fwiw the USDA enforces the federal law only which exempts breeders than only sell retail and puppystores and is reserved for comercial breeders only. It is the PA dog Law that is enforced by State Wardens that effects all kennels/breeders that own or sell/ transfer in total (catorgories amounts combined) 25 dorgs or more. Which is as little as two litters a year given the number of dogs a breeder owns as well.
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