In a subdivided flat of less than ten square meters in Sham Shui Po, seven female dogs of different breeds are continuously breeding in harsh conditions, with puppies sold online for thousands of dollars—this is a daily snapshot of many illegal breeding operations in Hong Kong in 2022.

According to data submitted to the Legislative Council by the Agriculture, Fisheries and Conservation Department (AFCD) in 2022, there are only a handful of licensed dog breeding establishments across Hong Kong, and the number of licensed animal sellers is starkly disproportionate to the number of pets circulating in the market. During the same year, several legislators pointed out significant regulatory gaps in cat breeding.

With the rise of social media and online trading platforms, a large, hidden network of illegal animal breeding and sales is spreading across Hong Kong, and current regulations are virtually powerless against this problem.

• Legal Gaps: Outdated Legislation Failing to Keep Pace with Change
  
  The primary legislation regulating animal breeding and sales in Hong Kong, the Public Health (Animals and Birds) Regulations, was designed mainly to protect public health rather than animal welfare. The definition of “animal seller” in this regulation is narrow, focusing primarily on the hygiene of the premises, with almost no requirements regarding the source of the animals, their welfare conditions, or the qualifications of the breeders.
  
  The most glaring gap is the lack of regulation on cat breeding. Under current law, dog breeding requires a license, while cat breeding is entirely unregulated. This has led to numerous “backyard breeders” overbreeding cats in poor conditions, reducing mother cats to breeding machines, with kittens often sold before weaning and without vaccinations.
  
  Even for regulated dog breeding, the licensing conditions are overly lenient. License holders do not need to demonstrate knowledge of animal care, and there are no specific standards for the size, ventilation, cleanliness, or social needs of the breeding environment. The AFCD conducts limited inspections, often with prior notice, making it difficult to uncover real issues.
  
  In 2022, legislators questioned the government regarding the regulation of cat breeding and how to strengthen oversight on online animal sales, indicating that the issue has garnered widespread attention.
  
• Online Black Market: Social Media as a Breeding Ground for Illegal Trade
  
  With platforms like Carousell, Facebook, and Instagram becoming widespread, illegal animal trading has shifted from physical pet shops to virtual spaces. In 2022, searching for terms like “Shiba Inu puppies” or “British Shorthair cats” on these platforms yields hundreds of sellers.
  
  These online transactions are almost completely outside the realm of regulation. Sellers are not required to provide proof of animal origin, health check records, or breeding license numbers. Many advertisements use stolen images or showcase healthy puppies while delivering sickly animals instead. Both consumer rights and animal welfare are compromised in this process.
  
  More concerningly, these online sellers are often directly linked to illegal breeding operations. To evade regulation, they use fake accounts and encrypted communications, deleting records immediately after transactions, creating a “guerrilla” sales model. Even if the AFCD detects suspicious advertisements, enforcement often fails due to difficulty in tracking physical locations.
  
  This covert trading model not only encourages illegal breeding but also leads to impulsive purchases. Consumers, unaware of the animals’ needs and their own responsibilities, easily acquire pets, often leading to abandonment or inadequate care later on.
  
• Animal Suffering: The Harsh Realities of Illegal Breeding Farms
  
  Illegal breeding farms operating in regulatory blind spots are hotspots for animal welfare disasters. These facilities are typically hidden in industrial buildings, village houses, or remote metal sheds, and the conditions are terribly inadequate.
  
  To maximize profits, illegal breeders keep mother animals continuously pregnant with little recovery time. The animals live in cramped, dirty cages, lacking proper food, clean water, and veterinary care. Common hereditary diseases spread due to inbreeding, and social deprivation causes severe behavioral issues.
  
  Puppies and kittens from these operations are often sold before reaching proper weaning age. Their immune systems are fragile, lacking necessary vaccinations, making them susceptible to deadly diseases like canine parvovirus and feline panleukopenia. Many consumers face hefty veterinary bills soon after purchase, while the animals suffer and sometimes die in pain.
  
  The suffering of these animals is silent, hidden from public view. Even if a facility is occasionally exposed, operators often escape punishment due to insufficient evidence or legal loopholes.
  
• Regulatory Challenges: Ineffective Enforcement and Insufficient Authority
  
  Hong Kong faces multiple enforcement challenges in combating illegal animal breeding and sales. The AFCD, as the principal enforcement agency, is severely understaffed. In 2022, the Animal Management Division, responsible for all related enforcement work, had limited personnel yet had to handle numerous complaints and inspections.
  
  Current laws grant enforcement officers limited powers. Even if there are suspicions of illegal breeding at a location, officers often cannot enter for inspections without a search warrant or direct observation of abuse. Enforcement is even more complicated for online transactions, requiring inter-departmental cooperation and more advanced investigative techniques.
  
  A critical issue is that the AFCD lacks the authority to revoke animal seller licenses due to animal cruelty convictions. Even if operators are convicted, they can continue to hold licenses, severely undermining the deterrent effect of the law.
  
  The fragmented responsibilities among departments exacerbate the problem. The AFCD is responsible for animal welfare, customs handles border controls, the police address criminal elements, and online platform supervision falls to the Communications Authority. The lack of an effective coordination mechanism makes enforcement actions less effective.
  
  
• The Path to Reform: Comprehensive Regulation of Illegal Animal Trade
  
  In the face of the growing problem of illegal animal trade, Hong Kong must undertake systemic reforms. We propose the following specific recommendations:
  
  • Amend Legislation to Plug Gaps
    
    • Immediately amend the Public Health (Animals and Birds) Regulations to include mandatory licensing for cat breeding, subjecting it to the same standards as dog breeding.
    • Increase the licensing thresholds for animal sellers and breeding establishments, requiring applicants to demonstrate knowledge of animal care and submit veterinary cooperation agreements.
    • Grant the AFCD clear authority to revoke or refuse the renewal of relevant licenses based on animal cruelty-related convictions.
      
  • Strengthen Regulation to Trace Origins
    
    • Implement a “mandatory microchipping prior to transfer” system, requiring all commercially sold dogs and cats to be microchipped in advance, recording information of breeders and the first buyers.
    • Establish a central registry for animal breeding and sales, requiring all license holders to regularly report the number of animals, breeding records, and sales situations.
    • Require all animal sales advertisements to display valid license numbers, allowing consumers to verify seller legitimacy.
      
  • Enhance Enforcement and Increase Deterrence
    
    • Increase the number of animal welfare inspectors at the AFCD and provide specialized training to enhance investigation and prosecution capabilities.
    • Establish a cross-departmental joint action mechanism to integrate resources from the AFCD, police, customs, and the Lands Department to target illegal breeding hotspots.
    • Raise penalties for illegal breeding and unlicensed sales to reflect the illicit gains with effective deterrent effects.
      
  • Public Education to Reduce Demand at Source
    
    • Initiate public education campaigns to raise consumer awareness, encourage “adoption over purchase,” and educate citizens to identify illegal sellers.
    • Collaborate with the veterinary industry to establish reporting mechanisms, encouraging veterinarians to report suspected animals from illegal breeding operations.
    • Promote the concept of “responsible purchasing” and provide guidelines to help prospective pet owners choose ethically sourced animals.

2022 is a crucial moment for strengthening regulations on animal breeding and sales in Hong Kong. As societal attention towards animal welfare increases, public expectations for the government to strengthen oversight are also rising.

Illegal breeding and sales not only cause immense animal suffering but also pose public health risks and issues regarding consumer rights. This is not just an animal welfare issue but also a public policy and social governance issue.

We call on the government to acknowledge this long-standing gap and take decisive measures to reform related legislation and enforcement mechanisms. Only through comprehensive, systemic reforms can we fundamentally dismantle the dark profit chain built on animal suffering, making Hong Kong a city that is friendly to all lives.