The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)—the planet’s most consequential pact for wildlife conservation—has expressed concern about India’s handling of endangered animals crossing borders. Though the treaty is seldom a matter of public drama, recent findings by a CITES-designated committee have propelled it into the spotlight.
The central issue is that the codes used on permits governing international trade in live animals do not always accurately reflect the actual transactions, and India’s system of checks is lacking.
As one of the 185 Parties to CITES, India formally ratified the treaty in 1976. India’s Wildlife (Protection) Act, 1972, as amended in 2022, was lauded for its global standing: CITES rated it in “Category 1” under the National Legislation Project, indicating complete alignment with the treaty’s baseline requirements. However, despite this sturdy legislative framework, the treaty’s compliance mechanisms have flagged India for concern.
The red flag emerged most prominently in a verification mission conducted in mid-September 2025. The team visited two wildlife facilities in Jamnagar, Gujarat: the Greens Zoological Rescue and Rehabilitation Centre (GZRRC), and the Radha Krishna Temple Elephant Welfare Trust (RKTEWT), both part of the broader Vantara initiative by the philanthropic arm of Reliance, an Indian conglomerate.
The purpose was to inspect how India’s authorities verify the provenance of imported live animals—specifically whether their status as “captive-bred” or “wild” (via source codes like ‘C’ or ‘W’) and their intended purpose (e.g., for zoos under code ‘Z’, or for commercial trade under ‘T’) were in fact properly validated.
The good news first: the CITES mission found that the laboratories, veterinary care, facilities and operational standards at GZRRC and RKTEWT were “exceptionally high” and that the institutions were suitably equipped to house Appendix I species under the treaty’s rules. The Indian authorities, as well as the facilities themselves, cooperated with the mission; they demonstrated openness, invited review, and expressed a willingness to upgrade their procedures further.
But the key concerns lie in what lies behind the paperwork. The verification team was clear in its report that “several imports … raise questions regarding the origin of the specimens … the use of source and purpose-of-transaction codes, and the exercise of due diligence by India.” For example, in one prominent case involving two snow leopards imported from Germany, the German exporting authority issued a permit under purpose code ‘T’ (commercial) and source code ‘C’ (captively bred).
Indian authorities then accepted the recipient’s claim that the animals were “donated”. They reissued an import permit under code ‘Z’ (zoo) without verifying with the German authority that the original classification was correct. The mission report deemed it inadequate in terms of cross-border verification.
In another suspicious case, the mission identified forged export permits for chimpanzees from Cameroon. The Indian authorities ultimately stopped the import when the recipient raised a concern, but the mission observed that the Indian side could have identified the issue earlier.
Cameroon has no record of chimpanzee exports under the treaty since 2000, and is not known for captive breeding of the species. Yet the import permit had been granted by India. The mission pointed out that the CITES database available to India would have flagged that anomaly.
The mission therefore recommended that India pause issuing import permits for live animals of Appendix I listed species until the country implements systematic and consistent “due diligence” measures, particularly in verifying whether specimens originated in the wild or were truly captive-bred, whether intended for zoo use or commercial sale, and whether exporting facilities were registered and known to meet the standard criteria of the treaty.
India’s Management Authority (as required under CITES) told the committee that its system for live animal import oversight engages multiple ministries, the state forest departments, the central zoo authority and the wildlife crime control bureau, and that no-objection certificates (NOCs) for imports are issued only after verifying source and purpose codes where possible. Yet the mission concluded that the verification process is less rigorous than it should be, especially when the quantity of imports is large, when transactions originate from non–range states, or when the exporting country has weak or opaque captive-breeding credentials.
One of the most notable findings is that the use of source code ‘C’ (captive-bred) and purpose code ‘Z’ (zoo) may mask commercial transactions and specimens of wild origin. CITES defines the distinction: animals bred in captivity must come from a facility meeting the criteria (often the second generation or beyond in captivity, under resolution Conf . 10.16 (Rev. CoP19)), whereas wild-caught specimens must be coded ‘W.’
The mission found that for many specimens imported into India under code ‘C’, the exporting facilities did not appear to be equipped to qualify under the captive-bred definition; yet, India accepted the paperwork.
The report underscored that for species listed in Appendix I—those already, or likely to be, threatened with extinction—trade is supposed to be conducted under “exceptional circumstances” only, and large-scale imports organised through commercial‐type transactions may contradict the spirit of the treaty. The sheer volume of imports into GZRRC (for example) by itself raised questions about whether the conditions of exceptionalism were met.
At one level, the story reflects a possibility: India, having negotiated and implemented a robust wildlife-protection statute, may now be entering a new phase of animal welfare and ex-situ conservation infrastructure. The GZRRC is recognised, since 2019, by the Central Zoo Authority (CZA) as a zoological park, rescue and conservation‐breeding centre; its recognition was renewed in 2023 and re-evaluated in 2025.
The authority to receive exotic species, conduct breeding programmes (for 26 native and 16 non-native species, for instance), and develop long-term release and rewilding programs marks a shift in Indian conservation ambition. And the CITES Secretariat, in its field visit, did not find evidence that animals had been imported without valid permits, or that the facilities were engaged in commercial sales of offspring.
However, the highlight here is not the praise but the caveat. The international treaty’s machinery is designed not only to support conservation breeding, zoos and rescue centres—but also to stop illegal trade in endangered animals, which globally ranks among the most lucrative forms of smuggling. The point of using source and purpose codes is precisely to ensure that the movement of wildlife is transparent, traceable and matches the declared purpose.
Cases where imports are large in number, cross multiple jurisdictions, pass through non-range states, or rely on uncertain “captive-bred” credentials raise the red flags that the treaty mechanism is built to catch. The mission’s language is unambiguous:
large numbers of acquisitions … may attract attention … certain individuals or entities could attempt to exploit this as a way to traffic animals.
In short, the recommendation from CITES is that India should pause importation of live animals, especially Appendix I species, until its system for verifying origin, purpose and facility registration is strengthened and transparent. India has expressed appreciation for the guidance and has affirmed in writing that it will improve its processes. The Facilities in question (the GZRRC and RKTEWT) have likewise stated their willingness to be in full compliance with CITES and to develop stronger internal due diligence systems.
What remains to be seen is how this plays out in practice. Will India impose a moratorium on new imports of endangered species, or will it refine its data-sharing and verification channels with exporting countries and the CITES Secretariat? Can the loophole of purpose code re-labelling be addressed, so that ‘Z’ is not simply used as a rubber stamp for activities that are de facto commercial? How will India’s wildlife authority build institutional capacity to evaluate credibly the breeding claims of far-flung facilities in distant countries?
In a world where illegal wildlife trade thrives on opacity and clever paperwork, treaty compliance is not just a bureaucratic exercise—it is a matter of species survival. For India, the moment is nothing short of a crossroads.
On the one hand lie the promise of world-class animal welfare facilities, breeding programmes for endangered species, and a global reputation for conservation leadership. On the other hand lurks the risk that even well-intentioned import programmes become unwitting conduits for laundering wild animals through captive-breeding paperwork, undermining the treaty’s purpose. As the final word in the latest field report phrased it: “reinforced due diligence … is crucial.”
In the arena of international wildlife trade, the difference between a “Z” for zoo and a “T” for trade can be the difference between a species surviving and the shadows of extinction.
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