The Veterinary Procedural Notice 59 (VPN-59) regulations introduce a ‘split system’, requiring animals destined for export markets to be sourced from registered production units that comply with defined biosecurity protocols, veterinary oversight, and traceability measures. This includes separating export animals from the general herd, maintaining documented health histories, and ensuring verifiable movement controls.
The intent is to align South Africa with the sanitary and phytosanitary expectations of premium international markets, particularly in the context of ongoing foot-and-mouth disease (FMD) risks.
However, the implementation of Addendum D to VPN-59 on 1 April 2026 has created significant challenges at industry level.
Producers and exporters report that they were given limited time – some as little 48 hours – to comply with new or clarified requirements. As a result, companies unable to demonstrate compliance have, in practice, been unable to secure veterinary certification for export, effectively halting trade to key markets like the United Arab Emirates (UAE).
Industry stakeholders attribute this not to resistance to compliance but to a combination of the following:
- Limited availability of registered production units, particularly in extensive systems
- Departmental delays in communicating detailed requirements and addendums
- Capacity constraints within state veterinary services and delays in private vet approvals
- Uncertainty around how the rules are interpreted and applied
While the framework is intended to enable and protect exports, its implementation has had the unintended effect of constraining trade.
Industry players warn that exports to key markets, including the UAE, have effectively been brought to a standstill, with losses running into tens of millions of rand each week.
The situation stands in stark contrast to Agriculture Minister John Steenhuisen’s stated emphasis on expanding agricultural exports as a driver of economic growth and rural development.
‘A DE facto suspension of exports’
According to Alex Cilliers, managing director of KYTO Operations (KYTO), the implementation of Addendum D has resulted in what the company describes as a ‘de facto suspension of exports’.
In its formal complaint submitted to the Department of Agriculture, KYTO stated that current implementation measures are misaligned with UAE import requirements, and that the additional requirements are administrative and not risk-based.
KYTO, an export abattoir in Groblershoop, Northern Cape, supplies lamb to the Middle East and has been directly affected by the implementation of Addendum D.
Cilliers said exports have halted despite the availability of eligible animals, approved abattoir facilities, and established international clients awaiting product, pointing to what he argues is a failure in implementation rather than compliance.
The industry was caught off guard by the enforcement of the new measures, with some producers receiving notice only days before implementation. Stakeholders say the difficulty lies not in meeting export standards but in the absence of clear, consistent guidance.
Although VPN-59 refers to market-specific addendums, these were not always formally distributed or clearly communicated, leaving both producers and veterinarians uncertain about requirements.
This has contributed to what some describe as an administrative ‘black hole’, where compliance is expected but the pathway to achieve it remains unclear.
Rollout concerns
The Red Meat Abattoir Association (RMAA) has also raised concerns about the rollout of the new measures. It said in response to members that updated veterinary health certificate requirements and Addendum D guidelines were not distributed in time, forcing industry players to source documents informally through provincial channels.
The association added that some draft guidelines appear to exceed the requirements agreed with importing countries, warning that the implementation approach could disrupt exports unnecessarily.
KYTO argues that VPN-59’s structure is not yet practically aligned with South Africa’s production systems, particularly in extensive farming regions.
The requirement to source animals from registered units has created a bottleneck, as such units are not yet available at scale in some areas. As a result, feedlots are unable to source compliant animals, abattoirs cannot meet sourcing requirements, and exports cannot proceed.
The company says the UAE import protocol is outcome-based, focusing on animal health, veterinary supervision, and defined FMD risk mitigation, whereas South Africa’s implementation introduces additional system-based requirements such as full farm registration and expanded traceability.
KYTO maintains that these measures do not improve risk management but instead add administrative complexity and delay trade.
The current disruption is not an isolated event. KYTO’s submission highlights that similar export interruptions were experienced in the Kuwait, Jordan, and Hong Kong markets between November 2025 and February 2026, despite these countries being ready to receive product.
These disruptions were linked to delays in certification processes, inconsistent application across provinces, and limited coordination between authorities.
Responding to the RMAA’s concerns, Dr Nadia de Beer, deputy director in the Department of Agriculture’s (DoA) Import Export Policy Unit, said South Africa’s framework is aligned with UAE import requirements.
“The documentation and implementation measures are consistent with the agreed import requirements,” she said.
She added that the DoA has called for closer engagement between provincial and national veterinary authorities to address what it views as possible misinterpretation at implementation level.
Capacity constraints add to delays
Implementation challenges have been compounded by capacity constraints within veterinary services. Although VPN-59 allows for the use of authorised private veterinarians, stakeholders report delays in approvals, limited state capacity, and a lack of clear operational guidance.
This has resulted in a situation where exports are technically permissible but practically constrained.
The financial impact has been severe. With exports constrained, product has been diverted to the domestic market, contributing to price pressure, with slaughter prices reportedly declining from more than R100/kg to around R92/kg.
KYTO estimates its own losses at between R2 million and R4,5 million per week, while industry-wide losses range from R6 million to R30 million per week, or up to R130 million per month.
Ambition vs reality
Steenhuisen has emphasised the importance of expanding agricultural exports to drive growth and rural development. However, the current situation highlights a disconnect between that policy ambition and on-the-ground implementation.
Industry stakeholders warn that unless these challenges are resolved, South Africa risks losing market share and undermining its export competitiveness.
Proposed solutions
KYTO and other stakeholders have submitted alternative, scientifically based solutions to the DoA, including the use of registered private veterinarians and recognised traceability systems to allow exports to continue while longer-term issues are resolved.
The company also recommends:
- Immediate reinstatement of exports where compliance can be demonstrated
- Alignment with importing country requirements
- Consistent national implementation
- Transitional arrangements during regulatory changes
- Establishment of a joint industry–government technical working group
Cilliers concluded: “This situation reflects a misalignment between policy design and practical implementation. In its current form, the system is not enabling exports, despite compliance being achievable, and is therefore constraining trade, with clear economic consequences for the value chain.”
