This part of it is left up for interpretation..it just brings more confusion because some of the Amish puppy millers will no doubt say they are breeding working dogs.
Q. Does this fi nal rule bring working dogs sold at
retail under regulation?
A. Working dogs are generally understood to be dogs
that are not sold for use as pets but for purposes such
as hunting, breeding, and security. Dogs sold at retail
for these purposes do not come under regulation
under the AWA.
Q. Will APHIS require working dog breeders to be
regulated if they occasionally sell an animal as a
pet that has proved unsuitable as a working dog
due to birth defects, poor temperament, or other
A. Individuals who intend to breed and sell dogs at
retail as working dogs may occasionally raise a dog
that lacks the characteristics that would enable it to be
sold or used for its intended working purpose. As long
as the individual originally intended to raise and sell
the dog at retail for that purpose and the individual
continues to market his or her dogs for that purpose,
the individual could sell the individual dog at retail
without needing to be regulated by APHIS.