UPDATE: Shortly after this was posted, the US CDC walked back most of the requirements discussed below. This post will be left up for the historical record, but please note that the information no longer applies. Updated information was posted on July 22, 2024.
Here’s our current list of frequently asked questions about the impending changes to US dog importation rules, which was compiled in collaboration with the CVMA and CFIA. This is where we stand as of today, but as with any emerging situation, things may still change, so keep checking the CFIA website on dogs travelling to the US for the latest updates.
1) Will there be any exceptions or exemptions to the new rules?
These new requirements are set by the CDC, so if a derogation (exemption) is needed, the dog owner/exporter will need to contact the CDC directly to request the exemption. It is at the CDC’s discretion to issue a derogation. This would most likely only be granted for dogs that must travel for veterinary care, but it should not be assumed that any derogation request will be granted, especially if it’s for any other reason. Derogation requests should be directed to CDC by phone (1-800-232-4636) or email (cdcanimalimports@cdc.gov). The CFIA does not have a role in this process. Owners should obtain any derogation in writing, as it should accompany the dog’s export documents and be presented when cross the border.
2) Have the new rules now been finalized?
Not necessarily. Discussions about the new rules and time frame for implementation continue. However, it is prudent to make plans based on the current guidelines as there is also no assurance that anything will change further.
3) What should be done with a dog that has a microchip that it is not ISO-certified?
Microchips that are universally readable but not ISO-certified can be used to identify the dog. However, if the microchip reader used at the border can’t read the microchip, the dog can be denied entry, so consider implanting a new ISO-certified microchip in cases like this, out of abundance of caution. CVMA maintains a list of ISO-certified devices.
4) What is considered “adequate” rabies vaccination?
Vaccination must be performed in Canada with a vaccine licensed for use in Canada. The Documentation of Canadian-Issued Rabies Vaccination form (the export document found on the CFIA’s webpage) indicates the following requirements:
- A primary rabies vaccine which was administered on or after 12 weeks (84 days) of age AND at least 28 days have elapsed since vaccination.
OR
- A booster rabies vaccine which was administered on or after 64 weeks (15 months) of age and the owner had proof of at least 1 previous rabies vaccination that was administered on or after 12 weeks (84 days) of age.
5) For how long is a rabies vaccine considered valid if the dog was late getting its booster?
This is currently a grey area that on which we are trying to get clarification. This is not addressed on the Documentation of Canadian-Issued Rabies Vaccination form (the export document found on the CFIA’s webpage). There is no specific statement that boosters must be given as per label instructions. However, there can be debate about whether an overdue vaccine is considered a “booster” or a primary vaccine from a regulatory standpoint. To be safe, always aim to vaccinate within the vaccine label’s 1 or 3 year interval. The CDC takes a strict line on this in the US – overdue by 1 day means a rabies vaccine can only be considered protective for 1 year. So until we hear otherwise, out of an abundance of caution, if a booster is late, the vaccine should be considered a primary vaccine dose, which means:
- it needs to be given 28 days prior to travel
- it would be considered protective for only 1 year.
If there are concerns or hesitancy surrounding re-vaccinating dogs, then it may be best to wait until all the details about this particular issues have been finalized.
It is important to note that the Documentation of Canadian-Issued Rabies Vaccination form (the export document found on the CFIA’s webpage) is to be signed and authorized 28 days or more after the date of the primary vaccination AND the dog cannot enter the US until 28 days or more after the primary vaccine. This 28 day waiting period does not apply for booster vaccination given withing the prescribed interval (1 or 3 years).
6) If a dog is vaccinated against rabies but does not have a microchip, once the microchip is implanted, does the dog need to restart its rabies vaccinations?
Currently, we have to attest that the animal has a microchip and that it is properly vaccinated against rabies, not the order in which those things happened. There is no guidance on the Documentation of Canadian-Issued Rabies Vaccination form (the export document found on the CFIA’s webpage) that indicates microchipping must precede vaccination. However, in the US, dogs must be microchipped prior to vaccination, and any vaccines that are given before microchipping are not considered when evaluating rabies vaccination status.
Similar to the issue with overdue vaccines, until the rules are clarified, it is prudent to only consider rabies vaccines given after microchipping as valid for export to the US. Therefore, if a dog was vaccinated prior to microchipping, then revaccinate the dog after microchipping (or on the same day as microchipping). That dose of vaccine would likely be considered a primary dose, therefore requiring a 28 day wait until it is considered protective and would only be valid for 1 year. As there is conflicting information being reported in the US about how to approach re-vaccination after microchipping, we are hoping to get clarification on whether this very conservative approach will be necessary. If there are concerns or hesitancy surrounding re-vaccinating dogs, then it may be best to wait until all details about this particular issue have been finalized.
7) What records need to be provided for a dog that has been microchipped for less than 6 months?
If the dog has been microchipped for less than 6 months at the time of travel, two (2) veterinary records (instead of just one) must be attached to the Documentation of Canadian-Issued Rabies Vaccination form (the export document found on the CFIA’s webpage):
- one that provides a description of the dog from 6-12 months ago AND
- one that includes the same description, as well as the new microchip number. This is to provide assurance that you believe the dog with the microchip is the same dog for which you are providing the earlier record.
8) What should be indicated in the medical record if a second microchip is implanted in the dog?
Both microchip numbers should be included in the medical record and on the Documentation of Canadian-Issued Rabies Vaccination form (the export document found on the CFIA’s webpage), so that there is no confusion if the original microchip is identified by the microchip reader at the border.
9) What veterinary records are required for a dog to cross the border to the US from Canada?
A veterinary record from between 6-12 months prior to travel is required as part of the process to confirm the dog has been in Canada for at least 6 months. This is described in note 4 on the Documentation of Canadian-Issued Rabies Vaccination form (the export document found on the CFIA’s webpage). This can be anything that documents the dog, its microchip number and contact with your clinic or another Canadian veterinary clinic. Examples of an applicable Canadian veterinary record include vaccination certificate, health certificate, invoice or purchase record (e.g pet food purchase, prescription renewal) from the veterinary clinic. The dog’s complete medical record in not required. While a record of a clinic visit during which you examined the dog is ideal, it appears that any clinic record for the dog would qualify, even if there was no associated examination or direct contact with the dog itself.
10) What should be done if a dog was last seen 15 months ago for vaccination and there are no veterinary records documenting contact with the dog in the past 6-12 months?
If records from the past 6-12 months are not available, the dog is not eligible to enter the US. They would have to wait 6 months, but not more than 12 months, from their latest visit. The importance of a yearly veterinary visit should be emphasized to owners who may want to take their dogs to the US. This is also an opportunity to discuss travel-associated disease risks and preventive medicine that may be relevant to the dog based on the intended destination (e.g. vaccination for other regionally prevalent diseases, tick prevention, heartworm prevention).
11) What should be done if a dog was last seen 15 months ago for vaccination, and then again 3 months ago, but there are no records in between during the 6-12 month interval from the date of travel?
As above, a record of some kind from 6-12 months ago is required. If that is not available, the dog would have to wait another 3 months until its last visit falls within this interval.
12) What should be done with a new patient being seen for the first time, that has valid vaccination and medical records, including a veterinary visit from 6-12 months ago, but not from my clinic?
The owners can use records from the other Canadian veterinary clinics to document the dog’s status. You can fill in the Documentation of Canadian-Issued Rabies Vaccination form (the export document found on the CFIA’s webpage) and the records from the other clinic can be used to document the dog’s history in Canada.
13) What are the options for a new patient that was microchipped and vaccinated at another clinic in Canada but the owner cannot get medical records?
The dog must have a medical record from 6-12 months earlier to show that it has been in Canada for that time period. If the owner cannot get the previous records, the dog must wait until that time frame has been reestablished based on records from the new clinic. Re-vaccination will also be required if the previous vaccination record cannot be found. The new vaccine would be considered a primary dose and therefore not protective until 28 days after vaccination, and only valid for 1 year.
14) What happens with a dog that moved to Canada from France with its owners 3 months ago, that the owners now want to take to the US?
Currently, dogs from other countries must be in Canada for at least 6 months, or they must travel directly to the US from their original country of origin. If a dog has moved to Canada within the past 6 months, it must be vaccinated in Canada and reside in Canada for 6 months before it is eligible to be taken to the US directly from Canada.
15) Can an exemption be made, or can a rabies antibody titre be used in lieu of re-vaccination, if an owner does not want to re-vaccinate their dog?
The requirement is current vaccination against rabies. There is no option to use an antibody titre in lieu of a rabies vaccination. If there are contraindications to vaccination for a particular dog, a letter to that effect can be provided by the veterinarian to CDC as part of the owner’s derogation request. Demonstrating an acceptable titre might be useful as part of the derogation request. The likelihood of acceptance of such a request is unknown.
It is also important for clients to be aware that, even if they get a CDC derogation, there may be individual state requirements for rabies vaccination of dogs, and that rabies vaccination is required if the dog is to return to Canada.
16) Can a medical exemption be obtained for a patient that would go straight from a Canadian veterinary clinic to a US veterinary clinic and back?
No, not beyond the standard derogation process mentioned above. A derogation is probably most likely to be granted for a situation like this, but is not guaranteed, and it would not necessarily be granted quickly. Last-minute border crossing for veterinary care may not be possible for dogs that are not able to immediately fulfill the standard requirements.
17) What should be entered on the export form if the date the dog’s microchip was implanted is unknown?
You can enter the date that you first documented the dog’s microchip in your medical records.
18) Can a veterinarian sign the export paperwork for their own dog?
This is not specifically addressed in the new rule, but it is a standard best practice for veterinarians not to sign export papers of any sort for their own animals, because of the potential conflict of interest. If possible, another veterinarian should sign the paperwork. If that is not possible, it would be wise to contact CDC to see if this will cause any problems.
19) What destination address should be entered for clients who are taking their dog to a park, mall or some other location in the US that’s not a house or hotel?
The address of a park, shopping facility or other location can be indicated as the destination. If multiple places will be visited, the location that the dog will spend the most time should be used. It must be an actual address (i.e., not a PO box). The US address being visited may change from what is initially recorded on the Documentation of Canadian-Issued Rabies Vaccination form (the export document found on the CFIA’s webpage), as it’s valid for up to 1 to 3 years. However, the dog owner/exporter will also complete the CDC’s Dog Import Form for each entry into the U.S., and there they will indicate the current address they will be visiting.
20) Can the export form be completed in French?
No, as the form is for submission to US officials, it must be completed in English. However, we are still awaiting confirmation that the accompanying medical records that are being used to document the presence of the dog in Canada can be supplied in French, as long as the dog’s name, owner’s information and microchip ID are clearly identifiable.
Where is the most up-to-date information on movement of dogs from Canada to the US posted?
- Canadian Food Inspection Agency (CFIA) webpage: Instructions for Canadian licensed veterinarians (Authorized Veterinarians)
- US Centers for Disease Control (CDC) webpage: Bringing a dog into the US