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The 25 least obedient small dog breeds

Any small dog breeds can be properly trained, according to the American Kennel Club.

Mary Burch, the director of AKC’s Family Dog program, tells Newsweek that each of the organisation’s nearly 200 breeds were originally “developed to perform specific jobs,” be that herding, hunting, guarding or just being great companions.

“Considering this, a key question when it comes to training is, what was your breed created to do, and what kinds of training do you want to do with your puppy?

“If you want to train your dog to hunt and you chose a terrier, you might end up thinking your dog is not being obedient, when it’s really you as the owner approaching training incorrectly.

“Also, some breeds are not as willing to please as others are, which in turn makes them more difficult (and fun!) to train.”

When a breed is described as “stubborn” with regard to training, Burch suggests that dogged determination is in part due to its daily lifestyle.

“In many cases, a behavior (such as refusal to cooperate in training) that looks like a breed tendency may actually be related to the dog’s learning history,” Burch says.

“For small breeds, if the dog is treated like a baby 95 percent of the time and allowed to do what it wants, it may not be the best student when suddenly taken to an obedience class.”

Pekingese

While the Pekingese breed is regal, intelligent, independent and affectionate, some Pekes can be somewhat stubborn and even aloof about training.

Some Pekingese dogs can be somewhat stubborn and aloof about training
Батуленко Тетяна/Getty Images

Pug

Many Pugs are loving and eager to please, but some members of this small dog breed can be slightly stubborn with regard to standard training exercises.

Pug
Pugs can be slightly stubborn with regard to standard training exercises
LexiTheMonster/Getty Images

Shih Tzu

Although the Shih Tzu is a happy, affectionate and generally agreeable breed, some of these dogs can be stubborn in typical training situations.

Shih Tzu
Some Shih Tzus can be stubborn in typical training situations
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West Highland Terrier

Demanding and testy, with the typical stubbornness and cleverness of a true terrier, the Westie must be shown early on by the owners exactly who in charge.

West Highland Terrier
The Westie must be shown early on by the owners exactly who in charge
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Welsh Terrier

While considered a little more relaxed than its close relatives, this small dog breed can be difficult to train and may need a consistent and fun education.

Welsh Terrier
The Welsh Terrier can be difficult to train
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Miniature Akita

The Akita has a complex personality including a stubborn streak and a strong will, making this beautiful breed occasionally very challenging to train.

Miniature Akita
The Akita has a complex personality including a stubborn streak and a strong will
Kateryna Kukota/Getty Images

Boston Terrier

Boston Terriers make excellent family dogs, due to their affectionate and friendly nature, although training this breed can require plenty of patience.

Boston Terrier
Training Boston Terriers can require plenty of patience
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Skye Terrier

The long, low and hardy Skye Terrier is cautious and reserved with strangers and will largely only respond to positive reinforcement when being trained.

Skye Terrier
Skye Terrier will largely only respond to positive reinforcement when being trained
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Norfolk Terrier

In addition to being rather reserved around new people, the Norfolk Terrier can reportedly require as many as 80 repetitions to learn a new command or rule.

Norfolk Terrier
The Norfolk Terrier can reportedly require as many as 80 repetitions to learn a new command or rule
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Sealyham Terrier

Although this breed of dog is entertaining and affectionate when well trained, they generally need a lot of time to learn new things.

Sealyham Terrier
Sealyham Terriers generally need a lot of time to learn new things
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Griffon Bruxellois

This breed of griffon is fun and affectionate, but this small dog breed is prone to being moody and the Bruxellois can be tricky to be effectively trained.

Griffon Bruxellois
The Griffon Bruxellois can be tricky to be effectively trained
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Maltese

While this breed of snow-white small dogs is adaptable, these cute pets are perceived to be set in their ways and can oftentimes be stubborn when it comes to training.

Maltese
Maltese dogs are perceived to be set in their ways and can oftentimes be stubborn when it comes to training
Utenzilije/Getty Images

Dandie Dinmont Terrier

These terriers can reportedly get bored very easily when owners attempt to train them, so keeping their lessons diverse can be a useful strategy.

Dandie Dinmont Terrier
Dandie Dinmont Terrier can reportedly get bored very easily when owners attempt to train them
muzzyco/Getty Images

Wire Fox Terrier

Despite its intelligence, this breed can a stubborn and independent nature, meaning owners should include obedience tasks as part of these dogs’ training.

Well-trained Wire Fox Terriers can perform fantastically at dog shows. Dogs of this breed have won Best in Show at Crufts three times and had 34 wins in the Westminster Kennel Club Dog Show too. It’s no wonder the AKC describes the breed as a “master show dog.”

Wire Fox Terrier
Wire Fox Terrier owners should include obedience tasks as part of their dog’s training
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Tibetan Terrier

Their high-energy and independent nature makes this breed difficult to deal with and positive reinforcement techniques such as praise, play, and food rewards can be used to train them.

Tibetan Terrier
Tibetan Terrier’s high-energy and independent nature makes this breed difficult to train
SStajic/Getty Images

Japanese Chin

While these traditional companions to Japanese royalty can eventually be trained, these dainty small dogs can certainly require a lot of effort.

Japanese Chin
Japanese Chin can require a lot of effort to train
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Scottish Terrier

These farm dogs were bred to work autonomously and they are thought to seek a reason to obey other than just to please their owners.

Scottish Terrier
Scottish Terriers are thought to seek a reason to obey other than just to please their owners
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Dachshund

Wiener dog owners have a headstrong temperament, meaning training should commence upon their arrival into their new home.

Dachshund
Dachshund owners have a headstrong temperament, meaning training should commence upon their arrival into their new home
NORRIE3699/Getty Images

Chihuahua

Known as purse dogs for their diminutive frame, prospective owners should be aware plenty of time and energy can be needed to train a Chihuahua to become properly obedient.

Chihuahua
Chihuahua owners should be aware plenty of time and energy can be needed to train this breed to become properly obedient
Elenasfotos/Getty Images

Lhasa Apso

New Lhasa Apso owners can discover just how tricky they are to train because they are independent dogs with a real stubborn streak.

Lhasa Apso
New Lhasa Apso owners can soon discover just how tricky they are to train
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Basset Hound

Bassets are rather intelligent dogs and often just refuse to cooperate when faced with excessive repetition, meaning this breed may frustrate owners while training.

Basset Hound
Bassets Hounds are rather intelligent dogs and often just refuse to cooperate when faced with excessive repetition
artisteer/Getty Images

Beagle

While Beagles are active and intelligent, this breed is easily distracted making them potentially tricky to train.

Beagle
While Beagles are active and intelligent, this breed is easily distracted making them potentially tricky to train
Przemysław Iciak/Getty Images

Chow Chow

Although it is in Chow Chow’s DNA to be quiet and well behaved, these excessively fluffy breed is also stubborn and resistant to training.

Chow Chow
Although it is in Chow Chow’s DNA to be quiet and well behaved, these excessively fluffy breed is also stubborn and resistant to training
IgnatenkoAleksey/Getty Images

Basenji

The Basenji breed is recognised for its individualism and this should be tolerated because it is in these dogs’ makeup.

Basenji
The Basenji breed is recognised for its individualism and this should be tolerated because it is in these dogs’ DNA
Ryhor Bruyeu/Getty Images

Chinese crested

Cresteds tend to have slightly childish traits and they possess a certain stubborn streak, meaning owners can need a lot of patience.

Chinese crested
Chinese Cresteds tend to have slightly childish traits and they possess a certain stubborn streak
Ekaterina Gorokhova/Getty Images

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