Animal Charity

The FOUR PAWS Model Solution

For full traceability across the European online puppy trade

Update: June 2021 

Through our investigations, research and campaigns, FOUR PAWS has revealed the illegal puppy trade is rife with animal cruelty, deception and risk of disease. The main channel to market for the illegal puppy trade is online classified ad sites which provide sellers with easy access to a significant pool of potential buyers. Due to the anonymity provided by such platforms, international puppy traders use them to sell illegally imported puppies to the UK without much threat of being identified and prosecuted. The national demand for puppies is higher than the breeding capacity of responsible breeders, and therefore unscrupulous breeders have stepped in to meet this demand. 

Traceability is a key issue across the illegal puppy trade as puppy dealers often disappear once the sale has been made online, leaving the human victims of the trade (pet buyers) to deal with sick animals and high veterinary costs. There is currently no legislation in place across Europe that tackles this problem. 

The EU Animal Health Law

The EU Animal Health Law (AHL) presents an unprecedented opportunity to eliminate the illegal puppy trade. The AHL has been in force in all EU member states since 21 April 2021. The overall aim of the AHL is to provide prevention, protection and control measures against transmissible animal diseases. 

In the illegal puppy trade, puppies are taken from their mothers while still too young and illegally transported across Europe, mostly from Eastern European puppy farms. 

The AHL requires that all sellers and breeders, transporters and assembly centers of dogs, cats and ferrets to register their establishments with the national government. This is a turning point towards phasing out the illegal puppy trade because the AHL provides traceability of all breeders and sellers establishments; this is important because it also helps to provide a way of identifying unscrupulous sellers and breeders. 

FOUR PAWS Model Solution

To exclude illegal puppy dealers effectively from the UK online market, the introduction of the FOUR PAWS Model Solution is essential, even as a non-EU member country.  

The AHL can also help to address the illegal online trade because it provides transparency. 

The way in which this can be achieved is for national governments to create digital national establishment registration databases and for registration numbers to be allocated to all breeders and sellers who register their establishments. Classified ad sites should be legally required to verify the registration number before an ad goes live. If a seller is not registered, they should ideally not be allowed to sell online. Registration should be made as simple as possible and cover both private and commercial sellers. Most unscrupulous sellers/breeders will not want to register their establishment because it means they can be identified and traced. This system would provide a very good starting point for enabling better traceability of breeders and sellers and help to reduce the illegal online puppy trade. 

However, a further step that should be taken to address the illegal online puppy trade would be to link national establishment registration databases with national identification and registration (pet microchip) databases – preferably by adding the establishment registration number to the dogs in the pet microchip database. With this additional step, full pet and seller traceability can be achieved. For example, it would be easy to see which animals are from which breeding/seller establishment and this will enable enforcement agencies to quickly identify how many sick or illegally imported puppies are linked to which breeding/seller establishment. Action can then be taken to address the situation. 

An international entity which is provided with information from national I&R databases (such as Europetnet), could set up an interface to provide a checking service to all classified ad sites across Europe. This could include checking that both the animal and seller are registered and that the animal is registered to the seller as the current owner. With this interface, the classifieds can verify if the sellers’ stated information, such as microchip number or age, and other parameters are correct. Only after this verification process should an ad be able to go live. 

To make individual pets fully traceable, it is crucial that animals are microchipped and registered on a national Identification and Registration (I&R) database by a vet. To facilitate full traceability there would need to be a legal requirement for these databases to include data covering all the stakeholders involved in an animal’s life: the breeder, the seller, the transporter (ideally including their status and registration number as specified under the AHL) and the microchipping vet. Only then will competent authorities be able to find out the origin of every sick animal, as well as the whereabouts of any stakeholder involved. 

Animal Charity

Statements of Support


Stakeholders across Europe have already aired their interest in participating in a pioneer project to implement the Model Solution, including EuroPetNet, pet registries and classified ad sites. 

FOUR PAWS is in touch with and supported by several further stakeholders.

“After exploratory talks, the Board of Europetnet wishes to express its support for the aims and approach of the FOUR PAWS Model Solution. We believe that cooperation between online advertisement platforms and Identification and Registration Databases through the integration of their respective processes will not only ensure tighter regulation of the online trade in dogs, but will also enable traceability of those involved and ultimately go a long way to eradicate the illegal puppy trade. 

Michel Schoffeniels, President of Europetnet, Belgium

“Eurogroup for Animals is the only pan-European umbrella organisation for animal welfare. We channel the national influence of each of our 66 members into a powerful voice, creating opportunities for a change across Europe that cannot be achieved individually. Our aim is to improve animal welfare as quickly as possible by working together with the EU institutions to deliver better legislation and enforcement. Eurogroup for Animals has contributed to FOUR PAWS’ Model Solution Report, and will encourage the implementation of the outlined ideas by bringing such effective and efficient solutions to policy makers and key stakeholders at the EU level.” 

Reineke Hameleers, Director of Eurogroup for Animals, Belgium

“Both 'Chipworks' in the UK, and 'Fido' in Ireland are interested in participating in a online trade registration validation and check system. In the case of both registries we are ready to integrate official breeder registration / license numbers within the current data file structure and we have developed IT systems that allow for information checks to validate online advertisements.”

Finbarr Heslin, Director of Fido (Irish-government licensed I&R database) and Director of Chipworks (UK-government approved I&R database), UK

With this system we could finally achieve Europe-wide full traceability of pets and exclude illegal puppy dealers from the market. This would be a critical step for disease prevention, consumer safety, protecting both animal and public health!

Next steps and your opinion

FOUR PAWS has produced a report to explain our Model Solution further, which you can find here. If you have comments about our Model Solution, please contact

Animal Charity

Download our report