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The final Section 10 Routine Vaccination Scheme for Foot and Mouth Disease (FMD) was published in the Government Gazette on 4 May 2026. The much-awaited scheme introduces a number of structural and governance changes compared with earlier draft versions released for public comment. However, according to feedback from a number of organisations that submitted comments requesting greater clarity and amendments to certain sections, few, if any, of their comments were included or accommodated.
According to Dr Frikkie Maré, CEO of the National Red Meat Producers’ Organisation (RPO), the scheme still contains numerous impracticalities and definitions that are vague, such as the definition of a traceable animal and eartags. “It seems as though they decided to omit a number of points rather than give greater clarity. The fact that industry representation has been removed from the committee for routine FMD vaccination paints a picture of total state control.”
This sentiment is echoed by Richard York, CEO of Wildlife Ranching SA, who says the previous draft gazette made specific provision for a private wildlife veterinarian to be included on the committee overseeing the voluntary vaccination rollout. That provision has now been removed in the final gazette.
FMD Response SA spokesperson, Andrew Morphew, says in their comments that the strategy in its current form and vaccination rollout at farm level remains fundamentally inadequate. While the scheme does make allowances for some measure of private partnerships in vaccination efforts, the state will still control all vaccine distribution. “This approach is a recipe for failure. As demonstrated by the successful vaccination campaigns of Brazil and Argentina, private distribution is essential to ensure vaccines reach farms timeously and are administered effectively at the farm level. Requiring the state to centrally control distribution leads to bottlenecks and delays,” said Morphew.
He said the Section 10 scheme also lacks mandatory tight time frames that should be enforced to ensure all cattle are vaccinated quickly.
What the scheme entails
The scheme, issued under the Animal Diseases Act, 1984 (Act 35 of 1984), provides the legal framework for voluntary vaccination against FMD by livestock owners in South Africa. The scheme was gazetted by minister of agriculture John Steenhuisen and is overseen by the director of animal health, Dr Mpho Maja, whose office is officially responsible for animal disease control, vaccination oversight, certification, and trade-related animal health requirements.
While the scheme is voluntary, government has described it as a fast-track option aimed at supporting broader FMD control efforts, maintaining market access, and allowing farmers to continue operating under clear biosecurity rules.
A comparison between the final gazetted scheme and earlier public consultation drafts shows changes affecting clause structure, committee composition, traceability rules, certification standards, and how vaccination costs are carried.
Fewer clauses, less prescriptive wording
The draft scheme released for public comment on 17 April contained 24 clauses. The final version contains 22, with two clauses removed before publication.
One of the removed clauses specifically addressed the prevention of infection and reinfection in vaccinated animals. That clause had outlined clear responsibilities for scheme participants to protect vaccinated herds from further exposure to the virus. In the final version, no standalone clause directly sets out those duties.
Another clause addressing the position of livestock owners who choose not to participate in the scheme was also removed. As gazetted, the scheme does not clearly spell out how non-participants fit into the vaccination framework, beyond the continued application of general movement controls and disease measures under the Animal Diseases Act.
Amended definitions and veterinary roles
Several definitions were amended in the final scheme. Earlier drafts referred to “agricultural associations,” while the final text uses the broader term “agricultural industries” without defining any requirements for representation.
The language around veterinary participation was also simplified and widened. The scheme refers to “authorised” persons, which includes veterinarians and veterinary paraprofessionals approved by the director of animal health. Earlier draft wording that made tighter distinctions between different types of veterinarians was removed.
Proposed definitions that referred to a single central data exchange system, specific eartag certification schemes, and required integration between traceability platforms do not appear in the final set of regulations.
Traceability requirements kept broad
The final scheme retains wide traceability requirements. All cloven-hoofed livestock owned by a participant must be permanently identified and recorded in a traceability system, whether or not vaccinated.
Batch-based identification for sheep and goats remains a requirement. The scheme also introduces an additional condition: participating farms or premises must be registered in a traceability system using a global location number (GLN).
The scheme does not require the use of a specific traceability platform, nor does it require systems to link to one another, provided they meet the basic requirements set out in the regulation.
Narrowed objectives of the scheme
The stated objectives of the scheme were reduced between the draft and final versions. References to vaccine procurement, storage, cold-chain management, and distribution oversight were removed from the objects section.
As gazetted, the scheme focuses on supporting existing FMD control measures, allowing voluntary vaccination under state oversight, encouraging public-private cooperation, and supporting business continuity, food security, and animal health. Practical and technical details are instead addressed through operational guidelines and a peer-reviewed FMD manual, to be released within 90 days of the scheme’s publication.
Committee composition revised
One of the most notable changes is the makeup of the committee for routine FMD vaccination. Earlier drafts listed representatives from several sectors, including cattle, dairy, feedlot operations, small stock, swine, the wildlife industry, laboratories, and academia.
In the final scheme, formal industry representation is limited to a single veterinarian nominated jointly by the cattle stud, dairy, and feedlot sectors. No specific provision is made for the wildlife sector, the small-stock industry, pig producers, or diagnostic laboratories. Committee appointments are made at the minister’s discretion, and the regulation no longer lists nominating bodies.
The final scheme does allow the committee to co-opt up to three additional members, including people from the agricultural industry, but this is optional rather than guaranteed.
Greater role for director of animal health
The final scheme affords the director of animal health more authority than earlier drafts did. Dr Maja is responsible for approving authorised vaccinators, determining which diagnostic tests may be used, issuing the intended peer-reviewed FMD manual, and granting certificates of participation to qualifying farmers.
The scheme states that the FMD manual must be published within 90 days of the scheme taking effect. While the committee must be consulted in this regard, final approval rests with the director. The problem with this, says Dr Maré, is that nothing can happen until the manual has been published. In other words, the scheme is not really in effect until the manual is released, which will take another three months.
Vaccination standards were also adjusted. Earlier drafts required vaccination to be administered according to the manufacturer’s instructions. In the final scheme, compliance is assessed “to the satisfaction of the director,” allowing for regulatory judgment based on circumstances.
Biosecurity framing changed
The removal of the clause relating to infection and re-infection changed how biosecurity duties are described. Under the final scheme, authorised veterinarians must provide a site-specific biosecurity plan for each vaccination location.
The regulation does not include a separate clause that imposes direct biosecurity duties on scheme participants beyond those already required under existing animal disease laws.
Impact on wildlife and buffalo operations
Although the scheme focuses on domestic livestock, wildlife operations remain affected by FMD control policy, particularly those involving disease-free buffalo.
South Africa has more than 3 000 registered disease-free buffalo farms. Under current legislation, if FMD is detected in a disease-free buffalo herd, the animals must be destroyed because buffalo are considered potential long-term carriers of the virus. York said this places wildlife ranchers at significant risk. “If FMD enters registered disease-free buffalo populations, it becomes a death sentence for those herds, as current legislation requires entire herds to be eradicated,” he said.
Costs and public-private funding
The final scheme makes it clear that vaccination costs are to be carried by participating livestock owners. This includes the cost of vaccines and veterinary services. In his media briefing following a visit to Latin America, minister Steenhuisen addressed this directly. “It should be further noted that the livestock owner will pay for the vaccines and the veterinarian’s services, although government may consider subsidies or cost-sharing in the future,” he said.
The scheme allows for public-private partnerships and future funding arrangements, but does not set cost limits or specify how traceability, certification, or administrative expenses will be shared.
Long-term disease control questions
The scheme forms part of a broader FMD control strategy that includes a parallel national vaccination programme led by the state and informed by South Africa’s engagement with countries such as Brazil.
However, some industry groups have questioned whether long-term disease control can succeed without clear inclusion of all affected sectors. “Any attempt to eradicate FMD in South Africa without including the wildlife sector and private wildlife veterinarians is unlikely to succeed in the long term,” York said.
Dr Maré says it seems as though the minister published the scheme due to recent pressure from the high court to publish the scheme by 5 May, and that industry comments were therefore simply not included. – Nikilene Steenkamp, Plaas Media
To read the full Scheme, click here.
