Pet Transporter Requirements in Canada: What the Law Actually Says
People ask us who licenses pet transporters in Canada. The honest answer is nobody, because no such licence exists. What does exist is a set of federal duties that apply to anyone who moves animals for money, and those duties are more demanding than a licence would be. Here is what Part XII of the Health of Animals Regulations actually requires, where each rule really lives, and what you can fairly ask any transporter before you hand over a deposit.
Requirements last checked against official sources on .
There is no pet transporter licence in Canada
Start here, because it clears up most of the confusion. Sections 136 to 155 of the Health of Animals Regulations, the part known as Part XII, create no licence, no permit, no certificate, no registration and no authorization for transporters. Part XII is not a Canadian Food Inspection Agency accreditation program and nobody issues a number you can look up.
So when a company calls itself approved or certified for pet transport in Canada, ask what body issued it and for what. The answer is usually a trade association membership or an airline account, both of which are real things, and neither of which is a government licence.
What Part XII does instead is impose duties directly on the people doing the work. The obligation lands on the carrier and on the individual handling the animal, and it applies whether or not anyone is watching. That is a higher bar than a licence renewal, not a lower one.
Why Canadian law covers a pickup in the United States
Section 137 sets the scope in one sentence: "This Part applies to the transport of animals entering or leaving Canada or within Canada."
Read that against a typical trip. A puppy is collected from a breeder in Ohio and delivered to a family in New Brunswick. From the moment that animal is being moved toward Canada, it is being transported entering Canada, and Part XII governs the run. American law governs the American portion of the same trip. The two do not compete; they stack. A transporter working this route answers to both.
This matters when you are comparing quotes. A carrier that only thinks about American rules because the pickup is American has misread the scope of the Canadian regulation that will apply to the animal for most of the journey. If your trip crosses the border, our guide to how the paperwork changes when you are not in the vehicle covers the import side of the same journey.
Who counts as a commercial carrier
Section 136(1) defines it plainly. "Commercial carrier means (a) the owner of a motor vehicle who is engaged in the business of transporting animals by land for financial benefit; (b) the owner of an aircraft ...; (c) the owner of a vessel ...; or (d) a railway company."
A ground pet transport business falls squarely inside paragraph (a). It owns a vehicle, it moves animals by land, and it does so for financial benefit. Dreamer's Bliss operates as a commercial carrier on that definition, so Part XII applies to us the same way it applies to every other paid transporter on the road.
Two details are worth noticing. The definition turns on financial benefit, not on company size, so a single van with one driver is a commercial carrier just as a fleet is. And some duties reach wider still: the contingency plan in section 138.2 binds every commercial carrier and anyone transporting animals in the course of business or for financial benefit. Calling yourself a hobbyist or a favour for a friend does not move you outside that obligation if money changed hands.
The four duties in sections 138 to 138.3
This is the block people most often describe incorrectly. Sections 138 to 138.3 are not about crates, weather, feeding or paperwork. They are about competence and planning, which is to say about the people rather than the equipment.
Section 138: knowledge and skills
"Every person who loads, confines or transports an animal in or unloads an animal from a conveyance or container shall have the necessary knowledge and skills to conduct those activities in compliance with this Part."
In practice: the person physically handling your dog has to know what they are doing. Not the owner of the business, not the dispatcher, the person with hands on the crate. That includes anyone helping at loading, which is why a transporter should be able to say who will be present at pickup.
Section 138.1: training
A commercial carrier has to provide or ensure training. The regulation lists what it covers: animal behaviour; assessment of an animal's capacity to withstand loading, confinement, transport and unloading; handling, restraint and space requirements; a contingency plan; effective monitoring; and the risk factors listed in section 138.3(1).
Read that list again and notice what it is doing. It is not teaching someone to drive. It is teaching someone to read an animal, decide whether this particular animal can cope with this particular trip, and know what to do when the answer changes partway.
Section 138.2: the contingency plan
Required of every commercial carrier, and of anyone transporting animals in the course of business or for financial benefit. It has to address unforeseen delays or circumstances that could cause unnecessary suffering, injury or death, and it has to cover what happens if an animal becomes compromised or unfit during the trip.
Translated: before the trip starts, the transporter has already decided what to do about a four-hour border queue in July, a blown alternator on the Trans-Canada, a closed highway, and a dog that stops eating and starts panting in a way that will not settle. A plan invented at the roadside is not a contingency plan.
Section 138.3: risk assessment before, monitoring during
Subsection (1) requires a pre-transport assessment that takes eleven specific risk factors into account:
- the animal's current condition
- any pre-existing infirmity, illness, injury or condition
- space requirements
- compatibility with other animals
- handling and restraint methods
- expected time without feed, safe water and rest
- expected duration of transport and confinement
- foreseeable delays
- foreseeable weather
- foreseeable conditions causing inclines, vibration, shifting or swaying
- the type and condition of the conveyance, container and equipment
Subsection (2) then requires monitoring during confinement and transport, at a frequency appropriate to assess the animal's capacity to withstand it. Note the wording: the frequency is set by what the animal needs, not by a fixed schedule. A resilient adult dog on a short run and a nervous rescue on a two-day haul do not get checked on the same clock.
Where the physical standards actually live
If you have read a summary that put crates and weather inside sections 138 to 138.3, it was wrong, and the mistake matters because it leaves out most of Part XII. The physical standards sit elsewhere, and there are a lot of them.
- Sections 139 and 140, unfit and compromised animals. These are the operative prohibitions, the ones that say an animal in a given state must not be transported, or must only be transported under conditions. The risk assessment in 138.3 feeds directly into them.
- Section 144, animal handling. How animals may and may not be handled.
- Section 146, ventilation and weather. Protection from inadequate ventilation and from weather. This is the heat and cold rule, and it is not in 138.
- Sections 147 and 148, space and overcrowding. How much room an animal must have, and the prohibition on packing in more.
- Section 150, conveyances and containers. The crate and vehicle standard. Section 150(5) requires containers used for air transport to meet the IATA Live Animals Regulations, 44th edition, which is why an airline-bound crate is judged against a different specification than a crate riding in a van.
- Section 152 and following, feed, safe water and rest. Including a duty at loading to determine the date, time and place the animal was last fed, watered and rested. That is a question the transporter is obliged to ask your breeder or shelter, so if nobody asks it, that tells you something.
- Section 154, records. A standalone record-keeping duty, plus a duty to keep the record on board during the trip.
Taken together these cover the vehicle, the crate, the temperature, the room the animal has, when it last ate and drank, and the paper trail proving all of it. A transporter who can speak to those points is describing compliance. One who reaches for the word certified usually is not.
What you can reasonably ask any transporter
You are not going to audit anyone's files, and you should not have to. But the duties above translate into four questions that a careful operator can answer on the phone, without preparation, and a careless one cannot answer at all.
- Who is driving, and what training have they had? Sections 138 and 138.1 make this a requirement, not a courtesy. You are asking about the person whose hands will be on the crate.
- What does your contingency plan say for a long border delay, or a breakdown? Section 138.2 says the plan has to exist. A specific answer means it does.
- How often will my dog be checked, and what makes you check more often? Section 138.3(2) sets frequency by the animal's needs, so the second half of that question is the revealing one.
- What will you record about when my dog was last fed, watered and rested, and can I see it? Sections 152 and 154 put both the asking and the recording on the transporter.
None of these are gotchas. They are the ordinary content of the job. Our broader vetting list for first-time customers, covering insurance, references, deposits and what a real itinerary looks like, is in ten questions to ask before you book a pet transporter.
Reading the regulation yourself
Part XII is short enough to read in a sitting, and it is written in plainer language than most regulations. If you are placing an animal in a stranger's vehicle for two days, an hour with the actual text is time well spent. Start at section 136 for the definitions, then read 138 through 138.3 for the duties on people, then 139 through 154 for the standards on the animal and the equipment.
Confirm before you book
Treat this as general information, not legal advice. Regulations are amended and the text below is the authority, not this page. The version referenced here is current to 2026-07-21, last amended 2025-09-19. We confirm current requirements for every trip we quote.
- Health of Animals Regulations, C.R.C., c. 296, full text
- CFIA: Health of Animals Regulations, Part XII, humane transport
Related: ten questions to ask before you book · accompanied vs. unaccompanied import · get a transport quote
FAQs
Do pet transporters need a licence in Canada?
No. Part XII of the Health of Animals Regulations, sections 136 to 155, creates no licence, permit, certificate, registration or authorization for transporters. There is no federal Canadian pet transporter licence at all. What the regulations create instead are duties: knowledge and skills, training, a contingency plan, a pre-transport risk assessment, monitoring, handling and space standards, feed and water and rest, and records. A transporter is either meeting those duties or it is not, and no piece of paper decides it for you.
Does Canadian law apply when my puppy is picked up in the United States?
Yes, for the Canadian leg. Section 137 says the Part applies to the transport of animals entering or leaving Canada or within Canada. A trip that starts at a US breeder and ends at your door in Canada is transport entering Canada, so Part XII governs it. American rules govern the American side of the same trip. Both apply to the same run.
What is a commercial carrier under the regulations?
Section 136(1) defines commercial carrier as (a) the owner of a motor vehicle who is engaged in the business of transporting animals by land for financial benefit; (b) the owner of an aircraft used for that purpose; (c) the owner of a vessel used for that purpose; or (d) a railway company. A ground pet transport business falls under paragraph (a). Dreamer's Bliss operates as a commercial carrier, so Part XII applies to it.
What is a contingency plan and who has to have one?
Section 138.2 requires a contingency plan from every commercial carrier, and from anyone transporting animals in the course of business or for financial benefit. It has to cover unforeseen delays or circumstances that could cause unnecessary suffering, injury or death, and it has to say what to do if an animal becomes compromised or unfit during the trip. In practice that means the transporter has already decided what happens when a border queue runs long, a vehicle fails, or a dog stops coping.
What has to be assessed before a dog is loaded?
Section 138.3(1) requires a risk assessment before transport, taking eleven listed factors into account: the animal's current condition; any pre-existing infirmity, illness, injury or condition; space requirements; compatibility with other animals; handling and restraint methods; expected time without feed, safe water and rest; expected duration of transport and confinement; foreseeable delays; foreseeable weather; foreseeable conditions causing inclines, vibration, shifting or swaying; and the type and condition of the conveyance, container and equipment.
Where do the crate, weather and feeding rules actually live?
Not in sections 138 to 138.3, which is where most summaries put them. Handling is section 144. Protection from inadequate ventilation and weather is section 146. Space requirements are section 147 and overcrowding is section 148. Conveyances and containers are section 150, and section 150(5) requires containers used for air transport to meet the IATA Live Animals Regulations, 44th edition. Feed, safe water and rest start at section 152, which also includes a duty at loading to determine the date, time and place the animal was last fed, watered and rested. Record keeping is section 154.
What should I ask a transporter before I book?
Ask who is driving and what training they have had, since sections 138 and 138.1 make knowledge, skills and training a requirement rather than a nice-to-have. Ask what their contingency plan says for a long border delay or a vehicle breakdown. Ask how often the dog is checked on the road. Ask what they recorded about when your dog was last fed, watered and rested, and whether they will share it. Anyone meeting the duties can answer all four without preparation.
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