On 13 May 2024, the US Centers for Disease Control and Prevention (CDC) issued a final rule effective 1 August 2024 that makes changes to the importation requirements for dogs into the United States to address the public health risk associated with dog-maintained rabies virus variant (DMRVV).

Among these rules, one provision imposes on airlines to create a “bill of lading” (i.e. an air waybill – hereafter AWB) for all dogs entering the United States via air, including dogs transported as cargo, hand-carried, and as checked-baggage.

Following joint action by IATA and other associations, CDC has recognized that the requirement to issue an AWB for dogs that are hand-carried or checked as baggage is an issue. Consequently, all airlines can apply immediately for a waiver to the AWB on a provisional basis.

  1. CDC will grant a waiver on a provisional basis based on a request from the air carrier that will be valid for 90 days. During this 90-day period, air carriers must complete their waiver application and submit all required documentation.
  2. Once complete, CDC will make a determination regarding the completed waiver application. If granted, the waiver will be extended so that it is valid for a period of 9 months from issuance of the provisional waiver. If denied, air carriers will no longer be able to transport dogs without an AWB.

To receive a provisional waiver that is valid for 90 days, air carriers should send the following letter on company letterhead signed by a company official with oversight and responsibility for cargo shipments of animals into the United States:

"On behalf of [INSERT AIR CARRIER], I am submitting a request for a provisional waiver of the requirement to generate an air waybill for dogs transported as checked baggage or hand-carried baggage as the air carrier listed above does not have the technical ability to do so.

Within 90 days of this request, the air carrier listed above will complete the full waiver application based on technical instruction that CDC will provide. The air carrier listed above understands that failure to submit the full waiver application and have it approved within 90 days will result in expiration of the provisional waiver.

The company official(s) who will serve as our point of contact for handling ill, injured, abandoned, deceased animals, animals on hold, or animals denied entry following arrival in the United States is [NAME, TITLE, PHONE NUMBER & EMAIL]. They or other appropriate representatives will be available to answer questions on a 24/7 basis."

CDC defers to air carriers regarding which company official is best positioned to sign its request for a provisional waiver. The company official who signs this letter can be the same company official as the point of contact or a different company official.

Dogs from low-risk countries

As of 1 August 2024, passengers transporting any dog from low- or no-risk countries are required to complete a CDC Dog Import Form.  The airline is responsible for checking whether the passenger has completed the form.  CBP will also check if the passenger has the form upon arrival. 

Dogs from high-risk countries: 
CDC advises that the existing rules for dogs arriving from high-risk countries will remain in place post 1 August 2024 with some minor modifications. 

The possibility to apply for a provisional waiver to the AWB does not imply further relief from the various other airline responsibilities outlined in the rule. Airlines are therefore encouraged to review all the obligations resulting from the CDC rule, available in the references below:

CDC website links for low-risk countries:

Dogs from high-risk countries:

Airlines’ FAQs : additional guidance pertaining to high-risk countries:

Failure to apply for a waiver and getting an approval of that application will mean the airline will need to issue an AWB for any dog departing to the US.

The IATA Live Animal Regulations (LAR) have amended the US State variation (USG-51) to reflect this change.