Large-scale breeding of predators with attendant welfare abuses continues unabated in South Africa, while exports only notionally comply with regulations.
A recent statement by Environment Minister Dion George in response to a Daily Maverick article by Adam Cruise signals a welcome move towards public engagement, but it neither resolves the core governance concerns that underpin the debate nor proposes adequate measures that would see beyond a narrow interpretation of export regulations.
In its response to the minister’s statement, animal welfare organisation Four Paws outlines several gaps between policy and implementation. After all, it was a Four Paws’ report from late 2024 that drew renewed attention to this abominable trade in captive-bred lions and tigers.
The absence of CITES-registered facilities for commercial tiger breeding in South Africa appears inconsistent with ongoing exports of live animals and parts. At issue is not only what the permits record, but whether the permitting process includes any verification of the animals’ origins, destinations and intended uses.
Tigers are not listed under South Africa’s Biodiversity Act because they are a non-native species. This results in a regulatory vacuum in which tigers fall between the cracks of national and provincial frameworks.
The lack of uniform and enforceable national regulation means welfare standards vary significantly; in some cases, they’re virtually non-existent. This regulatory gap enables the continued breeding of tigers in substandard conditions.
The minister’s statement also paid no heed to a 2024 CITES directive: “Parties with intensive operations breeding tigers on a commercial scale shall implement measures to restrict the captive population to a level supportive only to conserving wild tigers; tigers should not be bred for trade in their parts and derivatives.”
In answer to a parliamentary question on 29 November 2024, the minister explicitly stated that South Africa would not prepare a report for CITES on how it was ensuring that the country’s breeding of tigers would not imperil wild tiger survival, “as facilities that keep tigers in South Africa do not export tigers for commercial purposes”.
The minister states that South Africa adheres to CITES requirements and exports tigers solely for non-commercial purposes to zoos and wildlife parks abroad. But this assertion is based on an unquestioning reliance on details provided by exporters on their permits.
The minister writes: “Tigers are protected under CITES, and we follow its rules.” But this is evasive; where CITES rules are not fit for purpose, nor properly enforced, they cannot serve as a benchmark for governance practices.
It is implausible, given the sheer demand for illicit tiger bone products in East Asian markets, that South Africa’s breeders are only exporting “live animals to zoos and wildlife parks abroad”. The minister’s assertion that the exports are for “non-commercial purposes” to zoos and wildlife parks and that they are “strictly monitored” – despite the lack of even cursory checks on destinations – lacks resemblance to reality; there is no evidence of any strict monitoring.
As Don Pinnock explains: “By the transposition of one letter for another in the permit code of CITES – Z for zoo instead of T for Commercial – critically endangered wild animals become tradeable for huge sums of money. It’s a loophole so big that the very intention of CITES is being systematically undermined.”
It remains implausible for the minister to state that no facilities are breeding tigers for commercial purposes. Repeating it does not make it true, especially when nobody is checking whether the Z code is legitimate, and whether those purported zoos are not using the animals for commercial purposes.
While CITES permits may be procedurally correct, the absence of field-level or even desktop inspections, let alone independent validation, facilitates abuse of export destination criteria.
In May 2024, 40 tigers were exported to a single destination in India. The scale of this export is surely indicative of commercial purpose? However, the minister did not address this issue in his reply to Cruise’s article nor did he provide an answer to a parliamentary question of 29 November 2024 regarding this export.
On 4 April 2025, a parliamentary question asked the minister whether there was any evidence that tigers exported from South Africa were not being used for commercial purposes. This distinction is important because – as indicated above – CITES does not require exporting countries to verify the final destination or end use if the export is labelled “non-commercial”.
The response did not provide evidence. Instead, it stated only that no commercial tiger breeding facilities in South Africa are registered with CITES. In the eyes of the Department of Forestry, Fisheries and the Environment (DFFE), if they are not registered, then the breeding cannot be commercial.
But the absence of registration does not confirm non-commerciality. This leaves an important regulatory gap: the state holds no evidence that the exports are non-commercial, and likewise no evidence that they are not. This omission underscores a critical governance challenge – the difference between absence of evidence and evidence of absence.
The 2024 report by Four Paws mentioned above documents extensive tiger and lion part exports, often with unclear or unverifiable purposes. This is despite a 2020 high-level government panel recommending that the predator breeding industry be phased out, and a 2024 ministerial task team reinforcing those recommendations.
The latter report noted that South Africa’s large captive lion population – estimated at 8,000 – presents ongoing regulatory challenges and may conflict with international conservation trends. There are also at least 626 known tigers currently kept in captivity in South Africa across 72 facilities.
South Africa is the single-largest global exporter of big cats and their parts, according to the CITES trade database. While this may technically comply with CITES provisions for Appendix II species (captive-bred animals), inconsistencies between export and import data suggest that closer scrutiny is needed.
As of the time of writing, commercial-scale big cat farming was still permitted in South Africa. The country now also has the largest number of tiger breeding facilities outside Asia. Not one is CITES-registered, but – as I’ve argued above – they should be. That they aren’t raises questions about the destination and use of exported specimens.
There are three major areas of concern. The first is a lack of regulatory oversight. Under Nemba, permits are required for activities involving threatened or alien species such as tigers. However, enforcement varies across provinces. According to the Four Paws report:
- Only two provinces conduct regular inspections;
- Limpopo has no provincial regulations governing tiger breeding; and
- North West did not respond to a PAIA request, despite housing numerous facilities.
Without consistent provincial-level enforcement it becomes difficult to ensure that permits reflect on-the-ground compliance.
Second, there are radical international conservation implications for not addressing the murky tiger trade properly. Since 2004, South Africa has issued permits for the export of 3,545 live big cats and 34,246 parts, including 517 live tigers.
Yet the country has no CITES-registered commercial breeding facilities for tigers. CITES itself – as indicated above – has issued a directive that explicitly calls for countries (like South Africa) with “commercial-scale” breeding operations to put an end to those. Even if the minister argues that there isn’t explicit evidence of commercial operations, the scale certainly appears commercial.
The minister’s response appears to be missing the point by sticking to the “letter of the law” without any direct evidence that the operations are not commercial. Self-reporting by those who stand to benefit is not evidence; it’s wishful thinking.
Third, policy implementation remains weak and the political will to shut down the industry really needs to be stronger. On 15 November 2024, the government gazetted a voluntary exit programme, calling on lion bone stockpile holders to participate. While signalling intent, this initiative currently does not extend to tigers or address the scale of breeding activity.
It seems obvious that the DFFE machinery continues to obfuscate the truth, regardless of which minister is in charge. In a world where we have overstepped six of our nine planetary boundaries, and are witnessing the sixth extinction before our very eyes, it is deeply concerning that the South African government can turn a blind eye to commercial-scale tiger breeding by simply insisting – without evidence – that the breeding is for non-commercial purposes.
This violates the directive of the very same CITES that our government purports to comply with. DM
