PAPER TIGERS?
The Role of the U.S.
Captive Tiger Populationin the Trade in Tiger Parts
Douglas F. Williamson&
Leigh A. HenryA TRAFFIC NORTH AMERICA REPORTThis report was
published with thekind support ofPAPER TIGERS?
The Role of the
U.S. Captive Tiger Populationin the Trade in Tiger Parts

Douglas F. Williamson
andLeigh A. Henry

July 2008

TRAFFIC North America
World Wildlife Fund
1250 24th Street NW
Washington, DC 20037 USA

Visit www.traffic.org for an electronic edition of this report, and for more information about
TRAFFIC North America.

© 2008 WWF. All rights reserved by World Wildlife Fund, Inc.
All material appearing in this publication is copyrighted and may be reproduced with permission.
Any reproduction, in full or in part, of this publication must credit TRAFFIC North America.
The views expressed in this report do not necessarily reflect those of the TRAFFIC Network, World
Wildlife Fund (WWF), or IUCN-International Union for Conservation of Nature.
The designation of geographic entities in this publication and the presentation of the material do not
imply the expression of any opinion whatsoever on the part of TRAFFIC or its supportingorganizations concerning the legal status of any country, territory, or area, or of its authorities, orconcerning the delimitation of its frontiers or boundaries.
The TRAFFIC symbol copyright and Registered Trademark ownership are held by WWF.
TRAFFIC is a joint program of WWF and IUCN.
Suggested citation: Williamson, D.F. and L.A. Henry. 2008. Paper Tigers?: The Role of the U.S.
Captive Tiger Population in the Trade in Tiger Parts. TRAFFIC North America, Washington D.C.:
World Wildlife Fund.
Front cover photos from the top, clockwise, are: Tiger by fence, Sybille Klenzendorf; Tiger cub,Doug Williamson; Tiger bones, Mohit Aggarwal; Tiger behind fence, Doug Williamson; Tiger pelts,
Vladimir Shumkin.

TABLE OF CONTENTSACKNOWLEDGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .iv
PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .v
EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
METHODS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5
BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7
LAWS AND REGULATIONS GOVERNING TIGER TRADE AND CAPTIVE TIGERS IN THE U.S. . . . . . . . . . . .11
THE U.S. CAPTIVE TIGER POPULATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17
CASE STUDY: FLORIDA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22
DOMESTIC AND INTERNATIONAL TRADE OF TIGERS IN THE UNITED STATES . . . . . . . . . . . . . . . . . . . . .29
CONCLUSIONS AND RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43
REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .47

LIST OF TABLES
Table 1. Conservation status of extant and historical tiger subspecies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7
Table 2. U.S. states that allow/ban possession of Tigers as pets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15
Table 3. State controls on Tiger breeding in the United States . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20
Table 4. Live Tigers imported to and exported from the United States, 2001-2006 . . . . . . . . . . . . . . . . . . . .29
Table 5. Exhibition/circus Tigers imported into the United Statesby country of export, 2001-2006 (Number of Tigers) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31
Table 6. Exhibition/circus Tigers exported from the United Statesby destination, 2001-2006 (Number of Tigers) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32
Table 7. Scientific and biomedical Tiger imports, 2001-2006 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34
Table 8. Seizures of Tiger-related medicinal imports into the United States, 2001-2006 . . . . . . . . . . . . . . .35
Table 9. Import seizures of non-medicinal Tiger parts/derivatives 2001-2006 . . . . . . . . . . . . . . . . . . . . . . . .38

LIST OF FIGURES
Figure 1. Historic range of Tigers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8
Figure 2. Live Tigers imported into the United States, 2001-2006 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30
Figure 3. Live Tigers exported from the United States, 2001-2006 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30
Figure 4. Number of exhibition/circus Tigers imported into the United Statesby country of export, 2001-2006 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31
Figure 5. Number of exhibition/circus Tigers exported from the United Statesby destination, 2001-2006 (Number of Tigers) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32
Figure 6. Number of seizures of Tiger-related traditional medicine imports
into the United States by country, 2001-2006 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .36

i

ACKNOWLEDGEMENTS
provided valuable information and insights on issues
regarding the keeping and trade of Tiger in the UnitedStates for this report. Others who provided valuable
information and comments include Ron Tilson of theMinneapolis Zoo and Mike Carpenter of the U.S. Fish andWildlife Service.

TRAFFIC and the authors wish to thank a number ofpeople who provided invaluable assistance in the
research, writing, and review of this report.
We wish to thank Sue Lieberman of WWF International;
Craig Hoover of the U.S. Fish and Wildlife Service;
Kristin Nowell of the IUCN/SSC Cat Specialist Groupand Cat Action Treasury; Barney Long of WWF-US;
Steve Olson of the Association of Zoo and Aquariums;
Crawford Allan of TRAFFIC North America; and Steve
Broad of TRAFFIC International for their careful andinsightful reviews and comments on preliminary drafts of
the report.

TRAFFIC and the authors also express gratitude to therepresentatives of state fish and wildlife agencies,
agriculture departments, and other agencies who patiently
answered TRAFFIC’s questions about specific laws,
regulations and policies related to the keeping, breeding,
trade, and disposition of Tigers within their jurisdictions.

We would also like to thank Nicole Paquette of the Animal
Protection Institute in Sacramento, California, for her
assistance in identifying key laws and regulations regarding
captive Tigers in the United States. Carole Baskin of Big
Cat Rescue in Tampa, Florida; Lisa Stoner of the Peace
River Refuge in Zolfo Springs, Florida, and Dave Orndorffof the Mill Mountain Zoo in Roanoke, Virginia also

The Rufford Maurice Laing Foundation is gratefully
acknowledged for its support to TRAFFIC in the final
review process for this report.
Finally, TRAFFIC wishes to extend its sincere thanks to
the National Fish and Wildlife Foundation’s Save the Tiger
Fund and, in particular, to Judy Mills and Mahendra
Shrestha for their generous support of this project.

iv

PREFACE
The relationship between Tigers and the people whoshare their native ranges in Asia is longstanding,complex, and, in too many unfortunate circumstances,adversarial. At one time, Tigers were largely masters of
their environs, which once stretched from the Pacific
Ocean in the east to the Caspian Sea in the west. Over the
past hundred years or so, that vast range has shrunk by
more that 90%, and the contemporary population of wild
Tigers may be less than three percent of its size at theturn of the 20th century.

This report represents TRAFFIC’s effort to determine
whether the United States should be genuinely concerned
about such a threat, or whether the issue is a “Paper
Tiger”, a term derived originally from a literal English
translation of the Chinese phrase meaning somethingwhich seems as threatening as a Tiger but is reallyharmless. To answer that central question, TRAFFIC
undertook to answer a set of very specific questions.
Primary among these: How many Tigers really exist in
the United States? What legal or other steps has the U.S.
taken to protect them from illegal trade? What happens to
U.S. Tigers, and their carcasses and parts, when the
animals die? Is there evidence that U.S. Tiger parts areentering illegal trade, either domestically orinternationally? And, finally, if there is evidence of tradeor gaps in the U.S. system for managing captive Tigers tokeep them out of trade, what needs to be done about it?

Various reasons account for the decline of Tigers in thewild. Exploding human populations have eaten deeply
into their habitat and reduced their prey base. Predationsof livestock, and sometimes fatal encounters between
Tigers and people, have led local populations to eradicate
the cats in some areas. The value of Tiger pelts, bone,
tonics, meat, claws, teeth, and other parts for human use
or consumption have made the species a lucrative target
for poachers armed with modern weapons.

What we found in investigating these questions surprised
us. At the outset of the project, we believed thatanswering them would simply require contacting relevant
management authorities at the federal and state levels,and then assembling data on Tiger numbers, locations,rules for disposal, trade data, and other pertinent issues.
We quickly learned that getting to the bottom of the issue
would be far more difficult.

Even so, Tigers continue to exert a mysterious and evenmystical presence in their remaining redoubts. Yet few
people get to witness firsthand the power, grace, andmajesty of wild Tigers. Instead, public familiarity withthese great cats comes either indirectly through nature
documentaries or films, or in person through zoos,
circuses, wildlife sanctuaries, or wild animal acts orshows. In fact, the two largest single populations ofTigers are now those that reside in captivity in China andthe United States, respectively.

Although the United States keeps data on imports andexports of legally protected species such as Tigers, at thedomestic level federal responsibility for monitoring
captive Tiger populations is divided between two
different agencies, neither of which has a mandate tocomprehensively account for how many Tigers actuallyexist within the country. Among the 50 individual statesthat also have jurisdiction over these cats, not all evenhave laws and regulations governing their possession in
private hands, and there is little uniformity among thosethat do. We further discovered that gray areas and legal or
regulatory loopholes abound at both the federal and statelevels. What we began as a project to find straightforward
data and answers therefore turned out to be a massive
jigsaw puzzle, with small pieces spread all over theUnited States, involving numerous jurisdictional levels
and stakeholder interests. We struggled with accepting
the fact that many of the questions we had laid out were,in fact, unanswerable.

As this report explains, the emergence of a large captive
Tiger population in China is a recent phenomenon,
resulting from efforts to develop a new, legal source ofTiger parts to meet an enduring domestic demand for
Tiger parts in traditional Chinese medicine. The UnitedStates’ captive Tiger population, by contrast, grew slowly
over many years, not for purposes of trade orconsumption, but rather because of demand for live catsfor exhibitional use, and also to feed a market for people
who desire these cats as “pets”.
The ongoing decline of wild Tiger populations, coupledwith ongoing commercial demand for their parts, led
TRAFFIC North America to question whether and how
trade pressure might come to affect the U.S. captive Tiger
population. We speculated that persistent demand for
Tiger parts, combined with a potentially reduced supply
from the wild, might lead those involved in the illegal
Tiger trade to target the U.S. captive Tiger population.
We looked at this issue with the end question always
being whether and how this possible source of illegal
parts might, in turn, impact tigers in the wild.

This report summarizes the findings of our research. It
finds no clear evidence that the U.S. captive Tiger
population has played a role to date in illegal
international trade. Ordinarily, such a finding should beconsidered good news. However, the report also showsthat the current U.S. system for managing captive Tigersv

is wholly inadequate to address the question of what
would happen should this Tiger population become atarget for those seeking to engage in such activity. Putplainly, when looked at in trade terms, the U.S. legal andregulatory system governing these cats is completely
disjointed. There is no single source to turn to that knows
how many Tigers exist in the country, where they are,who owns them, and, most importantly in terms of trade,
what happens to them or their parts when they die.
Though we knew going into our research that the systemregulating captive Tigers would be somewhat complex
and disperse, we were nonetheless taken aback at its
complete inability to account for these cats with any levelof accuracy.

another roadblock to their continued survival. As the oldsaying goes, “an ounce of prevention…”
Two important caveats and limitations regarding thematerial presented should be kept in mind while reading
this report. First, this report concentrates on issues related
to trade in Tigers and their parts. We recognize that some
may have wanted to see more concentration on issues
regarding animal welfare and the propriety of keeping
Tigers in captivity. We do not dismiss such concerns. In
the course of the research that produced this report, we
saw captive Tigers being well cared for in zoos andresponsible animal sanctuaries that take in otherwise
unwanted cats. However, we also witnessed Tigers infacilities and conditions—or put to commercial uses—that we found profoundly disturbing. We believe thatwhile our recommendations focus on trade issues, theirfull implementation may address other concerns as well.

This report attempts to identify key gaps in the U.S.
regulatory system regarding Tiger trade that the country
needs to address, quickly. Should wild Tiger populations
continue to decline, and/or should demand for Tiger
products persist or even increase, there is no guarantee that
the U.S. captive Tiger population will not become a target.
Some might argue that given other priorities and limited
budgets, guarding against what is currently a prospective
threat is a low priority. We would argue that the specificrecommendations offered herein represent an opportunity
for the United States to take action now to preclude thechance that U.S. Tigers ever become a trade target for theinternational market, thereby helping to reinvigorate latentdemand for Tiger products, including traditional
medicine—a demand which would, in turn, further threaten
the world’s remaining wild populations. While this may
seem to some a tenuous link to Tiger conservation, wild
Tigers simply cannot withstand any further pressures, andeven the smallest additional threat now looms large as yet

Second, we note that while this report focuses on Tigers,
many of the issues and recommendations herein may wellapply to other species of protected and unprotected cats(e.g., Leopards, Jaguars, African lions, Bobcats, Cougars,etc.).
It is our hope that the information, conclusions, andrecommendations herein prove helpful to federal andstate authorities charged with managing captive Tigers,
policy-makers, and others involved in Tiger conservation.
We look forward to collaborating with all interested
parties in discussions on the lessons we have learned
from this project, and how to move forward.

Douglas F. Williamsonvi

Leigh A. HenryEXECUTIVE SUMMARY
Despite decades of conservation efforts, the future
survival prospects for the world’s wild Tiger populations
remain uncertain. While intensive conservation efforts
have made progress in stabilizing Tiger populations insome parts of their range, many have been decimated,and enforcement measures targeting illegal trade continue
to be insufficient.

that the U.S. captive Tiger population plays a significant
role in illegal international trade at present. On thenegative side, however, the report identifies critical flaws
in the United States’ management of its captive Tiger
population as it relates to trade. These flaws need to beaddressed to ensure that the U.S. Tiger population does
not become a trade problem going forward.

One of the most significant threats facing Tigers today
stems from demand for their parts, especially bones for
traditional Asian medicines and skins for ornamentation.
As a result, most of the world’s attention and attempts toresolve the Tiger conservation crisis have focused on
Asia—particularly on key Tiger range and consumer
States—but it is clear that a global effort is required toconserve this species in the long-term.

Previous studies have documented that although wild Tiger
populations may be stabilizing in some parts of their range,
threats from habitat loss, fragmentation, and degradation, as
well as human conflict and poaching, remain serious (seeDinerstein et al., 2006; Sanderson, et al. 2006;
Seidensticker et al., 1999). Especially troubling is theongoing demand in China and other Asian nations for Tiger
parts—particularly bone—used in traditional medicine.
Recent years have also seen some demand for Tiger skins
for fashion and for traditional Tibetan clothing.

The role of countries such as the United States that havesignificant captive Tiger populations must be considered.
This is because, unfortunately, the world’s largest
remaining numbers of Tigers are no longer found in thewild in Asia, but rather exist in captivity. With as many as
5,000 Tigers, the U.S. captive Tiger “population” wasuntil recently considered the world’s largest, far
exceeding the fewer than 2,500 breeding individuals
believed to exist in the wild today (Nowell and Xu, 2007;
IUCN SSC Cat Specialist Group, 2008). As of the end of
2006, however, the estimated number of Tigers held in
China’s commercial Tiger farms alone had increased toan estimated 5,000 as well, with an annual re-productive
rate of more than 800 animals (CITES, 2007a; Nowell,2007). Although it is highly likely that China has now
surpassed the United States as the country holding themost captive Tigers, the sizeable number of Tigers in the
United States, and their potential role in illegal wildlife
trade, cannot be discounted.
In the year covering the period January 2007 to January
2008, TRAFFIC researched and analyzed the status ofwild Tigers and the trade threats facing them, the laws
and regulations governing captive Tigers in the UnitedStates, the status of this population, the role of the UnitedStates in domestic and international Tiger trade, and,
finally, the overall implications for conservation of Tigers
in the wild. This research sought to answer two central
questions. Are Tigers or Tiger parts from the U.S. captive
population entering the international or domestic Tiger
trade? And are there any implications of trade in parts
from U.S. captive Tigers on the conservation of Tigers in
the wild?
The report paints a mixed picture of the U.S. system for
managing captive Tigers and their role in the illegal Tiger
trade. On the positive side, the report finds no evidence

TRAFFIC North America

Commercial international trade in Tigers and Tiger parts
has been prohibited under the Convention on
International Trade in Endangered Species of Wild Fauna
and Flora (CITES) for all Tiger subspecies except for the
Siberian Tiger since 1975; the Siberian Tiger received
full protection in 1987. Subsequently, a series of CITES
Decisions and Resolutions has called upon member
States to pass measures to effectively implement the trade
ban and undertake Tiger conservation measures, but not
all have. Markets for illegal Tiger products continue toexist not only in Asia, but also in the United States,
Europe, and other parts of the world.
The United States in particular has become the subject ofattention for its potential role in the ongoing Tiger trade,both as a market for Tiger parts and because of its large
captive Tiger population. As the report explains, there
exists in the United States a legal bifurcation between
these two issues. Whereas international and interstate
trade of Tigers and their parts is governed under federal
laws and regulations, the management of captive Tigers
lies largely within the jurisdiction of individual U.S.
states. Depending upon the state, this bifurcation canapply both to Tigers used for commercial purposes and to
those kept privately, sometimes as “pets”.
At the federal level, the United States has a number ofstrong laws that implement the United States’ obligations
under CITES, ban the sale of Tiger parts or derivatives(or anything labeled as Tiger parts or derivatives),
regulate the interstate transfer of live Tigers, and requireregistration for certain species of captive-bred wildlife,
including pure-bred Tigers (i.e., Tigers with a known
breeding pedigree at the subspecies level). U.S. federal
law also provides for the contribution of funding,1technical assistance, and other measures to conserve
remaining wild Tiger populations in Asia; the U.S.
Congress has appropriated significant funds for theconservation of Tigers in the wild through the Rhinoceros
and Tiger Conservation Act.
As the report explains, however, regulatory gaps at boththe federal and state levels have created loopholes that
could undercut the overall U.S. effort to combat theillegal Tiger trade. At the federal level, while the U.S.
Department of Agriculture (USDA) and the U.S. Fish andWildlife Service (USFWS) have regulatory responsibility
over aspects of the interstate transfer, take, sale, importand export, possession, and humane care of captive
Tigers, exceptions and exemptions to the applicable laws
and regulations mean in practice that Tiger owners needto simply maintain records of their animals.
Requirements that Tiger owners regularly report on theinventory of their cats are more limited, so these federal
agencies do not know at any given time how many Tigers
actually exist in the United States, and there are no
federal requirements that owners report what happens to
Tigers or their parts when the animals die.
At the state level, laws tend to focus on the keeping of live
Tigers and the threat that such animals may pose tohuman beings. As such, U.S. state laws tend to focus more
towards issues of human health and safety, as well as thewelfare of the animals, rather than on issues regarding thetrade of products or derivatives of dead Tigers.
Furthermore, a number of U.S. states continue to allow
for the private ownership of live Tigers with virtually no
regulation. U.S. states also differ greatly on who may
keep Tigers and under what conditions. Some states
regulate captive Tigers through wildlife departments,
while others do so through agricultural or other agencies,
with vastly different loopholes or exceptions regarding
ownership, licensing or permitting requirements, andother issues.
Even in states that have regulations regarding the keepingof Tigers in private hands, oversight is sometimes lax. A
field visit by TRAFFIC to Florida, summarized in a casestudy later in this report, provides an example. Florida
law allows for the private ownership of Tigers only forcommercial purposes (exhibition, etc.). However,
TRAFFIC found that while Florida has a significant
population of Tigers in private hands, state regulatory
authorities admittedly do not know exactly how many
there are, who the owners are, or the commercial
purposes that would justify such ownership.
The practical implications of this legal disconnect
become clear in TRAFFIC’s examination of the status of
captive Tigers in the United States. A study by Werner(2005) categorized four different types of U.S. captive

2

Tigers. The first are Tigers held in zoos or other facilities
accredited by the Association of Zoos and Aquariums(AZA). These cats, which account for only a small
fraction (as little as six or seven percent of the overall
estimated U.S. Tiger population), are the most likely to
be involved in conservation-based programs and well
documented and tracked through the USFWS registration
system for captive-bred wildlife. The second are Tigers
held in facilities licensed and regulated by the USDA.
These include cats imported, bought, sold, or traded(interstate), as well as animals in animal performances,zoos (AZA and other), carnivals, or promotional exhibits.
The third category involves Tigers held in rescue facilities
or animal sanctuaries. It should be noted that while there
are a number of reputable sanctuaries in the United States,
as is explained in the body of the report, some facilities
that call themselves “sanctuaries” or “refuges” are engaged
in the breeding, sale, and trade of Tigers, both legal andillegal. Fourth are Tigers held in private collections.
A fundamental problem TRAFFIC identified in its
research is that under the United States’ diffuse
regulatory system, there is no way to determine exactly
how many Tigers exist in captivity in the United States,
where they are, or who owns them. For example, while
the AZA can account for the Tigers in its zoos, the
USDA does not keep a species-specific database ofTigers held by its license-holders. USFWS regulations for
captive-bred wildlife cover only a small fraction of Tigers
in the United States. And some states either do not
require Tiger owners to report their animals, or records
are sketchy and incomplete.
For the above reasons, only anecdotal information isavailable about what happens to U.S. captive Tigers when
they die; no precise data exist on how many Tigers may
die each year or what becomes of their carcasses or parts.
Indeed, especially with Tigers in private collections,disposal of the animals is typically at the discretion of theowners in compliance with state or local ordinances, if
such ordinances exist. This report discusses what is
known about the keeping and disposal of these animals
and, just as importantly, how much remains unknown.
The report also details how some legal international“trade” of Tigers continues. The overwhelming majorityof such trade involves the export and subsequent reimport of live U.S. captive Tigers for purposes ofexhibition or entertainment (circuses, film projects, etc.).
Live Tigers also continue to enter and leave the UnitedStates for zoological, educational, breeding, or otherauthorized purposes. Recent years have also seen theimport or export of a very small number of Tiger
products or derivatives (skins, rugs, claws, specimens,etc.). This aspect of the legal trade involves either items
authorized for educational, scientific, or research

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Partspurposes, or parts or products from Tigers that can crossinternational borders under legal exceptions granted foritems that pre-date CITES, or are antiques (more than
100 years old).
Official trade records also document a continuing illegal
trade in Tiger parts or derivatives entering the UnitedStates. From 2001 to 2006, USFWS seized more than
250 shipments of products, most traditional Asian
medicines labeled as containing Tiger, entering theUnited States. Trade records also show seizures of otherillegal Tiger parts or products including skins, claws,
teeth, rugs, and other items.
There is positive news, in that TRAFFIC’s examinationof trade records, seizures, and law enforcement
operations shows no evidence that bone or other parts
from U.S. captive Tigers are entering international trade.
Trade data kept by the USFWS indicate that the UnitedStates market for Tiger products (all illegal) is being fed
by imports from overseas, particularly China, with themost commonly seized product being traditional
medicines (e.g., Tiger tonics, plasters, etc.) purported to
be derived from Tiger bone. Data from 2001 to 2006
show no seizures of U.S. Tiger parts leaving the country,
and USFWS has not found evidence that parts or
products from U.S. Tigers are entering the global trade.
There have been cases of domestic seizures of parts(particularly meat and skins) from U.S. Tigers, but theseappear to be fairly isolated instances rather than evidenceof widespread trade activity.
It should be noted, however, that the absence of current
evidence of U.S. captive Tiger parts in international tradedoes not mean that such trade will not become an issue
going forward. Even if U.S. Tigers are not entering global
trade at present, the report shows that in some states there
are significant numbers of surplus adult Tigers that theirowners either do not want or struggle to support
financially, given the substantial expense of their upkeep.
Furthermore, weaknesses and gaps in the existing U.S.
regulatory system mean that the potential for significant
exploitation of parts from such U.S. Tigers represents a
potential problem. This is especially true if China, which
has banned domestic trade in Tiger parts and products
since 1993, goes ahead with plans to trade in “farmed”
Tigers1 to meet domestic demand. Reintroducing such alegal supply into the market will lead to the resumptionof a latent demand for Tiger products that many haveworked decades to suppress. There is no guarantee thatsuch market stimulation would be fed only from farmed
Tigers in China. More probable is that any such action

would increase demand for Tigers parts from all sources,
including possibly captive Tigers in the United Statesand, of course most worrying, from wild Tigers.
The question for the United States is straightforward:
How can the country develop and implement a consistent,
nationwide system to manage captive Tigers and prevent
their entry into illegal trade, thereby avoiding any U.S.
contribution to the reinvigoration of demand that could
further threaten wild tigers? As a nation that prides itself
as a global leader in wild Tiger conservation, it isimperative that the United States do so, with actions
needed at both the federal and state levels. Some key
solutions will also lie outside of government with zoos,
circuses, related associations and interest groups.
TRAFFIC recommends that the United States take steps
on the legal, regulatory, oversight, educational, and law
enforcement fronts to better track the U.S. captive Tiger
population and ensure that these animals or their partscannot enter illegal trade. These recommendations
include:• At the federal level, USFWS should issue new
regulations to require that all persons and facilities
breeding Tigers in the United States should be subject
to the agency’s Captive-Bred Wildlife registration
system. At present, “generic” or inter-subspecificcrossed Tigers are exempt, even though these are
believed to represent most of the U.S. captive Tiger
population.
• USDA should also require that all persons or facilities
holding USDA licenses for exhibition or
breeding/dealing in Tigers report annually on the numberof Tigers held, births, mortality, and transfer or sale.
• All U.S. states that allow private citizens to keep
captive Tigers must enact laws or regulations that
require a comprehensive accounting of the number andlocation of all captive Tigers in their jurisdictions; suchrecord-keeping must account not only for live Tigers,
but also for the disposal of Tigers and their parts when
they die.
• State and/or federal agencies tasked with regulating
Tigers should further require that all Tigers in the
United States be implanted with microchips containing
essential identifying information. When a Tiger dies,owners should be required to notify regulatory
authorities, who would collect the chips upon receiving
proof that the animal and its parts had been properly
and permanently disposed of.

1 Tiger farms are intensive operations breeding on a commercial scale; owners of Chinese Tiger farms have petitioned the government to legalize domestic trade in
products derived from the captive-bred animals (Nowell 2007). It is important to note that whereas in China thousands of Tigers exist on these commercial farms, no such
farms exist in the United States.

TRAFFIC North America3• States should also require that all facilities operating as
Tiger “sanctuaries” adhere to strict criteria such as banson breeding, sale, or trade in the animals; for example,
complying with the 2007 USFWS definition of what
constitutes an accredited sanctuary.
• States should also consider adopting laws or
regulations that establish a system of “reciprocity.”
Under such a system, states would enact rules that
require that any Tigers imported into their jurisdictions
be micro-chipped and registered as suggested above;
Tigers outside of the system would not be allowed.
• As an immediate interim measure, private stakeholders
in Tiger conservation such as zoos, sanctuaries,
circuses, and others could establish a voluntary system
to inventory, regulate, and accredit holders of captive
Tigers (and possibly other big cats) according to theprincipals outlined above. NGOs could further assist
this effort by offering to help fund and/or manage a

4

U.S. Tiger database that keeps track of U.S. captive
Tigers more broadly.
• U.S. federal and state government agencies—as well as
NGOs, facilities accredited with the AZA, and others
interested in Tiger conservation—should continue andenhance public awareness programs to further reducethe demand and use of Tiger parts in traditional Asian
medicines both in the United States and abroad.
• State and federal law enforcement should be provided
more resources to conduct surveys and undercover
operations of TCM shops in the United States—
funding for the USFWS wildlife inspection program
and related activities by U.S. Customs and Border
Protection (CBP) also needs to increase. Furthermore,
additional funding is also needed to enhance special
operations and undercover investigations in the UnitedStates to identify and eliminate potential markets for
Tiger parts in the United States and abroad.

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

METHODS
TRAFFIC conducted research for this report in several
stages. First, from late January to May 2007, data werecollected primarily through published and unpublishedreports, USFWS import and export data regarding Tigers
and Tiger parts, CITES documents, and a review offederal and state laws and regulations pertaining to thetrade, management, and keeping of captive Tigers in the
United States. Further information was derived frompress releases, the Internet, e-mail communications, andpersonal communications with organizations andindividuals involved in issues regarding the U.S. captive
Tiger population. Through this stage of the research,
TRAFFIC attempted to determine the overall scope of thepresence of captive Tigers in the United States, the types
and extent of legal imports and exports of live animals,
the existence and scope of illegal trade in Tiger parts(both domestic and international), and the potential
impact of such trade on remaining wild Tiger populationsin Asia.
Second, during the last half of 2007, government
authorities at the federal and state levels, as well as torepresentatives of sanctuary associations, individual

TRAFFIC North America

sanctuaries, safari parks and zoos, circuses, and others
were contacted, primarily by phone, to try to determine
how various laws and regulations are implemented inpractice. Specifically, as many people as possible wereinterviewed to learn how much is known about the
number of Tigers in private hands in the United States,
how closely these animals are regulated and monitored,
and what systems are in place to keep these Tigers andespecially their parts out of illegal trade.
Third, in December 2007, some of the information
gathered through interviews and research were groundtruthed by looking at some case studies in situ in the
United States. This involved field trips to review
operations that maintained Tigers in captivity in a region
where such operations were relatively common—thesouth-east United States. The field trips included visits tosmall zoos, sanctuaries, and other facilities holding
Tigers, to see the conditions under which the animals areheld and ask questions of the owners about how they
dispose of animals that die in their care.

56Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade of Tiger PartsBACKGROUND
The status of Tigers in the wild
Five subspecies of Tiger exist today: the Bengal Tiger
Panthera tigris tigris, the Amur or Siberian Tiger P. tigris
altaica, the Indochinese Tiger P. tigris corbetti, the Malayan
Tiger P. tigris jacksonii, and the Sumatran Tiger P. tigris
sumatrae. The South China Tiger P. tigris amoyensis isconsidered possibly extinct; three other subspecies, the Bali
Tiger P. tigris balica, Javan Tiger P. tigris sondaica andCaspian or Persian Tiger P. tigris virgata are extinct (IUCN
SSC Cat Specialist Group, 2008).
Tigers overall are classified as Endangered by the IUCNRed List of Threatened Species, having suffered an
estimated decline of greater than 50% in the last three
generations, with a total effective population size
estimated at fewer than 2,500 mature breeding individuals,
and no subpopulation containing more than 250 mature
breeding individuals. That figure represents a mere
fraction of the 100,000 Tigers found in the wild at the
beginning of the 20th century (IUCN SSC Cat Specialist
Group, 2008). It is also a significant drop even from total
population estimates in the late 1990s of 5,000–7,000
Tigers surviving in the wild (Seidensticker et al., 1999).
With poaching continuing and significant losses in someof India’s Tiger reserves, that country’s Tiger population
very likely remains in decline. Table 1 summarizes thelatest information provided for IUCN’s Red List ofEndangered Species on the conservation status of theworld’s historical and existing Tiger subspecies.

Another recent assessment showed that wild Tigers
remain extant in widely varying population sizes in
Bangladesh, Bhutan, Cambodia, China, India, Indonesia,
Laos, Malaysia, Myanmar, Nepal, Russian Federation,
and Viet Nam (Sanderson et al., 2006). However, anaccurate estimate of specific remaining wild Tiger
populations and sub-populations does not exist. A Tiger
census conducted by the government-run Wildlife
Institute of India estimates that there are as few as
1,165–1,657 Tigers left in the wild in India (Governmentof India, 2008).
A positive indicator for the future of remaining Tiger
populations is that a large area of suitable habitat remains(>1.1 million km2), and four strongholds were found that can
support more than 500 Tigers: the Russian Far East, Northeast China, the Terai Arc Landscape of India and Nepal, theNorthern Forest Complex-Namdapha-Roya Manas(Bhutan/Myanmar/India), and the Tenasserims of Thailand
and Myanmar (Dinerstein et al., 2006). With conservation
efforts focusing on preserving these habitats, as well as onreestablishing a sufficient prey base, the prospects for some
populations of wild Tigers may be positive.
Even so, future prospects for the survival of the world’s
few remaining wild Tigers remain uncertain. As a reportto the 54th meeting of the Standing Committee of CITES
noted in October 2006:“If the number of Tigers (and other Asian big cats) in
the wild is used as a performance indicator, it seems

Table 1. Conservation status of extant and historical Tiger subspecies
Subspecies

Distribution

StatusYear Assessed

Bengal Tiger

India, Bangladesh, Bhutan,
Myanmar, Nepal

Endangered

2007

Siberian (Amur) Tiger

China, Russian Federation,
North Korea

Endangered

2007

Indochinese Tiger

South-east Asia

Endangered

2007

Sumatran Tiger

Indonesia

Critically Endangered

2007

Malayan Tiger

Peninsular Malaysia

Endangered

2007

South China Tiger

China

Possibly Extinct

2007

Bali Tiger

Indonesia

Extinct (~1940s-1950s)

2003

Javan Tiger

Indonesia

Extinct (1970s)

2003

Caspian Tiger

South-west Asia

Extinct (~1960s-1970s)

2003

Source: IUCN SSC Cat Specialist Group, 2008.

TRAFFIC North America

7the efforts of governments, NGOs, the international
community and CITES over recent decades havefailed. Whilst there has been, and continues to be,good work taking place, the desired results ofincreases in population numbers and reductions in
illicit activities have, overall, not been achieved, andthe Secretariat sees little room for optimism” (CITES
Secretariat, 2006, in Nowell, 2007).

Threats to Tigers
Wild Tiger populations continue to be threatened by anarray of factors, including expanding human populations(and thereby conflict with local people), habitat loss andfragmentation, prey base depletion, commercial poaching
and trade, and lack of law enforcement. Exploding humanpopulations, for example, have led to loss, degradation,and fragmentation of Tiger habitat. Dinerstein et al.
(2006) found that Tiger habitat in India, Indochina andSouth-east Asia is now 40% less than 1995 estimates, andthat Tigers now occupy only 7% of their historic range.
Figure 1 shows the historic range of Tigers, as well as
their current range.
Loss of Tiger habitat, in turn, means a loss of habitat for,and thus a decrease in, Tiger prey. This loss of habitat,and encroachment of humans into the Tiger habitat thatremains, has led to an inevitable increase in human-Tiger
conflicts. These conflicts range from unexpected

Figure 1. Historic range of Tigers

Source: Dinerstein, E., C. Loucks, A. Heydlauff, E. Wikramanayake, G. Bryja, J.
Forrest, J. Ginsberg, S. Klenzendorf, P. Leimgruber, T. O’Brien, E. Sanderson, J.
Seidensticker and M. Songer. 2006. Setting Priorities for the Conservation andRecovery of Wild Tiger: 2005-2015. A User’s Guide. WWF, WCS, Smithsonian, and
NFWF-STF, Washington, D.C.- New York.

encounters between people and Tigers (which can resultin human death or injury) to Tiger attacks on domestic
livestock, which make an easy prey alternative(Dinerstein et al., 2006). Both of these are likely to resultin ill-will towards and retribution killings of the predator.
Mitigation of this human-Tiger conflict, as well as habitat
preservation, is critical to successful conservation of wild
Tiger populations.
More directly relevant for purposes of this report, one of
the most significant trade threats facing Tigers today
stems from demand for their parts and derivatives in
traditional Asian medicines2 (Dinerstein et al., 2006).
Cultures throughout the world have depended on
traditional medicines for thousands of years, and these
medicines depend on plants and animals as their key
ingredients. Though the bulk of such medicines use
plants, some also require parts of various animal species,
including Tigers, although many TCM practitioners
today, realizing the conservation implications, do notprescribe Tiger parts or parts of other endangered species.
Bone is the most widely used part of the Tiger in TCM,
and is historically prescribed to treat migratory joint pain
and stiffness, paralysis, weak knees and legs, spasms,
stiffness and pain in the lower back, and pain in bones(Bensky and Gamble, 1993). Tiger bone derivatives usedin traditional medicine include raw bone powder, gelatin,
wine, pills, “tea balls”, plasters or poultices, and tonics.
These products are not necessarily prescribed by TCM
practitioners. Many consumers of TCM believe that theparts of wild animals are more powerful and have astronger desired effect than the parts of captive or farmed
animals, and as such any opening of or increase in tradefrom captive or farmed Tigers will further threaten wild
populations. Along with bone, Tiger skins, claws andteeth are used for clothing, charms, and decorations. Meatfor dishes and penis for aphrodisiac can also be found invarious domestic and international markets (Nowell,2000; Nowell, 2007).
Despite efforts to combat trade in Tiger parts, demand
for Tiger bone in Asia remains strong. For example,
Nowell (2007) listed Tiger range States with substantial
domestic markets in recent years as including China(skins, Tiger bone wine); Indonesia (bones, skins, claws
and teeth); Malaysia (Tiger meat and manufactured
Tiger bone medicines); Myanmar (skins); and Viet Nam(Tiger bone gel). Although commercial poachingpressure continues to exist at varying levels in all range
States, the presence of substantial commercial poachingin recent years in India, Indonesia, and Myanmar, inparticular.

2 For purposes of this report, TRAFFIC hereafter uses the common term “Traditional Chinese Medicine” (TCM) to refer to these practices, although we recognize thatdifferent Asian countries have their own specific variants and traditions.

8Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

China, which holds the largest market share of the global
illegal trade in Tigers, instituted a domestic Tiger trade
ban in 1993; this action has been successful in reducing
demand. The Chinese government has also implemented
many successful enforcement and public education
efforts, and, since 1999, China has seized more Tiger
products than any other Tiger range state (Nowell andXu, 2007). China is to be commended for its enforcement
efforts and its efforts to reduce demand. Much work,
however, remains to be done.
For example, the demand has not been completely
eradicated. Of particular concern is that, although
response to a CITES recommendation to prevent illegal
trade from farmed sources has been good in most range
States, China’s response to the issue has been inadequate,
if not poor. While China has not allowed any commercial
exports in Tiger parts derived from such farms,
government management has to date failed to prevent
illegal trade. There is, for example, disturbing evidence
that Chinese Tiger farms are selling both Tiger bone wine
and Tiger meat (Nowell, 2007).
Demand and markets for Tiger-based medicinals are not
only found in China, but also elsewhere in Asia, as wellas in Europe and North America. Medicines claiming tocontain Tiger bone were found in a 2003 market survey
in San Francisco and New York City. While theavailability of and demand for these medicines in the
United States has significantly decreased over the past
decade, thanks to concerted outreach and enforcement
efforts, it is clear that some demand still exists (Henry,
2004). As with any demand for an illicit product,
vigorous education and enforcement must continue toprevent an escalation.
Additionally, in recent years, a resurgence in the Tiger
skin trade emerged as another key trade threat to wild
Tigers, as Tiger skins for traditional Tibetan clothing
became fashionable amongst increasingly affluent
Chinese populations in traditionally Tibetan areas. About
3% of Tibetans surveyed by TRAFFIC in major towns inthese areas claimed to own chubas, or traditional robes,
made with Tiger or Leopard skin, despite the fact thatmost are aware of its illegality (Nowell and Xu, 2007).
China, along with numerous conservation organizations,publicized the illegality of this practice and its impact onwild Tigers in 2005. Since that time, surveys show thatsales and use of traditional Tiger skin clothing has
decreased, though it is clear that some demand still exists(Nowell and Xu, 2007).
Persistent demand for Tiger parts or derivatives isapparent not only in markets, but is also evidenced by theongoing poaching of wild Tigers. For example, in June
2006, Thai police confiscated illegal wildlife parts,
including the remains of six Tigers, during an inspection

TRAFFIC North Americaof air cargo at Bangkok’s Don Muang Airport. The cargo
had been transported from near Thailand’s border with
Malaysia to Bangkok in the cargo section of a Thai
Airways flight. In January 2007, Russian law
enforcement officials seized three Siberian Tiger skins,eight Tiger paws and 332 Tiger bones, among otheritems, near the Russian border with China. Police
intercepted the contraband when they stopped a car that
had its passenger seats removed and was stuffed full ofbags, which the driver claimed contained potatoes. Most
surprisingly, in 2005, staff at India’s Sariska Tiger
Reserve discovered that its entire population of Tigers
had vanished due to poaching. It is clear that despite
decades of good faith efforts by range States, consumer
States, and the conservation community, demand for
Tigers and their parts remains a threat to their continued
existence in the wild (Dinerstein et al., 2006; Nowell andXu, 2007).

International trade controls
Given the international, and indeed global, scope of the
trade in Tiger parts, preventing this threat from further
decimating remnant wild Tiger populations requires acooperative, multilateral effort. Global trade in wildlife
and wildlife products is regulated by the Convention on
International Trade in Endangered Species of Wild Fauna
and Flora (CITES). CITES, which entered into force in
1975, established a worldwide system of controls oninternational trade in threatened and endangered wildlife
and wildlife products. As of February 2008, 172
signatory countries (known as “Parties”) had acceded to
the Convention (CITES, 2007b).
Some 5,000 species of animals and 28,000 species ofplants are covered by CITES. Protection for species isprovided through three CITES Appendices, which
describe the status of the species and determine which
may enter international commercial trade. The mostthreatened and endangered species are listed in Appendix
I, which includes species threatened with extinction thatare or may be affected by trade. Appendix II species arethose that are not threatened at present but could become
so if trade is not regulated. Appendix III species are
subject to regulation within the listing nation for the
purposes of preventing or restricting exploitation, and, as
requested, promoting the cooperation of other parties in
the control of trade (CITES, 2007c).
Tigers were listed in CITES Appendix I in 1975, with the
exception of the Siberian Tiger, which was listed inAppendix II. In 1987, the Siberian Tiger was transferredto Appendix I, and all Tigers have since been listed inAppendix I. According to the Convention, commercial
trade is not permitted for Appendix I species, and othertrade for purposes such as scientific research or breeding9

is strictly controlled. Any such trade requires the grantingof permits from both the importing and exporting
country, and these permits are only granted when certain
criteria are met, including a determination that theimport/export will not be detrimental to the survival of
the species and that the animal or specimen was not
obtained illegally (CITES, 2007d).
In addition to the Appendix I listing, CITES has also
addressed Tiger trade and conservation through a seriesof Resolutions. In 1994, CITES Parties adopted
Resolution Conf. 9.13, which directed Parties toimplement certain Tiger conservation measures. The
Resolution urged Parties to prohibit domestic trade andsale of Tigers and Tiger parts and derivatives, andrecommended bilateral and multilateral cooperation on
enforcement and information sharing, ensuring securityof stocks of Tiger parts and derivatives, development ofawareness campaigns in Tiger range and consumer States,
and work with the traditional medicine community toeliminate the use of Tiger derivatives (CITES, 1994).
Although CITES has no force of law over domestic
policy, the strength of the Resolution lay in the fact that it
was adopted by consensus of the Parties.
This Resolution was then revised and strengthened at the10th Meeting of the Conference of the Parties (CoP) in
1997, and was subsequently superseded by Resolution
Conf. 11.5 in 2000 and by Resolution Conf. 12.5 in 2002,
which broadened the scope of the recommendations for
Tiger conservation to include other species of Asian big
cats listed in CITES Appendix I (CITES, 2002).
Implementation of CITES Resolutions and Decisions in
Tiger range States remains incomplete, as range States
have not always reported on their implementation andenforcement efforts. For example, only six of fourteen
Asian big cat range States had submitted their reports atthe time the CITES Secretariat drafted its document on
Asian big cats for the 14th Meeting of the Conference of
the Parties to CITES (CoP14), and only four of these—
Malaysia, Myanmar, Thailand and Viet Nam—are Tiger
range States. Several range States, though, have achieved
success in combating poaching and illegal trade. In the
Russian Federation, for example, which operates
Inspection Tiger Brigades in the Russian Far East, Tiger
populations have stabilized, according to a Wildlife
Conservation Society–led 2005 Winter survey of Amur
Tigers. However, the CITES Secretariat noted in CoP14
Doc. 52 that it believes that two important range States—
China and India—remain a concern. China suffers fromsignificant levels of illicit trade in Asian big cats,
particularly in traditionally Tibetan regions, and India
lacks coordination in wildlife law enforcement efforts(CITES, 2007e). The Secretariat noted that:10“Saying that proper implementation of the Convention
is essentially what is required may be somewhat
simplistic but it is also accurate. Experience showsthat political will to provide the resources needed,
combined with law enforcement priority in range andconsumer States, is effective” (CITES, 2007e).
At CITES CoP14 in June 2007, India, Nepal, the RussianFederation, and China introduced a draft Decision which
addressed trade in Asian big cats, including strengthening
efforts to implement CITES Resolution Conf. 12.5. The
draft did not, though, adequately address the threat posed
to wild Tigers by Tiger farms and any possibility of legal
domestic trade in their parts and derivatives—apossibility that had been tabled by China in various
forums. Therefore, the U.S. delegation and others
intervened and offered amendments that significantly
strengthened the Decision. Several range States—inparticular India, Nepal, and Bhutan—also spoke of thesignificant threat posed by Tiger farms in other countries,
and the threat of any commercialization from those
farms. Two elements of the Decisions adopted areespecially critical:
Decision 14.66 All Parties, especially those evaluating
their domestic Tiger trade control
policies, shall take into consideration theview of the Parties as expressed in
Resolution Conf. 12.5.
Decision 14.69 Parties with intensive operations
breeding Tigers on a commercial scale
shall implement measures to restrict thecaptive population to a level supportive
only to conserving wild Tigers; Tigers
should not be bred for trade in their partsand derivatives (CITES, 2007f).
Although CITES cannot regulate the domestic laws of
any Party to the Convention, it can suggest such actions
and measures. The strength behind this particular
Decision is that it was adopted by consensus of theParties, and therefore provides a clear directive.
Because implementation of CITES obligations rests withthe domestic legislation of individual Parties, theConvention can be effective only if signatory nations
enact laws, policies, and regulations to enforce its
provisions. As the focus of this report is the UnitedStates’ role in the global trade in Tiger parts, the next
section examines the U.S. legal framework governinginternational wildlife trade, and also domestic laws that
affect Tigers specifically.

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

LAWS AND REGULATIONS GOVERNING TIGER TRADE
AND CAPTIVE TIGERS IN THE U.S.
Several U.S. federal laws govern the import, export, anddomestic sale, trade, and transportation of Tigers and Tiger
parts. At the federal level, the U.S. legal framework
governing international trade in Tigers and Tiger parts isstrong. Federal law explicitly bans the domestic sale of any
parts or derivatives from Tigers, or items advertised as
containing Tiger products. There are also federal laws andregulations that govern the keeping, care, breeding, andinterstate trade or transfer of live Tigers: however,exceptions or exemptions to these laws and regulations
create troubling loopholes that could have implications forillegal trade.
Many, although not all, individual states also have laws
governing captive Tiger populations. However, at thestate level, the U.S. legal framework can be described as
decentralized and somewhat haphazard. This section
describes U.S. federal and state laws and regulations
governing trade in Tigers and issues regarding theircaptivity.

U.S. Federal Laws and Regulations
Key laws and regulations at the federal level include theEndangered Species Act (ESA), the Lacey Act, theRhinoceros and Tiger Conservation Act (RTCA), theCaptive Wildlife Safety Act (CWSA), the Animal Welfare
Act (AWA), USFWS regulations governing captive-bred
wildlife, and parts of the Criminal Code. The specific ways
in which these laws or regulations relate to the international
trade and domestic keeping of Tigers are as follows.
The Endangered Species Act (ESA)
Enacted in 1973, the ESA established the legal basis for
the U.S. to protect and conserve species in danger ofextinction, and the ecosystems upon which such species
depend. Under the ESA, species may be listed as either
endangered or threatened. According to the law,endangered species are those that are in danger ofextinction throughout all or a portion of their range.
Threatened species are defined as those that are likely to
become endangered within the foreseeable future if
measures are not taken to ensure their conservation(USFWS, 2002).
Tigers have been listed as Endangered under the ESA
since the Act’s inception, signifying that they are “indanger of extinction throughout all or a significant
portion of [their] range,” and cannot be traded
commercially either internationally or interstate (50 CFR
17.11 and 17.12). In fact, even prior to passage of the
ESA, all Tigers were added to the “U.S. List of

TRAFFIC North America

Endangered Foreign Fish and Wildlife” in 1972,amending an earlier version of that list that had included
only the Bali, Javan, and Caspian subspecies (Federal
Register, 1972; Federal Register, 1970).
The ESA also serves as the U.S. domestic enabling
legislation for implementation of CITES, and the law
makes it unlawful to engage in trade contrary to CITES,
or to possess any specimen that was “traded contrary to
the provisions of the Convention” (50 CFR 17.11 and17.12). USFWS is the principal federal agency charged
with implementing and enforcing the ESA and U.S.
CITES obligations. USFWS agents and inspectors are
responsible for U.S. efforts to combat illegal trade andcontrol international movement of Tigers and their partsand products (USFWS, 2006).
The Lacey Act
Originally enacted in 1900, the Lacey Act prohibits theimport, export, transport, acquisition, receipt, sale, orpurchase in interstate or foreign commerce of any fish or
wildlife taken, possessed, transported, or sold in violationof any wildlife law or regulation of any state, or in
violation of any foreign wildlife law. It also prohibits theimport, export, transport, sale, receipt, acquisition orpurchase of fish, wildlife, or plants taken, possessed, orsold in violation of any wildlife law, treaty, or regulationof the United States, or in violation of any Indian tribal
law. Further, the Act prohibits attempts to commit any ofthese acts (Hoover and Tarr, 1997).
Particularly relevant to current efforts to halt illegal tradein Tiger parts, another provision of the Lacey Act
prohibits the actual or attempted falsification of
information, records, or accounts regarding species thathave been imported, exported, transported, sold,purchased, or received in interstate or foreign commerce.
The Act makes it illegal to import, export, or transport ininterstate commerce any container or package containing
fish or wildlife unless it has “previously been plainly
marked, labeled, or tagged” in accordance with USFWS
marking regulations, and authorizes USFWS to detain
any package or container (and accompanying papers)
being imported into or exported from the United States(Hoover and Tarr, 1997). As will be described further
below in the section on international trade, this provision
is particularly important because the vast majority ofTiger derivatives currently being seized by USFWS are
shipments of medicinal products containing, or labeled as
containing, Tiger bone being illegally imported into theUnited States.

11

The Rhinoceros and Tiger Conservation Act (RTCA)
In 1994 the U.S. Congress enacted the RTCA, which
established the Rhinoceros and Tiger Conservation Fundto support conservation of wild Rhinoceros and Tiger
populations through anti-poaching assistance programs,
habitat and ecosystem management, public awarenesscampaigns, and other programs and efforts. Because the
ESA and the Lacey Act apply only to international tradeand interstate commerce, there remained a possibleloophole regarding intrastate trade in parts from these
species. Therefore, in 1998 Congress amended the RTCA
through the Rhino and Tiger Product Labeling Act, which
prohibits the import, export and, most importantly, sale ofany product for human consumption or application
containing, or labeled or advertised to contain, any
substance derived from any species or subspecies of Tiger
or Rhinoceros (USFWS, 2007a; USFWS, 2007b).
Combined with the provisions of the ESA and the Lacey
Act, the RTCA as amended closed any remaining
loopholes regarding the legality of selling Tiger parts or
products in the United States.
The Animal Welfare Act (AWA)Through the AWA, which Congress last amended in
2002, the USDA has legal jurisdiction to protect warmblooded animals used in research, bred for commercial
sale, exhibited to the public, or commercially transported.
The law requires that minimum standards of animal carebe established and enforced. Authority to develop andenforce regulations, issue licenses, and conduct
inspections and investigations falls under the jurisdictionof the Animal Care program of the USDA’s Animal and
Plant Health Inspection Service (APHIS) (APHIS, 2003;
APHIS, 2005).
Under the AWA and USDA/APHIS regulations, anyone
importing, buying, selling, or trading (interstate) animals
foreign to the United States (wild or domestic) must be
licensed. Licenses are also required to sell domesticallybred exotic animals. Anyone using Tigers in animal
performances (circuses, etc.), zoos, carnivals, wildlife
parks, promotional exhibits, and some sanctuaries mustbe licensed. For licensed animals, federal standards
include periodic inspections covering issues of humane
handling and care (housing, space, feeding and watering,adequate veterinary care, transportation, etc.). Licensed
exhibitors must maintain on their premises accurate
records of covered animals that come into theirpossession and of the veterinary care the animals receive;such information must be made available to APHIS
during inspection (APHIS, 2003; APHIS, 2007a).
There are exemptions. Animal preserves or sanctuaries thatmaintain exotic or wild animals are exempt from regulation,for example, provided that they do not exhibit or use the12animals for promotional purposes. A private facility that
conducts donor tours or uses the animals for fundraising,
however, must obtain a license (USFWS, 2003).
The Captive Wildlife Safety Act (CWSA)In 2003, Congress enacted the CWSA to provide certain
cat species, including Tigers, in the United States withanother layer of protection; enforcement of the law went
into effect in September 2007 (USFWS, 2007c). The
purpose of the law is to further the conservation ofcertain species and to protect the public from dangerous
animals. The CWSA makes it illegal to “import, export,
buy, sell, transport, receive, or acquire, in interstate or
foreign commerce, live lions, Tigers, Leopards, Snow
Leopards, Clouded Leopards, Cheetahs, Jaguars, orCougars, or any hybrid combination of any of these
species, unless certain exceptions are met.” It is
important to note that there are no pre-Act exemptions
under the law, so that regulated species acquired prior to
the law taking effect will still be subject to theprohibitions of the CWSA (USFWS, 2007c; Federal
Register, 2006; Federal Register, 2007).
It should also be noted that the law’s regulation ofinterstate and foreign transportation applies to alltransportation, not just that involving commercial
activities. Anyone owning a Tiger, for example, isprohibited from transporting it across state lines unlessthey meet exemptions mandated under the law. Such
exemptions apply to:• Persons, facilities, or other entities licensed by
APHIS under the AWA to possess big cats (typicallyzoos, circuses, and those who conduct research withwild animals);• State colleges and universities;• State agencies;• State-licensed wildlife rehabilitators;• State-licensed veterinarians; and,• Wildlife sanctuaries that meet specific criteria (which
are detailed later in this report) (USFWS, 2007c).
The law also does not, and cannot, regulate intrastate
trade and transportation in these species, which is left tothe jurisdiction of the states (Federal Register, 2007).
USFWS Captive-Bred Wildlife Registration
To decrease federal permit requirements for captive-born
exotic, endangered, and threatened wildlife, USFWS has
further implemented a captive-bred wildlife (CBW)
registration and permit system. Under the system,otherwise prohibited activities can occur when theactivities can be shown to enhance propagation or survivalof the affected species, provided the principal purpose isPaper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

Eligible wildlife arelimited to those listed as
endangered or threatened
under the ESA; includes
only living specimens;
pertains only to species
exotic to the UnitedStates3, and involves only
animals bred in captivity
within the country.
Without a CBW wildlife
registration, it is unlawful
for a person to commit,
attempt to commit, solicit
another to commit, or
cause to be committed anyof the following activities:

PHOTO COURTESY DOUG WILLIAMSON

to facilitate captive
breeding (USFWS, 2003;
50 CFR Part 17.3).

Captive Tigers in a wildlife “sanctuary” in central Florida. These cats are “white” Tigers, bred primarily for
exhibition or animal show purposes.

• Take within the UnitedStates and its territorial
seas or upon the high seas4;• Delivery, receipt, carrying, transporting or shipment ininterstate or foreign commerce in the course of acommercial activity;• Sale or offer for sale in interstate or foreign commerce;• Import or export; or,• Possession, shipment, delivery, carrying, transportation,
sale or receipt of unlawfully taken wildlife (USFWS,
2003; 50 CFR Part 17.3).
Registration under the CBW system authorizes take andinterstate commerce, provided that the purpose of suchactivities is to enhance the propagation or survival of theaffected species. This is because, under USFWS
regulations, the definition of take (i.e., harassment) of
captive wildlife does not include generally accepted
animal husbandry practices that meet AWA standards forfacilities and care; breeding procedures; and provisions ofveterinary care for confining, tranquilizing, or
anesthetizing, when such activities will not likely resultin injury to the wildlife. Interstate commerce pertains to
the purchase and sale of affected species among CBWregistrants who are not residents of the same state andwho are registered for the species involved. If either thebuyer or the seller lacks such registration, the buyer mustobtain an endangered or threatened species interstate
commerce permit prior to the sale. Further, registration

may not be issued or used to sell protected species as pets
or for hybridization of any listed species; neither are
registrations issued for conservation education only
(USFWS, 2003; 50 CFR Part 17.3).
There is a further exception that pertains specifically tocaptive Tigers in the United States. In 1998, USFWS
issued a Final Rule amending the definition of “harass” in
50 CFR 17.3. The rule:“…deletes the requirement to obtain a CBWregistration for eight species of pheasants, parakeets ofthe species Neophema splendida and N. pulchella, theLaysan duck, and the ‘generic’ or inter-subspecificcrossed Tiger” (Federal Register, 1998).
In practical terms, the exception has two major implications
regarding the issues covered in this report. First, as is
discussed in more detail later, most Tigers kept in the
United States are believed to be hybrids. According to the
USFWS, there are currently 14 CBW permits for Tigers
with a known breeding pedigree at the subspecies level, andanother 66 CBW permits issued to facilities (mostly AZA
facilities) that have CBW registrations for Tiger subspecies(M. Carpenter, USFWS Division of Management Authority,
pers. comm. to D. Williamson, January 2008). If the UnitedStates is currently home to some 5,000 captive Tigers, itwould appear that only a small fraction of that number do
not fall under the exception.

3 USFWS may determine, on a species-by species basis, that particular species native to the United States are eligible. At present, only the Laysan duck Anas laysanensis
has been granted eligibility under the registration.
4 Take is defined as to harm, harass, pursue, hunt, shoot, wound, kill, trap, capture or collect, or attempt to engage in any such conduct.

TRAFFIC North America

13Second and related, reporting requirements differ for
CBW-registered Tigers and those exempted. Specifically,
holders of CBW-registered species must submit to
USFWS an annual report including activities conductedwith registered species and a year-end inventory of all
such species for the previous year. Persons claiming thebenefit of the exception, however, must only maintainaccurate written records of activities, including births,
deaths and transfers of specimens, and make those records
accessible to Service agents for inspection; there is noreporting requirement (50 CFR Part 17.3; USFWS, 2008).
The Criminal CodeIn addition to these laws relating specifically to wildlife,
other ancillary federal laws can also apply to Tigers intrade or captivity. For example, federal prosecutors
routinely use several provisions of the Criminal Code
(Title 18, US Code) to prosecute CITES violations. The
provisions of Title 18 most often used, in addition topenalties for violations of the wildlife laws themselves,
include “Document Smuggling”, which makes it illegal toimport or otherwise enter into the United States by meansof false or fraudulent declarations, or false oral or written
statements. A provision against “Clandestine Smuggling”
makes it illegal to knowingly and willfully import or
clandestinely introduce into the United States any
merchandise contrary to law. It is also illegal to buy, sell,receive, conceal, or facilitate the transportation ofmerchandise that has illegally entered the country(Hoover and Tarr, 1997).

Recent Tiger and Other Big Cat Incidents in the United States
State and other regulatory authorities charged withoverseeing U.S. captive Tigers and other big cats havegood grounds for concern about their threat to humanhealth and safety. Information provided to TRAFFIC
by the Animal Protection Institute (API) showed thatduring the period from 1990 to 2006, there were 157
documented incidents of escapes, attacks, sightings, orother events involving captive big cats, spread amongat least 34 U.S. states. Not surprisingly, states that haveno laws on the subject, have enacted laws only
recently, or have laws that are permissive towards
private possession of big cats accounted for most ofthese incidents. These include Texas (21 incidents),
Florida (16), Ohio (14), Washington (9), and North
Carolina (8). Together these five states accounted for
67 (43%) of total incidents.
Of these incidents, 41 (26%) were specific to Tigers or
Tiger hybrids. Some may appear innocent, or evencomical. For example, in 2002 two Tiger cubs in Las
Vegas, Nevada were found loose on the roof of aneighbor’s house, and subsequently recaptured. In a2005 incident in Arkansas, a man released his “pet”
Tiger—presumably unwanted—60 miles from his
home. The Tiger found its way back. The owner thendelivered it to a wildlife sanctuary.
Unfortunately, in the majority of cases, there is nothing
innocent or funny about the results of such encounters
between captive Tigers and people. From 1990 to 2006,
U.S. captive Tigers attacked at least 27 people,
resulting in seven documented deaths and 20 cases ofsevere injury. Three of those killed were adults,
including two people—a trainer and an owner—killedby the same Tiger in separate instances in 1998. The
other four people killed were children: ages three, four,
10, and 13. In all four cases, the children died from14

injuries inflicted by Tigers kept by adult relatives.
Other children suffered severe injuries under similar
circumstances. For example, in 2005, a “pet” Tiger andlion attacked a 10-year old boy in Minnesota, who
suffered brain injury and a severed spinal chord
resulting in quadriplegia and dependence on a
respirator.
The Tigers involved fare no better; many cases result in
the animals being killed by law enforcement or private
individuals. For example, in 2004 a six-year old Tiger
belonging to an actor who had played Tarzan escapedfrom its enclosure after jumping a 12-foot fence thatsurrounded the property where it was being kept. The
animal was later located and killed. In that same year
in North Carolina, a 14-year old girl was mauled by
one of her father’s four pet Tigers after entering one of
the cages to take pictures; after the incident, all four
Tigers were killed. Another Tiger was killed after
escaping from a trailer at a truck stop in Illinois while
its owner was trying to give it water. These stories havedepressing similarities: a Tiger either escapes or gets
access to a person, resulting in death or serious injury
to the person and the subsequent killing of the Tiger.
Even Tigers in highly secure facilities can be
dangerous. In a well-documented case on Christmas
Day 2007, a Tiger at the San Francisco Zoo escapedfrom its enclosure, killing one man and injuring twoothers before it was killed by police.
These statistics and cases are not cited to be maudlin,
but rather to point out that there is good reason for U.S.
states to maintain tight regulatory control over captive
Tigers and other big cats. With a large, predatory
species such as the Tiger, there is zero margin for error.
Source: API 2007a

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

Another provision of the Criminal Code covers “False
Statements”, making it illegal to knowingly and willfully
falsify a material fact, or make a false or fraudulent
statement or entry. This provision is often filed inconjunction with document smuggling charges. Finally,
those caught violating wildlife laws can be charged with“Conspiracy”, which occurs when two or more persons
conspire to commit any offense against the United States,or to defraud the United States, and one of theconspirators commits any act to implement theconspiracy (Hoover and Tarr, 1997).

U.S. state laws
While this panoply of federal laws and regulations
controls the international and interstate trade in Tigers,
and bans domestic sale of Tiger parts and products, state
governments have the lead in regulating the possession
and use of live Tigers inside their jurisdictions. At thestate level, laws and regulations generally focus issues ofhuman safety and welfare, as well as animal welfare,related to the keeping of live Tigers in captivity, rather
than on trade-related issues. The picture is complex;
individual state laws differ significantly on whether
keeping Tigers is allowed, under what licensing or
permitting requirements, and by whom.
According to information provided by the Animal
Protection Institute (API), as of 2005, 39 U.S. states hadlaws governing the “private” possession of big cats andother exotic animals and 11 (Alabama, Idaho, Iowa,
Louisiana, Nevada, North Carolina, Ohio, South Carolina,
Washington, West Virginia, and Wisconsin) did not (API,2007b). In 2007, Washington State and Louisiana enacted
laws banning future private possession of Tigers andother dangerous species (API, 2007b; TRAFFIC review
of state laws and regulations, 2007). More specifically to
Tigers alone, Table 2 shows states that do or do not allow
the keeping of Tigers in private collections, and underwhat permitting requirements. As the table shows, 26
states now have laws banning the possession of Tigers inprivate collections. Sixteen states allow for the keeping ofTigers by individuals, but require a state permit orregistration. Nine states (Alabama, Idaho, Iowa, Nevada,North Carolina, Ohio, South Carolina, West Virginia, andWisconsin) allow for the keeping of Tigers with no statepermitting restrictions (API, 2007b; TRAFFIC review ofstate laws and regulations, 2007).
Furthermore, although at least half of U.S. states ban the
keeping of Tigers in private collections as pets, virtually
all state codes and regulations have exemptions that allow
for the keeping of Tigers by other private (i.e.
nongovernmental) individuals or entities under someconditions. These can include breeders, dealers, AZA
facilities, roadside zoos, other exhibitors, circuses, rescue

TRAFFIC North America

Table 2. U.S. states that allow/banpossession of Tigers as pets
State
Alabama
AlaskaArizona
Arkansas
California
Colorado
Connecticut
Delaware
FloridaGeorgia
Hawaii
Idaho
Illinois
Indiana
Iowa
KansasKentuckyLouisiana
Maine
Maryland
Massachusetts
MichiganMinnesota
Mississippi
MissouriMontana
Nebraska
NevadaNew Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
OregonPennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming

Tigers Allowed
as “Pets”?

License, Permit, orRegistration Required?

Yes
No
No
No
No
No
Yes
Yes
No
No
No
Yes
No
Yes
Yes
No
No
Yes
Yes
No
No
No
No
Yes
Yes
Yes
No
Yes
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
No
No
No
Yes
Yes
No

No
n/a
n/a
n/a
n/a
n/a
Yes
Yes
n/a
n/a
n/a
No
n/a
Yes
No
n/a
n/a
Yes
Yes
n/a
n/a
n/a
n/a
Yes
Yes
Yes
n/a
No
n/a
n/a
n/a
n/a
No
Yes
No
Yes
Yes
Yes
Yes
No
Yes
n/a
Yes
n/a
n/a
n/a
Yes
No
No
n/a

Source: API 2007b; TRAFFIC Review of State Laws and Regulations 2007.

15

centers or sanctuaries, and educational, scientific andresearch facilities, among others (API, 2007b; TRAFFIC
review of state laws and regulations, 2007). As noted
above, in some circumstances the facilities in which these
Tigers are kept normally fall under the jurisdiction of the
USDA or the USFWS, as well as state laws. The stateswith the tightest restrictions are Alaska, which allows
only temporary commercial use, education, and research,and New Mexico, which allows for only temporary
exhibition. Most states have far broader exceptions. To
provide one example, Arkansas, which specificallyprohibits the keeping of Tigers and lions as pets, exempts
AZA facilities, nonprofit humane societies, animal
control and law enforcement agencies, veterinary
hospitals and clinics, USDA exhibitors, employees of the
Arkansas Game and Fish Commission (AGFC), persons
holding scientific collection permits, and holders of
AGFC breeder/dealer permits (API, 2007b; TRAFFIC
review of state laws and regulations, 2007).
Further fragmenting the U.S. legal system regulating
captive Tigers is the limited consistency at the state level
regarding which agencies oversee these animals. Of thestates that either prohibit or regulate possession of exotic
wildlife, 26 designate wildlife or natural resource
departments as the lead regulatory agency, sevendesignate agricultural agencies or boards, and the rest
designate local animal control authorities or local law
enforcement (API, 2007c). In yet another level ofdecentralization, in states that allow the private
possession of Tigers, counties, cities, townships, andother municipalities may have their own local ordinanceson the subject. There has never been a comprehensive
study of all of the local ordinances governing the keepingof captive Tigers. Given the number of such jurisdictionsin the United States, compiling such information would
be daunting (API, 2007d).

At the state level, the fact that some states do not regulate
the possession of Tigers in private hands also makes it
impossible to determine exactly how many Tigers there
may be in the United States. State laws and regulations
were not generally written with the Tiger parts trade inmind. These statutes tend to focus on issues such as
mitigating the potential extreme danger that Tigers inprivate hands can pose to human beings by ensuring that
captive Tigers are housed in facilities in which they are
secure, and also that the animals are handled
professionally and humanely.
At both the federal and state levels, a key issue regarding
the implications for illegal trade—the disposal of Tiger
bones and other parts when captive Tigers die—goesbasically unaddressed. As the following sections describe,
under this legal structure large gaps in knowledge remain
regarding how many Tigers there are, how many arebeing bred each year and where, what purposes they arebeing used for, and, critically, what happens to theseanimals and their component parts (skins, bones, etc.)
when they die.

Implications for the Tiger trade
As becomes clear below, this fragmented legal framework
and bifurcation of responsibility between the federal andstate governments in the United States for regulating
captive Tigers has potential implications for theinternational Tiger trade. For example, at the federal
level, regulations and exceptions/exemptions incorporated
into the AWA and the USFWS registration system for
captive-bred wildlife mean that not all facilities are
required to provide a regular inventory of Tigers held.
While these laws are strong regarding international andinterstate trade, the fact that many facilities holding
Tigers have to simply keep records of such cats, rather
than provide regular reports of Tiger inventories, meansthat the federal agencies tasked with regulating theseanimals do not know how many Tigers actually exist in
the country or, outside of inspections, where they are.

16

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

THE U.S. CAPTIVE TIGER POPULATIONWith that legal framework as a background, TRAFFIC
found that it is realistically impossible to pinpoint theexact population of captive Tigers in the United States,
although estimates have been made. For example, Werner(2005) estimated that as of 2005, the U.S. Tiger
population was made up of approximately 4,692 Tigers.
Given the fragmented legal and regulatory framework
governing U.S. captive Tigers, and the number of statesthat do not regulate their captive Tiger populations, theexact size of the population remains unknown. As Table 2
showed, in some states captive Tigers may be kept byprivate individuals without any licenses or records. Aslong as the owners of these Tigers do not engage inactivities that would prompt the need for USDA licensing
or annual reporting under the USFWS CBW registration
system, they are very difficult to locate.
There are also some Tigers that likely exist “off-thegrid”. For example, in 2003 a man was found to be
keeping a captive Tiger and a caiman in an apartment in
the Bronx, New York, even though the State of New Yorkand New York City both have laws specificallyforbidding possession of Tigers by private individuals.
The Tiger was found only when it attacked its owner.
Anecdotally, TRAFFIC also learned during field visits in
the State of Virginia that zoos get periodic phone callsfrom owners of Tigers wanting to give up their cats, eventhough possession of private Tigers is illegal in that state
as well. It is unknown how many other such Tigers may
be in private hands unaccounted for in states that ban
their possession.
This section discusses what is known about various
captive Tiger populations in the United States, thelegality and conditions for breeding and keeping them,and what is known about the disposition of Tigers andtheir parts when they die.

U.S. Tiger populations
Werner (2005) divided the U.S. captive Tiger population
into four categories: Tigers kept in zoos accredited by the
AZA, Tigers in animal sanctuaries, Tigers held by USDA
permit holders, and Tigers in private collections.
However, as that paper noted and TRAFFIC’s 2007
research further revealed, there is the potential forsignificant overlap between some of these categories.
Tigers in AZA facilities
There are 214 “accredited” AZA facilities worldwide,
including 206 in the United States. There are also 18
AZA-Certified Related Facilities, all in the United States(AZA, 2007a; AZA, 2007b). AZA accreditation means

TRAFFIC North America

official recognition and approval of a zoo or aquarium bya group of experts—the AZA Accreditation
Commission—that evaluates every candidate facility tomake sure that it meets AZA’s standards for animal
management and care, including living environments,social groupings, health, and nutrition. The Commission
also evaluates the veterinary program, involvement inconservation and research, education programs, safety
policies and procedures, physical facilities, guest
services, and the quality of the institution’s staff (AZA,
2007c). As public exhibitors of Tigers and other exotic
wildlife, all AZA facilities are also required to holdpermits by the USDA, and are therefore subject toinspection under the AWA (APHIS, 2007a).
The AZA population of Tigers is the only one in the
United States for which there is a reasonably exact
population count, given births and mortality. Werner(2005) estimated the population at 264. More recent
information provided to TRAFFIC by the AZA showedapproximately 350 Tigers as of January 2008 (S. Olsen,
AZA, pers. comm. to L. Henry, January 2008). There isno evidence that any AZA Tigers have entered illegal
trade. However, as is discussed below, it remains uncertain
exactly what happens to AZA Tigers when they die.
Tigers held in “sanctuaries”
A second population of captive Tigers in the United States
resides in Animal “Sanctuaries” or “Refuges.” Werner(2005) estimated this population at approximately 1,179
Tigers, or about 25% of the total estimate for that year.
However, TRAFFIC’s 2007 analysis shows that thesenumbers change if conflicting definitions of what
constitutes a sanctuary or refuge are taken into account. The
2005 study used a definition under which a given facility(sanctuary, refuge, zoo, USDA permit holder, etc.) was
included based upon “primary operational mode”. In otherwords, under those parameters there could be secondary
uses (e.g., breeding, exhibition, dealing, etc.) for Tigers insanctuary or refuge facilities as long as those were notdeemed to be the primary mission of the facility.
Others use a much stricter version of what constitutes a
Tiger sanctuary or refuge facility. Non-profit
organizations that accredit facilities have in recent years
developed their own criteria. Facilities applying tobecome accredited by the American Sanctuary
Association (ASA), for example, must have precluded
any secondary uses or purposes for Tigers in captivity.
Some of the criteria involved for membership haveincluded a ban on breeding, a ban on any use of theanimals in commercial activities, lifetime responsibility
for the animals, that the welfare of the animals is always

17

primary, and that member sanctuaries maintain all
required licenses and permits in good standing, as well as
their federal 501(c)(3) not-for-profit status (ASA, 2007).
In 2007, USFWS developed its own definition of an
accredited wildlife sanctuary as part of the final rules
implementing and enforcing the Captive Wildlife Safety
Act, which is largely consistent with the standards listed
above:“Accredited Wildlife Sanctuary means a facility thatcares for live specimens of one or more of theprohibited wildlife species and:1. Is approved by the United States Internal Revenue
Service as a corporation that is exempt fromtaxation under Sec. 501(a) of the Internal Revenue
Code of 1986, which is described in Sec. 501 (c)(3)and 170 (b)(1)9A0(vi) of that code;
2. Does not commercially trade in prohibited wildlife
species, including offspring, parts, and products;
3. Does not propagate any of the prohibited wildlife
species; and4. Does not allow any direct contact between the
public and the prohibited wildlife species.
Direct contact means any situation in which any
individual other than authorized keeper or care giver
may potentially touch or otherwise come into physicalcontact with any live specimen of the prohibitedwildlife species” (Federal Register, 2006; Federal
Register, 2007; USFWS, 2007c).
Applying this revised definition, the number of facilities
that could be considered true sanctuaries holding Tigers
in the United States may be quite limited. Unfortunately,organizations such as the ASA have not required
accredited facilities to provide an inventory of exactly
how many Tigers are in their care; therefore it is
impossible to accurately estimate how many Tigers would
fall under this definition of “sanctuaries” or “refuges” (C.
Baskin, Big Cat Rescue, pers. comm. to D. Williamson,
December 2007; L. Stoner, Peace River Refuge, pers.
comm. to D. Williamson, December 2007).
As the Florida case study below demonstrates, there arean undetermined number of other facilities in the UnitedStates that claim to be sanctuaries or refuges, but these
may be involved in breeding, dealing, or othercommercial activities. Furthermore, as the next section
on trade in U.S. domestic Tigers shows, some of themost significant domestic cases of illegal trade of Tiger
parts have involved Tigers “donated” from purported
animal sanctuaries.

USDA permit holders
Captive Tigers residing within facilities licensed by the
USDA and managed and inspected under department
regulations and the AWA likely constitute the largest
percentage of Tigers in the United States. Werner (2005)
estimated that this population accounted for 2,120 captive
Tigers, or approximately 45% of the total in that year.
Again, however, there may be some overlap with other
U.S. captive Tiger populations. For example, under theAWA, persons or institutions that require licenses include:• Animal dealers, including exotic animal dealers5 andsuppliers of specimens;• Animal transporters, including carriers, intermediate
handlers, and contract carriers;• Animal exhibitors, including zoological parks, animal
performances (any owner exhibiting animals doing
tricks or shows), roadside zoos, carnivals, or
promotional exhibits; and,• Research facilities, including state and local
government-owned facilities, drug firms, and teaching
institutions (APHIS, 2007a).
As this list shows, the range of activities that require alicense from the USDA is broad. Specifically regarding
captive U.S. Tigers, it includes zoos (AZA accredited andnon-AZA); those owning animals involved in circuses,
amusement parks, carnivals, independent animal acts,
television shows, movies, educational exhibits, and otheranimal performances; roadside zoos; promotional exhibits;
public research institutions administered or funded bystate or local government; sanctuaries or refuges thatallow public exhibition of Tigers; and, private collections
that are open to the public. Airlines, railroads, motor
carriers, shipping lines, terminals, and freight storage arealso covered, as is anyone taking custody of regulated
animals in connection with transporting them on public
carriers as intermediate handlers (APHIS, 2007a). Theselatter possessors or owners of captive U.S. Tigers are also
covered under the CWSA should Tigers be transported
interstate or internationally.
Unfortunately, for purposes of this report, TRAFFIC
found that the USDA licenses owners of exotic animals
by facility, not by species. In the summer of 2007,
TRAFFIC reviewed available data on holders of various
USDA licenses, especially Class C licenses, required for
those exhibiting Tigers and other exotic animals.
TRAFFIC found that the USDA, through APHIS,
maintains an Internet web site that shows an extensive listof all holders of USDA Class C licenses, but, becausesuch licenses are not broken down by species, it proved

5 Exotic animal dealers under USDA regulations include anyone importing, buying, selling, or trading animals foreign to the United States (wild or domesticated) (APHIS 2007a).

18

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

licensed, does have two Tigers. The Oregon Departmentof Agriculture representative explained that Tigers in
USDA-licensed facilities do not have to be licensed
separately by the state, and would not appear in thestate’s database, which is also not compatible with the
USDA database. Under the current system, with Tigers
regulated and reported to different standards at the stateand federal levels, it is extremely difficult to get an
accurate national view of exactly how many Tigers arebeing held in various facilities.
PHOTO COURTESY DOUG WILLIAMSON

Tigers in private possession

A Tiger cub at a wild animal “sanctuary” in central Florida. Suchcubs may be kept for display or breeding, or sold to wild animal
shows or for other commercial purposes.

impossible to get a fixed number of Tigers in such
facilities in the United States (APHIS, 2007b). A phone
call to the APHIS office responsible for maintaining thedatabase of USDA license-holders under the provisionsof the AWA confirmed that records of how many of thoselicense-holders may have Tigers, and how many, is not
information that they keep (TRAFFIC survey of state,federal, and private authorities, 2007).
TRAFFIC’s research also uncovered another troubling
disconnect between U.S. states and the federal government
in keeping track of how many Tigers may be held in
USDA-licensed facilities in individual states. Some statesthat require licenses for individuals keeping Tigers inprivate collections exempt USDA licensed facilities from
reporting or licensing requirements. If the USDA licenses
the facility, it does not then also have to be licensed or
include any Tigers present in the state’s database.
For example, when a representative from the Oregon
Department of Agriculture, which is responsible forlicensing Tigers in private hands in that state, wascalled, we were informed that while Oregon does
require individuals holding Tigers to obtain a license, nosuch licenses are currently issued, implying that there
are no Tigers in private hands in the state. Furthermore,
the state’s database showed no Tigers having been
imported into the state, which would also require apermit. However, TRAFFIC’s call to a safari park in
Oregon revealed that that facility, which is USDA-

TRAFFIC North America

The fourth captive Tiger population in the United States
involves Tigers in private collections. Werner (2005)
estimated that some 1,129 Tigers were in private
collections as of that year. However, because not all statesrequire that private owners register or license their Tigers,
the precise number of cats in the country is not known.
Ironically, the fact that the number of Tigers potentially inthese collections is not known does not indicate that theowners of these cats are necessarily operating outside ofthe law. Quite the contrary, the laws and regulations inplace in the United States can serve to encourage people
not to display their Tigers publicly. As long as individuals
in certain states do not deal their Tigers commercially,
breed them for sale, exhibit them to the public, or movethem across state lines, they can avoid the strict oversightof the AWA, the CWSA, USFWS CBW registration, orother possible state laws or regulations. Therefore, peopleinterested in keeping Tigers as pets, but do not want to be
subject to federal regulation, have an incentive to keep
their animals outside of the public domain. Such aversion
to regulation makes locating or accurately gauging the sizeof this Tiger population impossible for practical purposes.
TRAFFIC found in various conversations that evidence ofthe presence of such Tigers is often anecdotal. For
example, one individual told TRAFFIC that he has seen
Tigers in an enclosure at a private residence by the sideof a state road in North Carolina. Another individual
related that he knew of two Tigers in the back yard of an
acquaintance’s house outside of Las Vegas, Nevada.
These examples are used to illustrate the difficulty inestimating precisely how many Tigers there might be insuch circumstances in the United States. Neither North
Carolina nor Nevada has a state law governing the
keeping of Tigers in private collections. As long as theowners of the cats do not open their facilities to the
public or sell or trade the Tigers, they do not have to belicensed by the USDA. Unless all states without current
regulations change their laws to require the reporting,permitting, or licensing of all such Tigers within theirjurisdictions, it will remain impossible to determine
definitively how many Tigers exist in private hands in the
United States.

19

Table 3. State controls on Tiger breeding in the United States
Breeding ofBreeding
Privately held
Exemption
Tigers allowed? under license
permitted?6

State

Tigers Allowed
as “Pets”?

Breeding ofBreeding
Privately held
Exemption
Tigers allowed? under license
permitted?6

State

Tigers Allowed
as “Pets”?

Alabama

Yes

No*

Yes

Nebraska

No

No

Yes

AlaskaNo

No

No

NevadaNo Law

No Law

No Law

Arizona

No

No

Yes

New Hampshire

No

No

Yes

Arkansas

No

No*

Yes

New Jersey

No

No

Yes

California

No**

No

Yes

New Mexico

No

No

No

Colorado

No

No

Yes

New York

No

No

Yes

Connecticut

Yes

No

Yes

North Carolina

No Law

No Law

No Law

Delaware

Yes

Yes

Yes

North Dakota

Yes

Yes

Yes

Florida

No

No

Yes

Ohio

No Law

No Law

No Law

Georgia

No

No

Yes

Oklahoma

Yes

Yes

Yes

Hawaii

No

No

Yes

Oregon

Yes

Yes

Yes

Idaho

No Law

No Law

No Law

Pennsylvania

Yes

Yes

Yes

Illinois

No

No

Yes

Rhode Island

Yes

Yes

Yes

Indiana

Yes

Yes

Yes

South Carolina

No Law

No Law

No Law

Iowa

No Law

No Law

No LawSouth Dakota

Yes

Yes

Yes

Kansas

No

No

Yes

Tennessee

No

No

Yes

Kentucky

No

No

Yes

Texas

Yes

Yes

Yes

Louisiana

Yes**

No

Yes

Utah

No

No

Yes

Maine

Yes

Yes

Yes

Vermont

No

No

No

Maryland

No

No

Yes

Virginia

No**

No

No

Massachusetts

No

No

Yes

Washington

Yes**

No

Yes

Michigan

No

No

Yes

West Virginia

No Law

No Law

No Law

Minnesota

No

No

Yes

Wisconsin

No Law

No Law

No Law

Mississippi

Yes

Yes

Yes

Wyoming

No

No

Yes

Missouri

Yes

Yes

Yes

Montana

Yes

Yes

Yes

* Must spay/neuter animals** Grandfather Clause permitting keeping of Tigers owned prior to Ban

Source: API 2007b; TRAFFIC Review of State Laws and Regulations, Summer 2007.

6 Some states allow licensed breeder/dealers, businesses, sanctuaries, zoos, etc. to breed tigers in captivity.

20

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

Tiger breeding and sale in the
United States
As is also discussed in the next section on trade, itappears that the U.S. captive Tiger population is selfsustaining. Very few live Tigers are being imported into
the United States for breeding or zoological purposes on
permits consistent with the Appendix I CITES
designation.
Table 3 shows state laws regarding the breeding of Tigers
in the United States. As it indicates, twenty U.S. stateseither have laws that allow for the breeding of Tigers in
captivity or have no laws on the subject. Many more U.S.
states do not allow for the private breeding of Tigers but
do have exceptions so that approved facilities (AZA zoos,
USDA licensed breeder/dealers, etc.) may breed Tigers(API, 2007b; TRAFFIC review of state laws andregulations, 2007).
As with estimating the number of Tigers in the UnitedStates, however, TRAFFIC found that determining a
reliable number on how many Tigers are bred and sold in
the United States each year is impractical. Along with a listof licensed exhibitors in the United States, USDA also
keeps records of licensed animal breeder/dealers.
Reviewing these records, TRAFFIC found literally
thousands of individuals and company names with breeder
and/or dealer licenses. But as with exhibitors, these licenses
are not broken down by species, making it impossible todetermine what fraction of them may breed or deal either
partly or exclusively in Tigers (APHIS, 2007b).
Also, as was noted above and is discussed further below,
USFWS CBW permits are required only for Tigers with aknown breeding pedigree at the subspecies level, which
represent only a fraction of the U.S. captive Tiger
population. The majority of Tigers being bred in the
United States currently fall outside of this system,
meaning that those breeding them must only maintainaccurate written records of their activities, including
births, deaths and transfers; there is no periodic reporting
requirement, and thus USFWS keeps no comprehensive
data on how many Tigers are being bred or sold annually(50 CFR Part 17.3; USFWS, 2008).
TRAFFIC further tried to determine how readily
available Tigers are for sale in the United States.
TRAFFIC’s Internet research found that Tigers are notreadily available to the public, which is very positive. For
example, a search using terms such as “Tigers for sale” orsimply “Tiger sale” found links to Tiger-related products(not actually Tigers or Tiger parts) and species such as
domesticated Tiger cats, but no actual Tigers. In lesspositive news, however, TRAFFIC found that there areprivate web sites and links to publications aimed atanimal enthusiasts that do advertise Tigers, mainly Tiger
cubs. TRAFFIC has decided not to publish or publicize
information or addresses on specific sites or how to findthem so as not to further facilitate this trade.
Although the breeding and sale of Tigers as pets in the
United States is not the primary focus of this report, thefact that such transactions are occurring does present a
potential challenge regarding the international Tiger
trade. The link between the two issues comes aboutbecause, while the CWSA strictly prohibits the interstatesale or transport of Tigers in private hands to nonexempted individuals or facilities, the breeding and saleof such Tigers within states that allow such trade or haveno laws regulating the activity is virtually untraceable.
Some of these Tigers inevitably end up unwanted. For
example, from 1999 to 2006, one sanctuary in Florida
alone took in several hundred unwanted big cats (not allof them Tigers) (Big Cat Rescue, 2007). These unwanted
animals are often those that people purchased as pets
when they were cubs. As is discussed in the next section,
to date there has been no evidence that U.S. captive
Tigers are being killed and sold for parts in theinternational Tiger trade, but the fact that the UnitedStates continues to generate Tigers that end up unwanted
indicates that the U.S. could become a source for parts in
the illegal trade in the future. The lack of regulations orreliable data in many jurisdictions makes it impossible todetermine how many Tigers may be in such conditions,but this is certainly an area for concern.

Mortality and disposal of dead Tigers
in the United States
Several key questions remain to be answered. Two of themost important of these are: What is the annual rate ofmortality in the U.S. Tiger population? And what happens
to captive U.S. Tigers and their parts when they die?
TRAFFIC’s research and investigation into these questions
hoped to find a clear answer. However, TRAFFIC quickly
found that U.S. laws and regulations, especially at the statelevel, were not written to specifically address these vitalquestions. Given that there are no comprehensive data on
how many Tigers exist in the United States at any given
time, there are similarly no accurate data on how many dieannually, where, or how. Once Tigers die, they no longer
present a threat to human life, and considerations of their
humane treatment in captivity no longer apply. Theirultimate disposal falls largely outside of the legal
framework, and again, some states have no regulations on
private possession of live Tigers, much less on the ultimate
disposition of their carcasses.7

7 Many states and localities do have laws or ordinances that generally restrict the burying of dead animals to approved pet cemeteries. Many of these laws relate to issues
such as groundwater protection that are ancillary to the issue addressed herein, which is wildlife trade, and therefore TRAFFIC did not attempt to do a detailed analysis.

TRAFFIC North America

21Case Study: Florida
In late December 2007, TRAFFIC undertook a fieldvisit to the State of Florida to view firsthand some of
the issues regarding captive Tigers in the United States.
Florida was chosen because the state has a large
population of Tigers, an interesting and controversial
regulatory system, and a number of facilities breeding,selling, and exhibiting the animals. What TRAFFIC
learned during the visit highlights the broader issues
facing the United States in managing captive Tigers as
they relate to possible illegal trade.

estimated that of the 500 animals her operation wasoffered in a recent year, as many as one-third were
unwanted Tigers. According to both, this problem often
arises from people who purchase Tigers as cubs, butthen either cannot or choose not to maintain their careas adults.
The expense of keeping an adult Tiger is a major
factor. An adult Tiger eats 10–20 pounds of meat perday, which means that simply feeding one can cost
USD5,000–6,000 per year. Add in even routine
veterinary expenses and the cost can reach USD7,500
per year for a healthy Tiger, and more if the cat
develops health issues (as Stoner noted, these are notcats that can be simply driven to the veterinary clinic
for check-ups). In addition, adult Tigers need to behoused in secure enclosures, and building such an
enclosure to ASA standards can cost as much as
USD45,000, though not all private Tiger owners meetsuch standards (most probably do not).

Four facilities were visited: two sanctuaries that do notbreed or sell Tigers or other exotic cats; one “refuge”
that does breed and sell Tiger cubs; and a commercial
wildlife park that exhibits Tigers and conducts wild
animal shows involving Tiger cubs. These visits
revealed some startling and troubling facts about the
Tiger situation in Florida that could have implications
for potential illegal Tiger trade.
Florida law allows for the keeping of Tigers in private
hands only for “commercial” purposes; individuals are
not allowed to keep Tigers simply as pets. However,there are several thousand people or businesses thathave licenses to own exotic animals, and several
hundred have licenses to own the most dangerous
animals, including Tigers. Although licensed wildlife
owners must submit annual counts of their animals, a
2007 investigation by the St. Petersburg Times foundthat state wildlife officials have no idea exactly how
many exotic animals are present in Florida. Some files
were found to be missing, while others lacked the latest
inventories.

First, Florida already has a serious problem withunwanted Tigers. Carole Baskin, CEO of the Big Cat
Rescue sanctuary in Tampa, told TRAFFIC that in2003 alone, her operation was asked to accommodate
some 300 Tigers. Lisa Stoner, who runs the ASAaccredited Peace River Refuge in Zolfo Springs,

22

PHOTO COURTESY DOUG WILLIAMSON

The newspaper quoted a representative of the Florida
Fish and Wildlife Conservation Commission: “In an
ideal world, it would be better to have inventories onwhat is possessed on a daily basis, but that’s notrealistic. Especially with the frequency and amount ofchange. What’s important is to know where all thesefacilities are located” (St. Petersburg Times, 2007).
Information uncovered by TRAFFIC during the visit
shows, however, that in the case of Tigers (in which
preventing the animals or their parts from possibly
entering illegal trade is paramount), that answer isinadequate for several reasons.

The presence of so many unwanted Tigers stems froma second major problem: the prevalence of Tiger
breeding in Florida. It is unclear exactly how many
people may be breeding Tigers in the state, but the
number has apparently been high enough in recent
years to sharply reduce the cost of Tiger cubs. BothBig Cat Rescue’s Baskin and Peace River Refuge’s
Stoner estimated that, whereas a decade ago a Tiger
cub might cost USD2,000, at present the cost would be

An approximately six-month old Tiger at an animal show in Miami,
Florida. When these young Tigers mature and their owners canno longer expose the public to them, their commercial value drops.

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

Breeding of Tigers in Florida may be driven by a quirk
in the state’s laws and regulations that make Tiger cubs
a commercial asset, while devaluing adult Tigers. One
purpose for which Tiger cubs are bred in Florida
involves their use as “props” in photographs fortourists. Young Tiger cubs weighing less than 25
pounds can be handled by members of the public
without any form of restraint. Tiger cubs that weigh25-40 pounds require a leash. Once Tiger cubs reach
40 pounds or six months in age, no direct publiccontact is allowed. In addition, there are no caging
requirements for Tigers less than six months in age;
therefore, whereas keeping a Tiger more than six
months old requires the expense of an enclosure, young
Tiger cubs present no such financial outlay and greater
potential for financial gain.
To view how the system works, two further facilities
holding Tigers were visited. The first was a “refuge”
advertising itself as a not-for-profit operation devoted
to the conservation of big cats and other wildlife that,among other species, held Tigers. During TRAFFIC’s
visit, the owner of the facility openly discussed boththe fact that he was breeding Tigers and that theoperation had some connection to a commercial
wildlife park in Miami. Close to a dozen Tigers were
witnessed and photographed, ranging in age from ayoung cub, through some juvenile Tigers, to several
full adults. Five of the cats observed were variants on
the “white” Tiger, the significance of which is
described below.
Subsequently, the facility in Miami was visited, which
publicly exhibits at least two adult Tigers (one white)
and a Liger (the product of cross-breeding a male lion
and a female Tiger). During a wild animal show, thefacility further produced five more Tigers advertised as
being six-months of age. The first was described as
being a Bengal Tiger, while the remaining four were
described as a “white Bengal”, a “golden tabbie”, a“snow white ghost Tiger”, and a “royal white” Bengal
cub. The presentation stressed that one of the goals of
the program breeding and displaying the Tigers was toraise funds for conservation and restoration of these
Tigers in the wild.
At the close of the presentation, members of theaudience were offered the opportunity, for USD40, tohave a picture taken with a very young white Tiger
cub, with one audience member holding the cub and up
to five people allowed in each picture. TRAFFIC notedthat a related facility, run by the same organization

TRAFFIC North America

PHOTO COURTESY DOUG WILLIAMSON

only USD200–500, which is less than the cost of many
pedigreed dog puppies.

An adult “white” Tiger at an animal park in Miami, Florida. As
adults, Tigers are potentially very dangerous and thus need to be
kept in secure enclosures.

sponsoring the Miami show, charges USD79 for a
photo with Tiger cubs in Myrtle Beach, South Carolina.
Whether or not the Tiger cubs witnessed in Miami
came from the specific “refuge” facility visited earlier
cannot be confirmed. However, several aspects of any
such commercial breeding and use of Tigers raise
disturbing questions. For one, there is no legitimate
connection between the rearing and commercial use ofwhite Tiger cubs in the United States and conservationof Tigers in the wild. All white Tigers in the UnitedStates originate from a single male white Bengal Tiger
imported years ago. The variants witnessed in Miami
are the result of various inbreeding and other genetictransformations over time. These Tigers may also havebeen hybridized, for example by crossing Bengal with
Siberian Tigers to increase size and weight. It isfurthermore dubious that funds from these commercial
operations are contributing to the in situ conservationof wild Tiger populations in Asia (R. Tilson,
Minneapolis Zoo, pers. comm. to D. Williamson,
January 2008).
Another more serious issue, when considering thepossibilities for illegal trade, is the ultimate fate ofthese Tigers. As noted above, Tigers in Florida cangenerate revenue as cubs, but often become a financial
liability as adults. Along with the facility visited,
TRAFFIC also identified the names and locations ofseveral other commercial breeding operations that arelikely producing Tiger cubs. The fact that the state is
producing a stream of new Tiger cubs, while adult23

Tigers go apparently unwanted, poses another question:
Where are these Tiger cubs going when they mature?

that Tiger owners microchip and provide photographic
evidence to the state of every Tiger present, from cubs
to adults; that the death, sale, loan or donation of every
Tiger be reported, along with proof that, upon death,
the Tiger’s carcass has been properly disposed of in a
way that its parts cannot enter trade; that Tiger
breeding be far more closely regulated to prevent thecreation of more potentially unwanted animals; andthat steps be taken to address the issue of unwanted
adult Tigers.

Speculation on that question reveals another flaw in thestate’s management system. While Florida Tiger
owners may have to account annually for the numberof Tigers they possess, there is no requirement thatthese owners account for the fate of the animals. It is
possible that some may enter breeding operations. It is
possible that some may be sold to other organizations
and even moved out-of-state. There is a third
possibility, however—the Tigers may simply be killed.
TRAFFIC’s conversations with several sources, bothwithin and outside of Florida, raise this outcome as areal option. For example, Peace River Refuge’s Lisa
Stoner noted that although such fate for the Tigers iscompletely abhorrent to her, for the owners of
unwanted Tigers it may be the option that is “cheapest,
easiest, and perfectly legal”. Unfortunately, given
constraints of space and the cost of keeping such
Tigers, there is virtually nothing that legitimate
sanctuaries could do to stop it.

Simply put, the days when management programs that
simply document which facilities may hold captive
Tigers are considered adequate need to end. Precluding
the chance that U.S. Tigers might enter into illegal
trade means that all such Tigers need to be accounted
for, from birth to death. This may seem a daunting
task, but given that the rough estimate of the country’s
overall Tiger population is about 5,000 animals, it is
not likely to be overwhelming or prohibitively
expensive. The question is whether the United States
has the collective will to recognize that, given thespecial threat that ongoing trade in Tiger parts poses toremaining wild populations, special measures need tobe taken to ensure that U.S. captive Tigers cannot enter
the trade stream and thereby exacerbate the problem.

Given that each unwanted Tiger represents a possible
source of hides, meat, bone, and other derivatives,states such as Florida need to significantly tighten their
management programs for these endangered cats. It
should be noted that, as of late 2007, Florida now
requires that Tiger owners purchase insurance anddeposit a bond for their facility. However, we also notethat the purpose of these bonds and insurance is toguard against the potential that the cats may escape andcause harm to human beings; the initiative does notaddress the issue of potential trade in Tiger parts.
As is detailed in the recommendations at the close ofthis report, further specific steps need to be taken, notonly in Florida but nationwide. These include requiring

24

PHOTO COURTESY DOUG WILLIAMSON

Combining the elements and points above, states withTiger management schemes such as the one TRAFFIC
found in Florida could have potentially detrimental
impacts on U.S. efforts to keep Tigers and their partsout of illegal trade. The state has an evident surplus ofadult Tigers that their owners either cannot afford or do
not want to keep. There is a continuing stream of Tiger
cubs into the state’s commercial population (although it
is possible that some of these Tigers may not be used
for truly commercial purposes). The state has not kept
accurate records of how many Tigers may be present at
any given time. And, the state does not require Tiger
owners to account for the fate of Tigers leaving the
population.

Tigers at an ASA-certified sanctuary in south-central Florida. Such
sanctuaries take in Tigers no longer wanted by their owners, but
because it costs a minimum of USD5,000–7,000 annually to feed
and provide medical care for each animal, there are moreunwanted Tigers than space or resources available.

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

Tiger mortality
TRAFFIC’s attempt to determine how many Tigers dieannually in the United States, and to extrapolate from thathow much Tiger bone or other Tiger products the
population may be producing on a yearly basis, produced
no clear answer, for several reasons. First and mostobvious, neither the federal government nor U.S. states
maintain current data on the subject. Individual entities
such as animal sanctuaries, zoos, circuses, or others may
know how many Tigers die each year in their individual
subpopulations, but these data are not combined andcompiled by governmental authorities in a way that is
publicly accessible. Furthermore, there are no annual
mortality data regarding Tigers held by private owners,
especially in states that do not require licensing or
registration of the animals.
Second, various Tiger populations and hybridizations
may have different lifespans. For example, Tigers held inzoos or legitimate animal sanctuaries may live into theirteens or even early twenties. “White” tigers that are
genetically bred for certain characteristics attractive tocommercial exhibitors have far shorter lifespans (C.
Baskin, Big Cat Rescue, pers. comm. to D. Williamson,
March 2008.) As witnessed during TRAFFIC’s visit to
Florida, many Tigers in the commercial private sector are
white Tigers selectively bred for such display, although
the exact number is not known. Given the discrepancy,
therefore, it is not possible to simply calculate that there
are approximately 5,000 Tigers in the United States witha fairly fixed natural lifespan, and from that extrapolate
an average rate of mortality.
Third, it is further unknown exactly what happens to
Tigers used for commercial activities such as those in
Florida once the cats reach maturity. As the Florida casestudy showed, the primary commercial value of Tigers
used in shows derives from Tiger cubs. Once the Tigers
reach an age or size at which they can no longer be usedin shows or handled by the public, they may be transferred
to other facilities or sold or donated to private owners. At
that point, these Tigers essentially leave the public radar
screen. Whether the cats then live on into old age, orwhether owners have an incentive to dispose of the cats
instead of paying to feed, house, and provide veterinary
care for some number of these animals is unknown.
Fourth and related, little is known of the fate of Tigers
that owners no longer want. As noted earlier, sanctuaries,
zoos, and others regularly receive inquiries from Tiger
owners looking to give up their cats, and these facilities
simply do not have the capacity or funding to take themall. Some of the owners of these Tigers may succeed infinding new homes for their animals, and others may
decide that if they cannot find a new home for a Tiger
they will keep it. However, it is possible that other

TRAFFIC North America

owners may decide to have their Tigers put down. In fact,
there are known cases in the United States of owners
killing surplus Tigers. As is described in more detailbelow in the section on illegal trade, a law enforcement
investigation from 2001–2003 led to multiple
prosecutions of individuals found to be killing exotic
cats, including 19 Tigers, and selling their products(particularly meat and skins) in the illegal market. While
such incidents appear to be isolated, they further point to
the possibility that there may be a level of unnatural
mortality in the U.S. Tiger population that is very
difficult to detect or measure.
Together, this lack of comprehensive recordkeeping or
regulatory oversight, differing lifespans between Tigers andTiger hybrids, and general absence of data or knowledge
about what happens to Tigers in the United States when
they are no longer commercially viable or wanted by theirowners, makes it impossible to accurately determine how
many captive U.S. Tigers may be dying on an annual basis.
Instead of trying to come up with a firm numericalestimate, therefore, TRAFFIC believes that the focus ofattention should be on developing a regulatory andmonitoring system in the United States that will make itpossible to readily answer this question going forward.
Some of the primary recommendations offered at the closeof this report include specific suggestions for ways in which
U.S. state and federal authorities charged with overseeing
various segments of the U.S. captive Tiger population, in
conjunction with private and non-profit organizations, canwork together to address the issue.
Disposal of dead Tigers
TRAFFIC’s inquiries to those involved in regulating,managing, or holding Tigers at the federal, state, andprivate levels also provided no satisfactory or
comprehensive answers to the question of what actually
happens to U.S. captive Tigers after the animals die.
Responses varied across these different groups. For
example, the AZA has a detailed written policy on theacquisition/disposal of animals. It states: “Deadspecimens (including animal parts and samples) are only
to be disposed of from an AZA member institution’s
collection if the following conditions are met:
1. Dispositions of dead specimens must meet therequirements of all applicable local, state, federal andinternational regulations and laws.
2. Maximum utilization is to be made from the remains,which could include use in educational programs or
exhibits.
3. Consideration is given to scientific projects thatprovide data for species management and/or
conservation.
4. Records (including ownership information) are to be25

kept on all disposals, including animal body parts, whenpossible.
5. SSP and TAG necropsy protocols are to beaccommodated insofar as is possible” (AZA, 2007d).
The first of those conditions clearly indicates that AZA
Tigers cannot be sold for parts, which, depending on thenature of the sale could violate a panoply of federal andalso possibly state laws. There is also a requirement forrecord-keeping.
TRAFFIC’s inquiry to the ASA regarding the disposal of
Tigers that die in certified sanctuaries produced a
response that most Tigers that die at such facilities arelikely cremated. The ASA representative further pointed
out that in many jurisdictions local groundwater laws
prohibit the burial of dead animals, and that the costs tobury such animals in special pet cemeteries are likely
prohibitive (V. Weir, ASA, pers. comm. to D. Williamson,
September 2007).
Similarly, a representative of the circus industry indicatedthat they have no formal policy or regulations regarding
disposal of their Tigers. Ringling Brothers and Barnum &Bailey Circus normally sends out their deceased animals
for necropsy, and disposal is then carried out by thenecropsy facility. In the rare case where a necropsy is notneeded, the animals are buried. Independent circus
operators generally have their animals necropsied, buriedon site, or collected by animal disposal providers. Again,
though, none of these organizations have any establishedpolicy on disposal of deceased Tigers. (J. Galvin, The
Livingston Group, LLC, pers. comm. to L. Henry,
September 2007).
Most troubling, neither the federal government nor state
regulatory agencies keep data on the disposition of Tigers
that die under their jurisdictions. TRAFFIC’s inquiries tostate authorities typically elicited variations of the
response that the Tigers’ owners “probably bury them.”
This is a subject area which remains unregulated at a
direct level, unless there are state or local ordinances
regarding issues such as protection of groundwater(TRAFFIC survey of state and local agencies, 2007).
There may be laws regarding disposition of live Tigers
through trade or sale in some states (though not all), but
the ultimate disposition of dead Tigers goes largely
unaddressed at the state level.
As an example, when a representative of the Arizona
Department of Game and Fish office that issues permits
for captive Tigers in that state was contacted, we were
informed that Arizona does not allow for the keeping ofTigers in private collections but does regulate them as a
Restricted Wildlife species subject to permits forzoological display. When asked whether the state requires
any reporting or permitting for the disposal of Tigers that26

may die in such captivity, the answer was no. Arizona
only has reporting requirements for cervids, whose
disposal is monitored as part of an effort to monitor andeliminate the current threat posed by chronic wasting
disease. Given limited resources, and the mandates ofstate agencies, such responses make sense. The mainpriorities of game and fish departments tend to beprotection of native wildlife and game, regulating andmonitoring hunting seasons, enforcing anti-poaching laws,
and other such mandates. The ultimate disposition of
captive Tigers in zoos and other facilities does not seem tobe a high priority. Should international demand for Tiger
parts for medicinals or other purposes increase, however,this lack of focus on the disposition of Tigers and theirparts as they die could represent a gap to be exploited bythose seeking supply for illegal trade. This does not mean,
however, that there is evidence that parts from dead U.S.
Tigers are currently entering the illegal international trade,as there is no such evidence. The next full section on tradereviews what is known on that subject.
Policy & management options
The above findings suggest a troubling lack of solid
available information regarding key aspects of the U.S.
captive Tiger population as it relates to potential
international trade. No clear census or regulatory system
exists to detail the precise numbers or whereabouts ofTigers in captivity in the United States. There is no clear
way to determine the numbers of Tigers dying annually in
the United States, and it is further impossible to determine
comprehensively what happens to these animals when
they die. Stemming from those data and informational
gaps, it is therefore impossible to accurately determine
how much Tiger bone or other parts the United States isgenerating on an annual basis that could potentially enter
domestic or international trade. TRAFFIC is continuing toinvestigate these elements of the U.S. captive Tiger
management system, but has found to date that obtaining
specific, numerical data is akin to completing a puzzle
without access to all of the pieces, or even being able todetermine exactly how many pieces there are.
Given these circumstances, the next obvious question that
TRAFFIC asked was: What policy or management
options are available to address the situation? As wasnoted in the section on laws and regulations, anincreasing number of U.S. states have moved to simply
ban the private possession of Tigers and other large
exotic cats. In 2007, Washington and Louisiana became
the latest states to take such action. While such a solution
is very direct, and will over time likely reduce thenumber of Tigers in private hands in the United States, inthe near term it is unlikely to resolve issues regarding
potential trade in Tiger parts.
For example, even those states that are now moving toPaper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

ban the possession of Tigers as pets have not mandated or
advocated the confiscation of extant captive Tigers.
Conversations with people in several places suggested
anecdotally to TRAFFIC that state authorities haveneither the inclination for such action, nor the budgets or
facilities to try to assume responsibility for Tigers
currently living in captivity. In practical terms, this would
indicate that even should all U.S. states that continue toallow the private possession of Tigers decide to ban thepractice, a residual population of such cats, and thus apotential source of parts for illegal trade, would continue
to exist for years to come.
The reason for this is that Tigers can live for a significant
number of years in good conditions. For example, Big
Cat Rescue in Tampa, Florida, had 17 Tigers as ofDecember 2007; according to CEO Carole Baskin, mostof the Tigers currently held are in their late teens or earlytwenties. Although not all captive U.S. Tigers live in
optimal conditions, efforts to ban their possession in
private hands may be a welcome long-term development,
but it does not obviate the need for other, more
immediate, regulatory actions specifically related to trade.
The fundamental trade-related policy and management
issues that need to be addressed involve the ongoingbreeding, sale, and transfer of live U.S. captive Tigers,
and the disposal of Tiger carcasses when the animals
inevitably (or prematurely) die. Options in these areas
need to be focused, realistic, and cost effective.
TRAFFIC’s assessment of management and policy
options is as follows.
The first issue that needs to be faced is ongoing breedingof new Tigers into the U.S. captive population. As
described earlier, at present both federal and many statelaws and regulations allow for the commercial breeding
and sale of Tiger cubs without close scrutiny. USDA
regulates by facility and, while facility owners are
required to maintain records, they do not have to regularly
report every birth, sale, or transfer of Tiger cubs.
Similarly, because USFWS Captive Wildlife Breeding
regulations require regular reporting only of Tigers
certified to be pure-bred at the sub-species level, there isthus no regular reporting requirement to that agency by
the majority of Tiger breeding operations. At the statelevel, some jurisdictions do not maintain their own recordsof Tiger breeding in federally regulated facilities, some
may have laws but monitoring is incomplete, and some
simply have no laws on the subject.
The second issue involves the sale or transfer of Tigers,
both interstate and intra-state. At the federal level,
implementation of the Captive Wildlife Safety Act, forwhich implementing regulations came into force in
September 2007, may go a long way towards regulating
the movement of live Tigers in private hands between

TRAFFIC North America

state jurisdictions. It remains too early to know exactly
what the effect of that law will be. In addition, sale ortransfer of Tigers within a state, or among entities
exempted from that law, would remain unaffected.
The third issue regards the disposal of Tigers once theydie. On this subject there are clear federal laws thatprohibit the sale of Tiger parts, but no federal or state legal
framework that otherwise monitors or speaks directly tothe subject. The closest the law comes lies in local or stateordinances regarding the generic disposal of pets forgroundwater or other human health and safety reasons.
TRAFFIC’s review of management options found that thiscurrent system can be dramatically improved regarding
trade at fairly little cost. For example, to better monitor how
many Tigers are entering the U.S. captive population eachyear, loopholes in current laws and regulations could beclosed by requiring that breeders/dealers have to report on
how many Tiger cubs they produce annually, and to whomthey are sold or transferred. USDA and USFWS-regulated
facilities already have to keep records of these activities,
and it would not be very much of a stretch to require thatsuch records be transmitted electronically to databases atthe state or national level. Private groups or NGOs could
assist in such an effort by helping to establish and maintainsuch a database, which would not be a tremendous
endeavor if the generally accepted figure of about 5,000
Tigers in the country is taken as a starting point.
Another option to better manage and monitor the U.S.
captive Tiger population could be to require that Tiger
owners insert a microchip into every animal, with theidentifying information to be entered into the abovesuggested database. This practice of using microchips to
identify and track animals is increasingly common forhousehold pets such as dogs and domestic cats. By
implanting such a microchip, animal owners have a muchbetter chance of recovering animals that run away or get
lost and are subsequently found by animal control officials
or others. In the case of U.S. captive Tigers, applying thistechnology universally would be a ready identifier toconnect individual animals to their legal owners, and, in
terms of potential illegal trade, it would make it very
difficult for Tigers to be killed or sold illegally because
management authorities would have a mechanism to know
if a Tiger went missing or was unaccounted for. To
preclude the possibility that such microchips could beillegally transferred between cats, Tiger owners could befurther required to submit a hair sample for DNA
comparison, or even provide periodic digital photographsof each Tiger to the above-mentioned database to allay
fears of such activities and enhance enforcement.
Furthermore, the microchipping process itself is relatively
inexpensive–around USD10–25 for a Tiger cub–and canbe done during a routine veterinary visit. An adult Tiger

27requires tranquilization, which is more expensive–around
USD300–1,000, depending upon whether it is done in thefield or in a clinic. One possible approach to this issue
would be to require that all cubs under six months of age
be microchipped in conjunction with vaccinations. For
adult Tigers, it would be required that the cats bemicrochipped if they are ever tranquilized for any otherpurpose, thereby reducing the costs to the owners by
eliminating the need for a special visit or procedure (L.
Stoner, Peace River Refuge, in litt. to D. Williamson,
March 2008). Under such a system, it is likely that in amatter of a few years there would be only a very small
number of remaining adult Tigers without microchips, andthe system could be implemented at reasonable expense.
A final option to preclude illegal trade would be torequire Tiger owners to report all Tiger deaths and certifythat the animals are disposed of properly in a way that
their parts cannot enter the illegal market. Here, the mostcost-effective means of implementation would probably
be to mandate the cremation of carcasses by licensed
facilities. Anecdotal information provided to TRAFFIC
by several sources estimated that the cost of cremating a
Tiger at a funeral home is approximately USD500, or
perhaps a bit more for a very large specimen. By
comparison, burial in a dedicated pet cemetery can run
into the thousands of dollars to buy the plot and inter the
animal (not just for Tigers, but for other domestic animals
as well). The practice of simply burying the animals
privately may be common as noted above, but it may also28

be technically illegal under groundwater laws or otherstate or local ordinances.
Requiring Tiger owners to cremate their Tigers andprovide subsequent proof may seem a burden. However,
TRAFFIC notes that, as is also described above,
providing these animals with an enclosure that would
meet accepted sanctuary standards can cost some
USD45,000, and even housing them in secure but lesser
facilities can run into the tens of thousands of dollars.
Adult Tigers also require some USD5,000 per year just to
feed, and, when veterinary care is included, their annual
upkeep can easily reach USD7,500 or more. Given those
expenses, requiring that owners spend some USD500 toperhaps even USD1,000 to properly cremate and disposeof the animals so that their parts are rendered useless forpotential illegal trade seems a reasonable requirement.
Taken together, implementing these options wouldchange the current U.S. system of captive Tiger
management from one in which very little information isavailable about the status and dynamics of the population
to one in which there would be few loopholes for thosepotentially interested in exploiting U.S. captive Tigers forillegal purposes. From birth to death, federal and state
regulatory authorities, as well as NGOs and others whomonitor captive wildlife issues and the international
wildlife trade, would have a much greater ability to track
the U.S. captive Tiger population. Specificrecommendations for how such a system might be
implemented appear at the close of this report.

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

DOMESTIC AND INTERNATIONAL TRADE OF TIGERS IN
THE UNITED STATES
Very limited legal trade in Tigers and some parts orderivatives continues; most of this trade involves the
movement of live Tigers between countries for exhibition,entertainment, zoological, or breeding purposes. Of the
138 USFWS records of legal imports of Tigers or Tiger
parts from 2001 to 2006, for example, 112 (81%)
involved live Tigers, as did 96 of the 102 records of legal
exports (94%).8 Ongoing trade in Tiger parts orderivatives consists primarily of items imported orexported under CITES and/or ESA exceptions forscientific research or education, although during theperiod examined there were also a very small number ofrecords indicating trade for personal or commercial
purposes. USFWS exceptions to the ESA and CITES
trade bans that allow such shipments are discussed below(TRAFFIC analysis of USFWS LEMIS data, February
2007 and January 2008).
Unfortunately, illegal trade also persists. Evidence ofsuch trade consists primarily of USFWS seizures of
medicinal imports containing, or purporting to contain,
Tiger bone. USFWS records also show seizures of otherTiger parts or derivatives such as skins, rugs, teeth, claws,
and other items. Domestically, recent years have also
seen cases involving the illegal killing and sale orattempted sale of parts from captive Tigers within the
United States. In a positive development, from 2001 to
2006 there was not a single seizure of Tiger parts being

exported from the United States, which suggests that the
U.S. role in the illegal international trade is that ofconsumer rather than supplier.

Legal imports and exports ofTigers/parts into and out of theUnited States
From 2001 to 2006, data provided to TRAFFIC from the
USFWS Law Enforcement Management Information
System (LEMIS) through the Freedom of Information
Act (FOIA) show records of 138 imports and 102 exports
cleared by USFWS. These fell into several broad
categories.
Live Tigers
As noted above, live Tigers constituted the vast majority
of ongoing legal trade involving the species. Table 4shows the annual number of LEMIS records for live
Tigers from 2001 to 2006, as well as the number ofTigers involved. As noted above, the number of LEMIS
records here does not necessarily reflect the number ofindividual shipments of Tigers, which would be asignificantly smaller number.
As the Table shows, during the period examined, several
hundred live Tigers entered and/or left the United States.
Declared purposes for these imports and exports in the

Table 4. Live Tigers imported to and exported from the United States, 2001–2006
Imports

Exports

Year

No. of Records

No. of Tigers

No. of Records

No. of Tigers

2001

28

64

12

36

2002

24

47

21

44

2003

34

59

27

50

2004

10

21

20

32

2005

9

21

7

16

2006

7

18

9

20

Total

112

230

96

198

Source: TRAFFIC analysis of USFWS LEMIS data, February 2007 and January 2008.

8 TRAFFIC notes that the number of records shown in the LEMIS system does not necessarily indicate the number of actual shipments of Tigers into and out of the UnitedStates. For example, as the data below demonstrate, in some cases shipments of multiple Tigers to the same destination on the same date include an individual record foreach individual Tiger imported or exported. When such shipments of multiple cats are aggregated, there may have been as few as 40 total import shipments and 43
exports in the six years of data examined.

TRAFFIC North America

29

LEMIS records included exhibition, zoological,
commercial, educational, personal, and breeding. Figures
2 and 3 show the aggregate breakdown of live Tigers
imported and exported from the United States bydeclared purpose.
The table and figures to the right indicate that from 2001
to 2006, the United States was a slight net importer oflive Tigers. Further analysis of each of the categories andnumbers involved, however, shows that without carefulreading and interpretation they can be deceiving, andshould be treated carefully.

Figure 2. Live Tigers imported into theUnited States, 2001-2006
11 4
16

Live Tigers for exhibition
LEMIS records show that 175 of the 198 Tigers (88%)
listed as being exported from the United States, and 199of the 230 Tigers (87%) listed as being imported from2001 to 2006, were for exhibition purposes. Most of theserecords, however, did not represent Tigers thatpermanently left or entered the United States, but rather
corresponding exports and imports of the same cats.
These are most likely Tigers used in circuses, film
projects, and other display or entertainment that
temporarily traveled outside of the country and then reentered. One needs to view these data with theunderstanding that if a circus or other entertainment
entity takes a Tiger out of the United States for a show or
exhibit, and then returns to the United States, this iscounted in LEMIS records separately as both an export
and an import in LEMIS records (TRAFFIC analysis of
USFWS LEMIS data, February 2007 and January 2008).
For example, in 2001 the United States exported six
Tigers to Canada on a permit for circus/exhibition
purposes, and LEMIS records then show a subsequent
import of the same six Tigers back into the United Statesin the same year, judging by the fact that the value,
number of cats, and all other fields of data corresponded
exactly. In May of 2003, LEMIS records show a circus
export of 11 Tigers to Mexico, and then a re-import ofthe same cats in June of that year. In 2005, LEMIS
records show two exports and subsequent re-imports ofsix and 10 Tigers, respectively. In short, the USFWS data
show a consistent pattern of such activity in all six yearsof records examined, accounting for the vast majority oflive Tigers leaving and entering the country (TRAFFIC
analysis of USFWS LEMIS data, February 2007 andJanuary 2008).
Second, TRAFFIC noted that USFWS data show that theUnited States is listed as the country of origin for 192 of
the 199 live Tigers imported (96%), and 169 of the 175
Tigers exported from 2001 to 2006 for exhibition or circus
purposes. The only other countries of origin for circus or
exhibition imports were Japan (two Tigers in 2001) andthe UK (five Tigers in 2004), which were imported

30

199
Exhibition
Commercial
Zoological
Other (Personal, Breeding, etc.)

Figure 3. Live Tigers exported from theUnited States, 2001-2006
7 2
14

175
Exhibition
Commercial
Zoological
Other (Personal, Breeding, etc.)

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

through Spain. LEMIS records from 2006 show an exportof six Tigers to Spain whose country of origin is listed as
the UK. It is possible that this re-export included the
Tigers imported in 2004. USFWS records also indicatedthat all of the live Tigers being imported into or exported
from the United States for circus or exhibition purposescame from captive sources. There were no records
showing wild Tigers from any Tiger range States in thispart of the trade (TRAFFIC analysis of USFWS LEMIS
data, February 2007 and January 2008).

Figure 4. Number of exhibition/circus
Tigers imported into the United Statesby country of export, 2001-2006
17
13
17

Furthermore, the reader should not assume that thismovement of live Tigers involves imports from, or
exports to, Tiger range countries, unless specified. In fact,
TRAFFIC found that the majority of live Tigers imported
into or exported from the United States from 2001 to
2006 for circus or exhibition purposes did not leave
North America. For example, Canada accounted for 152of the 199 Tigers imported into the United States in thiscategory, while Mexico accounted for another 17.
Together, those imports accounted for some 85% ofexhibition Tigers imported overall (TRAFFIC analysis of
USFWS LEMIS data, February 2007 and January 2008).

152
CanadaMexicoOther nations from which the United States imported
circus or exhibition Tigers were China, Japan, Spain,
Bermuda, Thailand, the Dominican Republic, and one
Tiger from country unspecified in the records in 2001
(TRAFFIC analysis of USFWS LEMIS data, February
2007 and January 2008). Table 5 breaks these figures
down by year; Figure 4 presents the data graphically.

China
Other

Other includes: Spain 5; Bermuda 5; Japan 3: Thailand 2; Dominican Republic 1;
Unspecified 1.

Table 5. Exhibition/circus Tigers imported into the United States by country of export,
2001–2006 (Number of Tigers)
CountryYear

Total:

2001

2002

2003

2004

2005

2006

Canada

46

27

38

13

16

12

152

Mexico

0

5

11

0

0

1

17

China

0

13

0

0

0

0

13

Spain

0

0

0

5

0

0

5

Bermuda

0

0

0

0

0

5

5

Japan

0

1

2

0

0

0

3

Thailand

0

0

2

0

0

0

2

Dom. Rep.

0

0

1

0

0

0

1

Unspecified

1

0

0

0

0

0

1

Total:

47

46

54

18

16

18

199

TRAFFIC North America

31

Export records during the same period show a similar
pattern. Canada accounted for 113 (65%) of the 175 live
Tigers leaving the United States for circus or exhibition
purposes. Exports to Mexico accounted for another 24(14%) of the individual Tigers. Exports to South Africa,
Japan, the Dominican Republic, Cambodia, China, Italy,
Bermuda, Brunei; Malaysia; the UK, and Spain combined
to constitute the remaining 38 (21%) of the total Tigers
involved (TRAFFIC analysis of USFWS LEMIS data,
February 2007 and January 2008).

Figure 5. Exhibition/circus Tigers exported
from the United States by destination,
2001–2006 (Number of Tigers).

38

Table 6 details exports of Tigers from the United States toother countries for circus/exhibition purposes from 2001–
2006; Figure 5 shows the aggregate data in a pie chart.

24

As noted above, with the exception of the 2006 export ofsix Tigers to Spain, all of these records listed the originof the Tigers as being from captive U.S. populations. For
some species, in many cases wild-caught animals arefalsely misidentified as captive-bred. However, there is noevidence whatsoever that this is the case for Tigers.
Furthermore, captive-born Tigers are much more suitablefor zoos, circuses, and private collections, and therefore
there is no reason to think any wild Tigers are falsely
identified as captive-bred in the U.S. trade of exhibitionor circus Tigers.

113
CanadaMexicoOther
Other includes Spain (6), UK (5), South Africa (5), Cambodia (4), China (4), Japan (3),Thailand (3), Malaysia (2), Italy (2), Brunei (2), Bermuda (1), Dominican Republic (1).

Table 6. Exhibition/circus Tigers exported from the United States by destination,
2001–2006 (Number of Tigers).
CountryYear

Total:

2001

2002

2003

2004

2005

2006

Canada

27

25

33

12

16

0

113

Mexico

0

4

11

9

0

0

24

Spain

0

0

0

0

0

6

6

S. Africa

5

0

0

0

0

0

5

UK

0

0

0

0

0

5

5

Cambodia

0

2

2

0

0

0

4

China

0

0

0

4

0

0

4

Japan

0

1

2

0

0

0

3

Thailand

0

0

0

3

0

0

3

Italy

1

0

1

0

0

0

2

Malaysia

0

0

0

0

0

2

2

Brunei

0

0

0

2

0

0

2

Dom. Rep.

0

1

0

0

0

0

1

Bermuda

1

0

0

0

0

0

1

Total:

34

33

49

30

16

13

175

32

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

Tigers recorded as commercial
From 2001 to 2006, USFWS LEMIS data show sevenrecords (two shipments) of Tiger imports for commercial
purposes, all from Thailand, with a total of 16 Tigers(thirteen in 2001 and three in 2004). As with Tigers
involved in the previous category, however, these figures
should be treated carefully.
For example, it is important to keep in mind that
USFWS permit and declaration information should
generally be consistent with regard to the source, countryof origin, purpose, etc. LEMIS data represent
information recorded on the declaration, not necessarilyon the permit. So these LEMIS records reflectdeclarations indicated as commercial, but not necessarily
permits issued for commercial purposes. In addition, thepurpose code on each declaration is a single data point.
It is possible that a shipment can have multiple purposesor species; however, the USFWS declaration form anddatabase allow for only one purpose to be entered foreach entire shipment (C. Hoover, USFWS DMA, in litt.
to D. Williamson, January 2008).
Additionally, as documented above, during the period
2001–2006, the United States exported Tigers to Thailand
for circus or traveling exhibition purposes. It is therefore
entirely possible that the subsequent LEMIS importrecords reflect re-export certificates issued by Thailand
which indicated a purpose of commercial. In fact, the
LEMIS database appeared to show cases where Tigers
were exported for purposes originally entered into thesystem as commercial and then re-imported as circus or
exhibition animals, or vice-versa. USFWS is working tocorrect and clarify such records. It would appear thatwhat may appear on initial examination to involve“commercial” export or import of live Tigers actually
involves U.S. captive Tigers leaving the United States
temporarily for exhibition or entertainment purposes(movie productions, etc.) and then returning (TRAFFIC
analysis of USFWS LEMIS data, February 2007 andJanuary 2008; C. Hoover, USFWS DMA, in litt. to D.
Williamson, January 2008).
Zoological trade
A third part of the trade in live Tigers from 2001 to 2006
involved Tigers imported or exported for zoological
purposes. LEMIS records indicated that such trade is very
limited, with only four records (three shipments)
involving imports and four records (four shipments) ofexports during the period covered by TRAFFIC’s
analysis. In total, the United States imported one Tiger
from Canada in 2002, five Tigers from Malaysia in 2003,

and five Tigers from Canada in 2005 for zoological
purposes. Of these, the five Tigers from Malaysia wererecorded as originating from the wild—these are the only
live Tigers from the wild recorded in LEMIS as being
imported into the United States in any trade category.9
The United States exported for zoo purposes two Tigers
to Brazil in 2001; five Tigers to New Zealand and six toThailand in 2002; and one Tiger to Sweden in 2003. Allof these Tigers were recorded as coming from the U.S.
captive population (TRAFFIC analysis of USFWSLEMIS data, February 2007 and January 2008).
Other live Tiger trade
Beyond these purposes, LEMIS contained only four
records of imports or exports of live Tigers from 2001 to
2006. These included three Tigers imported into theUnited States from South Africa in 2001 for personal
purposes, and in the same year one Tiger imported into
the United States from Mexico for breeding purposes.
The listed origin of all four cats was the U.S. captive
Tiger population, which leads to the assumption thatthese were Tigers that had been previously exported fromthe United States in years prior to 2001 and were now
returning. The United States also exported two U.S.
captive Tigers to the United Arab Emirates in 2004 forbreeding purposes, and seven Tigers to Thailand in 2006
for educational purposes (TRAFFIC analysis of USFWSLEMIS data, February 2007 and January 2008).
Based on all these data, TRAFFIC concluded that
although the trade in live Tigers constituted the vast
majority of legal imports and exports during the years
studied, this trade has very little impact on existing wild
Tiger populations. With the exception of the five Tigers
imported from Malaysia in 2003 for zoological purposes,
this aspect of the international trade almost exclusively
involves captive-bred U.S. Tigers periodically leaving andre-entering the United States on a regular basis forcircus/exhibition or other purposes.
Legal trade in Tiger parts or derivatives
Along with live Tigers, a limited number of Tiger parts orderivatives were legally imported into or exported fromthe United States from 2001 to 2006. These fell into two
broad categories. One category included specimens orparts imported or, to a very limited degree, exported fromthe United States for scientific purposes or biomedical
research. The other included parts imported or exported
for educational, personal, or commercial purposes.
During the period 2001 to 2006, LEMIS records show 12
import records involving imports of unspecified Tiger
specimens for scientific purposes, one record of Tiger

9 These Tigers were taken from the wild under a Malaysian program to remove problem animals from areas of human-tiger conflict and to relocate them into a captive
breeding program. These five Tigers had been in captivity in Malaysia for some time when they were exported to three U.S. zoos for breeding purposes. (Michael
Moore, USFWS, in litt. to TRAFFIC North America. November 27, 2007.)

TRAFFIC North America

33hair imported for the same purpose, and one record of a
Tiger specimen imported for biomedical research. Table 7
shows these imports by description, quantity, and countryof origin.
There were only three reported scientific exports during
the period covered. In 2001, USFWS recorded a legal
shipment of two Tiger claws to Canada for scientificpurposes, and in 2005 three non-specified Tiger specimens
were sent to Singapore. In 2006, the U.S. exported 200g
of unspecified Tiger specimen to the Russian Federation.
The origin for the first two shipments was recorded as
U.S. captive Tigers; the 2006 specimen was recorded asoriginating in Japan (TRAFFIC analysis of USFWSLEMIS data, February 2007 and January 2008).
The final component of legal Tiger trade from 2001 to
2006 involved Tiger parts imported into or exported fromthe United States for educational, personal, orcommercial purposes. Imports for educational purposes
included a Tiger carcass (presumably stuffed) from
Malaysia in 2001, a Tiger claw from Germany 2005, anda trophy from Australia in 2006. Exports included a Tiger
trophy from the United States to the UK in 2005 and a
Tiger claw to Germany in 2006 (possibly the same claw
shown as an import in 2005).
Parts cleared for import for personal purposes included askull from the UK and a trophy from Canada in 2002

(valued at USD2,449 and USD400, respectively), as wellas three skins (two from the UK and one from India) in
2004, and a rug from the UK in 2005. LEMIS records
also showed the legal export of a rug to Canada for
personal purposes in 2005. Commercially, one rug valued
at USD2,995 was imported from the UK in 2001, and acarcass valued at USD1,250 was legally imported fromthe UK in 2003 (TRAFFIC analysis of USFWS LEMIS
data, February 2007 and January 2008).
It should be noted that USFWS permits for personal
imports and exports must certify that the items involved
came from pre-Convention sources (i.e., they werecertified to have come from Tigers that died before Tigers
were listed in the CITES Appendices in 1975). In
addition, the imports cleared as commercial involved
items certified to be antiques (more than 100 years old),which are specifically exempted from certain clearance
and permit requirements, and therefore do not need ESA
permits (C. Hoover, USFWS Division of Management
Authority, pers. comm. to D. Williamson, January 2008).

Illegal international trade
Along with this limited amount of ongoing legal trade,
there is also disturbing evidence of continuing illegal
trade. Available evidence suggests, however, that suchtrade predominantly involves illegal imports for
medicinal purposes. As is described below, there is no

Table 7. Scientific and biomedical Tiger imports, 2001–2006
Year

No. of Records

Description

QuantityCountry or Territory of Export

2001

2

Specimen

203

Thailand2

Specimen

23

Taiwan1Specimen

32

Bangladesh

1Specimen

1

Iran

1

Specimen

9

Cambodia

1

Specimen

127

Russian Federation

2003

1

Specimen

2

Russian Federation

2004

1

Hair

11

Russian Federation

1

Specimen

295

Russian Federation

2005

1

Specimen*

2

Singapore*

2006

1

Specimen

30

Thailand

Total:

13

—

735

—

2002

* The 2005 import from Singapore involved two undefined Tiger specimens imported for biomedical research, with the country of origin listed as Malaysia. With thatexception, the countries or territories exporting these specimens were also recorded as the countries of origin for them.
Source: TRAFFIC analysis of USFWS LEMIS data, February 2007 and January 2008.

34

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

evidence at present that the United States is a source for
Tiger parts entering the international market.
The illegal medicinal trade
TRAFFIC’s review of USFWS LEMIS data from 2001 to
2006 found more than 250 records of illegal Tiger-related
medicinal items being detected and either seized or
abandoned entering the United States. These included
seizures of more than 5,900 individual units ofmedicinals containing Tiger parts or derivatives (orproducts purporting to do so), as well as almost 7,500g
and 450 ml of such medicinals recorded by weight orvolume.10 Table 8 shows Tiger-related medicinal seizuresfrom 2001 to 2006.
The table and Figure 6 below show some clear trends.
For example, China was the country of export for the
overwhelming majority of medicinal shipments
confiscated entering the United States from 2001 to 2006,
accounting for 163 of the 258 total seizures (63%).
Furthermore, unlike the live Tiger trade, in which most of
the trade involved exhibition purposes, LEMIS records
show that the overwhelming purposes of medicinal Tiger
imports were either for personal or commercial purposes.

Of the 258 seizure records, 212 (82%) were listed as
involving imports for personal purposes, while 45 (17%)
listed commercial purposes as the reason for the import.
Only one statistically insignificant seizure involved
another purpose—a shipment of 15 unspecified units ofTiger medicinals imported from China for biomedical
research in 2003. Also, whereas corporations, companies,
or other entities (circuses, film companies, wildlife acts,
zoos, etc.) dominated records of importers and exporters
in the legal trade, individuals overwhelmingly dominatedimports records concerning illegal trade (TRAFFIC
analysis of USFWS LEMIS data, February 2007 andJanuary 2008).
However, available data do not answer significant
questions, and further research is required. For example,
as Table 8 notes, LEMIS data show the countries ofexport for illegal shipments of (purported) Tiger
medicinals seized. The same database indicates that all ofthese shipments came from either wild or unknown
sources, and that the countries of export are also either
listed as the countries of origin for the medicinals, or theorigin is listed as unknown. Yet countries of export/origin
in the database include nations or territories such as

Table 8. Seizures of Tiger-related medicinal imports into the United States, 2001–2006.
Year

No. of Seizures

No. of Units

Exporting Countries or Territories (no. of seizures)

2001

68

1,881 +
12 g

China (59); Viet Nam (2); Thailand (1); Cambodia (1);
Malaysia (1); Hong Kong (1); Philippines (1);Unspecified (2)

2002

58

896

China (50); Viet Nam (2); Thailand (2); South Korea(1); Cambodia (1); Hong Kong (1); Unspecified (1)

2003

18

392 +
5,087 gChina (13); Viet Nam (1); South Korea (1);Cambodia (1); Unspecified (2)

2004

11

59 +
450 mlChina (6); Viet Nam (1); Thailand (5); Hong Kong (1);Cambodia (1); Unspecified (2)

2005

43

1,134 +
1,200 gChina (19); Viet Nam (12); Thailand (5); Hong Kong (1);Japan (2); South Korea (1); Unspecified (3)

2006

60

1,583+
1,200 gViet Nam (31); China (16); Laos (5); Unspecified (3);Hungary (1); Taiwan (2); South Korea (1); Japan (1)Total:

258

5,945 +
7,499 g +450 mlChina (163); Viet Nam (49); Thailand (13);Lao PDR (5); Hong Kong (3); South Korea (4);Japan (3); Taiwan (2); Malaysia (1); Philippines (1);Hungary (1); Unspecified (13)Source: TRAFFIC analysis of USFWS LEMIS data, February 2007 and January 2008.

10 It should be noted that, because of the way seizures are recorded in LEMIS, the number of units indicated is an absolute minimum. A seizure recorded as a single unit
could be either one vial of Tiger bone or one box of such vials. For example, TRAFFIC noted one seizure recorded as a single unit that was in fact composed of 11
Tiger plasters. These data should be interpreted accordingly.

TRAFFIC North America

35Figure 6. Number of seizures of Tigerrelated traditional medicine imports into
the United States by country or territory,
2001-2006
20
13
13

49

163

Other surveys in the late 1990s, summarized in Nowell(2000), showed that Cambodia, Indonesia, Lao PDR,
Myanmar, and Viet Nam were also significant supply
markets for live Tigers and Tiger parts, especially bones.
Cambodia, Myanmar, and Lao PDR were singled out ascountries with very limited local consumption of Tiger
parts. Hunting and trade in these countries was believed
to be commercially driven, catering to foreign markets
primarily in China, Viet Nam, and Thailand.

China
Viet Nam
Thailand
Unspecified
Other
Other includes Lao PDR (5), Hong Kong (3), South Korea (4), Japan (3), Taiwan(2), Malaysia (1), Philippines (1), Hungary (1).

Japan, South Korea, Hong Kong, and in one case even 11
Tiger plasters imported from Hungary, none of whichhave wild Tigers (TRAFFIC analysis of USFWS LEMIS
data, February 2007 and January 2008).
These glitches occur because in collecting wildlife tradedata, key source and trade information is not likely toaccompany illegal goods. Though the country ofexport/re-export is generally available, country of origin
information is not, nor is information on the actual sourceof the wildlife. Wildlife inspectors therefore begin with apresumption that wildlife is of wild origin unless there isinformation that suggests another source. Often, if thecountry of origin is unavailable, that data point in LEMIS
is completed with the same information as the country ofexport. Though this is often a safe assumption, it isobviously problematic when the wildlife in question does
not occur in the country of (re-)export (C. Hoover,
USFWS DMA, in litt. to D. Williamson, January 2008).
For example, previous studies by TRAFFIC and others
indicate that a significant proportion of Tiger bone andother products found in China likely originate from wild
Tigers in other range States. As Nowell and Xu (2007)36

noted, in the latter half of the twentieth century China
went from being one of the range States with the mostTigers to the range state with the least, because of humanpopulation growth, habitat loss and fragmentation,
depletion of the Tiger’s wild prey base, and intensive
hunting from the 1950s to 1977 of Tigers as pests,
including the payment of government bounties for skinand bones. The number of wild Tigers in China now iswell under 50 (IUCN SSC Cat Specialist Group, 2008).
A review of Chinese CITES data also found that thesource of big cat products seized in China include not
only China itself, but also Myanmar, Nepal, and theRussian Federation among Tiger range States. Althoughnone of the seizures were reported to have originated inIndia, China is believed to be the destination country forbig cats taken in India and Nepal. Because India and
Nepal are not traditional consumers of Tiger bone, suchbone seized in those countries is likely destined for China(Nowell and Xu, 2007).

Therefore, for purposes of this study, it is important tonote that while China overwhelmingly dominates thenumber of LEMIS records showing the country of exportof medicinal products derived from Tigers that are seizedentering the United States, there is no way to determine
the actual source country of the Tiger bone or otherderivatives involved. The same is true of the Tiger
medicinals from South Korea, Hong Kong, Japan, or anyof the other countries or territories listed. This appears to
be a fairly fluid cross-border trade.
A second unanswered question involves the commercial
value of the trade in Tiger medicinals. An accurate
calculation proved impossible to obtain for two reasons.
For one, calculating the overall value of the illegal importtrade of Tiger medicinals cannot be done because
USFWS records show only products that have been
detected and seized, not those which successfully enterthe United States. Poaching and trade in Tiger products iscovert, and like the illegal drug trade, seizures may
represent only a fraction of what the total trade may be(Jackson, P., in Nowell, 2000). As is explained below,
some of the methods being used to smuggle wildlife parts
such as Tiger medicinals internationally (including into
the United States) make the trade very hard to detect, andits full scope remains unknown.

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

For another, LEMIS data record the declared value of
wildlife shipments cleared or seized. However, asignificant proportion of the LEMIS records show no
declared value. For example, in 2001 the 1,881 units and
12g of Tiger medicinals seized by USFWS had anaggregate recorded value of USD2,064. Yet that figure
included financial information on only 57 of the 68
seizures. Eleven others, making up 772 of the total unitsof medicinals seized, had no declared value, including asingle seizure of 680 unspecified units identified as Tiger
medicinals recorded as being imported for commercial
purposes. Similarly, in 2003, only 15 of the 18 recorded
seizures included monetary estimates of the value of the
products. Missing from these data was any estimate of
the value of the 5,087g of Tiger medicinals seized in thatyear (TRAFFIC analysis of USFWS LEMIS data,
February 2007 and January 2008).
This inconsistency in the data reflects the fact thatdeclared value is generally not a data point provided by
the importer or exporter of illegal wildlife. Therefore, if avalue is assigned, it is generally assigned by theenforcement officer involved in the seizure. Such value
may be based on documents accompanying the wildlife,
past experience with these products, or some other basis.
Further, current USFWS practice is to assign zero value
to wildlife that is prohibited from sale in the UnitedStates, explaining why many of the records showed novalue (C. Hoover, USFWS DMA, in litt. to D.
Williamson, January 2008).
A third question that remains unresolved is whether
seized imports of medicinal products purporting tocontain Tiger bone or other derivatives are real or fake.
Although it is not a major focus of this report, it should
be noted that numerous previous studies have shown thata significant percentage of products advertised as Tiger
bone or other products in internal domestic markets in
Asia and international trade are either fake or so diluted
as to be virtually undetectable (see: Gaski and Johnson,
1994; Mills and Jackson, 1994; Mills, 1997; Gaski, 1998;
Nguyen et al., 1999; Petrar, 1999; Sellar et al., 1999;
Hemley and Mills, 1999; Nowell, 2000; Nowell and Xu,
2007). For purposes herein, it should be made clear that,
under the RTCA amendments of 1998, import, sale, ortrade of medicinals or other products purported to containTiger products is illegal whether or not actual Tiger boneor other derivatives are present.
A fourth question involves whether the Tiger medicinals
being seized are intended for commercial or personal
purposes. LEMIS records that show one or the other ofthese purposes in the seizure data reflect the judgment of

the law enforcement personnel involved in eachindividual case. The data recorded in LEMIS that reflect
this input may very well be accurate. However, TRAFFIC
noted that in some cases, seizures of substantial amountsof Tiger medicinals were recorded as being imported for
personal purposes, while in other cases very small
amounts (sometimes one or two units of insignificant
monetary value) were recorded as being imported forcommercial purposes. Because logic would seem to
dictate the opposite, that large shipments of multiple units
would more likely be for commercial purposes and small
shipments for personal use, TRAFFIC concluded that it
was impossible to determine definitively how manyseizures represented commercial versus personaldestinations in the United States (TRAFFIC analysis of
USFWS LEMIS data, February 2007 and January 2008).
A fifth and final question regards the emergence of Viet
Nam as a significant source of seized Tiger medicinals in2005 and 2006. As was shown in Table 8, whereas theperiod from 2001 to 2004 saw a combined total of only
six seizures exported from Viet Nam, in 2005 there were
12 seizures, and in 2006 31—more than half of the total
for that year. Although there is not enough data to
determine whether this represents a short term anomaly
or an emerging shift in the illegal trade stream (or why it
may be occurring), it bears watching by law enforcement
agencies and those focused on Tiger conservation(TRAFFIC analysis of USFWS LEMIS data, February
2007 and January 2008).
Illegal imports of non-medicinal parts and derivatives
Beyond medicinals, LEMIS data show 28 seizure
records11 of other Tiger parts and derivatives, involving 51
individual items. The majority of these records (15) show
the seizure of Tiger claws or teeth; other items included
rugs, skin pieces, trim (garment or decorative), jewelry,
specimens, a trophy, a Tiger penis, and one unspecified
shipment. Table 9 details the items seized, by year.
Unlike the seizure of medicinals (or purported
medicinals), no single country or territory stands out inthe data as a primary source of these parts or derivatives.
For example, claws and teeth were seized entering theUnited States from Malaysia, Taiwan, Laos, Nigeria,
Cambodia, India, and Viet Nam. Rug seizures included
shipments from France, the UK, and Argentina (twoseizures, including a rug valued at USD100,000 in 2002).
Tiger skins or skin pieces were seized entering the UnitedStates from Canada and China. Other seizures included
an item of jewelry from India in 2003; a trophy fromSingapore in 2004; 2 unidentified specimens from11 As with imports of live Tigers, seizure records may differ from the number of shipments seized. For example, if seizures of claws and teeth from the same sources (inMalaysia and Taiwan in 2001, and Nigeria in 2002) are combined, there may only have been 26 seizures during the period examined, 12 (50%) of which involved claws
or teeth.

TRAFFIC North America

37

Table 9. Import seizures of non-medicinal Tiger parts/derivatives, 2001–2006
Part/DerivativeYear

Total:

2001

2002

2003

2004

2005

2006

Claws

7

1

4

0

0

3

15

Teeth

11

0

1

4

0

3

19

Rugs

1

1

1

0

1

0

4

Skins/Pieces*

1

0

0

0

0

0

1

Trim

0

5

0

0

1

0

6

Jewelry

0

0

1

0

0

0

1

Trophies

0

0

0

1

0

0

1

Specimens

0

0

0

0

2

0

2

Genitalia

0

0

0

0

0

1

1

Unspecified

1

0

0

0

0

0

1

Total:

21

7

7

5

4

7

51

Source: TRAFFIC analysis of USFWS LEMIS data, February 2007 and January 2008.

Australia in 2005, a Tiger penis from Viet Nam in 2006;
and an unspecified import from China in 2001. However,
TRAFFIC did note that, as with medicinals, Viet Nam
emerged as a source of such parts only in 2006, at theclose of the period examined (TRAFFIC analysis of
USFWS LEMIS data, February 2007 and January 2008).
Illegal exports of Tiger parts from the United States
Missing from the LEMIS data is any evidence that the
U.S. captive Tiger population is playing a role in thisillicit international trade. While there have been a few
cases within the United States of individuals charged withselling Tigers or parts (primarily skins and meat) from
U.S. Tigers contrary to the ESA and the Lacey Act,
TRAFFIC noted that LEMIS data did not show a single
seizure of Tiger parts being illegally exported during theperiod 2001 to 2006 (TRAFFIC analysis of USFWSLEMIS data, February 2007 and January 2008).
This might be explained by the fact that the United States
gives more scrutiny to people and goods entering theUnited States than it does to people and goods leaving thecountry. However, TRAFFIC noted a couple of factorsthat would seem to indicate that the U.S. captive Tiger
population is not a real factor in the international market
for Tiger parts. For one thing, although it is possible thatthe absence of seizure records of exports could mean thatthey are simply not being caught, previous TRAFFIC
investigations into other CITES-listed species found that38

the United States was in fact catching some illegal
exports of bear parts, caviar from North American
sturgeon and paddlefish, and elephant ivory, even thoughthese items can also be transported in small quantities by
individual travelers (Williamson 2002; Williamson 2003;
Williamson 2004). How it is that these items are detected,
while there are no records of seizures of Tiger parts, may
indicate that the United States really is an importer rather
than a supplier of Tiger bone for medicinal purposes.
It is also important to note that China, which has
become more aggressive in recent years in combatingillegal trade in Tiger parts, has not indicated the UnitedStates as a source country for Tiger parts seized. As wasnoted above, China reported to CITES in late 2006 thatmajor source countries for illegally imported Tiger parts
were other Asian nations, not the United States. There isno evidence of other Asian or non-Asian consumer
nations reporting quantities of Tiger bone or other parts
coming from the United States. If the United States is
not detecting Tiger parts leaving the country, and China
and other nations involved in manufacturing andconsuming Tiger medicinals and other parts are notdetecting shipments coming in from the United States, aplausible conclusion is that the U.S. captive Tiger
population is not at present a real factor in theinternational trade. However, the possibility that isolated
incidences of such trade may have occurred undetectedmust be acknowledged.

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

Illegal domestic trade
As LEMIS seizure records of Tiger medicinals (orpurported medicinals) entering the United States show,
there is no doubt that the United States remains a market
for illegal Tiger products. Several previous TRAFFIC
studies have also shown this. For example, in a study
published in 1998, 18% of TCM users surveyed in the
United States indicated having used Tiger bone either
sometimes or rarely (Lee et al., 1998). A 2000 study on
the Tiger trade showed the United States as a non-range
consumer state for Tiger bone pills, plasters, wine, andgel (Nowell, 2000). And a 2004 study of TCM markets inthe cities of San Francisco and New York showed that,while availability was in decline, medicines claiming tocontain Tiger bone could still be found in TCM shops inboth cities (Henry, 2004).
There have also been troubling examples of U.S. captive
Tigers being killed or traded for domestic purposes. For
example, an 18-month, multi-state, covert investigation
known as “Operation Snow Plow” led to the prosecution
and conviction from 2001 to 2003 of 16 individuals andone business for the buying, selling, and slaughter of
exotic cats, including 19 Tigers. Subjects from 13 states
identified in the investigation included exotic animal
exhibitors and dealers, taxidermists, trophy collectors, agame and seafood company, and an exotic meat dealer inIllinois who bought and sold Tiger meat mislabeled aslion. Most of the endangered cats originated from USDAlicensed exhibitors and dealers who unlawfully sold thecats and then provided documentation that thetransactions were “donations”. Parts from the Tigers
identified in the case included meat, skulls, gallbladders,and numerous skins sold to trophy collectors for display(Federal Wildlife Officers Association [FWOA], 2003).
In 2005, a husband and wife were convicted andsentenced to 18 and 15 months in prison, respectively, forfalse labeling of endangered and threatened animals,
including Tigers. The couple had advertised their interestin buying, trading, and selling live exotic wildlife,
including Tigers, through the Internet and publications.
The investigation identified sources and customers in 19
states, including the above-mentioned Tiger found in anapartment in the Bronx, New York. At the same time, thecouple was soliciting donations, memberships, and othersponsorships for the care of the animals in an animal
sanctuary, neglecting to disclose the regular purchase andsale of the animals as part of a commercial enterprise(U.S. Department of Justice [USDOJ], 2006a; Big Cat
Rescue, 2005; FWOA, 2004).
And, in 2006, an individual was sentenced to 25 months
in prison and three years supervised release for sellingand offering for sale in interstate commerce more than

TRAFFIC North America

USD200,000 worth of endangered species, including
Tigers. The investigation that resulted in the arrest
originated from an unsolicited e-mail to a USFWS officer
offering “cat skins” for sale. The agent was able topurchase Tiger, Snow Leopard, and Leopard skins fromthe defendant (USDOJ, 2006b).
These appear to be fairly isolated cases, rather than
indicators of widespread trade in parts from U.S. Tigers.
In addition, there is no indication that these activities
involve the export of Tiger parts from the United States.
In each case, the parts in trade appeared to involve trophy
items such as skins and skulls, or meat for consumption,rather than Tiger bone for the medicinal trade. Available
evidence suggests that the U.S. market for medicinals
derived (or purported to derive) from Tiger bone continue
to be supplied from outside the United States. It should
not be implied, however, that no illegal trade involving
captive U.S. Tigers may be occurring. It cannot be ruledout that there is some activity that has simply not yet
been detected. Nevertheless, the fact that there have beenno export seizures in recent years, and no evidence of aconsistent pattern of illegal trade in Tiger parts, strongly
suggests that any such undetected activity is likely to be
fairly isolated in nature.
However, as TRAFFIC’s visit to Florida demonstrated, itshould also be noted that the prevalence of unwanted
Tigers in some U.S. states, the expense involved forowners in keeping these animals alive, and the fact thatneither the federal government nor states generally
monitor what happens to these animals and their parts
after they die means that there is a potential supply ofTiger parts being generated in the country. As discussed
in the next section, the relatively low price of live Tigers
in some parts of the United States, combined with highprices for Tiger parts in Asia, may come to provide an
incentive to illegally export U.S. Tiger parts. Gaps in the
U.S. regulatory and management system for captive
Tigers, therefore, have possible implications for illegal
trade and efforts to conserve the world’s remaining wild
Tiger populations.

Implications for wild Tiger
conservation and CITES
The current management system governing the U.S.
captive Tiger population is a cause for concern, and theUnited States needs to take further actions to tighten
controls. At present, available evidence suggests that thecontribution of the U.S. captive Tiger population to theillegal international trade in Tiger parts remains a
potential issue rather than a current crisis. Recent years
have seen no documented cases of parts from U.S. Tigers
entering international trade (seizures of exports, arrests orlaw enforcement cases related to international smuggling

39

PHOTO © WWF-CANON / EDWARD PA

of U.S. Tiger parts, etc.). Left
unaddressed, however,continuing lax management of
the U.S. Tiger population
could have global trade
implications, as U.S. Tigers
entering the illegal
international market have thepotential to act as a drip-feed,
keeping demand alive andadding to pressure on wild
Tigers. Increasing illegal
supply into markets for Tiger
products will lead to theresumption of a demand thatmany governments, traditional
medicine practitioners,
conservation organizations andothers have worked decades tosuppress in the interest ofsaving the world’s remaining
wild Tigers.

Wild Tiger populations are threatened by demand for their skins and for their parts, many of which areused in traditional Chinese medicines such as this Tiger bone plaster. These plasters are still being
seized coming into the United States, even though they are completely illegal.

The possible role of captive
Tiger populations in theinternational Tiger trade is an issue receiving considerable
and justified attention among the Parties to CITES. Most
immediately, there has been much discussion about thepossible implications of proposals in China to allow
domestic trade in medicines made from captive-bred Tigers.
There are believed to be more than 5,000 Tigers on
China’s commercial Tiger farms, where the cats are being
bred intensively and the population may be growing by as
many as 800 Tigers per year (CITES, 2006; Nowell,2007). The government of China implemented a domestic
Tiger trade ban in 1993; this ban is worthy of praise, andhas been a major positive factor in the continued
existence of Tigers in the wild. Tiger farm owners,
however, have asked the Chinese government to allow the
body parts of these farmed Tigers to enter into trade.
They argue that the current ban on all trade in Tiger
products has failed to conserve wild Tigers and protect
public health. In 2006, Chinese Tiger farm operators andadvocates suggested that a supply from 100,000 farmed
Tigers in the next 10 to 15 years could produce up to
10,000 Tiger carcasses per year. The Tiger farm owners
and their supporters believe that China’s internal demand
could be met by Tiger bone from these farmed animals(National Geographic, 2006).
Rebutting that argument, conservationists and otheropponents of these requests (including many in the TCM
community) point out that poaching of wild Tigers would
almost certainly continue even if such an alternative supplyof Tiger parts became available, and in fact would likely

40

increase. There is already an alternative source of supply,in that an indeterminate but likely significant proportion of
products labeled as containing Tiger bone at present may
be fake. Yet clearly poaching of wild Tigers continues tooccur. Many consumers prefer parts of wild Tigers, which
they believe to be more potent. Also, given that raising a
farmed Tiger to maturity is 150–200 times as expensive as
poaching a wild Tiger, poaching will continue to be themore attractive and profitable alternative in supplying any
demand for Tigers and their parts (R. Damania, World
Bank, in litt. to L. Henry, January 2008). It is therefore too
risky given the precarious state of remaining wild
populations to take any actions that may expand the market(Nowell and Xu, 2007).
Similar arguments could be made as to how the presenceof a large captive Tiger population in the United Statesmight affect, and in turn be affected by, market conditions
should China decide to re-open a domestic market for
Tiger parts. If demand for Tiger parts rises in Asia, or
indeed internationally, because China reopens its
domestic market, two scenarios can be surmised. In thefirst, it could be argued that the ready availability of Tiger
parts from Chinese Tiger farms might not stimulate
economic incentives to try to exploit U.S. captive Tiger
populations for international trade purposes, or even for
the U.S. domestic market. With a ready, legal supply ofTiger parts available domestically, it may not prove
economically attractive to exploit and smuggle Tiger
parts from the United States to Asia or other markets.

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

In a second scenario, the stimulation of significant further
demand in Asia could raise the price of Tiger parts highenough that seeking parts from Tigers in the UnitedStates or elsewhere becomes attractive. Given the size of
China’s population, domestic Tiger farms may not be able
to meet demand. Furthermore, given that those seeking
the Tiger parts would not have to pay to raise, feed, andcare for the cats themselves—an expensive proposition—
parts of Tigers from surplus captive populations such as
those present in the United States could become cheaper
to try to obtain.
Under either scenario it appears likely that the greatest
consequences of increased demand or consumption ofTiger parts in Asia or elsewhere would fall on remaining
wild Tiger populations whose numbers are too low tosustain even more poaching; wild Tigers cannot take therisk of any reopening of trade. Whether or not demand
for Tiger parts rises enough that the U.S. population
becomes a target for those who might seek to exploit itfor illegal international trade, poaching of wild Tigers
today remains the cheapest, and therefore most profitable,
source of bone, skins, meat, and other products for themarket. The key for the survival and possible recovery ofremaining wild Tiger populations would therefore seemto lie in continuing efforts to dampen demand for Tiger
parts, reduce human/Tiger conflicts, and enhance habitat
conservation and other in situ conservation efforts.
There is, however, one scenario of particular concern. Thatwould be that the continuing decline of remaining wild
Tiger populations makes the U.S. captive Tiger population
an especially attractive target for those involved in illegal
trade, particularly given the large number of unwanted
U.S. Tigers described earlier in the report.

further and enforcement efforts rally around the few
remaining Tigers in the wild.
A point may be reached—soon if not already—when acriminally minded individual may consider theopportunity costs of selling parts from U.S. captive Tigers
worth the risks of detection, capture, and prosecution. It
cannot be explained why this phenomenon has not alreadybeen seen. It is possible that it is not yet economically
viable. It is possible that the risks of detection and federal
prosecution under statutes such as the ESA, Lacey Act,
RTCA, and other statutes provide an effective deterrent. It
is possible that, as TRAFFIC heard anecdotally frommultiple sources, most U.S. Tigers in captivity remain
held by people who love the cats and would notcontemplate such activity. It could be some combinationof these factors, or others not contemplated here.
Whatever the reasons, it must be made clear that any useof U.S Tigers to feed international demand is illegal, andtherefore would also be an intermittent, unreliable supply.
This population should therefore not be looked to as any
form of viable alternative to feed international ordomestic demand for Tiger parts. Additionally, it seems
highly unlikely that the United States will reverse its
historic position and legalize any trade in parts andderivatives from U.S. captive Tigers. This is clear fromthe United State’s leadership in June 2007 at CITES
CoP14 to insert strong language on domestic tradecontrols and against intensive breeding of and trade from
captive Tiger populations, which resulted in CITES
Decisions 14.66 and 14.69 (CITES, 2007f).

According to the IUCN/SSC Cat Specialist Group, there
may be as few as 2,500 breeding Tigers left in the wildand, notwithstanding some locally successfulconservation efforts, we are not seeing major signs ofrecovery. While parts of wild Tigers are likely always tobe preferred in traditional medicines, and poachingremains a cheaper option to farming Tigers or seeking
those in captive populations, the situation could change.
The relationship between poaching effort and risk may
shift, for example, should the transaction costs ofpoaching increase if wild Tiger populations decrease

TRAFFIC North America

PHOTO COURTESY SYBILLE KLENZENDORF

It is arguable when the point may come—or if, in fact, it
has already been reached—that the price is right to makethe killing of U.S. captive Tigers and selling their partson the international market economically attractive.
Evidence of ongoing sales of Tiger tonics and otherproducts in China, potential increased demand asaffluence in China rises, and the growth of production,
trade and consumption in other markets such as Viet Nam
are ominous signs.

Captive Tigers on a Tiger “farm” in China. China now has the largest
population of captive Tigers in the world, surpassing that of theUnited States.

41

Regardless, there is the concern that, given the risks, gaps
in existing regulations, monitoring, and reporting on U.S.
captive Tiger populations could become very
problematic. The United States at present cannot evenaccount accurately for how many Tigers are in the
country, much less what happens to the parts of Tigers
that might either die of natural causes or be killed.
As noted, this issue of the potential impact of the U.S.
Tiger population in the international marketplace, and of
the international marketplace on the U.S. Tiger
population, remains speculative. That said, the UnitedStates has two options. One is to maintain the status quoand leave the present regulatory system in place. Such acourse might seem attractive given the uncertain nature of
the trade threat and the paucity of financial and otherresources for enhanced enforcement measures at both thefederal and state levels.
The second is for the United States to take a proactive
position. This second course would require addressing thedisconnect between federal laws which regulateinternational and interstate trade, and state laws whichlargely focus on issues of animal care, welfare, andhuman safety. It would involve more closely monitoring
the breeding, keeping, and sale or disposition of live
Tigers, and the fate of Tiger parts post mortem. It would
entail further enhancing U.S. efforts to educate the publicboth in the United States and abroad to reduce demand
for Tiger-based medicinals or other products. It would
mean further enhancing law enforcement efforts tocombat illegal trade. And, finally, it would necessitate
reaching out to representatives of conservation NGOs,
zoos, responsible animal sanctuaries, circuses, and others

42

involved with these cats to create a framework, both legal
and voluntary, to better manage and monitor U.S. Tigers
and prevent their entry into illegal trade.
The second course seems wiser. Although evidence of adirect trade threat regarding the U.S. Tiger population
may appear prospective, there is no denying that wild
Tiger populations continue to suffer losses. Absent an end
to market demand for Tiger parts or derivatives—not onlyin Asia but in North America and other markets as well—continued dwindling of wild Tiger populations can only
increase incentives for those involved in illegal trade tolook at captive Tiger populations such as the one extant
in the United States. While any impact of U.S. Tigers inillegal trade on wild populations remains speculative, andno one can say for certain what that impact would be,
TRAFFIC maintains that it would most likely be
negative, and that wild tiger populations are at such a
critical juncture that such risks simply cannot be taken.
As one of the leading voices among CITES Parties forstrong, comprehensive measures to reduce threats to
Tigers in the wild and promote their conservation andrecovery, the United States has an obligation to put its
own house in order on the subject.
Therefore, the United States must take a proactive
position on the issue of shutting down avenues for illegal
Tiger trade domestically as it has internationally. There
are specific actions the United States should take now to
insulate the U.S. captive Tiger population against thepotential threat of illegal international trade, and tofurther establish itself as a leader in international Tiger
conservation. To that end, TRAFFIC presents thefollowing conclusions and recommendations.

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

CONCLUSIONS AND RECOMMENDATIONS
Conclusions• Despite some progress in conservation efforts, thenumber of Tigers remaining in the wild has continued
to dwindle in recent years, from an estimated 5,0007,000 in the late 1990s to as few as 2,500 mature
breeding adults currently. Expanding humanpopulations, habitat loss and degradation, and depletionof the prey base all pose ongoing threats to the survivalof wild Tigers in Asia. Especially dire, however, is thethreat posed by commercial poaching and trade for
medicinals and other parts and derivatives used for
TCM, clothing, and ornamentation.
• All Tiger subspecies are listed in Appendix I of CITES;
commercial international trade in Tigers or their partsor derivatives is prohibited. Enforcement of CITES,
however, is the responsibility of member Parties, andthe record of compliance with CITES Decisions andResolutions remains uneven in Tiger range States.
• Markets continue to exist in Asia and elsewhere for avariety of Tiger products and derivatives, includingbone and bone derivatives, tonics, meat, skins, andother trophy or souvenir items. While most genuine
Tiger products likely come from the poaching of wildcats at present, TRAFFIC and others are concerned
about the potential impact of China’s proposal to reopen a domestic market for Tiger derivatives fromcommercial Tiger farms. With the emergence of thesefarms, it is believed that China now claims the world’s
largest captive Tiger population. Re-opening of any
legal trade in Tiger parts carries potential implications
not only for wild Tigers but also for captive Tigers heldin other countries.
• With a rough estimate of some 5,000 Tigers in
captivity, the United States now likely ranks second
behind China as the country with the single largest
Tiger population. Although the United States has nocommercial Tiger farms, all of these cats are held in
captivity. Unfortunately, U.S. laws and regulations
governing the keeping of these Tigers are not currently
adequate to foreclose the possibility that parts orderivatives from these animals could enter illegal trade.
• The United States has a strong legal framework at thefederal level governing international trade in Tigers or
their parts through the ESA, the Lacey Act, and the
Criminal Code. The RTCA, as amended in 1998,
further prohibits any domestic sale of Tiger parts, aswell as the sale of any products labeled or advertised tocontain Tiger parts.
• Through the AWA, the CWSA, and the USFWSTRAFFIC North America

registration and permit system for captive-bred
wildlife, the United States also has a federal legal
framework governing the interstate movement of
captive Tigers, rules for the sale, trade, or exhibition oflive Tigers, and conditions for their confinement. All ofthese laws and regulations, however, have exceptions or
exemptions that mean, in practical terms, that the
majority of private owners of Tigers in the UnitedStates need to simply keep records of Tigers held.
While such records must be made available uponrequest or inspection, federal agencies charged with
implementing these laws and regulations do not have amandate to maintain a current inventory of how many
Tigers may be in the country, where they are, whopossesses them, when they die, or how they aredisposed of.
• At the state level, laws and regulations governing the
keeping of Tigers in private possession vary widely. Asof 2007, 26 states have laws banning the possession ofTigers in private collections, 16 states allow for the
keeping of Tigers by individuals but require a statepermit or registration, and nine states have no laws on
the subject. Furthermore, requirements that owners of
captive Tigers register or report their cats to stateauthorities are inconsistent; a number of states have
either no reporting requirements or have laws andregulations that do not account for all Tigers present.
• Given that the vast majority of U.S. captive Tigers
reside in private hands (individual or other), and thatmany of these cats reside in states that do not havelaws or regulations requiring close monitoring or
scrutiny, it proved impossible to accountcomprehensively for all captive Tigers in the country.
Furthermore, there is no comprehensive legislative or
regulatory system in existence at the federal or statelevel to document how many Tigers are being bred orborn each year, how many may die (naturally orotherwise), or what happens to Tigers or their parts
when the animals do perish.
• This finding is consistent among all of the primary
U.S. captive Tiger populations—AZA facilities,
USDA-regulated Tigers, sanctuaries and refuges, andindividual collections or pets. In some cases, even thesecategories can be deceptive. Depending on theactivities of the Tiger owners, sanctuaries or refuges
may be USDA-regulated, yet in some cases haveactively engaged in the breeding and/or selling ofTigers or their parts, legally or illegally. As the casestudy regarding Florida also showed, in somejurisdictions private possession of Tigers is43

illegal except for commercial purposes.
• There are no national statistics available to document
how many Tigers may die annually in the UnitedStates. Because so many Tigers are unregulated, lifespans vary widely between different populations.
Tigers in commercial operations may regularly crossstate borders or be moved between facilities, and someTigers may be disposed of because they are no longer
economically viable or owners simply do not wantthem, determining an accurate rate of annual nationalmortality is for practical reasons impossible. When
Tigers do die, potential disposal costs vary, ranging
from practically nothing if the owner simply buries thecat privately, to approximately USD500 for cremation,
to potentially much more if the animal is either buried
in a special cemetery or mounted.
• There thus exists a potential supply of Tiger parts being
generated within the United States that could reachillegal markets. To date, there is no evidence that parts
from such Tigers are entering illegal international trade.
Available evidence further suggests that the U.S.
domestic market for Tiger parts is being fed from
Asia—and China in particular—and consists mostly of
medicinal products, be they real or fake.
• There have been cases of U.S. Tigers in illegal
domestic trade, but these have been fairly rare andinvolved primarily parts such as skins and meat rather
than Tiger bone for medicinal purposes.

indicates that there are potentially hundreds of mature
unwanted Tigers in private possession or captive U.S.
facilities in any given year.
• Should demand for Tiger parts rise to a level where theU.S. captive Tiger population becomes a serious target
for individuals involved in the parts trade, the potential
implications for conservation of remaining wild Tiger
populations could be grave. Preventing such an
outcome needs to be raised as a priority, including thefollowing steps.

Recommendations
TRAFFIC recommends that the United States take steps
on the legal, regulatory, oversight, educational, and law
enforcement fronts to better track the U.S. captive Tiger
population and ensure that these animals or their partscannot enter illegal trade. The specific, directed
recommendations below outline ways in which this could
be undertaken.
TRAFFIC’s first set of recommendations applies
primarily to actions needed at the federal and, especially,
state levels to improve the monitoring and oversight ofTigers in the United States. State and federal agencies
tasked with regulating these animals need to better track
their whereabouts, reproduction, and ultimate disposition;
NGOs may be able to assist in this effort. Specifically:• As noted above, USFWS data show an ongoingproblem with the attempted smuggling of medicinal
products (or purported products) derived from Tiger
bone into the United States. It proved difficult todetermine whether such shipments were commercial or
personal in nature, but there clearly remains a market
for illicit Tiger products.

• At the federal level, exceptions to rules that exempt
certain categories of captive U.S. Tigers from
regulation need to be rescinded. USFWS should issue
new regulations removing the exemption for “generic”
or inter-subspecific crossed Tigers under the agency’s
Captive-Bred Wildlife Registration system. As thisreport shows, it is believed that most Tigers in the
United States are generic and thus exempt from the
CBW registration system. Rescinding the exemption
would require that many more persons and facilities
holding captive Tigers would have to report annually
their year-end inventory of Tigers and activities
conducted with the cats, thereby exponentially adding
to current knowledge of the number, whereabouts, anduses of the U.S. captive Tiger population.

• However, the fact that state laws and regulations
governing U.S. captive Tigers focus on the dangerous
nature of live animals and their humane treatment,
rather than their potential as a source of parts for trade,means that not enough attention is being paid to thislatter issue. Federal laws and regulations are stronger,
yet the exceptions and exemptions within them meanthat the agencies tasked with implementing theirrequirements also do not know where captive U.S.
Tigers actually reside.

• USDA, through the APHIS Animal Care program,should also require that all persons or facilities holding
USDA licenses for exhibition or breeding/dealing in
Tigers report annually on the number of Tigers held,
births, mortality, and transfer or sale (including both“in house” transfers from one facility to another owned
or managed by the same person or entity, and the nameand location of outside buyers/recipients). This
information should be kept in a distinct database, madeavailable for public review.

• Furthermore, TRAFFIC’s research for this project• Furthermore, all U.S. states that allow private citizens• There are also records of ongoing legal imports andexports of Tigers into and out of the United States. The
vast majority of such trade, however, involves live captivebred U.S. Tigers leaving and subsequently re-entering thecountry for exhibition (circus, etc.), entertainment,
zoological, educational, or breeding purposes.

44

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

to keep captive Tigers must enact laws or regulations
that require a comprehensive accounting of the number
and location of all captive Tigers in their jurisdictions,
whether they are pets, used for commercial or exhibition
purposes, sanctuary animals, or other. Record-keeping at
a minimum should include information on the numberof Tigers, their locations, owners, births, and deaths.
State laws should also clearly ban any breeding ofTigers in facilities that are not USDA-licensed andregistered under the USFWS CBW system (as amended
above to include all Tigers, not just those that can beproved to be pure-bred).
• Such record-keeping must account not only for live
Tigers, but also for the disposal of Tigers and theirparts when they die. Agencies tasked with regulating
U.S Tigers (federal or state) should require that all
Tiger deaths be immediately reported, with a further
requirement that the carcasses be disposed of throughprompt cremation by a licensed facility, with
documentation of the incineration provided to theregulatory body. In that way, state and/or federal
authorities would have a mechanism to ensure that the
Tigers’ parts do not disappear into illicit trade.
• State and/or federal agencies tasked with regulating
Tigers should further require that all Tigers in the
United States be implanted with microchips containing
information on the animal’s license or permit number,age, sex, and other identifying information. A hairsample also needs to be provided from every Tiger as areference should DNA analysis need to be performedon the animal, its carcass, or subsequent parts andderivatives. Furthermore, because each Tiger has
unique markings, Tiger owners should be required toprovide a digital picture every year or two to confirm
each Tiger’s identity visually. These pictures could becompiled into a database kept by regulatory authorities
to ensure that they have a comprehensive inventory of
Tigers in each state. Regulatory authorities should
maintain these photos and DNA reference samples
securely until a Tiger’s death and confirmed proper
disposal. This will deter misuse of microchips andlaundering of parts. Any Tigers found without suchproof of legality would be confiscated, with the owners
facing criminal prosecution. When the Tiger dies,owners should be required to notify regulatory
authorities, who would collect the chips upon receiving
proof that the animal and its parts had been properly
and permanently disposed of.
• States should also require that all facilities operating
as Tiger “sanctuaries” adhere to strict criteria such asbans on breeding, sale, or trade in the animals. Everystate at a minimum should adopt the USFWS 2007
definition of what constitutes an accredited sanctuary,

TRAFFIC North America

as some of the most prominent cases of illegal trade in
Tiger parts in the United States in recent years
originated from and among facilities that were callingthemselves sanctuaries but were in fact breeding,dealing or trading Tigers.
• States should also consider adopting laws or
regulations that establish a system of “reciprocity”.
Under such a system, states would enact rules that
require that any Tigers imported into their jurisdictions
be micro-chipped and registered as suggested above;
Tigers outside of the system would not be allowed. For
example, consider a hypothetical case of transferring a
Tiger from State ‘A’ to State ‘B’. State ‘A’ has not
adopted the above protocols, but State ‘B’ has. In thatcase, State ‘B’ would refuse to allow for theimportation of any Tigers from State ‘A’.
• As an immediate interim measure, private stakeholders
in Tiger conservation such as zoos, sanctuaries,
circuses, and others could establish a voluntary system
to inventory, regulate, and accredit holders of captive
Tigers (and possibly other big cats) according to theprincipals outlined above. Formal legal or regulatorychanges at the federal or state levels to achieve thesegoals may take time; responsible private entities may
be able to move more quickly.
• NGOs could further assist this effort by offering to help
fund and/or manage a U.S. Tiger database that keeps
track of U.S. captive Tigers more broadly. Records insuch a database could include each animal’s license or
permit number, microchip identification code, age, sex,
owner, and location. The database could also include a
digital photographic library of the cats, again to ensurethat microchips are not transferred between Tigers.
While this may seem a daunting task, the fact that there
are only an estimated 5,000 Tigers in the United Statesmeans that it should be manageable.
On the educational front, TRAFFIC recommends that:• U.S. federal and state government agencies should
continue and enhance public awareness programs tofurther reduce the demand and use of Tiger parts intraditional Asian medicines both in the United States
and abroad. Previous initiatives have shown thatconcerted efforts to reach out to the traditional
Chinese medicine (TCM) community have beeneffective in reducing the use of endangered wildlife in
traditional medicine. NGOs, facilities accredited with
the AZA, and others interested in Tiger conservation
should also be encouraged to participate in andsupport such initiatives.
On the law enforcement front, TRAFFIC recommends
that:

45

• State and federal law enforcement should be provided
more resources to conduct surveys and undercover
operations of TCM shops in the United States. Just as
TRAFFIC has done repeatedly in discovering ongoingavailability of medicines either containing or
purporting to contain Tiger parts in markets in various
U.S. locations, law enforcement should be encouraged
to conduct similar operations. The difference would bethat while TRAFFIC can survey and document theavailability, law enforcement has the ability toconfiscate the products and prosecute the offenders,
thereby supplementing public awareness initiatives
with real enforcement action (and also thereby
stimulating compliance).

identify and eliminate potential markets for Tiger partsin the United States and abroad. The fact that USFWS
and CBP inspectors have in recent years continued todetect and seize illegal imports of products, primarily
medicinals, purported to contain Tiger bone inquantities that could indicate commercial activity
shows that there remains some level of demand forthese products in the United States. Should suchdemand increase, or should China stimulate further
demand by re-opening its domestic market for Tiger
bone from farmed sources, U.S. law enforcement willneed to be increasingly vigilant to keep the UnitedStates out of the trade as either a consumer or a source
for Tiger parts.

• Funding for the USFWS wildlife inspection program
and related activities by U.S. Customs and Border
Protection (CBP) needs to increase. Additional fundingis also needed to enhance special operations andundercover investigations in the United States to46

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

REFERENCES
APHIS (2003). Animal exhibitors. APHIS Factsheet, Riverdale, Maryland, July 2003. Available at
http://www.aphis.usda.ac.
APHIS (2005). The Animal Care Program and the U.S. Department of Agriculture’s authority under the Animal Welfare
Act: Basic questions and answers. APHIS Factsheet, Riverdale, Maryland, July 2005. Available at
http://www.aphis.usda.ac.
APHIS (2007a). Licensing and registration under the Animal Welfare Act: Guidelines for dealers, transporters, andresearchers. www.aphis.usda.gov/lpa/pubs/awalicreg.html. Viewed April 20, 2007.
APHIS (2007b). www.aphis.usda.gov/animal_welfare/efoia/index.shtml.
API (2007a). Captive feline incidents. www.api4animals.org/popups/a3b_captive_feline_incidents.php. Viewed
February 7, 2007.
API (2007b). State laws regulating big exotic cats. Unpublished document, provided by Nicole Paquette, API, in litt. to
TRAFFIC North America, January 19, 2007.
API (2007c). Agencies regulating private possession of exotic animals covered under existing law. Unpublisheddocument, provided by Nicole Paquette, API, in litt. to TRAFFIC North America, January 19, 2007.
API (2007d). Ordinances regulating private possession of exotic animals.
www.api4animals.org/b4a2_exotic_animals_ords.php. Viewed January 19, 2007.
ASA (2007). Sanctuary criteria. www.asaanimalsanctuaries.org/Criteria/criteria.htm. Viewed June 25, 2007.
AZA (2007a). AZA accredited zoos and aquariums. www.aza.org/Accreditation/AccreditList/. Viewed February 7, 2007.
AZA (2007b). AZA certified related facilities. www.aza.org/Accrediation/certList/. Viewed February 7, 2007.
AZA (2007c). What is AZA Accreditation? www.aza.org/Accreditation/AccreditationIntro/. Viewed February 7, 2007.
AZA (2007d). AZA acquisition/disposal policy adopted by the AZA Board of Directors on July 29, 2006.
www.aza.org/AboutAZA/ADPolicy/. Viewed May 7, 2007.
Bensky, D. and A. Gamble (1993). Chinese herbal medicine Materia Medica. Eastland Press, Seattle, Washington, USA.
Big Cat Rescue (2005). Killing captive bred Tigers. U.S. Fish and Wildlife Service Press Release, November 13, 2001.
Headline: Five indicted in federal court for illegal trafficking of protected Tigers and Leopards.
www.bigcatrescue.org/big_cat_news_files/2005/bearcathollow.htm. Viewed April 19, 2005.
CITES (1994). Conservation of and Trade in Tigers. Resolution Conf. 9.13, Ninth meeting of the Conference of theParties to CITES, Fort Lauderdale, USA.
CITES (2002). Conservation of and trade in Tigers and other Appendix-I Asian big cat species. Resolution Conf. 12.6,
Twelfth meeting of the Conference of the Parties to CITES, Santiago, Chile.
CITES (2006). Tiger: Report of the Secretariat. CITES document SC54 Doc. 25.1.
http://www.cites.org/eng/com/SC/54/E54-25-1.pdf.
CITES (2007a). Report by the CITES Secretariat on implementing Resolution Conf. 12.5 of CITES. COP14 Doc. 52
Annex 1. http://www.cites.org/common/cop/14/doc/E14-52A07.pdf. Viewed January 25, 2008.

TRAFFIC North America

47

CITES (2007b). Alphabetical List of Contracting Parties to CITES. http://www.cites.org/eng/disc/parties/alphabet.shtml.
Viewed September 8, 2007.
CITES (2007c). CITES Species Database. http://www.cites.org/eng/resources/species.html. Viewed 17 April, 2007.
CITES (2007d) CITES Article II Fundamental Principles and Article III Regulation of Trade in Specimens of Species
Included in Appendix I. http://www.cites.org/eng/disc/text.shtml#III. Viewed June 2007.
CITES (2007e). Interpretation and implementation of the Convention, Species trade and conservation issues, Asian big
cats. Cop14 Doc. 52. Fourteenth meeting of the Conference of the Parties, The Hague (Netherlands).
CITES (2007f). Asian Big Cats. Decisions 14.65-14.72. http://www.cites.org/eng/dec/valid14/14_65-72.shtml. Viewed
November 2007.
Dinerstein, E., C. Loucks, A. Heydlauff, E. Wikramanayake, G. Bryja, J. Forrest, J. Ginsberg, S. Klenzendorf, P.
Leimgruber, T. O’Brien, E. Sanderson, J. Seidensticker and M. Songer. 2006. Setting Priorities for theConservation and Recovery of Wild Tigers: 2005-2015. A user’s guide. WWF, WCS, Smithsonian, and NFWF-STF,
Washington, D.C. – New York.
Federal Register (1970). Title 50—Wildlife and Fisheries, Part 17—Conservation of endangered species and other fish
or wildlife. Volume 35, No. 106, Tuesday, June 2, 1970. pp. 8491-8498.
Federal Register (1972). Title 50—Wildlife and Fisheries, Part 17—Conservation of endangered species and other fish
or wildlife. List of endangered foreign fish and wildlife. Volume 37, No. 62, Thursday, March 30, 1972. p. 6476.
Federal Register (1998). Captive-bred wildlife regulation: Final rule. Federal Register, Volume 63, Number 176,
September 11, 1998. pp. 48634-48641.
Federal Register (2006). Regulations to implement the Captive Wildlife Safety Act: Proposed rule. Federal Register,Volume 71, Number 20, January 31, 2006. pp. 5041-5048.
Federal Register (2007). Regulations to implement the Captive Wildlife Safety Act: Final rule. Federal Register, Volume
72, Number 158, August 16, 2007. pp. 45938-45947.
FWOA (2003). Operation snow plow gets 17th conviction in Tiger killing trial. In: The Federal Wildlife Officer, Volume
17, Number 2, Summer 2003.
FWOA (2004). Nine individuals indicted on wildlife related charges. In: The Federal Wildlife Officer, Volume 18,
Number 4, Fall 2004.
Gaski, A. L. and Johnson, K. A. (1994). Prescription for Extinction: Endangered Species and Patented Oriental
Medicines in Trade. TRAFFIC USA, Washington D.C.
Gaski, A. L. (Ed.). (1998). While Supplies Last: The Sale of Tiger and other Endangered Species Medicines in North
America, 1996-1997. Revised report, TRAFFIC North America, Washington, D.C.
Government of India, Ministry of Environment and Forests (12 February 2008). Total Country Level Population ofTiger 1411. Press Release. http://pib.nic.in/release/release.asp?relid=35336.
Hemley, G. and Mills, J. A. (1999). The beginning of the end of Tigers in trade? In: Seidensticker, J., Christie, S. andJackson, P. (eds.). Riding the Tiger: Tiger Conservation in Human-Dominated Landscapes. Cambridge University
Press, Cambridge, U.K. pp. 217-228.
Henry, L.A. (2004). A Tale of Two Cities: A Comparative Study of Traditional Chinese Medicine Markets in San
Francisco and New York City. TRAFFIC North America. Washington, D.C.: World Wildlife Fund.

48

Paper Tigers? The Role of the U.S. Captive Tiger Population in the Trade in Tiger Parts

Hoover, C. and Tarr, T. (1997) The U.S. Fish and Wildlife Service Division of Law Enforcement: A Review of theProgram Primarily Responsible for Enforcing CITES. TRAFFIC USA and World Wildlife Fund, Washington, D.C.
34 pp.
IUCN SSC Cat Specialist Group 2008. Draft 2008 Red list of threatened species. In prep.
Lee, S., Hoover, C., Gaski, A., and Mills, J. (1998). A World Apart? Attitudes Toward Traditional Chinese Medicine andEndangered Species in Hong Kong and the United States. TRAFFIC East Asia, TRAFFIC North America, andWorld Wildlife Fund, Washington, D.C.
Mills, J. A. (Ed.). (1997). Rhinoceros Horn and Tiger Bone in China: An Investigation of Trade Since the 1993 Ban.
TRAFFIC International, Cambridge, U.K.
Mills, J. A. and Jackson, P. (1994). Killed for a Cure: A Review of the Worldwide Trade in Tiger Bone. TRAFFIC
International, Cambridge, U.K.
National Geographic (2006). China Tiger farms lobby to sell animal parts to aid conservation. http://news.national
geographic.com/news/2006/12/061222-tiger-farms.html. Viewed March 13, 2007.
Nguyen, X. D., Vu, N. T., and Cao, V. S., with Nguyen, T. M. and Compton, J. (Eds.). (1999). The Trade and use ofTiger and Tiger Products in Viet Nam. TRAFFIC South-east Asia-Viet Nam, Hanoi, Viet Nam. Unpublished report.
Nowell, K. (2000). Far from a Cure: The Tiger Trade Revisited. TRAFFIC International, Cambridge, U.K.
Nowell, K. (2007). Asian Big Cat Conservation and Trade Control in Selected Range States: Evaluating
Implementation and Effectiveness of CITES Recommendations. TRAFFIC International, Cambridge, UK.
Nowell, K. and Xu, Ling (2007). Taming the Tiger Trade: China’s Markets for Wild and Captive Tiger Products sincethe 1993 Domestic Trade Ban. TRAFFIC East Asia.
Petrar, B. (1999). Searching for Tigers in Canada: Limitations of Forensic Analysis. Paper presented by Environment
Canada to the 15th triennial meeting of the International Association of Forensic Sciences, August 22-28, Los
Angeles, USA.
Reuters. (August 2007) Indian Tiger Population More than Halved.
http://uk.reuters.com/article/reutersEdge/idUKZWE34948920070803?pageNumber=1
Sanderson, E., J. Forrest, C. Loucks, J. Ginsberg, E. Dinerstein, J. Seidensticker, P. Leimgruber, M. Songer, A.
Heydlauff, T. O’Brien, G. Bryja, S. Klenzendorf and E. Wikramanayake. 2006. Setting Priorities for theConservation and Recovery of Wild Tigers: 2005-2015: A User’s Guide. The Technical Assessment. WCS, WWF,
Smithsonian, and NFWF-STF, New York – Washington, D.C.
Seidensticker, J., Christie, S. and Jackson, P. (Eds) (1999). Riding the Tiger: Tiger Conservation in Human-DominatedLandscapes. Cambridge University Press, Cambridge, UK.
Sellar, J. et al. (1999). Tiger Technical Missions Report. Presented at the 42nd meeting of the CITES Standing
Committee, Lisbon, Portugal.
St. Petersburg Times. 2007. Records sparse on exotic animals in our midst, by Leonora LaPeter Anton, Times Staff
Writer. Published November 11, 2007.
USDOJ (2006a). Department of Justice commemorates Earth Day, highlights successes in environmental enforcement.
News Release, Friday, April 21, 2006.
USDOJ (2006b). Seller of Tiger and other endangered big cat skins sentenced to prison. News Release, Thursday, April
20, 2006.

TRAFFIC North America

49

USFWS (2002). USFWS basics fact sheet. U.S. Fish and Wildlife Service Endangered Species Program, Arlington,
VA, October 2002.
USFWS (2003). Captive-bred wildlife registration under the U.S. Endangered Species Act. Factsheet, USFWSInternational Affairs, Division of Management Authority, Arlington, Virginia, Summer 2003. Available at
http://international.fws.gov.
USFWS (2006). U.S. conservation efforts for tigers. U.S. Fish and Wildlife Service, International Affairs, Division ofManagement Authority, Arlington, VA, Fall 2006.
USFWS (2007a). Public Law 103-391 [H.R. 4924]: Rhinoceros and Tiger Conservation Act of 1994.
http://www.fws.gov/international/laws/rtc-fv.html. Viewed February 7, 2007.
USFWS (2007b). Title IV–Rhinoceros and Tiger Conservation Act of 1998.
http://www.fws.gov/international/laws/rtlabl2.html. Viewed February 7, 2007.
USFWS (2007c). Captive Wildlife Safety Act: What big cat owners need to know. U.S. Fish and Wildlife Service fact
sheet, Office of Law Enforcement, Arlington, Virginia, August 2007.
USFWS (2008). Captive-bred wildlife registration. http://www.fws.gov/international/permits/captivebred.html. Viewed
January 23, 2008.
Werner, B. (2005). Distribution, abundance and reproductive biology of captive Panthera tigris populations living within
the United States of America. Feline Conservation Federation Magazine 49(2), March/April.
http://www.thefcf.com/species/dynamics.asp?key=190. Viewed 21 March 2007.
Williamson, D. F. 2002. In the Black: Status, Management and Trade of the American Black Bear (Ursus americanus) in
North America. TRAFFIC North America. Washington, D.C.: World Wildlife Fund.
Williamson, D. F. 2003. Caviar and Conservation: Status, Management and Trade of North American Sturgeon andPaddlefish. TRAFFIC North America. Washington, D.C.: World Wildlife Fund.
Williamson, D. F. 2004. Tackling the Ivories: The Status of the US Trade in Elephant and Hippo Ivory. TRAFFIC North
America. Washington, D.C.: World Wildlife Fund.

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TRAFFIC, the wildlife trademonitoring network, works to ensurethat trade in wild plants and animals
is not a threat to the conservation ofnature. It has offices covering mostparts of the world and works in close
co-operation with the Secretariat of
the Convention on International Tradein Endangered Species of Wild Fauna
and Flora (CITES).

For further information contact:
The Director
TRAFFIC North America
c/o World Wildlife Fund-US
1250 24th Street, N.W.
Washington, D.C. 20037 USA
Telephone: +1-202-293-4800
Fax: +1-202-775-8287
Email: tna@wwfus.org
Web Site: www.traffic.org