attempt to import dogs

with falsified documents or fraudulent or insufficient titers. CDC has documented multiple

instances of falsified documents, including intentionally altered import permits, forged titer

results, and falsified rabies vaccination records, submitted by U.S. government employees and

military service members both during and prior to CDC’s temporary suspension of dogs entering

the United States from high-risk countries. CDC reported violations to the USDA, the

Department of Defense, and the State Department for internal investigation. Additionally, CDC

has documented numerous reports of U.S. government employees, including military service

members, adopting stray dogs while stationed overseas. CDC supports the human-animal bond

and recognizes the important role these animals play in the lives of government employees and

service members stationed overseas; however, the employment status of the importer does not

affect the dog’s potential risk of carrying DMRVV. Adopted stray dogs often have unknown

rabies exposure history, have received little or no veterinary care or vaccines, and can present a

risk of DMRVV just like any other dog that has been in a high-risk country with an unconfirmed

vaccination status. Vaccination, titer, and quarantine requirements are essential to protect USG

employees, service members, and their families as well as the U.S. communities these dogs are

being introduced into when they arrive in the United States. Furthermore, HHS/CDC strongly

disagrees that this final rule specifically targets USG employees. This rule bases its importation

requirements on the risk profile of the dog’s country of origin and the dog’s vaccination status

(U.S.- versus foreign-vaccinated), and not the type of importer. It imposes no additional
requirements on USG employees or members of the U.S. military compared to any other

importers. Finally, the State Department has made relocation funds available to U.S. government

staff for quarantine fees or titer services. Additionally, there are CDC-approved laboratories

providing discounted services for USG employees. In sum, the risk of DMRVV importation is

best determined based on a dog’s vaccination status and its recent presence in a DMRVV high-

risk country rather than the employer of the importer. Thus HHS/CDC declines to create a

specific exemption for USG employees and military members.

Comment: HHS/CDC received comments noting that USG employees, members of the

U.S. military, U.S. citizens, and U.S. permanent residents often need to return to the United

States quickly with their families when an unexpected crisis develops in a foreign country, and

that exemptions should be provided in these instances. Some comments said exceptions should

be made or requirements should be different for emergency situations without specifying a

category of importer that should be exempted.

Response: HHS/CDC recognizes that USG employees, members of the U.S. military, U.S.

citizens, and U.S. permanent residents often need to return to the United States quickly with their

families when an unexpected crisis develops in a foreign country. In these scenarios, CDC works

closely with the U.S. State Department on a case-by-case basis regarding emergency departures

from foreign countries. CDC has assisted the U.S. State Department with more than ten

evacuations during the temporary suspension, including evacuations of USG staff from Ukraine,

Ethiopia, Nigeria, Haiti, and China, and has ensured foreign services officers were able to

evacuate safely with their pet dogs. However, HHS/CDC declines to create a specific exemption

under these circumstances because dogs from high-risk rabies countries continue to present a

potential DMRVV importation risk regardless of whether imported in emergent or non-emergent

circumstances. HHS/CDC plans to continue to support importers during emergency situations by

assisting them in making reservations at ACF and educating importers about the importance of

maintaining their dog’s current rabies vaccination. Potential importers of foreign-vaccinated


dogs from DMRVV high-risk countries should also always maintain a valid rabies titer for their

dogs from a CDC-approved laboratory in the event of an unplanned emergency. Additionally,

HHS/CDC is reducing the burden on importers to maintain a valid titer from a CDC-approved

laboratory by reducing the frequency with which titers must be drawn and tested compared to the

annual titer requirement during the temporary suspension, which will assist importers in the

event of an emergency (see CDC technical instructions available at www.cdc.gov/dogtravel).

Given the demonstrated and close effective working relationship between CDC and the U.S.

Department of State, CDC does not believe a specific exemption for emergencies is necessary in

the final rule.

Comment: HHS/CDC received five individual comments and one form letter from an

organization representing foreign service officers stating that the proposed requirements in the

NPRM on government employees with dogs would result in U.S. employees retiring from public

service or would cause them to avoid working in DMRVV high-risk countries.

Response: HHS/CDC appreciates these comments but believes the updated regulation is

necessary to protect the public’s health and to prevent the reintroduction of DMRVV into the

United States because there is a continued threat posed by dogs from high-risk countries that are

unvaccinated or inadequately vaccinated against rabies. This continued threat is due to various

factors, including: a high volume of dogs being imported into the United States contemporaneous

with insufficient veterinary controls in high-risk countries to prevent the export of inadequately

vaccinated dogs, inadequate veterinary supply chains for vaccines and related materials, and

persistent workforce capacity shortages, particularly in high-risk countries that export dogs to the

United States. HHS/CDC is addressing the various risks associated with the importation of dogs

observed in recent years by establishing a regulatory framework based on the documented

successes of the temporary suspension. In addition, the requirements and standards in the rule

will help ensure the health and safety of the public while also protecting animal health and

preventing the reintroduction of DMRVV into the United States.


HHS/CDC is easing the burden on all importers, including USG employees, by relaxing

the entry requirements for U.S.-vaccinated dogs so they may enter through any U.S. port if they

meet the criteria outlined in §71.51(t) of the final rule. HHS/CDC is also revising the titer

requirements for foreign-vaccinated dogs to reduce both the waiting period before entry into the

United States, and the frequency with which titers must be collected.

Further, HHS/CDC’s requirements remain less burdensome when compared to WOAH

standards that are widely used in other rabies-free countries. As noted above, HHS/CDC

carefully considered the WOAH standards when drafting the final rule, consulting with rabies

subject matter experts and reviewing peer-reviewed literature. Based on these considerations and

experience during the temporary suspension, HHS/CDC eased requirements on importers,

including USG employees, relative to WOAH standards in several key areas, including but not

limited to: (1) applying requirements only to dogs; (2) not requiring examination the day before

travel; (3) not requiring use of vaccines manufactured in accordance with the WOAH Terrestrial

Manual; (4) not requiring a six-month quarantine prior to shipping an animal without a titer; and

(5) requiring only a 28-day quarantine rather than six months. The approach in this final rule

represents an appropriate balance between flexibility for importers while protecting against

importation of DMRVV from high-risk countries.

Additionally, HHS/CDC’s requirements remain less burdensome when compared to other

countries, such as European Union member states and Australia, that have strengthened their

importation requirements for the international movement of dogs (even for animals merely

transiting through such countries). The increased challenges that some government employees

may face when stationed abroad reflect an international effort to reduce the spread of foreign

animal diseases associated with the movement of animals and are not solely a result of this final

rule.

Comment: HHS/CDC received a comment that USG-owned dogs (as distinguished from

dogs owned by USG employees) should be exempt from HHS/CDC entry requirements.
Response: An exemption for USG-owned dogs is unnecessary because based on CDC’s

discussions with USG agencies that utilize government-owned working dogs the dogs owned by

the USG are all over six months of age, are microchipped, and maintain a current and valid U.S.

rabies vaccination prior to deployments. HHS/CDC does not consider the final rule to be overly

burdensome in this regard such than any form of exemption is needed.

Comment: HHS/CDC received a comment stating that dogs imported for research

purposes should be exempt from entry requirements.

Response: HHS/CDC has determined that a research exemption is not necessary given

the infrequency with which dogs are imported for research purposes from DMRVV high-risk

countries. For instance, in the past five years, CDC has not received any requests to import dogs

for research purposes. Furthermore, during the more recent period of the temporary suspension,

CDC has not documented any dogs imported for research from DMRVV high-risk countries. The

final rule allows for the importation of unvaccinated dogs from DMRVV-free or DMRVV low-

risk countries if the dogs have been only in those countries during the six months before arriving

in the United States. Therefore, importers seeking to import unvaccinated dogs for research

purposes may do so from DMRVV-free or DMRVV low-risk countries. Thus, considering the

infrequency with which dogs are imported for research purposes and the availability of dogs

from DMRVV-free or DMRVV low-risk countries that can be used for research, HHS/CDC does

not believe an exemption for individuals seeking to import dogs for research purposes is needed.

Comment: HHS/CDC received comments that the rule may be detrimental to animal

welfare and inhibit rescue organizations’ ability to import dogs.

Response: While HHS/CDC acknowledges that the final rule will result in additional

requirements for some rescue groups to operate from high-risk countries, these difficulties do not

outweigh the benefits to U.S. public health. HHS/CDC believes that, in addition to protecting

public health, the rule will likely better ensure the health of dogs prior to their release into the

United States. This helps protect the domestic dog and animal populations, as well as people,
from communicable diseases that imported dogs may carry and spread into U.S. communities.

There is no clear reason why dogs imported by rescue organizations would be at a lower risk of

DMRVV than other dogs from high-risk rabies country. Nothing in the rule prevents rescue dogs

from being imported if they meet entry requirements. HHS/CDC further notes that commercial

importers and rescue groups were adept at responding to changes in import requirements

established during the period of the temporary suspension and that this rule adopts many of those

same practices. Accordingly, HHS/CDC believes an exemption is not required.

Comment: HHS/CDC received comments that the proposed requirements for individual

pet owners were excessive because there have been few rabid dog importations, and these were

all from animal rescue organizations, and that personal pets should be exempt from the

importation requirements.

Response: Although the final rule is more burdensome for individuals importing dogs as

pets when compared to the current regulation, HHS/CDC believes it is less burdensome when

compared to dog importation standards among other WOAH member countries. As more

countries have strengthened their importation requirements for the international movement of

dogs, the requirements in HHS/CDC’s final rule remain less cumbersome than what other

countries, such as European Union member states, Australia and New Zealand, require for the

movement of animals, including for animals merely transiting through such countries. The

increased challenges that some pet owners may face when traveling abroad reflects an

international effort to reduce the spread of foreign animal diseases associated with the movement

of animals and are not solely a result of this final rule.

Further and as noted above, although recent rabid dog importations have been associated

with rescue groups, HHS/CDC has determined that the public health risk from dog imports is

based primarily on the dog’s country of origin and vaccination status (U.S.- vs. foreign-

vaccinated), and not the type of importer. HHS/CDC further notes that attempting to distinguish

between pet owners and rescue groups would be difficult to enforce and creates opportunities for
fraud. In CDC’s experience, as noted above, it is not unusual for importers to misrepresent the

reasons why dogs are being imported. As noted above there has been an increase in fraudulent

importations and importers misrepresenting that they were the personal owners of the dogs. Such

an increase in importers misrepresenting the purpose for which dogs are being imported could

increase the risk of a rabid dog being imported and also place importers at risk of exposure to

rabies and other zoonotic diseases of concern.

Applying standardized importation requirements for all dogs regardless for the reasons

why dogs are being imported (i.e., rescue, resale, personal pet) helps minimize the risk of human

exposure to rabies and ensure dogs are adequately protected against rabies. Therefore, HHS/CDC

has decided to apply the rule’s requirements equally to all importers to ensure imported dogs do

not present a public health risk.

D. Comments on Specific Provisions of the Proposed Rule

Definitions

Comment: HHS/CDC received specific comments on the following sections and

paragraphs of the proposed rule.

Section 71.50

Paragraph (a) — Definitions

HHS/CDC received comments on the following definitions:

Authorized Veterinarian

Comment: HHS/CDC received a comment requesting that CDC “define the term

‘Authorized Veterinarian’ in order to establish a single documentation standard all carriers can

follow.”

Response: HHS/CDC has finalized the definition for authorized veterinarian that was

proposed in the NPRM with minor modifications for clarification. Per the final rule, authorized

veterinarian means an individual who has an advance degree relevant to the practice of
veterinary medicine, has a valid license or accreditation, and is authorized to practice animal

medicine in the exporting country.

DMRVV low-risk countries

Comment: HHS/CDC received a comment that instead of using the terms “low-risk

countries” or “rabies-free countries” it should use the terms “countries free of canine rabies” and

“countries with low risk of canine rabies.”

Response: HHS/CDC appreciates this comment but declines to incorporate the suggested

changes. HHS/CDC notes that the commenter’s concerns relate solely to grammar and the

commenter has proposed terms conveying the same meaning as those used in the proposed rule.

HHS/CDC has chosen the terms DMRVV-free and DMRVV low-risk because HHS/CDC

believes these terms are easy to use and likely to be understood by stakeholders.

Importer

Comment: HHS/CDC received comments to define and clarify the term “flight parent.”

Response: In the proposed rule, HHS/CDC did not include a definition for “flight parent”

but used this term in the preamble to describe a person that transports one or more dogs for the

purpose of resale, adoption, or transfer of ownership. The flight parent may be compensated

(e.g., provided with a complimentary airplane ticket, baggage fees, or other paid fee) for the

transport of the animal or agree to transport the animal as an uncompensated volunteer. CDC

added a definition for “flight parent” to the final rule. Per this final rule, if required by CBP or

USDA, flight parents transporting animals must have a valid license or registration to transport

animals.

Comment: HHS/CDC received a comment stating that friends and family who transport

dogs belonging to USG employees should be excepted from the definition of flight parent.

Response: HHS/CDC reiterates that flight parents are limited to those individuals

transporting one or more dogs for purposes of resale, adoption, or transfer of ownership. If a

friend or family member is transporting a dog for purposes of returning the dog to its owner, who
was previously in physical possession of the dog, then the friend or family member would not be

considered a flight parent. Alternatively, if the dog’s owner in the United States merely

purchased a dog from another owner or breeder in a foreign country and never previously

physically possessed the animal, then the individual transporting the dog would be considered a

flight parent regardless of their relationship to the U.S. owner.

Official government veterinarian

Comment: HHS/CDC received questions about how HHS/CDC defines a government

veterinarian.

Response: HHS/CDC’s definition of an official government veterinarian is outlined in

71.50 and states it is “a veterinarian who performs work on behalf of an exporting country’s

government and can verify the license or credentials of an Authorized Veterinarian.”

Forms

Comment: HHS/CDC received comments on the definitions of CDC Import Certification

of Rabies Vaccination and Microchip Required for Live Dog Importations into the United States

and Certification of U.S.-issued Rabies Vaccination for Live Dog Re-entry into the United States.

Response: These comments are addressed below in our replies to paragraph (s) and

paragraph (t). HHS/CDC notes that it has shortened the names of these forms in the final rule to

Certification of Rabies Vaccination and Microchip and Certification of U.S.-issued Rabies

Vaccination, respectively.

Importation

Comment: HHS/CDC received a comment that HHS/CDC “needs to better define what

conditions they are considering when they are talking about ‘importation’ and what activity they

are trying to regulate.” The comment stated that U.S. government personnel bringing a pet dog or

cat back to the United States are not “importing” an animal.

Response: HHS/CDC welcomes the opportunity to further explain what it means by

“importation” but disagrees that individuals, including U.S. government personnel, bringing dogs
or cats into the United States from foreign countries are not “importing” an animal just because

the animal is returning to the United States from a foreign country. HHS/CDC considers an

importation to occur whenever a dog or cat is entering the United States from a foreign country,

regardless of whether the animal was in the United States previously and is seeking to reenter the

United States. Through this final rule, HHS/CDC is seeking to regulate the importation of dogs

and cats into the United States. Although HHS/CDC acknowledges that pets may have emotional

value to their owners, animals are considered to be “goods” (i.e., merchandise or property that

can be moved) that are imported into the United States if arriving from foreign countries. Per the

definition for importer in this final rule, importer means “any person importing or attempting to

import an animal into the United States, including an owner, or a person acting on behalf of an

importer, such as a broker registered with CBP or a flight parent. If required by USDA or CBP,

an individual transporting an animal on behalf of an importer, including a flight parent must

possess all required Federal licenses or registrations to transport animals.” U.S. government

personnel bringing dogs or cats into the United States from foreign countries would be included

under this definition of “importer.”

HHS/CDC did not receive comments on the following definitions proposed for 42 CFR

70.50: cat, dog, histopathology, in-transit shipment, microchip, and necropsy.

HHS/CDC also did not receive comments on the following definitions proposed for 42

CFR 71.51: animal, CDC-registered animal care facility, CDC Dog Import Form, conditional

release, DMRVV, DMRVV-restricted countries, SAFE TraQ, serologic testing, USDA-accredited

veterinarian, or USDA official veterinarian.

Sections 71.51

Paragraphs (b) — Authorized U.S. airports for dogs and cats and (c) —Authorized U.S. land

ports for dogs and cats.;


Comment: HHS/CDC received several comments regarding permissible ports of entry.

Some commenters opposed any restrictions on ports of entry for any dog being imported into the

United States. Other commenters opposed restrictions only for U.S-vaccinated dogs, suggesting

that these dogs should be able to enter through any U.S. port and/or be able to enter at U.S. land

ports. Some comments suggested that entry be allowed for all personal pets at U.S. ports with

CDC quarantine stations. Some comments suggested that entry be allowed at all U.S. ports for all

dogs, at all U.S. ports for U.S.-vaccinated dogs, for all personal pets at ports with CDC

quarantine stations, and for dogs from DMRVV high-risk countries at land-borders.

HHS/CDC also received comments acknowledging the need to limit the number of

authorized ports to reduce fraud and provide greater government oversight to adequately regulate

dog imports from DMRVV high-risk countries and inspect shipments of dogs on arrival.

Response: HHS/CDC disagrees with comments suggesting that there should be no

restrictions on ports of entry for any dogs entering the United States from foreign countries. The

port of entry requirements proposed in the NPRM and finalized through this rulemaking

safeguard the public’s health by ensuring that adequate staff and facilities are available to

provide care for and evaluate foreign-vaccinated dogs from DMRVV high-risk countries for

rabies and other diseases that may pose a public health risk. CDC has documented previous

instances of dogs not meeting CDC requirements that arrived at U.S. ports that lack adequate

facilities to care for and house abandoned dogs or dogs denied entry into the United States. In

other instances, adequate housing facilities and care were arranged only with great difficulty,

which potentially endangers the health of both dogs and animal handlers. The port of entry

requirements are further designed to reduce the burden on airlines, CBP, state/local health

departments, and the local veterinary community by ensuring foreign-vaccinated dogs from

DMRVV high-risk countries arrive only at a U.S port with an ACF.

However, based on comments received and its review of available data, HHS/CDC has

revised the requirements proposed in the NPRM regarding imports of U.S.-vaccinated dogs.
CDC has a high degree of confidence in the safety and effectiveness of USDA-licensed rabies

vaccines administered by U.S. veterinarians within the United States. Therefore, HHS/CDC is

revising its proposal to allow dogs from DMRVV high-risk countries that are at least six months

old, microchipped, and have a valid Certification of U.S.-issued Rabies Vaccination form and a

CDC Dog Import Form receipt to re-enter the United States through any U.S. port (by air, land,

or sea).

Comment: HHS/CDC received comments that there are too few U.S. ports with ACF for

foreign-vaccinated dogs to enter the U.S.

Response: HHS/CDC believes there is an adequate number of ACF currently available

for the volume of foreign-vaccinated dog importations into the United States (less than 1% of

dogs imported into the United States require quarantine). CDC recognizes that more ACFs would

further reduce the burden on travelers, and is working to expand the network of ACF to provide

importers with greater flexibility for ports of arrival. ACF are able to receive, examine, vaccinate

and release dogs within 1 business day of arrival, most of which are cleared the same day they

arrive. Additional ACF would provide importers additional travel flexibility for ports of arrival,

and CDC is dedicated to expanding the number of available ACF. CDC worked with USDA,

CBP, and local businesses to identify and approve five ACF in 2021 and 2022 as part of the

strategic shift towards safer importation controls. HHS/CDC notes that since the publication of

the NPRM, it has registered two additional ACF at Los Angeles International Airport and

Philadelphia International Airport. As of April 1, 2024, there are seven CDC-registered ACF

with a USDA intermediate handlers registration and a FIRMS code issued by CBP. The facilities

are located at Atlanta Hartsfield-Jackson International Airport, John F. Kennedy International

Airport (New York), Los Angeles International Airport (2), Miami International Airport,

Philadelphia International Airport, and Washington Dulles International Airport (Washington

DC Metropolitan Area). The registration of new ACF at additional ports continues to be a

priority for HHS/CDC.


Comment: Commenters noted travel with animals in cargo into certain ports of entry can

be restricted during times of the year due to extreme temperatures.

Response: HHS/CDC acknowledges that some airlines may restrict dogs flying as cargo

into certain ports during different times of the year but notes that this is an airline requirement

put in place for the protection and safety of animals and is not a function of this rulemaking

process. Transportation restrictions due to extreme temperatures is a component of the Animal

Welfare Act which is enforced by USDA APHIS Animal Care. However, HHS/CDC

acknowledges that international travel is stressful for animals and can result in illness and death

in young or old animals, specialty breeds (i.e., snub-nosed breeds, hairless breeds, etc.), or those

with pre-existing medical conditions that cannot compensate for the stresses they undergo during

travel, including extreme temperatures. Therefore, HHS/CDC defers to USDA APHIS AC to

determine appropriate regulatory requirements for the movement of animals during extreme

weather conditions and encourages all air carriers to comply with USDA APHIS AC standards.

Comment: Commenters recommended that HHS/CDC seek greater uniformity among

U.S. ports handling dog imports. It was noted that each U.S. port has their own procedure, often

with their own “job aid” document requirements, which can be unhelpful and lead to

unnecessary confusion. It was suggested by a commenter that HHS/CDC’s requirements should

supersede and preclude duplicate data requirements or job aids at U.S. ports.

Response: HHS/CDC appreciates this comment but notes that several Federal agencies

have authority over operations at U.S. ports and CDC does not establish procedures for how

those agencies conduct their own operations. However, HHS/CDC does work closely with port

partners to develop and disseminate standardized documents (e.g., job aids, trainings,

presentations) to promote consistency between ports and will continue to do so as the final rule is

implemented. For example, during the temporary suspension, CDC worked closely with CBP

and airlines to disseminate standardized job aids nationwide to streamline importation operations

at the ports.
Paragraph (e) — Limitation on U.S. ports for dogs and cats.

HHS/CDC received no public comment on this provision of the rule.

Paragraph (f) — Age requirement for all dogs.

Comment: HHS/CDC received comments in support of the six-month age requirement

from individuals concerned about animal welfare and from public health and animal health

organizations and agencies. HHS/CDC also received numerous comments opposing the six-

month age requirement for dogs as too high. Commenters, including representatives of the airline

industry, breeders, breed enthusiasts, and trade groups, stated that dogs should be allowed entry

at either 12 weeks of age (the earliest age at which dogs can be vaccinated against rabies), or 16

weeks of age (the earliest age at which the vaccine is considered effective), or at any age (if

arriving from a DMRVV low-risk or DMRVV-free country).

Response: HHS/CDC agrees that establishing a six-month age requirement for all dogs

will assist in protecting public health while simultaneously improving safety and welfare benefits

for young animals subjected to stressful travel environments in which their health could be

compromised.

HHS/CDC disagrees, however, with comments suggesting that dogs should be admitted

into the United States if under six months of age. The purpose of an age requirement in the

context of dogs arriving from DMRVV high-risk countries is to ensure 1) that imported dogs are

old enough to be vaccinated for rabies; 2) that the vaccination has time to be effective and confer

immunity on the dog; 3) that protection is verifiable; and 4) that there is an appropriate waiting

period after drawing the titer to ensure the dog does not develop symptoms of rabies. In short, it

is not sufficient that a dog be old enough to be vaccinated; there must be sufficient time for

immunity to develop, and authorities must be able to verify the immunity. CDC has also

documented cases of importers moving dogs too young to be vaccinated effectively from
DMRVV high-risk countries to DMRVV-free or DMRVV low-risk countries to avoid rabies

vaccination requirements. Therefore, CDC is also requiring that dogs from DMRVV-free or

DMRVV low-risk countries be at least six months old to prevent importers from trying to

circumvent CDC’s requirements by moving dogs from DMRVV high-risk countries through

DMRVV-free or DMRVV low-risk countries.

The WOAH established vaccine and titer standards set seven-months as the minimum age

for importation of dogs from DMRVV high-risk countries.151 Countries following WOAH

standards do not allow entry of dogs younger than seven months old if following vaccine and

titer timeline recommendations. Many rabies vaccines are licensed for use in dogs on or after 12

weeks of age and laboratories suggest titer collection occur 30 days after initial rabies

vaccination. WOAH's standards call for importation to occur a minimum of 90 days after titer

collection (i.e., earliest age for importation is seven months of age).

The final rule departs from the WOAH standard to provide additional flexibility and less

burden to importers without compromising public health goals. HHS/CDC agrees that vaccine

administration must follow manufacturer’s guidelines (i.e., with vaccination occurring on or after

12 weeks of age) and a 30-day period between vaccination and titer collection is essential to

ensure the animal has developed an adequate antibody response to vaccination. However, based

on available scientific evidence,152 HHS/CDC concluded that a 30-day waiting period (rather

than WOAH's 90-day waiting period) between titer collection and travel is sufficient for

monitoring the dog to ensure it does not develop signs of rabies.

HHS/CDC is also establishing a six-month age requirement for all dogs because it can be

difficult for veterinarians to determine with specificity whether a dog has reached the age at

which it can be fully protected by the rabies vaccine before six months of age. Veterinarians rely

151 WOAH Terrestrial Manual 2023, chapters 3.1.18 and 8.15.7.


152 Smith TG, Fooks AR, Moore SM, Freuling CM, Muller T, et al. Negligible risk of rabies importation in dogs
thirty days after demonstration of adequate serum antibody titer. Vaccine 2021; 39 (18): 2496-2499.
on dental patterns to age dogs. However, it is difficult to accurately assess the age of dogs that

are between four and six months old due to variability in an individual dog’s dental eruption

patterns (loss of baby teeth).153 Dogs lose all their deciduous (baby) teeth by six months of age

making it easier to accurately assess the age of a dog. CDC has documented over 1000 cases of

importers providing vaccine records that falsely stated the dog was over six months of age, but

upon examination, the dog presented was much younger (often 6-8 weeks of age). Because the

rabies vaccine is not considered effective in dogs under 12 weeks of age these puppies were not

protected against rabies and presented a threat to the families that purchased or adopted them. By

requiring all dogs to be at least six months of age, CDC can better confirm that the dog presented

matches the documentation presented, particularly the age listed for the dog, and that the dog is

old enough to have been adequately vaccinated for rabies.

The six-month requirement for all dogs also aligns with USDA importation rules, eases

enforcement of the vaccination requirements, and reduces opportunities for fraud. USDA

requires dogs imported for commercial purposes (e.g., resale, rescue, or adoption) to be at least

six months of age. Aligning with USDA requirements for commercial dog imports will help

minimize confusion among travelers importing dogs from outside the United States, and among

airlines and port partners that enforce HHS/CDC and USDA entry requirements for dogs.

Setting the minimum age for importation below six months would undermine the ability

of authorities to ensure dogs are fully, effectively, and verifiably vaccinated. A 12- or 16-week

age requirement for importation would require potentially compromising the full 28-day

development of immunity and/or risk importation of a rabid dog because screening fully for

signs of rabies was not done. Screening for rabies can be difficult in puppies because they can

often exhibit dyskinetic or uncoordinated movement as part of their normal growth and

development. These awkward movements can also be seen in rabid dogs and may be mistaken in

153Roccaro, M., & Peli, A. (2020). Age determination in dog puppies by teeth examination: legal, health and welfare
implications, review of the literature and practical considerations. Veterinaria Italiana, 56(3), 149–162.
https://doi.org/10.12834/VetIt.1876.9968.2
young puppies for normal movement patterns. Contrary to some common misconceptions,

puppies are susceptible to rabies and rabies has been diagnosed in young puppies. For these

reasons, the final rule sets six months as the appropriate minimum age for dog importation.

Comment: HHS/CDC received comments opposing its proposal to allow importers to

import up to three dogs under the age of six months if arriving into the United States from

Mexico or Canada, contending that the requirements between land and air should be the same.

Some commenters also opposed any limit on the number of dogs under six months of age that an

importer could import through U.S. land ports. Specifically, HHS/CDC received a comment

from the airline industry stating that requiring a six-month age limit for all dogs arriving by air,

but not for all dogs arriving by land, was neither fair nor equitable. Additionally, commenters

noted that allowing dogs under six months of age at the land border potentially created a

loophole for importers from DMRVV high-risk countries to exploit.

Response: HHS/CDC agrees that dogs should be subject to the same age requirement

regardless of whether arriving by air, land, or sea. Furthermore, HHS/CDC also agrees that

allowing some dogs under six months of age to arrive via the land border potentially creates a

loophole for unscrupulous importers to exploit. CDC and CBP have documented numerous

instances in which importers transported dogs from a DMRVV high-risk country to Mexico (a

DMRVV-free country) and who then made claims that their dogs had not been in a DMRVV

high-risk country. CDC worked with CBP and airlines and were able to confirm the importers

had traveled with the dogs from a DMRVV high-risk country and were attempting to avoid U.S.

entry requirements. If CDC were to allow dogs under six months of age to enter via land border

crossings, CBP and CDC believe this could create a significant burden on CBP officers at U.S.-

Mexico border crossings as more importers would attempt to enter the United States through a

land border crossing. This could potentially lead to dogs from DMRVV high-risk countries

arriving in the United States via land borders to circumvent HHS/CDC entry requirements.

Given that CDC has no ACF at land border crossings this creates a potentially dangerous
situation for dogs that must be held pending determination of their admissibility since neither

CBP nor CDC have safe housing options at land ports of entry.

HHS/CDC originally proposed a limited exemption for dogs under six months old

primarily to reduce the burden on U.S. travelers who frequently travel across the U.S. and

Canada/Mexico borders and choose to travel with young dogs. Although data suggests more

dogs enter the United States by air each year, extrapolated data from 2006 estimated that 287,000

dogs entered the United States through land border crossings that year.154 CDC does not have

recent data to confirm the volume of dogs crossing at land borders, but unofficial statements

from CBP officers stationed at U.S.-Mexico land border crossings suggest the volume remains

high. However, upon further consideration and careful evaluation of the comments received,

HHS/CDC has removed the exemption proposed in the NPRM to create a uniform standard for

all dogs, ensure U.S.-land borders are not overwhelmed with dog importations, and reduce the

risk of importers fraudulently claiming that their dog has not been in DMRVV high-risk country.

HHS/CDC has documented many instances of young dogs under six months of age being

routed from DMRVV high-risk countries through DMRVV-free countries, such as Canada or

Mexico, to circumvent U.S. entry requirements. To prevent this type of fraud, HHS/CDC

believes there is reasonable need to require a standardized age for all dogs, regardless of the

purported country of origin or port of entry. Accordingly, HHS/CDC has removed from the final

rule the exemption at land borders proposed in the NPRM for an importer to import up to three

dogs under six months of age through Canada or Mexico via a U.S. land port if the dog has not

been in a DMRVV high-risk country or DMRVV-restricted country since birth.

Comment: There were also comments that a six-month minimum age requirement for all

imported dogs could lead to the decline of specialty breeds. Commenters stated that breeders in

other countries would not want to house and care for dogs bred for resale for six months due to

154McQuiston JH, Wilson T, Harris S, Bacon RM, Shapiro S, et al. Importation of dogs into the United States: risks
from rabies and other zoonotic diseases. Zoonoses and Public Health; 2008: 1-6.
increased cost. Additional commenters said dogs need to be socialized with their owner prior to

six months of age.

Response: HHS/CDC disagrees with these comments. First, USDA prohibits the

importation of dogs under six-months of age for commercial purposes, which includes any

transfer of ownership; therefore, the comment that breeders need to be able to import dogs under

six months of age is invalid because it is already prohibited. CDC’s age requirement is aligning

with a currently existing regulatory requirement from a partner Federal agency. CDC’s

requirement is not new and therefore, there is no new or additional burden on commercial dog

importations (i.e., dogs imported for rescue, resale, or transfer of ownership). Additionally, CDC

notes that a six-month age requirement aligns more closely with WOAH requirements for the

international movement of dogs and that 67% of DMRVV-free countries require dogs to be at

least six months of age for importation.155 Furthermore, because dogs under six months of age

are sexually immature and cannot be used for breeding, delaying their importation will not

negatively impact their use as breeding animals.

Second, although the primary public health reason for requiring a six-month age

limitation for importation has been described above, HHS/CDC notes that socialization of

puppies may be done overseas at the breeding facility or another overseas location such as a

kennel or foster family prior to the dogs arriving in the United States. Additionally, the rule will

likely better ensure the health of dogs during international travel to the United States, which is

stressful for young animals and can result in illness and death. As noted above, the six-month age

requirement for importation helps protect the health and safety of all dogs. HHS/CDC further

notes that breeders and commercial importers effectively adapted to changing import

requirements during the temporary suspension and that this rule adopts many of those same

practices.

155 Internal CDC data. Accessed January 30, 2024.


HHS/CDC further notes that separating puppies from the mother and littermates when

they are too young may adversely impact dogs’ behavior and socialization.156,157 In HHS/CDC's

view, separating the puppies from their mothers and littermates has the potential to affect their

social and mental development greatly and negatively. In HHS/CDC's view, this risk outweighs

the possible associated costs. HHS/CDC has also documented hundreds of cases where puppies

under eight weeks of age (who are not yet protected against rabies due to their age) have been

imported for resale. Although HHS/CDC acknowledges that some overseas breeders may choose

to change their operations based on HHS/CDC’s dog import requirements, HHS/CDC believes

that the public health benefits of this change outweigh the theoretical possibility of some

specialty breeders choosing to import fewer dogs into the United States.

Comment: HHS/CDC received comments that there should be exemptions for service

dogs under six months of age or that HHS/CDC should create an accreditation system for service

dogs.

Response: HHS/CDC disagrees with these commenters. To be considered a valid service

dog, a dog needs to meet the definition of a “service animal” under 14 CFR 382.3 and be

accompanied by an “individual with a disability” as defined under 14 CFR 382.3. Most dogs

under six months of age are not yet capable of being trained to work or perform tasks directly

related to an individual’s disability. Therefore, it is HHS/CDC’s determination that the

requirement for dogs to be at least six months of age is unlikely to impact importers with service

dogs. Additionally, it is not operationally feasible for CDC to provide certification or

accreditation of service dogs.

Paragraph (g) — Microchip requirements for all dogs.

156 McMillan FD. Behavioral and psychological outcomes for dogs sold as puppies through pet stores and/or born in
commercial breeding establishments: Current knowledge and putative causes. Journal of Veterinary Behavior. 2017;
19: 14-26.
157 Pierantoni L, Albertini M, Pirrone F. Prevalence of owner-reported behaviors in dogs separated from the litter at

two different ages. Vet Record. 2011; 169: 468.


Comment: HHS/CDC received comments that microchips are too expensive and that

microchips may be difficult to obtain in some low-income countries. Some USG employees also

opined that their dogs should be exempt from microchip requirements.

Response: HHS/CDC disagrees with these comments. HHS/CDC notes that microchips

are already used and available globally for the international movement of animals. Microchips

are required by 86% of DMRVV-free countries for the importation of dogs from DMRVV high-

risk countries and microchips are a WOAH standard for the international movement of

animals.158 Microchips are recommended by WOAH, the international veterinary community,

and animal rescue and welfare organizations to reunite lost animals with their owners and ensure

the veterinary records for an animal can be linked to the animal.159 HHS/CDC’s rule aligns the

United States with international standards and practice.

The microchip requirement will also promote greater confidence in the information

recorded on the rabies vaccination records and prevent fraud. CDC has documented several

instances of importers attempting to import an unvaccinated dog using the vaccination

paperwork for another dog.160 By requiring microchips, which will be verified by the ACF

during revaccination and examination, CDC can ensure the paperwork for foreign-vaccinated

dogs from DMRVV high-risk countries matches the microchip implanted in the dog.

Further, during the period of CDC’s temporary suspension of dogs entering the United

States from DMRVV high-risk countries, CDC documented that 99 percent of permit

applications received were for dogs that had microchips implanted prior to the announcement of

the suspension. Microchips are frequently used by pet owners and required for international

transit by many foreign countries. Given these existing practices and the ubiquity of

158 Personal communication with C. Williams, CDC. October 24,2023.


159 American Veterinary Medical Association. Microchipping FAQ. https://www.avma.org/resources-tools/pet-
owners/petcare/microchips-reunite-pets-families/microchipping-faq. Accessed June 1, 2023.
160 Centers for Disease Control and Prevention. Public Health Activity Reporting System (previously the Quarantine

Activity Reporting System, version 4.9.8.8.2.2A). Dog importation data, 2018-2020. Accessed: February 15, 2021.
microchipping of dogs, the microchip requirement is not likely to impose a burden on importers

and would have minimal impact on dog importations.

CDC did not receive specific public comments on when a dog’s microchip should be

implanted. However, through this final rule, HHS/CDC is clarifying that a dog’s microchip must

have been implanted on or before the date the current rabies vaccine was administered. Rabies

vaccines administered prior to the implantation of a microchip are invalid because without the

microchip the identity of the dog that received the rabies vaccine cannot be properly verified.

The microchip is required to be able to verify a rabies vaccine was administered to an individual

dog.

Comment: One commenter stated microchipping their dog would run counter to their

religious beliefs and requested an exemption based on religious grounds.

Response: The Religious Freedom Restoration Act (RFRA), 42 U.S.C 2000bb et seq.,

provides that the U.S. government shall not substantially burden a person’s exercise of religion,

even if the burden results from a rule of general applicability, unless it demonstrates that

application of the burden to the person is in furtherance of a compelling governmental interest;

and is the least restrictive means of furthering that compelling governmental interest. HHS/CDC

complies with RFRA where applicable and will make determinations arising under RFRA on a

case-by-case basis. If individuals believe they may be entitled to an exemption or

accommodation based on religious beliefs under RFRA, they should contact CDC through

[email protected] for additional guidance concerning how to submit their request.

Requests for an exemption or accommodation under RFRA must be made 120 days prior to

importing a dog into the United States.

HHS/CDC further wishes to emphasize the importance of microchips. Microchips are a

critical component of a dog importation system designed to mitigate occurrences of fraud in dog

importations because microchips ensure that veterinary records for a dog can be linked to that

specific dog. Microchips are also recommended by WOAH, the international veterinary
community, and animal rescue and welfare organizations to reunite lost animals with their

owners.161 HHS/CDC’s rule aligns the United States with international standards and practice in

regards to microchipping.

Comment: Two comments asked that tattoos be permitted in lieu of microchips, with one

comment stating, “Not everyone in the dog industry is comfortable with microchips.”

Response: HHS/CDC declines to permit use of tattoos in lieu of microchips because

tattoos do not provide the same level of assurance against fraud compared to microchips.

Specifically, it would be more difficult for CDC to verify the identity of dogs arriving with

tattoos instead of microchips because tattoos can be altered and can fade over time making

identification challenging. Altered or indistinguishable tattoos could lead to attempts to falsify or

forge vaccine or titer documentation to circumvent U.S. entry requirements. HHS/CDC notes

that microchips are already used and available globally for the international movement of

animals. Microchips are required by 86% of DMRVV-free countries for the importation of dogs

from DMRVV high-risk countries and microchips are a WOAH standard for the international

movement of animals.162 Furthermore, during the period of CDC’s temporary suspension of dogs

entering the United States from DMRVV high-risk countries and as noted above, 99 percent of

permit applications CDC received were for dogs that had microchips implanted prior to the

announcement of the suspension.

Comment: Some commenters expressed concerns that because “the proposed rule does

not distinguish between personal and commercially imported dogs, requiring all dogs to be at

least six months old, bear a microchip and submit a CDC import form prior to travel” would

“dramatically increase[] [CDC’s] regulatory volume.”

161 American Veterinary Medical Association. Microchipping FAQ. https://www.avma.org/resources-tools/pet-


owners/petcare/microchips-reunite-pets-families/microchipping-faq. Accessed June 1, 2023.
162 Personal communication with C. Williams, CDC. October 24, 2023.
Response: CDC disagrees that it would be unable to handle an increase in regulatory

volume based on requirements in the final rule relating to age, microchips, or submission forms,

or that this regulatory volume would be alleviated by distinguishing between personally owned

and commercially imported dogs. Many of the provisions of this final rule are designed to reduce

instances of fraud and improve the ability of Federal agencies including CDC to ensure that dogs

meet entry requirements. In particular, the six-month age requirement is designed to reduce

instances of importers presenting dogs for import that are too young to be effectively vaccinated

against rabies and will make it easier for veterinarians to appropriately age dogs based on dental

eruptions. Microchips will reduce CDC’s regulatory burden by providing an ability to confirm a

dogs’ identity. Importers can demonstrate that their dog has a microchip by including the number

on their documentation. Importer documentation will be examined by government officials upon

entry in the same manner that it was examined prior to this regulatory update. Microchips for

foreign-vaccinated dogs from DMRVV high-risk countries will be scanned and confirmed by

ACF; therefore, requiring microchips does not create an unmanageable burden on CDC. The

final rule further replaces the current requirement for a valid RVC with standardized forms that

will make it easier for CDC and CBP to process dogs for entry to the United States because there

will be less variability in documentation. Furthermore, distinguishing between dogs imported for

commercial reasons and those imported as personal pets would increase rather than decrease

CDC’s regulatory burden because importers often misrepresent the reasons why dogs are being

imported into the United States.

Comment: One commenter stated that "CDC references ‘larger shipments’ of dogs from

importers as an issue not individual dog owners… Microchipping would not solve the alleged

large shipment problem. It simply moves the problem while imposing additional cost and a new

potential failure point. The idea of using trusted vaccination sites is far more workable and would

yield higher confidence levels.”


Response: HHS/CDC disagrees. CDC will be able to verify the identity and vaccination

status of the dogs in large shipments through the use of microchips. Previously, CDC has

documented large shipments of dogs imported with fraudulent paperwork whereby one dog’s

paperwork was “swapped” with another dog’s paperwork. Microchips are the safest and least

expensive way to confirm a dog matches the paperwork presented by the importer. CDC is

requiring microchips because it helps prevent fraud, particularly for the highest risk category of

dogs – foreign-vaccinated dogs from DMRVV high-risk countries. These dogs will have their

microchip scanned upon arrival at the ACF. The ACF will then be able to confirm that the

scanned microchip number matches the number on the importer’s documentation. Furthermore,

CDC notes that this final rule does include trusted vaccination sites, which are ACF. ACF are

facilities registered with CDC that will be revaccinating all foreign-vaccinated dogs from

DMRVV high-risk countries upon entry.

Paragraph (h) — CDC Dog Import Form for all dogs.

Comment: Several commenters expressed support for the CDC Dog Import Form

requirement. Commenters supported CDC improving its ability to track how many dogs enter the

United States. Commenters also suggested CDC create a system whereby frequent travelers

could login and pre-populate the form to reduce the time spent filling out the form.

Response: HHS/CDC agrees with these comments and believes use of the CDC Dog

Import Form will improve CDC’s ability to track the number of dogs being imported into the

United States. HHS/CDC appreciates the suggestion to use a system with login capabilities for

frequent travelers. CDC does not have the funding available to establish the suggested system at

this time but will work in the future to establish a system that addressees the unique need of

frequent travelers.

Comment: HHS/CDC received a number of comments regarding the CDC Dog Import

Form (OMB approval number 0920-1383, exp 04/30/2027). Commenters requested clarification

about the information to be collected, and whether foreign veterinarians will need to verify the
form. One comment said the form should not become a requirement until it is available to the

public. Another comment stated, “disabled individuals and veterans with US vaccinated service

dog canines would be burdened with extra work due to the additional tracking systems.” CDC

takes this to be referring to the CDC Dog Import Form. This commenter also stated, “Citizens in

the US will be further burdened with extra work due to the additional tracking systems

and…Citizens returning to their country are already tracked [and] should not need to submit

further tracking data for data collection.” Additional commenters questioned the purpose of the

CDC Dog Import Form and did not support its use due to cost and burden on importers.

Response: HHS/CDC seeks to clarify several points raised by commenters. The CDC

Dog Import Form has been available to the public since the publication of the NPRM. It is

available on www.reginfo.gov under the information collection review (ICR) number 0920-1383.

Importers must submit the CDC Dog Import Form prior to travel via an online automated system

that is accessible from a smartphone, tablet, or computer. It is free for importers to submit the

form; therefore, there is no cost to importers. The form will collect identifying information about

the importer, their dog, and the dog’s travel itinerary. Importers will need to upload a photo of

their dog as part of the submission. No U.S. government agency is currently collecting this

information for all dog importations; therefore, it is not information that is already tracked.

Neither veterinarians nor government officials will be asked to complete, verify, or submit any

information as part of this form. The form is intended to help CDC capture the number of dogs

imported, the locations from which these dogs arrive, and to provide assistance to CBP, USDA,

CDC, and State government agencies in conducting contact tracing when there is a public health

need. Upon successfully submitting the form, importers will immediately receive an automated

receipt for presentation to their airline, if arriving by air, and CBP and the ACF (for foreign-

vaccinated dogs from DMRVV high-risk countries), upon arrival at a U.S. port. CBP and the

ACF, if applicable, will review and confirm that the information matches the animal presented.

HHS/CDC estimates that an importer can complete the form in less than 15 minutes. HHS/CDC
believes this new requirement places a small burden on importers and that the benefits of the

requirement (the collection of data on all dog importations) outweighs the minimal burden being

placed on importers. CDC also disagrees that these measures place an extra or disproportionate

burden on disabled individuals and or U.S. veterans traveling with U.S. vaccinated service dogs.

Comment: Some comments asked how the CDC Dog Import Form will be reviewed and

verified by CDC with some seeming to believe this form would be the same as the CDC Dog

Import Permits CDC issued during the temporary suspension or some saying to require the CDC

Dog Import Permit instead. Some of these comments also questioned whether CDC has the

capacity to handle the volume of forms received. Comments from the airline industry asked how

airlines would be expected to verify the CDC Dog Import Form. Another comment questioned

why the “CDC import permit” should be required for U.S.-vaccinated dogs since it is not

currently required for U.S.-vaccinated dogs. CDC understood this comment to mean that the

commenter confused the CDC Dog Import Form with the CDC Dog Import Permit.

Response: The CDC Dog Import Form is not the same as the CDC Dog Import Permit

application. CDC will discontinue issuing CDC Dog Import Permits when the temporary

suspension expires and this final rule goes into effect. In the future, CDC will only issue CDC

Dog Import Permits for importers of dogs from DMRVV-restricted countries; however, CDC is

not including any countries on the DMRVV-restricted list at the time of publication of this final

rule. Unlike the CDC Dog Import Permit, however, the CDC Dog Import Form does not require

review by CDC staff prior to the issuance of the auto-generated receipt. CBP will confirm the

information on the form upon arrival, along with other documents required for entry. Because the

system is automated, the volume of forms submitted will not adversely impact CDC’s workload

nor will it impact the time that importers will need to wait for the receipt; whereas issuing CDC

Dog Import Permits does require CDC staff time and requires importers to await review by CDC

before receiving their permit. The wait time for a CDC Dog Import Permit can take anywhere

from one to eight weeks, particularly if the importer did not submit all required information.
CDC is also requiring that all importers use the CDC Dog Import Submission Form, including

those importing U.S. vaccinated dogs, because the form includes important information such as

the importer’s contact information and information related to each dog being imported, and will

allow CDC to more easily track the frequency and number of dog imports.

Additionally, CDC will not require that airlines verify information on the form. For

example, airlines will not be required to scan dogs’ microchips to ensure the microchip number

matches the number listed on the form. Rather, airlines will only be required to confirm that the

importer has a CDC Dog Import Form receipt and either a Certification of U.S.-Issued Rabies

Vaccination form, a reservation at an ACF, or documentation the dog has resided only in a

DMRVV-free or DMRVV low-risk country for the six months prior to boarding the dog on the

plane.

Comment: One comment said the CDC Dog Import Form may infringe on privacy

without stopping the reintroduction of rabies. The commenter did not elaborate further on how

they believed the CDC Dog Import Form may infringe on privacy or why use of this form would

not help mitigate the reintroduction of DMRVV into the United States.

Response: Although the commenter did not elaborate on how they believe the CDC Dog

Import Form may infringe on privacy interests, HHS/CDC does not believe that requiring

importers to complete this form will infringe on privacy. CDC notes that it will maintain and use

the information collected via the CDC Dog Import Form in accordance with the Privacy Act of

1974 (5 USC 552a) and its applicable System of Records Notice.163 Personally identifiable

information may be used and shared only for lawful purposes, including with authorized

personnel of HHS, State and local government agencies, and other cooperating authorities, as

authorized by law.

163HHS System of Records Notice (SORN) 09-20-0171.


https://www.hhs.gov/foia/privacy/sorns/09200171/index.html.
Furthermore, although the commenter did not elaborate on why they believe use of the

CDC Dog Import Form would not help mitigate the reintroduction of DMRVV into the United

States, CDC disagrees that this form will not be useful in preventing the reintroduction of

DMRVV. The information that importers will submit to CDC via the CDC Dog Import Form

will allow CDC to better track the overall number and frequency of dog importations to the

United States. This information in turn will help CDC better determine the risk of human

exposure incidence to DMRVV from imported dogs, improve CDC’s ability to conduct a contact

tracing investigation if a rabid dog were to be imported into the United States, and provide CDC

with data about which countries are responsible for importing dogs of public health concern to

the United States. This information will further help CDC assess the DMRVV risk to the United

States based on the level of DMRVV present in each country and the number of importations

from DMRVV countries.

Comment: HHS/CDC received comments that the CDC Import Certificate should be

certified by an official veterinarian. HHS/CDC interprets this to mean the Certification of

Foreign Rabies Vaccination and Microchip form.

Response: HHS/CDC agrees with this comment. HHS/CDC is implementing

requirements in this final rule that veterinary documentation be certified by official government

veterinarians in order to reduce the use of fraudulent documentation by importers. Official

government veterinarians are able to certify that an accredited veterinarian is authorized to

practice veterinary medicine in the exporting country. Additionally, engaging foreign

government official veterinarians in the exportation process of an animal provides a pathway to

communicate with a foreign government when cases of fraud are detected by CDC. Currently,

there is no recourse or follow-up that a foreign government can perform when CDC identifies

fraudulent paperwork because CDC does not require foreign governments to certify the

paperwork prior to export. Official government veterinarians currently review and certify dog

exportation paperwork for most other countries in the world, but the United States does not have
this requirement. The final rule will align the United States requirements more closely with other

countries that already require official government certification of export documentation in order

to prevent fraud and provide an official pathway to engage with foreign government officials

when cases of fraud are detected.

Comment: HHS/CDC received comments from foreign government representatives

requesting that the CDC Dog Import Form not require involvement from a licensed veterinarian

or from an official government veterinarian.

Response: HHS/CDC agrees with these comments and does not think it is necessary to

have this form certified by a veterinarian because a purpose of this form is to collect data on the

number of dogs arriving into the United States and the proportion arriving from DMRVV high-

risk countries which is something the U.S. government was previously unable to do. The form is

administrative in nature and does not capture medical information about the dog; therefore, a

veterinarian does not need to certify the form.

Comment: One comment stated it is illogical to require the CDC Dog Import Form for

importations at the land borders and the commenter questioned the intended purpose of the form.

Response: HHS/CDC disagrees. The information that importers will submit to CDC via

the CDC Dog Import Form will help CDC prevent the reintroduction of rabies. It allows CDC to

track all dog importations, including those arriving at U.S. land ports, which helps CDC better

determine the risk of human exposure incidence to DMRVV from imported dogs. It will allow

CDC to better conduct contact tracing if a rabid dog were to be imported into the United States.

It would also provide data to CDC about the countries from which dogs are being imported. This

information helps CDC assess the DMRVV risk to the United States based on the level of

DMRVV present in each country and the number of importations from DMRVV countries.

Paragraph (i) — Inspection requirements for admission of all dogs and cats.

Comment: HHS/CDC received comments that a health certificate or certificate of

veterinary inspection (CVI) should be required in addition to rabies vaccine documentation


because this is a basic protection adopted by other countries. A health certificate or CVI is a

document used by some foreign countries for the export of animals from those countries.

Response: HHS/CDC declines to accept this suggestion. Although health certificates can

contain valuable information regarding the dog’s health status, health certificates often do not

contain all the necessary information that would allow HHS/CDC to confirm valid rabies

vaccination. Therefore, HHS/CDC has adopted its own documentation requirements for this final

rule.

Comment: Commenters also noted that EU pet passports should be accepted or that CDC

should create a passport that is compatible with or comparable to the EU pet passport.

Response: HHS/CDC declines to accept these suggestions. CDC has documented

numerous instances of importers using falsified or fraudulent EU pet passports. EU pet passports

are not certified by official government veterinarians. HHS/CDC is implementing requirements

in this final rule that veterinary documentation be certified by official government veterinarians

in order to reduce the use of fraudulent documentation by importers. Official government

veterinarians are able to certify that an accredited veterinarian is authorized to practice veterinary

medicine in the exporting country. Additionally, engaging foreign government official

veterinarians in the exportation process of an animal provides a pathway to communicate with a

foreign government when cases of fraud are detected by CDC. Currently, there is no recourse or

follow-up that a foreign government can perform when CDC identifies fraudulent paperwork

because CDC does not require foreign governments to certify the paperwork prior to export.

Official government veterinarians currently review and certify dog exportation paperwork for

most other countries in the world, but the United States does not have this requirement. The final

rule will align the United States requirements more closely with other countries that already

require official government certification of export documentation in order to prevent fraud and

provide an official pathway to engage with foreign government officials when cases of fraud are

detected.
Comment: HHS/CDC received comments that dogs and cats should have the same

vaccination and entry requirements or that cats should have to be vaccinated for rabies to enter

the United States. HHS/CDC also received comments asking that HHS/CDC not render it harder

to import cats and exempt various groups (e.g., military members and Foreign Service Officers)

from the requirements for cats to be imported into the United States. Additional comments asked

to clarify what the requirements are for cats or if there were proposed updates to cat requirements

in the NPRM.

Response: HHS/CDC would like to clarify that this final rule does not substantively

update requirements to import a cat into the United States. The NPRM did not propose, nor is

this final rule establishing, vaccination requirements for importing cats into the United States.

Although HHS/CDC recommends that cats be vaccinated against rabies prior to importation

because cats can acquire rabies from other animals (i.e., be an incidental host of the virus), this

final rule does not require vaccination of cats because cats are not considered a reservoir of

rabies. Additionally, HHS/CDC has never documented a report of an imported rabid cat. This

final rule is updating the requirements for the care and transport of cats that appear unhealthy

upon arrival, by requiring that any ill cat undergo a veterinary examination immediately upon

arrival to ensure it receives timely care, and that CDC is notified of any potential zoonotic

diseases that could be transmitted to people. The final rule is also updating requirements for

necropsy of cats that arrive dead in order to determine the cause of death and ensure CDC is

notified of any potential zoonotic diseases that could be transmitted to people. Because the final

rule is not imposing new requirements to import cats, no exemption, including for specific

groups such as military members and Foreign Service Officers, is not needed.

Paragraph (j) — Examination by a USDA-Accredited Veterinarian and confinement of exposed

dogs and cats or those that appear unhealthy.

HHS/CDC received no public comment on this paragraph of the proposed rule.


Paragraph (k) — Veterinary examination, revaccination against rabies, and quarantine

at a CDC-registered Animal Care Facility for foreign-vaccinated dogs from DMRVV high-risk

countries.

Comment: Many State and local public health and animal health agencies expressed

support for requiring veterinary examination, revaccination, and quarantine (if needed) of dogs

on arrival to reduce the burden on these agencies. These commenters also noted that these

practices would also reduce the public health risk that imported dogs pose to U.S. communities,

domestic pets, and wildlife and would improve the government’s ability to identify dogs with

diseases or external parasites before they enter the United States.

Response: HHS/CDC agrees with the commenters regarding the public health benefit of

these provisions in preventing rabies as well as additional zoonotic diseases. In drafting this final

rule, HHS/CDC recognized that there is limited value in reviewing paperwork alone because

physical inspection of animals in combination with a review of paperwork submitted by

importers has a greater likelihood of allowing CDC to detect both fraudulent paperwork and

communicable diseases of concern in dogs.

Comment: HHS/CDC received comments objecting to the revaccination requirements for

foreign-vaccinated dogs from DMRVV high-risk countries because the dogs have already been

vaccinated overseas.

Response: HHS/CDC disagrees with these comments. There is a high degree of

variability in the quality and efficacy of rabies vaccines produced in some countries.164,165

Therefore, re-vaccination with a high-quality USDA-licensed vaccine is necessary to ensure

adequate protection against rabies. CDC has also documented instances in DMRVV high-risk

164 Hu RL, Fooks AR, Zhang SF, Liu Y, Zhang F. Inferior rabies vaccine quality and low immunization coverage in
dogs in China. Epidemiol Infect 2008;136: 1556-1563.
165 Rathnadiwakara H, Gunatilake M, Servat A, Wasniewski M, Thibault JC, Cliquet F. Potency of Veterinary

Rabies Vaccines Marketed in Sri Lanka. Vaccines (Basel). 2023 May 9;11(5):961. Doi: 10.3390/vaccines11050961.
PMID: 37243065; PMCID: PMC10222363.
countries in which rabies vaccines have been improperly administered.166 USDA-licensed rabies

vaccines undergo rigorous testing to ensure they are safe and effective. Requiring a rabies

booster vaccine on arrival ensures dogs are adequately protected against rabies and do not pose a

public health risk.

Comment: Some commenters expressed concerns regarding revaccinating dogs upon

arrival that were already vaccinated overseas and the impact of multiple rabies vaccines on dogs’

health.

Response: HHS/CDC appreciates these concerns but finds them unwarranted because

revaccinating a dog with a USDA-licensed rabies vaccine upon arrival in the United States is not

likely to result in an adverse vaccine event. A 2023 review of more than 4.5 million veterinary

records for dogs vaccinated in the United States found adverse rabies vaccine reactions occurred

in less than 0.25% of dogs.167 Furthermore, studies have noted dogs that did experience adverse

vaccine reactions were more likely to do so when multiple vaccines (four or more) were

administered concurrently.168,169 CDC is only requiring the administration of a single rabies

vaccine upon arrival.

The results of this study demonstrate that the benefits of rabies vaccination continue to

outweigh the risks. CDC rabies subject matter experts receive reports of dogs infected with

wildlife rabies virus variants each year corresponding to an annual rate of rabies infections

acquired domestically of about four cases per one million unvaccinated dogs.170 If no U.S. dogs

were vaccinated and the rate of infection observed in the unvaccinated U.S. dog population was

166 Whitehill F, Bonaparte S, Hartloge C, et al. Rabies in a Dog Imported from Azerbaijan- Pennsylvania, 2021.
MMWR Morb Mortal Wkly Rep 2022; 71: 686-689
167 Moore GE, Morrison J, Saito EK, Spofford N, & Yang M. Breed, smaller weight, and multiple injections are

associated with increased adverse event reports within three days following canine vaccine administration. Journal
of the American Veterinary Medical Association, 2023; 261(11), 1653-1659.
168 Frana TS, Clough NE, Gatewood DM, Rupprecht CE. Postmarketing surveillance of rabies vaccines for dogs to

evaluate safety and efficacy. JAVMA 2008; 232:1000-1002.


169 Moore GE, Morrison J, Saito EK, Spofford N, & Yang M. Breed, smaller weight, and multiple injections are

associated with increased adverse event reports within three days following canine vaccine administration. Journal
of the American Veterinary Medical Association, 2023; 261(11), 1653-1659.
170 Huang P. Vaccine hesitancy affects dog-owners, too, with many questioning the rabies shot. October 11,2023.

Available at: www.npr.org/sections/health-shots/2023/10/11/1205016558/canine-vaccine-hesitancy-dogs-rabies.


applied to the entire U.S. dog population (85 million dogs), HHS/CDC can estimate the number

of rabies infections averted through vaccination. Thus, these vaccinations are estimated to

prevent nearly 300 dogs from developing rabies virus infection each year. This compares very

favorably to the reported number of annual severe adverse events (60 per year). On average,

CDC subject matter experts estimate that each dog infection would be associated with 2.2 human

exposures. As a result, HHS/CDC estimates that dog rabies vaccination prevents more than $3

million in healthcare-associated costs for rabies PEP each year. High rabies vaccination coverage

also reduces the risk that dog owners may die in the event of an exposure to their infected dogs.

The United States spent several decades and hundreds of millions of dollars to eliminate the

circulation of rabies in U.S. dogs. Maintaining a high level of herd immunity prevents rabies

from becoming reestablished in U.S. dog populations, which if it were to occur, would result in

far more dog and human deaths from rabies.171 HHS/CDC believes vaccination against rabies is

unlikely to pose a significant risk to the dog’s health and requiring vaccination would result in

the significant public health benefits outlined above.

Comment: HHS/CDC received comments objecting to the titer requirements for foreign-

vaccinated dogs from DMRVV high-risk countries on the basis that only a rabies vaccine should

be sufficient for entry into the United States. Some comments asked why CDC does not trust

vaccines from other countries.

Response: HHS/CDC disagrees with these comments. WOAH and the international

community have long recognized vaccination paperwork alone is not sufficient to ensure a dog is

adequately vaccinated against rabies. There is a high degree of variability in the quality and

Huang P. Vaccine hesitancy affects dog-owners, too, with many questioning the rabies shot. October 11,2023.
171

Available at: www.npr.org/sections/health-shots/2023/10/11/1205016558/canine-vaccine-hesitancy-dogs-rabies.


efficacy of rabies vaccines produced in some countries.172,173,174 Therefore, re-vaccination with a

high-quality USDA-licensed vaccine is necessary to ensure adequate protection against rabies.

CDC has also documented instances in DMRVV high-risk countries in which rabies vaccines

have been improperly administered.175 A titer provides supportive evidence that a dog has been

adequately vaccinated against rabies. Rabies vaccination documentation can also be falsified.

Requiring a titer in addition to rabies vaccination documentation makes it more difficult for

importers to falsify documents.

Titers or quarantine are the WOAH recommended importation standards that should be

implemented for dogs arriving from DMRVV high-risk countries. HHS/CDC has provided

alternative entry pathways through an ACF with a 28-day quarantine if an importer is unable or

unwilling to receive a titer prior to arriving in the United States.

Comment: HHS/CDC received comments objecting to the requirement for dogs with

titers to go to an ACF because titers demonstrate the presence of rabies antibodies in dogs and

that should be sufficient for entry. The comments stated that requiring these dogs to be

revaccinated and examined at ACF is unnecessary.

Response: HHS/CDC disagrees with these comments. As noted above, there is a high

degree of variability in the quality and efficacy of rabies vaccines produced in some

countries,176,177 as well as evidence that some rabies vaccines administered in DMRVV high-risk

countries contain an additive that may cause an initial robust immune response that quickly

172 Hu RL, Fooks AR, Zhang SF, Liu Y, Zhang F. Inferior rabies vaccine quality and low immunization coverage in
dogs in China. Epidemiol Infect 2008;136: 1556-1563.
173 Rathnadiwakara H, Gunatilake M, Servat A, Wasniewski M, Thibault JC, Cliquet F. Potency of Veterinary

Rabies Vaccines Marketed in Sri Lanka. Vaccines (Basel). 2023 May 9;11(5):961. Doi: 10.3390/vaccines11050961.
PMID: 37243065; PMCID: PMC10222363.
174 Rathnadiwakara H, Gunatilake M, Servat A, Wasniewski M, Thibault JC, Cliquet F. Potency of Veterinary

Rabies Vaccines Marketed in Sri Lanka. Vaccines (Basel). 2023 May 9;11(5).
175 Whitehill F, Bonaparte S, Hartloge C, et al. Rabies in a Dog Imported from Azerbaijan- Pennsylvania, 2021.

MMWR Morb Mortal Wkly Rep 2022; 71: 686-689


176 Hu RL, Fooks AR, Zhang SF, Liu Y, Zhang F. Inferior rabies vaccine quality and low immunization coverage in

dogs in China. Epidemiol Infect 2008;136: 1556-1563.


177 Rathnadiwakara H, Gunatilake M, Servat A, Wasniewski M, Thibault JC, Cliquet F. Potency of Veterinary

Rabies Vaccines Marketed in Sri Lanka. Vaccines (Basel). 2023 May 9;11(5):961. Doi: 10.3390/vaccines11050961.
PMID: 37243065; PMCID: PMC10222363.
wanes and provides no protection against an exposure to the rabies virus.178 This can result in

titer test results falsely demonstrating adequate antibodies for rabies. Additionally, elevated (or

passing) titers suggest an animal has either been vaccinated against rabies or could be infected

with the rabies virus. Re-vaccination with a high-quality USDA-licensed vaccine provided at an

ACF is necessary to ensure adequate protection against rabies. USDA-licensed rabies vaccines

undergo rigorous testing to ensure they are safe and effective. Requiring a rabies booster on

arrival ensures dogs are adequately protected against rabies and do not pose a public health risk.

Although not a primary reason for this final rule, it is also important for CDC-registered

ACF to examine animals on arrival to ensure sick animals are not released into U.S.

communities. During the period of the temporary suspension, CDC and ACF detected or ruled

out numerous cases of dogs with foreign ticks, leishmaniasis, brucellosis, canine influenza, or

COVID-19 through physical examination and testing prior to clearing an animal for entry into

the United States.179,180 Prior to the establishment of ACF and the requirement for dogs to

undergo physical examination upon arrival, State health departments detected these diseases, as

well as rabies, only after dogs had been released into U.S. communities. Examination of the

highest-risk category of dog imports – foreign-vaccinated dogs from DMRVV high-risk

countries – on arrival by a network of ACF helps reduce the risk of ill or rabid dogs entering

U.S. communities. While this rule primarily addresses the importation of rabies into the United

States, the ability to safely house and care for animals while they undergo screening for other

zoonotic diseases is an additional benefit and further protects public health in the United States.

Comment: HHS/CDC received comments objecting to dogs undergoing quarantine even

when there is a rabies vaccination document.

178 Rathnadiwakara H, Gunatilake M, Servat A, Wasniewski M, Thibault JC, Cliquet F. Potency of Veterinary
Rabies Vaccines Marketed in Sri Lanka. Vaccines (Basel). 2023 May 9;11(5):961. Doi: 10.3390/vaccines11050961.
PMID: 37243065; PMCID: PMC10222363.
179 Williams C, Swisher S, Miller N, Pinn-Woodcock T, Austin C, et al. Human exposures to Brucella canis from a

pregnant dog imported during an international flight: Public health risks, diagnostics challenges and future
considerations. Zoonoses and Public Health 2024; 00:1-13 DOI: 10.1111/zph.13121.
180 Centers for Disease Control and Prevention. System for Animal Facility Electronic Tracking of Quarantine

(SAFE TraQ) dog import surveillance data. 2023-2024. Accessed 26 March 2024.
Response: HHS/CDC disagrees with these comments. WOAH and the international

community have long recognized vaccination paperwork alone is not sufficient to ensure a dog is

adequately vaccinated against rabies due to the high frequency of falsified documents. There is a

high degree of variability in the quality and efficacy of rabies vaccines produced in some

countries.181,182 Therefore, documentation of a rabies vaccine alone is not sufficient to ensure a

dog is adequately protected from rabies. According to WOAH, adequate titer or a sufficient

period of quarantine are the importation standards that should be implemented for dogs arriving

from DMRVV high-risk countries. HHS/CDC has provided both options to importers depending

on an importer’s preference, logistical considerations, and feasibility. Importers may provide

either proof of an adequate titer or undergo quarantine at an ACF to meet U.S. entry

requirements.

Foreign-vaccinated dogs arriving from DMRVV high-risk countries must undergo

revaccination and, for dogs without a titer result from a CDC-approved laboratory, a quarantine

period of 28 days. This quarantine period allows CDC to be confident the dog is not incubating

rabies. Dogs that have been exposed to rabies and are subsequently vaccinated will either 1)

adequately respond to vaccination and develop sufficient antibodies to prevent clinical infection

and death; or 2) succumb to the virus within an accelerated timeframe (<28 days). Quarantining

dogs ensures that if a dog is going to develop rabies and die, it will do so in an environment

where no other animals are exposed, and where it is cared for by only a limited number of people

who are trained to wear personal protective equipment and administer veterinary care as needed.

Comment: HHS/CDC received comments that unvaccinated dogs should be quarantined

or vaccinated only upon arrival or that HHS/CDC should not require dogs to be vaccinated

overseas if they have to undergo vaccination and/or quarantine upon arrival.

181 Hu RL, Fooks AR, Zhang SF, Liu Y, Zhang F. Inferior rabies vaccine quality and low immunization coverage in
dogs in China. Epidemiol Infect 2008;136: 1556-1563.
182 Rathnadiwakara H, Gunatilake M, Servat A, Wasniewski M, Thibault JC, Cliquet F. Potency of Veterinary

Rabies Vaccines Marketed in Sri Lanka. Vaccines (Basel). 2023 May 9;11(5):961. Doi: 10.3390/vaccines11050961.
PMID: 37243065; PMCID: PMC10222363.
Response: HHS/CDC disagrees with these comments. It is critical that dogs from

DMRVV high-risk countries be vaccinated overseas prior to their arrival in the United States to

prevent the reintroduction of rabies into the United States and help prevent people and animals

from being exposed to rabid dogs in transit and upon arrival. Additionally, HHS/CDC notes that

if dogs were not vaccinated prior to arrival, then every dog from a DMRVV high-risk country

would be required to undergo a 28-day quarantine. The cost to quarantine these dogs for 28 days

on arrival would be a financial burden on importers. There is also limited space available for

quarantine at the AFC, making this option unfeasible for many importers. HHS/CDC notes that

the titer requirement combined with revaccination upon arrival would serve a similar purpose at

a fraction of the cost for importers.

Comment: Some commenters said that HHS/CDC should not ban dogs and cats from

being imported into the U.S. and instead allow quarantine and vaccination upon arrival.

Response: First, HHS/CDC would like to clarify it is not banning the importation of dogs

and cats. Second, as mentioned above, to require quarantine for all dogs from DMRVV high-risk

countries would increase costs for most importers. It is significantly less expensive for importers

to have their dogs vaccinated prior to travel and provide rabies documentation and titer results, if

applicable, for entry into the United States compared to quarantining their dogs upon arrival.

Comment: HHS/CDC received comments that in lieu of revaccination, examination, and

quarantine (if required) at an ACF for foreign-vaccinated dogs from DMRVV high-risk

countries, HHS/CDC should continue to issue the CDC Dog Import Permits, which were issued

during the temporary suspension. HHS/CDC also received comments that in lieu of requiring

that dogs go to an ACF, HHS/CDC should allow home quarantine and verify revaccination

through compliance checks after a dog has been cleared for entry and released into the

community.

Response: HHS/CDC disagrees. ACF visits are critical because physical examinations by

a veterinarian who can identify signs of rabies in dogs and verify the microchip matches all
rabies vaccination and titer paperwork presented for the dog have a greater public health benefit

than review of paper-based forms or records (such as the permit system HHS/CDC used during

the temporary suspension) that can be fraudulent or falsified. Home quarantine and verification

of revaccination through random compliance checks also does not ensure that dogs have been

physically examined by a veterinarian prior to their release into U.S. communities. HHS/CDC

would also have to rely on states and localities to follow-up with home-quarantined dogs. Prior

to 2018, HHS/CDC allowed home quarantine of dogs through the issuance of confinement

agreements;183 however, this practice proved to be too burdensome for the states and localities.

Therefore, HHS/CDC did not propose this option in the NPRM due to poor feasibility.

Because of the above-listed reasons, foreign-vaccinated dogs arriving from DMRVV

high-risk countries must undergo revaccination and, for dogs without a titer result from a CDC-

approved laboratory, a quarantine period of 28 days. This quarantine period allows HHS/CDC to

be confident the dog is not incubating rabies. As discussed above, dogs that have been exposed

to rabies and are subsequently vaccinated will either 1) adequately respond to vaccination and

develop sufficient antibodies to prevent clinical infection and death; or 2) succumb to the virus

within an accelerated timeframe (<28 days). Quarantining dogs ensures that if a dog is going to

develop rabies and die, it will do so in an environment where no other animals are exposed, and

where it is surrounded only by a limited number of people who are trained to wear personal

protective equipment and administer veterinary care as needed.

Comment: HHS/CDC received comments that there are too few ACF and that ACF are

too expensive. Some of these comments expressed concern about ACF’ ability to accommodate

all foreign-vaccinated dogs from DMRVV high-risk countries while other comments said the

limited number of ACF places a burden on importers who are forced to arrive into the United

States at a port with an ACF.

183 CDC. Issuance and Enforcement Guidance for Dog Confinement Agreements. 79 FR 39403 (July 10, 2014): 39403-

39406.
Response: HHS/CDC appreciates this comment and notes that it has registered two

additional ACF since the publication of the proposed rule. The registration of new ACF at

additional ports continues to be a priority for CDC; however, CDC believes there is an adequate

number of ACF currently available to handle the volume of dogs being imported. CDC is making

efforts to expand the network of CDC-registered ACF to additional ports of entry in order to

provide greater flexibility for importers arriving from DMRVV high-risk countries with foreign-

vaccinated dogs. CDC notes that the agency does not set prices charged by an ACF, which are

privately owned and operated. Additionally, based on data during the temporary suspension, the

vast majority of importers of foreign-vaccinated dogs from DMRVV high-risk countries chose to

submit titer results in lieu of having their dogs complete a 28-day quarantine. These dogs were

usually examined, re-vaccinated and released back to the owner the same day they arrived in the

United States. The cost to importers of these dogs is significantly less than for dogs without titer

results, which require quarantine. Only a small percentage (<3%) of importers are required to

pay the highest cost of quarantine for 28 days.

Comment: HHS/CDC received comments requesting that HHS/CDC consider allowing a

single titer for the lifetime of an animal instead of annual titers, and to consider new technologies

that might be available in the future. HHS/CDC also received comments that the titer takes too

long, is too expensive, or that it is difficult to ship blood samples from countries that do not have

a CDC-approved laboratory.

Response: HHS/CDC notes that, as proposed in the NPRM, prior to granting a

reservation, an ACF must ensure they have received serologic test results obtained from a CDC-

approved laboratory on a blood sample collected in accordance with CDC's technical

instructions (if applicable); otherwise, the dog will be required to quarantine for 28 days upon

revaccination at an ACF. HHS/CDC intends to provide additional information relating to titers

through technical instruction posted on CDC’s website. HHS/CDC’s current intent is to align the

frequency of titer testing and waiting periods between the time of titer collection and date of
importation with the most recent peer-reviewed literature, WOAH guidelines, and input from

CDC rabies subject matter experts. During the temporary suspension, CDC has required titers to

be drawn 45 days to 365 days prior to importation; however, CDC will periodically review its

titer requirements and provide updates through technical instructions as needed and consistent

with the best scientific practices.

Although no public comments were received, HHS/CDC is clarifying that suspected or

confirmed communicable diseases need only be reported to CDC and not to other public health

entities. Additional notification of Federal, State, and local public health partners will be done by

CDC.

CDC is updating the name of this paragraph to reflect all the required components of the

paragraph. However, the requirements within the paragraph have not changed.

Paragraph (l) — Registration or renewal of CDC-registered Animal Care Facilities.

HHS/CDC received no public comment on this paragraph of the proposed rule. However,

HHS/CDC will be amending this provision of the final rule to require that an ACF be located

within 35 miles of a CDC quarantine station. Although the NPRM did not propose that an ACF

be located within a certain distance from a CDC quarantine station, HHS/CDC is confident that

the public could infer that HHS/CDC would consider physical location, distance, and travel

times when deciding to register a facility as an ACF. As explained extensively throughout the

preamble to the NPRM (88 FR 43992) the rule is intended, in part, to address the difficulty that

airlines encountered finding appropriate housing for dogs denied admission and the lack of

facilities that maintain an active CBP FIRMS code. If an animal arriving at an airport is sick or

injured, it will also need to be transported to an ACF which must, therefore, be located within a

reasonable distance from the airport to ensure the animal’s health and safety as well as the safety

of transport personnel. Accordingly, it is reasonable for the public to have inferred that

HHS/CDC would only approve and register facilities as an ACF that were located within a
reasonable distance from an airport where a CDC quarantine station was located. HHS/CDC

further notes that the 35-mile distance requirement for an ACF aligns with CBP’s Bonded

Warehouse Manual184 and ensures inspection of animals at the facility can occur in a timely

manner when the ACF requests assistance from CDC.

HHS/CDC also takes this opportunity to clarify that in its inspections, an ACF will be

guided by the standards published by the Association of Shelter Veterinarians’ Guidelines for

Standards of Care in Animal Shelters.185 These guidelines provide standards applicable to all

personnel caring for shelter animals in a variety of settings, including foster-based organizations,

nonprofit humane societies, municipal animal services facilities, and sanctuaries. These

guidelines are also applicable to any other organization that routinely cares for populations of

mobile companion animals with unknown medical histories and possible exposures to unknown

pathogens. HHS/CDC notes that the NPRM explained that facilities applying for registration as

an ACF would be subject to inspection by CDC at least annually and required to renew their

registration every two years (88 FR 43994). HHS/CDC further explained that animal health

records, facilities, vehicles, or equipment to be used in receiving, examining, and processing

imported animals would also be subject to inspection, see id. Accordingly, HHS/CDC believes

that the public was reasonably apprised that CDC would be conducting inspections of facilities

seeking to register as ACF and, by necessity, these inspections would need to be guided by the

industry standard for facilities that care for populations of mobile companion animals.

Paragraph (m) — Record-keeping requirements at CDC-registered Animal Care Facilities.

Bonded Warehouse Manual for CBP Officers and Bonded Warehouse Proprietors. Available at:
184

www.cbp.gov/document/guidance/bonded-warehouse-manual-cbp-officers-and-bonded-warehouse-proprietors.
185Guidelines for Standards of Care in Animal Shelters. Available at: www.sheltervet.org/resources/guidelines-for-
standards-of-care.
HHS/CDC received no public comment on this section of the rule; however, HHS/CDC

is clarifying that records for necropsy results should be uploaded into SAFE TraQ within 30 days

of an animal’s death.

Paragraph (n) — Worker protection plan and personal protective equipment (PPE).

HHS/CDC received no public comment on this paragraph of the proposed rule.

HHS/CDC is noting that procedures for reporting suspected or confirmed communicable

diseases associated with handling animals in facility workers must be reported to CDC within 48

hours. This requirement was included in the NPRM in proposed paragraph (q) and has been

moved to paragraph (n) for clarity.

Paragraph (o) — CDC-registered Animal Care Facility standard operating procedures,

requirements, and equipment standards for crating, caging, and transporting live animals.

HHS/CDC received no public comment on this paragraph of the proposed rule.

Paragraph (p) — Health reporting and veterinary service requirements for animals at CDC-

registered Animal Care Facilities.

Comment: HHS/CDC received a comment from a veterinary professional organization

stating, “if the animal requires veterinary care prior to export to its country of origin, the

organization supports an exception if the animal is taken directly to a veterinary facility for

treatment with appropriate quarantine.”

Response: HHS/CDC seeks to clarify that this is the current standard of care and

HHS/CDC has no intent to change this current practice. Although protecting the public’s health

is CDC’s chief priority, CDC takes reasonable steps to ensure the health and safety of ill or

injured animals and will continue to work with airlines, the animal transportation industry, and

port partners so that ill or injured animals arriving in the United States receive veterinary care in
a timely manner. Further, HHS/CDC does not require the return of ill or injured animals to the

country of departure until such animals are deemed fit to travel if that action would be in

violation of USDA’s Animal Welfare Act.

Additionally, although HHS/CDC did not receive public comment on this issue,

HHS/CDC is clarifying that if an animal is suspected of having a communicable disease, it must

be immediately isolated and CDC-registered Animal Care Facilities must implement infection

prevention and control measures in accordance with industry standards and CDC technical

instructions.

Although no public comments were received, HHS/CDC is clarifying that suspected or

confirmed communicable diseases need only be reported to CDC and not to other public health

entities. Additional notification of Federal, State, and local public health partners will be done by

CDC.

HHS/CDC notes the paragraph name has been modified to reflect all the required

components of the paragraph. However, the requirements within the paragraph have not

changed.

Paragraph (q) — Quarantine requirements for animals at CDC-registered Animal Care

Facilities.

HHS/CDC received no public comment on this paragraph of the proposed rule. However,

HHS/CDC is clarifying that although implicit in its use of the term “quarantine” that quarantined

animals must be housed in such a manner that they do not expose other quarantined animals.

Additionally, animals in quarantine may not be housed together even if they were transported as

part of the same shipment. This clarification is considered a veterinary industry standard of care.

Paragraph (r) — Revocation and reinstatement of a CDC-registered Animal Care Facility's


registration.
HHS/CDC received no public comment on this paragraph of the proposed rule.
Paragraph (s) — Requirement for the CDC Import Certification of Rabies Vaccination and

Microchip Required for Live Dog Importations into the United States form to import foreign-

vaccinated dogs from DMRVV high-risk countries.

Comment: HHS/CDC received comments that importers should not be required to have

an official government veterinarian certify rabies vaccination forms prior to travel.

Response: HHS/CDC disagrees with these comments. HHS/CDC has documented

numerous instances of importers who falsify vaccination documents with the names of persons

who are not authorized to practice veterinary medicine within their countries or who alter the

vaccine records of animals unbeknownst to the veterinarian. Official government veterinarians

are able to certify a veterinarian’s authorization to practice veterinary medicine and can help

detect cases of fraud before an animal is shipped to the United States. Additionally, engaging

foreign government official veterinarians in the exportation process of an animal provides a

pathway to communicate with a foreign government when cases of fraud are detected by CDC.

Currently, there is no recourse or follow-up that a foreign government can perform when CDC

identifies fraudulent paperwork because CDC does not require foreign governments to certify the

paperwork prior to export. Official government veterinarians currently review and certify dog

exportation paperwork for most other countries in the world, but the United States does not have

this requirement. The final rule will align the United States’ requirements more closely with

other countries that already require official government certification of export documentation to

prevent fraud and provide an official pathway to engage with foreign government officials when

cases of fraud are detected. This is a critical public health intervention in the pre-departure phase

of preparing an animal for travel.

Lastly, many DMRVV-free and DMRVV high-risk countries currently require importers

to obtain health certificates or vaccination records certified by official government veterinarians

in the exporting country as part of the importation requirements for those countries.
Comment: HHS/CDC received comments expressing concern that individuals in low-

income countries (which tend to be DMRVV high-risk countries), may have trouble identifying

government officials to certify paperwork and that issues of poor governance and bureaucracy in

these countries may lead to bribery.

Response: Although issues of poor governance, including bribery and corruption, in

foreign countries fall outside the scope of this final rule, HHS/CDC notes that through this

rulemaking at § 71.51(ee), HHS/CDC will be able to prohibit exports of dogs to the United

States from countries that are unable to prevent the export of dogs with fraudulent vaccination

paperwork or other fraudulent documentation. In addition, through the use of the Certification of

Rabies Vaccination and Microchip form, HHS/CDC will be utilizing an existing framework that

already includes official government veterinarians that are trained and experienced in certifying

standardized veterinary documentation for the international movement (import and export) of

animals. HHS/CDC is updating U.S. importation requirements in a way that will more closely

align with international practices and WOAH standards. By leveraging the current international

animal movement system overseen by official government veterinarians in exporting countries,

HHS/CDC will be streamlining documentation requirements while strengthening the validity of

importer documentation. HHS/CDC defined official government veterinarian in § 71.50(a) of the

final rule.

Comment: A commenter stated that veterinarians who vaccinate or falsify the rabies

vaccination documentation of rabid dogs imported into the U.S. should be banned instead of

restricting the importation of dogs from that country. Additionally, HHS/CDC received

comments to consider creating a list of approved veterinarians abroad for tracking the

administration of rabies vaccines in foreign countries.

Response: HHS/CDC appreciates these comments and notes that this is the purpose of

having official government veterinarians certify the rabies vaccination form. Official government

veterinarians are able to verify which veterinarians are authorized to vaccinate dogs against
rabies in their country. Additionally, engaging foreign government official veterinarians in the

exportation process of an animal provides a pathway to communicate with a foreign government

when cases of fraud are detected by CDC. Currently, there is no recourse or follow-up that a

foreign government can perform when CDC identifies fraudulent paperwork because CDC does

not require foreign governments to certify the paperwork prior to export. Official government

veterinarians currently review and certify dog exportation paperwork for most other countries in

the world, but the United States does not have this requirement. The final rule will align the

United States requirements more closely with other countries that already require official

government certification of export documentation in order to prevent fraud and provide an

official pathway to engage with foreign government officials when cases of fraud are detected. It

is not feasible for HHS/CDC to maintain a list of veterinarians globally nor for USG officials to

verify that an importer does not present documentation signed by a banned veterinarian;

therefore, HHS/CDC is leveraging the existing international animal movement system that is

overseen by official government veterinarians in each respective country.

Comment: HHS/CDC received a comment that having official government veterinarians

verify vaccination forms may result in significant delays.

Response: HHS/CDC disagrees with the comment. The rabies vaccination form can be

completed during an animal’s health examination prior to export, and most official government

veterinarians can certify paperwork within 3-10 days of submission. Owners and importers

should plan ahead as wait times to have the forms certified can vary. However, HHS/CDC is

utilizing the existing international animal movement system which already has a process in place

for issuing travel documents for international pet movement, therefore, HHS/CDC does not

anticipate significant delays in certifying paperwork prior to exportation.

Comment: HHS/CDC also received a comment that rather than provide the vaccination

form, importers should be required to test tissue samples from dogs to prove they do not have

rabies.
Response: HHS/CDC would like to clarify that testing tissue samples for rabies can only

be done after an animal has died because the tissues are obtained from the animal’s brain. There

is no test that can be done to prove an animal does not have rabies while the animal is still alive.

Serologic blood tests (titers) can be run to measure antibodies against rabies while an animal is

alive, but titer tests do not prove an animal does not have rabies. In fact, elevated (or passing)

titers suggest an animal has either been vaccinated against rabies or is infected with the rabies

virus. This is why HHS/CDC requires a waiting period between the time a titer is collected and

when an animal can be imported, or the time between ACF vaccination and the 28-day

quarantine on arrival in the United States. The waiting period or quarantine period helps to

ensure the animal is not infection with the rabies virus.

Paragraph (t) — Requirement for Certification of U.S.-Issued Rabies Vaccination for Live Dog
Re-entry into the United States form for importers seeking to import U.S.-vaccinated dogs from
DMRVV high-risk countries
Of note: CDC has shortened the name of this form in the final rule to Certification of

U.S.-Issued Rabies Vaccination.

Comment: HHS/CDC received comments that an importer should not be required to have

USDA certify rabies vaccination forms prior to travel.

Response: HHS/CDC disagrees. As noted above, HHS/CDC has documented instances of

importers who falsify vaccination documents with the names of persons who are not accredited

to practice veterinary medicine in the United States, or who alter the U.S. vaccine records of

animals unbeknownst to the veterinarian. USDA official veterinarians can certify a veterinarian’s

authority to practice veterinary medicine in the United States through an electronic system that is

less susceptible to fraud. CDC, CBP and other government agencies can verify all documentation

on USDA’s website enhancing importer compliance and reducing risk of fraud.

Comment: HHS/CDC received questions from the public concerning how a U.S. person

traveling abroad would be able to have the Certification of U.S.-issued Rabies Vaccination for
Live Dog Reentry into the United States form completed by a U.S. veterinarian and endorsed by

USDA if they have already left the country.

Of note: CDC has shortened the name of this form in the final rule to Certification of

U.S.-Issued Rabies Vaccination.

Response: HHS/CDC has taken steps to address these concerns. HHS/CDC will plan for

a transition period to allow personal pet owners to return to the U.S. with their U.S.-vaccinated

dog without providing a titer or needing to quarantine at an ACF if they left the United States

without obtaining the rabies vaccination form if they can provide a USDA-issued export health

certificate that includes proof of a current, valid rabies vaccine. During this transition period,

HHS/CDC will have additional guidance available on its website for U.S. veterinarians regarding

how to document U.S. rabies vaccination in the event an importer has already left the United

States with their U.S.-vaccinated dog.

Comment: HHS/CDC also received comments encouraging HHS/CDC to work with

USDA to create joint documents, or to align with USDA requirements and documentation.

Commenters also asked what coordination with USDA has occurred and how CDC plans to

engage with USDA-accredited veterinarians to communicate the new requirements.

Response: HHS/CDC notes that it works closely with USDA regarding dog importation

requirements and believes the current, close coordination is sufficient. CDC has engaged with

USDA Veterinary Service to leverage the Veterinary Export Health Certification System already

used by USDA-accredited veterinarians for the completion of CDC’s Certification of U.S.-Issued

Rabies Vaccination Form during a dog’s export process. CDC plans to distribute website

materials through CDC and USDA websites and communicate directly with veterinary

organizations, such as the American Veterinary Medical Association, the National Association of

State Public Health Veterinarians, and the U.S. Animal Health Association.

CDC is also aligning with USDA APHIS Animal Care’s age requirement for the

importation of commercial dog imports by requiring all dogs to be at least six-months of age for
importation; partnering with USDA to ensure only USDA-accredited veterinarians complete the

Certification of U.S.-Issued Rabies Vaccination form; and requiring the form be endorsed by

USDA official veterinarians during the exportation process to reduce fraud. CDC and USDA

also work closely with ACF to ensure all dogs meet both agencies importation requirements.

However, CDC notes that current USDA APHIS Animal Care requirements do not apply to all

dogs and USDA APHIS Veterinary Service’s importation requirements do not focus on

protecting human health, therefore, CDC requirements are needed in addition to USDA

requirements to protect both human and animal health against the reintroduction of DMRVV.

Paragraph (u) — Requirement for proof that a dog has been only in DMRVV low-risk or

DMRVV-free countries.

Comment: Commenters expressed various concerns relating to the ability of an importer,

airline, or veterinarian to provide documentation confirming that a dog has been only in

DMRVV low-risk or DMRVV-free countries during the six months before its arrival into the

United States. Commenters also requested greater clarity regarding acceptable forms of

documentation.

Response: HHS/CDC appreciates these comments. Based on these public comments,

HHS/CDC has included a list of acceptable documents in the regulatory text that an importer

may use to confirm that a dog has been only in DMRVV-free or DMRVV low-risk countries

during the six months prior to its importation into the United States. Importers may provide proof

of rabies vaccination, which is recommended but not required, using the Certification of Foreign

Rabies Vaccination and Microchip form or the Certification of U.S.-Issued Rabies Vaccination

form listed below.

All forms must be endorsed by an official government veterinarian to be considered

valid. Importers should contact their local veterinarian who can submit the required form to an

official government veterinarian in the exporting country. Importers may also use the USDA pet
travel website or IPATA website to contact a pet shipper to request assistance.186,187This list also

appears on CDC’s website at www.cdc.gov/dogtravel. These documents include, but are not

limited to:

• A valid Certification of Foreign Rabies Vaccination and Microchip form if completed in

a DMRVV-free or DMRVV low-risk country and the dog is arriving into the United

States from the same DMRVV-free or DMRVV low-risk country as that listed on the

form. This form must be completed by an authorized veterinarian, which may include an

Official Government Veterinarian, and must be endorsed by an official government

veterinarian in the exporting country.

• A valid Certification of U.S.-Issued Rabies Vaccination form completed by a USDA-

accredited veterinarian and endorsed by a USDA official veterinarian.

• A valid USDA export certificate if the certificate is issued by a USDA-accredited

veterinarian and endorsed by a USDA official veterinarian to allow the dog to travel to a

DMRVV-free or DMRVV low-risk country and the dog is returning to the United States

from the same DMRVV-free or DMRVV low-risk country as that listed on the export

certificate.

• A valid foreign export certificate from a DMRVV-free or DMRVV low-risk country that

has been certified by a government veterinarian in that country. The export certificate

must be accompanied by veterinary records (such as the EU pet passport) or proof of

payment for veterinary services establishing that veterinary services were performed in

the exporting country at least six months before traveling to the United States.

• A Certification of Dog Arriving from DMRVV-free or DMRVV low-risk Country form if

accompanied by veterinary records or proof of payment for veterinary services

establishing that veterinary services were performed in the same DMRVV rabies-free or

186 USDA Pet Travel. www.aphis.usda.gov/pet-travel/us-to-another-country-export.


187 International Pet and Animal Transportation Association. www.ipata.org.
DMRVV low-risk country at least six months before traveling to the United States. This

form must be completed by an authorized veterinarian, which may include an official

government veterinarian, and must be endorsed by an official government veterinarian in

the exporting country.

Regarding airlines, CDC does not require that airlines confirm that a dog has been only in

DMRVV low-risk or DMRVV-free countries during the six months before its arrival into the

United States. Rather, airlines must confirm that importers have presented required

documentation to the airline before boarding the dog. CDC will specify in communication

materials how airlines can confirm an importer has presented the required documentation.

HHS/CDC further notes that it is the importer and not the veterinarian who is responsible

for providing documents to the airline confirming that a dog has been only in DMRVV low-risk

or DMRVV-free countries during the six months before its arrival into the United States.

Comment: HHS/CDC also received comments from public health agencies expressing

concern that allowing dogs from DMRVV-free countries to enter the United States without proof

of vaccination creates potential loopholes for unscrupulous importers to exploit.

Response: HHS/CDC shares this concern. However, HHS/CDC believes there should be

reduced importation requirements for countries that have eliminated canine rabies in order to

encourage other countries to implement canine rabies elimination plans and to reduce the burden

on importers traveling from DMRVV-free countries to the United States. HHS/CDC

acknowledges that there have been numerous cases documented by CBP, CDC, and USDA of

importers moving dogs from DMRVV high-risk countries through DMRVV-free countries to

avoid U.S. entry requirements. HHS/CDC is attempting to address this issue by requiring

documentation from importers arriving with dogs from DMRVV-free countries attesting that the

dog has been in a DMRVV-free country for the six months before arrival. This documentation

must be certified by an official government veterinarian in the exporting country. Through this

rulemaking HHS/CDC has attempted to balance the needs of public health with the desire to not
unnecessarily burden the vast majority of importers who enter the United States with dogs from

DMRVV-free or DMRVV low-risk countries. HHS/CDC is not requiring proof of rabies

vaccination, serologic titers, quarantine, or limiting ports of entry for dogs arriving from

DMRVV-free or DMRVV low-risk countries with appropriate paperwork. HHS/CDC believes

that this rule appropriately strikes this balance.

Paragraph (v) — Denial of admission of dogs and cats.

Comment: HHS/CDC received a comment from an airline industry organization stating

that the proposed “six-hour window from which an animal denied admission into the United

States should be relocated to a CDC-facility or a CDC-registered facility” was too short. The

commenter suggested “that airlines notify the CDC within six (6) hours of an animal being

denied admission into the U.S. with transport scheduled within 24 hours.”

Response: HHS/CDC has split § 71.51(v) as written in the NPRM into two paragraphs.

Paragraph (w) is a new paragraph in the final rule. In response to public comment, under

paragraph (w), HHS/CDC now requires airlines to transport healthy animals to a CDC-registered

ACF or other CDC-approved facility (if a CDC-registered ACF is not available) within 12 hours

of arrival. Ill or injured animals must be transported by the airline immediately to a CDC-

registered Animal Care Facilities or other CDC-approved veterinary clinic as directed by CDC.

Animals arriving by air that are awaiting an admissibility determination or denied admission

must be held in CDC-registered Animal Care Facilities or other CDC-approved facility (if a

CDC-registered Animal Care Facility is not available).

An airline must immediately report an obviously ill or injured animal (e.g., the animal is

unable to stand, has difficulty breathing, is bleeding, has broken bones or disfigured limbs, or is

experiencing seizures, vomiting, or discharge from the nose, mouth, or eyes) arriving into the

United States to the CDC quarantine station (also known as the port health station) of
jurisdiction. The airline must immediately arrange to transport an obviously ill or injured animal

to a CDC-registered Animal Care Facility or veterinary clinic as directed by CDC.

Animals arriving by sea that are denied admission must remain on the vessel while

awaiting return to the country of departure.

HHS/CDC is also clarifying that it may deny entry to an animal if an importer refuses to

comply with CDC-required diagnostic tests to rule out communicable diseases. Diagnostic tests

are crucial to determine the cause of an illness and ensure the animal does not pose a public

health threat.

Paragraph (w) — Disposal or disposition of dogs and cats denied admission to the United States.

HHS/CDC addressed comments above in “General Comments” that inaccurately

interpreted HHS/CDC’s NPRM as proposing to euthanize dogs that do not meet HHS/CDC entry

requirements. Additionally, comments noted in paragraph (z) may also be applicable to

paragraph (w).

Paragraph ( (x)) — Appeals of CDC denials to admit a dog or a cat upon arrival into the United

States.

HHS/CDC received no public comment on this paragraph of the proposed rule.

Paragraph (y) — Record of death of dogs and cats en route to the United States and disposition

of dead animals.

Comment: HHS/CDC received a comment that charging importers for the cost of a

necropsy is egregious because it imposes an extra burden on a grieving family. The comment

stated that only, “if the autopsy revealed that the importer had falsified documentation then fines

and any other action against the importer would be appropriate.”


Response: HHS/CDC disagrees with this comment. CDC acknowledges the important

role pets play in the lives of people and their families; however, determining the cause of death

of an imported dog or cat is crucial to ensuring an importer, their family members, and other

people or animals were not exposed to a potential communicable disease that could threaten the

health and safety of an importer, their family, or a community. Necropsies are performed by

licensed veterinarians who can arrange for the remains or cremated ashes of an animal to be

returned to the importer if the cause of death is determined not to be a communicable disease,

which provides grieving families the ability to mourn their dog or cat while ensuring the safety

of travelers and U.S. communities. Importers are financially responsible for the animals they

import, including the cost of any diagnostic tests needed to ensure a dog or cat is not carrying a

communicable disease, including post-mortem diagnostic tests. While the focus of this final rule

is DMRVV, there are other communicable diseases that dogs and cats can spread to people, so

requiring an importer to pay for a necropsy only if the rabies vaccination paperwork is falsified is

not sufficient to protect public health.

Paragraph (z) — Abandoned shipments of dogs and cats.

Comment: HHS/CDC received numerous letters from public health partners, animal welfare

groups, importers, and rescue groups that stated that HHS/CDC should identify resolutions for

the issues of abandoned animals at ports of entry and the public health risks associated with

delayed care or evaluation for sick or injured animals that arrive in the United States. However,

other commenters, including an airline industry member organization, objected to airlines being

identified as the responsible party for dogs they transport in the event an importer abandons the

dog. An airline industry member organization suggested that CDC and CBP should be

financially responsible for abandoned animals. Commenters stated the responsibility for finding

appropriate housing for dogs denied admission should not be shifted to airlines. In their view, the

care of a dog denied admission into the United States should be the responsibility of the Federal
agency denying entry and/or the facility where entry is denied. Commenters argued there is no

justification for shifting the consequences of enforcing Federal agency rules onto carriers, and

that this was akin to an unfunded mandate for airlines.

Response: HHS/CDC notes that abandonment of animals arriving in the United States is

a genuine, documented problem, which can create public health risks (exposures to sick or rabid

animals), animal welfare concerns, and additional costs for housing and care. The final rule seeks

to reduce the incidence of abandoned animals by requiring airlines to confirm entry requirements

prior to boarding, which will likely reduce the number of dogs denied entry and abandoned on

arrival. The final rule further provides that when an airline accepts an animal for boarding,

whether in cargo or in the cabin, the airline must provide care for the animal in the event an

importer abandons it or to transport the animal to a veterinary clinic on behalf of the importer if

it becomes ill or injured prior to being cleared for entry into the United States. Such costs have

never been borne by Federal agencies, and this requirement does not represent a shifting of this

responsibility. This is consistent with existing practice, as carriers are already assigned

responsibility for the goods they transport (if there is an AWB). For the rare occasions in which

an animal is abandoned, carriers have the ability to use contractual provisions to ensure

importers are responsible for associated costs, as discussed at more length below.

HHS/CDC would like to note that this requirement would not be considered an unfunded

mandate, as that term is understood under the Unfunded Mandate Reform Act, 2 U.S.C. 1501 et

seq., for several reasons. First, HHS/CDC is not imposing a cost of $177M USD or more onto

airlines, as required to be an unfunded mandate under the 1995 Unfunded Mandate Reform Act

of 1995. HHS/CDC estimated that between 300 and 750 dogs would be denied entry each year

under the regulatory baseline (i.e., under the dog importation requirements specified prior to this

final rule going into effect and assuming the temporary suspension was not in effect). With the

requirements in the final rule, CDC assumed that between 30 and 75 dogs would be denied entry

because HHS/CDC believes that the standardization of rabies vaccination documentation will
facilitate the ability of airlines to check this documentation is in place prior to boarding dogs for

flights to the United States. Only a small portion of all imported dogs would be abandoned by

importers such that the costs of the dogs’ care and their return to their countries of origin would

be incurred by airlines. CDC estimated that the costs to airlines under the regulatory baseline

would range from $42,000 to $650,000. These costs would be further reduced by the

requirements in the final rule. Second, the costs for transportation, care, and housing are not

being shifted from the government to the airline because these costs have never been a

government responsibility. Third, ensuring airlines are responsible for confirming entry

requirements for dogs prior to boarding is likely to result in fewer dogs denied entry and

abandoned at the U.S. port, reducing the number of abandoned animals that airlines may be

responsible for and resulting in fewer costs to airlines for abandoned animals. HHS/CDC

acknowledges that the need for airlines to review additional documents and create bills of lading

(or other CDC-approved alternative) as required in this final rule will also increase costs for

airlines to transport dogs to the United States. In addition, this final rule is expected to reduce the

number of dogs flown into the United States, which would reduce the revenue and profit earned

by airlines to transport dogs.

Comment: HHS/CDC received comments requesting that it require importers to either

reimburse airlines for costs relating to care and transporting an animal to a veterinary clinic or

require that the importer be the financially responsible if the animal is abandoned.

Response: HHS/CDC notes that the importation of animals and other goods involves

multiple parties (importers, carriers, etc.), each with its own sets of responsibilities. The final

rule outlines these responsibilities in ways that best protect public health. Airlines have

responsibilities for the animals they carry, and the final rule is designed to minimize this burden

where possible while protecting public health from the importation of rabid dogs. HHS/CDC

agrees that an airline may pursue reimbursement from importers for any expenses incurred on

behalf of the importer if an animal arrives ill, is denied admission, or is exposed to a sick animal
in transit. Both the NPRM and the final rule include regulatory text that states that an airline may

make “contractual arrangements with an importer or a third party relating to the expenses of

returning an animal to its country of departure, for veterinary care, or otherwise disposing of an

animal, provided that no government costs are incurred.” Airlines would also be able to include

reimbursement for costs incurred relating to animal importations as part of their contract for

carriage with an importer. To the extent that the commenters argue that HHS/CDC should

directly reimburse carriers for costs incurred on behalf of an importer abandoning an animal,

HHS/CDC notes that it would lack the legal authority to provide such indemnification. The cost

of caring for a dog denied admission has never been a government responsibility. Long-standing

regulations at 42 CFR 71.51(g) have provided that animals denied admission shall be detained at

the owner’s expense, and not at government expense. Although the rule may have the effect of

transferring immediate responsibility from the owner to the carrier, this is to ensure that animals

abandoned by their owners after import are housed appropriately pending return to their country

of departure, and as noted above, contractual mechanisms are available to carriers to pursue

reimbursement from importers for any expenses incurred on behalf of the importer if an animal

arrives ill, is denied admission, or is exposed to a sick animal in transit. This shifting of

responsibility is justified because airlines can establish the conditions by which they accept

goods and cargo transported into the United States. It is also the airline, not the owner, that

establishes flight schedules and can therefore arrange to return a dog denied admission quickly to

its country of departure, thereby reducing potential housing costs, or otherwise disposing of an

animal, provided that no government costs are incurred.

Comment: HHS/CDC also received comments that veterinary clinics should be

acceptable housing alternatives for animals abandoned at ports of entry in the event an ACF is

not available.
Response: HHS/CDC works closely with the airlines, USDA, and CBP when an animal is

abandoned at a port of entry. In the event an ACF is not available, CDC may contact local

veterinary clinics to determine whether there is available housing for an abandoned animal.

Abandoned animals are the responsibility of the airline and the animal’s ultimate disposition is

determined in collaboration with the airline. CDC veterinarians will contact local veterinary

clinics or veterinary teaching hospitals to determine whether they are equipped to house an

imported dog. CDC may request verification from the clinic or hospital that it is equipped to

handle a variety of scenarios, such as an isolation or quarantine, emergency surgery, diagnostic

testing capabilities, or overnight (24 hours a day) monitoring to determine whether a hospital or

clinic is suitable to house an animal pending admissibility determination. These determinations

are made based on the health status of the dog and assessment of potential communicable disease

risks. In the past, CDC has allowed dogs to be held at local veterinary clinics or veterinary

teaching hospitals when ACF are not available for short periods of time. HHS/CDC agrees that if

an ACF is not available, a CDC-approved alternative facility such as a veterinary clinic or kennel

may be a suitable alternative for animals abandoned at ports of entry. The facility must be

approved by HHS/CDC prior to transport.

Comment: HHS/CDC received a comment stating that an importer should not be allowed

to abandon an animal if the animal has not been cleared to enter the United States with its

importer.

Response: HHS/CDC notes that in practice it is very difficult to prevent importers from

abandoning animals after the animals arrive in the United States. In general, there is a large

amount of inanimate goods that are abandoned by importers upon arrival. Although HHS/CDC

in theory could attempt to penalize importers from abandoning dogs upon arrival, to do so,

HHS/CDC must request assistance from other departments and agencies to address violations

which can be a time-consuming process. This process would also not address the immediate

concern of port partners who would still need to find adequate housing and care for abandoned
animals and determine their ultimate disposition on a timely basis. Considering the enforcement

needs and practical difficulties in preventing an individual importer from abandoning a dog,

HHS/CDC has sought alternative solutions as explained in this final rule.

Paragraph (aa) — Sanitation of cages and containers of dogs and cats.

HHS/CDC received no public comment on this paragraph of the proposed rule.

Paragraph (bb) — Requirements for in-transit shipments of dogs and cats.

Comment: HHS/CDC received a comment clarifying that in-transit shipments only

include dogs transported as cargo.

Response: HHS/CDC confirms that this is accurate. HHS/CDC is aligning with the

USDA’s definition of in-transit which only applies to dogs in cargo. This is because animals in-

transit must remain under the care of the airlines to minimize contact with members of the public

or illegal entry into the United States. Dogs flown in the passenger environment (hand-carried or

checked baggage) do not meet the definition of in-transit and must meet HHS/CDC entry

requirements.

Comment: HHS/CDC received a comment that in-transit shipments should be required to

contain an entry number on the in-bond form.

Response: HHS/CDC disagrees. In-transit shipments are, by definition, not entering the

U.S.; therefore, an entry number is not needed. HHS/CDC believes that the addition of an entry

number could lead to confusion and the accidental admission of animals that do not meet U.S.

entry requirements.

Although HHS/CDC did not receive public comment about microchip requirements for

dogs in-transit, HHS/CDC is clarifying that a microchip is not required for dogs that are

transported by aircraft and are being transited through the United States if retained in the custody

of the airline.
Paragraph (cc) — Bill of lading and other airline requirements for dogs.

Comment: HHS/CDC received comments from airlines that they should not be held

responsible for confirming that importers meet entry requirements before boarding dogs. Other

commenters requested more information on how they can confirm the CDC Dog Import Form

has been completed.

Response: HHS/CDC is requiring airlines to confirm entry requirements in order to

decrease the likelihood a dog will be denied entry and abandoned at upon arrival. Airlines can

ensure importers have appropriate paperwork prior to departure, and airlines are best positioned

to confirm required documentation at the point of departure. Additionally, these requirements

align with other airline responsibilities in other contexts (verifying traveler passport and visa

information, screening cargo and baggage). Airlines will be required to confirm all necessary

paperwork is present and that the information on documents is consistent when multiple

documents are presented to the airline. For example, airlines should deny boarding based on

discrepancies in paperwork that would be obvious to a reasonable observer. CDC will issue

guidance on how to confirm documentation. It will not be an onerous process for airlines to

confirm importers have a CDC Dog Import Form receipt as importers will be able to present the

emailed receipt digitally or a paper print-out of the receipt to an airline representative at check-

in.

Comment: HHS/CDC received comments supporting the requirement that airlines should

deny boarding dogs whose importer does not present required documentation to prevent

inadmissible dogs from flying to the United States.

Response: HHS/CDC agrees with this comment. Federal agencies that work at ports

strongly support airlines confirming importer documentation prior to the flight to limit the

number of inadmissible dogs that arrive at ports in the United States. Many State agencies also
voiced support for required document review and visual screening of dogs by airlines prior to

accepting dogs for transport to prevent inadmissible dogs from flying to the United States and

entering their jurisdictions. These requirements align with other airline responsibilities in other

contexts (verifying traveler passport and visa information, screening cargo and baggage).

Comment: HHS/CDC received comments from airlines that they believed the proposed

rule would require them to buy specialized equipment (microchip scanners) and opposed this

requirement.

Response: HHS/CDC clarifies it is not asking airlines to scan dogs’ microchips. Scanning

is performed at the ACF or by the importer with assistance from CDC’s quarantine station

officers (also known as CDC port health station officers). Airlines will be required to confirm all

necessary paperwork is present and that the information on documents is consistent when

multiple documents are presented to the airline. For example, airlines should deny boarding

based on discrepancies in paperwork that would be obvious to a reasonable observer. CDC will

issue guidance on how to confirm documentation.

Comment: HHS/CDC received numerous comments from public health partners, animal

welfare groups, importers, and rescue groups that airlines should be responsible for the animals

they transport.

Response: HHS/CDC agrees with these comments and believes the best way to ensure

airline responsibility for the animals they transport is through an existing process called a bill of

lading. A bill of lading (including an AWB) is a legally binding document issued by a carrier to

a shipper or importer that details the type, quantity, and destination of the goods (i.e., dogs)

being carried. A bill of lading serves as a shipment receipt when the carrier delivers the goods at

a predetermined destination. A bill of lading is a key document to ensure theft or abandonment

of goods does not occur while the goods are being shipped to the final destination. Additionally,

a bill of lading serves as undisputed proof of shipment, and it represents the agreed upon terms

and conditions for the transportation of the goods. Dogs that arrive ill, injured, or who are
denied entry upon arrival in the United must have a bill of lading to ensure the animal receives

timely care and can be tracked by Federal agencies and airlines throughout the clearance or

return process. A bill of lading gives the Federal Government authority to leverage the carrier’s

bond in cases of noncompliance. HHS/CDC encourages airlines with limited cargo operations to

work with sales supervisors in their local offices or partner airlines to create AWB. CDC and

several foreign-based air carriers have successfully piloted the creation of AWB for dogs

transported in the passenger environment.

Comment: HHS/CDC received a comment that the rule usurps the USDA’s authority by

treating all pets as imports and by forcing all dogs to travel by air as cargo.

Response: HHS/CDC disagrees because it is not unusual for different Federal agencies to

possess overlapping legal authority and HHS/CDC’s requirements complement and do not

conflict with applicable USDA requirements. Additionally, dogs and cats are goods that are

imported into the United States if entering from a foreign country regardless of whether the

owner/importer considers the animal to be a personal pet. An importation occurs whenever a dog

or cat is presented for admission at a U.S. port, regardless of whether the animal is being

presented for admission for the first time or returning to the United States after traveling abroad.

Dogs and cats must meet the United States’ importation requirements to be eligible for entry or

re-entry. HHS/CDC has authority to create requirements based on public health concerns for the

importation of dogs into the United States. USDA is the competent authority for animal export

and animal welfare during transport. HHS/CDC’s final rule is focused on dog and cat

importation and protecting the public health by establishing requirements specific to preventing

the reintroduction of DMRVV into the United States. HHS/CDC’s requirements for airlines to

confirm documentation before boarding and create a bill of lading or record of transport serve a

public health function by preventing inadmissible dogs from being transported to the United

States. These requirements also allow HHS/CDC more easily track and identify dogs upon
arrival that require further public health evaluation, such as examinations needed for sick or dead

dogs or cats.

Additionally, HHS/CDC clarifies that the proposed rule and this final rule do not require

that all dogs fly as cargo. HHS/CDC does note that some U.S. ports may require dogs to enter as

cargo based on the ACF and CBP Port Director’s authority. CBP Port Directors have authority to

direct how dogs are processed and cleared at their ports. This is done at the CBP Port Director’s

discretion and is not a requirement of this final rule. HHS/CDC also notes that travelers can

choose to import dogs through another port if they want to import their dog in the passenger

environment (hand-carried or checked baggage). HHS/CDC’s final rule requires airlines to create

an Airway Bill (AWB) or other suitable bill of lading for the movement of dogs in the passenger

environment.

Comment: Some commenters stated that the creation of AWB is not possible for dogs

transported in the passenger environment (hand-carried or checked baggage). CDC also received

comment from the public that flying with an AWB will force dogs to fly as cargo. One

commenter requested that HHS/CDC require importers and dogs transported in the passenger

environment be cleared together (which can only occur in the Federal Inspection Station) and

multiple comments stated that importers should be able to continue to fly imported dogs as

checked baggage or hand-carried or both because it is more expensive to fly a dog as cargo and

because importers do not want to be separated from their dogs. Commenters also stated that

some airlines do not have cargo operations so they cannot create an AWB.

Response: HHS/CDC disagrees with these comments. CDC has successfully piloted the

creation of AWB for dogs transported in the passenger environment with several airlines,

therefore, HHS/CDC believes this approach can be adopted by other air carriers so that dogs can

continue to fly as hand carried or checked baggage. HHS/CDC has also revised the requirements

in this final rule to allow greater flexibility for airlines that are unable for technical reasons to

generate an AWB to transport dogs as cargo, checked baggage, or hand-carried baggage. Airlines
that lack the technical ability to generate an AWB to transport dogs as checked baggage or as

hand-carried must request a waiver from CDC and provide a standard operating procedure (SOP)

outlining how they will ensure care for any ill, injured, or abandoned animals in the absence of

an AWB. CDC may grant an annual waiver. As a condition of granting a waiver, CDC may

require the airline to work with a broker to file the appropriate paperwork and identify suitable

housing accommodations for any dogs detained pending admissibility (such as an ACF or local

kennel). The SOP must include the location of a bonded facility or other suitable alternative

approved by CBP and CDC prior to transport of animals. As a further condition of granting a

waiver, CDC may require the airline to submit documentation outlining a timetable and steps

that will be taken to develop the technical capacity to generate an AWB (or another suitable

alternative to an AWB) to transport dogs. CDC will provide additional details for airlines

seeking exemption for the AWB requirement in technical instructions available by emailing

[email protected].

Comment: One commenter noted that HHS/CDC should utilize CBP’s Automated

Commercial Environment (ACE) 2.0 system for dog importations.

Response: HHS/CDC carefully considered this comment but declines this option because

using ACE would require importers to hire a broker which would significantly increase importer

costs. Additionally, ACE is only accessible by CBP personnel as authorized by their respective

agency role and provisioned for cargo environments, and would not be provisioned for use by

CBP officers located in the FIS in verifying whether an owner has uploaded all required

documentation prior to arrival. Instead, by requiring that dog importers use the CDC Dog Import

Form, CDC is able to track dog imports in a manner similar to ACE through a web-based system

that does not require importers to use brokers. Importers will present the paper-based CDC Dog

Import Form receipt to CBP officers in the FIS, or the receipt can be uploaded into ACE for dogs

traveling in cargo. This ensures the receipt is accessible by all Federal officers at ports of entry.
Additionally, CDC does not currently have access to ACE and obtaining access would be costly

for CDC at this time. CDC, however, may consider use of this system in the future.

Comment: HHS/CDC also received comments from the airline industry on the six-hour

timeline for airlines to transport abandoned, ill, or injured dogs and dogs denied entry awaiting

return to their country of origin to an HHS/CDC-approved facility. The commenter suggested

that the six-hour window is arbitrary and not supported by corroborative evidence and requested

24 hours to transport these dogs from cargo warehouses to veterinary clinics or kennel facilities,

and six hours to notify HHS/CDC of the abandoned, ill, or injured dogs. HHS/CDC also received

many comments from public health partners, animal welfare groups, importers, and rescue

groups supporting the six-hour timeframe for airlines to transport abandoned, ill, or injured dogs

or dogs awaiting return to their country of origin to a veterinary or kennel facility for

examination or care.

Response: HHS/CDC appreciates these comments and notes that it has carefully

considered the proposed 6-hour timeframe based on concerns relating to the burden on the carrier

and to the health and safety of animals detained pending a determination as to their admissibility

and workers who may interact with these animals. HHS/CDC anticipates that significantly

increasing the time airlines are allowed to keep dogs in cargo warehouses (from 6 hours to 24

hours) would result in an increase in illness and deaths in dogs. An increase in ill dogs and dogs

dead on arrival would negatively impact Federal and State public health resources because CDC

would need to conduct a public health investigation into the cause of the illness or death. CDC

conducted an average of 38 animal health investigations per year between 2019-2023. Each

illness/death investigation can cost between $100-$5,500 per event ($3,800-$209,000 per year in

public health costs to State or Federal agencies).188

188Pieracci EG, Maskery B, Stauffer K, Gertz A, Brown C. Risk factors for death and illness in dogs imported into
the United States, 2010-2018. Transboundary and Emerging Diseases, 2022; 1-9.
Additionally, CDC notes that cargo warehouse staff are not trained to feed/water/care for

animals and that detaining animals for long periods of time increases the health risks to the

animals as well as the potential risk of injury or expose to workers. Expanding the timeframe for

airlines to house dogs in cargo warehouses necessitates additional care from cargo warehouse

staff, thereby increasing the risk of bites, scratches, and other injuries from dogs. Additionally,

the stress dogs experience during transport could exacerbate the risk of injury to cargo

warehouse workers. CDC has documented instances of cargo warehouse staff leaving animals

unattended in their crates without food, water, or access to elimination areas outside their crates

for prolonged periods of time. Prolonged wait times in cargo warehouses have also led to illness

and death in multiple animals (five illnesses and one death in 2019; and two deaths in 2023).

Consistent with USDA regulations, animals should receive food at a minimum every 24

hours and water every 12 hours during transport.189Additionally, animals must have their

enclosures and food and water receptacles cleaned every 24 hours. CDC and USDA have

documented numerous shipments of animals that did not have adequate food and water during

transport, nor were their cages cleaned as required. Lengthy international flights, which can

begin for a crated animal up to 4 hours before the flight departs and includes the flight time (6-16

hours) plus a 24-hour wait in a cargo hold, will leave many animals exceeding this

feeding/watering/cleaning period leading to dehydration, hypoglycemia, illness, or death.

Neglect of basic animal care, such as feeding and watering, has a direct public health impact on

CDC as noted above because CDC must investigate every report of illness or death in an

imported animal to determine the public health risk.

However, HHS/CDC recognizes that some airlines may need additional time to find

suitable housing for animals; therefore, HHS/CDC is modifying the language in the final rule to

allow airlines up to 12 hours to move dogs from cargo warehouses to an ACF or other CDC-

189USDA. Animal Welfare Act and Animal Welfare Regulations. Title 9, Chapter 1, Subpart A, Part 3.9, 3.10, 3.14,
3.17). https://www.aphis.usda.gov/animal_welfare/downloads/AC_BlueBook_AWA_508_comp_version.pdf.
approved location if the animal is healthy. Obviously ill or injured animals must be reported

immediately to the CDC quarantine station of jurisdiction and must be transported immediately

thereafter to a veterinary clinic or as directed by CDC. Notification to CDC should be made

based on visual observation of illness in animals (e.g., unable to stand, difficulty breathing,

bleeding, broken bones or disfigured limbs, seizures, vomiting, or discharge from the nose,

mouth, or eyes) by the airline employees or its agents (including contracted cargo warehouse

staff) or by Federal government officials (e.g., CDC or CBP staff). Delaying the care of ill or

injured animals will likely result in more deaths, increased potential public health risks, and

would be considered inhumane.

Comment: HHS/CDC received comments from the public that it will be difficult to

ensure airlines comply with these requirements.

Response: HHS/CDC has outlined options for addressing noncompliant air carriers in §

71.51(ee) of the final rule. Failure to comply with CDC requirements can result in CDC

prohibiting carriers from transporting animals. However, CDC will develop training materials for

airline partners and animal shippers in the industry and work collaboratively with the animal

transportation industry to ensure compliance. Diligence is needed from importers as well as the

airlines to ensure compliance with U.S. entry requirements. CDC will continue to develop job

aids, presentations, website information, and other materials to distribute to those in the animal

transport industry.

Comment: HHS/CDC received a comment that “since airlines have transport registrations

with USDA, it is the USDA’s responsibility to set the rules and regulations for transportation of

live animals.”

Response: Although HHS/CDC agrees that USDA’s regulations govern many aspects of

animal transportation, this final rule is authorized under section 361 of the Public Health Service

Act (PHS Act) (42 U.S.C. 264), which authorizes the HHS Secretary to make and enforce such

regulations as in the Secretary’s judgment are necessary to prevent the introduction,


transmission, or spread of communicable diseases from foreign countries into the United States

and from one State or possession into any other State or possession. The final rule’s provisions,

among other things, are designed to prevent the importation of inadequately vaccinated, ill, or

dead animals which can lead to communicable disease spread. This is both a public health issue

and an animal health issue. HHS/CDC regulates public health risks and works closely with

USDA to align requirements where possible; however, the agencies have different mandates, and

the purpose of this final rule is to protect the public’s health.

Comment: HHS/CDC also received comments that airline costs would increase or that

airlines will stop transporting dogs.

Response: HHS/CDC appreciates these comments and notes that the comment from an

airline industry organization did not state that HHS/CDC’s proposed requirements would cause

airlines to stop transporting dogs. For the NPRM, HHS/CDC attempted to estimate the costs to

airlines but lacked data on the potential costs to airlines for additional document review and to

create bills of lading. HHS/CDC did not receive data from commenters that would help refine

these cost estimates, but HHS/CDC understands that commenters may believe the cost estimates

for airlines are too low. In the NPRM, HHS/CDC estimated the costs to airlines would include an

additional five minutes per dog from DMRVV-free or low-risk countries and 15 minutes per dog

from DMRVV high-risk countries. This resulted in an estimate of about $3.2 million (range: $1.3

to $6.6 million) to airlines. On average, this would correspond to between $6.25 to $17.29 per

dog transported. CDC could only assume how much time would be required for airlines to

review documentation. However, based on comments from the airline industry about the

potential difficulties for some airlines to produce bills of lading and other commenters

expressing concern that the cost to airlines were underestimated, HHS/CDC increased the

amount of time that would assume to be required for airlines to comply with the requirements of

this final rule. In the analysis in the final rule, HHS/CDC assumed the amount of time per dog

would be 50% more than the estimate for the NPRM for dogs from DMRVV high-risk countries
and 100% more for dogs from DMRVV-free or low-risk countries. This amount should not

significantly impact airlines’ costs to transport dogs on international flights.

On an individual dog basis, the greatest costs to airlines would be incurred when dogs are

denied entry and abandoned by an importer. However, this would only occur for a fraction of the

dogs transported and HHS/CDC believes the additional requirements included in this final rule

should reduce the number of dogs denied entry by standardizing the forms used to verify rabies

vaccination documentation. As noted above, the annual costs to airlines for abandoned dogs was

estimated to be between $42,000 and $650,000 per year. Assuming the number of dogs denied

entry with the final rule is less than under the regulatory baseline, the costs to airlines for

abandoned dogs should decrease.

In addition, HHS/CDC has included language in the final rule that allows airlines to seek

reimbursement from importers that abandoned animals on arrival, thereby mitigating the

potential cost burden on airlines and making it unlikely that airlines will stop transporting

animals. They may modify their transportation process to ensure animals are healthy and meet

CDC entry requirements prior to transporting the animal. Furthermore, the clearance process at

airports may have to be modified to reflect CDC’s requirements that are being put in place to

control the public health risk of dogs arriving from DMRVV high-risk countries, but CDC will

work with airlines and other port partners to continue the safe transportation of dogs from

DMRVV high-risk countries.

Paragraph (dd) — Order prohibiting carriers from transporting dogs and cats.

HHS/CDC received no public comment on this paragraph of the proposed rule.

Paragraph (ee) — Prohibition on imports of dogs from DMRVV-restricted countries.

Comment: HHS/CDC received several comments and questions regarding DMRVV-

restricted countries. The questions included how the list would be determined, whether data
would be publicly available, and whether a country could appeal their status. Suggestions were

offered to ban veterinarians instead of countries and to issue permits for dogs arriving from

DMRVV-restricted countries. Some commenters expressed concern that people could get stuck

overseas with pets when a country was added to the DMRVV-restricted list.

Response: HHS/CDC will maintain a “List of DMRVV-Restricted Countries” from

which the importation of dogs into the United States would be prohibited. The list of DMRVV-

restricted countries would be maintained on HHS/CDC’s website. The addition of countries to

the DMRVV-restricted country list will also be announced in notices published in the Federal

Register and the data supporting the announcement will also be published in the Federal

Register. HHS/CDC is aware of the risk of some travelers being unable to return with their dogs,

and HHS/CDC will consider ways to provide adequate notice to importers of changes to the

DMRVV-restricted country list, such as including as much time as possible between the

announcement of a change to the list and the effective date. HHS/CDC will also retain the ability

to issue, at its discretion, a special exemption permit on an extremely limited basis for certain

dogs that have been in a DMRVV-restricted country in the six months prior to their importation

into the United States.

Although there is no formal appeal process, a listed country’s officials may submit

additional information to CDC if they believe that the country has been added to the “List of

DMRVV-Restricted Countries” in error or if they believe the listing is no longer current.

However, HHS/CDC may maintain restrictions or prohibitions in place until the Director is

satisfied that the DMRVV-restricted country has established sufficient controls to prevent the

reintroduction of DMRVV into the United States, including measures to prevent the use of

falsified or fraudulent vaccination credentials or invalid rabies vaccination certificates, or the use

of expired, ineffective, or unapproved vaccine products within a country.

HHS/CDC notes that maintaining a list of individual veterinarians would be extremely

cumbersome, operationally difficult to revise and maintain, and raise concerns regarding
HHS/CDC’s ability to effectively enforce such a restriction. Therefore, HHS/CDC declines to

implement this proposal. HHS/CDC further notes that the goal of having an official government

veterinarian certify the export documentation is to ensure that the exporting country is

monitoring the activity of their veterinarians and not certifying any documents they deem

suspicious or fraudulent. This also allows CDC to communicate concerns directly with exporting

country officials if fraudulent paperwork is noted. Each country has its own rules and regulations

governing veterinary medicine and it would be inappropriate and likely ineffective for

HHS/CDC to focus on individual foreign veterinarians.

Paragraph (ff) — Request for issuance of additional fines or penalties.

HHS/CDC received no public comment on this paragraph of the proposed rule. However,

CDC is adding language informing the public that it may also refer potential violations of

Federal law to the U.S. Department of Justice for investigation, and based on the results of such

investigation, prosecution. Specifically, CDC may refer a matter to the U.S. Department of

Justice if the Director has reason to believe that an individual or organization has violated

Federal law, including by forcibly assaulting, resisting, opposing, impeding, intimidating, or

interfering with a U.S. government employee while engaged in or on account of the performance

of their official duties in violation of 18 U.S.C. 111, by obstructing an agency proceeding in

violation of 18 U.S.C. 1505, or by otherwise engaging in conduct contrary to law. CDC believes

that this provision serves an important function in informing the public and potentially deterring

bad actors from engaging in conduct that forcibly interferes with CDC and CBP’s ability to carry

out its official duties or obstructing an agency proceeding under this section.

Comment: HHS/CDC received public comment on matters that were not part of

HHS/CDC’s proposed changes to its regulations and thus are outside of the scope of this final

rule. These comments included statements about saving wildlife and suggestions for the

regulation of other animals such as nonhuman primates.


Response: HHS/CDC is not updating its regulations for species other than dogs and cats

in this rule.

Comment: HHS/CDC also received comments asking to end the temporary suspension of

dogs entering the United States from countries with a high risk of rabies.190

Response: HHS/CDC notes that these comments are outside the scope of the proposed

rulemaking which did not solicit any comments or propose changes to the temporary suspension.

However, HHS/CDC clarifies that the purpose of this rulemaking is to mitigate the need for

future suspensions by reducing the likelihood of DMRVV being reintroduced into the United

States. HHS/CDC further intends to let the temporary suspension expire on July 31, 2024. These

comments are beyond the scope of this final rule.

Comment: HHS/CDC received comments about focusing efforts on other areas rather

than this rulemaking such as vaccinating immigrants or “illegal immigrants,” addressing drug

trafficking, addressing human trafficking, and working to prevent the next pandemic.

Response: HHS/CDC notes that these comments are outside the scope of the proposed

rulemaking, which is focused on dog and cat importation.

E. General comments relating to DMRVV high-risk countries.

Comment: HHS/CDC received a number of comments stating that too many countries

were on the DMRVV high-risk country list. Commenters also requested that HHS/CDC make

publicly available the data used to determine the DMRVV high-risk list.

Response: HHS/CDC notes that none of the comments it received questioned

HHS/CDC’s proposed definition for DMRVV high-risk countries, which HHS/CDC proposed to

define as “countries 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

190CDC. Extension of temporary suspension of dogs entering the United States from countries with a high risk of
rabies. 88 FR 43570 (July 10, 2023): 43570-43581.
low confidence in rabies surveillance systems or dog vaccination programs.” Rather, these

comments were directed solely at the number of countries that are categorized as high-risk, how

the list is compiled, and the criteria used to develop the list. There are over 100 countries

currently on the DMRVV high-risk country list which reflects the fact that rabies is a neglected

tropical disease. Neglected tropical diseases (NTDs) are a diverse group of conditions caused by

a variety of pathogens (including viruses, bacteria, parasites, fungi and toxins) and are associated

with devastating health, social, and economic consequences. NTDs are mainly prevalent among

impoverished communities in tropical areas, although some have a much larger geographical

distribution.191

The robust rabies control programs present in the United States do not exist in many

other countries due to a variety of factors, such as access to veterinary care, sufficient

infrastructure to support adequate vaccination, and lack of veterinarians or animal support staff

trained to vaccinate animals.192 Many DMRVV high-risk countries do not have adequate rabies

surveillance and testing capacity and therefore do not report cases to WOAH even though rabies

is widespread within their country. For example, in 2021 only 35 countries reported rabies case

data to WHO and none reported on the number of suspected cases that underwent testing. Until

countries report complete data routinely, relying on international organizations’ data to make risk

determinations will remain problematic. A lack of rabies surveillance data is more likely to

reflect a poor public health infrastructure for rabies case detection within a country than the

absence of rabies.

CDC evaluates and updates the DMRVV high-risk country list every year and posts the

updated list on CDC’s website by April 1. For this annual country risk assessment, CDC subject

matter experts review publicly available data, including data from international organizations

World health Organization. www.who.int/news-room/fact-sheets/detail/rabies.


191

Wallace RM, Undurraga EA, Blanton JD, Cleaton J, Franka R. Elimination of Dog-Mediated Human Rabies
192

Deaths by 2030: Needs Assessment and Alternatives for Progress Based on Dog Vaccination. Front Vet Sci. 2017
Feb 10;4:9. doi: 10.3389/fvets.2017.00009. PMID: 28239608; PMCID: PMC5300989.
(including the World Health Organization (WHO); the WHO Rabies Bulletin – Europe; the Pan-

American Health Organization, and WOAH); published government reports; scientific

publications; and outbreak report alerts such as ProMED,193 as well as information provided by

national and international rabies experts. HHS/CDC will also review the information and re-

assess a country’s status when presented with additional substantial data to support canine

rabies-free status by a foreign country’s officials. Lastly, CDC has published the criteria for how

it determines a country’s classification as a high-risk, low-risk and DMRVV-free country in a

peer-reviewed journal which is publicly available.194,195

Comment: HHS/CDC received questions asking why HHS/CDC’s DMRVV high-risk

country list differs from those used by other countries, including the European Union.

Response: HHS/CDC notes that it is not unusual for different countries to use different

methods, criteria, or data for determining a country’s rabies risk level. CDC’s list is very similar

and closely aligns with the lists used by the EU, Australia, New Zealand, and Canada. However,

HHS/CDC notes that the entry requirements for dogs from DMRVV high-risk countries differ

significantly for the EU and Australia because those countries having stricter entry requirements

than those outlined in this final rule. CDC’s method for developing the high-risk country list is

described in detail above.

Comment: HHS/CDC received questions asking why CDC’s list of approved laboratories

differs from the laboratories on the EU list. Commenters also noted there were limited or no

laboratories in certain regions of the world, or that shipping samples was cost prohibitive and

challenging. Commenters noted the lack of CDC-approved laboratories in Asia, Africa, and

South America was discriminatory toward U.S. citizens and tourists from those regions.

193 The Program for Monitoring Emerging Diseases (ProMED) is a program of the International Society for
Infectious Diseases and is available at https://promedmail.org/.
194 Henry RE, Blanton JD, Angelo KA, Pieracci EG, Stauffer K, et al. A country classification system to inform

rabies prevention guidelines and treatment. Journal of Travel Medicine, 2022;29(4):taac046. doi:
10.1093/jtm/taac046. PMID: 35348741.
195 Minhaj FS, Bonaparte SC, Boutelle C, Wallace RM. Analysis of available animal testing data to propose peer-

derived quantitative thresholds for determining adequate surveillance capacity for rabies. Scientific Reports 2023;
13: 3986.
Response: CDC acknowledges that there are limited or no laboratories in certain regions

of the world. For this reason, CDC has included the option to quarantine at an ACF if they

cannot obtain a titer for their dog. Prior to 2022, the Nancy Laboratory for Rabies and Wildlife

which is part of the French Agency for Food, Environmental and Occupational Health Safety

(ANSES) conducted the global proficiency testing program for rabies serology laboratories

worldwide. CDC uses the ANSES-approved rabies laboratory list, excluding several laboratories

that have been associated with fraudulent titers resulting in the importation of rabid dogs into

rabies-free countries. Laboratory proficiency testing is an essential tool for helping to ensure that

a laboratory gets its results right. Proficiency testing allows participating laboratories to compare

their results and performance with their peers across the world. It helps to identify testing or

measurement problems. A proficiency testing program is critical to ensure laboratories are

qualified to test samples to ensure the results they produce are valid. In the case of rabies

serology laboratories, it is imperative that an animal that receives a passing titer —which can

suggest that an animal is protected against rabies virus infection — is truly protected from

infection. CDC is working to establish a proficiency testing program to further expand the

current list of CDC-approved laboratories. CDC intends to work with laboratories to enhance

coverage and accessibility.

HHS/CDC will add laboratories that have successfully completed ANSES proficiency

testing (or other CDC-approved proficiency testing equivalent) to the CDC-approved laboratory

list (assuming they have not issued fraudulent titers). Additionally, HHS/CDC recognizes there

are currently three ANSES-approved labs in the United States. Due to the limited availability of

approved laboratories in some countries, CDC strongly encourages U.S. citizens have their dogs

vaccinated against rabies while in the United States before traveling, and submit a titer to a U.S.

laboratory while in the United States to minimize cost and shipping challenges, and ensure U.S.

citizens can return to the United States with their dogs after traveling to a DMRVV high-risk

country for a prolonged period of time (i.e., when their U.S.-issued rabies vaccination may be
expired). HHS/CDC notes that the requirement for titers is a WOAH standard for the

international movement of any dog that has been in a DMRVV high-risk country; therefore,

HHS/CDC disagrees that the final rule is discriminatory toward U.S. citizens and tourists.

Comment: Other commenters asked that HHS/CDC only use the number of cases of

human and dog rabies for a country to determine the DMRVV high-risk list because only

countries that report cases of rabies in humans and/or dogs should be considered high-risk.

Response: HHS/CDC disagrees with this request because many DMRVV high-risk

countries do not have adequate rabies surveillance and testing capacity and therefore do not

report cases to WOAH even though rabies is widespread within their country. For example, in

2021 only 35 countries reported rabies case data to WHO and none reported on the number of

suspected cases that underwent testing. Until countries report complete data routinely, relying on

international organizations’ data to make risk determinations will remain problematic. A lack of

rabies surveillance data is more likely to reflect a poor public health infrastructure for rabies case

detection within a country than the absence of rabies.

As discussed above, there are over 100 countries currently on the DMRVV high-risk

country list which reflects the fact that rabies is a neglected tropical disease.196 The robust rabies

control programs present in the United States do not exist in many other countries due to a

variety of factors, such as access to veterinary care, sufficient infrastructure to support adequate

vaccination, and lack of veterinarians or animal support staff trained to vaccinate animals.197

CDC evaluates and updates the DMRVV high-risk country list every year and posts the updated

list on CDC’s website by April 1. For this annual country risk assessment, CDC subject matter

experts review publicly available data, including data from international organizations (including

the World Health Organization (WHO); the WHO Rabies Bulletin – Europe; the Pan-American

World health Organization. www.who.int/news-room/fact-sheets/detail/rabies.


196

Wallace RM, Undurraga EA, Blanton JD, Cleaton J, Franka R. Elimination of Dog-Mediated Human Rabies
197

Deaths by 2030: Needs Assessment and Alternatives for Progress Based on Dog Vaccination. Front Vet Sci. 2017
Feb 10;4:9. Doi: 10.3389/fvets.2017.00009. PMID: 28239608; PMCID: PMC5300989.
Health Organization, and WOAH); published government reports; scientific publications; and

outbreak report alerts such as ProMED,198 as well as information provided by national and

international rabies experts. CDC has published the criteria for how it determines a countries

classification as a high-risk, low-risk and DMRVV-free country in a peer-reviewed journal

which is publicly available.199,200 HHS/CDC also believes that countries will be more motivated

to share their rabies surveillance data to be removed from the DMRVV high-risk list, which will

result in improved rabies global surveillance.

Comment: Some commenters expressed concerns that sudden changes to the DMRVV

high-risk country list could result in animals being abandoned overseas.

Response: In HHS/CDC’s experience, such concerns are unfounded. Since the inception

of the list in 2018, only one country has been added to the list, which was based on a widespread

outbreak of DMRVV along a porous international border. CDC has, however, removed multiple

countries after they demonstrated improvement in their rabies control programs (moving the

countries from DMRVV high-risk to DMRVV low-risk or DMRVV-free status). Additionally, if

a country were to be added to the DMRVV high-risk country list, CDC would publish the

information on its website and allow for a transition period which would provide importers

sufficient time to come into compliance with new importation requirements for dogs arriving

from that country. HHS/CDC further encourages people intending to travel to the United States

to review the DMRVV high-risk list before traveling and maintain a valid rabies vaccination

record and titer (if required) for the dog they wish to bring into the United States.

Comment: HHS/CDC also received comments that it should not maintain a list or

differentiate between DMRVV-free, DMRVV low-risk and DMRVV high-risk countries because

198 The Program for Monitoring Emerging Diseases (ProMED) is a program of the International Society for
Infectious Diseases and is available at https://promedmail.org/.
199 Henry RE, Blanton JD, Angelo KA, Pieracci EG, Stauffer K, et al. A country classification system to inform

rabies prevention guidelines and treatment. Journal of Travel Medicine, 2022;29(4):taac046. Doi:
10.1093/jtm/taac046. PMID: 35348741.
200 Minhaj FS, Bonaparte SC, Boutelle C, Wallace RM. Analysis of available animal testing data to propose peer-

derived quantitative thresholds for determining adequate surveillance capacity for rabies. Scientific Reports 2023;
13: 3986.
all imported dogs should be subject to the same requirements regardless of the endemicity of

DMRVV within a country. Some comments included statements that any imported dog

potentially poses a public health threat and could threaten the health of the U.S. domestic dog

population.

Response: HHS/CDC appreciates these comments and recognizes there could be

challenges in confirming whether a dog has been only in DMRVV-free or DMRVV low-risk

rabies countries during the six months prior to the dog’s arrival in the United States. HHS/CDC

further acknowledges that some importers have, in the past, moved dogs from DMRVV high-risk

countries to DMRVV-free countries solely to circumvent HHS/CDC entry requirements.

HHS/CDC defines risk based on the dog’s country of origin (or countries the dog has been

present in during the previous six months), the risk of rabies within countries (based on

endemicity and rabies control programs), and the dog’s vaccination status (U.S.- vs. foreign-

vaccinated). Although HHS/CDC acknowledges that holding all imported dogs to one standard

could theoretically reduce the burden of confirming a dog’s country of origin, the final rule does

not adopt this approach because it would be unduly burdensome for importers arriving with dogs

from countries that have demonstrated adequate control of DMRVV.

Comment: HHS/CDC received three comments specific to Ecuador’s inclusion on the

DMRVV high-risk list and one comment specific to Ukraine’s inclusion on the DMRVV high-

risk list.

Response: Ecuador and Ukraine are on the DMRVV high-risk list because they currently

meet HHS/CDC’s criteria for inclusion on the DMRVV high-risk list.

As noted above, CDC evaluates and updates the DMRVV high-risk country list annually

and posts the updated list on CDC’s website by April 1. CDC subject matter experts review

publicly available data, including data from international organizations (including the WHO; the

WHO Rabies Bulletin – Europe; the Pan-American Health Organization, and WOAH); published
government reports; scientific publications; and outbreak report alerts such as ProMED,201 as

well as information provided by national and international rabies experts. HHS/CDC will also

review the information and re-assess a country’s status when presented with additional

substantial data to support canine rabies-free status by a foreign country’s officials. Lastly, CDC

has published the criteria for how it determines a countries classification as a high-risk, low-risk

and DMRVV-free country in a peer-reviewed journal which is publicly available.202,203

HHS/CDC continues to review its list of DMRVV high-risk countries annually and will update

the listed based on available data.

F. Comments relating to the economic impact of the proposed rule.

Comment: HHS/CDC received a number of comments stating the economic impact

analysis underestimated the cost to importers. Some commenters reported facing higher costs

relative to estimates included in the NPRM and provided additional cost information relevant to

the analysis. HHS/CDC received a number of comments around the cost for post-arrival follow-

up at ACF and the costs for transporting dogs as cargo, which is required by some U.S. ports

with ACF.

Response: HHS/CDC considered these comments and notes that it is challenging to

extrapolate costs incurred by some importers to generate the average cost of importation for an

estimated 800,000 dogs per year. HHS/CDC increased the average cost estimate for post-arrival

care at ACF to $900 per dog with a range from $500 to $1,300. These costs depend in part on

how many dogs arrive in a shipment such that if more dogs arrive in a single shipment, the cost

201 The Program for Monitoring Emerging Diseases (ProMED) is a program of the International Society for
Infectious Diseases and is available at https://promedmail.org/.
202 Henry RE, Blanton JD, Angelo KA, Pieracci EG, Stauffer K, et al. A country classification system to inform

rabies prevention guidelines and treatment. Journal of Travel Medicine, 2022;29(4):taac046. Doi:
10.1093/jtm/taac046. PMID: 35348741.
203 Minhaj FS, Bonaparte SC, Boutelle C, Wallace RM. Analysis of available animal testing data to propose peer-

derived quantitative thresholds for determining adequate surveillance capacity for rabies. Scientific Reports 2023;
13: 3986.
per dog would be less. HHS/CDC does not require any dogs to be shipped as cargo; this decision

may be made by some U.S. ports as part of their working relationships with ACF and the CBP

Port Director. HHS/CDC acknowledges that such a requirement would increase costs for some

importers. Both of these costs (ACF prices and need to ship dogs as cargo) would only be

incurred by the subset of foreign-vaccinated dogs imported from DMRVV high-risk countries.

However, the additional costs associated with shipping via cargo would only apply to importers

who would have hand-carried their dogs or checked them as baggage without this requirement

and arrive at a U.S. port with the cargo shipping requirement. The average costs associated with

shipping dogs as cargo are estimated to be $2,000 (range: $1,500 to $2,500) 204 compared to an

average of $300 (range: $200 to $400) for dogs shipped as hand-carried or checked baggage.

Under the regulatory baseline, HHS/CDC assumes 25%, range: 17% to 50% of dogs going to

ACF are shipped as cargo. With the final rule, HHS/CDC assumes that 60%, range: 60% to 70%

of dogs going to ACF will be shipped as cargo. HHS/CDC also increased the cost estimate

associated with the need for importers of foreign-vaccinated dogs from high-risk countries to

arrive at authorized U.S. ports with ACF to a range of between $292 and 984 per dog shipment.

Comment: HHS/CDC received a comment inquiring about the estimated costs incurred by

different categories of importers with the final rule. HHS/CDC received a request to provide

separate cost estimates for deployed Federal employees.

204Feathers and Fur Express (2023) How much does it cost to fly a pet/s internationally? International Pet Shipping
Costs – Feathers & Fur Express (ffexpresspets.com). Accessed November 10, 2023. Note that the costs reported in
this reference include cargo shipping costs to Germany, the United Kingdom, Japan, and Australia. The reference
includes costs for small and large dogs shipped to each country. Costs are much higher for larger dogs or for dogs
shipped over longer distances. The highest costs were for Australia, which may be more representative of shipping
costs from DMRVV high-risk countries in Africa. The European costs may be similar to shipping costs for dogs
imported from DMRVV high-risk countries in Europe or Central America or South America. The costs for Japan
may be similar to costs for DMRVV high-risk countries in Asia. The simple average cost across the four countries
and dog sizes is $1,931 in 2023 USD. This would correspond to $1,622 in 2020 after adjustment with the consumer
price index: CPI Inflation Calculator (bls.gov). The most likely estimate is increased to $2,000 in case the costs to
importers from DMRVV high-risk countries would be higher than for the countries for which data are available.
This increase from $1,600 to $2,000 would also allow some importers to choose to hire shippers to facilitate the
importation process or brokers to support customs clearance. The need to hire shippers may be reduced by the need
to visit CDC-registered ACF, who may be able to review documentation in advance of arrival when reservations are
made.
Response: HHS/CDC does not have a specific cost breakdown per category of importer but

believes that costs would be most impacted by the foreign country from which importers choose

to import dogs and not by the category of importer. The costs to importers would primarily

depend on whether dogs are imported from DMRVV high-risk countries versus DMRVV-free or

low-risk countries and from which specific countries importers choose to import dogs. Even

among dogs imported from DMRVV high-risk countries, the costs would depend on whether the

dog was vaccinated in the United States or vaccinated in a foreign country. The costs to Federal

employees would then depend on whether they are deployed to DMRVV high-risk countries and

whether they had their dogs vaccinated in the United States prior to deploying to the high-risk

DMRVV country. For commercial importers, their costs would depend on which foreign

countries they choose to import dogs. If commercial importers currently import dogs from

DMRVV high-risk countries, their future costs will depend on whether they could shift their

operations to instead import dogs from DMRVV-free or low-risk countries.

The average estimated marginal cost of the final rule to importers of dogs from DMRVV-free

or low-risk countries is $23 per dog (range $7.70 to $48 per dog). In contrast, the average

estimated marginal cost for dogs from DMRVV high-risk countries is $870 per dog (range $260

to $2,400 per dog). These cost estimates are net of the costs estimated under the regulatory

baseline. Among dogs from DMRVV high-risk countries, the costs depend on whether the dog

was vaccinated in the United States (estimated average marginal cost per dog range: $15 to $73

per dog) or another country (estimated average marginal cost per dog range: $910 to $3,800 per

dog). Finally, among foreign-vaccinated dogs from DMRVV high-risk countries, the costs to

importers are likely to vary considerably depending on the country from which dogs would be

imported, which will influence costs associated with obtaining titer tests and shipping costs

(especially for dogs arriving as cargo).

The estimates reported above represent the average cost per dog for each type of dog import

in the first year of implementation. The estimated cost per dog is expected to decrease slightly in
subsequent years depending on the introduction of more HHS/CDC-registered ACF and CDC-

approved laboratories. However, the costs faced by any individual importer may be higher than

these average cost estimates. The most complete data on the countries from which dogs were

imported prior to the temporary suspension is for dogs shipped as cargo. HHS/CDC only has

data for dogs that are imported as cargo. During 2018 through 2020, about 75% of these dogs

arrived from four countries: Ukraine, Colombia, Russia, and China, in order. Almost of half

(47%) of dogs arrived from two countries (Ukraine and Colombia) among dogs imported from

DMRVV high-risk countries as cargo. The dogs imported from these countries may have lower

costs than dogs imported from DMRVV high-risk countries because these countries either have a

CDC-approved laboratory or share a border with a country with an approved laboratory.

In addition, HHS/CDC updated the cost estimates for importers from DMRVV-free or low-

risk countries by accounting for the additional costs associated with being unable to import dogs

younger than six months of age at land borders. The costs associated with the requirement for

proof that a dog has been only in DMRVV low-risk or DMRVV-free countries have increased

because HHS/CDC added more examples of the types of proof required. Each type of document

requires certification by a USDA or foreign official government veterinarian. Examples include:

a) a valid foreign export certificate from a DMRVV-free or DMRVV low-risk country that has

been certified by an official government veterinarian in that country; b) a USDA export

certificate if the certificate is issued to allow the dogs to travel to a DMRVV-free or DMRVV

low-risk country, c) a valid Certification of Foreign Rabies Vaccination and Microchip form if

completed in a DMRVV-free or DMRVV low-risk country, or d) a valid Certification of U.S.-

Issued Rabies Vaccination form. These documents are often required for individuals to travel

internationally with their pets but are not required for travel to Canada or Mexico. These

documents may be used as long as they specify travel to or from the country from which a dog is

imported. Individuals who frequently travel to and from Canada and Mexico (or any other

country) can obtain a valid Certification of U.S.-Issued Rabies Vaccination form, which will
remain valid for multiple trips for up to three years corresponding to the duration of protection

for dog rabies vaccines.

HHS/CDC also accounted for the reduction in costs associated with a dog only needing one

titer test during its lifetime if a dog is imported more than once from a DMRVV high-risk

country and maintains a current rabies vaccination. HHS/CDC also accounted for the reduction

in transportation costs for U.S.-vaccinated dogs imported from DMRVV high-risk countries,

which will no longer have to arrive at U.S. ports with CDC quarantine stations. HHS/CDC did

not revise estimates for titer shipment costs but notes that, per technical instructions being

published in conjunction with this rule, a single titer test will be valid for a dog’s lifetime

(provided the dog remains current with rabies vaccinations). The cost for shipping may be

reduced since importers may obtain the titer test at any time. This change may allow some

importers to pool samples for shipment to HHS/CDC-approved laboratories to reduce their costs.

In general, importers of dogs originating from African countries may face higher costs to

comply with the requirements finalized in this rule because there are fewer HHS/CDC-approved

laboratories on this continent, which would increase the costs for importers to ship samples for

titer testing or require quarantine if a titer test cannot be conducted. However, it is challenging to

extrapolate costs from individual situations to the total costs for imported dogs from DMRVV

high-risk countries because HHS/CDC lacks data on both the total number of dogs imported as

well as the proportion of dogs imported from each DMRVV high-risk country. HHS/CDC

acknowledges that individual importers may face higher costs than those estimated for the

average cost estimates and that importers of foreign-vaccinated dogs from DMRVV high-risk

countries will face higher costs than other importers. This group faces higher costs because the

dogs they import present a greater risk of DMRVV importation and thus require more substantial

and costly measures to mitigate that elevated risk.

HHS/CDC believes the cost per dog estimates presented above would apply to deployed

Federal government employees and that their costs to import dogs would be similar as for other
dog importers within each category (i.e., importers of dogs from DMRVV-free or low-risk

countries, importers of U.S.-vaccinated dogs from DMRVV high-risk countries, or importers of

foreign-vaccinated dogs from DMRVV high-risk countries). Deployed Federal government

employees may be able to reduce their costs by vaccinating their dogs in the United States and

obtaining a Certification of U.S.-issued Rabies Vaccination form prior to departing the United

States. As noted above, the costs for U.S.-vaccinated dogs imported from DMRVV high-risk

countries are much less than for foreign-vaccinated dogs. The Certification of U.S.-issued Rabies

Vaccination form will remain valid for three years after a dog receives a three-year rabies

vaccine in the United States. Dog rescue organizations operating in DMRVV high-risk countries

would face the highest costs assuming all of their dogs would be foreign-vaccinated (and not

U.S.-vaccinated). However, as noted above, the last four dogs imported while infected with

DMRVV were rescue dogs from DMRVV high-risk countries. Thus, this category of importer

likely poses the greatest public health risk.

Comment: HHS/CDC received some comments that the changes proposed in the NPRM and

finalized in this final rule underestimate the costs to airlines. The commenters did not provide

further details regarding which specific costs they believed HHS/CDC had underestimated.

Response: In the NPRM, HHS/CDC attempted to estimate the costs to airlines but lacked

data on the potential costs to airlines for additional document review and to create bills of lading.

HHS/CDC did not receive specific comments requesting refinement of these cost estimates but

understands that airlines may believe the cost estimates are too low. In the NPRM, HHS/CDC

estimated that the costs to airlines for document review and processing would include an

additional five minutes per dog from DMRVV-free or low-risk countries and 15 minutes per dog

from DMRVV high-risk countries. This resulted in an estimate of about $3.2 million (range: $1.3

to $6.6 million) to airlines.

In the analysis in the final rule, CDC increased the estimated costs to airlines by 100% for

dogs imported from DMRVV-free or low-risk countries and by 50% for dogs imported from
DMRVV high-risk countries to account for a number of commenters who suggested that costs to

airlines should be higher than the estimates included in the NPRM analysis. The average cost

corresponds to between $7.12 to $20.42 per dog transported as a result of the provisions of this

final rule. This amount should not significantly impact airlines’ costs to transport dogs on

international flights. On an individual dog basis, the greatest costs would be incurred when dogs

are denied entry to the United States and abandoned by an importer. However, this would only

occur for a small proportion of the dogs transported, and HHS/CDC believes the additional

requirements included in this final rule should reduce the number of dogs denied entry by

requiring airlines to confirm documentation before boarding dogs and by requiring government

certification of rabies vaccination documentation. The use of standardized forms should facilitate

and streamline review of rabies vaccination documentation. This will be the primary new

requirement for U.S.-vaccinated dogs. The review of documentation for foreign-vaccinated dogs

is greater, and CDC will develop guidance to support airlines in reviewing these new

documentation requirements. Further, the final rule will provide stability to requirements relative

to the temporary suspension. Finally, the annual costs to airlines for abandoned dogs was

estimated to be between $42,000 and $650,000 per year. Assuming the number of dogs denied

entry with the final rule is less than under the baseline, the costs to airlines for assuming

responsibility for abandoned dogs should decrease.

Comment: One commenter stated $400,000 is not that much money to conduct a rabies

investigation when HHS/CDC gave $455,151,295 in funding to the State of Kansas, for example,

in fiscal year 2021.

Response: HHS/CDC disagrees with this statement and the characterization of State and local

public health resources. With regard to the example of Kansas, the funding Kansas (and other

states) received from HHS/CDC in 2021 was primarily for COVID-19 response efforts. Kansas
only received $2.1M in core public health funding for 2021205 which means a single imported

rabid dog event could have a substantial adverse impact on the state’s public health budget.

States also have very limited funding dedicated to rabies control and response. In 2023, for

instance, HHS/CDC awarded $200,000 in total to U.S jurisdictions, or approximately $3,500 per

state, for rabies response activities, which is not enough to cover the cost of a typical rabies

investigation. State health departments conduct a multitude of activities with HHS/CDC funds

and the cost associated with a rabid dog investigation are additional costs for which the states do

not receive routine funding. The funding limitations in local jurisdictions can be even more

significant than those at the State level.

Comment: Some commenters suggested that the costs of this final rule exceed the potential

benefits associated with mitigating the risk of DMRVV reintroduction to the United States.

Specially, other commenters suggested that the costs to importers of personal pets were too high

because the four most recent imports of dogs from DMRVV high-risk countries with rabies were

by animal rescues.

Response: HHS/CDC disagrees that the costs of this final rule exceed the potential benefits

or that the final rule is overly burdensome on importers of personal pets. The cost of public

health investigations following the importation of rabid dogs is estimated to be between

$210,000 and $510,000. While this cost is much less than the estimated annualized net cost of

this rule (best estimate: $57 million, range: $12 to $203 million), the main benefit is a significant

reduction in the risk of DMRVV reintroduction in the United States. This is a low-probability,

but high-consequence outcome, which could significantly increase DMRVV costs in the United

States, especially if reintroduction was associated with an increase in human rabies cases. As

noted above, when DMRVV found in Mexico began spreading in U.S. coyote populations, it

spread to wildlife and dogs in Texas where DMRVV had been previously eliminated in dogs.

205CDC Epidemiology and Laboratory Capacity 2021 funding table. Available at: www.cdc.gov/elc/funding/2021-
funding-table.html.
Wildlife and domestic dog vaccination programs were implemented over the period from 1995

through 2003, costing more than $56 million (in 2023 USD) to eliminate the virus; before the

virus was eliminated, two people died from DMRVV.206,207,208 The potential costs and the

number of human rabies cases during a future reintroduction of DMRVV are difficult to predict

in advance and would depend on how the virus would be transmitted to wildlife species and the

contact rates between infected animals and humans.

Malaysia provides a pertinent example of the risks of DMRVV reintroduction. Malaysia

had been declared DMRVV-free, but the virus was reintroduced around 2017. Despite a large

public health response, DMRVV has not yet been eliminated in Malaysia and 45 people have

died after having been infected between 2017 and 2022.209 The probability of DMRVV

reintroduction in the United States is likely to be much less than in Malaysia, which shares a land

border with Indonesia, which is a DMRVV high-risk country. However, the potential risk for the

United States would increase if the U.S. dog rabies vaccination rates were to decrease or if the

number of imported DMRVV-infected dogs from DMRVV high-risk countries were to increase.

The requirements included in this final rule would reduce the risk of importations of DMRVV-

infected dogs.

While the estimated monetized costs of this final rule significantly exceed estimated

monetized benefits, HHS/CDC was not able to monetize the potential benefits associated with

reducing the risk of re-introduction of DMRVV in the United States. This could increase costs

for dogs traveling from the United States to DMRVV-free countries for all dogs leaving the

206 CDC. Human Rabies—Alabama, Tennessee, and Texas, 1994. MMWR 1995; 44(14): 269-272.
207 Sidwa, T., Wilson, P., Moore, G., Oertli, E., Hicks, B., Rohde, R., Johnston, D. (2005). Evaluation of oral rabies
vaccination programs for control of rabies epizootics in coyotes and gray foxes: 1995-2003. Journal of the American
Veterinary Medicine Association, 227(5),785-92. doi: 10.2460/javma.2005.227.785.
208 Sterner, R., Meltzer, M., Shwiff, S., Slate, D. (2009). Tactics and Economics of Wildlife Oral Rabies

Vaccination, Canada and the United States. Emerging Infectious Diseases, 15(8), 1176-1184. doi:
10.3201/eid1508.081061.
209Tuah L., Sabri MSM, Hashim M, Hashim M. (Dec. 8, 2022) Spatial Risk Assessment on Spread of Dog-
Mediated Rabies in Sarawak. SEACFMD Joint EpiNet and LabNet Virtual meeting. https://rr-asia.woah.org/wp-
content/uploads/2022/12/4-seacfmd__mcda-spatial-risk-assessment-on-rabies-in-sarawak.pdf. Accessed November
9, 2023.
United States. This would include dogs that later return to the United States. These costs would

be in addition to any public health response efforts as discussed above when DMRVV was re-

introduced from Mexico to Texas.

HHS/CDC also disagrees that the final rule is overly burdensome on importers of personal

pets considering the enforcement burden involved in attempting to distinguish between different

types of importers. Although it appears that the risks associated with personal pets may be less

than for dogs imported for adoption or resale, HHS/CDC has limited ability to verify which dogs

are imported as personal pets versus which dogs are imported as rescue or for resale because it is

not unusual for importers to misrepresent the reasons why they are importing a dog into the

United States. As discussed above, owners of personal pet dogs who travel from the United

States to a DMRVV high-risk country will incur significantly less cost if they obtain a three-year

vaccine prior to departure and a Certification of U.S.-Issued Rabies Vaccination. This would

reduce costs for some importers of personal pets.

Comment: HHS/CDC received many comments from breeders and breed enthusiasts

reporting that the costs to import dogs from DMRVV-free or low-risk countries would increase

as a result of the six-month age requirement. Other breeders and enthusiasts did not mention an

increase in costs, but suggested the change in regulations would reduce the number of exporters

willing to send dogs to the United States, which would decrease genetic diversity.

Response: HHS/CDC disagrees that costs for breeders and breed enthusiasts importing dogs

from DMRVV-free or low-risk countries will increase as a result of the six-month age

requirement because most breeders should already be complying with this requirement. Breeders

frequently import dogs for resale, rescue, adoption, or transfer of ownership, which are defined

by USDA as commercial importations. USDA regulations already require that commercially

imported dogs be six months or older. In addition, because dogs under six months of age are

sexually immature and cannot be used for breeding, delaying their importation will not
negatively impact their use as breeding animals. Thus, HHS/CDC did not consider this as a

change to the regulatory baseline.

HHS/CDC also believes that the six-month age requirement helps protect the health and

safety of all dog breeds because dogs that are at least six months old or older are better able to

endure the stresses of international travel (e.g., long travel times, temperature fluctuations,

oxygen or altitude changes, and food/water deprivation). The six-month age requirement for

importation will further reduce the burden on Federal and State government agencies of

conducing public health investigations. Any time a dog becomes ill or dies during international

travel, regardless of country of import, Federal and State government agencies must conduct

public health investigations to ensure the animal is not infected with a zoonotic disease that

could be transmitted to people (or did not die from a zoonotic disease). These investigations take

considerable resources away from other public health priorities. Therefore, because the six-

month age requirement helps ensure that dogs are less stressed during international travel and

arrive in a healthier state, the burden on Federal and State government agencies of conducting

public health investigations should be reduced.

While HHS/CDC acknowledges that this comment was specific to dogs from DMRVV-free

countries, HHS/CDC notes that breeders and commercial importers were adept at responding to

changes in import requirements established during the period of the temporary suspension and

that this rule adopts many of those same practices. HHS/CDC believes that the benefits in

improved animal health and public health strongly support this rulemaking.

G. Other Comments
Comment: Some commenters suggested that the proposed rule would result in an increase

in pet abandonment in foreign countries and/or at U.S. ports for dogs that do not meet HHS/CDC

entry requirements.

Response: HHS/CDC disagrees with these commenters. Throughout the temporary

suspension, which has had similar importation requirements in place, HHS/CDC did not
document an increase in pets being abandoned by importers at U.S. ports. HHS/CDC does not

track the number of dogs abandoned in foreign countries. Although HHS/CDC appreciates the

efforts of animal rescue organizations in foreign countries, HHS/CDC’s mandate is the

protection of human lives and prevention of the consequences that the reintroduction of DMRVV

could have on people, pets, and wildlife populations in the United States. Additionally,

HHS/CDC has no reason to believe that the final rule will increase animals abandoned in foreign

countries because it expects importers to adapt to the new regulatory requirements which align

with, but are less burdensome than, WOAH standards. Thus, an exemption is not needed.

Comment: HHS/CDC received comments that the proposed rule seeks to enrich vaccine

and microchip manufactures as well as the ACF, and that ACF fees are too high. One comment

asked, “Who has shares in microchip companies and Rabies vaccine manufacturers?”

Response: HHS/CDC disagrees with this comment. The intent of this rulemaking is to

protect public health—not to enrich private companies. Vaccination is broadly recognized by

international health experts, including the World Health Organization and WOAH, as essential to

the effective prevention and control of rabies.210 Microchips are one of the only ways to confirm

the identity of a dog and match the vaccination and titer documents to the animal presented for

importation. While other permanent identification methods, such as tattoos, do exist, they are

subject to alteration and fading, creating opportunities for importers to falsify documents to

circumvent entry requirements. Microchipping is a key component required for the international

movement of animals, including livestock, zoo animals, wildlife, and pets. It is an international

standard required by other countries for the importation of pets and is also a WOAH standard for

the international movement of dogs, cats, and ferrets. Regarding fees, HHS/CDC does not set

prices charged by privately owned and operated businesses, including manufacturers of vaccines,

microchips, or ACF. Although HHS/CDC acknowledges some costs such as vaccination and

World Health Organization. Prevent Rabies by Vaccination. Available at: www.who.int/activities/vaccinating-


210

against-rabies-to-save-lives.
examination of dogs at the ACF may be higher than those charged by other providers (U.S.

average $86211,212 vs. ACF average $208), it has found that other fees such as those for boarding

(U.S. average $40-$280/night213 vs. ACF average $137/night) are comparable with those charged

by other providers.

Comment: HHS/CDC received 14 comments suggesting that the proposed rule would

make it more difficult for breeders and breed enthusiasts to import rare dog breeds and prevent

inbreeding in U.S. dog populations through the importation of dogs from other countries.

Response: Although HHS/CDC acknowledges that the final rule will result in additional

requirements to import dogs from high-risk countries and will prevent breeders and breed

enthusiasts from importing dogs under six months of age, these difficulties do not outweigh the

benefits to U.S. public health. HHS/CDC believes that, in addition to protecting public health by

ensuring all imported dogs are adequately protected against rabies, the rule will likely better

ensure the health of dogs during international travel and prior to their release into the United

States. As noted above, international travel is stressful for animals and can result in illness and

death in young animals or specialty breeds (e.g., snub-nosed breeds, hairless breeds) that cannot

compensate for the stresses they undergo (length of travel time, temperature fluctuations, oxygen

or altitude changes, food/water deprivation).

As noted above, the six-month age requirement for importation helps protect the health

and safety of all dogs, including rare dog breeds. Since dogs under six months of age are

sexually immature and cannot be used for breeding, delaying their importation will not

negatively impact their use as breeding animals. Additionally, waiting until a dog is six months

of age to import the dog will help ensure the safety and welfare of the dog during international

travel when they are subjected to the stresses of international travel mentioned above (e.g., long

211 Kilroy, A. How much do dog vaccinations cost? March 29,2023. Available at: www.forbes.com/advisor/pet-
insurance/pet-care/how-much-do-dog-vaccinations-cost/.
212 Kilroy, A. How much does a vet visit cost? March 29,2023. Available at: www.forbes.com/advisor/pet-

insurance/pet-care/how-much-does-vet-visit-cost/.
213 Coy, W. How much does dog boarding cost? Available at: www.rover.com/blog/how-much-does-dog-boarding-

cost/.
travel times, temperature fluctuations, oxygen or altitude changes, and food/water deprivation).

Rare dog breeds may be imported under the final rule if they meet entry requirements. Although

HHS/CDC acknowledges that it lacks data to quantify whether specific types of breeds of dogs

imported into the United States will change, HHS/CDC believes that the final rule is not overly

burdensome in regard to dog breeders and breed enthusiasts because the final rule has strong

public health benefits and will help ensure the safety and welfare of dogs engaged in

international travel. Thus, an exemption is not needed.

Comment: HHS/CDC received comments that the final rule will make it harder to travel

abroad with pets.

Response: HHS/CDC does not believe that the final rule is overly burdensome with

regard to individuals traveling abroad with their pets in large part because the rule does not apply

to animals being exported from the United States. Other countries set their own importation

requirements, separate from HHS/CDC’s import requirements. Additionally, HHS/CDC does not

believe travel will be more difficult for importers with U.S.-vaccinated dogs because HHS/CDC

has amended the final rule to allow these importers to enter the United States at any U.S. port,

rather than only at one of the 18 U.S. airports with a CDC quarantine station as proposed in the

NPRM. Therefore, importers who maintain their dog’s valid Certification of U.S.-issued Rabies

Vaccination can easily return to the United States with their dog from any country through any

U.S. port provided their dog is at least six months old, microchipped, and accompanied by a

Certification of U.S.-issued Rabies Vaccination form and a CDC Dog Import Form receipt. Also,

as noted more extensively above, the final rule aligns U.S. importation requirements with

practices in other rabies-free countries while providing significant additional flexibilities relative

to WOAH importation standards to alleviate unnecessary burden on pet owners and importers.
Comment: HHS/CDC received comments stating that the NPRM was unclear and

suggesting that HHS/CDC reorganize the rule into different categories, such as “Family Pets,”

“On-line Sales and/or Commercial Sales,” Service Animals,” and “Cats.”

Response: HHS/CDC declines to reorganize the final rule as suggested by the

commenters because it believes that the final rule is sufficiently clear and that some of the

proposed categories are unneeded and would be more difficult to enforce. HHS/CDC has

determined that the public health risk from dog imports is based primarily on the dog’s country

of origin (high-risk DMRVV countries) and vaccination status (U.S.- vs. foreign-vaccinated) and

has, through this final rule, established different requirements based on these factors.

In CDC’s experience, because importers frequently misrepresent the reasons why a dog is

being imported, CDC cannot reliably ensure that dogs presented as “personal pets” are not being

imported for other reasons, including commercial resale after the dogs have been permitted to

enter the United States. For instance, USDA APHIS Animal Care (AC) currently requires dogs

imported for commercial purposes to apply for and receive a USDA AC dog import permit,

however, over the past several years, USDA, CDC, and CBP have documented hundreds of

instances of commercial importers attempting to avoid USDA entry requirements by

misrepresenting the reasons why dogs are being imported. HHS/CDC also notes that service

animals are subject to the same public health risk as other dogs from DMRVV high-risk

countries and that the final rule already includes a separate provision for service animals entering

through a U.S. seaport. For these reasons, HHS/CDC declines to reorganize the final rule as

suggested in this comment.

Comment: HHS/CDC received a comment that the changes would make the process of

dog importation more confusing, expensive, time consuming, and difficult for people without

financial and educational resources.

Response: HHS/CDC acknowledges that animal transportation can be a confusing and

frustrating process. However, CDC believes the changes it is implementing will reduce
confusion among importers, government officials, airlines, and the animal transportation

industry. For example, with CDC’s implementation of standardized forms certified by official

government veterinarians, CDC will be less likely to deny animals entry due to missing,

incomplete, or fraudulent vaccination forms. Airline staff and CBP officers will no longer have

to search through multiple documents to ascertain whether all required information for a dog is

present for entry into the United States. Instead, a single form can be referenced and used to

streamline the process, avoid confusion, and ensure entry requirements are met. The microchip

requirement will reduce confusion and uncertainty about an animal’s identity and vaccination

history. Having ACF at multiple ports will provide a place for sick or injured pets to receive

prompt veterinary care and will reduce an owner’s stress in those unfortunate circumstances.

HHS/CDC also acknowledges there is an increased cost to importers under the final rule,

however, CDC’s requirements align more closely with WOAH standards, which have already

been implemented by the majority of DMRVV-free countries around the world. The additional

expense associated with international animal travel is not a U.S.-phenomenon due solely to

CDC’s updated final rule, but rather reflects an international commitment by numerous countries

to prevent DMRVV importations through enhanced entry requirements, including

microchipping, certified vaccination records, serologic titers, and quarantine. HHS/CDC notes

that it is limiting costs to importers by not enacting all WOAH standards (as outlined above).

Finally, HHS/CDC plans to engage in a proactive education campaign for importers,

government officials, U.S. and foreign-based veterinarians, airlines, and the animal

transportation industry in order to ensure importers are aware of the new requirements. Many of

the requirements under the final rule were implemented during the temporary suspension and are

therefore, already in place and are general, widespread knowledge. Importers were able to adapt

quickly under the temporary suspension and CDC anticipates the same will be true of the final

rule given the similarities with the requirements already in place through the temporary

suspension.
Comment: HHS/CDC received comments that the proposed requirements infringe on

individuals’ rights and freedoms. The commenter did not specify further which individual rights

and freedoms they believed would be infringed by the final rule.

Response: Because the commenter did not specify further, HHS/CDC assumes that the

commenter meant to refer to due process rights that may be protected by the Fifth and Fourteenth

Amendments to the U.S. Constitution. However, HHS/CDC disagree that the final rule

implicates any rights or interests protected by the Due Process Clause. Where applicable, the

Due Process Clause “imposes procedural constraints on governmental decisions that deprive

individuals of liberty or property interests.” Nozzi v. Hous. Auth. of City of Los Angeles, 806 F.3d

1178, 1190 (9th Cir. 2015). However, “[d]ue process protections extend only to deprivations of

protected interests.” Shinault v. Hawks, 782 F.3d 1053, 1057 (9th Cir. 2015). Because

individuals have no protected property or liberty interest in importing dogs or other animals into

the United States, the final rule does not infringe upon any due process rights protected by the

U.S. Constitution. See Ganadera Ind. V. Block, 727 F.2d 1156, 1160 (D.C. Cir. 1984) (“no

constitutionally-protected right to import into the United States”); see also Arjay Assoc. v. Bush,

891 F.2d. 894, 896 (Fed. Cir. 1989) (“It is beyond cavil that no one has a constitutional right to

conduct foreign commerce in products excluded by Congress.”).

Comment: CDC received a comment stating that “CDC is a quasi-governmental agency,

it's difficult to understand the authority allowed for this proposed rule (and current rules on the

books).”

Response: CDC is a U.S. government agency within HHS. The primary legal authority

supporting this final rule is section 361 of the Public Health Service Act (PHS Act) (42 U.S.C.

264). Under section 361, the Secretary of HHS (Secretary) may make and enforce such

regulations as in the Secretary’s judgment are necessary to prevent the introduction,

transmission, or spread of communicable diseases from foreign countries into the United States

and from one State or possession into any other State or possession. It also authorizes the
Secretary to promulgate and enforce a variety of public health regulations to prevent the spread

of communicable diseases, including through inspection, fumigation, disinfection, sanitation,

pest extermination, destruction of animals or articles found to be sources of dangerous infection

to human beings, and other measures. Since at least 1956, Federal quarantine regulations

(currently found at 42 CFR 71.51) have controlled the entry of dogs and cats into the United

States.

In addition to section 361, other sections of the PHS Act relevant to this final rule are

section 362 (42 U.S.C. 265), section 365 (42 U.S.C. 268), section 367 (42 U.S.C. 270), and

section 368 (42 U.S.C. 271). Section 362, among other things, authorizes the Secretary to

promulgate regulations prohibiting, in whole or in part, the introduction of property from foreign

countries or places, for such period of time and as necessary for such purpose, to avert the

serious danger of introducing communicable disease into the United States.

Comment: HHS/CDC received several comments that proposed CDC issue fines or

citations against importers who violate U.S. entry requirements, present fraudulent

documentation, or import rabid dogs.

Response: HHS/CDC appreciates this comment, but notes that it must rely on other U.S.

Federal agencies, such as the U.S. Department of Justice, to seek criminal penalties for

individuals who violate quarantine regulations, including those relating to the importation of

dogs into the United States. Under section 368 of the PHS Act (42 U.S.C. 271) any person who

violates regulations implementing sections 361 (42 U.S.C. 264) or 362 (42 U.S.C. 265) is subject

to imprisonment of not more than one year, a fine, or both. Pursuant to 18 U.S.C. 3559 and 3571,

an individual may face a fine of up to $100,000 for a violation not resulting in death and up to

$250,000 for a violation resulting in death. Because these penalties are criminal in nature, to

implement section 368, HHS/CDC would refer potential violators to the U.S. Department of

Justice for criminal prosecution.


Through this final rule, HHS/CDC is also including new language advising individuals

and organizations that it may request that DHS/CBP take additional action pursuant to 19 U.S.C.

1592 and 19 U.S.C. 1595a. Specifically, CDC may request that DHS/CBP issue additional fines,

citations, or penalties to importers, brokers, or carriers whenever the CDC Director (Director)

has reason to believe that an importer, broker, or carrier has violated any of the provisions of this

section or otherwise engaged in conduct contrary to law. HHS/CDC stresses that it does not

administer Title 19, and decisions regarding whether to issue such fines, citations, or other

penalties would be entirely at the discretion of DHS/CBP and subject to its policies and

procedures. Notwithstanding, HHS/CDC believes it important to include this language to advise

individuals and organizations that it may request that DHS/CBP pursue such actions.

Comment: HHS/CDC received comments that funding should not be spent implementing

the provisions in this final rule as well as comments that the final rule will increase CDC costs

and require additional staff. Another comment stated, “I do not see the CDC having staff to

coordinate this quarantine process and how will it be funded? This seems like tax payers will pay

the burden.”

Response: This final rule implements an importation system relying on a network of

privately operating ACF for the examination, revaccination, and quarantine (if necessary) of

foreign-vaccinated dogs from DMRVV high-risk countries. During the temporary suspension,

CDC was issuing CDC Dog Import Permits for foreign-vaccinated dogs from DMRVV high-risk

countries. Issuing permits required costs to CDC in the form of personnel and IT services. By

replacing the permitting system for foreign-vaccinated dogs from DMRVV high-risk countries

with a system of ACF, CDC anticipates a reduction in costs and staff time associated with dog

importation. CDC will not bear any costs for quarantining dogs. The costs of examination,

revaccination, and quarantine at ACF will be paid for by the importer.


Comment: HHS/CDC also received comments suggesting that HHS/CDC should spay

and neuter animals or consider spaying and neutering animals in lieu of euthanizing animals.

Response: The final rule also contains no requirements relating to imported animals being

spayed or neutered because HHS/CDC does not typically regulate the control of animal

populations. HHS/CDC reiterates that the rule does not require that animals be euthanized if they

do not meet HHS/CDC import requirements. If an animal is not fit to travel, poses a public

health risk, or would pose a risk to other animals, then the carrier must arrange for the animal to

be transported to an ACF or a CDC-approved veterinary clinic (if an ACF is not available) for

either housing and treatment by a licensed veterinarian until approved by CDC for entry or

denied entry to the United States and returned to its country of departure. If the veterinarian

recommends humane euthanasia (e.g., under circumstances where the animal is fatally ill or

injured), or if this option is chosen by the importer or carrier, then the animal must be euthanized

by a U.S.-licensed veterinarian in accordance with American Veterinary Medical Association

guidelines. Under these circumstances, the decision to euthanize an animal is made by the

animal’s custodian (i.e., the importer or the carrier if the importer abandons the animal) and not

HHS/CDC.

Comment: HHS/CDC received 29 comments stating support for “Option 2.” HHS/CDC

believes “Option 2” referred to Table 4 in the NPRM, which is a “Summary Table of Important

Changes to Regulatory Requirements Based on the Provisions of this NPRM and Alternatives

Considered.” Option 2 is described as the less restrictive option and included no age requirement,

no certification of rabies vaccination forms, acceptance of titers from any lab, follow-up

vaccination performed by local veterinarian in the United States, and no port of entry restrictions.

Response: HHS/CDC disagrees with the request to adopt components of “Option 2” with

the exception of providing additional flexibility regarding the ports of entry at which U.S.-

vaccinated dogs may arrive in the United States. This final rule allows U.S-vaccinated dogs from

DMRVV high-risk countries to enter at any U.S. port instead of only arriving via air at a U.S.
airport with a CDC quarantine station as proposed in the NPRM. HHS/CDC addresses the

justification for each of the remaining requirements outlined in Table 1. Additional details on the

costs the lower cost and higher cost alternatives is provided in section (VIIA: Required

Regulatory Analyses).

VII. Required Regulatory Analyses

A. Executive Orders 12866, 13563, and 14094

Under Executive Order 12866 (EO 12866), Regulatory Planning and Review (58 FR

51735, October 4, 1993), HHS/CDC is required to determine whether this regulatory action

would be “significant” and therefore subject to review by the Office of Management and Budget

(OMB) and the requirements of the Executive Order. EO 12866, as amended by Executive Order

14094, defines “significant regulatory action” as an action that is likely to result in a rule:

• Having an annual effect on the economy of $200 million or more (adjusted every 3 years

by the Administrator of OIRA for changes in gross domestic product), or adversely affect

in a material way the economy, a sector of the economy, productivity, competition, jobs,

the environment, public health or safety, or State, local, territorial, or Tribal governments

or communities;

• Creating a serious inconsistency or otherwise interfere with an action taken or planned by

another agency;

• Materially altering the budgetary impact of entitlements, grants, user fees, or loan

programs or the rights and obligations of recipients thereof; or

• Raising legal or policy issues for which centralized review would meaningfully further

the President’s priorities, or the principles set forth in EO 12866, as specifically

authorized in a timely manner by the Administrator of OIRA in each case.

OMB’s Office of Information and Regulatory Affairs has determined that this rulemaking is

“significant” under EO 12866.


The provisions of this rule are not likely to have an annual effect on the economy of $200

million or more, although there is considerable uncertainty around the number of dogs imported

at baseline, including the number of dogs imported from DMRVV high-risk countries.

HHS/CDC conducted an analysis to estimate the costs and benefits of the provisions of this rule

relative to a regulatory baseline without any change in requirements. HHS/CDC also reports the

costs and benefits of the set of lower-cost alternatives and higher-cost alternatives relative to the

same regulatory baseline. HHS/CDC requested public comment on costs associated with these

changes to importers, airlines, and State and local health departments to improve the accuracy of

cost and benefit estimates. More details on the assumptions used to develop this analysis are

included in an Appendix found in the Supplemental Materials tab of the docket.

The economic regulatory baseline is based on the provisions included in the existing 42

CFR 71.51. The baseline analysis does not incorporate the impact of the temporary suspension of

dogs imported from DMRVV high-risk countries that has been in effect since July 14, 2021.214

The economic baseline does not account for the temporary suspension but does account for a

change to the definition of DMRVV-free country published in 2019.215 This baseline is used as a

comparator to assess the impact of the provisions of the final rule. The summary of the

regulatory baseline is defined further in Appendix Section A3 found in the Supplemental

Materials tab of the docket.

The rule addresses the market inefficiency in which dog importers do not consider or bear

the potential detrimental impacts to the public’s health that may result from the importation of ill

dogs, especially dogs infected with DMRVV. At the societal level, this could include the

214 On June 14, 2021, CDC published the “Notice of Temporary Suspension of Dogs Entering the United States
from High-Risk Rabies Countries.” Through that notice, CDC informed the public that, effective July 14, 2021, it
was temporarily suspending the importation of dogs from: countries classified by CDC as having high risk for
DMRVV; AND countries that are NOT at high risk if the dogs have been in high-risk countries during the previous
six months. See 86 FR 32041 (June 16, 2021). The suspension was extended effective June 10, 2022. See 87 FR
33158 (June 1, 2022).
215 HHS/CDC. Guidance Regarding Agency Interpretation of “Rabies-Free” as It Relates to the Importation of Dogs

Into the United States. 84 FR 724 (Jan. 31, 2019).


reintroduction of DMRVV into the United States. Regulation at the Federal level is necessary to

address the public health risk of infectious diseases from the importation of ill or unhealthy dogs.

Federal action allows risks to be addressed and mitigated prior to dogs’ arrival in the United

States. The rule is expected to affect the following categories of interested parties and

implementing partners:

• Importers of dogs from countries that are DMRVV-free or at low risk for DMRVV;

• Importers of dogs from countries that are at high risk of DMRVV;

• Airlines and other carriers;

• CBP;

• CDC;

• USDA; and

• State and local public health and animal health departments.

As discussed above, the rule incorporates different requirements depending on whether

dogs are imported from DMRVV high-risk countries compared to countries that are DMRVV-

free or DMRVV low-risk. Requirements for dogs from DMRVV high-risk countries are further

differentiated depending on whether imported dogs have received their rabies vaccines in the

United States or in another country. Foreign-vaccinated dogs imported from DMRVV high-risk

countries would have to arrive at one of currently six airports with a CDC-registered Animal

Care Facility. Importers of foreign-vaccinated dogs from DMRVV high-risk countries would

make reservations prior to arrival with a CDC-registered ACF for a veterinary examination and

revaccination. As part of the entry requirements, importers would either agree to a 28-day post-

arrival quarantine period for the dog or prior to arrival submit samples of the dog’s blood to a

CDC-approved laboratory for serologic testing at a time interval specified in CDC technical

instructions to demonstrate immunity to rabies virus. CDC assumes that most importers would

choose serologic testing in lieu of the quarantine period. All importers of dogs from DMRVV
high-risk countries need a Certification of Foreign Rabies Vaccination and Microchip form or

Certification of U.S.-issued Rabies Vaccination form, which require certification by an Official

Government Veterinarian in the country of origin or a USDA Official Veterinarian, respectively.

However, dogs imported from DMRVV-free or DMRVV low-risk countries and importers of

U.S.-vaccinated dogs from DMRVV high-risk countries do not require examination at CDC-

registered Animal Care Facilities and are eligible to arrive at any U.S. port.

In lieu of the Certification of Foreign Rabies Vaccination and Microchip form or

Certification of U.S.-issued Rabies Vaccination form, importers may provide documentation that

the dogs have been only in DMRVV-free or DMRVV low-risk countries during the six months

prior to arriving in the United States (i.e., to demonstrate the dog had not been in a high-risk

country). This documentation must be certified by an official government veterinarian, but many

importers must already obtain a foreign export certificate from a DMRVV-free or DMRVV low-

risk country that has been certified by an official government veterinarian in that country prior to

importing dogs into the United States. In addition, importers who make multiple trips to and

from the United States (e.g., across land borders) may use the Certification of U.S.-issued Rabies

Vaccination form for U.S.-vaccinated dogs, which will remain valid for three years after a dog

receives a three-year rabies vaccine in the United States. Thus, the additional costs will only be

incurred for a subset of dogs imported from DMRVV-free or low-risk countries.

All dog imports arriving on aircraft conveyances, regardless of whether they arrive from

countries that are DMRVV-free or at low- or high-risk for DMRVV, are subject to a six-month

minimum age requirement. In addition, all dogs, other than those in transit, need to be implanted

with microchips for identification purposes. All dogs, regardless of country of origin, must be

listed on a bill of lading or CDC-approved alternative by the airline, if entering the U.S. via air.

All importers of dogs arriving at an air, land, or seaport must submit a CDC Dog Import Form to

CDC via a CDC-approved system prior to the dog’s departure from the foreign country. The
form must be presented to the airline or other carrier prior to boarding and to Federal officials

upon arrival in the United States.

The annualized and present value estimates of monetized costs and benefits over the 10-

year period from 2024 through 2033 using three percent and seven percent discount rates are

summarized in Tables 2 and 3. The annualized, monetized costs (2020 USD) of the provisions in

the final rule are estimated to be $59 million (range: $13 to $207 million) using a three percent

discount rate, and the results were almost unchanged using a seven percent discount rate. Most

monetized costs are expected to be incurred by importers (87 percent for the most likely

estimate). The estimated monetized costs are expected to be less for importers of dogs from

DMRVV-free or DMRVV low-risk countries compared to importers of dogs from DMRVV

high-risk countries. The provisions estimated to result in the greatest increase in costs for

importers of dogs imported from DMRVV-free or low-risk countries were associated with the

additional costs associated with the documentation requirements to show that the dogs have not

been in a DMRVV high-risk country, minimum age, and with the microchip requirements, and

completing the new CDC Dog Import Form.

The provisions estimated to result in the greatest increase in costs for importers of dogs

from DMRVV high-risk countries were associated with the requirements regarding use of a

CDC-registered Animal Care Facility for foreign-vaccinated dogs from DMRVV high-risk

countries in section 71.51(k). Other costs included: 1) laboratory testing, 2) an expected

reduction in the number of dogs imported from DMRVV high-risk countries, 3) the need for

some travelers to reroute travel to an airport with a CDC quarantine station (also known as a

CDC port health station) and CDC-registered Animal Care Facility, and 4) the costs with

providing a CDC Import Certification of Rabies Vaccination and Microchip Record form or

Certification of U.S.-issued Rabies Vaccination form (certified by an Official Government

Veterinarian or USDA Official Veterinarian, respectively). Most of these requirements are

specific to foreign-vaccinated dogs from DMRVV high-risk countries.


Airlines are expected to incur the greatest costs among carriers and their costs are

estimated to comprise about 7.0 percent of the estimated annualized, monetized costs, with most

of their costs associated with ensuring that all transported dogs comply with the bill of lading or

CDC-approved alternative requirements of the final rule and a reduction in the number of dogs

transported. HHS/CDC was unable to estimate costs from other types of carriers of dogs arriving

by land or sea. Specifically, CDC does not have any data on how the six-month age requirement

may impact surface transportation conveyances importing dogs from Canada or Mexico

(although CDC notes that importation of dogs less than six months of age for resale is already

prohibited by USDA regulations). CDC is estimated to incur about 3.3 percent of the annualized,

monetized costs (most likely estimate) associated with the provisions of this final rule. Most

CDC costs would be associated with the oversight of animal care facilities and laboratory

proficiency testing programs for dogs imported from high-risk countries. CBP is expected to

incur about 3.0 percent of the annualized costs (most likely estimate) associated with the

provisions of this final rule. Most CBP costs would result from the additional time spent on

reviewing documentation for importers of dogs from DMRVV-free or low-risk countries and for

training personnel to enforce the requirements. USDA is expected to receive payments

commensurate with its cost to provide Certification of U.S.-issued Rabies Vaccination forms for

U.S.-vaccinated dogs traveling internationally.

The annualized monetized benefits of the provisions in the final rule are estimated to be

about $1.8 million (range: $0.75 to $3.6 million) using a three percent or seven percent discount

rate, with most of the benefits accruing to importers (47 percent of the most likely estimates) and

to CBP (30 percent of the most likely estimates). Some of the benefits estimated for both

importers and CBP would result from reduced time spent on screening dogs from high-risk

countries at U.S. ports. The amount of time required per dog at U.S. ports would be reduced

because it is assumed that the CDC standardized vaccination forms would be easier to review

compared to non-standardized documentation for dogs arriving from DMRVV high-risk


countries. The provisions in this final rule are also estimated to reduce the number of dogs

denied entry or arriving ill or dead, with benefits estimates for importers, airlines, CBP, and

CDC.

The wide range between the lower-bound and upper-bound cost and benefit estimates

demonstrates that there is considerable uncertainty in these results. More details on the input

parameters and assumptions used to generate these estimates may be found in the Appendix

under the Supplemental Materials tab of the docket. At present, the number of dogs imported

into the United States is neither accurately nor completely tracked by any data system, and the

uncertainty in the cost and benefit estimates reflect uncertainty in both the total number of dogs

imported and the number of dogs imported from DMRVV high-risk countries, as well as the cost

of the new requirements included in the final rule. The net annualized, monetized costs (total

cost estimate – total benefit estimate) are estimated to be about $57 million per year (range: $12

to $203 million) using a three percent discount rate.

Since the estimated costs for foreign-vaccinated dogs from DMRVV high-risk countries are

much higher than costs for other dog imports, importers may choose to import dogs from

DMRVV-free or low-risk countries instead of from DMRVV high-risk countries. In addition,

individuals who travel from the United States to DMRVV high-risk countries with their pet dogs

for long-term visits may take the additional step to have their dogs revaccinated with a three-year

rabies vaccine prior to departure (e.g., many deployed Federal employees may obtain the

Certification of U.S.-issued Rabies Vaccination, which would allow up to three years for return

to the United States). These changes should result in lower overall costs than the above estimates
for the final rule in which HHS/CDC assumed individuals would be unable to change the

countries from which dogs are imported into the United States.

Table 2. Annualized, monetized costs and benefits summary table (in 2020
million dollars, over a 10-year time horizon relative to baseline, three Source (RIA
percent or seven percent discount rate) Section)

Most Likely
Estimate Lower bound Upper bound
Annualized, monetized benefits (reduced costs)
Three percent discount rate
Importer benefits $0.84 $0.36 $1.7 B2, B3, B4
Airline benefits $0.18 $0.038 $0.59 B5
DHS/CBP benefits $0.54 $0.26 $0.70 B6
HHS/CDC benefits $0.22 $0.090 $0.59 B7
State and local health
department benefits $0.005 $0.0 $0.022 B8
Total benefits (A1) $1.8 $0.75 $3.6

Seven percent discount rate


Importer benefits $0.84 $0.36 $1.7 B2, B3, B4
Airline benefits $0.18 $0.038 $0.59 B5
DHS/CBP benefits $0.54 $0.26 $0.70 B6
HHS/CDC benefits $0.22 $0.09 $0.59 B7
State and local health
department benefits $0.005 $0 $0.022 B8

Total benefits (A2) $1.8 $0.75 $3.6


Quantified, but The social cost of the consequences associated
unmonetized, benefits with a dog imported while infected with
DMRVV were estimated to be about $270,000,
ranging from $210,000 to $510,000. The
requirements in the final rule reduce the risk of
imported dogs arriving with DMRVV, and the
costs associated with rabies response activities
will decrease. C1
Qualitative With each importation of a dog infected with
(unquantified) benefits DMRVV, there is a risk that a person may
become infected and die or that DMRVV may be
re-introduced in the U.S. wildlife population,
which could dramatically increase costs relative
to the public health response cost summarized
above. In addition, by obtaining high-quality
data on the number of dogs imported by country,
CDC and other Federal agencies, including
USDA, will improve preparedness for outbreaks
of new and emerging infectious disease threats to D1
Table 2. Annualized, monetized costs and benefits summary table (in 2020
million dollars, over a 10-year time horizon relative to baseline, three Source (RIA
percent or seven percent discount rate) Section)

Most Likely
Estimate Lower bound Upper bound
humans (e.g., DMRVV) and animals (e.g.,
African swine fever). The provisions of the final
rule will also ensure that dogs that are denied
entry or arrive ill will receive the care needed to
protect their health and safety.
Annualized, monetized costs
Three percent discount rate
Importer costs $51.0 $9.2 $193.2 B2, B3, B4
Airline costs $4.1 $1.8 $8.0 B5
DHS/CBP costs $1.7 $0.75 $2.9 B6
HHS/CDC costs $1.9 $1.4 $2.5 B7
Total costs (B1) $58.8 $13.1 $206.6

Seven percent discount rate


Importer costs $51.4 $9.3 $194.5 B2, B3, B4
Airline costs $4.1 $1.8 $8.0 B5
DHS/CBP costs $1.8 $0.76 $3.0 B6
HHS/CDC costs $2.0 $1.4 $2.6 B7

Total costs (B2) $59.2 $13.2 $208.1

Quantified, but
unmonetized, costs Not applicable C2
Qualitative CDC will monitor countries and may suspend
(unquantified) costs entry of dogs from countries with repeated
instances of dogs with falsified or fraudulent
rabies vaccination documentation. The lost value
of these imports would impact some U.S.
businesses and dog purchasers. In addition, the
duration of any suspensions for these countries is
highly uncertain and may be ended in the event
of improvement of those countries' dog export
controls. Under the final rule, CDC may issue
orders to revoke a carrier’s or importer’s
permission to transport live dogs and cats if
either has endangered the public’s health;
however, CDC does not have any plans to
suspend any carriers or importers at this time.
Owners of dogs that undergo a 28-day
quarantine period may suffer qualitative costs
from being separated from their dogs during
quarantine. D2
Net annualized costs
Table 2. Annualized, monetized costs and benefits summary table (in 2020
million dollars, over a 10-year time horizon relative to baseline, three Source (RIA
percent or seven percent discount rate) Section)

Most Likely
Estimate Lower bound Upper bound
Total (three percent
discount rate), (B1) -
(A1) $57.0 $12.3 $203.0
Total (seven percent
discount rate), (B2) -
(A2) $57.4 $12.5 $204.5

The present value of the estimated monetized cost over a 10-year period for the

provisions in the final rule is estimated to be $502 million (range: $111 to $1,750 million) using

a three percent discount or $416 million (range: $91 to $1,450 million) using a seven percent

discount rate. The present value of monetized benefits over a 10-year period of the provisions in

the final rule is estimated at $15 million (range: $6.4 to $30 million) using a three percent

discount rate or $13 million (range: $5.2 to $25 million) using a seven percent discount rate. The

net annualized monetized cost (total costs – total benefits) is estimated at $486 million (range:

$104 to $1,720 million) using a three percent discount rate and $403 million per year (range: $86

to $1,430 million) using a seven percent discount rate.

Table 3. Present value of costs and benefits summary table (in 2020 million dollars, over a
10-year time horizon relative to baseline, three percent or seven percent discount rate)

Most Likely Source (RIA


Estimate Lower bound Upper bound Section)
Present value of monetized benefits (reduced costs)
Three percent discount rate
Importer benefits $7.2 $3.1 $14 B2, B3, B4
Airline benefits $1.5 $0.32 $5.0 B5
DHS/CBP benefits $4.6 $2.2 $5.9 B6
HHS/CDC benefits $1.9 $0.77 $5.0 B7
State and local health
department benefits $0.042 $0.0 $0.19 B8
Total benefits (A1) $15 $6.4 $30
Seven percent discount rate
Importer benefits $5.9 $2.5 $12 B2, B3, B4
Table 3. Present value of costs and benefits summary table (in 2020 million dollars, over a
10-year time horizon relative to baseline, three percent or seven percent discount rate)

Most Likely Source (RIA


Estimate Lower bound Upper bound Section)
Airline benefits $1.2 $0.27 $4.1 B5
DHS/CBP benefits $3.8 $1.8 $4.9 B6
HHS/CDC benefits $1.6 $0.63 $4.1 B7
State and local health
department benefits $0.034 $0.0 $0.16 B8
Total benefits (A2) $13 $5.2 $25
Quantified, but The social cost of the consequences associated
unmonetized, benefits with a dog imported while infected with DMRVV
were estimated to be about $270,000, ranging from
$210,000 to $510,000. The requirements in the
final rule reduce the risk of imported dogs arriving
with DMRVV, and the costs associated with rabies
response activities will decrease. C1
Qualitative With each importation of a dog infected with
(unquantified) benefits DMRVV, there is a risk that a person may become
infected and die or that DMRVV may be re-
introduced in the U.S. wildlife population, which
could dramatically increase costs relative to the
public health response cost summarized above. In
addition, by obtaining high-quality data on the
number of dogs imported by country, CDC and
other Federal agencies, including USDA, will
improve preparedness for outbreaks of new and
emerging infectious disease threats to humans
(e.g., DMRVV) and animals (e.g., African swine
fever). The provisions of the final rule will also
ensure that dogs that are denied entry or arrive ill
will receive the care needed to protect their health
and safety. D1
Present value of monetized costs
three percent discount rate
Importer costs $435 $78 $1,648 B2, B3, B4
Airline costs $35 $15 $64 B5
DHS/CBP costs $14.9 $6.2 $24.1 B6
CDC costs $17 $11 $18 B7
Total costs (B1) $502 $111 $1,754

Seven percent discount rate


Importer costs $361 $65 $1,366 B2, B3, B4
Airline costs $29 $12 $50 B5
DHS/CBP costs $12.4 $5.0 $19.4 B6
CDC costs $14 $9 $14 B7
Table 3. Present value of costs and benefits summary table (in 2020 million dollars, over a
10-year time horizon relative to baseline, three percent or seven percent discount rate)

Most Likely Source (RIA


Estimate Lower bound Upper bound Section)

Total costs (B2) $416 $91 $1,450

Quantified, but
unmonetized, costs Not applicable C2
Qualitative CDC will monitor countries and may suspend
(unquantified) costs entry of dogs from countries with repeated
instances of dogs with falsified or fraudulent
vaccine credentials or invalid rabies vaccination
documentation. The lost value of these imports
would impact some U.S. businesses and dog
purchasers. In addition, the duration of any
suspensions for these countries is highly uncertain
and may be ended in the event of improvement of
those countries' dog export controls. Under the
final rule, CDC may issue orders to revoke a
carrier’s or importer’s permission to transport live
dogs and cats if either has endangered the public’s
health; however, CDC does not have any plans to
suspend any carriers or importers at this time.
Owners of dogs that undergo a 28-day quarantine
period may suffer qualitative costs from being
separated from their dogs during quarantine. D2
Net annualized costs
Total (three percent
discount rate), (B1) -
(A1) $486 $104 $1,723
Total (seven percent
discount rate), (B2) -
(A2) $403 $86 $1,426

As discussed in the response to public comments section of the preamble above, the

estimated monetized cost estimate has increased considerably relative to the estimates included

in the NPRM. The primary reasons for the increase in cost include:

• The fees charged by CDC-registered ACF have increased relative to CDC’s

preliminary estimates.
• Some U.S. ports require that dogs that need follow-up care at CDC-registered

ACF arrive as cargo. This requirement was not anticipated by CDC and will

increase costs for importers of foreign-vaccinated dogs from DMRVV high-risk

countries who otherwise would have chosen to transport their dogs as hand-

carried or checked baggage. The fee charged for cargo shipments are highly

variable.216,217 The future costs associated with this rule will depend on U.S. port

policies that are subject to change. The average cost for the follow up visit at

CDC-registered ACF is estimated to be $900 (range: $500 to $1,300 per dog).

The average costs associated with shipping dogs as cargo is estimated to be

$2,000 (range: $1,500 to $2,500) 218 compared to an average of $300 (range:

$200 to $400) for dogs shipped as hand-carried or checked baggage219. Under the

regulatory baseline, HHS/CDC assumes 25%, range: 17% to 50% of dogs going

to ACF are shipped as cargo. With the final rule, HHS/CDC assumes that 60%,

range: 60% to 70% of dogs going to ACF will be shipped as cargo.

• The costs associated with the requirement for proof that a dog has been only in

DMRVV low-risk or DMRVV-free countries have increased because HHS/CDC

216 http://www.airline-pet-policies.com/united-airlines-pet-policy.php. Accessed 15 Nov 2023.


217 Katie Morrell (March 3, 2021) How Much Does It Cost To Fly With Your Dog on a Plane? Dailypaws.com
https://www.dailypaws.com/living-with-pets/pet-travel/how-much-does-it-cost-to-fly-a-dog-on-a-plane. Accessed:
06 February 2022.
218 Feathers and Fur Express (2023) How much does it cost to fly a pet/s internationally? International Pet Shipping

Costs - Feathers & Fur Express (ffexpresspets.com). Accessed November 10, 2023. Note that the costs reported in
this reference include cargo shipping costs to Germany, the United Kingdom, Japan, and Australia. The reference
includes costs for small and large dogs shipped to each country. Costs are much higher for larger dogs or for dogs
shipped over longer distances. The highest costs were for Australia, which may be more representative of shipping
costs from DMRVV high-risk countries in Africa. The European costs may be similar to shipping costs for dogs
imported from DMRVV high-risk countries in Europe or Central America or South America. The costs for Japan
may be similar to costs for DMRVV high-risk countries in Asia. The simple average cost across the four countries
and dog sizes is $1,931 in 2023 USD. This would correspond to $1,622 in 2020 after adjustment with the consumer
price index: CPI Inflation Calculator (bls.gov). The most likely estimate is increased to $2,000 in case the costs to
importers from DMRVV high-risk countries would be higher than for the countries for which data are available.
This increase from $1,600 to $2,000 would also allow some importers to choose to hire shippers to facilitate the
importation process or brokers to support customs clearance. The need to hire shippers may be reduced by the need
to visit CDC-registered ACF, who may be able to review documentation in advance of arrival when reservations are
made.
219 http://www.airline-pet-policies.com/united-airlines-pet-policy.php. Accessed 15 Nov 2023.
added more examples of the types of proof required. Each type of document

requires certification by a USDA or foreign official government veterinarian.

Examples include: a) a valid foreign export certificate from a DMRVV-free or

DMRVV low-risk country that has been certified by an official government

veterinarian in that country; b) a USDA export certificate if the certificate is

issued to allow the dogs to travel to a DMRVV-free or DMRVV low-risk country,

c) a valid Certification of Foreign Rabies Vaccination and Microchip form if

completed in a DMRVV-free or DMRVV low-risk country, or d) a valid

Certification of U.S.-Issued Rabies Vaccination form. These documents are often

required for individuals to travel internationally with their pets but are not

required for travel to Canada or Mexico. These documents may be used as long as

they specify travel to or from the country from which a dog is imported.

Individuals who frequently travel to and from Canada and Mexico (or any other

country) can obtain a valid Certification of U.S.-Issued Rabies Vaccination form,

which will remain valid for multiple trips for up to three years corresponding to

the duration of protection for dog rabies vaccines.

• The cost estimate for foreign-vaccinated dogs from DMRVV high-risk countries

to re-route travel destinations to arrive at authorized U.S. ports with ACF was

increased.

• CDC increased the estimated costs associated with shipping blood samples to

CDC-approved laboratories for serological testing based on a number of

comments from individuals suggesting their shipping costs were higher.

• CDC changed the requirement for importing dogs from DMRVV-free or low-risk

countries such that no dogs less than six months may be imported at land borders.

This will increase costs for individuals who wish to travel with their young dogs

to or from Canada and Mexico.


• CDC increased the estimated costs to airlines by 100% for dogs imported from

DMRVV-free or low-risk countries and by 50% for dogs imported from DMRVV

high-risk countries to account for a number of commenters who suggested that

costs to airlines should be higher than the estimates included in the NPRM

analysis.

Some of the cost estimates for the final rule have also decreased due to changes made

between the NPRM and the final rule. These include:

• The costs to importers of U.S.-vaccinated dogs from DMRVV high-risk countries were

reduced because the final rule will not require that such dogs arrive at U.S. ports with

CDC quarantine stations (also known as CDC port health stations).

• The costs for serological testing for foreign-vaccinated dogs from DMRVV high-risk

countries were reduced because CDC plans to implement a policy that only one

serological test will be required during the lifetime of such dogs as long as they remain

current with their rabies vaccinations.

The most significant increase in estimated costs is for importers of foreign-vaccinated

dogs from high-risk countries, because the expected fees charged by CDC-registered ACF have

increased and because some U.S. ports or ACF now require dogs who need to visit to CDC-

registered ACF to be shipped as cargo. HHS/CDC did not anticipate that some U.S. ports would

require that dogs going to ACF be shipped as cargo in analyzing costs for the NPRM. Other U.S.

ports do not require dogs going to ACF to be shipped as cargo. U.S. port-specific policies may

change in the future, which, in conjunction with the uncertainty around the number of dogs

imported, significantly complicates the project of future costs for the requirements in the final

rule. As of March 2024, one U.S. port requires dogs going to ACF to be shipped as cargo, one

U.S. port recommends dogs be shipped as cargo to avoid clearance delays and four U.S. ports do
not have requirements or recommendations for shipping dogs as cargo. In total six U.S. ports

have CDC-registered ACF.

The next key change, which will increase the costs for importers of dogs from DMRVV-

free or low-risk countries. In response to public comment, HHS/CDC further defined the

required documentation needed for importers to prove that a dog has been only in DMRVV low-

risk or DMRVV-free countries. For the NPRM, HHS/CDC had assumed that veterinary records

from DMRVV-free or low-risk countries would be sufficient. However, after observing a

number of importers using fraudulent documentation to circumvent requirements for DMRVV

high-risk countries by moving dogs to DMRVV-free or low-risk countries prior to entering the

United States. As a result, HHS/CDC is requiring at least one record certified by an official

veterinarian in 42 CFR 71.51(u). A second change is that HHS/CDC is eliminating the

exemption for importers of dogs from DMRVV-free or low-risk countries to import three or

fewer dogs less than six months of age at land borders. Both of these changes will increase costs

to importers of dogs from DMRVV-free or low-risk countries and these changes are reflected in

the higher-cost estimates.

The United States was declared DMRVV-free in 2007. Importing dogs from DMRVV

high-risk countries involves a significant public health risk. The provisions of this final rule

would better align U.S. dog importation requirements with those of other countries that have

been declared DMRVV-free. Further, the serologic testing requirements are consistent with

standards in the WOAH Terrestrial Manual for dogs imported from DMRVV high-risk countries

to DMRVV-free countries.220 One DMRVV-infected dog may cause transmission to humans,

domestic pets, livestock, or wildlife. The social cost of the consequences associated with the

220WOAH Terrestrial Animal Health Code. Chapter 5.11. Available at: Access online: WOAH - World
Organisation for Animal Health https://www.woah.org/en/what-we-do/standards/codes-and-manuals/terrestrial-
code-online-access/?id=169&L=0&htmfile=chapitre_certif_rabies.htm.
importation of a DMRVV-infected dog was estimated to be $270,000 (range: $210,000 to

$510,000) to conduct public health investigations and administer rabies PEP to exposed persons.

Historically, CDC has denied entry to approximately 200 dogs annually due to

fraudulent, incomplete, or inaccurate paperwork.221 However, between January 2020 and July

2021 (i.e., during the COVID-19 pandemic, prior to the temporary suspension), CDC

documented more than 1000 instances of incomplete, inadequate, or fraudulent rabies

vaccination certificates for dogs arriving from DMRVV high-risk countries.222 The diversion of

public health resources globally to COVID-19 response activities contributed to a lapse in dog

rabies vaccination efforts and a related increase in the prevalence of dogs infected with DMRVV

in some high-risk countries. The combination of an increasing number of dogs imported without

adequate documentation of rabies vaccination,223 in addition to the potential increase in the

prevalence of DMRVV in high-risk countries,224 would increase the risk of importation of dogs

that are infected with DMRVV. This combination of factors would increase the likelihood of

DMRVV-importation events relative to the time-period before the COVID-19 pandemic.

CDC is unable to predict future trends with or without the provisions included in this

final rule to estimate how many dogs infected with DMRVV may be imported. Two rabid dog

imports (both from Iran) have been reported in Canada within a seven-month period (specifically

July 2021 and January 2022) at around the same time the United States implemented a temporary

suspension of dogs imported from DMRVV high-risk countries. Prior to these two imports,

Canada had not reported a dog infected with DMRVV since the 1960s.225 Given the limited

221 Centers for Disease Control and Prevention (2021). Quarantine Activity Reporting System (version 4.9.8.8.2.2A).
Dog Importation data, 2010-2019. Accessed October 1, 2022.
222 Pieracci, E., Williams, C., Wallace, R., Kalapura, C., Brown, C. U.S. dog importations during the COVID-19

pandemic: Do we have an erupting problem? PloS ONE,16(9), e0254287. Doi: 10.1371/journal.pone.0254287.


223 Centers for Disease Control and Prevention. Quarantine Activity Reporting System (version 4.9.8.8.2.2A). Dog

importation data, 2018-2020. Accessed: 15 February 2021.


224 A Kunkel, Jeon S, Haim, Dilius CJP, Crowdis K, Meltzer MI, Wallace R. (2021) The urgency of resuming

disrupted dog rabies vaccination campaigns: a modeling and cost-effectiveness analysis. Scientific Reports;
11:12476. https://doi.org/10.1038/s41598-021-92067-5.
225 Outbreak News Today (Feb. 10, 2022) Rabies case reported in Toronto in a dog imported from Iran.

http://outbreaknewstoday.com/rabies-case-reported-in-toronto-in-a-dog-imported-from-iran-46958. Accessed:
February 14, 2022.
number of reported dogs with DMRVV, this observation may be indicative of a higher risk for

dogs imported from DMRVV high-risk countries during the COVID-19 pandemic or could be

anomalous occurrences in Canada. However, the provisions included in the final rule are

expected to substantively reduce the risk of importation of dogs infected with DMRVV relative

to baseline.

The primary public health benefit of this final rule is the reduced risk that a dog infected

with DMRVV will be imported from a DMRVV high-risk country. Using the most likely

estimates of the net monetized cost estimate ($57.0 million) and the most likely estimate of the

potential benefit of averting the social cost of the consequences associated with an importation of

one dog with DMRVV from a high-risk country ($270,000), it is possible to calculate the change

in the number of imported dogs infected with DMRVV with the provisions of the final rule

relative to the baseline such that the benefit would equal cost. The most likely estimate of the net

cost ($57.0 million) divided by the most likely estimate of the social cost of the consequences

associated with an importation of a dog infected with DMRVV ($270,000) suggests that the

provisions of the final rule relative to baseline would have to avert the importation of 211 dogs

infected with DMRVV for the benefit to exceed the cost. This would require an increase in the

number of dogs imported into the United States while infected with DMRVV, which could only

occur because of widespread failures of rabies control programs in multiple countries. However,

this analysis does not consider the potential for fatal rabies cases in people or the risk of

reintroduction of DMRVV in the United States, as analyzed below.

The above estimate of the cost of an importation of a dog with DMRVV does not account

for the worst-case outcomes, which include 1) transmission of rabies to a person who dies from

the disease, or 2) ongoing transmission to other domestic and wildlife species in the United

States. The cost of reintroduction could be especially high if DMRVV spreads to other species of

U.S. wildlife. Re-establishment of DMRVV in the United States could result in costly efforts

over several years to eliminate the virus again. Both worst-case outcomes may be more likely to
occur after the COVID-19 pandemic because public health resources were diverted to COVID-

19 response activities and disruptions in rabies control programs in high-risk countries.

Disruptions to rabies control programs in DMRVV high-risk countries may contribute to

elevated risks even as the COVID-19 pandemic wanes. Human deaths from rabies continue to

occur in the United States after exposure to wild animals; however, no U.S. resident has died

after exposure to an imported dog with DMRVV in over 20 years. CDC uses the value of

statistical life (VSL) to assign a value to interventions that can result in mortality risk reductions.

For fatal cases, HHS recommends the use of the value of statistical life to estimate the potential

benefits of averted deaths, an estimate of $11.6 million in 2020 USD and a range of $5.5 to $17.7

million.226 However, CDC is unable to estimate the potential magnitude of the mortality risk

reduction associated with the final rule. Based on the central VSL, the provisions of the final rule

would need to avert 4.9 or more human deaths per year, on average, for the benefits to exceed

costs.

Efforts to eliminate DMRVV if re-established in the United States would also prove

costly. A previous campaign to eliminate domestic dog-coyote rabies virus variant jointly with

gray fox (Texas fox) rabies virus variant in Texas over the period from 1995 through 2003 cost

$34 million,227,228 or $56 million in 2023 USD. The costs to contain any reintroduction would

depend on the time-period before the reintroduction was realized, the wildlife species in which

DMRVV was transmitted, and the geographic area over which reintroduction occurs. The above

estimate is limited to the cost of rabies vaccination programs for targeted wildlife and does not

include the costs to administer PEP to any persons exposed after the reintroduction has been

226 U.S. Department of Health and Human Services, 2016. Office of the Assistant Secretary for Planning and
Evaluation. Guidelines for Regulatory Impact Analysis.
https://aspe.hhs.gov/system/files/pdf/242926/HHS_RIAGuidance.pdf. Accessed: April 20, 2020.
227 TJ Sidwa et al. (2005) Evaluation of oral rabies vaccination programs for control of rabies epizootics in coyotes

and gray foxes: 1995-2003.Journal of the American Veterinary Medicine Association; 227(5):785-92.
228 R.T. Sterner et al. (2009) Tactics and Economics of Wildlife Oral Rabies Vaccination, Canada and the United

States. Emerging Infectious Diseases; 15(8), 1176-1184.


identified. Human deaths from DMRVV could increase following the reintroduction of DMRVV

to the United States as the risk of exposure would increase.

At the same time, hesitancy towards vaccinating dogs may be increasing in the United

States. In a recent survey, about half of survey respondents reported skepticism toward dog

vaccination; however, 84% of these survey respondents reported that their dogs were up to date

with required vaccinations.229 If this skepticism leads to reduced coverage rates for U.S. dog

rabies vaccination, the United States would become more vulnerable to the reintroduction of

DMRVV. In the worst-case scenario, a large-scale reintroduction of DMRVV could result in

much greater costs than were reported for the elimination of the fox variant discussed previously.

Malaysia had been declared DMRVV-free, but the virus was reintroduced around 2017.

Despite a large public health response, DMRVV has not yet been eliminated in Malaysia and 45

people have died after having been infected between 2017 and 2022.230 The probability of

DMRVV reintroduction in the United States is likely to be much less than in Malaysia, which

shares a land border with Indonesia, which is a DMRVV high-risk country. However, the

potential risk for the United States would increase if the U.S. dog rabies vaccination rates were to

decrease or if the number of imported DMRVV-infected dogs from DMRVV high-risk countries

were to increase. The requirements included in this final rule would reduce the risk of

importations of DMRVV-infected dogs.

The provisions of the final rule would also ensure that dogs that are denied admission or

arrive ill will be housed appropriately and receive the care needed to protect their health and

safety. This will reduce the likelihood that dogs may be left in unsafe conditions in cargo

229 Motta M, Motta G, Stecula D. Sick as a dog? The prevalence, politicization, and health policy
consequences of canine vaccine hesitancy (CVH). Vaccine2023 41 (2023): 5946-5950.
230 Tuah L., Sabri MSM, Hashim M, Hashim M. (Dec. 8, 2022) Spatial Risk Assessment on Spread of Dog-

Mediated Rabies in Sarawak. SEACFMD Joint EpiNet and LabNet Virtual meeting. https://rr-asia.woah.org/wp-
content/uploads/2022/12/4-seacfmd__mcda-spatial-risk-assessment-on-rabies-in-sarawak.pdf. Accessed November
9, 2023.
warehouses for extended periods of time with the potential to expose workers who are not

trained to handle live animals safely.231

Under the current baseline, the number of dogs imported into the United States is neither

accurately nor completely tracked. The more comprehensive data collection in this final rule

through the CDC Dog Import Form will benefit public health investigations and enable better

and more timely contact tracing of all animals exposed to an imported dog with DMRVV. The

current lack of data also inhibits the Federal government’s ability to target interventions for dogs

imported from specific countries. The collection of data from the CDC Dog Import Form as

required in this final rule may also benefit other agencies such as USDA/ Animal and Plant

Health Inspection Service (APHIS) that may want to regulate dog imports based on the risk of

introduction of diseases that may affect U.S. livestock. For example, in 2021, APHIS regulated

importers of dogs for resale based on whether the dogs were imported from countries where

African swine fever exists.232 The potential economic benefits of reducing the risk of the

importation of African swine fever could be significant. For example, a recent African swine

fever outbreak in China was estimated to have total economic losses equivalent to 0.78 percent

of China’s gross domestic product in 2019.233 The requirement in the final rule to report all dogs

to CDC via a CDC-approved system would reduce the risk of importation of infected dogs from

countries with ongoing disease outbreaks that may affect livestock.

Viruses exploiting new host species have led to some of the most devastating disease

epidemics, such as influenza, Ebola, and the HIV/AIDS pandemic.234 Viruses continually evolve

231 https://www.cbsnews.com/chicago/news/dog-dies-at-ohare-airport-warehouse-17-others-saved-after-being-left-
without-food-or-water-for-3-days/.
232 Animal and Plant Health Inspection Service (Aug. 4, 2021) USDA Announces Requirements for Importing Dogs

from Countries Affected with African Swine Fever.


https://www.aphis.usda.gov/aphis/newsroom/news/sa_by_date/sa-2021/asf-dog-imports. Accessed: 05 February
2022.
233 Shibing You, Tingyi Liu, Miao Zhang, Xue Zhao, Yizhe Dong, Bi Wu, Yanzhen Wang, Juan Li, Xinjie Wei and

Baofeng Shi (2021) African swine fever outbreaks in China led to gross domestic product and economic losses.
Nature Food; 2: 802–808.
234 Woolhouse M, Haydon D, Antia R. Emerging pathogens: the epidemiology and evolution of species jumps.

Trends in Ecology & Evolution 2005; 20 (5): 238-244. https://doi.org/10.1016/j.tree.2005.02.009.


in their animal hosts. This has been observed in viruses such as avian and swine influenza

viruses, constituting a permanent pandemic threat to humans.235 Although CDC cannot predict

when future zoonotic diseases may emerge or whether future zoonotic diseases may be

associated with transmission from dogs to humans, such events remain a possibility. Future dog-

mediated communicable diseases may pose an acute risk to the public’s health because, in

contrast to other animal imports, most dogs are imported as pets and will be in close contact with

their owners.

During the COVID-19 pandemic a variant of the SARS-CoV-2 virus was detected in

mink populations in Europe and entered human populations from this animal host. Between

February 18, 2020, and December 15, 2021, 457 mink farms in 12 countries experienced SARS-

CoV-2 outbreaks236 and mink-to-human transmission of the SARS-CoV-2 virus was documented

on mink farms in the Netherlands, Denmark, Poland, and the United States.237,238,239 In August

and September of 2020, Denmark documented a mink-associated SARS-CoV-2 variant strain

found in 12 people, eight of whom had links to the mink farming industry. Due to concerns about

transmissibility, immunity, and potential impacts on vaccine efficacy, the Danish government

ordered that all 15-17 million minks in the country be culled. Following a risk assessment of live

mink importations from the Western European region to the United States using data from U.S.

Fish and Wildlife Service who regulate and track mink importations, it was determined

additional regulatory action to prohibit live mink importations was unnecessary due to public

health prevention measures taken by mink importers and the low numbers of imported mink. In

235 Woolhouse M, Haydon D, Antia R. Emerging pathogens: the epidemiology and evolution of species jumps.
Trends in Ecology & Evolution 2005; 20 (5): 238-244. https://doi.org/10.1016/j.tree.2005.02.009.
236 Koopmans M. SARS-CoV-2 and the human-animal interface: outbreaks on mink farms. The Lancet Infectious

Diseases 2021; 21 (1): 18-19.


237 Hammer AS, Quaade ML, Rasmussen TB, et al. SARS-CoV-2 Transmission between Mink (Neovison vison)

and Humans, Denmark. Emerg Infect Dis. 2021 Feb;27(2):547-551. doi: 10.3201/eid2702.203794. Epub 2020 Nov
18. PMID: 33207152; PMCID: PMC7853580.
238 Oude Munnink BB, Sikkema RS, Nieuwenhuijse DF, et al. Transmission of SARS-CoV-2 on mink farms

between humans and mink and back to humans. Science. 2021 Jan 8;371(6525):172-177. doi:
10.1126/science.abe5901. Epub 2020 Nov 10. PMID: 33172935; PMCID: PMC7857398.
239 Rabalski L, Kosinki M, Mazur-Panasiuk N, et al. Zoonotic spillover of SARS-CoV-2: mink-adapted virus in

humans. Available at: https://www.biorxiv.org/content/10.1101/2021.03.05.433713v1.full.pdf.


comparison, CDC would not have the same data available to conduct a risk assessment for dog

imports in the event of a future dog-mediated communicable disease outbreak because dog

imports are neither accurately nor completely tracked in any government data system in the

absence of the CDC Dog Import Form requirement included in this final rule. This would limit

HHS/CDC’s ability to accurately quantify the risks presented from specific countries because the

United States does not have data on the number of dogs imported from each country.

The reporting of dog import volumes by country in an approved CDC import submission

data system provides an opportunity to target interventions for dogs imported from specific

countries. Such reporting as now required in 42 CFR 71.51(h) would allow CDC or other Federal

agencies to more easily implement preventive measures to mitigate the risk of introductions of

new zoonotic diseases or foreign animal diseases targeted to specific countries of concern. The

import submission data requirement may also help CDC and other Federal agencies, as well as

State and local health departments, retrospectively inspect shipments from specific countries.

This would reduce the costs of future interventions; however, CDC is not able to quantify future

savings.

The provisions of the final rule are expected to reduce the risk of dogs arriving ill. If an

animal arrives in the United States and appears ill or is dead, a public health investigation is

required to ensure the ill or dead animal does not present a public health threat. The overall

health of an animal can play a significant role in whether it can maintain core body functions

(i.e., body temperature regulation and glucose levels) during prolonged flights. Stressed,

malnourished, and young animals are more likely to become ill and can transmit communicable

diseases that can affect humans;240,241 therefore, safety and welfare concerns for the transport of

240 Galanis E et al. Brucellosis and other diseases imported with dogs. BCMJ 2019; 61 (4): 177-190. Available at:
https://bcmj.org/bccdc/brucellosis-and-other-diseases-imported-dogs.
241 Denstedt E. Echinococcus multilocularis as an emerging public health threat in Canada: A knowledge synthesis

and needs assessment. Accessed: February 28, 2019. Available at: www.ncceh.ca/sites/default/files/Guelph-
Denstedt-2017.pdf.
dogs have a public health impact that requires a degree of oversight from public health agencies

to ensure human and animal health is protected.242

The required veterinarian examinations of foreign-vaccinated dogs from DMRVV high-

risk countries should lead to the earlier detection of other exotic pathogens. A recent study from

the United Kingdom performed additional screening for Babesia canis, Ehrlichia canis,

Hepatozoon canis, Leishmania infantum, Brucella canis, and Dirofilaria immitis among 133

recently imported rescue dogs. They identified one or more of these pathogens in 24% (32/133)

of the fully tested dogs.243 Although the authors found no significant association between

infected dogs and presenting clinical signs, this study helps demonstrate how the mandatory

veterinarian examination of foreign-vaccinated dogs from DMRVV high-risk countries may lead

to early detection of other diseases prior to spreading into the U.S. dog population.

In addition to the unmonetized benefits described above, there may be additional

unmonetized costs. CDC plans to monitor countries with high risk of DMRVV and may suspend

entry of dogs from countries with repeated instances of falsified or fraudulent dog vaccine

credentials or invalid rabies vaccination documents (defined as DMRVV-restricted countries in

this final rule). The lost value of imports from DMRVV-restricted countries would impact some

U.S. businesses and dog purchasers. However, the duration of any suspensions for these

countries is highly uncertain and may be ended in the event of improvement of those countries’

export controls.

HHS/CDC will have the authority to issue orders to revoke a carrier’s permission to

transport live dogs and cats if a carrier has endangered the public’s health; however, CDC does

not have plans to suspend any carriers at this time.

242 Pieracci EG, Maskery B, Stauffer K, Gertz A, Brown C. Risk factors for death and illness in dogs imported into
the United States, 2010-2018. Transbound Emerg Dis. 2022 Mar 15. doi: 10.1111/tbed.14510.
243 Wright I, Whitfield V, Hanaghan R, et al. (2023) Analysis of exotic pathogens found in a large group of imported

dogs following an animal welfare investigation. Vet Rec 4;193(9):e2996. doi: 10.1002/vetr.2996.
CDC lacks data on the cost to airlines of ensuring that a representative be on-site at the

U.S. airport and available to coordinate the entry/clearance of dogs with Federal government

officials. The representative must remain on site until all live imported dogs have either been

cleared for entry or arrangements have been made to transport the dogs to a facility (either a

CDC-registered ACF or other veterinary facility approved by CDC) pending admissibility

determination. CDC believes this will only incur additional costs on occasion since airline staff

are typically available on-site.

Analysis of the Costs and Benefits of the Alternatives

The summary costs and benefits of the lower and higher-cost alternatives are presented

assuming that either all of the lower-cost alternatives or all of the higher-cost alternatives are

selected. The annualized monetized costs and benefits are calculated relative to the same

regulatory baseline used to evaluate the impacts of the final rule. The alternatives are presented

above in Table 1. More detail on the impacts of each section is presented in the appendix in the

supplemental materials tab of this docket. Some of the key assumptions for the lower-cost

alternative include:

• If the age limit were reduced from six months to four months for dogs arriving by air, the

estimated reduction in the number of dogs arriving by air would decrease by two percent

relative to the regulatory baseline. This is less than the five percent reduction assumed

for the six-month age requirement included in the final rule. Also, there would be no

reduction in dogs arriving at land borders if there were no age limit for dog imports

arriving by land (or sea).

• If dogs were allowed to have either a microchip or tattoo (instead of allowing only

microchips), the cost of implementation is assumed to be reduced by 25%. Since dog


tattoos usually cost more than microchips244, the benefit is mostly due to some importers

preferring the tattoo to the microchip. Thus, the additional cost of the tattoo would have

to be offset by the utility to dog owners from owners who strongly prefer to have the

option of choosing either a tattoo or microchip. The reduction of cost is tied to the

increase in options available to dog importers, especially for importers who strongly

prefer not to have microchips implanted. This is an approximation since HHS/CDC is

unable to measure the disutility for dog owners who are strongly opposed to microchip

implantation.

• If only importers of dogs from DMRVV high risk countries are required to provide

advance data submission to CDC and airlines only need to provide a bill of lading or

CDC-approved alternative for such dogs, the costs for airlines and importers of dogs

imported from DMRVV-free or low-risk countries would decrease accordingly (i.e.,

these costs would only be incurred for importing dogs from DMRVV high-risk

countries).

• If importers of U.S.-vaccinated dogs from DMRVV high-risk countries no longer need to

have the form Certification of U.S.-issued Rabies Vaccination endorsed by a USDA

Official veterinarian, importer costs would decrease. CDC assumed that the vaccinating

veterinarians would be willing to fill out the appropriate form at no additional cost.

• If importers of foreign-vaccinated dogs from DMRVV high-risk countries were allowed

to have their dogs examined and revaccinated by any licensed U.S. veterinarian instead of

visiting a CDC-registered ACF, the cost to these importers would decrease considerably.

This alternative process would not require dogs to be transported as cargo (as required for

dogs transported to CDC-registered ACF at some U.S. ports). Also, the average fees

charged by U.S.-licensed veterinarians (assumed to be $100 to $200 per dog versus $500

244Gibeault S. (2021) Are ID Tags Enough? The Importance of Identifying Your Dog. American Kennel Club.
https://www.akc.org/expert-advice/home-living/id-tags-enough-importance-identifying-dog/.
to $1,300 per dog at CDC-registered ACF) would be lower. Owners could transport their

own dogs to a U.S.-licensed veterinarian. In addition, other U.S.-licensed veterinarians

would not have to comply with CDC requirements that are specific to CDC-registered

ACF. The change in costs also incorporate the costs to ship dogs as cargo, as described

above, which are much higher than for dogs that may be transported as hand-carried or

checked baggage.

• If CDC accepted serological test results from any laboratory as opposed to only CDC-

approved laboratories, the costs to importers of foreign-vaccinated dogs from DMRVV

high-risk countries would be reduced. CDC assumed that blood sample shipping costs

would be reduced by 50% and the costs for serological testing would be reduced by 25%.

This is because importers could choose from more potential laboratories and may choose

laboratories with lower fees since these laboratories would not have to adhere to the

requirements for CDC approval.

• If CDC allowed foreign-vaccinated dogs imported from DMRVV high-risk countries to

arrive at any U.S. port instead of only U.S. ports with CDC-registered ACF, CDC

assumed a much lower percentage of importers would have to change their travel plans

(20% instead of 60%). These importers would no longer incur additional ticket costs and

travel time costs. This change would probably only affect costs in conjunction with

another lower-cost alternative that would allow foreign-vaccinated dogs from DMRVV

high-risk countries to be evaluated by any licensed U.S. veterinarian rather than at a

CDC-registered ACF). In the absence of a simultaneous change to that requirement, there

would be little benefit to arriving at a U.S. port without a CDC-registered ACF for this

lower-cost alternative.

The total annualized monetized costs associated with the set of lower-cost alternative are

summarized in Table 4. The costs to importers and to airlines would decrease considerably

relative to the requirements included in the final rule ($16.7 million versus $51.0 million for
annualized monetized importer costs and $1.2 million versus $4.1 million for annualized

monetized airline costs, 3% discount rate). The total annualized monetized costs for these

alternatives are $22 million (range: $7.0 to $60 million, 3% discount rate). The annualized

monetized benefits also decrease for these lower-cost alternatives ($1.3 million, range: $0.54 to

$2.6 million).

Table 4. Annualized, monetized costs and benefits summary table (in 2020
million dollars, over a 10-year time horizon relative to the regulatory
baseline, three percent or seven percent discount rate) [Lower-cost Source (RIA
alternatives] a Section)

Most Likely Upper


Estimate Lower bound bound
Annualized, monetized benefits (reduced costs)
Three percent discount rate
Importer benefits $0.58 $0.25 $1.2 B2, B3, B4
Airline benefits $0.12 $0.025 $0.39 B5
DHS/CBP benefits $0.42 $0.20 $0.68 B6
HHS/CDC benefits $0.14 $0.060 $0.35 B7
State and local health
department benefits $0.001 $0.0 $0.006 B8
Total benefits (A1) $1.3 $0.54 $2.6
Seven percent discount rate
Importer benefits $0.58 $0.25 $1.2 B2, B3, B4
Airline benefits $0.12 $0.025 $0.39 B5
DHS/CBP benefits $0.42 $0.20 $0.68 B6
HHS/CDC benefits $0.14 $0.06 $0.35 B7
State and local health
department benefits $0.001 $0 $0.006 B8
Total benefits (A2) $1.3 $0.54 $2.6
Annualized, monetized costs
Three percent discount rate
Importer costs $16.7 $4.4 $50.7 B2, B3, B4
Airline costs $1.2 $0.4 $2.8 B5
DHS/CBP costs $2.0 $0.84 $3.5 B6
HHS/CDC costs $1.9 $1.4 $2.5 B7
Total costs (B1) $21.9 $7.0 $59.5
Seven percent discount rate
Importer costs $16.9 $4.4 $51.0 B2, B3, B4
Airline costs $1.3 $0.4 $2.8 B5
DHS/CBP costs $2.0 $0.85 $3.5 B6
HHS/CDC costs $2.0 $1.4 $2.6 B7
Total costs (B2) $22.1 $7.1 $60.0
Table 4. Annualized, monetized costs and benefits summary table (in 2020
million dollars, over a 10-year time horizon relative to the regulatory
baseline, three percent or seven percent discount rate) [Lower-cost Source (RIA
alternatives] a Section)

Most Likely Upper


Estimate Lower bound bound
Net annualized costs
Total (three percent
discount rate), (B1) -
(A1) $19.6 $6.3 $48.5
Total (seven percent
discount rate), (B2) -
(A2) $19.8 $6.4 $48.9
a That quantified, but unmonetized, costs and benefits and the qualitative (unquantified) costs

and benefits reported in Table 2 for the analysis of the final rule would not be impacted by the
changes in the lower-cost alternatives other than an increase the probability of importing dogs
infected with DMRVV.

However, this set of lower-cost alternatives would likely not have a significant impact on

reducing the risk of dogs being imported with DMRVV compared to the regulatory baseline. The

requirements in the final rule would more effectively reduce this risk. If the age requirements

were reduced, importers may be more likely to attempt to circumvent CDC rules to move dogs

from DMRVV high-risk to DMRVV-free or low-risk countries prior to importation into the

United States. It is difficult to age dogs under six months, and CDC has documented cases of

fraud involving the movement of dogs under six months of age from DMRVV high-risk

countries to DMRVV-free and DMRVV low-risk countries to avoid rabies vaccination

requirements. By requiring all dogs to be at least six months of age, CDC can better confirm that

the dog presented matches the documentation presented, particularly the age listed for the dog,

and that it is old enough to be adequately vaccinated for rabies.

In addition, transporting dogs under six months of age under conditions with unstable and

fluctuating air temperatures, such as those present in the cargo area of a plane, may subject these

young animals to adverse events (illness or death) because young animals cannot regulate their
body temperature as efficiently as adult animals.245 International travel often results in prolonged

time between feeding and watering of animals leading to potential adverse events (illness and

death) in young animals due to physiologic stressors associated with or exacerbated by low blood

glucose levels, low oxygen environments (such as the cargo area of a plane), dehydration, and

the stress of travel.246 This could result in more ill and dead dogs arriving on flights (reducing the

benefits estimated for the final rule). CDC would lack data on the total number of dogs imported

into the United States and would have less data to conduct public health investigations in the

event that a sick dog is imported from DMRVV-free or low-risk country. In the absence of

official certification of the Certification of U.S.-issued Rabies Vaccination form, CDC believes it

would be much easier for importers of dogs from DMRVV high-risk countries to present

fraudulent documentation of U.S. rabies vaccination. It would be more difficult for CDC to

verify the identity of dogs arriving with tattoos instead of microchips (increasing the risk of

fraudulently imported dogs).

Follow-up examination and revaccination of dogs by any U.S.-licensed veterinarian

would be less costly in comparison to services provided by CDC-registered ACF; however, this

would increase the public health risk associated with foreign-vaccinated dogs from DMRVV

high-risk countries. CDC would have limited capacity to follow up with importers to ensure that

the dogs had been appropriately examined and revaccinated in a timely manner. Prior to the

examination, the dog could come into contact with additional people and potentially other pets or

wildlife. Finally, staff at CDC-registered ACF will operate according to CDC regulations and

guidance to minimize the risk of disease transmission to humans and other animals.

CDC would have very limited oversight of the laboratories conducting serological tests.

Importers would also find it easier to obtain fraudulent serological tests from laboratories that are

245Hardy J. Physiology of temperature regulation. Physiologic reviews 1961: 41; 521-606.


246Jahn K, Ley J, DePorter T, Seksel K. How Well Do Dogs Cope with Air Travel? An Owner-Reported Survey
Study. Animals (Basel). 2023 Oct 4;13(19):3093. doi: 10.3390/ani13193093. PMID: 37835699; PMCID:
PMC10571552.
not approved by CDC or may get inaccurate test results from unapproved laboratories. If CDC

allowed foreign-vaccinated dogs to arrive at any U.S. port with a CDC quarantine station (also

known as a CDC port health station), the government (i.e., CBP and CDC) would not be able to

ensure that the dogs had been cleared by a CDC-registered ACF prior to admitting the dogs into

the United States. In summary, the lower-cost alternatives would result in significantly less costs

for importers and airlines but would also significantly limit the ability of CDC to prevent the

importation of inadequately vaccinated dogs from DMRVV high-risk countries. CDC has

observed that many importers have tried to circumvent CDC requirements for dog importation

and the provisions in this final rule are chosen to mitigate these risks. The lower-cost alternatives

would lead to a significantly increased risk that dogs infected with DMRVV would be imported.

However, CDC is unable to quantify the magnitude of this risk directly.

Some of the key assumptions that increase costs for the higher-cost alternative include:

• If the age limit were increased from six months to seven months for imported dogs, the

estimated reduction in the number of imported dogs would be six percent instead of five

percent as estimated for the final rule.

• If dogs were required to have both a microchip and a tattoo (instead of requiring only

microchips), the cost of implementation is assumed to be increased by 125% because dog

tattoos tend to cost more than microchips (i.e., the cost for this requirement would 2.25

times the cost of the microchip only.)

• If all importers of dogs had to use the CBP formal entry process for imported dogs, it

would require more time to register for (20 minutes on average) and file an entry (15

minutes on average) with the CBP data systems relative to the estimated time required to

submit entry data to CDC (seven minutes on average). This would also increase costs for

CBP to review the formal entry documentation.


• If all dog importers had to obtain either the Certification of U.S.-issued Rabies

Vaccination or Certification of Foreign Rabies Vaccination and Microchip form

endorsed by an USDA Official Veterinarian or Official Government Veterinarian, the

costs to importers of dogs from DMRVV-free or low-risk countries would increase

because they currently do not need to obtain these documents (with an assumed cost of

$35 per document on average).

• If importers of U.S.-vaccinated dogs from DMRVV high-risk countries were required to

visit a CDC-registered ACF, their costs would increase commensurate with estimates for

foreign-vaccinated dogs. CDC also assumed that five percent fewer U.S.-vaccinated dogs

would be imported from DMRVV high-risk countries due to the additional cost

associated with this requirement.

• If CDC required a 90-day waiting period from the time a dog blood sample was drawn to

perform a serological titer test (instead of 30 days as required in CDC technical

instructions), there would be additional costs to some importers who would be unable to

plan further in advance. These costs could range from staying in the country for an extra

60 days to no cost if importers could arrange to have the blood sample taken earlier

relative to when they plan to enter the United States. CDC assumed that it would cost an

extra $200 on average, although this cost would vary considerably according to importer

circumstances.

• If CDC required all dogs imported from DMRVV high-risk countries (including U.S.-

vaccinated dogs) to arrive at U.S. ports with CDC-registered ACF instead of limiting this

requirement to foreign-vaccinated dogs, the costs to importers of U.S.-vaccinated dogs

would increase commensurately and 60% of all imported dogs from DMRVV high-risk

countries would have to re-route their travel plans to a U.S. port with a CDC-registered

ACF instead of their preferred U.S. port.


The total annualized monetized costs associated with the higher-cost alternative are

summarized in Table 5. The costs to importers would increase considerably relative to the

requirements included in the final rule ($108 million versus $51.0 million for annualized

monetized importer costs). The total costs for these alternatives are $122 million (range: $31 to

$320 million, 3% discount rate). The annualized monetized benefits this set of higher-cost

alternatives is $1.3 million (range: $0.51 to $3.0 million).

CDC did not select any of these higher-cost alternatives because most of these alternatives do

not address the highest-risk category of imported dogs, i.e., foreign-vaccinated dogs from

DMRVV high-risk countries. As a result, the public health benefits associated with these higher-

cost alternatives would not decrease the risk to the public health sufficiently to balance the costs

of these alternatives. CDC has not observed any DMRVV infections among U.S.-vaccinated

dogs imported from DMRVV high-risk countries or among dogs imported from DMRVV-free or

low-risk countries. In addition, CDC can obtain the data it needs from the lower-cost CDC

import data submission system and does not require a tattoo in addition to a microchip to confirm

the identity of imported dogs. Because of the limited public health benefit and excessive costs,

HHS/CDC believes the requirements in the final rule address the risks associated with imported

dogs infected with DMRVV or other exotic pathogens more cost effectively than the alternatives.

Table 5. Annualized, monetized costs and benefits summary table (in 2020
million dollars, over a 10-year time horizon relative to the regulatory
baseline, three percent or seven percent discount rate) [Higher-cost Source (RIA
alternatives] a Section)

Most Likely Upper


Estimate Lower bound bound
Annualized, monetized benefits (reduced costs)
Three percent discount rate
Importer benefits $0.69 $0.30 $1.4 B2, B3, B4
Airline benefits $0.18 $0.038 $0.59 B5
DHS/CBP benefits $0.22 $0.09 $0.34 B6
HHS/CDC benefits $0.22 $0.090 $0.59 B7
State and local health
department benefits $0.005 $0.0 $0.022 B8
Table 5. Annualized, monetized costs and benefits summary table (in 2020
million dollars, over a 10-year time horizon relative to the regulatory
baseline, three percent or seven percent discount rate) [Higher-cost Source (RIA
alternatives] a Section)

Most Likely Upper


Estimate Lower bound bound
Total benefits (A1) $1.3 $0.51 $3.0
Seven percent discount rate
Importer benefits $0.69 $0.30 $1.4 B2, B3, B4
Airline benefits $0.18 $0.038 $0.59 B5
DHS/CBP benefits $0.22 $0.09 $0.34 B6
HHS/CDC benefits $0.22 $0.09 $0.59 B7
State and local health
department benefits $0.005 $0 $0.022 B8
Total benefits (A2) $1.3 $0.51 $3.0
Annualized, monetized costs
Three percent discount rate
Importer costs $108 $25.6 $293 B2, B3, B4
Airline costs $4.2 $1.8 $8.0 B5
DHS/CBP costs $8.2 $2.08 $15.2 B6
HHS/CDC costs $1.9 $1.4 $2.5 B7
Total costs (B1) $122 $30.9 $318
Seven percent discount rate
Importer costs $109 $25.8 $295 B2, B3, B4
Airline costs $4.2 $1.8 $8.1 B5
DHS/CBP costs $8.2 $2.09 $15.3 B6
HHS/CDC costs $2.0 $1.4 $2.6 B7

Total costs (B2) $123 $31.1 $321


Net annualized costs
Total (three percent
discount rate), (B1) -
(A1) $121 $30.4 $316
Total (seven percent
discount rate), (B2) -
(A2) $122 $30.6 $318
a That quantified, but unmonetized, costs and benefits and the qualitative (unquantified) costs

and benefits reported in Table 2 for the analysis of the final rule would not be impacted by the
changes in the higher-cost alternatives other than a slight decrease the probability of
importing dogs infected with DMRVV.

Impact of the final rule on Dog Import Volumes


CDC did not receive any additional data to update its estimates of the number of

imported dogs and used the same set of estimates presented in the NPRM analysis. In total, CDC

estimates that under the current regulatory baseline, about 800,000 imported dogs would arrive

in the United States each year and that about 500 dogs from DMRVV high-risk countries would

be denied admission (Table 6). The number denied entry is based on CDC data from 2020 and

the first six months of 2021 prior to the suspension of dog imports from DMRVV high-risk

countries. This approach may overestimate the number of dogs denied entry in the future if the

COVID-19 pandemic was associated with a significant increase in dogs denied admission due to

pandemic-associated factors. Since dog rabies vaccine certificates are not currently required for

dogs from DMRVV-free or DMRVV low-risk countries, CDC did not assume any dogs from

these countries would be denied admission under the baseline.

Table 6. Estimated annual numbers of dogs imported into the United States under the current
regulatory baseline
Most likely Lower Upper
estimate bound bound
Baseline estimate of dog imports
From DMRVV-free or DMRVV low-risk countries under
733,787 619,229 848,344
baseline, total
Airports 371,507 297,205 445,808
Land ports 362,280 322,024 402,536
Canada-U.S. land ports 247
120,780 96,624 144,936
Mexico-U.S. land ports 248
241,500 225,400 257,600
Dogs temporarily denied admission 0 0 0

From DMRVV high-risk countries 65,560 32,780 98,340


Dogs approved entry with adequate rabies vaccination
documentation 65,060 32,480 97,590
Dogs denied admission 500 300 750
Total dog imports at baseline 798,847 651,709 945,934

247 Id.
248 Id.
The provisions of the final rule that are expected to reduce the number of dog imports

include: 1) age restrictions on air travel for all dogs under six months of age, including dogs from

both DMRVV high-risk and DMRVV low-risk or DMRVV-free countries; and 2) the additional

costs of fulfilling the requirements for follow-up and revaccination at CDC-registered Animal

Care Facilities for foreign-vaccinated dogs from DMRVV high-risk countries. At the same time,

HHS/CDC believes that the number of dogs denied admission and returned to their countries of

origin would decrease with the provisions included in the final rule because the standardized

forms, requirements for carriers to confirm required documentation, and the requirement for

foreign-vaccinated dogs from DMRVV- high-risk countries to have reservations at and arrive at

U.S. ports with CDC-registered ACF should reduce the number of dogs denied entry.

The estimated impact of the final rule on the number of dog imports is summarized in

Table 7a. HHS/CDC lacks data on what fraction of dogs arriving by air or land are less than six

months old under the baseline. In the absence of this information, HHS/CDC assumes five

percent (range: three to eight percent) of imported dogs currently are less than six months of age

and would not be eligible to be imported into the United States under the final rule. HHS/CDC

notes that these provisions should primarily impact individuals traveling with their personal pets

because the importation of dogs for resale or adoption (including transfer of ownership) that are

less than six months of age is already prohibited by USDA regulations (7 CFR 2148). Another

provision of the final rule requires importers of dogs from DMRVV-free or low-risk countries to

submit verified documentation that the animal has been in a DMRVV low-risk or DMRVV-free

country for the six months prior to importation into the United States. CDC does not anticipate

denying admission to dogs that may arrive from DMRVV-free or low-risk countries without

such documentation when the final rule goes into effect, but there may be delays at U.S. ports

while HHS/CDC confirms dogs from DMRVV-free or low-risk countries have not been in a

DMRVV high-risk country within the last six months.


HHS/CDC assumes that the additional costs associated with importing dogs from

DMRVV high-risk countries with foreign-issued rabies vaccination documentation would reduce

the number of imports by about 20 percent (range: 10 to 30 percent) with the final rule. In

addition, CDC believes the number of dogs from DMRVV high-risk countries that are denied

entry will decrease with the provisions of the final rule because CDC will be able to require the

use of standardized forms to confirm rabies vaccination and CDC-registered ACF follow-up

requirements should be clear to importers. The number of dogs denied entry after arriving by air

in calendar year 2022 was 96. Based in part on the number of dogs denied entry during

HHS/CDC’s temporary suspension and assuming that number would continue to decrease with a

final rule in place, HHS/CDC estimates that about 50 dogs per year from DMRVV high-risk

countries would be denied entry under the final rule. Overall, the final rule is expected to have a

small impact on the total number of dogs imported (from about 799,000 [range: 652,000 to

946,000] at baseline to 755,000 [range: 630,000 to 872,000] with the provisions of the final rule

in effect).
Table 7a. Estimated average annual numbers of dog imports by DMRVV risk category and by
immunization status with the final rule relative to the baseline
Most likely
estimate Lower boundb Upper boundc
Baseline estimate of dog imports
From DMRVV-free or low-risk countries under regulatory baseline
Total 733,787 619,229 848,344
Airports 371,507 297,205 445,808
Land ports 362,280 322,024 402,536
Canada-U.S. land ports 249
120,780 96,624 144,936
Mexico-U.S. land ports 250
241,500 225,400 257,600
Dogs denied entry from
DMRVV-free or low-risk
countries 0 0 0
Dogs from DMRVV high risk countries
Total 65,560 32,780 98,340
Dogs approved entry with
rabies vaccination
documentation 65,060 32,480 97,590
Estimated fraction of
imported dogs from
DMRVV high-risk
countries that are U.S.-
vaccinated 50% 65% 35%
Estimated U.S.-vaccinated
dogs 32,530 21,112 34,157
Estimated foreign-
vaccinated dogs 32,530 11,368 63,434
Dogs denied entrya 500 300 750
Total imported dogsa 798,847 651,709 945,934
With final rule
Dogs from DMRVV-free or low-risk countries
Fraction of dogs that cannot be
imported with final rule at airports
(due to age restrictions) 5% 3% 8%
Airports 352,931 288,289 410,143
Dogs approved entry 352,578 288,145 409,528
Dogs temporarily denied
entry 353 144 615
Fraction of dogs that cannot be
imported with final rule at land ports
(due to age restrictions) 5% 3% 8%
Land ports 344,166 312,363 370,333
Canada-U.S. land ports 114,741 93,725 133,341
Dogs approved entry 114,626 93,678 133,141
Dogs temporarily denied
entry 115 47 200
Table 7a. Estimated average annual numbers of dog imports by DMRVV risk category and by
immunization status with the final rule relative to the baseline
Most likely
estimate Lower boundb Upper boundc
Mexico-U.S. land ports 229,425 218,638 236,992
Dogs approved entry 229,196 218,529 236,637
Dogs temporarily denied
entry 229 109 355
Dogs temporarily denied entry
from DMRVV-free or low-risk
countries (total) 697 300 1,171
Dogs from DMRVV high-risk countries

Fraction of foreign-vaccinated dog


imports that cannot be imported with
the final rule due to the higher costs
associated with importation 20% 30% 10%
Total 58,554 29,070 91,247
Number of U.S.-vaccinated
dogs approved entry 32,530 21,112 34,157
Number of foreign-vaccinated
dogs approved entry 25,974 7,928 57,015

Total dogs approved entry 58,504 29,040 91,172


Dogs denied entry and
returned to country of origina 50 30 75
Total imported dogs (with final rule) a 755,601 629,692 871,648
Total imported dogs (Regulatory
Baseline)a 798,847 651,709 945,934
a Since these dogs are denied entry and returned to their countries of origin, they are not

included in the total number of imports.


b The lower bound estimates are selected to minimize the number of dogs imported or the costs

associated with the regulatory changes (e.g., when considering dogs from DMRVV high-risk
countries, the costs for foreign-vaccinated dogs are much higher than the costs for U.S.-
vaccinated dogs). Thus, assuming a greater fraction of dogs from these countries are U.S.-
vaccinated would reduce the cost estimate for this final rule. HHS/CDC does not have data for
this parameter and had to make assumptions.
c The upper bound estimates are selected to maximize the number of dogs imported or the costs

associated with the regulatory changes (e.g., when considering dogs from DMRVV high-risk
countries, the costs for foreign-vaccinated dogs are much higher than the costs for U.S.-
vaccinated dogs). Thus, assuming a greater fraction of dogs from these countries are foreign-
vaccinated would increase the cost estimate for this final rule. HHS/CDC does not have data for
this parameter and had to make assumptions.

249 CDC. Guidance Regarding Agency Interpretation of “Rabies-Free” as It Relates to the Importation of Dogs Into
the United States. 84 FR 724 (Jan. 31, 2019).
250 Id.
The estimated numbers of imported dogs arriving in the United States with lower-cost

alternatives and the higher-cost alternatives are summarized in Tables 7b and 7c. With the set of

lower-cost alternatives, the reduction in the number of imported dogs relative to baseline is

relatively small (most likely estimate: 790,000 [range: 648,000 to 926,000] with lower-cost

alternatives compared to a most likely estimate of 799,000 for the regulatory baseline). The costs

associated with the potential requirements to import foreign-vaccinated dogs from DMRVV

high-risk countries would be less than with the final rule. In addition, the age restrictions for all

imported dogs would be mitigated for the lower-cost alternatives versus the final rule. As a

result, the total number of dogs would be greater with the lower-cost alternatives than with the

final rule requirements. With the set of higher-cost alternatives, the reduction in the number of

imported dogs relative to baseline is greater (most likely estimate: 747,000 [range: 623,000 to

868,000] with higher-cost alternatives compared to a most likely estimate of 799,000 for the

regulatory baseline). With the potential higher-cost alternatives, there would be an additional

reduction in the estimated number of U.S.-vaccinated dogs from DMRVV high-risk countries

because many of the requirements in the final rule that are limited to foreign-vaccinated dogs

would also apply to U.S.-vaccinated dogs. In addition, all imported dogs would have to be seven

months of age instead of six months of age, which also result in fewer imported dogs from

DMRVV-free or low-risk countries compared to the requirements in the final rule.

Table 7b. Estimated average annual numbers of dog imports by DMRVV risk category and by
immunization status with the lower-cost alternatives
Most likely
estimate Lower boundb Upper boundc
Dogs from DMRVV-free or low-risk countries
Fraction of dogs that cannot be imported
with lower-cost alternatives at airports
(due to age restrictions) 2% 1% 3%
Airports 364,077 294,233 432,434
Dogs approved entry 363,712 294,086 431,785
Dogs temporarily denied entry 364 147 649
Fraction of dogs that cannot be imported
with lower-cost alternatives at land ports
(due to age restrictions) 0.0% 0.0% 0.0%
Land ports 362,280 322,024 402,536
Canada-U.S. land ports 120,780 96,624 144,936
Dogs approved entry 120,659 96,576 144,719
Dogs temporarily denied
entry 121 48 217
Mexico-U.S. land ports 241,500 225,400 257,600
Dogs approved entry 241,259 225,287 257,214
Dogs temporarily denied
entry 242 113 386
Dogs temporarily denied entry
from rabies-free, DMRVV-free,
or low-risk (total) 726 308 1,252
Dogs from DMRVV high-risk countries
Fraction of foreign-vaccinated dog
imports from DMRVV high-risk
countries that would not occur under the
provisions of the lower-cost alternatives
due to the higher costs associated with
importation 5% 3% 10%
Total 63,434 32,139 91,247
Number of U.S.-vaccinated dogs
approved entry 32,530 21,112 34,157
Number of foreign-vaccinated
dogs approved entry 30,704 10,907 56,790

Total dogs approved entry 63,234 32,019 90,947


Dogs denied entry and returned to
country of origina 200 120 300
Total imported dogs (with lower-cost
alternatives) 789,590 648,276 925,916
Total imported dogs (Regulatory
Baseline)a 798,847 651,709 945,934
a Since these dogs are denied entry and returned to their countries of origin, they are not

included in the total number of imports.


b The lower bound estimates are selected to minimize the number of dogs imported or the costs

associated with the regulatory changes (e.g., when considering dogs from DMRVV high-risk
countries, the costs for foreign-vaccinated dogs are much higher than the costs for U.S.-
vaccinated dogs). Thus, assuming a greater fraction of dogs from these countries are U.S.-
vaccinated would reduce the cost estimate for this final rule. HHS/CDC does not have data for
this parameter and had to make assumptions.
c The upper bound estimates are selected to maximize the number of dogs imported or the costs

associated with the regulatory changes (e.g., when considering dogs from DMRVV high-risk
countries, the costs for foreign-vaccinated dogs are much higher than the costs for U.S.-
vaccinated dogs). Thus, assuming a greater fraction of dogs from these countries are foreign-
vaccinated would increase the cost estimate for this final rule. HHS/CDC does not have data for
this parameter and had to make assumptions.

Table 7c. Estimated average annual numbers of dog imports by DMRVV risk category and by
immunization status with the higher-cost alternatives
Most likely
estimate Lower boundb Upper boundc
Dogs from DMRVV-free or low-risk countries
Fraction of dogs that cannot be
imported with higher-cost alternatives
at airports (due to age restrictions) 6% 4% 8%
Airports 349,216 285,317 410,143
Dogs approved entry 348,867 285,174 409,528
Dogs temporarily denied
entry 349 143 615
Fraction of dogs that cannot be
imported with higher-cost alternatives
at land ports (due to age restrictions) 6.0% 4.0% 8.0%
Land ports 340,543 309,143 370,333
Canada-U.S. land ports 113,533 92,759 133,341

Dogs approved entry 113,420 92,713 133,141


Dogs temporarily
denied entry 114 46 200
Mexico-U.S. land ports 227,010 216,384 236,992
Dogs approved entry 226,783 216,276 236,637
Dogs temporarily
denied entry 227 108 355
Dogs temporarily denied entry
from rabies-free, DMRVV-
free, or low-risk (total) 690 297 1,171
Dogs from DMRVV high-risk countries
Fraction of foreign-vaccinated dog
imports from DMRVV high-risk
countries that would not occur under
the provisions of the higher-cost
alternatives due to the higher costs
associated with importation 20% 30% 10%
Fraction of U.S.-vaccinated dog
imports from DMRVV high-risk
countries that would not occur under
the provisions of the higher-cost
alternatives due to the higher costs
associated with importation 5% 3% 10%
Total 56,928 28,436 87,831
Number of U.S.-vaccinated
dogs approved entry 30,904 20,479 30,741
Number of foreign-vaccinated
dogs approved entry 25,974 7,928 57,015

Total dogs approved entry 56,878 28,406 87,756


Dogs denied entry and returned to
country of origina 50 30 75
Total imported dogs (with lower-cost
alternatives) 746,637 622,866 868,232
Total imported dogs (Baseline) a 798,847 651,709 945,934
a Since these dogs are denied entry and returned to their countries of origin, they are not

included in the total number of imports.


b The lower bound estimates are selected to minimize the number of dogs imported or the costs

associated with the regulatory changes (e.g., when considering dogs from DMRVV high-risk
countries, the costs for foreign-vaccinated dogs are much higher than the costs for U.S.-
vaccinated dogs). Thus, assuming a greater fraction of dogs from these countries are U.S.-
vaccinated would reduce the cost estimate for this final rule. HHS/CDC does not have data for
this parameter and had to make assumptions.
c The upper bound estimates are selected to maximize the number of dogs imported or the costs

associated with the regulatory changes (e.g., when considering dogs from DMRVV high-risk
countries, the costs for foreign-vaccinated dogs are much higher than the costs for U.S.-
vaccinated dogs). Thus, assuming a greater fraction of dogs from these countries are foreign-
vaccinated would increase the cost estimate for this final rule. HHS/CDC does not have data for
this parameter and had to make assumptions.

HHS/CDC has not attempted to project future changes to the volume of dogs imported

annually because of insufficient data. HHS/CDC believes that introducing another factor to

project future volumes is not prudent. While HHS/CDC observed an increase in the number of

dogs arriving with fraudulent paperwork prior to implementing the temporary suspension, this

may not correspond to changes in the total number of dogs imported, of which only a small

fraction arrives with fraudulent paperwork.

The most likely estimates of the annual monetized costs and benefits for each interested

party or implementing partner with the final rule relative to the regulatory baseline are

summarized in Table 8a over a 10-year period from 2024 through 2033 using the estimated

values presented in Sections B2 through B9 of the Appendix found in the Supplemental

Materials tab of the docket. The most likely estimate of monetized costs across interested parties

is $79 million in the first year and $56 million in subsequent years for the final rule relative to
the regulatory baseline. The most likely estimate of monetized benefits across interested parties

is estimated to be $1.8 million each year.

The annual costs and benefits for importers are split into importers of dogs from

DMRVV-free or DMRVV low-risk countries versus importers of dogs from DMRVV high-risk

countries. However, it is likely that some importers of dogs from DMRVV high-risk countries

may also be importers of dogs from DMRVV-free or low-risk countries. In addition, the

provisions of the final rule may result in some importers switching from importing dogs from

DMRVV high-risk countries to dogs from DMRVV-free or low-risk countries.

As a percentage of total costs, importers were estimated to incur 85 to 87 percent of the

total costs (most likely estimates), with a higher fraction of total costs incurred in the subsequent

years after the first year of implementation. Total costs are approximately 3.2 to 3.3 times greater

for dogs imported from DMRVV high-risk countries compared to dogs from DMRVV-free or

low-risk countries. In addition, it is important to note that more than 10 times as many dogs are

estimated to be imported from DMRVV-free or low-risk countries. Thus, the cost per dog for

importers of dogs from DMRVV high-risk countries is significantly greater than for importers of

dogs from DMRVV-free or low-risk countries. This is especially true for foreign-vaccinated

dogs from DMRVV high-risk countries.

Table 8a. Most likely estimates of annual monetized costs and benefits by affected party or
implementing partner from 2024 – 2033 for the final rule relative to baseline in 2020 USD
Importers Centers State/ local
Importers of dogs for public
of dogs from Disease health and
from DMRVV Control animal
DMRVV -free or Customs and and health
high-risk low-risk Border Preventio department
Year countries countries Airlines Protection n s Total
Annual monetized costs (million)
2024 $51.0 $15.9 $5.3 $2.7 $4.1 $0 $79
2025 $37.7 $11.3 $4.0 $1.617 $1.7 $0 $56
2026 $37.7 $11.3 $4.0 $1.617 $1.7 $0 $56
2027 $37.7 $11.3 $4.0 $1.617 $1.7 $0 $56
2028 $37.7 $11.3 $4.0 $1.617 $1.7 $0 $56
2029 $37.7 $11.3 $4.0 $1.617 $1.7 $0 $56
2030 $37.7 $11.3 $4.0 $1.617 $1.7 $0 $56
2031 $37.7 $11.3 $4.0 $1.617 $1.7 $0 $56
2032 $37.7 $11.3 $4.0 $1.617 $1.7 $0 $56
2033 $37.7 $11.3 $4.0 $1.617 $1.7 $0 $56
Annual monetized benefits (million)
2024 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8
2025 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8
2026 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8
2027 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8
2028 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8
2029 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8
2030 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8
2031 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8
2032 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8
2033 $0.81 $0.035 $0.18 $0.54 $0.22 $0.0049 $1.8

The costs to airlines are expected to comprise 6.7 to 7.0 percent of total costs. Among

Federal government agency costs for the provisions included in the final rule, CBP’s additional

costs (2.9 to 3.4 percent of the total) are expected to be less than CDC’s additional costs (3.0 to

5.2 percent of the total).

The greatest fractions of the most likely estimates of the monetized benefits associated

with the provisions in the final rule would accrue to importers of dogs from DMRVV high-risk

countries (45 percent) and to CBP (30 percent). For both groups, the costs of screening dogs at

U.S. ports would be reduced for two reasons. First, documentation of rabies vaccination for U.S.-

vaccinated dogs from DMRVV high-risk countries would be standardized to reduce the amount

time required for screening. Second, fewer dogs would be screened at U.S. ports, reducing time

spent on screening. This would result in cost savings for both groups at U.S. ports, although costs

for importers to obtain the standardized forms and to forgo importing some dogs would increase

(as documented in the cost estimates). Additional benefits are estimated to accrue to importers of

dogs from DMRVV high-risk countries, airlines, CBP, and CDC from a reduction in the number

of dogs denied entry and returned to their countries of origin.


The most likely estimates of the annual monetized costs and benefits for each interested

party or implementing partner for the lower-cost alternatives relative to the regulatory baseline

are summarized in Table 8b over a 10-year period using the estimated values presented in the

Appendix found in the Supplemental Materials tab of the docket. For the lower-cost alternatives,

the most likely estimates of monetized costs across interested parties are $31 million in the first

year and $21 million in subsequent years. These estimates are substantially lower than the costs

for the final rule as summarized in Table 8a. The most likely estimate of monetized benefits

across interested parties is estimated to be $1.3 million each year.

As a percentage of total costs, importers are estimated to incur 72 to 77 percent of the

total costs (most likely estimates), with a higher fraction of total costs incurred in the subsequent

years after the first year of implementation. Importer costs are similar for dogs imported from

DMRVV high-risk countries and dogs from DMRVV-free or low-risk countries for the lower-

cost alternatives. The costs to airlines are expected to comprise 5.1 to 5.8 percent of total costs.

Among Federal government agency costs for the provisions included in the final rule, CBP’s

additional costs (9.4 percent of the total) are expected to be less than CDC’s additional costs

(13.0 percent of the total) in the first year and slightly greater (8.9 percent of the total versus 8.1

percent of the total) in subsequent years.

Table 8b. Most likely estimates of annual monetized costs and benefits by affected party or
implementing partner from 2024 – 2033 for lower cost alternatives relative to baseline in 2020
USD
Importers Centers State/ local
Importers of dogs for public
of dogs from Disease health and
from DMRVV Control animal
DMRVV -free or Customs and and health
high-risk low-risk Border Preventio department
Year countries countries Airlines Protection n s Total
Annual monetized costs (million)
2024 $11.1 $11.7 $1.6 $2.9 $4.1 $0 $31
2025 $8.1 $7.9 $1.2 $1.848 $1.7 $0 $21
2026 $8.1 $7.9 $1.2 $1.848 $1.7 $0 $21
2027 $8.1 $7.9 $1.2 $1.848 $1.7 $0 $21
2028 $8.1 $7.9 $1.2 $1.848 $1.7 $0 $21
2029 $8.1 $7.9 $1.2 $1.848 $1.7 $0 $21
2030 $8.1 $7.9 $1.2 $1.848 $1.7 $0 $21
2031 $8.1 $7.9 $1.2 $1.848 $1.7 $0 $21
2032 $8.1 $7.9 $1.2 $1.848 $1.7 $0 $21
2033 $8.1 $7.9 $1.2 $1.848 $1.7 $0 $21
Annual monetized benefits (million)
2024 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3
2025 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3
2026 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3
2027 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3
2028 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3
2029 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3
2030 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3
2031 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3
2032 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3
2033 $0.57 $0.010 $0.12 $0.42 $0.14 $0.0015 $1.3

The most likely estimates of the annual monetized costs and benefits for each interested

party or implementing partner for the higher-cost alternatives relative to the regulatory baseline

are summarized in Table 8c over a 10-year period using the estimated values presented in the

Appendix found in the Supplemental Materials tab of the docket. The most likely estimates of

monetized costs across interested parties are $164 million in the first year and $117 million in

subsequent years. The most likely estimate of monetized benefits across interested parties is

estimated to be $1.3 million each year. These estimates are substantially higher than the costs

summarized in Table 8a.

As a percentage of total costs, importers are estimated to incur 88 percent of the total

costs (most likely estimates). Importer costs are approximately 3.0 to 3.3 times greater for dogs

imported from DMRVV high-risk countries compared to dogs from DMRVV-free or low-risk

countries. The costs to airlines are expected to comprise 3.3 to 3.4 percent of total costs. Among

Federal government agency costs for the provisions included in the final rule, CBP’s additional

costs (6.7 percent of the total) are expected to be more than CDC’s additional costs (1.4 to 2.5

percent of the total).


Table 8c. Most likely estimates of annual monetized costs and benefits by affected party or
implementing partner from 2024 – 2033 for higher cost alternatives relative to baseline in
2020 USD
Importers Centers State/ local
Importers of dogs for public
of dogs from Disease health and
from DMRVV Control animal
DMRVV -free or Customs and and health
high-risk low-risk Border Preventio department
Year countries countries Airlines Protection n s Total
Annual monetized costs (million)
2024 $107.7 $35.9 $5.3 $11.0 $4.1 $0 $164
2025 $79.3 $24.2 $4.0 $7.814 $1.7 $0 $117
2026 $79.3 $24.2 $4.0 $7.814 $1.7 $0 $117
2027 $79.3 $24.2 $4.0 $7.814 $1.7 $0 $117
2028 $79.3 $24.2 $4.0 $7.814 $1.7 $0 $117
2029 $79.3 $24.2 $4.0 $7.814 $1.7 $0 $117
2030 $79.3 $24.2 $4.0 $7.814 $1.7 $0 $117
2031 $79.3 $24.2 $4.0 $7.814 $1.7 $0 $117
2032 $79.3 $24.2 $4.0 $7.814 $1.7 $0 $117
2033 $79.3 $24.2 $4.0 $7.814 $1.7 $0 $117
Annual monetized benefits (million)
2024 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3
2025 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3
2026 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3
2027 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3
2028 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3
2029 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3
2030 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3
2031 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3
2032 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3
2033 $0.65 $0.035 $0.18 $0.22 $0.22 $0.0049 $1.3

B. Regulatory Flexibility Act

Under the Regulatory Flexibility Act, as amended by the Small Business Regulatory

Enforcement Fairness Act, agencies are required to analyze regulatory options to minimize the

significant economic impact of a rule on small businesses, small governmental units, and small

not-for-profit organizations. CDC examined the potential impact of the rule on small entities,
including small businesses that may import dogs for commercial purposes as well as airlines that

transport dogs internationally. HHS/CDC lacks key data on the number of dogs imported. In the

absence of data on the number of dogs imported, CDC made several assumptions to estimate

revenues from small businesses for different categories of businesses that may import dogs and

used these revenue estimates to calculate how many dogs could be imported such that the costs

associated with the rule would be less than two percent of estimated revenues. HHS/CDC

published an initial regulatory flexibility analysis with the NPRM, invited public comments, but

did not receive any comments on the RFA. HHS/CDC did receive some comments from

breeders, some of which identified as hobbyists, indicating that the six-month age requirements

would impact their ability to import dogs for breeding purposes. HHS/CDC received some

comments from breeders and breed enthusiasts reporting that the costs to import dogs from

DMRVV-free or low-risk countries would increase as a result of the six-month age requirement.

Other breeders and enthusiasts did not mention an increase in costs, but suggested the change in

regulations would reduce the number of exporters willing to send dogs to the United States,

which would decrease genetic diversity.

USDA prohibits the importation of dogs under six-months of age for commercial

purposes, which includes any transfer of ownership; therefore, importing dogs under six months

of age is already prohibited. Thus, HHS/CDC did not consider this as a change to the regulatory

baseline. Additionally, HHS/CDC believes that the six-month age requirement for importation

helps protect the health and safety of all dog breeds. Since dogs under six months of age are

sexually immature and cannot be used for breeding, delaying their importation may not

negatively impact their use as breeding animals. Additionally, waiting until a dog is six months

of age to import the dog will help ensure the safety and welfare of the dog during international

travel when they are subjected to the stresses of international travel (e.g., long travel times,

temperature fluctuations, oxygen or altitude changes, and food/water deprivation). Any time a

dog becomes ill or dies during international travel, regardless of country of import, Federal and
State government agencies must conduct public health investigations to ensure the animal is not

infected with a zoonotic disease that could be transmitted to people (or did not die from a

zoonotic disease). These investigations take a tremendous amount of resources. HHS/CDC

believes that the six-month age requirement for importation helps protect the health and safety of

all dogs and will result in a reduced burden on Federal and State government agencies.

Based on these analyses, CDC believes that the only small entities for which this rule

would have significant impacts would be those that specialize in importing dogs from DMRVV

high-risk countries. The provisions of this rule would probably not have a significant economic

impact on small airlines and probably would not have a significant impact on small entities that

import dogs from DMRVV-free or DMRVV low-risk countries. The requirement most likely to

impact small airlines is § 71.51(dd), which requires airlines to provide bills of lading for all

imported dogs. However, there is a waiver process for airlines to have an alternative process

while preparing to provide bills of lading. CDC notes that the importation of dogs less than six

months of age for resale or adoption in the United States is already prohibited by USDA

regulations (7 CFR 2148). Thus, the minimum age requirements in this rule should not impact

entities that sell or resell imported dogs but may impact entities that import very young dogs for

commercial purposes other than resale assuming no transfer of ownership.

As part of the economic impact analysis, CDC calculated the marginal cost associated

with the rule per dog imported from DMRVV-free or DMRVV low-risk countries ($23, range:

$7.74 to $48 per imported dog). The marginal cost associated with the requirements in the final

rule per dog imported from DMRVV high-risk countries was further subdivided between

foreign-vaccinated dogs (vaccinated outside the United States) ($1,910, range: $910 to $3,800)

compared to U.S.-vaccinated dogs ($41, range: $15 to $73). These estimates cover the first year

of implementation after a final rule is published. Marginal costs in the second year and later are

estimated to be about 25 percent less per dog compared to the first year of implementation.
As discussed in the response to public comments section of the preamble above, the

estimated monetized cost estimate has increased considerably relative to the estimates included

in the NPRM. The primary reasons for the increase in cost include:

• The fees charged by CDC-registered ACF have increased relative to CDC’s

preliminary estimates.

• Some U.S. ports require that dogs that need follow-up care at CDC-registered

ACF arrive as cargo. This requirement was not anticipated by CDC and will

increase costs for importers of foreign-vaccinated dogs from DMRVV high-risk

countries who otherwise would have chosen to transport their dogs as hand-

carried or checked baggage. The fee charged for cargo shipments are highly

variable.251,252 The future costs associated with this rule will depend on U.S. port

policies that are subject to change. The average cost for the follow up visit at

CDC-registered ACF is estimated to be $900 (range: $500 to $1,300 per dog).

The average costs associated with shipping dogs as cargo is estimated to be

$2,000 (range: $1,500 to $2,500) 253 compared to an average of $300 (range:

$200 to $400) for dogs shipped as hand-carried or checked baggage254. Under the

251 http://www.airline-pet-policies.com/united-airlines-pet-policy.php. Accessed 15 Nov 2023.


252 Katie Morrell (March 3, 2021) How Much Does It Cost To Fly With Your Dog on a Plane? Dailypaws.com
https://www.dailypaws.com/living-with-pets/pet-travel/how-much-does-it-cost-to-fly-a-dog-on-a-plane. Accessed:
06 February 2022.
253 Feathers and Fur Express (2023) How much does it cost to fly a pet/s internationally? International Pet Shipping

Costs - Feathers & Fur Express (ffexpresspets.com). Accessed November 10, 2023. Note that the costs reported in
this reference include cargo shipping costs to Germany, the United Kingdom, Japan, and Australia. The reference
includes costs for small and large dogs shipped to each country. Costs are much higher for larger dogs or for dogs
shipped over longer distances. The highest costs were for Australia, which may be more representative of shipping
costs from DMRVV high-risk countries in Africa. The European costs may be similar to shipping costs for dogs
imported from DMRVV high-risk countries in Europe or Central America or South America. The costs for Japan
may be similar to costs for DMRVV high-risk countries in Asia. The simple average cost across the four countries
and dog sizes is $1,931 in 2023 USD. This would correspond to $1,622 in 2020 after adjustment with the consumer
price index: CPI Inflation Calculator (bls.gov). The most likely estimate is increased to $2,000 in case the costs to
importers from DMRVV high-risk countries would be higher than for the countries for which data are available.
This increase from $1,600 to $2,000 would also allow some importers to choose to hire shippers to facilitate the
importation process or brokers to support customs clearance. The need to hire shippers may be reduced by the need
to visit CDC-registered ACF, who may be able to review documentation in advance of arrival when reservations are
made.
254 http://www.airline-pet-policies.com/united-airlines-pet-policy.php. Accessed 15 Nov 2023.
regulatory baseline, HHS/CDC assumes 25%, range: 17% to 50% of dogs going

to ACF are shipped as cargo. With the final rule, HHS/CDC assumes that 60%,

range: 60% to 70% of dogs going to ACF will be shipped as cargo.

• The cost estimate for foreign-vaccinated dogs from DMRVV high-risk countries

to re-route travel destinations to arrive at authorized U.S. ports with ACF was

increased.

• The costs associated with the requirement for proof that a dog has been only in

DMRVV low-risk or DMRVV-free countries have increased because HHS/CDC

added more examples of the types of proof required. Each type of document

requires certification by a USDA or foreign official government veterinarian.

Examples include: a) a valid foreign export certificate from a DMRVV-free or

DMRVV low-risk country that has been certified by an official government

veterinarian in that country; b) a USDA export certificate if the certificate is

issued to allow the dogs to travel to a DMRVV-free or DMRVV low-risk country,

c) a valid Certification of Foreign Rabies Vaccination and Microchip form if

completed in a DMRVV-free or DMRVV low-risk country, or d) a valid

Certification of U.S.-Issued Rabies Vaccination form. These documents are often

required for individuals to travel internationally with their pets but are not

required for travel to Canada or Mexico. These documents may be used as long as

they specify travel to or from the country from which a dog is imported.

Individuals who frequently travel to and from Canada and Mexico (or any other

country) can obtain a valid Certification of U.S.-Issued Rabies Vaccination form,

which will remain valid for multiple trips for up to three years corresponding to

the duration of protection for dog rabies vaccines.


• CDC increased the estimated costs associated with shipping blood samples to

CDC-approved laboratories for serological testing based on a number of

comments from individuals suggesting their shipping costs were higher.

• CDC changed the requirement for importing dogs from DMRVV-free or low-risk

countries such that no dogs less than six months may be imported at land borders.

This will increase costs for individuals who wish to travel with their young dogs

to or from Canada and Mexico.

• CDC increased the estimated costs to airlines by 100% for dogs imported from

DMRVV-free or low-risk countries and by 50% for dogs imported from DMRVV

high-risk countries to account for a number of commenters who suggested that

costs to airlines should be higher than the estimates included in the NPRM

analysis.

Some of the cost estimates for the final rule have also decreased due to changes made

between the NPRM and the final rule. These include:

• The costs to importers of U.S.-vaccinated dogs from DMRVV high-risk countries were

reduced because the final rule will not require that such dogs arrive at U.S. ports with

CDC quarantine stations (also known as CDC port health stations).

• The costs for serological testing for foreign-vaccinated dogs from DMRVV high-risk

countries were reduced because CDC plans to implement a policy that only one

serological test will be required during the lifetime of such dogs as long as they remain

current with their rabies vaccinations.

The most significant increase in estimated costs is for importers of foreign-vaccinated

dogs from high-risk countries, because the expected fees charged by CDC-registered ACF have

increased and because some U.S. ports or ACF now require dogs who need to visit to CDC-

registered ACF to be shipped as cargo. HHS/CDC did not anticipate that some U.S. ports would
require that dogs going to ACF be shipped as cargo in analyzing costs for the NPRM. Other U.S.

ports do not require dogs going to ACF to be shipped as cargo. U.S. port-specific policies may

change in the future, which, in conjunction with the uncertainty around the number of dogs

imported, significantly complicates the project of future costs for the requirements in the final

rule. As of March 2024, one U.S. port requires dogs going to ACF to be shipped as cargo, one

U.S. port recommends dogs be shipped as cargo to avoid clearance delays and four U.S. ports do

not have requirements or recommendations for shipping dogs as cargo. In total six U.S. ports

have CDC-registered ACF.

The next key change, which will increase the costs for importers of dogs from DMRVV-

free or low-risk countries. In response to public comment, HHS/CDC further defined the

required documentation needed for importers to prove that a dog has been only in DMRVV low-

risk or DMRVV-free countries. For the NPRM, HHS/CDC had assumed that veterinary records

from DMRVV-free or low-risk countries would be sufficient. However, after observing a

number of importers using fraudulent documentation to circumvent requirements for DMRVV

high-risk countries by moving dogs to DMRVV-free or low-risk countries prior to entering the

United States. As a result, HHS/CDC is requiring at least one record certified by an official

veterinarian in § 71.51(u). A second change is that HHS/CDC is eliminating the exemption for

importers of dogs from DMRVV-free or low-risk countries to import three or fewer dogs less

than six months of age at land borders. Both of these changes will increase costs to importers of

dogs from DMRVV-free or low-risk countries and these changes are reflected in the higher-cost

estimates. More information regarding these cost estimates is available in the Appendix found in

the Supplemental Materials tab in the docket.

The estimates summarized below are subject to a great degree of uncertainty. CDC does

not know how many dogs any small individual entity currently imports or the average number of

imported dogs across entities. However, based on the relative estimates of annual revenues by

type of entity and subdivided by the number of employees, CDC calculated how many dogs each
entity could import before this final rule would have a significant economic impact on their

businesses.

Small entities that import dogs for commercial purposes


The estimated revenues of small businesses likely to import and resell dogs are

summarized in Table 9. Since there are no specific codes in the North American Industry

Classification System (NAICS) specific to dog importers, CDC used the codes 115210, 423820,

424990, 485991, 812910, and 813312 to estimate the revenue of the small businesses that may

import and resell dogs. The businesses affected by the final rule would be a fraction of the firms

summarized in Table 9, as CDC does not know how many dog importers are in these categories.

Small business status was determined based on either firms’ revenue or the numbers of

employees, according to the Small Business Association’s (SBA) table of small business size

standards.255 The revenue of firms in each business category subdivided by the number of

employees was not available. Using annual payroll data from the Statistics of U.S. Businesses

(SUSB),256 CDC estimated the revenue based on the assumption that each firm’s payroll expense

would be approximately 15 to 30 percent.257

Table 9. Estimated revenue of small businesses that may import dogs for commercial
purposes, 2020 USD
Annual Revenue per firm (thousand USD)a
payroll
per Most
firm Lower Upper likely
Number (thousa bound bound estimate
NAICS of nd (Payroll/ (Payroll/1 (midpoint
code Description employees Firms USD) 30%) 5%) )
Support <5 3,633 $48 $161 $321 $241
Activities for 5-9 585 $181 $605 $1,210 $907
Animal 10-19 238 $406 $1,355 $2,709 $2,032
115210 Production 20-99 118 $1,259 $4,197 $8,394 $6,296

255 SBA, Table of small business size standards. Effective August 19, 2019. https://www.sba.gov/document/support-
table-size-standards.
256 2019 SUSB Annual Data Tables by Establishment Industry.

https://www.census.gov/data/tables/2019/econ/susb/2019-susb-annual.html.
257 How to figure the gross percent of payroll. https://smallbusiness.chron.com/figure-gross-percent-payroll-

66395.html.
Farm and <5 1,808 $90 $300 $599 $450
Garden 5-9 958 $308 $1,026 $2,053 $1,539
Machinery 10-19 835 $693 $2,309 $4,619 $3,464
and
Equipment
Merchant
423820 Wholesalers 20-99 820 $2,094 $6,980 $13,960 $10,470
Other <5 7,068 $75 $249 $499 $374
Miscellaneou 5-9 1,493 $299 $996 $1,992 $1,494
s Nondurable 10-19 791 $657 $2,191 $4,383 $3,287
Goods
Merchant
424990 Wholesalers 20-99 670 $1,755 $5,850 $11,700 $8,775
<5 1,553 $55 $184 $368 $276
Special Needs 5-9 554 $148 $493 $986 $740
Transportatio 10-19 500 $338 $1,127 $2,254 $1,691
485991 n 20-99 611 $1,050 $3,500 $6,999 $5,249
Pet Care <5 12,257 $43 $142 $283 $213
(except 5-9 4,026 $140 $466 $931 $698
Veterinary) 10-19 2,580 $280 $932 $1,863 $1,398
812910 Services 20-99 1,213 $663 $2,210 $4,421 $3,316
Environment, <5 3,575 $75 $249 $498 $373
Conservation 5-9 1,262 $263 $875 $1,751 $1,313
and Wildlife 10-19 922 $516 $1,720 $3,441 $2,580
813312 Organizations 20-99 745 $1,551 $5,169 $10,338 $7,754

aRevenue was estimated from the annual payroll reported in the 2019 SUSB Annual Data
Tables by Establishment Industry (https://www.census.gov/data/tables/2019/econ/susb/2019-
susb-annual.html). Estimated were updated to 2020 USD using the Consumer Price Index for
All Urban Consumers (CPI-U).

CDC assumes that the costs associated with the provisions of the final rule would be

significant if the additional costs would exceed two percent of the estimated revenue shown in

Table 9 by category. Unless a small entity only specializes in importing dogs for resale or

adoption, the costs associated with dog importation would only constitute a portion of each

firm’s operational costs. Other operational costs by an entity should be unaffected by the

provisions included in this final rule. CDC is unaware of the proportion of dog import costs

relative to all the other activities for each type of entity. Thus, CDC is not able to directly

estimate the impact of the final rule as a fraction of total revenue. Instead, CDC calculates a

threshold for each category representing the number of imported dogs at which the cost of the

provisions in the final rule to importers would begin to exceed two percent of the revenue of
firms in each category. To calculate the number of dogs at which point the costs associated with

the final rule would be likely to exceed two percent of revenue for each category of the firm, the

category-specific revenue per firm in Table 9 (most likely estimate, lower bound, and upper

bound) were multiplied by 2 percent and then divided by the marginal cost per foreign-

vaccinated dog from high-risk countries ($1,910, range: $910 to $3,800 per dog). This was

repeated for U.S.-vaccinated dogs from DMRVV high-risk countries ($41, range: $15 to $73)

and dogs from DMRVV-free or DMRVV low-risk countries ($23, range: $7.70 to $48).

The estimated thresholds for the number of Imported dogs per firm for each small

business category are summarized in Tables 10a and 10b. For example, if a wildlife organization

(NAICS code 813312) with fewer than five employees imports more than 3.9 foreign-vaccinated

dogs (most likely final rule cost estimate and midpoint revenue estimate) from high-risk

countries, the costs associated with the final rule would be expected to exceed two percent of

revenue. For U.S.-vaccinated dogs, the threshold would increase from about four dog imports to

182 dog imports using the most likely cost estimate and midpoint revenue estimate. This NAICS

category may include dog rescue organizations that are likely to work with dogs imported from

DMRVV high-risk countries, most or all of which would be foreign vaccinated. Because the

marginal cost estimate per dog imported from DMRVV-free or DMRVV low-risk countries is

much less than per dog imported from DMRVV high-risk countries, the threshold numbers of

dogs that may be imported from DMRVV-free or DMRVV low-risk countries are much greater

than for DMRVV high-risk countries.

The values shown in Tables 10a and 10b are estimated by assuming that all dogs

imported by each firm are either from DMRVV-free or DMRVV low-risk countries or,

alternatively, from DMRVV high-risk countries. Some firms may import dogs from both types

of countries, in which case, the threshold values would be in between the two sets of estimates.

The difference in costs may also cause some entities to shift from importing dogs from DMRVV

high-risk countries to dogs imported from DMRVV-free or DMRVV low-risk countries. In this
case, for a business with NAICS code of 813312, the estimated threshold number of dogs would

increase from four imported foreign-vaccinated dogs from DMRVV high-risk countries to 327

dogs imported from DMRVV-free or DMRVV low-risk countries (both thresholds calculated

using most likely final rule cost estimate and midpoint revenue estimate).

Table 10a. Estimated threshold for the number of imported dogs from DMRVV high-risk
countries per firm at which final rule costs would exceed two percent of revenue during the
first year of implementation of the requirements
Foreign-vaccinated dogs U.S.-vaccinated dogs from
from high-risk countries high-risk countries
Most Most
Number of likely Lower Upper likely Lower Upper
NAICS code employees estimate bound bound estimate bound bound
Marginal final rule cost per
dog (USD)) $1,913 $912 $3,776 $41 $15 $73
Number of imported dogs per year at which final rule cost > 2 percent of revenue
115210, <5 2.5 3.5 1.7 117.7 218.7 88.3
Support 5-9 9.5 13.3 6.4 443.0 821.9 332.7
Activities for 10-19 21.2 29.7 14.3 992.5 1840.9 744.8
Animal
Production 20-99 65.8 92.1 44.5 3075.2 5702.0 2307.8
423820, <5 4.7 6.6 3.2 219.8 407.6 164.7
Farm and 5-9 16.1 22.5 10.9 751.7 1393.9 564.4
Garden 10-19 36.2 50.6 24.5 1692.0 3137.0 1269.9
Machinery and
Equipment
Merchant
Wholesalers 20-99 109.5 153.1 73.9 5114.0 9483.0 3838.1
424990, <5 3.9 5.5 2.6 182.7 338.3 137.2
Other 5-9 15.6 21.8 10.6 729.7 1353.2 547.7
Miscellaneous 10-19 34.4 48.1 23.2 1605.5 2976.7 1205.0
Nondurable
Goods Merchant
Wholesalers 20-99 91.7 128.3 62.0 4286.1 7947.8 3216.7
<5 2.9 4.0 1.9 134.8 250.0 101.2
485991, 5-9 7.7 10.8 5.2 361.4 669.8 271.1
Special Needs 10-19 17.7 24.7 11.9 826.0 1531.1 619.7
Transportation 20-99 54.9 76.8 37.1 2563.8 4755.1 1924.3
812910, <5 2.2 3.1 1.5 104.0 192.9 77.8
Pet Care (except 5-9 7.3 10.2 4.9 340.9 633.1 256.0
Veterinary) 10-19 14.6 20.4 9.9 682.8 1266.2 512.2
Services 20-99 34.7 48.5 23.4 1619.7 3002.5 1215.5
813312, <5 3.9 5.5 2.6 182.2 338.3 136.9
Environment, 5-9 13.7 19.2 9.3 641.3 1188.8 481.4
Conservation 10-19 27.0 37.7 18.2 1260.2 2336.8 946.0
and Wildlife
Organizations 20-99 81.1 113.4 54.8 3787.4 7022.6 2842.3
Table 10b. Estimated threshold for the number of imported dogs from DMRVV-free or
DMRVV low-risk countries per firm at which final rule costs would exceed two percent of
revenue during the first year of implementation of the requirements
Dogs from DMRVV-free or low-risk countries
Number of Most likely Lower
NAICS code employees estimate bound Upper bound
Marginal final rule cost per dog
(USD) $22.81 $7.74 $47.50
Number of imported dogs per year at which final rule cost > two percent of revenue
115210, <5 211 416 135
Support Activities 5-9 795 1,563 510
for Animal 10-19 1,782 3,501 1,141
Production 20-99 5,520 10,844 3,535
423820, <5 395 775 252
Farm and Garden 5-9 1,349 2,651 864
Machinery and 10-19 3,037 5,966 1,945
Equipment
Merchant
Wholesalers 20-99 9,180 18,034 5,878
424990, <5 328 643 210
Other Miscellaneous 5-9 1,310 2,573 839
Nondurable Goods 10-19 2,882 5,661 1,846
Merchant
Wholesalers 20-99 7,694 15,114 4,927
<5 242 475 155
485991, 5-9 649 1,274 415
Special Needs 10-19 1,483 2,912 949
Transportation 20-99 4,602 9,043 2,947
<5 187 367 119
812910, 5-9 612 1,204 392
Pet Care (except 10-19 1,226 2,408 784
Veterinary) Services 20-99 2,907 5,710 1,862
813312, <5 327 643 210
Environment, 5-9 1,151 2,261 737
Conservation and 10-19 2,262 4,444 1,449
Wildlife
Organizations 20-99 6,799 13,355 4,353

The marginal cost per dog imported for the final rule relative to the reported commercial

values of imported dogs are estimated using data from CBP for dogs imported under Harmonized

Tariff Schedule code 0106.19.91.20, Other live animals, Other, Other, Dogs is shown in Table

11. The estimated ratio of the marginal cost of final rule requirements relative to the reported

value of the commercially imported dogs from DMRVV-free or DMRVV low-risk countries is
2.9 percent (range: 1.0 percent to 6.1 percent). Based on this ratio, the expected marginal

increase in cost per dog imported should not change much for dogs imported from DMRVV-free

or low-risk countries.

However, for the foreign-vaccinated dogs imported from DMRVV high-risk countries,

the estimated ratio is 536 percent (range: 256 percent to 1059 percent). This ratio is much larger

both because the marginal cost per dog imported for the final rule is much greater and because

the reported commercial value of dogs imported from DMRVV high-risk countries is lower

compared to dogs imported from DMRVV-free or low-risk countries. Since CBP’s commercial

values of imported dogs only provide a comparison of the estimated marginal cost of the final

rule to reported commercial value, these ratios cannot be directly compared to the revenue

estimates by firm since the costs associated with dog imports would only be a portion of each

firm’s operational cost. However, it does provide an estimate of the potential increase in cost per

dog imported from either DMRVV-free or low-risk countries or from DMRVV high-risk

countries for the final rule. For this analysis, CDC assumes that most of the dogs imported from

DMRVV high-risk countries for commercial purposes would have been vaccinated outside the

United States.

Table 11. Estimated impact of the final rule on the cost per dog imported for commercially
imported dogs (2020 USD)
Most likely
Lower bound Upper bound
estimate
Importers from DMRVV-free or low-risk countries
Baselinea
- Total dogs imported over three years
(A) 57,860 - -
- Average commercial value per dog
(B) $777 - -
- Total commercial value
(C)=(A)×(B) $44,957,220 - -
With final rule
- Estimated marginal final rule cost
per dog imported (D) $22.81 $7.74 $47.50
- Total marginal final rule costs for
dogs imported for commercial purposes
(E)=(D)×(A) $1,319,800 $447,893 $2,748,194
Estimated ratio of marginal final rule
costs to commercial value of
imported dogs (E)/(C) 2.94% 1.00% 6.11%
Importers from high-risk countries of foreign-vaccinated dogs
Baselinea
- Total dogs imported over three years
(F) 43,382 - -
- Average commercial value per dog
(G) $357 - -
- Total commercial value
(H)=(F)×(G) $15,468,053 - -
With final rule
- Estimated marginal final rule costs
per dog imported (I) $1,913 $912 $3,776
- Total marginal final rule costs for
dogs imported for commercial purposes
(J)=(I)×(F) $82,983,095 $39,558,297 $163,801,943
Estimated ratio of marginal final rule
costs to commercial value of
imported dogs (J)/(H) 536% 256% 1059%
a Baseline values were based on the data received from CBP, not publicly available (HTS

code 0106.19.91.20).

U.S. Airlines
The provisions of this final rule would affect U.S. airlines conducting international flight

operations arriving in the United States. Of the 60 U.S. airlines with international flights in 2020,

35 airlines can be identified as small business entities. This is based on the size standard of

“fewer than 1,500 employees” from the SBA for small businesses within NAICS Code 481111,

Scheduled Passenger Air Transportation, and those within NAICS Code 481211, Nonscheduled

Chartered Passenger Air Transportation in 2019.258 For the analysis, airline employee counts

were estimated from the U.S. Department of Transportation’s Bureau of Transportation

Statistics.259 Monthly average numbers of employees in 2019, including part- and full-time

employment, were used for U.S. airlines.

258 Small Business Association (SBA), Table of small business size standards. Effective August 19, 2019.
https://www.sba.gov/document/support-table-size-standards. Accessed: February 21, 2022.
259 Bureau of Transportation Statistics. Air Carrier Financial Reports (Form 41 Financial Data). Air Carrier

Financial: Schedule P-1(a) Employees. Bureau of Transportation Statistics.


https://www.transtats.bts.gov/DL_SelectFields.asp?gnoyr_VQ=GEF&QO_fu146_anzr=Nv4percent20Pn44vr4perce
nt20Sv0n0pvny. Accessed: February 21, 2022.
The annual revenue per U.S. airline was estimated based on the 2019 revenue of each

airline.260 Lower-bound and upper-bound estimates were calculated by multiplying by 75 and

125 percent (Table 12). Among the selected 35 airlines, seven had zero U.S. international

arrivals in 2019.261

Table 12. Estimated annual revenue of small business U.S. airlines


Total revenue (million USD)
2019 U.S.
Most likely
arrivals
Airline estimate Lower bound Upper bound
1 $290 $218 $363 317
2 $78 $58 $97 279
3 $112 $84 $140 169
4 $241 $181 $301 136
5 $38 $28 $47 116
6 $44 $33 $55 114
7 $230 $173 $288 113
8 $541 $406 $677 111
9 $218 $164 $273 96
10 $115 $87 $144 86
11 $558 $419 $698 80
12 $1,296 $972 $1,620 75
13 $42 $31 $52 73
14 $52 $39 $66 57
15 $169 $127 $212 57
16 $37 $28 $46 55
17 $104 $78 $130 49
18 $147 $110 $183 46
19 $265 $199 $331 45
20 $7 $6 $9 41
21 $40 $30 $50 40
22 $2 $1 $2 31
23 $105 $79 $131 18
24 $59 $44 $74 13
25 $20 $15 $25 12
26 $19 $14 $23 6
27 $9 $7 $12 2
28 $313 $235 $391 1
29 $12 $9 $14 0

260 Bureau of Transportation Statistics. Air Carrier Financial Reports (Form 41 Financial Data). Air Carrier
Financial: Schedule P-1.1, and P-1.2 Operating revenues.
https://www.transtats.bts.gov/DL_SelectFields.asp?gnoyr_VQ=FMD&QO_fu146_anzr=Nv4percent20Pn44vr4perc
ent20Sv0n0pvny; and
https://www.transtats.bts.gov/DL_SelectFields.asp?gnoyr_VQ=FMI&QO_fu146_anzr=Nv4percent20Pn44vr4perce
nt20Sv0n0pvny. Accessed: February 21, 2022.
261 Air Carriers: T-100 International Market (U.S. Carriers Only)

https://www.transtats.bts.gov/DL_SelectFields.asp?gnoyr_VQ=GDJ&QO_fu146_anzr=Nv4percent20Pn44vr45.
Accessed: February 21, 2022.
30 $115 $86 $143 0
31 $117 $88 $146 0
32 $13 $10 $16 0
33 $10 $7 $12 0
34 $21 $16 $27 0
35 $19 $14 $23 0

The threshold numbers of dogs that may be transported by each airline such that the costs

associated with the provisions of this final rule to airlines would be less than two percent of

annual revenue are estimated using the same methodology as for the dog importers above. The

annualized marginal cost per dog transported by airlines is estimated to be about $12.81 per dog

(range: $7.12 to $20.42 per dog) for the requirements in the final rule. This is calculated based on

the annualized costs to airlines divided by the number of dogs transported. However, costs are

estimated to be higher in the first year of implementation and some airlines may be

disproportionately affected if their customers are proportionally more likely to reduce the

number of dogs transported to the United States. The estimated number of dogs is calculated by

multiplying the revenue per airline in Table 12 by two percent and then dividing by the marginal

airline cost per dog imported in the final rule. As shown in Table 13, the estimated numbers of

dogs that each airline could transport were significantly greater than the number of international

passengers reported in 2019 and, in most cases, greater than the total estimated number of dogs

estimated to be imported into the United States each year.

CDC did not separately estimate marginal costs to airlines for dogs imported from

DMRVV-free or DMRVV low-risk countries versus dogs imported from DMRVV high-risk

countries. The estimated marginal cost per dog is higher for airlines to transport dogs imported

from DMRVV high-risk countries because dogs from these countries are more likely to be

denied entry and abandoned by importers. Thus, marginal costs will be higher for airlines that

specialize in travel to DMRVV high-risk countries. However, the general finding still holds that

the provisions of this final rule should not have a significant impact on airlines. Smaller airlines

will also be eligible to receive a waiver for the bill of lading requirements included in §
71.51(dd). This should help to reduce the costs of this requirement during the period shortly after

the final rule goes into effect since it would allow smaller airlines more time to comply.

Table 13. Estimated threshold of the annual number of imported dogs per airline at
which the marginal costs of the final rule begin to exceed 2 percent of annual revenue

Most likely 2019 U.S.


Airline estimate Lower bound Upper bound arrivals
Marginal final rule
cost per dog $12.81 $7.12 $20.42 -
Annual number of transported dogs at which final rule cost > 2 percent of annual
revenue
1 452,883 612,673 355,528 317
2 121,810 163,005 95,003 279
3 174,907 236,076 137,118 169
4 376,362 508,687 294,804 136
5 59,343 78,692 46,033 116
6 68,713 92,744 53,868 114
7 359,183 486,204 282,072 113
8 844,862 1,141,033 663,064 111
9 340,443 460,910 267,380 96
10 179,592 244,507 141,036 86
11 871,410 1,177,568 683,632 80
12 2,023,920 2,731,734 1,586,653 75
13 65,590 87,123 50,930 73
14 81,207 109,607 64,641 57
15 263,922 356,924 207,636 57
16 57,782 78,692 45,053 55
17 162,413 219,213 127,324 49
18 229,565 309,147 179,233 46
19 413,842 559,275 324,186 45
20 10,932 16,863 8,815 41
21 62,467 84,313 48,971 40
22 3,123 2,810 1,959 31
23 163,975 222,024 128,303 18
24 92,138 123,659 72,477 13
25 31,233 42,156 24,485 12
26 29,672 39,346 22,527 6
27 14,055 19,673 11,753 2
28 488,802 660,450 382,951 1
29 18,740 25,294 13,712 0
30 179,592 241,697 140,056 0
31 182,715 247,317 142,995 0
32 20,302 28,104 15,671 0
33 15,617 19,673 11,753 0
34 32,795 44,967 26,444 0
35 29,672 39,346 22,527 0

C. Paperwork Reduction Act of 1995

HHS/CDC has determined that this rule includes information collections and

recordkeeping requirements that are subject to review by the Office of Management and Budget

(OMB) under the Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3501-3520). A

description of these provisions is given below, with an estimate of the annual reporting and

recordkeeping burden. Included in the estimate is the time for reviewing instructions, searching

existing data sources, gathering and maintaining the data needed, and completing and reviewing

each collection of information. Comments are invited on the following subjects:

• Whether the collection of information is necessary for the proper performance of the

functions of CDC, including whether the information will have practical utility.

• The accuracy of CDC's estimate of the burden of the collection of information.

• Ways to enhance the quality, utility, and clarity of the information to be collected.

• Ways to minimize the burden of the collection of information on respondents, including

by using information technology.

Under the PRA, Federal agencies must obtain approval from OMB for each collection of

information they conduct or sponsor. In the NPRM, HHS/CDC published a 60-day notice in the

Federal Register concerning the collection of information related to proposed updates to 42 CR

71.50 and 71.51. HHS/CDC addressed all comments above in Section VI. To comply with this

requirement, OMB is publishing a notice of a revised data collection in conjunction with this

final rule.

Data Collection
Importation Regulations (42 CFR 71 Subpart F) OMB Control No. 0920-1383, Exp. 1/31/2026)

– Revision – National Center for Emerging and Zoonotic Infectious Diseases (NCEZID), Centers

for Disease Control and Prevention (CDC).

Background and Brief Description

This information collection is a Revision to OMB Control No. 0920-1383 related to the

importation of animals, animal products, and human remains. Section 361 of the PHS Act (42

U.S.C. 264) authorizes the Secretary of HHS to make and enforce regulations necessary to

prevent the introduction, transmission, or spread of communicable diseases from foreign

countries into the United States. The existing regulations governing foreign quarantine activities

(42 CFR 71) authorize quarantine officers (also known as port health officers) and other U.S.

government personnel to inspect and undertake necessary control measures with respect to

conveyances, persons, shipments of animals, articles, and other items to protect the public’s

health.

CDC regulations govern the importation of animals and animal products capable of

causing human disease. Animals that are regulated by CDC include dogs, cats, turtles, nonhuman

primates (NHPs), civets (and other animals in Family Viverridae), African rodents, and bats.

CDC controls the importation of these animals to ensure that these animals, or animal products,

imported into the United States meet requirements of CDC regulations. CDC does this through a

permitting process for certain animals.

HHS/CDC is adding or amending the following information collection instruments:

• CDC is adding a form titled Certification of Foreign Rabies Vaccination and

Microchip form. This form will capture the rabies vaccination and microchip

information for foreign-vaccinated dogs and it must be completed by an


authorized veterinarian and certified by a government official from the exporting

country. CDC is including certification by an exporting country to prevent fraud

and falsification of documentation.

• CDC is adding a new form titled Certification of U.S.-issued Rabies Vaccination.

This is a standardized form to capture rabies vaccination information for U.S-

vaccinated dogs. It must be completed by a USDA-accredited veterinarian and

endorsed by USDA during the exportation process to prevent fraud and

falsification of documentation. CDC is creating this standardized form to assist

importers in ensuring they provide all required information and to prevent fraud

and falsification of documentation.

• CDC is adding the new form titled Certification of Dog Arriving from DMRVV-

free or DMRVV low-risk Country form. The form can be used to demonstrate that

a dog has not been in a DMRVV high-risk country within the last six months if

accompanied by veterinary records or proof of payment for veterinary services

establishing that veterinary services were performed in a DMRVV-free or

DMRVV low-risk country at least six months before traveling to the United

States. This form must be completed by an Authorized Veterinarian and must be

certified by an Official Government Veterinarian in the exporting country. This is

one option among multiple options that importers of dogs from DMRVV-free or

DMRVV low-risk countries can use to certify that their dog has not been in a

DMRVV high-risk country within the last six months. Since this is one of

multiple options, CDC is estimating that only a small percentage of importers of

dogs from these countries will use this form. Additional options for these

importers are outlined in technical instructions.

• CDC will continue using the Application for Special Exemption for a Permitted

Dog Import until the expiration of the temporary suspension on July 31, 2024.
Applicants complete this form to apply for a CDC Dog Import Permit. CDC has

been issuing CDC Dog Import Permits to importers of foreign-vaccinated

personal pet dogs with a valid rabies vaccine and serologic titer results during the

temporary suspension. CDC will discontinue issuing permits to that category of

importer once this final rule goes into effect on August 1, 2024. Starting August

1, 2024, CDC will instead use this form to issue permits to importers of dogs from

DMRVV-restricted countries. Since CDC is not adding any countries to the

DMRVV-restricted country in concurrence with the publication of this rule, CDC

does not anticipate using this form in 2024.

• CDC is adding a new form - CDC Dog Import Form - which will collect

information similar to what is currently approved to be collected on the

Application for Special Exemption for a Permitted Dog Import form. The CDC

Dog Import Form is an online form that all importers must complete for each dog

imported. It collects contact information for the importer and details about the dog

being imported. CDC has added this form to gather data on the number of annual

importations of dogs as well as where they originate. This information will assist

CDC in its public health investigations related to imported dogs with

communicable diseases.

• CDC is adding four new forms related to CDC-registered animal care facilities.

Per this final rule, CDC-registered animal care facilities are facilities that are

registered with CDC for the revaccination, examination, and quarantine (if

applicable) of foreign-vaccinated dogs from DMRVV high-risk countries. In

order to register with CDC, representatives of the facility need to complete and

sign the following documents to attest to their understanding of the requirements

and recommendations for CDC-registered Animal Care Facilities.

o Application to Operate as a CDC-registered Animal Care Facility


o Technical Instructions for CDC-Registered Animal Care Facilities (ACF)

o Standard Operating Procedures for SAFE TraQ data use by CDC-

registered Animal Care Facilities Participating in Public Health

Evaluations of Imported Animals

o Rules of Behavior Agreement for Access to Centers for Disease Control

and Prevention (CDC) Division of Global Migration Health (DGMH)

System for Animal Facility Electronic Tracking of Quarantine (SAFE

TraQ)

• CDC will make available to air carriers two new forms to assist in the

implementation of our requirements for dogs arriving into the United States. Both

forms are optional and may be filled out by the air carriers to help them ensure

dogs flown on their flights meet entry requirements. One form is for dogs flown

as checked baggage or carried-on and the other form is for dogs flown as cargo.

• CDC may collect information from air carriers that are unable to complete a bill

of lading for all dogs arriving into the United States on their flights. In order to

transport dogs, these air carriers must request a waiver from CDC by submitting

the information outlined in the document titled Technical Instructions for Air

Carriers that are Unbale to Create Air Waybills.

In addition to the forms listed above related to the importation of dogs, CDC is also

revising the following forms related to the importation of nonhuman primates (NHP). These are

existing forms currently approved under this information collection. All edits are minor and non-

substantive.

• CDC Notification of Proposed Nonhuman Primate (NHP) Importation to the United

States

• Application for Registration as an Importer of Nonhuman Primates


• Registration Form for NHP Importation (Part 2 – Full Quarantine Standard Operating

Procedures)

• Registration Form for NHP Importation (Part 2 – Lab-to-Lab Standard Operating

Procedures

• Registration Form for NHP Importation (Part 2- Zoo-to-Zoo Standard Operating

Procedures)

The burden table below has been updated to reflect updated burden hours for the new and

amended forms.

Estimated Annualized Burden Hours

Average
No. of Burden
Responses per Total
Type of No. of per Response Burden
Respondents Form Name Respondents Respondent (in hours) Hours
Application for
Importers of
Special
Foreign-
Exemption for a
Vaccinated
Permitted Dog
Dogs from
Import
DMRVV high-
risk countries* (Attachment 6) 15,000 1 60/60 15,000
Veterinarians
CDC Rabies
of Foreign-
Vaccination and
Vaccinated
Microchip
Dogs from
Record
DMRVV high-
risk countries* (Attachment 8) 15,000 1 15/60 3,750
Veterinarians
of U.S.
Vaccinated U.S. Rabies
Dogs from Vaccination
DMRVV high- certificate (no
risk countries* form) 3,000 1 15/60 750
CDC Dog
Import Form
All Dog
Importers (Attachment 7) 750,000 1 7/60 87,500
Veterinarians
of Dogs from
DMRVV-free
and low-risk
countries and
Official
Government
Veterinarians
Certification of
in Exporting
Dog Arriving
Country of
from DMRVV-
Dogs from
free or Low-risk
DMRVV-free
Country
or low-risk
countries (Attachment 9) 1,382,000 1 15/60 345,000
Veterinarians
of Foreign-
Vaccinated
Dogs and
Government
Veterinarians
Certification of
in Exporting
Foreign Rabies
Country of
Vaccination and
Foreign-
Microchip form
Vaccinated
Dogs (Attachment 10) 52,000 1 15/60 13,000
Certification of
U.S.-Issued
Rabies
Vaccination
USDA-
form
accredited
veterinarians (Attachment 11) 33,000 1 30/60 16,500
Importers of
foreign- Titer results
vaccinated from CDC-
dogs from approved
high-risk laboratory (no
countries form) 25,000 1 30/60 256,000
CDC Airline Job
Aid for Dogs
Air Carriers
Imported as
Transporting
Cargo
Dogs into the
U.S. (Attachment 16) 223 224 5/60 4,163
CDC Airline Job
Aid for Dogs
Imported as
Hand-Carried or
Air Carriers
Checked
Transporting
Baggage
Dogs into the
U.S. (Attachment 17) 223 1,121 5/60 20,382
Technical
Instructions for
Air Carriers that
are Unable to
Create Air
Waybills
Air Carriers (Attachment 18) 10 1 120/60 20
Application to
Operate as a
CDC-registered
Animal Care
Animal Care
Facility
Facility
Applicant (Attachment 12) 10 1 120/60 20
Rules of
Behavior
Agreement for
Access to the
Centers for
Disease Control
and Prevention
Division of
Global Migration
Health System
for Animal Care
Facility
Electronic
Tracking of
Quarantine
Animal Care
(SAFE TRaQ)
Facility
Applicant (Attachment 13) 10 1 5/60 1
Standard
Operating
Procedures for
SAFE TRaQ use
by CDC-
Registered
Animal Care
Facilities
Participating in
Public Health
Evaluations of
Imported
Animal Care
Animals
Facility
Applicant (Attachment 14) 10 1 10/60 2
Technical
Instructions for
CDC-registered
Animal Care
Animal Care
Facilities (ACF)
Facility
Applicant (Attachment 15) 10 1 10/60 2
Application for
Registration as
an Importer of
Nonhuman
Primates
NHP Importer
Applicant (Attachment 19) 5 1 30/60 3
CDC
Notification of
Proposed
Nonhuman
Primate (NHP)
Importation to
the United States
NHP Importer (Attachment 20) 25 6 15/60 38
Registration
Form for NHP
Importation Part
2 - Full
Quarantine
Standard
NHP Importer Operating
Applicant Procedures 25 1 120/60 50
(Attachment 21)

Registration
Form for NHP
Importation Part
2 – Lab-to-Lab
Standard
Operating
Procedures
NHP Importer
Applicant (Attachment 22) 5 1 120/60 10
Registration
Form for NHP
Importation Part
2 – Zoo-to-Zoo
Standard
Operating
Procedures
NHP Importer
Applicant (Attachment 23) 10 1 120/60 20
Request to
Importers of
Import CDC-
Turtles, Civets,
Regulated
African
Animals
Rodents, and
Bats (Attachment 24) 15 1 15/60 4

Record of
Dog and Cat sickness or death
Importers (no form) 50 1 30/60 25

Human Provide death


Remains certificate (no
Importers form) 50 1 15/60 13
Statement or
documentation
Importer of of non-
Animal infectiousness
Products (no form) 5,000 1 15/60 1,250
Total 533,003
*These forms/information collections will be used during the remainder of the temporary

suspension of dogs entering the United States from countries with a high risk of rabies, which

expires on July 31, 2024. Starting August 1, 2024, the CDC Rabies Vaccination and Microchip

Record form and the U.S. rabies vaccination certificate will no longer be required and collected.

The Application for Special Exemption for a Permitted Dog Import form will only be used for

the importation of dogs from DMRVV-restricted countries after July 31, 2024.

D. National Environmental Policy Act (NEPA)

HHS/CDC has determined that amendments to 42 CFR part 71 will not have a significant

impact on the human environment. Therefore, neither an environmental assessment nor an

environmental impact statement is needed.

E. Executive Order 12988: Civil Justice Reform

HHS/CDC has reviewed this final rule under Executive Order 12988 on Civil Justice

Reform and determines that this rule meets the standard in the Executive Order.

F. Executive Order 13132: Federalism

Under Executive Order 13132, if the rulemaking would limit or preempt State, local, or

Tribal authorities, then a federalism analysis is required. The agency must consult with State,

local, and Tribal officials to determine whether the rule would have a substantial direct effect on

State or local governments, as well as whether it would either preempt State law or impose a

substantial direct cost of compliance on them. HHS/CDC has determined that this final rule will

not have sufficient federalism implications to warrant the preparation of a federalism summary

impact statement.
G. Plain Language Act of 2010

Under 63 FR 31883 (June 10, 1998), Executive Departments and Agencies are required

to use plain language in all proposed and final rules. HHS/CDC has attempted to use plain

language in this regulation to make our intentions and rationale clear.

List of Subjects in 42 CFR Part 71

Airline, Animal, Carrier, Cat, CDC-registered animal care facility, Communicable

diseases, DMRVV, Dog, Dog-maintained rabies virus variant, Entry, Importation, Importer,

Microchip, Necropsy, Port, Public health, Quarantine, Rabies, Rabies vaccination, Rabies virus,

Serologic testing, Titer, Travel, Zoonotic diseases.

For the reasons discussed in the preamble, the Department of Health and Human Services

amends 42 CFR part 71 as follows:

PART 71 — FOREIGN QUARANTINE

1. The authority citation for part 71 continues to read as follows:

Authority: Secs. 215 and 311 of Public Health Service (PHS) Act. as amended

(42 U.S.C. 216, 243); secs. 361-369, PHS Act, as amended (42 U.S.C. 264-272).

1. Amend § 71.50 by:

a. In paragraph (b); adding in alphabetical order definitions for “Authorized

veterinarian”, “Cat”, “Dog”, “Histopathy”, and “In-transit shipment”;

b. Adding in alphabetical order definitions for “Microchip”, “Necropsy”, and “Official

government veterinarian;” and

c. Adding paragraph (c).

The revision and additions read as follows:


§ 71.50 Scope and definitions.

*****

(b) * * *

Authorized veterinarian means an individual who has an advanced degree relevant to the

practice of veterinary medicine, has a valid license or accreditation, and is authorized to practice

animal medicine in the exporting country.

Cat means any domestic cat (Felis catus).

*****

Dog means any domestic dog (Canis familiaris).

*****

Histopathology means the study of changes in human or animal tissues caused by disease.

*****

In-Transit Shipment means a cargo shipment originating in a foreign country that is

moved through one or more U.S. ports while transiting through the United States to a third-

country destination. In-transit shipments pass through a U.S. port of entry and a U.S. port of exit,

which may be in the same location, or which may involve numerous stopping points.

*****

Microchip means an implanted radio-frequency device placed under the skin of an animal

that contains a unique identification tag that meets the International Standards Organization

(ISO) compatibility through ISO 11784 or ISO 11785, or similar technologies as approved by the

Director.

Necropsy means an animal autopsy in which the cause of death may be determined

through the examination and collection, post-mortem, of tissues, organs, or bodily fluids.

Official government veterinarian means a veterinarian who performs work on behalf of

an exporting country’s government and can verify the license or credentials of an authorized

veterinarian.
*****

(c) Any provision of this subpart held to be invalid or unenforceable by its terms, or as

applied to any person or circumstance, shall be construed so as to continue to give the maximum

effect to the provision permitted by law, unless such holding shall be one of utter invalidity or

unenforceability, in which event the provision shall be severable from this subpart and shall not

affect the remainder thereof or the application of the provision to persons not similarly situated

or to dissimilar circumstances.

2. Amend § 71.51 by:

a. In paragraph (a), adding in alphabetical order the definition for “Animal”,

b. Removing the definition for “Cat”;

c. Adding in alphabetical order definitions for “Certification of foreign rabies vaccination

and microchip”, “CDC dog import form”, “CDC dog import permit”, “CDC-registered animal

care facility”, “Certification of dog arriving from DMRVV-free or DMRVV low-risk country”,

“Certification of U.S.-issued rabies vaccination”, and “Conditional release”,

d. Revising the definition of “Confinement”;

e. Removing the definition for “Dog”;

f. Adding in alphabetical order definitions for “DMRVV”, “DMRVV-free country”,

“DMRVV high-risk country”, “DMRVV low-risk country”, and “DMRVV-restricted country”,

“Flight parent”, “Importer”, “SAFE TraQ”, “Serologic testing”, “USDA-accredited

veterinarian”, and “USDA official veterinarian”;

g. Removing the definition for “Valid rabies vaccination certificate”;

h. Removing paragraphs (b) through (g);

i. Adding new paragraphs (b) through (g); and

j. Adding paragraphs (h) through (ff).

The revision and additions read as follows:


§ 71.51 Dogs and cats.

(a) * * *

Animal means, for purposes of this section, any domestic cat (Felis catus) or domestic

dog (Canis familiaris).

Certification of foreign rabies vaccination and microchip means the Office of

Management and Budget (OMB)-approved form that must be:

(i) completed by an authorized veterinarian, which may include an official government

veterinarian, in the exporting country; and

(ii) reviewed and signed by an official government veterinarian in the exporting country

attesting that the information listed is true and correct.

CDC dog import form means an OMB-approved form submitted to CDC through an

online portal that includes the importer’s name and contact information; description of the dog,

including microchip number and current photographs of the dog’s face and body; purpose of

importation; travel information, including dates of departure and arrival, country of departure,

countries the dog has been physically present in within the last six months, and U.S. port of

entry; and other information as described in CDC technical instructions.

CDC dog import permit means a document issued by CDC granting approval to import a

dog into the United States from a DMRVV-restricted country. To receive a permit, eligible

importers submit information to CDC that includes the importer’s name and contact information;

description of the dog, including microchip number and current photographs of the dog’s face

and body; purpose of importation; travel information, including dates of departure and arrival,

country of departure, countries the dog has been physically present in within the last six months,

and U.S. port of entry; and other information as described in CDC technical instructions.

CDC-registered animal care facility means a facility registered by CDC for the purpose

of providing veterinary care and housing to animals imported into the United States.
Certification of dog arriving from DMRVV-free or DMRVV low-risk country means the

OMB-approved form that together with other records may be used by an importer to demonstrate

that a dog has been only in DMRVV-free or DMRVV low-risk countries during the six months

before the dog’s arrival in the United States.

Certification of U.S.-issued rabies vaccination means the OMB-approved form that must

be completed by a U.S. Department of Agriculture (USDA)-Accredited Veterinarian and

endorsed by a USDA Official Veterinarian prior to a dog’s departure from the United States in

order to demonstrate compliance with admissibility requirements upon the dog’s return to the

United States from a DMRVV high-risk country.

Conditional release, when applied to an animal, means the temporary release of an

animal from the custody of a carrier or a CDC-registered animal care facility into the care of a

licensed veterinarian approved by the Director, for the purpose of receiving emergency medical

care or a public health evaluation, pending an admissibility determination or removal of the

animal from the United States. The licensed veterinarian must return conditionally released

animals immediately to the custody of the carrier or the CDC-registered animal care facility upon

the conclusion of such medical care or evaluation.

Confinement, when applied to an animal, means restriction to a building or other

enclosure at a U.S. port or other location approved by the Director, including en route to a

destination, separate from other animals, and from persons except for contact necessary for its

care. If the animal is allowed out of the enclosure, it must be muzzled and kept on a leash.

DMRVV means dog-maintained rabies virus variant and includes any rabies virus variant

that is known or suspected to have an enzootic transmission cycle in which dogs are essential for

the maintenance of the viral variant. This includes epidemiologic situations in which dogs are the

only recognized reservoir species, as well as situations in which dogs and other species (typically

wildlife) both play epidemiologically relevant roles in maintaining enzootic transmission.


DMRVV-free country means a country determined by the Director as not having DMRVV

present based on internationally accepted standards.

DMRVV high-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. A list of the DMRVV high-risk countries is available on CDC’s website.

DMRVV low-risk country means a country determined by the Director as having low risk

for DMRVV transmission based on factors such as the virus being limited to a localized area,

adequacy of surveillance and dog vaccination programs to prevent further geographic

distribution of the virus, and the virus being in a controlled status with the country’s heading

toward eventual DMRVV-free status.

DMRVV-restricted country means a country from which the import of dogs into the

United States has been prohibited or otherwise restricted. Designation of a DMRVV-restricted

country may be based on the country’s export of dogs infected with DMRVV to any other

country within a timeframe determined by the Director or based on the country’s lacking

adequate controls, as determined by the Director, to monitor and prevent the export of dogs to

the United States with falsified or fraudulent rabies vaccination credentials, inaccurate or invalid

rabies vaccination documentation, or other fraudulent, inaccurate, or invalid importation

documents.

Flight parent means any person transporting one or more animals on behalf of an

importer for purposes of resale, adoption, or transfer of ownership. A flight parent is typically

solicited through social media and may be compensated (including through goods and services,

e.g., complimentary airplane ticket, paid baggage fees, other paid fees) or be uncompensated. If

required by USDA, flight parents must possess all required Federal licenses or registrations to

transport animals.
Importer for purposes of this section means any person importing or attempting to import

an animal into the United States, including an owner or a person acting on behalf of an importer,

such as a broker registered with U.S. Customs and Border Protection (CBP) or a flight parent. If

required by USDA, an individual transporting an animal on behalf of an importer, including a

flight parent must possess all required Federal licenses or registrations to transport animals.

*****

SAFE TraQ means CDC’s System for Animal Facility Electronic Tracking of Quarantine

or other system as approved by the Director for tracking pre-clearance management (e.g.,

quarantine, medical examinations, vaccinations, diagnostic testing, screening, and travel

information) of animals arriving in the United States through a CDC-registered animal care

facility.

Serologic Testing, when applied to an imported animal, means a rabies antibody titration

test performed by a CDC-approved rabies laboratory using a CDC-approved technique. The

serology sample must be drawn, submitted, and tested in accordance with CDC technical

instructions. The current list of CDC-approved laboratories is available online on CDC’s

website. CDC will update its website as needed.

USDA-Accredited Veterinarian shall have the same definition as Accredited Veterinarian

under 9 CFR 160.1.

USDA Official Veterinarian means the Animal and Plant Health Inspection Service

(APHIS) veterinarian who is assigned by the USDA Administrator to supervise and perform the

official work of APHIS in any U.S. State or several U.S. States.

(b) Authorized U.S. airports for dogs and cats. (1) Cats may arrive at and be admitted

into the United States through any U.S. airport.

(2) Dogs arriving to the United States from DMRVV low-risk or DMRVV-free countries

and with documentation confirming that they have been only in DMRVV low-risk or DMRVV-
free countries during the last six months may arrive at and be admitted into the United States

through any U.S. airport.

(3) Dogs that have a valid certification of U.S.-Issued rabies vaccination form may arrive

at and be admitted into the United States through any U.S. airport.

(4) Dogs that have been in a DMRVV high-risk country within the last six months and

have a valid certification of foreign rabies vaccination and microchip form must arrive at and

may be admitted only through a U.S. airport with a CDC quarantine station (also known as a

U.S. port health station) and a CDC-registered animal care facility.

(5) Dogs that have been in a DMRVV high-risk country within the last six months that

arrive at an unauthorized U.S. airport or that arrive without a valid certification of U.S.-issued

rabies vaccination or certification of foreign rabies vaccination and microchip form shall be

denied admission and returned to their countries of departure via air pursuant to paragraph (v) of

this section.

(6) The current list of U.S. airports with CDC-registered animal care facilities is available

on CDC’s website. CDC will update the list as needed.

(c) Authorized U.S. land ports for dogs and cats. (1) Cats may arrive at and be admitted

into the United States through any U.S. land port.

(2) Dogs arriving to the United States from DMRVV low-risk or DMRVV-free countries

and with documentation confirming that they have been only in DMRVV-free or DMRVV low-

risk countries during the last six months may arrive at and be admitted into the United States

through any U.S. land port.

(3) Dogs that have a valid certification of U.S.-issued rabies vaccination form may arrive

at and be admitted into the United States through any U.S. land port.

(4) Dogs that have been in a DMRVV high-risk country within the last six months and do

not have a valid certification of U.S.-issued rabies vaccination form are not authorized to enter
the United States through any U.S. land port and shall be denied admission into the United

States.

(d) Authorized U.S. seaports for dogs and cats. (1) Cats may arrive at and be admitted

into the United States through any U.S. seaport.

(2) Dogs arriving to the United States from DMRVV low-risk or DMRVV-free countries

and with documentation confirming that they have been only in DMRVV-free or DMRVV low-

risk countries during the last six months may arrive at and be admitted into the United States

through any U.S. seaport.

(3) Dogs that have a valid certification of U.S.-issued rabies vaccination form may arrive

at and be admitted into the United States through any U.S. seaport.

(4) Dogs that have been in a DMRVV high-risk country within the last six months and do

not have a valid certification of U.S.-issued rabies vaccination form are not authorized to enter

the United States through any U.S. seaport and shall be denied admission into the United States.

(5) Notwithstanding paragraph (d)(4) of this section, a dog meeting the definition of a

“service animal” under 14 CFR 382.3 that has been in a DMRVV high-risk country within the

last six months and was vaccinated against rabies in a foreign country may be admitted through a

U.S. seaport if:

(i) The dog accompanies an “individual with a disability” as defined under 14 CFR

382.3; and

(ii) The dog has a valid and complete certification of foreign rabies vaccination and

microchip form and a valid serologic titer from a CDC-approved laboratory.

(e) Limitation on U.S. ports for dogs and cats. (1) The Director may limit the times, U.S.

ports, or conditions under which dogs or cats may arrive at and be admitted to the United States

based on an importer’s, CDC-registered animal care facility’s, or carrier’s failure to comply with

the provisions of this section or as needed to protect the public’s health. If the Director

determines a limitation is required, the Director will notify importers, CDC-registered animal
care facilities, and carriers in writing of the specific times, U.S. ports, or conditions under which

dogs and cats may be permitted to arrive at and be admitted to the United States.

(2) CBP will prescribe the time, place, and manner in which dogs are presented upon

arrival at a port of entry, which may include prohibiting dogs from being presented within the

Federal Inspection Station.

(f) Age requirement for all dogs. (1) All dogs presented for admission into the United

States must be at least six (6) months old at the time of their arrival into the United States.

(2) Dogs arriving into the United States that are not at least six (6) months old at the time

of their arrival shall be denied admission and returned to the country of departure pursuant to

paragraph (v) of this section.

(g) Microchip requirements for all dogs. (1) All dogs presented for admission into the

United States must have a microchip implanted prior to arrival at the U.S. port.

(2) The microchip must have been implanted on or before the date the current rabies

vaccine was administered. Rabies vaccines administered prior to the implantation of a microchip

are invalid.

(3) The microchip number must be documented on the certification of foreign rabies

vaccination and microchip form, the certification of U.S.-issued rabies vaccination form, or if the

dog is arriving from a DMRVV low-risk or DMRVV-free country, documented on one of the

forms listed in paragraph (u)(2) of this section and all accompanying veterinary records. The

microchip number must also be documented on the CDC dog import form.

(4) Importers must consent to the scanning of the dogs’ microchip by CDC quarantine

public health officers, CDC-registered animal care facility staff, or their representatives, upon the

dogs’ arrival at a U.S. port.

(5) Dogs arriving in the United States without a microchip, with a microchip that cannot

be detected, with a microchip that does not match the accompanying documentation, or if the
importer refuses to have the dogs’ microchip scanned, shall be denied admission and returned to

the country of departure pursuant to paragraph (v) of this section.

(h) CDC dog import form for all dogs. (1) All importers of dogs must submit a complete

and accurate CDC dog import form to CDC via a CDC-approved system prior to the dogs

arriving in the United States. This includes accompanied or unaccompanied dogs arriving by air,

land, or sea regardless of where the dogs originated or whether arriving as cargo, checked-

baggage, or hand-carried baggage. This excludes dogs that are transiting through the United

States without making an entry in accordance with paragraph (cc) of this section.

(2) Dogs that arrive without a receipt confirming that the CDC dog import form was

submitted before the dogs’ arrival in the United States may be denied admission and returned to

their country of departure pursuant to paragraph (v) of this section, regardless of the value of the

shipment.

(3) Dogs arriving by air without a receipt confirming that the CDC dog import form was

submitted before the dogs’ arrival in the United States may be held in the care of a CDC-

registered animal care facility, on a space-available basis, for up to 24 hours after their arrival. If

the dogs arrive at an airport without a CDC-registered animal care facility or if the animal care

facility lacks space to house the dogs, the dogs may be held in the care of a licensed veterinarian

approved by CDC for up to 24 hours after their arrival until the CDC Dog Import Form is filed.

The importer (or airline if the importer abandons the animal) is responsible for making all

necessary arrangements with a CDC-registered animal care facility or a veterinary clinic (if the

CDC-registered animal care facility is unavailable at the airport or lacks space to house the

dogs), including arranging transportation to the facility. The airline may require reimbursement

from an importer for any associated costs incurred by the airline on the importer’s behalf.

(4) Dogs arriving by sea without a receipt confirming submission of a CDC dog import

form may be held on board the vessel until the form is filed. The vessel’s owner or operator may
require reimbursement from an importer for any associated costs incurred by the vessel’s owner

or operator on the importer’s behalf.

(5) Dogs arriving by land without a receipt confirming submission of a CDC dog import

form shall be denied admission and returned immediately to the dogs’ country of departure, but

such denial does not prevent the importer from reapplying for admission of the dogs after the

form is filed.

(6) A receipt confirming submission of the CDC dog import form must accompany all

dogs departing foreign locations for travel to the United States. For dogs departing from foreign

airports to the United States, the airline must deny boarding to dogs unless the importer has

presented this receipt prior to boarding.

(7) Airlines, unless granted a waiver in accordance with paragraph (dd) of this section,

are required to create a bill of lading for all dogs arriving in the United States prior to the dogs’

arrival. This includes dogs transported as cargo, checked-baggage, or hand-carried baggage. If

granted a waiver to the bill of lading requirement, the airline’s handling and transport of the dogs

must be consistent with the terms of that waiver.

(8) Unless being transported by an airline for which a waiver to the bill of lading

requirement has been granted pursuant to paragraph (dd) of this section, dogs arriving by air for

which a bill of lading has not been filed prior to their arrival in the United States (or if the

airline’s handling and transport of the dogs is inconsistent with the terms of the waiver) shall be

denied admission and returned to their country of departure pursuant to paragraph (v) of this

section.

(i) Inspection requirements for admission of all dogs and cats. (1) All animals arriving at

a U.S. port shall be inspected upon arrival, and only those animals that show no signs of

communicable disease as defined in 42 CFR 71.1 shall be admitted into the United States.

(2) All animals presented for admission into the United States may be subject to

additional examination and disease surveillance screening for the purpose of communicable
disease surveillance. Ill animals may be required to undergo additional diagnostic testing prior to

release of the animal; such testing is not considered surveillance screening.

(3) The Director may require confinement of an animal and examination by a veterinarian

when necessary to determine whether the animal is admissible into the United States, for

instance, if dental examination would assist in determining the animal’s age.

(4) Importers who refuse to consent to inspection, examination, disease surveillance

screening, or diagnostic testing of the animal upon arrival shall have the animal denied

admission and returned to its country of departure pursuant to paragraph (v) of this section.

(j) Examination by a USDA-accredited veterinarian and confinement of exposed dogs

and cats or those that appear unhealthy. (1) If an animal, upon inspection, does not appear to be

in good health (e.g., it has signs such as emaciation, lesions of the skin, discharge of the eyes or

nose, coughing, sneezing, nervous system disturbances, inability to stand or walk, difficulty

breathing, jaundice, vomiting, or diarrhea), or appears healthy but, during shipment, may have

been exposed to a sick or dead animal (including an animal other than a dog or cat) suspected of

having a communicable disease, the Director may require prompt confinement and veterinary

examination.

(2) In the case of animals that appear unhealthy or those that were potentially exposed

and arriving by air or sea, the Director may require the airline or vessel’s master or operator to

arrange for a licensed veterinarian to examine the animal and give or arrange for any tests or

treatment indicated. In the case of animals that appear unhealthy or those that were potentially

exposed and arriving by land, the Director may deny admission, but such denial does not prevent

the importer from reapplying for admission after providing the Director with satisfactory

evidence that a licensed veterinarian has examined the animal and administered any tests or

treatment as needed to ensure the animal does not have a communicable disease.
(3) Carriers shall maintain a record of sickness of animals occurring while en route to the

United States and shall submit the record to the CDC quarantine station with jurisdiction for the

U.S. port.

(4) Animals that become sick while en route or on arrival shall be separated from other

animals (including animals other than dogs or cats) as soon as the sickness is discovered and

shall be held in confinement pending any necessary examination as determined by the Director.

(5) Airlines (in the case of arrivals by air) or the masters or operators of vessels (in the

case of arrivals by sea) shall immediately arrange for confinement and medical evaluation of any

ill or injured animals at a CDC-registered animal care facility or CDC-approved veterinary

facility (if a CDC-registered animal care facility is not available) which, in the judgment of the

Director, affords protection against transmission of any communicable disease, and suitable

housing in accordance with the Animal Welfare Act (7 U.S.C. 2131 et seq., as may be amended).

In the case of ill or injured animals arriving by land, the Director may deny admission, but such

denial does not prevent the importer from reapplying for admission after providing the Director

with satisfactory evidence of confinement (as needed) and examination by a licensed

veterinarian.

(6) The airline or vessel’s master or operator shall immediately thereafter arrange for

transportation of any ill or injured animals by a CBP-bonded transporter to the CDC-registered

animal care facility or other CDC-approved veterinary facility (if a CDC-registered animal care

facility is not available) for confinement and medical evaluation. The airline or vessel’s master

or operator shall arrange to have ill or injured animals transported in a way that does not expose

transportation personnel or the public to communicable diseases.

(7) The Director will consider the findings of the examination and tests in determining

whether the animal may have a communicable disease.

(8) The importer shall bear the expenses of transportation, confinement, examination,

tests, and treatment under this paragraph. If an importer fails to arrange for or pay for such
expenses or cooperate with any CDC-mandated public health evaluations, then the animal will be

considered abandoned, and the carrier shall assume financial responsibility pursuant to paragraph

(aa) of this section.

(9) Confinement shall be subject to conditions specified by the Director to protect the

public’s health.

(10) CDC may request that CBP conditionally release animals for medical evaluation and

treatment in emergency or exigent circumstances. Animals eligible for conditional release shall

remain under the legal custody of the carrier or CDC-registered animal care facility for the

purpose of receiving veterinary medical care. If such animals are conditionally released to a

CDC-approved veterinary facility (if a CDC-registered animal care facility is not available or

cannot provide the level of care needed), then the animal must be immediately returned to the

custody of the carrier or CDC-registered animal care facility once medical treatment is no longer

required or upon request by either CDC or CBP.

(11) If an importer (or carrier if the animal is abandoned by the importer) opts to have an

animal euthanatized (e.g., under circumstances where the animal is fatally ill or injured), the

importer or carrier shall promptly communicate this decision to CDC in writing and prior to

euthanasia. Euthanasia does not relieve importers or carriers of the obligation to arrange and pay

for testing and necropsy required by CDC.

(k) Veterinary examination, revaccination against rabies, and quarantine at a CDC-

registered animal care facility for foreign-vaccinated dogs from DMRVV high-risk countries. (1)

All dogs arriving into the United States that have been in DMRVV high-risk countries within the

last six months and that do not have a valid certification of U.S.-issued rabies vaccination form

shall undergo veterinary examination and revaccination against rabies at a CDC-registered

animal care facility upon arrival.

(2) The importer is responsible for making all arrangements relating to the examination,

revaccination, and quarantine (if applicable) at a CDC-registered animal care facility prior to the
dog’s arrival in the United States. The costs of examination, vaccination, and quarantine (if

applicable) shall be borne by the importer and not at the government’s expense.

(3) Prior to granting a reservation, CDC-registered animal care facilities must ensure they

have received the following:

(i) The completed certification of foreign rabies vaccination and microchip form;

(ii) Serologic test results (if applicable) obtained from a CDC-approved laboratory on a

blood sample drawn, submitted, and tested in accordance with CDC's technical instructions;

(iii) Photos of the dogs’ teeth to assist with age verification;

(iv) The travel itinerary for the dogs confirming that the dogs will be arriving only at a

U.S. airport with a CDC-registered animal care facility and will not be arriving at any other U.S.

port; and

(v) A receipt confirming submission of the CDC dog import form.

(4) Importers must present documentation to airlines confirming their reservation at a

CDC-registered animal care facility prior to their dogs boarding a flight to the United States.

Airlines must deny boarding to dogs if the importer fails to present such documentation.

(5) Airlines must deny boarding to any foreign-vaccinated dog that has been in a

DMRVV high-risk country within the last six months for which the importer has not presented a

receipt confirming submission of the CDC dog import form and proof of a reservation at a CDC-

registered animal care facility, or that is being presented for travel to an unauthorized U.S.

airport.

(6) The airline shall arrange for dogs to be transported by a CBP-bonded transporter to

the CDC-registered animal care facility immediately upon arrival at the U.S. airport.

(7) The dogs shall remain in the custody of the CDC-registered animal care facility until

the following requirements are met:

(i) Veterinary health examination by a USDA-accredited veterinarian for signs of illness.

All illnesses must be documented in SAFE TraQ. CDC will review these illness case reports and
determine admissibility prior to the dog’s release. Suspected or confirmed communicable

diseases, including the presence of ectoparasites (i.e., ticks and fleas), must be reported to CDC

prior to release of the dog;

(ii) Confirmation of microchip number;

(iii) Confirmation of age through dental examination by a USDA-accredited veterinarian;

(iv) Vaccination against rabies with a USDA-licensed rabies vaccine that is administered

by a USDA-accredited veterinarian; and

(v) Confirmation of adequate rabies serologic titer from a CDC-approved laboratory.

Blood samples for serologic tests must be drawn within a timeframe as specified in CDC

technical instructions. Dogs that arrive without an adequate rabies serologic test results from a

CDC-approved laboratory, or with a serologic test result drawn outside the acceptable timeframe,

or with serologic test results outside acceptable parameters, shall be housed at the CDC-

registered animal care facility for a 28-day quarantine period following administration of the

USDA-licensed rabies vaccine.

(l) Registration or renewal of CDC-registered animal care facilities. (1) A facility must

register with and receive written approval from the Director to function as a CDC-registered

animal care facility before housing any live dog imported into the United States. Applications

and all required documents must be submitted to [email protected].

(2) The CDC-registered animal care facility must be located within 35 miles of a CDC

quarantine station.

(3) To register or renew a registration certificate, a facility must submit the following

documents to CDC:

(i) A completed registration/application form;

(ii) A statement of intent that describes the number and types of animals the facility can

safely house at any one time, including the number of animals that can be housed in the

quarantine area;
(iii) Written standard operating procedures that include all elements required in

paragraphs (k) through (q) of this section;

(iv) A copy of all required Federal, State, or local registrations, licenses, and/or permits; a

facility must have a USDA Class H intermediate handlers registration (and any additional class

licenses or registrations as deemed appropriate by USDA) and a CBP Facilities Information and

Resource Management System (FIRMS) code; and

(v) A self-certification signed by the owner or manager of the CDC-registered animal

care facility stating that the facility is in compliance and agrees to continue to comply with the

regulations in this section.

(3) Upon receiving the documentation required by this section, the Director will review

the application and either grant or deny the application for registration as a CDC-registered

animal care facility. Applications that are denied may be appealed under paragraph (r) of this

section.

(i) Before issuing a registration, the Director may inspect any animal health record,

facility, vehicle, or equipment to be used in management, examination, and clearance of

imported animals. Thereafter, animal health records, facilities, vehicles, and equipment used in

importing animals may be inspected during annual site inspection visits or when otherwise

needed to protect the public’s health.

(ii) CDC may conduct unannounced inspections of facilities seeking to register or renew

their status as a CDC-registered animal care facility or when otherwise needed to protect the

public’s health.

(iii) CDC inspections will be based on USDA Animal Welfare regulation standards (9

CFR parts 1, 2, and 3) and other standards as outlined in CDC’s Technical Instructions for CDC-

registered Animal Care Facilities.


(iv) Unless revoked in accordance with paragraph (r) of this section, a registration

certificate issued under this section is effective for two years beginning from the date CDC

issues the registration certificate.

(v) A CDC-registered animal care facility must apply to CDC for renewal of the

registration certificate not less than 60 days and not more than 90 days before the existing

registration expires.

(4) The Director may deny an application to register, renew, or reinstate a facility as a

CDC-registered animal care facility if the registrant has had a previous registration revoked in

accordance with paragraph (r) within the last five years.

(5) All CDC-registered animal care facilities must comply with the requirements of

paragraphs (k) through (q) of this section.

(m) Record-keeping requirements at CDC-registered animal care facilities. (1) A CDC-

registered animal care facility must retain records regarding each imported animal for three years

after the release or return of the animal. Each record must include:

(i) the bill of lading (or other alternative documentation if the airline has been granted a

waiver under paragraph (dd) of this section) for the shipment;

(ii) the name, address, phone number, and email address of the importer and owner (if

different from the importer);

(iii) the number of animals in the shipment;

(iv) the identity of each animal in each shipment, including name, microchip number,

date of birth, sex, breed, and coloring;

(v) the airline, flight number, date of arrival, and port of arrival of the shipment; and

(vi) veterinary medical records for the animal, including:

(A) Certification of foreign rabies vaccination and microchip form and rabies serology

obtained before arrival in the United States (if applicable);

(B) the USDA-licensed rabies vaccine administered upon arrival;


(C) veterinary examination records upon arrival and while in quarantine;

(D) rabies serology performed while in quarantine in the United States (if applicable);

(E) all diagnostic test results performed during quarantine; and

(F) necropsy reports for imported animals that die while in the care of the CDC-registered

animal care facility.

(2) A CDC-registered animal care facility must maintain records electronically in SAFE

TraQ.

(i) Copies of all records must be entered directly into or uploaded into SAFE TraQ;

(ii) Records must be uploaded and complete prior to the animal’s release from the facility

(or for necropsy results within 30 days of an animal’s death); and

(iii) CDC will audit records remotely as needed and in-person during site inspection

visit(s) at the facility.

(n) Worker protection plan and personal protective equipment (PPE). (1) A CDC-

registered animal care facility must establish and maintain a worker protection plan with

standards comparable to those in the Occupational Safety and Health Administration’s

Recommended Practices for Safety and Health Programs and the National Association of Public

Health Veterinarians (NASPHV) Compendium of Veterinary Standard Precautions for Zoonotic

Disease Prevention in Veterinary Personnel.

(2) In addition to complying with the requirements of this section, a facility must comply

with all relevant Federal and State requirements relating to occupational health and safety.

(3) Rabies pre-exposure prophylaxis is required for workers who handle imported

animals with signs of illness or in quarantine, and for staff who perform necropsies of imported

animals. Rabies pre-exposure prophylaxis must be administered in accordance with the Advisory

Committee on Immunization Practices guidelines for pre-exposure prophylaxis vaccination to

prevent human rabies.


(4) Post-exposure procedures that provide potentially exposed workers with direct and

rapid access to a medical consultant are required.

(5) Procedures for documenting the frequency of worker training, including for those

working in the quarantine area, are required.

(6) As part of the worker protection plan, a facility must establish, implement, and

maintain hazard evaluation and worker communication procedures that include the following:

(i) Descriptions of known communicable disease and injury hazards associated with

handling animals;

(ii) The need for PPE when handling animals and training in the proper use of PPE,

including re-training and reinforcement of appropriate use;

(iii) Procedures for disinfection or safe disposal of garments, supplies, equipment, and

waste; and

(iv) Procedures for reporting to CDC within 48 hours suspected or confirmed

communicable diseases in facility workers associated with handling imported animals.

(o) CDC-registered animal care facility standard operating procedures, requirements,

and equipment standards for crating, caging, and transporting live animals. (1) Equipment

standards for crating, caging, and transporting live animals must be in accordance with USDA

Animal Welfare regulation standards (9 CFR parts 1, 2, and 3) and International Air Transport

Association standards.

(2) Animals must not be removed from crates during transport.

(3) Used PPE, bedding, and other potentially contaminated material must be removed

from the ground transport vehicle upon arrival at the animal care facility and disinfected in a

manner that would destroy potential pathogens of concern or safely disposed of in a manner that

prevents the spread of communicable disease.

(p) Health reporting and veterinary service requirements for animals at CDC-registered

animal fare facilities. (1) A CDC-registered animal care facility must provide the following
services for each animal upon arrival and ensure that each animal meets CDC entry requirements

prior to release from the facility:

(i) veterinary examination by a USDA-accredited veterinarian within one business day of

arrival;

(ii) verification of microchip and confirmation that the microchip number matches the

animal’s health records;

(iii) verification of an animal’s age via a dental examination or, if dental examination

cannot be reliably performed, verification through another CDC-approved diagnostic method

(e.g., ocular lens examination, radiographs);

(iv) revaccination against rabies using a USDA-licensed vaccine; and

(v) confirmation of a valid serology test from a CDC-approved laboratory on a sample

drawn from a dog prior to arrival within a timeframe and results within parameters as specified

in CDC technical instructions, or completion of a 28-day quarantine at the CDC-registered

animal care facility after administration of the USDA-licensed rabies vaccine.

(2) A CDC-registered animal care facility must provide the following services upon the

occurrence of any morbidity or mortality in an imported animal in the facility:

(i) Immediate isolation of the animal and implementation of infection prevention and

control measures in accordance with industry standards and CDC technical instructions if a

communicable disease is suspected.

(ii) Notification to CDC within 24 hours of the arrival of an ill animal or occurrence of

any illness or death occurring in an animal.

(iii) Examination by a USDA-accredited veterinarian immediately upon detection of

illness and diagnostic testing to determine the cause of illness. All costs associated with

examination and diagnostics are the responsibility of the importer.

(iv) For any animal that dies or is euthanized due to fatal illness or injury, necropsy

(gross and histopathologic examination are required), and any subsequent infectious disease
testing based on gross or histopathology findings or as determined by CDC, to determine the

cause of death. The importer is responsible for all costs associated with necropsy and testing.

(v) Suspected or confirmed communicable diseases, including the presence of

ectoparasites (i.e., ticks and fleas), must be reported to CDC within 24 hours of identification.

(3) Upon completion of the quarantine period and before a facility releases any animal

from quarantine, the facility must ensure that the facility's USDA-accredited veterinarian has

verified the health status of the animal.

(4) Any report required under this paragraph must be uploaded to SAFE TraQ prior to the

release of the animal.

(q) Quarantine requirements for animals at CDC-registered animal care facilities. (1) A

CDC-registered animal care facility must maintain a quarantine area for holding animals when

quarantine is required. Foreign-vaccinated dogs that have been in a DMRVV high-risk country

within six months of arrival must be quarantined for 28 days after revaccination with a USDA-

licensed rabies vaccine at the facility if they do not have a valid rabies serologic test from a

CDC-approved laboratory. CDC may also require quarantine or extend the quarantine period if a

facility or CDC finds or suspects that an animal is infected with, or has been exposed to, a

communicable disease or if CDC determines that additional diagnostic testing is warranted.

(2) For any quarantine area established or maintained under this section, a facility must

establish, implement, maintain, and adhere to standard operating procedures that meet the

following physical security requirements:

(i) The CDC-registered animal care facility must be locked and secure, with access

limited to authorized and trained personnel.

(ii) A CDC-registered animal care facility must limit access to animal quarantine areas to

authorized personnel responsible for the transport, care, or treatment of the animals.
(3) During the quarantine period, a CDC-registered animal care facility must monitor

animals for signs of any communicable disease, including, but not limited to, signs consistent

with rabies, brucellosis, leptospirosis, leishmaniasis, or ecto- or endoparasites.

(4) If any animals appear ill during quarantine, the CDC-registered animal care facility

must, in accordance with paragraphs (p)(2)(i) through (v) of this section, ensure appropriate

evaluation, monitoring, and treatment. Suspected or confirmed communicable diseases in

animals must be reported to CDC within 24 hours.

(5) A CDC-registered animal care facility must not knowingly release any ill animal from

quarantine under paragraph (q)(3) of this section without prior consultation with and written

approval from CDC.

(6) Quarantined animals must be housed in such a manner that they do not expose other

quarantined animals or non-quarantined animals (including animals other than dogs or cats) to

potentially infectious materials, including soiled bedding, caging, and other potentially

contaminated items. Animals in quarantine may not be housed together.

(7) If CDC notifies a CDC-registered animal care facility of any evidence that animals

have been exposed to a communicable disease, the facility must, at the facility's expense (subject

to reimbursement by the importer or carrier (in case of abandonment)), implement or cooperate

in the CDC's implementation of additional measures to rule out the spread of suspected

communicable disease before releasing an animal or shipment of animals from quarantine,

including examination, additional diagnostic procedures, treatment, detention, extended

quarantine, isolation, seizure, or destruction of exposed animals.

(8) A CDC-registered animal care facility must establish, implement, and adhere to

standard operating procedures for safe handling and necropsy of any animal that dies in

quarantine.

(r) Revocation and reinstatement of a CDC-registered animal care facility's registration.

(1) The Director may revoke a CDC-registered animal care facility’s registration if the Director
determines that the facility has failed to comply with any applicable provisions of this section,

the facility's standard operating procedures, USDA Animal Welfare standards (9 CFR parts 1, 2,

and 3), or other standards as outlined in CDC’s Technical Instructions for CDC-registered

Animal Care Facilities.

(2) CDC will send the CDC-registered animal care facility a notice of revocation stating

the grounds upon which the proposed revocation is based.

(3) If the CDC-registered animal care facility wishes to contest the revocation, the facility

must file a written response to the notice within five business days after receiving the notice.

(4) As part of the response, a CDC-registered animal care facility may request that the

Director review the written record.

(5) If a CDC-registered animal care facility fails to file a response within five business

days, all of the grounds listed in the proposed revocation will be deemed admitted, in which case

the notice shall constitute final agency action, unless the Secretary, within one business day,

decides to excuse the facility’s failure to respond on a timely basis.

(6) If a CDC-registered animal care facility's response is timely, the Director will review

the registration, the notice of revocation, the response, and make a decision in writing based on

the written record.

(7) As soon as practicable after completing the written record review, the Director will

issue a decision in writing that shall constitute final agency action, unless the Secretary, within

one business day, decides to review the Director’s decision. The Director will provide the facility

with a copy of the written decision.

(8) The Director may reinstate a revoked registration after inspecting the facility,

examining its records, conferring with the facility, and receiving information and assurance from

the facility of compliance with the requirements of this section.

(s) Requirement for the certification of foreign rabies vaccination and microchip form to

import foreign-vaccinated dogs from DMRVV high-risk countries. (1) Importers of foreign-
vaccinated dogs from DMRVV high-risk countries must submit the certification of foreign rabies

vaccination and microchip form to the CDC-registered animal care facility in order to make a

reservation at that facility.

(2) Importers must present documentation confirming the dog’s reservation at a CDC-

registered animal care facility to the airline prior to boarding and to CBP upon arrival at a U.S.

port for admission of foreign-vaccinated dogs from DMRVV high-risk countries.

(3) The certification of foreign rabies vaccination and microchip form must be truthful

and accurate, completed in English, and include:

(i) The name of the person importing the dog (consignee), physical address, phone

number, email address, passport number, and date of birth;

(ii) The owner’s name, phone number, and email address;

(iii) The destination address (physical address) where the dog will reside upon arrival in

the United States;

(iv) The dog’s name, breed, sex, date of birth or approximate age if the date of birth is

unknown, and color or markings of the dog;

(v) Rabies vaccination information for the dog administered within a timeframe and in

accordance with the vaccination schedule as specified in CDC technical instructions;

(vi) Rabies vaccine product information (product name, manufacturer, lot number, and

product expiration date);

(vii) Rabies vaccine expiration date (date when next vaccine is due), which must be after

the dog’s date of arrival at a U.S. port;

(viii) Microchip number and microchip implant date, which must be on or before the date

of administration of the most recent rabies vaccination included on this form;

(ix) The name, license number or official stamp, address, telephone number, email

address, and signature of the authorized veterinarian or official government veterinarian that

examined the dog in the exporting country; and


(x) The name, address, official seal or stamp, and signature of an official government

veterinarian attesting that the authorized veterinarian is licensed or authorized to practice

veterinary medicine in the exporting country and further attesting that the information listed on

the form is true and correct.

(4) Importers who fail or refuse to present the certification of foreign rabies vaccination

and microchip form or present a form that is untruthful, inaccurate, and incomplete may result in

the dog being denied admission and returned to the country of departure pursuant to paragraph

(v) of this section.

(t) Requirement for Certification of U.S.-Issued Rabies Vaccination form for importers

seeking to import U.S.-vaccinated dogs from DMRVV high-risk countries. (1) Importers

returning to the United States with a U.S.-vaccinated dog that has been in a DMRVV high-risk

country within the last six months may present their dog for admission without a rabies serologic

test from a CDC-approved laboratory, without the dog undergoing veterinary examination

(unless ill, injured, or exposed), and without revaccination against rabies or quarantine at a CDC-

registered animal care facility upon arrival under the following circumstances:

(i) The importer presents a certification of U.S.-issued rabies vaccination form that is

truthful, complete, and accurate.

(ii) The importer presents a valid certification of U.S.-issued rabies vaccination form that

sufficiently and reliably demonstrates that a USDA-licensed rabies vaccine was administered

within a timeframe and age parameters as specified in CDC technical instructions.

(2) The certification of U.S.-issued rabies vaccination form must have been completed

and endorsed prior to the dog leaving the United States and cannot be completed upon arrival at

a U.S. port or after the dog has left the United States.

(3) Importers returning to the United States from a DMRVV high-risk country with their

U.S.-vaccinated dog that are unable to meet the requirements of this paragraph shall have the dog

treated as if it was vaccinated in a foreign country in accordance with the provisions of


paragraphs (k) and (s) of this section or, alternatively, have the dog denied admission and

returned to the country of departure pursuant to the paragraph (v) of this section.

(4) If an importer fails to immediately (within 24 hours of arrival) arrange for the dog’s

return to the country of departure, then the animal will be considered abandoned pursuant to

paragraph (aa) of this section.

(u) Requirement for proof that a dog has been only in DMRVV low-risk or DMRVV-free

countries. (1) Dogs arriving, including those returning to the United States, from a DMRVV

low-risk or DMRVV-free country may be admitted into the United States subject to the

requirements in this section if the importer submits written documentation satisfactory to the

Director that for the six months before arrival, the dog has been only in DMRVV low-risk or

DMRVV-free countries.

(2) For purposes of paragraph (u)(1) of this section, written documentation satisfactory to

the Director shall include any one of the following:

(i) A valid certification of foreign rabies vaccination and microchip form if completed in

a DMRVV-free or DMRVV low-risk country and the dogs are arriving into the United States

from the same DMRVV-free or DMRVV low-risk country as that listed on the form. This form

must be completed by an authorized veterinarian, which may include an official government

veterinarian, and must be certified by an official government veterinarian in the exporting

country;

(ii) A valid certification of U.S.-issued rabies vaccination form completed by a USDA-

accredited veterinarian and endorsed by a USDA official veterinarian;

(iii) A valid USDA export certificate if the certificate is issued to allow the dogs to travel

to a DMRVV-free or DMRVV low-risk country and the dogs are returning to the United States

from the same DMRVV-free or DMRVV low-risk country as that listed on the export certificate.

The form must be completed by a USDA-accredited veterinarian and endorsed by a USDA

official veterinarian;
(iv) A valid foreign export certificate from a DMRVV-free or DMRVV low-risk country

that has been certified by an official government veterinarian in that country. The export

certificate must be accompanied by veterinary records (such as the European Union pet passport)

or proof of payment for veterinary services establishing that veterinary services were performed

in the exporting country at least six months before traveling to the United States;

(v) A certification of dog arriving from DMRVV-free or DMRVV low-risk country form

if accompanied by veterinary records or proof of payment for veterinary services establishing

that veterinary services were performed in the same DMRVV-free or DMRVV low-risk country

at least six months before travel to the United States. This form must be completed by an

authorized veterinarian, which may include an official government veterinarian, and must be

certified by an official government veterinarian in the exporting country; or

(vi) Other records or documents satisfactory to the Director that CDC may establish

through technical instructions and publish on its website.

(v) Denial of admission of dogs and cats. (1) The following categories of animals are

inadmissible to the United States:

(i) Any dog arriving from a DMRVV low-risk or DMRVV-free country without written

documentation satisfactory to the Director that the dog has been only in DMRVV low-risk or

DMRVV-free countries during the six months prior to the attempted entry, or if the Director

reasonably suspects fraud.

(ii) Any dog that is not accompanied by a receipt confirming that a CDC dog import form

has been submitted to CDC through a CDC-approved system.

(iii) Any dog arriving by air for which a bill of lading, including an air waybill, has not

been created by the airline prior to the dog’s arrival in the United States (regardless of the value

of the shipment) unless the airline transporting the dog has been granted a waiver pursuant to

paragraph (dd) of this section and the airline’s handling and transport of the dog is consistent

with the terms of that waiver.


(iv) Any unvaccinated or foreign-vaccinated dog arriving by land to the United States if

the dog has been in a DMRVV high-risk countries within the last six months.

(v) Any unvaccinated or foreign-vaccinated dog arriving by sea to the United States if the

dog has been in a DMRVV high-risk country within the last six months, except for a foreign-

vaccinated dog qualifying as a service animal and meeting the standards set forth in paragraph

(d)(5) of this section.

(vi) Any animal imported by an importer who refuses to comply with the requirements (if

applicable) for disease surveillance screening, microchip scanning, veterinary examination,

diagnostics tests to rule out communicable diseases, revaccination, providing proof of sufficient

rabies serologic tests, or quarantine (if applicable) at a CDC-registered animal care facility or

other CDC-approved facility (if a CDC-registered animal care facility is not available) upon

arrival.

(vii) Any dog that has been in a DMRVV high-risk country within the last six months and

arrives without a valid certification of U.S.-issued rabies vaccination form or a valid certification

of foreign rabies vaccination and microchip form.

(viii) Any foreign-vaccinated dog that has been in a DMRVV high-risk country within

the last six months and does not arrive via air at a U.S. airport with a CDC quarantine station and

a CDC-registered animal care facility, except for a foreign-vaccinated dog arriving by sea that

qualifies as a service animal and meets the standards set forth in paragraph (d)(5) of this section.

(ix) Any dog imported from a DMRVV high-risk country that arrives without a

reservation at a CDC-registered animal care facility (if applicable).

(x) Any dog from a DMRVV-restricted country that arrives without a valid CDC dog

import permit.

(xi) Any dog, regardless of country of departure, if the Director reasonably suspects fraud

in any documentation required for admission or if such documentation is otherwise untruthful,

inaccurate, or incomplete.
(xii) Any animal, regardless of country of departure, that poses a public health risk,

including animals that appear unhealthy upon arrival or demonstrate signs or symptoms of

communicable disease.

(xiii) Any dog under six months of age that arrives in the United States.

(xiv) Any dog that arrives in the United States without a microchip or without its

microchip number documented on the importation paperwork required by CDC.

(2) An importer must meet the admission requirements of all U.S. government agencies

for the admission of an animal into the United States. Satisfaction of CDC’s requirements for the

admission of animals does not fulfill the admission requirements of other U.S. government

agencies.

(w) Dogs and cats awaiting an admissibility determination or return to their country of

departure. (1) Animals arriving by air that are denied admission and awaiting return to their

country of departure or awaiting a determination as to their admissibility must be held in a CDC-

registered animal care facility or other CDC-approved facility (if a CDC-registered animal care

facility is not available) in such a way as to prevent the potential spread of communicable

diseases.

(2) An airline must arrange to transport an animal arriving by air to a CDC-registered

animal care facility (or other boarding, kennel, or veterinary clinic approved by CDC if a CDC-

registered animal care facility is not available) if the animal is denied admission and is awaiting

return to its country of departure or is awaiting a determination of its admissibility. If the animal

is apparently healthy, the airline must transport the animal (by a CBP-bonded transporter) within

12 hours of its arrival.

(3) An airline must immediately report an obviously ill or injured animal (e.g., the animal

is unable to stand, has difficulty breathing, is bleeding, has broken bones or disfigured limbs, or

is experiencing seizures, vomiting, or discharge from the nose, mouth, or eyes) arriving into the

United States to the CDC quarantine station of jurisdiction. The airline must immediately arrange
to transport an obviously ill or injured animal by a CBP-bonded transporter to a CDC-registered

animal care facility or veterinary clinic as directed by CDC.

(4) Animals arriving by sea that are denied admission must remain on the vessel while

awaiting return to the country of departure.

(x) Disposal or disposition of dogs and cats denied admission to the United States. (1)

Animals shall be subject to such additional requirements as authorized under this part or 42 CFR

part 70 as may be deemed necessary by the Director to protect the public’s health, including

suspension of entry under § 71.63.

(2) Animals denied admission to the United States that were transported to the United

States via air must be returned by the airline to the country of departure at the importer’s expense

on the next available outbound flight (no later than 72 hours after arrival), regardless of airline or

route, if fit to travel. Pending the animal’s return, the animal shall be detained at the importer’s

expense in the custody of the carrier at a CDC-registered animal care facility (or other boarding,

kennel, or veterinary clinic approved by CDC if a CDC-registered animal care facility is not

available).

(3) Animals denied admission to the United States that were transported to the United

States via sea shall be reembarked immediately by the vessel’s master or operator and returned to

their country of departure on the next voyage.

(4) Animals denied admission to the United States that were transported to the United

States via land shall be returned immediately by importer or carrier to their country of departure.

(5) If an animal is not fit to travel, poses a public health risk, or would pose a risk to other

animals, then the carrier shall arrange for the animal to be transported to a CDC-registered

animal care facility or a CDC- approved veterinary clinic (if a CDC-registered animal care

facility is not available) for housing and treatment by a licensed veterinarian until approved for

travel by CDC or humanely euthanized (e.g., under circumstances where the animal is fatally ill

or injured) by a licensed veterinarian. The importer shall be responsible for all costs associated
with the denial, veterinary evaluation, care, or disposal of the animal. If the importer refuses to

pay for any costs associated with the denial, evaluation, care, or disposal of the animal, then it

will be considered abandoned, and the carrier shall assume custody and financial responsibility

for these costs.

(6) If humane euthanasia is recommended by a veterinarian or chosen by an importer or

carrier (e.g., under circumstances where the animal is fatally ill or injured), the animal must be

euthanized by a U.S.-licensed veterinarian in accordance with American Veterinary Medical

Association guidelines. Euthanasia does not relieve carriers or importers of the obligation to

arrange and pay for testing and necropsy required by CDC.

(7) The Director may grant temporary extensions of returns for animals that are not fit for

travel as determined by a CDC veterinarian, but the importer (or carrier in the case of

abandonment) must arrange for the return of the animal to its country of departure as soon as

CDC notifies the carrier that the animal is fit for travel.

(8) The requirements of this paragraph shall additionally apply to dogs or cats abandoned

by the importer prior to the dogs’ or cats’ admission into the United States. A dog or cat may be

deemed abandoned pursuant to the provisions of paragraph (aa) of this section.

(9) Carriers must provide transportation to/from and holding at a CDC-registered animal

care facility or another CDC-approved facility (if a CDC-registered animal care facility is not

available) while the animal is pending an admissibility determination, undergoing veterinary

evaluation or care, or upon denial of entry. Carriers may require reimbursement from an importer

for any costs incurred on behalf of the importer.

(10) Importers must comply with CDC requirements for the return of an animal or for the

veterinary assessment of an animal. Refusal to cooperate, including refusal to pay any associated

veterinary fees, will result in the animal being considered abandoned by the importer, and

custody of the animal will be transferred to the carrier who will assume financial responsibility

for costs relating to the denial, evaluation, care, or disposal of the animal.
(11) A carrier may enter into contractual arrangements with an importer or a third party

relating to the expenses of returning an animal to its country of departure, for veterinary care, or

otherwise disposing of an animal, provided that no government costs are incurred. The return of

an animal to its country of departure or the initiation of veterinary care shall not be delayed while

the carrier attempts to enter into or negotiate contractual arrangements.

(12) The provisions of this paragraph may be applied to importers of animals and to

carriers transporting such animals in circumstances where an animal is denied entry at a land port

or seaport of the United States and the animal cannot be immediately returned to its country of

departure (e.g., because it is unfit to travel).

(y) Appeals of CDC denials to admit a dog or a cat upon arrival into the United States.

(1) If CDC denies admission to an animal upon arrival, then the importer may appeal that denial

to the Director.

(2) The importer must submit the appeal in writing to the Director, stating the reasons for

the appeal and demonstrating that there is a genuine and substantial issue of fact in dispute.

(3) The importer must submit the appeal within one (1) business day of the denial by

emailing [email protected].

(4) Submitting an appeal will not delay the return of the animal to the country of

departure.

(5) The Director will issue a written response to the appeal, which shall constitute final

agency action, unless the Secretary, within one (1) business day, decides to review the Director’s

decision.

(z) Record of death of dogs and cats en route to the United States and disposition of dead

animals. (1) Carriers shall maintain a record of the death of animals occurring while en route to

the United States and shall submit the record to the CDC quarantine station of jurisdiction for the

U.S. port upon arrival.


(2) Animals that become sick or die en route or are identified as sick or dead upon arrival

shall be separated from other animals (including animals other than dogs or cats) as soon as the

sickness or death is discovered and shall be held in confinement pending any necessary

examination as determined by the Director. Sick animals shall be examined pursuant to the

provisions of paragraph (j) of this section or disposed of pursuant to the provisions of paragraph

(x) of this section.

(3) The carrier shall arrange for any animals that die en route to the United States or that

die while detained pending determination of their admissibility to undergo a necropsy (gross and

histopathologic examination are required), and any subsequent infectious disease testing based

on gross or histopathology findings or as determined by CDC. The carrier or CDC-registered

animal care facility must contact the CDC quarantine station of jurisdiction prior to transporting

an animal for necropsy to determine whether rabies testing is required. In the event an importer

abandons an animal, the carrier will become the owner and shall assume responsibility for all

expenses described in this paragraph.

(4) The carrier shall send copies of the final necropsy report and all test results to the

CDC quarantine station of jurisdiction.

(5) Pursuant to paragraphs (p) and (x) of this section, the importer is responsible for costs

associated with the necropsy, testing, and disposal of the body. In the event an importer

abandons an animal, then pursuant to paragraph (aa) of this section, the carrier will become the

owner and shall assume responsibility for all expenses described in this paragraph.

(aa) Abandoned shipments of dogs and cats. (1) In the event an importer abandons an

animal under this section, the carrier will become the owner and shall assume responsibility for

all expenses described in this section.

(2) An animal shipment will be deemed abandoned under the following circumstances:

(i) when explicitly stated by the importer verbally or in writing to the carrier, CDC, or

CBP; or
(ii) if the importer fails to cooperate with or respond to the carrier’s attempts to comply

with the provisions of this section within 24 hours; or

(iii) if the importer refuses payment within 24 hours for CDC-mandated examinations,

testing, holding, or treatment needed to ensure the safe importation of dogs and cats into the

United States.

(bb) Sanitation of cages and containers of dogs and cats. When the Director finds that the

cages or other containers of animals arriving in the United States are in an unsanitary or other

condition that may constitute a communicable disease risk, the animals shall not be admitted in

such containers unless the carrier has the containers cleaned and disinfected or the animals are

removed and placed in clean containers in accordance with USDA and, in the case of airlines, the

International Air Transport Association shipping requirements. Discarded containers must be

cleaned and disinfected or destroyed in accordance with carrier policies. CDC may require

documentation of container disinfection or destruction by the carrier.

(cc) Requirements for in-transit shipments of dogs and cats. (1) In-transit shipments of

live animals are not eligible for release into the United States and may only be transported as

cargo and not as hand-carried baggage or checked/excess baggage.

(2) In-transit shipments must be maintained under continuous confinement with USDA

APHIS oversight on board a conveyance until export, or off-loaded and maintained under

continuous confinement and APHIS oversight at a USDA APHIS-preapproved holding facility

with a CBP-issued FIRMS code while awaiting a connecting conveyance, and then loaded and

maintained under USDA APHIS oversight on board the connecting conveyance until export.

(3) The provisions of this section shall apply to animals transiting through the United

States from one foreign country to another, except as provided below:

(i) Animals that appear healthy but have been exposed to a sick or dead animal (including

an animal other than a dog or cat) suspected of having a communicable disease are not required

to undergo examination or tests as provided in paragraph (j) of this section if the Director
determines that the conditions under which the animals are being transported afford adequate

protection against introduction of communicable disease into the United States.

(ii) The certification of foreign rabies vaccination and microchip form, certification of

U.S.-issued rabies vaccination form, certification of dog arriving from DMRVV-free or DMRVV

low-risk country form, or CDC dog import form is not required for dogs that are transported by

aircraft and are being transited through the United States if retained in the custody of the airline

under conditions that would prevent transmission of communicable diseases.

(iii) There is no minimum age requirement for dogs that are transported by aircraft and

are being transited through the United States if retained in the custody of the airline under

conditions that would prevent transmission of communicable diseases.

(iv) A microchip is not required for dogs that are transported by aircraft and are being

transited through the United States if retained in the custody of the airline under conditions that

would prevent transmission of communicable diseases.

(dd) Bill of lading and other airline requirements for dogs. (1) Airlines are required to

create a bill of lading, which includes air waybills (AWB), for all dogs arriving in the United

States prior to arrival. This includes dogs transported as cargo, checked-baggage, or hand-carried

baggage.

(2) Airlines that lack the technical ability to generate a bill of lading to transport dogs as

checked baggage or as hand-carried baggage may request a waiver from CDC by emailing

[email protected].

(i) The airline’s request for a waiver must be accompanied by a written standard

operating procedure (SOP) describing how the airline will ensure care, transportation, and

housing for any ill, injured, or abandoned animals in the absence of a bill of lading. The SOP

must also identify and provide the location of a CDC-registered animal care facility or other

suitable alternative approved by CBP and CDC that will provide care and suitable housing for

any ill, injured, or abandoned animals prior to any animals being transported to the United States.
(ii) As a condition of granting a waiver, CDC may require the airline to obtain the

services of a licensed U.S. customs broker who will be responsible for coordinating on behalf of

the airline the entry and clearance of any dogs imported into the United States, including

compliance with CDC’s requirements relating to the admission of dogs.

(iii) As a condition of granting a waiver, CDC may require the airline to provide a

timetable and identify steps that the airline will take to develop the technical capacity to generate

an AWB (or another suitable alternative to an AWB) to transport dogs as cargo, checked-

baggage, or hand-carried baggage.

(iv) The Director may revoke a waiver granted to an airline upon notice to the airline and

a finding that an airline has acted inconsistent with the terms of the waiver, including any

provision of its SOP.

(v) CDC may publish additional technical instructions on its website for airlines seeking

a waiver from the bill of lading requirement.

(3) Any dog arriving by air for which a bill of lading, including an AWB, has not been

created by the airline prior to the dog’s arrival in the United States will be denied admission and

returned to the country of departure pursuant to paragraph (v) of this section, unless the airline

transporting the dog has been granted a waiver and the airline’s handling and transport of the dog

are consistent with the terms of that waiver.

(4) Airlines must deny boarding to any dogs for which the importer: has not presented to

the airline before boarding a receipt confirming submission of the CDC dog import form; if the

dogs are scheduled to arrive at a different U.S. port than the one listed on the receipt of the CDC

dog import form; or if the dogs presented for travel do not match the description on the receipt of

the CDC dog import form.

(5) For U.S.-vaccinated dogs that have been in a DMRVV high-risk country within the

last six months, airlines must deny boarding unless the importer presents prior to boarding a
valid certification of U.S.-issued rabies vaccination form or if the dogs presented for travel do

not match the description on the certification of U.S.-issued rabies vaccination form.

(6) For foreign-vaccinated dogs that have been in a DMRVV high-risk country within the

last six months, airlines must deny boarding unless the importer presents documentation to the

airline before boarding of a reservation at a CDC-registered animal care facility and the dog is

scheduled to arrive in the United States at the U.S. airport where the CDC-registered animal care

facility is located.

(7) For dogs from DMRVV-free or DMRVV low-risk countries, airlines must deny

boarding unless the importer before boarding presents documentation as described in paragraphs

(g)(2) and (u)(2) demonstrating that the dog is over six months of age, has a microchip, and has

been only in DMRVV low-risk or DMRVV-free countries during the last six months. Airlines

must also deny boarding if the dog presented for travel does not match the description on the

documents presented by the importer for travel.

(8) A representative of an airline transporting live dogs into the United States must be on-

site at the U.S. airport and available to coordinate the entry/clearance of the dogs with Federal

government officials until all live dogs transported on an arriving flight into the United States

have either been cleared for entry or arrangements have been made to transport the dogs to a

CDC-registered animal care facility or other facility (e.g., veterinary clinic or kennel) approved

by CDC pending an admissibility determination.

(ee) Order prohibiting carriers from transporting dogs and cats. (1) If the Director

determines that a carrier has endangered the public health of the United States by acting or

failing to act to prevent the introduction of DMRVV, as would occur through failure to comply

with any applicable provisions of this section, the Director may issue an order revoking the

carrier’s permission to transport live animals into the United States, which shall be served on the

carrier’s owner or operator.


(2) The Director may rescind the order after inspecting the carrier’s facilities; examining

its records; conferring with the carrier’s owners or operators, its contractors, or staff; or receiving

information and written assurances from the carrier owner or operator that it has taken remedial

steps to ensure future compliance with the requirements of this section.

(3) A carrier owner or operator may appeal a revocation of a carrier’s permission to

transport live animals into the United States. The appeal shall be in writing, addressed to the

Director, state the reasons for the appeal, and demonstrate that there is a genuine and substantial

issue of fact in dispute. The appeal must be submitted via email to [email protected].

(4) As soon as practicable after completing the written record review, the Director will

issue a decision in writing that shall constitute final agency action, unless the Secretary, within

one business day, decides to review the Director’s decision. The Director will serve the carrier

with a copy of the written decision.

(ff) Prohibition on imports of dogs from DMRVV-restricted countries. (1) The Director

may prohibit or otherwise restrict the import of dogs into the United States from certain countries

designated as DMRVV-restricted countries. CDC will maintain a list of DMRVV-restricted

countries based on the countries’ prior export of dogs infected with DMRVV to any other

countries within a time frame determined by CDC or based on inadequate controls, as

determined by CDC, in the countries to monitor and prevent the export of dogs to the United

States with falsified or fraudulent rabies vaccine credentials, invalid rabies vaccination

certificates, or other fraudulent, inaccurate, or invalid exportation/importation documents.

(2) DMRVV-restricted countries may be subject to additional restrictions, including a

complete prohibition on the importation of dogs into the United States from those countries as

needed to prevent the reintroduction of DMRVV.

(3) The Director may maintain such additional restrictions or prohibitions in place until

the Director is satisfied that the DMRVV-restricted country has established sufficient controls to
prevent the reintroduction of DMRVV into the United States, including measures to prevent the

use of falsified or fraudulent vaccine credentials or invalid rabies vaccination certificates.

(4) The addition or removal of DMRVV-restricted countries from the list shall be

announced through notice in the Federal Register, and a list will be maintained on CDC’s

website.

(5) Notwithstanding the prohibition on imports of dogs from DMRVV-restricted

countries, the Director may allow the importation of dogs for scientific purposes, when used as

service animals (as defined in 14 CFR 382.3) for individuals with disabilities, or in furtherance

of an important government interest. In such instances CDC will issue a CDC dog import permit

for the importation of dogs from DMRVV-restricted countries. Instructions for how to apply for

a permit will be included in CDC technical instructions.

(gg) Request for issuance of additional fines or penalties. (1) CDC may request that CBP,

pursuant to 19 U.S.C. 1592 and 19 U.S.C. 1595a, issue additional fines, citations, or penalties to

importers, brokers, or carriers when the Director has reason to believe that an importer, broker,

or carrier has violated any of the provisions of this section or otherwise engaged in conduct

contrary to law.

(2) CDC may request that the U.S. Department of Justice investigate, and if determined

appropriate based on the outcome of such investigation, prosecute any person who the Director

has reason to believe may have violated Federal law, including by forcibly assaulting, resisting,

opposing, impeding, intimidating, or interfering with a U.S. government employee while

engaged in or on account of the performance of their official duties in violation of 18 U.S.C. 111,

by obstructing an agency proceeding in violation of 18 U.S.C. 1505, or by otherwise engaging in

conduct contrary to law.


Dated: April 30, 2024.

Xavier Becerra,

Secretary, Department of Health and Human Services.

[FR Doc. 2024-09676 Filed: 5/8/2024 11:15 am; Publication Date: 5/13/2024]

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