More than 8,000 tigers live in captivity in China, Laos, Thailand, and Vietnam, where they are kept and bred for commercial uses, including for selfies with tourists and illegal trade in their bones, skins, and other parts. Tiger bones may be turned into medicinal paste or brewed into a wine believed to make the drinker stronger and more virile, while skins and teeth are used in decor and jewelry.
Captive tiger facilities have been documented speed breeding females, holding cats in inadequate enclosures, drugging them to make them safer for tourist interactions, and feeding them poor diets that lead to either emaciation or obesity. Connections to criminal enterprises have also been documented.
Many conservationists also say that these tiger “farms” destigmatize the use of tigers as a commodity and thus also pose a threat to the 3,900 tigers left in the wild, which are at risk of being killed by poachers. For years, tiger experts and wildlife trade experts in the international community have worked to discourage tiger farms and prevent captive tigers’ parts from ending up on the black market. (Here’s what you need to know about tiger farms.)
But now, a draft document, funded by the U.S. Fish and Wildlife Service and shared with National Geographic, appears to legitimize tiger farming, according to experts on the illegal trade in tigers. Preliminarily entitled “Inspection Manual for Facilities Breeding Tigers in Captivity,” it’s based on the premise that some commercial tiger breeding is acceptable. This premise is in contravention of internationally agreed rules and undermines efforts to phase out such facilities. Furthermore, multiple tiger experts say they weren’t consulted until after the draft was written and that the scientists leading the project have little expertise on the issue of tiger farming.
Gabriel Fava, a senior policy advisor at the Born Free Foundation, who reviewed the document, told National Geographic that its contents are “grossly unfit” and “have inherent biases.”
“The report promotes commercial breeding of tigers as a valid conservation strategy, and that is wrong,” says Debbie Banks, the campaign leader for tigers and wildlife crime at the nonprofit Environmental Investigation Agency, in London. “This document comes dangerously close to promoting tiger farming.”
None of these facilities has ever reintroduced tigers back into the wild, Banks says—nor could they, given problems with inbreeding, habituation to humans, and lack of survival skills. “Those facilities are not contributing to conservation,” she says.
The Fish and Wildlife Service acknowledged multiple interview requests and questions for comment but did not respond with answers in time for publication.
The document was commissioned by the Secretariat of the Convention on the International Trade in Endangered Species of Wild Fauna and Flora (CITES), a global treaty signed by 183 member states that regulates the cross-border trade of imperiled animals and plants. It was meant to be “a user-friendly inspection guide/manual for verifying [that] tiger captivity breeding facilities” are in compliance with international rules, according to the instructions given to the authors, which were also shared with National Geographic.
While tigers are bred in captivity for commercial purposes, breeding for conservation efforts is the only acceptable purpose under to a 2007 rule adopted by CITES member nations.
Nonetheless the draft document is based on the idea that commercially breeding tigers is acceptable, say five experts interviewed by National Geographic. Its opening line states, “Breeding tigers for exhibition to the public, or for conservation, are both widely acknowledged as legitimate purposes.”
That is simply not true, says Sue Lieberman, vice president of international policy at the New York-based Wildlife Conservation Society. “CITES has made a strong statement that tigers should only be bred for conservation purposes,” she says, “but this document says that display is fine, and if the public would like to see more tigers, it’s really fine to breed more,” says Lieberman, who worked on CITES issues at the Fish and Wildlife Service for more than a decade, including as chief of the office responsible for scientific issues related to CITES implementation.
Despite the 2007 rules, tiger farms in some countries have grown, Banks says.
Recognizing this, in 2016 and again in 2019, CITES member countries passed a decision to conduct investigative missions to “facilities which may be of concern keeping Asian big cats in captivity.” The goal was to determine whether CITES needed to take stronger action, such as issuing trade sanctions, to encourage certain countries to close their commercial tiger farms. In 2018, a report identified seven countries with 66 such facilities of concern—ones that seemed to be breeding tigers on a commercial basis without an apparent benefit to conservation and ones already implicated in illegal trade.
To support the investigative missions, the Fish and Wildlife Service donated $30,000, but when the pandemic prevented the in-person trips, the service agreed that its funds could be used for other activities, including developing inspection guidelines for tiger breeding facilities, according to Francisco Pérez, a program support officer at CITES. The CITES secretariat contracted the International Union for Conservation of Nature (IUCN) to research and write the guide.
The IUCN did not respond to questions about the content of the guide.
When a draft of the inspection guidelines was shared with a handful of nonprofits, among others, for feedback on July 2, the nonprofits raised immediate concerns. At least two, the Environmental Investigation Agency and the Born Free Foundation, asked for their names to be removed from the acknowledgement section.
Six days later, Pamela Scruggs, who leads the Fish and Wildlife Service’s office responsible for implementing CITES in the U.S., acknowledged to several nonprofits that “given the process concerns you and we have noted, we are exploring our options to remedy or improve the situation,” according to an email sent on her behalf, which was shared with National Geographic. The email did not specify what “remedies” may be considered.
Experts left out
Officials at the U.S. Department of State, which has long been opposed to tiger farms, were only informed of the report’s existence after it was shared with the nonprofit groups, a spokesperson told National Geographic in an email.
“The draft text shared with NGOs has serious flaws and factual errors that run contrary to U.S. and international efforts to combat tiger trafficking,” the spokesperson said.
Many others, including tiger scientists and tiger trafficking experts, say they were left out of the process as well. Such experts are typically involved in developing policies and guidelines from the start, as opposed to being consulted for feedback once a draft has been prepared. The lack of transparency regarding the report’s conception and creation is concerning, Lieberman says: “To be charitable, this might have been undertaken out of pure naiveté and ignorance, but it’s still a flawed process.”
The IUCN Cat Specialist Group, made up of scientists focused on the conservation of wild cat species, also was not consulted during the early drafting process, nor were members invited to be co-authors, says Kristin Nowell, part of the IUCN Cat Specialist Group and a leading authority on tigers and tiger trade. Instead, the primary expertise of three of the four authors commissioned to undertake the project is in reptiles.
Daniel Natusch, the senior author of the report and chair of the IUCN’s Boa and Python Specialist Group, explained in an email to the nonprofits with whom the draft was shared that he had previously developed a more generic inspection guide for captive breeding facilities for the IUCN, on behalf of CITES. “I don’t personally do much work on tigers, so have no emotional attachment to the animal or the issue,” he wrote. “I believe this is a strength.”
The report was led by Kirsten Conrad, a member of the IUCN Sustainable Use and Livelihoods Specialist Group, which promotes the sustainable use and trade of wildlife. Conrad has expressed pro-tiger trade and farming views for more than a decade. Trade bans have caused tigers to be worth more dead than alive, Conrad has argued, so legalizing the sale of parts from farmed tigers should be evaluated as a means to brings relief to wild tigers—a contention Banks and others disagree with.
“Having such a person as the lead author certainly gives the appearance of putting the fox in charge of inspecting the henhouse for possible security weaknesses,” Nowell says.
Another co-author of the report, Hank Jenkins, has also written in favor of tiger trade. Jessica Lyons, a member of the IUCN Sustainable Use Group and two IUCN reptile groups, was the fourth co-author.
None of the authors responded to requests for comment. The IUCN did not provide clarification about how the authors were chosen and which IUCN bodies were involved in the decision-making process. “The draft inspection manual remains unfinished,” wrote Matthias Fiechter, an IUCN spokesman in an email, adding that the IUCN is working with the CITES secretariat to determine next steps.
When Natusch shared the draft on July 2 for feedback, he sent it to select zoos, IUCN specialists, officials from the seven countries that have tiger breeding facilities of concern, and five nonprofits: the World Wide Fund for Nature, the Wildlife Conservation Society, the Born Free Foundation, the Environmental Investigation Agency, and the Species Survival Network. The criteria used to select those five groups—and to exclude others that work closely with tigers, tiger trade, and tiger farms—is unclear.
Natusch invited representatives of the five groups to submit composite comments within six days. “We appreciate your comments and suggestions and aim to incorporate them, however, their final inclusion will not be guaranteed,” Natusch wrote in his email, which was forwarded to National Geographic. He added that input received from experts from other organizations not on the list “will not be considered.”
In addition to taking issue with the report’s premise that commercial tiger breeding for exhibition to the public is acceptable under international rules, other errors and omissions further imply a lack of knowledge about tigers and how best to monitor them, Lieberman and others say.
For example, the document calls on inspectors to count the number of tigers present “to determine how many tigers … are held by the facility, and what numbers have died and/or been sold/exported since the last inspection.”
But as Banks and other experts said in their comments to the authors, simply counting tigers isn’t enough to track them. If a facility slaughters one tiger for its parts, it could replace it with another tiger of roughly the same age, and inspectors counting total tiger numbers may not notice. “Just counting individuals is basically a manual on how to launder tigers,” Lieberman says. “It really shows a lack of expertise.”
The document suggests that microchips and ear tags could prevent unrecorded tiger swaps, but Scott Roberton of the Wildlife Conservation Society noted in comments submitted to the authors that ear tags are commonly torn out when tigers are housed together. Some facilities have also been caught removing microchips from dead tigers, likely with the intention of reusing them.
Instead, DNA analysis and stripe pattern profiles are key to monitoring what happens to animals. In March, for example, the Mukda Tiger Park and Farm in Thailand—a facility that whistleblowers had long said was implicated in illegal trade—was closed after DNA tests on six cubs revealed that none were born in captivity.
DNA, Roberton emphasized, is particularly important for supporting law enforcement investigations of poached animals and parts, as exemplified by the case in Thailand.
The report also says that inspectors should “contact the facility owner(s) and/or manager(s) to confirm the inspection date and time”—that is, that inspectors should call ahead of time to let tiger farm owners know that they are coming.
“Because of the crime and corruption associated with these facilities, you have to make sure there’s also unannounced, unscheduled inspections,” Banks says.
CITES’ Pérez did not respond to follow-up questions about whether the draft manual will be amended to reflect experts’ comments and criticisms, or about how publication will proceed—if at all.
Lieberman, echoing others, says, “I’m hoping it’ll just be shelved and killed.”
Wildlife Watch is an investigative reporting project between National Geographic Society and National Geographic Partners focusing on wildlife crime and exploitation. Read more Wildlife Watch stories here, and learn more about National Geographic Society’s nonprofit mission at natgeo.com/impact. Send tips, feedback, and story ideas to NGP.WildlifeWatch@natgeo.com.