CDC Dog Import Final Rules Effective Aug 1, 2024
CDC Dog Import Final Rules Effective Aug 1, 2024
42 CFR Part 71
RIN 0920-AA82
AGENCY: Centers for Disease Control and Prevention (CDC), Department of Health and
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.
Global Migration Health, Centers for Disease Control and Prevention, 1600 Clifton Road, NE,
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
I. Executive Summary
III. Background
a. Legal Authority
b. Regulatory History
V. Alternatives Considered
I. Executive Summary
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
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
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
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,
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,
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
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
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.
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,
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
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
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,
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
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
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-
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
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.
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.
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
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
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
registered ACF.
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
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
compliance with CDC regulations; 3) ACF are experienced in pet transportation and trained to
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.
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
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
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
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
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
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
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
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
Table E1. Summary table of finalized importation requirements for dogs based on
vaccination status and country of origin
* 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
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
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*
required to provide additional information to the ACF to make a reservation for their dog prior to
** Importers of dogs from DMRVV-restricted countries are required to have either a valid
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.
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
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
• Importers of dogs from countries that are DMRVV-free or are low risk for DMRVV;
• CBP;
• CDC;
• USDA; and
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
• 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
added more examples of the types of proof required. Each type of document
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
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
which will remain valid for multiple trips for up to three years corresponding to
• CDC increased the estimated costs associated with shipping blood samples to
• 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
• 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
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
reduced because the final rule will not require that such dogs arrive at U.S. ports with
• 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
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
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
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
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
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
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
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
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
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
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
free country in peer-reviewed journal articles which are publicly available.41,42 Because of an
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.
Changes to 71.50
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
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
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.
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
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
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
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
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,
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
months must enter through a U.S. airport with a CDC quarantine station and an ACF.
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.
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
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
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.
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
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
Section 71.51(i) is finalized as proposed. This final rule requires that dogs and cats may
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
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
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
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
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
This final rule further requires that the dogs remain in the custody of an ACF until all of
USDA-Accredited Veterinarian.
considered valid, serologic tests must be drawn prior to arrival within an established
instructions.50 Dogs that arrive without an adequate rabies serologic test results from a
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
Technical Instructions for CDC-registered Animal Care Facilities would constitute grounds for
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
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,
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
• The bill of lading (or other alternative documentation if the airline has been granted a
• The name, address, phone number, and email address of the importer and owner (if
• The identity of each animal in each shipment, including name, microchip number, date of
• The airline, flight number, date of arrival, and port of each shipment; and
applicable); and
▪ All diagnostic test, histopathology and necropsy results performed during
The facility is required to maintain these records electronically and allow CDC to inspect the
records.
Section 71.51(n) is finalized as proposed with the exception that HHS/CDC is noting that
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
Recommended Practices for Safety and Health Programs51 and the National Association of
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
(o) CDC-registered animal care facility standard operating procedures, requirements, and
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
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
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:
arrival;
• Verification of microchip and confirmation that the microchip number matches the
• Verification of animal’s age via a dental examination (or other CDC-approved method);
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
testing to determine the cause of death. An animal that arrives ill or becomes ill while at the ACF
diagnostic testing to determine the cause of illness prior to release from the facility. Suspected or
identification.
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.
be reported to CDC. ACF must also establish standard operating procedures for safe handling
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
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
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
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
(s) Requirement for the Certification of Foreign Rabies Vaccine and Microchip form to import a
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
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
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
(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
considered valid. Certification of Foreign Rabies Vaccination and Microchip forms must be
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
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
comply with State or Territorial requirements for rabies vaccination in cats and dogs from
Section 71.51(v) is finalized as proposed with the exception that HHS/CDC may
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
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
• 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
• Any dog that is not accompanied by a receipt confirming that a CDC Dog Import Form
• 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
• 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
• Any dog that has been in a DMRVV high-risk country within the last six months and
• Any foreign-vaccinated dog imported from a DMRVV high-risk country that arrives
• Any dog from a DMRVV-restricted country that arrives without a valid CDC Dog Import
Permit.
country if the CDC Director reasonably suspects fraud in any documentation required for
• 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
• 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
(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
Animals arriving by air must be held in an ACF or another CDC-approved facility (if an ACF
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
(x) Disposal or disposition of dogs and cats denied admission or abandoned prior to admission
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
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
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
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
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
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
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
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
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
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
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.
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
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.
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
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.
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
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
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,
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
countries will be published as a notice in the Federal Register. HHS/CDC may allow the
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,
U.S. government employee while engaged in or on account of the performance of their official
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.
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
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
also improve
alignment with
USDA import
requirements (7
CFR 2148) for
dogs imported
for resale.
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.
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
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
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
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.
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
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:
• 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 proposed requirement for the rabies vaccination form for foreign-vaccinated
• The proposed public health standards and evidence used to maintain a list of
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
• The potential costs to carriers of dogs arriving by land or sea (as opposed to
• Estimates of the number of dogs any small individual entity currently imports
• 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
The following is a discussion of public comments received that are applicable and within
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
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.
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
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
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,
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
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
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
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
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
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,
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
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
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
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
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.
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
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
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
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
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
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
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
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
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.
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-
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
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.
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
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 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
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
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
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
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
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
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
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
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
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
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
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
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
Comment: HHS/CDC received comments that the NPRM is not needed because U.S.
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
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
There have been significant challenges for State and Federal agencies in enforcing or
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
This final rule will reduce the enforcement burden on jurisdictions and help to ensure all
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
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
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
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.
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
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
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
administration of a rabies vaccine and a rabies antibody titer collected and tested
• Undergo examination the day prior to shipment to ensure the animal is not
• Are permanently identified (e.g., microchip) with the identification number listed
on the certificate;
• Have a titer test conducted not less than 3 months and not more than 12 months
• 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
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
• 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
• 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;
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
titer as most countries do not have this capacity. Instead, HHS/CDC has identified CDC-
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.
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)
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
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
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
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
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
dogs, or owners of service animals to alleviate the potential burden of the temporary suspension
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,
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.
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
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
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
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
assisting them in making reservations at ACF and educating importers about the importance of
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
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
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
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
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
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.
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
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
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
Comment: HHS/CDC received a comment stating that dogs imported for research
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
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
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
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
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
Definitions
Section 71.50
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
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
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
veterinarian.
71.50 and states it is “a veterinarian who performs work on behalf of an exporting country’s
Forms
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
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
“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,
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
HHS/CDC did not receive comments on the following definitions proposed for 42 CFR
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
Sections 71.51
Paragraphs (b) — Authorized U.S. airports for dogs and cats and (c) —Authorized U.S. land
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.
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
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
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
Airport (New York), Los Angeles International Airport (2), Miami International Airport,
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
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
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.
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
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.
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
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
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
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
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
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
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.
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
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
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
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
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.
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.
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
requirement for dogs to be at least six months of age is unlikely to impact importers with service
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
microchips may be difficult to obtain in some low-income countries. Some USG employees also
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
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
The microchip requirement will also promote greater confidence in the information
recorded on the rabies vaccination records and prevent fraud. CDC has documented several
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
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
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
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
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
accommodation based on religious beliefs under RFRA, they should contact CDC through
Requests for an exemption or accommodation under RFRA must be made 120 days prior to
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.”
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
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
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
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
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
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
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
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.
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
Comment: HHS/CDC received comments that the CDC Import Certificate should be
requirements in this final rule that veterinary documentation be certified by official government
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
requesting that the CDC Dog Import Form not require involvement from a licensed 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
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.
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.
numerous instances of importers using falsified or fraudulent EU pet passports. EU pet passports
in this final rule that veterinary documentation be certified by official government veterinarians
veterinarians are able to certify that an accredited veterinarian is authorized to practice veterinary
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.
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
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
importers has a greater likelihood of allowing CDC to detect both fraudulent paperwork and
foreign-vaccinated dogs from DMRVV high-risk countries because the dogs have already been
vaccinated overseas.
variability in the quality and efficacy of rabies vaccines produced in some countries.164,165
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
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
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
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.
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
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
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
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
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
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
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.
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
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.
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
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
either proof of an adequate titer or undergo quarantine at an ACF to meet U.S. entry
requirements.
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.
or vaccinated only upon arrival or that HHS/CDC should not require dogs to be vaccinated
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
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.
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.
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
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
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
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.
reservation, an ACF must ensure they have received serologic test results obtained from a CDC-
instructions (if applicable); otherwise, the dog will be required to quarantine for 28 days upon
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
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.
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
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
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.
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).
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
requirements, and equipment standards for crating, caging, and transporting live animals.
Paragraph (p) — Health reporting and veterinary service requirements for animals at CDC-
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
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
Additionally, although HHS/CDC did not receive public comment on this issue,
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.
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.
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.
Microchip Required for Live Dog Importations into the United States form to import foreign-
Comment: HHS/CDC received comments that importers should not be required to have
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
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
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
Lastly, many DMRVV-free and DMRVV high-risk countries currently require importers
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
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
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
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
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
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
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
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
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
Comment: HHS/CDC received comments that an importer should not be required to have
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
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
Of note: CDC has shortened the name of this form in the final rule to Certification of
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
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
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
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.
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.
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
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 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
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
payment for veterinary services establishing that veterinary services were performed in
the exporting country at least six months before traveling to the United States.
establishing that veterinary services were performed in the same DMRVV rabies-free or
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
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
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
vaccination, serologic titers, quarantine, or limiting ports of entry for dogs arriving from
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
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
Animals arriving by sea that are denied admission must remain on the vessel while
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.
interpreted HHS/CDC’s NPRM as proposing to euthanize dogs that do not meet HHS/CDC entry
paragraph (w).
Paragraph ( (x)) — Appeals of CDC denials to admit a dog or a cat upon arrival into the United
States.
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
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
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
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
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
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
testing capabilities, or overnight (24 hours a day) monitoring to determine whether a hospital or
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
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,
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.
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
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
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
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
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
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
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
Comment: One commenter noted that HHS/CDC should utilize CBP’s Automated
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
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
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
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
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
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
Comment: HHS/CDC received comments from the public that it will be difficult to
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
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
Comment: HHS/CDC also received comments that airline costs would increase or that
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
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
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
Paragraph (dd) — Order prohibiting carriers from transporting dogs and cats.
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.
which the importation of dogs into the United States would be prohibited. The list of DMRVV-
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
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
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
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 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
interfering with a U.S. government employee while engaged in or on account of the performance
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
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
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
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.
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
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-
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
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
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
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
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
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
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
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
Comment: Some commenters expressed concerns that sudden changes to the DMRVV
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
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.
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
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
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
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
HHS/CDC continues to review its list of DMRVV high-risk countries annually and will update
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.
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
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
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
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
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
a) a valid foreign export certificate from a DMRVV-free or DMRVV low-risk country that has
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
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
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
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
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
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
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
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,
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
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
$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
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-
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
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
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
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
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.
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
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
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
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
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
Comment: HHS/CDC received comments that the final rule will make it harder to travel
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,”
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
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
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
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
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).
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
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
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
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
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
Comment: HHS/CDC received several comments that proposed CDC issue fines or
citations against importers who violate U.S. entry requirements, present fraudulent
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
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
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.”
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,
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
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).
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;
another agency;
• Materially altering the budgetary impact of entitlements, grants, user fees, or loan
• Raising legal or policy issues for which centralized review would meaningfully further
OMB’s Office of Information and Regulatory Affairs has determined that this rulemaking is
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
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
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
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;
• CBP;
• CDC;
• USDA; and
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
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.
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
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
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
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
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
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
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
commensurate with its cost to provide Certification of U.S.-issued Rabies Vaccination forms for
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
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
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
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
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
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
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)
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:
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
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
$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%,
• The costs associated with the requirement for proof that a dog has been only in
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
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
which will remain valid for multiple trips for up to three years corresponding to
• 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 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
DMRVV-free or low-risk countries and by 50% for dogs imported from DMRVV
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
• 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
• 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
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
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
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
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 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
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
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
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
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
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
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-
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
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
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
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
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
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
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.
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
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
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
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
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.
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
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
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
determination. CDC believes this will only incur additional costs on occasion since airline staff
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
• If dogs were allowed to have either a microchip or tattoo (instead of allowing only
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
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
these costs would only be incurred for importing dogs from DMRVV high-risk
countries).
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.
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
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-
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
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
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)
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
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,
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
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
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.
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
• If dogs were required to have both a microchip and a tattoo (instead of requiring only
tattoos tend to cost more than microchips (i.e., the cost for this requirement would 2.25
• 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
because they currently do not need to obtain these documents (with an assumed cost of
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
• If CDC required a 90-day waiting period from the time a dog blood sample was drawn to
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
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
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
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)
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.
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
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
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 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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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,
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
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
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:
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
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
$200 to $400) for dogs shipped as hand-carried or checked baggage254. Under the
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%,
• 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
added more examples of the types of proof required. Each type of document
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
which will remain valid for multiple trips for up to three years corresponding to
• 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
• 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
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
• 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
• 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
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
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
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 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.
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
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
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
Statistics.259 Monthly average numbers of employees in 2019, including part- and full-time
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
125 percent (Table 12). Among the selected 35 airlines, seven had zero U.S. international
arrivals in 2019.261
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
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
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
• Whether the collection of information is necessary for the proper performance of the
functions of CDC, including whether the information will have practical utility.
• Ways to enhance the quality, utility, and clarity of the information to be collected.
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
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
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
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
Microchip form. This form will capture the rabies vaccination and microchip
importers in ensuring they provide all required information and to prevent fraud
• 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
DMRVV low-risk country at least six months before traveling to the United
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
dogs from these countries will use this form. Additional options for these
• 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
personal pet dogs with a valid rabies vaccine and serologic titer results during the
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
• CDC is adding a new form - CDC Dog Import Form - which will collect
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
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
order to register with CDC, representatives of the facility need to complete and
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
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.
States
Procedures)
Procedures
Procedures)
The burden table below has been updated to reflect updated burden hours for the new and
amended forms.
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
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.
HHS/CDC has determined that amendments to 42 CFR part 71 will not have a significant
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.
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
diseases, DMRVV, Dog, Dog-maintained rabies virus variant, Entry, Importation, Importer,
Microchip, Necropsy, Port, Public health, Quarantine, Rabies, Rabies vaccination, Rabies virus,
For the reasons discussed in the preamble, the Department of Health and Human Services
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).
*****
(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
*****
*****
Histopathology means the study of changes in human or animal tissues caused by disease.
*****
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.
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.
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”,
(a) * * *
Animal means, for purposes of this section, any domestic cat (Felis catus) or domestic
(ii) reviewed and signed by an official government veterinarian in the exporting country
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
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
Certification of U.S.-issued rabies vaccination means the OMB-approved form that must
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
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
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
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
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,
distribution of the virus, and the virus being in a controlled status with the country’s heading
DMRVV-restricted country means a country from which the import of dogs into the
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
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
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.,
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
serology sample must be drawn, submitted, and tested in accordance with CDC technical
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
(b) Authorized U.S. airports for dogs and cats. (1) Cats may arrive at and be admitted
(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
(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
(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
(c) Authorized U.S. land ports for dogs and cats. (1) Cats may arrive at and be admitted
(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
(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
(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
(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
(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
(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
(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
(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
(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
(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
(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
(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’
granted a waiver to the bill of lading requirement, the airline’s handling and transport of the dogs
(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
(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
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.
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
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
veterinarian.
(6) The airline or vessel’s master or operator shall immediately thereafter arrange for
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
(7) The Director will consider the findings of the examination and tests in determining
(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
(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
(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
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
(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
(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;
(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
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
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
(iv) Vaccination against rabies with a USDA-licensed rabies vaccine that is administered
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
(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
(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:
(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
(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
care facility stating that the facility is in compliance and agrees to continue to comply with the
(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,
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
(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-
certificate issued under this section is effective for two years beginning from the date CDC
(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
(5) All CDC-registered animal care facilities must comply with the requirements of
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
(ii) the name, address, phone number, and email address of the importer and owner (if
(iv) the identity of each animal in each shipment, including name, microchip number,
(v) the airline, flight number, date of arrival, and port of arrival of the shipment; and
(A) Certification of foreign rabies vaccination and microchip form and rabies serology
(D) rabies serology performed while in quarantine in the United States (if applicable);
(F) necropsy reports for imported animals that die while in the care of the CDC-registered
(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
(iii) CDC will audit records remotely as needed and in-person during site inspection
(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
Recommended Practices for Safety and Health Programs and the National Association of Public
(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
(5) Procedures for documenting the frequency of worker training, including for those
(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,
(iii) Procedures for disinfection or safe disposal of garments, supplies, equipment, and
waste; and
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.
(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
(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
arrival;
(ii) verification of microchip and confirmation that the microchip number matches the
(iii) verification of an animal’s age via a dental examination or, if dental examination
drawn from a dog prior to arrival within a timeframe and results within parameters as specified
(2) A CDC-registered animal care facility must provide the following services upon the
(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
(ii) Notification to CDC within 24 hours of the arrival of an ill animal or occurrence of
illness and diagnostic testing to determine the cause of illness. All costs associated with
(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.
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
(4) Any report required under this paragraph must be uploaded to SAFE TraQ prior to the
(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
(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
(i) The CDC-registered animal care facility must be locked and secure, with access
(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
(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
(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
(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
(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
in the CDC's implementation of additional measures to rule out the spread of suspected
(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.
(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
(2) CDC will send the CDC-registered animal care facility a notice of revocation stating
(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
(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,
(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
(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
(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
(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
(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.
(3) The certification of foreign rabies vaccination and microchip form must be truthful
(i) The name of the person importing the dog (consignee), physical address, phone
(iii) The destination address (physical address) where the dog will reside upon arrival in
(iv) The dog’s name, breed, sex, date of birth or approximate age if the date of birth is
(v) Rabies vaccination information for the dog administered within a timeframe and in
(vi) Rabies vaccine product information (product name, manufacturer, lot number, and
(vii) Rabies vaccine expiration date (date when next vaccine is due), which must be after
(viii) Microchip number and microchip implant date, which must be on or before the date
(ix) The name, license number or official stamp, address, telephone number, email
address, and signature of the authorized veterinarian or official government veterinarian that
veterinary medicine in the exporting country and further attesting that the information listed on
(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
(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
(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
(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
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
(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
(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
country;
(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.
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
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
(vi) Other records or documents satisfactory to the Director that CDC may establish
(v) Denial of admission of dogs and cats. (1) The following categories of animals are
(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
(ii) Any dog that is not accompanied by a receipt confirming that a CDC dog import form
(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
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
(vi) Any animal imported by an importer who refuses to comply with the requirements (if
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
(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
(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
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
(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
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.
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
(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
(4) Animals arriving by sea that are denied admission must remain on the vessel while
(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
(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
(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
carrier (e.g., under circumstances where the animal is fatally ill or injured), the animal must be
Association guidelines. Euthanasia does not relieve carriers or importers of the obligation to
(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
(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
evaluation or care, or upon denial of entry. Carriers may require reimbursement from an 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
(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
(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
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
(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
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
(4) The carrier shall send copies of the final necropsy report and all test results to the
(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
(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
(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
cleaned and disinfected or destroyed in accordance with carrier policies. CDC may require
(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
(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
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
(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
(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
(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
(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
(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
(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
(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-
(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
(v) CDC may publish additional technical instructions on its website for airlines seeking
(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
(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
(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
(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
(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
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
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
(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
countries based on the countries’ prior export of dogs infected with DMRVV to any other
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
complete prohibition on the importation of dogs into the United States from those countries as
(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
(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.
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
(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,
engaged in or on account of the performance of their official duties in violation of 18 U.S.C. 111,
Xavier Becerra,
[FR Doc. 2024-09676 Filed: 5/8/2024 11:15 am; Publication Date: 5/13/2024]