Because that’s the rule: Dog Licensing and early re-vaccination

Recently, a question was raised by a resident about the need to re-vaccinate a dog in order to get an annual license from Teaneck.  I’ve looked into the issue.  As with most things in NJ, it’s…. complicated.  I’ll break down the relevant rules below and discuss some changes that I’ll be suggesting.

Issue:

  • July 2020: You get a new dog
  • October 2020: You get your dog vaccinated for Rabies (expires one year later in October 2021)
  • January 2021: You attempt to register your dog in Teaneck

 

This is a common scenario that many people have faced, only to find a rejection notice.  Residents are being told to re-vaccinate for rabies.  It’s confusing to most dog owners, because the vaccine is good for a year and they received it only 62 days ago.

Why can’t a dog get registered and then get a booster before the October vaccination expires?

NJ law is clear: the duration of immunity from the vaccination must extend through at least 10 of the 12 months of the licensing period.

As noted in the Townships communications:

Dog owners should also note that per NJ State guidelines rabies shots that expire prior to November 1, 2021 are NOT valid for licensing purposes. (Township Notice)

This means that if the duration of the immunity doesn’t reach at least November, it’s not going to be valid.


I’m posting the relevant links to the law(s) at the bottom of this post for anyone that wants to read them.
Just click here.


A deep dive into dog licensing rules:

Here are the very basics under Municipal Licensing Guidance (May 2018):

Owners of dogs 7 months of age or older are required by State statute to license their dogs in the
municipality where the dogs are housed. Licenses can be issued with either a 1 or 3-year duration and
licenses shall expire no later in the year than June 30th.

The purpose of the rule is to ensure rabies vaccinations are current for all dogs owned in the State.

To that end, the State devised a 10 Month vaccination Rule.

The owners of all dogs seven months of age or older are required to annually apply to the licensing clerk of the municipality in which he or she resides for a dog license. In order for the license to be issued, the owner must present proof that a licensed veterinarian has vaccinated the dog against rabies and that the duration of immunity from that vaccination extends through at least ten months of the twelve-month licensing period. An exemption to the rabies inoculation requirement shall be granted if the owner presents written certification from a licensed veterinarian that the dog cannot be vaccinated due to a medical condition or course of therapy. (emphasis added)

Therefore, if you are registering in January, you need evidence of a vaccine that lasts through November 1st.

What if you register in October?  Wouldn’t this solve the problem?

Remember that the Municipal Licensing Guidance says “Licenses can be issued with either a 1 or 3-year duration and
licenses shall expire no later in the year than June 30th.”  It would appear that we can’t issue a license that expires in October.

What if we get this 3-year rabies vaccination?

This will require a change in ordinance (and that will be the first of several changes that I will be requesting we do), but it doesn’t solve the 10-month issue.  It merely delays the paperwork.

What if we stagger the time of vaccinations?

We are permitted by State law to stagger licenses from January to June (see 4:19-15.3 and 4:19-15.3a).  This will also need an update to our ordinance, however it makes sending our renewals very difficult.  They are currently done once a year by the Health Department.  If that can be done electronically through our new online portal, I will be asking our Heath Department to opine on what can be done here.

Why can’t this be done online?

We have some good news on the horizon there.  This month, the Township is changing vendors and will be capable of accepting electronic payments through our new SDL portal, like other municipalities (see here for example).  Implementation was a bit slower than expected, due to the pandemic, but we hope to have completely on-line payment and processing up, soon.

What else can be done

We may be able to delay the late fee as long as the current vaccination duration is in effect.  I will be asking our attorneys to look into this.  For the example above, the resident would be able to wait until their next regularly scheduled vaccination the following October and renew without a late fee, as long as there’s no gap in duration of immunity.  Of course, this will also need to pass muster with the applicable State regulations and Health Department.  I’ll see what I can do.

If you have further questions, please email me or leave a comment below.


Laws and Codes

(a) Except as otherwise provided in 8:23A-4.3, no municipal clerk or other official designated to license dogs shall grant any such license and official metal registration tag for any dog unless the dog owner provides evidence that the dog to be licensed and registered has been inoculated against rabies with a vaccine having duration of immunity which extends throughout at least ten of the 12 months of the licensing period. Dogs with a duration of immunity against rabies that expires prior to the tenth month of the licensing period shall be revaccinated prior to issuance of a license. (emphasis added)

Any person who shall own, keep or harbor a dog of licensing age shall annually or every third year, in accordance with a 3-year dog license or renewal thereof issued under subsection b. of section 12 of this act (C. 4:19-15.12b), apply for and procure from the clerk of the municipality or other official designated by the governing body thereof to license dogs in the municipality in which he resides, a license and official metal registration tag for each such dog so owned, kept or harbored, and shall place upon each such dog a collar or harness with the registration tag securely fastened thereto.

3. The person applying for the license and registration tag shall pay the fee fixed or authorized to be fixed in section 12 of this act, and the sum of $1.00 for a one-year registration tag or $3.00 for a three-year registration tag for each dog; and for each renewal, the fee for the license and for the registration tag shall be the same as for the original license and tag; and said licenses, registration tags and renewals thereof shall expire no later than June 30 in the year stated on the license; except that this expiration date shall not require a municipality to alter its schedule for administering rabies inoculations to any dog to be licensed and registered; nor shall this expiration date require a municipality to alter its schedule for renewing licenses and registration tags, provided that the registration period precedes June 30. The governing body of a municipality may stagger the expiration of such annual licenses so long as all expirations occur no later than June 30 in the calendar year stated on the license.

Only one license and registration tag shall be required in any licensing year for any dog owned in New Jersey, and such license and tag shall be accepted by all municipalities as evidence of compliance with this section.

4. Subsequent to the effective date of P.L.1982, c.203, the provisions of any law to the contrary notwithstanding:
a. All annual licenses required pursuant to the provisions of section 2 of P.L.1941, c.151 (C.4:19-15.2), section 3 of P.L.1941, c.151 (C.4:19-15.3) and section 8 of P.L.1941, c.151 (C.4:19-15.8) shall expire no later than June 30 in the calendar year next following issuance; provided that the license and registration tag fee shall be prorated for any license and registration tag which is valid for longer than 12 months. The governing body of a municipality may stagger the expiration of such annual licenses so long as all expirations occur no later than June 30 in the calendar year next following issuance.

4:19-15.4. Time for applying for license

The owner of any newly-acquired dog of licensing age or of any dog which attains licensing age, shall make application for license and registration tag for such dog within ten days after such acquisition or age attainment.

No person shall own, keep, harbor or protect a dog, either male or female, within the township without having such dog registered and licensed in the manner provided by this article. Dog licenses shall be applied for during the month of December and shall be effective for the calendar year beginning January 1. The owner of any newly acquired dog of licensing age or any dog which attains licensing age during any other period must purchase a license within 10 days of such acquisition or age attainment.
[1] (Editor’s Note: For state law as to registration and licensing of dogs, see N.J.S.A. 4:19-15.1 to 4:19-15.29.)
All registration certificates and licenses issued under this article shall be for the calendar year in which they are issued, and shall expire on the last day of January in the following calendar year.
Of note, the State also had a rule about canvassing for dogs, which was repealed.

The purpose of the canvass rule was to get revenue.

Repeal of the Requirement to Perform an Annual Municipal Canvass of Licensed Dogs
The statutory requirement for municipal governments to perform a canvass of all owned dogs in their
jurisdiction (N.J.S.A. 4:19-15.15) has been repealed. However, the NJDOH recommends that a canvass
be conducted if at all possible to increase the number of dogs licensed and licensing revenue into the municipal budget. (emphasis added)