USDA licensure?

I was wondering what everyone's thoughts are about USDA licensure? Does anyone on here have licensing with the USDA for breeding rabbits (that aren't strictly fur/meat rabbits)? It doesn't seem practical (or even realistic) for anyone ... I wonder if they ever think of that before they make laws...

I believe unless make more than $500 in indirect sales (selling at shows or in person are direct sales... Selling to pet stores and stuff is indirect sales) you don't need a license.

BelleVie":3pz6dgc1 said:

I wonder if they ever think of that before they make laws...

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I wonder if you even read the law before forming an opinion and providing commentary? I would estimate the majority of rabbit people fall into the exemptions. It really doesn't affect anyone but people trying to do large scale pet operations; practically the rabbit equivalent of a puppy mill.

Your comment made me think of this article I read one time when I was looking into licensing.

Paraphrased Headline: Family Faces Massive Fine For Selling "A Few" Rabbits
Body of Article: They sold a couple hundred rabbits to pet stores. Not exactly your average rabbit owner, not even your above average rabbit owner who is lucky enough to actually make $$ in this.

That seemed a touch...harsh.

Look at it this way. Depending on where someone lives, some breeds go for big bucks. We have threads on prices somewhere. If someone sells just 10 rabbits to a pet store for resale at $50 each, there is the $500 limit. Hardly a rabbit mill.

And to answer your question Belle, I have read the reqs and want nothing to do with the licensing.

Marinea":6mxa2vjt said:

That seemed a touch...harsh.

Look at it this way. Depending on where someone lives, some breeds go for big bucks. We have threads on prices somewhere. If someone sells just 10 rabbits to a pet store for resale at $50 each, there is the $500 limit. Hardly a rabbit mill.

And to answer your question Belle, I have read the reqs and want nothing to do with the licensing.

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I agree... a bit to quick to jump to conclusions. The laws are not the easiest to read, and there are some people on here that have, or would like to have bigger scale options - not necessarily "puppy mills" like the media reports. And, as mentioned, some breeds are higher dollar than others so it wouldn't take many sales to hit that quota. Some people have such a following they are selling to people much farther than a local CL ad would reach. If you have prize show rabbits and would like to sell their offspring you could max out pretty quick!

I looked into them b/c I had someone contact me with a too-good-to-be-true business venture. I was pretty excited about it until I learned that I would need to deal with USDA stuff :x . I will never know now if it was them fishing for someone to bite to then nail with the laws or if they truly were interested...

Marinea":dckoelcf said:

That seemed a touch...harsh.

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FourRingCircus":dckoelcf said:

agree... a bit to quick to jump to conclusions.

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Good it was meant to be. Although I would argue it is no more harsh than BelleVie's analysis and willingness to jump to conclusions. BelleVie isn't asking if this applies to his/her situation. Or if his/her understanding is correct. Or throwing out a hypothetical. Or getting into a spirited debate on the appropriateness of the $500 limit. Something like that would get a nicer response.

You don't actually need to read 9 CFR. Do you know what the first result is if you do a simple Google search for USDA rabbit license? A nice explanation from the government on what is actually covered.

https://www.aphis.usda.gov/animal_welfa ... licreg.pdf

With nice bits of easy to comprehend information:

The rabbit business is exempt from regulation if the rabbits are intended only for food or fiber. If any rabbits are designated for use in the pet, exhibit, or laboratory-animal trade, the business is regulated.

Pet Breeders: Anyone breeding pets for the wholesale trade must be licensed. You also may have to be licensed if you sell dogs as breeding stock to other breeders. Some small-scale breeders can qualify for an exemption (see "Hobby Breeders"). Annual license fees are based on 50 percent of gross sales of regulated animals.

Direct Sales: Anyone who sells domestic pets directly to pet owners is exempt, regardless of sales volume. Such sales can be made in person or by mail.

Hobby Breeders: Small-scale breeders with gross sales under $500 per year are exempt, as long as these sales do not include wild or exotic animals, dogs, or cats. If you own no more than three breeding female dogs or cats and sell the offspring, into the pet channels only, you are exempt.

And if you have any questions:

If in doubt about your status, telephone or write the Regional Office of the USDA, Animal and Plant Health Inspection Service (APHIS), Animal Care (AC) for your State (see page 19). AC personnel will answer your questions and provide a copy of the Code of Federal Regulations, Title 9, Chapter 1, Subchapter A, which gives the legal requirements for businesses regulated by the Animal Welfare Act.

So if you are selling directly people it doesn't matter how much you make. If you're selling wholesale (e.g., to a pet store for resale) and you gross over $500 you need a license. Although I am unsure how this would apply if you had some sort of consignment agreement with a store. Perhaps that's a good question to ask? (My gut leans towards a direct sale since technically you didn't sell the rabbit to the store, but I'm going on a tangent.)

Marinea":dckoelcf said:

Look at it this way. Depending on where someone lives, some breeds go for big bucks. We have threads on prices somewhere. If someone sells just 10 rabbits to a pet store for resale at $50 each, there is the $500 limit. Hardly a rabbit mill.

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FourRingCircus":dckoelcf said:

And, as mentioned, some breeds are higher dollar than others so it wouldn't take many sales to hit that quota.

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True and I have as much sympathy for them as I do the person who sells 11 rabbits at $45.45/piece to a pet store , or 5 rabbits at $100/piece to a pet store , or 1 rabbit to a pet store for $500. It totally sucks that your situation crosses an arbitrary threshold, but it's a threshold directed at the much more common situation that a person who sells wholesale can usually only get $5-$15 per rabbit and is selling hundreds a year. Find comfort in the fact you can charge that much for wholesale price. And if it is not worth your while to sell wholesale and get a USDA license; you might want to consider selling directly which is exempt (especially if your market commands such wholesale pricing).

Kenosha Rabbits, I appreciate your passion on this topic. I'm sorry that you took this personally as an attack, as it was not my intention. I did actually read the law before I posted (as I do know how to read) but apparently not carefully enough in the initial scan. The point of my confusion and frustration is the fact that some of the information seems contradictory at first glance. That is what frustrates me.

I do want to follow the law, which is why I was looking into it. I sell rabbits directly to clients only, for pets, breeding stock, fur, and meat. I don't sell to pet stores. I currently sell under the $500 per year (which would in my interpretation qualify me as a Hobby Breeder). But it looks like I will be over the $500 this year easily. So what aspect of the 'Hobby breeder' definition clarifies that if I sell over $500 of rabbits (directly) I am still exempt? The 'Direct Sales' definition says nothing about breeding AND selling, only selling. So am I supposed to simply assume that I can choose which one of these the USDA would consider me to be? Sure, I see now that I've had time to look at it more closely I should certainly be considered a Direct Sales situation...but I really don't want to be wrong.

I do know (and did also read about and look at the forms and process for) what happens if I am actually not considered exempt by the government -- and if that is the case, the requirements to continue business become absolutely absurd, and frankly, impossible for any small-scale breeder to maintain (much less make a profit) which is what caused my initial comment that threw you into a fit of rage. It was more out of fear than anything. I love raising rabbits...the thought that the government could take that away (which is what I felt at the time, after scanning the law) was worrisome.

Believe it or not, I DO care, and I don't appreciate the direct attack on my intelligence or my intentions. I'm sorry you took this so personally. But I can appreciate when someone is passionate about a topic and strives to defend their position. I understand why the regulations exist and I hate animal abuse/neglect, puppy mills and rabbit peddling just as much as other responsible breeders. I am certainly for the ethical treatment of animals, and I want to do everything I can to be sure I am law-abiding and don't do something wrong.

Sincerely,
Amanda

KenoshaRabbits":2jx3sqmt said:

Marinea":2jx3sqmt said:

That seemed a touch...harsh.

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FourRingCircus":2jx3sqmt said:

agree... a bit to quick to jump to conclusions.

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Good it was meant to be. Although I would argue it is no more harsh than BelleVie's analysis and willingness to jump to conclusions. BelleVie isn't asking if this applies to his/her situation. Or if his/her understanding is correct. Or throwing out a hypothetical. Or getting into a spirited debate on the appropriateness of the $500 limit. Something like that would get a nicer response.

You don't actually need to read 9 CFR. Do you know what the first result is if you do a simple Google search for USDA rabbit license? A nice explanation from the government on what is actually covered.

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I understand the explanation, but if I read the first posting correctly, they were more just saying how hard it was to follow the USDA guidelines for licensure - not what would constitute needing it or not. It's a pretty big stretch for someone wanting to do a smaller scale business, anything that would cross the threshold of the USDA rules as explained above. It's definitely geared more toward big business and a huge deterrent for anyone small scale who is wanting to expand a little. Honestly I think the same thing about a lot of the laws made - do they really think these through? She didn't say why she was asking, just in general that they are tough to follow if you're not large scale. In my case mentioned above it would have been for research purposes which is very B&W - I would have had to have a license to sell to the company that contacted me. No if, ands or buts about it. Everyone's situation is different... and it's easy to just assume breeding is for pet/meat/pelt, but even though those 3 are pretty much common, there are other options (scientific research, pet food [which is a bit gray-er of an area than for human consumption], etc.). The attitude conveyed (which isn't always easy to interpret over the internet) is one that isn't usually found much on here, making RT a fantastic (and safe) place to go for asking questions...

Hey BelleVie.
I do have a pet peeve about people complaining about or praising things without taking some effort to understand what it is they're talking about. Your initial post was short and didn't touch on any research you actually did; so I am sorry I assumed you didn't take the time and that I made the glib remark about whether you actually read it. I interpreted your comment as "what? the government has laws on breeding rabbits? that's crazy! what are those fools thinking? instead of "I'm having some difficulty understanding what's applicable or not" which did not warrant my comment. To whatever extent I made you feel bad with my comment; that's my fault and I apologize for making an incorrect assumption and for any hurt feelings. Or to be blunt: my bad, it was a dick move on my part.

I can appreciate that you might have confusion over what does and doesn't apply to you. The questions you have are valid "am I a direct seller or a hobby breeder?". I can offer an opinion, if it truly concerns you feel free to ask the USDA or consult an attorney.

I think you fall under "direct sales" too and you can sell as much as you want. If you sell wholesale you need a license; unless you fall under "hobby breeder" of selling under $500 a year wholesale. And if you do sell over $500 in wholesale then your license fee is based on all your total sales, direct and indirect.