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COMMENT: Conservation Policy (captive breeding) | Dear South Africa




The Director-General: Department of Forestry, Fishery and the Environment

Private Bag X447


Attention: Dr Kiruben Naicker

  • Introduce yourself as a stakeholder, specifying your interest as, for example, a conservationist, or environmentalist, or a tourist, photographer, or a journalist, blogger, private individual with a passion for Africa / wildlife / the environment / Nature / South Africa. 




Illegal wildlife trade negatively impacts economies and ecosystems around the globe. In contrast, legal and regulated wildlife trade greatly benefits people and their surrounding environments.

Those two prior statements are opinions, not necessarily facts, held by the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) Secretariat. CITES being an international treaty aimed at regulating the trade of many animal and plant species and the Secretariat being the group responsible for administering the treaty.

The Secretariat reiterated their stance on legal and illegal wildlife trade when questioned about their role in preventing future pandemics. Many called for CITES to expand their role in wildlife trade beyond regulation, but the Secretariat responded they do not have the competence to comment on the link between wildlife consumption and zoonotic diseases.

Despite the Secretariat’s attempt at sidestepping responsibility for public health, wildlife trade and zoonotic diseases remain as intertwined as ever. A United Nations Environment Programme (UNEP) report shows that 60% of known and 75% of emerging infectious diseases are zoonotic. COVID-19 likely followed the same path, jumping from wildlife to humans. Research also confirms wildlife exploitation, like hunting and trade, is increasing opportunities for future disease transmissions from wildlife to humans. As well, a report from Traffic, an organisation dedicated to monitoring global trade in animals and plants, demonstrates that the public health risk remains with both legal and illegal wildlife trade, although noting illegal practices can cause additional risk.

And just as the Secretariat fail to assume any responsibility for the public health threats associated with wildlife trade, they fail to acknowledge the link between illegal and legal wildlife trade. It is all too easy to promote the benefits of legal wildlife trade while criticizing illegal trade. But the reality is that legal wildlife trade fuels illegal wildlife trade by providing cover for illicit activities.

An investigation by EMS Foundation (EMS) and Ban Animal Trading (BAT) culminated in a report confirming the connection between illegal and legal wildlife trade. The report, BREAKING POINT: Uncovering South Africa’s Shameful Live Wildlife Trade with China, details the illegal and questionable trade of thousands of live animals under the pretense of legal trade.

Large-scale illegal wildlife trade between South Africa and China is not surprising. Research shows China is a major source of illegal trade thanks to their revitalization of Traditional Chinese Medicine (TCM), investment in the developing world, and expansion of accessible trade routes. Add to this that many African nations’ growth strategies encourage prosperity at the expense of biodiversity loss and there is a perfect storm of illegal wildlife trade.

The more than 5,000 live animals listed in the report represent only a fraction of all wildlife exports from South Africa to China between 2015 and 2019. The level of regulation provided for trade in different species varies from strict to lenient. And while many of the species are under CITES regulation, there are also a number of concerning examples of trade in non-CITES regulated species. The Secretariat would, no doubt, absolve themselves of any responsibility of illegal trade in non-CITES regulated species which only raises more questions about the efficacy of the treaty and legal wildlife trade.

Species listed under CITES Appendix I are noted as being threatened with extinction and should theoretically receive the most comprehensive protection and their trade the strictest regulation. Trade in Appendix I species is only allowed if a non-detriment finding (NDF), an analysis ensuring trade does not hinder species’ survival, is made from a scientific authority body from both the exporting and importing countries. Trade, for these species, is not allowed for primarily commercial purposes and only under exceptional circumstances. 

However, guidelines for NDFs are left ambiguous and there is also a caveat that allows captive breeding facilities to trade Appendix I species for commercial purposes if the facility is registered with CITES. The registration process is as simple as filling out a questionnaire for review by the Secretariat. No guidelines provided by CITES are legally binding and allow for easy exploitation by parties wishing to make a quick profit.

For example, chimpanzees, an Appendix I species, were legally exported from South Africa to China without an appropriate NDF and primarily for commercial purposes between parties not registered with CITES. There is no evidence to suggest the 18 chimpanzees, two of which were reported as pregnant at time of export, sold by Hartbeespoort Snake and Animal Park were captive bred and not taken from the wild and illegally imported into South Africa. The only evidence suggesting the chimpanzees were captive bred came from a letter signed by the export agent, Christa Saayman of Mystic Monkeys and Feathers. A signed letter from an export agent is not sufficient proof of legality.

Worse yet, exporting chimpanzees to a zoo, Beijing Wild Animal Park in this case, can hardly be considered an exceptional circumstance and for non-commercial purposes. There is no conservation value in exporting chimpanzees to Chinese zoos. These chimpanzees are living in concrete rooms surrounded by glass panels and serve only as attractions for paying visitors. Unable to ever go outside, they are reduced to nothing more than museum exhibits.

Other Appendix I species including cheetahs, jaguars, lemurs, and tigers were shipped from South Africa to Chinese zoos and fail to meet the criteria of being primarily non-commercial and exceptional. Surely, many will seek to defend these transactions by arguing the conservation benefits of some zoos. While the positives and negatives of zoos can be debated for some specific facilities around the world, the zoos listed in the report offer nothing more than entertainment for paying customers at the expense of wildlife.

About half of the animals listed in the report fall under protection of CITES Appendix II and III. Trade in Appendix II and III species is less restrictive than for Appendix I species but still regulated, nonetheless. EMS and BAT found many instances of invalid permits and documentation being incomplete or incorrect, or both.

Most of the animals under Appendix II and III protection were sent to Chinese wholesalers and brokers without a disclosed destination or to breeding farms where they can no longer be traced. A disturbing piece of the report shows that hundreds of primates were sold to laboratories or laboratory breeding farms. The fate of these animals is unknown, but it can be surmised they are being used for commercial purposes and have no value in conservation.

As mentioned, a few species exported from South Africa to China are not offered protections under the CITES framework. The most concerning being the African wild dog, listed as an endangered species. Assumptions are often made that an endangered species listing would automatically garner the most comprehensive protection possible from CITES. Unfortunately, those assumptions are wrong. CITES framework only regulates trade of species the Secretariat deems appropriate. This means the 35 African wild dogs shipped to China since 2018 received no protection under CITES.

A past instance of African wild dog trade detailed by the report demonstrates why this is alarming. Manus Pretorius claims to have exported African wild dogs around the world, including China. He was also wrapped up in a controversial relocation of African wild dogs from South Africa to Zimbabwe. Pretorius held 24 wild caught African wild dogs in captivity before releasing them to Painted Dog Conservation. Only 16 were released back into the wild with seven believed to have died and one being a pregnant female. Of the 16 individuals released back into the wild, Painted Dog Conservation found only two of them were from the original 24 and the rest were captive bred.

CITES protection of African wild dogs was discussed in 2016. But the Secretariat deemed the work needed to protect the species too significant without evidence of trade threatening the species. An important note is that trade is not viewed as a threat simply because there is no official data surrounding international trade in the species. However, African wild dogs are found in zoos around the world. How does the Secretariat think they got there?

It is painfully obvious there is a burgeoning international market for African wild dogs. Instead of the Secretariat working to protect the endangered species, they dodge responsibility on a technicality of no official data being present. This sums up the Secretariat, and many other groups promoting legal wildlife trade, perfectly. Everyone wants to take responsibility for the positives of wildlife trade, namely the economic impact. But no one is willing to accept responsibility in preventing the negatives like zoonotic disease proliferation and illegal wildlife trade.

Often lost in the discussion of legal wildlife trade is the topic of animal welfare. When the value of a living being is calculated in monetary terms, it is easy to treat it like a commodity. The only language in the CITES framework surrounding animal welfare consists of shipment practices aimed at minimizing cruelty and recipients of Appendix I species providing suitable housing and care.

Apparently, a cement room surrounded by glass panels is suitable housing for chimpanzees. Even animals housed outside, like African wild dogs and hyenas, are restricted to stone and cement pathways with grass behind fences and beyond their reach. Captivity in these environments means animal suffering, pure and simple.

Until advocates of legal wildlife trade can decouple the inherent consequences of the industry, we can expect more coronaviruses and less biodiversity. The thing is, though, we do not necessarily need the consequences decoupled from legal wildlife trade. There is an easier and better option. We can ban wildlife trade.

Bans have lower transactional costs than regulations since less technical expertise is needed to enforce them. As the report also points out, bans send a clear message that this type of wildlife exploitation is no longer socially and ecologically acceptable. The EMS and BAT investigation makes another thing clear, illegal wildlife trade is not the only problem facing our world. The legal wildlife trade is just as problematic.

Jared Kukura is a freelance wildlife conservation writer based in California. He founded Wild Things Initiative to highlight the negative ramifications of the wildlife trade and hunting industries.

Image Credit: Karl Ammann on location in China. Karl Ammann is a conservationist and wildlife photographer.

© 2020 EMS Foundation. All rights reserved.




Written by Dr Ross Harvey – EMS FOUNDATION

Ahead of this year’s Safari Club International (SCI) Convention, at which Donald Trump Jr will be a keynote speaker, the organisation issued a press release attacking Humane Society’s objection to its cruel practices.

HSI also questioned whether hunting makes an overall positive net contribution to conservation. The SCI statement insists that “overwhelming evidence from multiple independent scientific entities such as the International Union for the Conservation of Nature (IUCN) proves this quote to be the opposite of reality.

The IUCN has repeatedly published articles that prove illegal poaching and habitat loss are the largest threats to wildlife and that so-called trophy hunting provides direct benefits for the species hunted, conserves a vast amount of land for wildlife habitat, funds anti-poaching efforts, encourages local community participation in conservation, supports livelihoods, and significantly contributes to rural economies…” (link to IUCN paper is

The IUCN paper, however, does no such thing as prove the benefits of trophy hunting in the way that the SCI thinks it does. To be sure, it makes generous claims in support of well-governed trophy hunting. The EMS Foundation has analysed the IUCN document, which is typically hauled out by proponents of trophy hunting or referred to by governments who have become reluctant to ban trophy hunting imports. The analysis serves primarily to inform the British government’s deliberations over whether to ban trophy imports (and what kind of ban would be appropriate). More broadly, it exposes holes in the paper’s arguments and brings other evidence to bear that suggests it has not been sufficiently rigorous in its appraisal of the conservation benefits of trophy hunting. In a nutshell, it provides a contrary view to conventional wisdom in conservation circles and suggests that alternatives to trophy hunting are feasible and socio-ecologically preferable in the long run. It also provides support for the IUCN ethics committee’s position, which held that trophy hunters and hunting organisations should not be permitted to IUCN membership. As the UK considers a ban on trophy imports, we trust that it will make the correct call and that the rest of the world will follow its lead.


© Copyright EMS Foundation 2020. All rights reserved.



The Long Tentacles of Safari Club International (SCI) Undermining Conservation Efforts in Africa

28th November 2019

The SCI exists to ‘protect the freedom to hunt’ and promote ‘wildlife conservation worldwide’. Since 2000, the organisation has spent $140 million on achieving its first objective through ‘policy advocacy, litigation and education for federal and state legislators to ensure hunting is protected for future generations.’ A little-known fact is that it also has a ‘donate’ tab on its website. This is interesting because the arguments made in favour of hunting in southern Africa typically entail an attack on NGOs that raise money for ‘animal rights’ as mere emotion-exploiting agents. If you happen to consider that animals are individuals with their own interests and advocate for an integrative rather than aggregative approach to conservation, you are likely to be dismissed as an emotional ‘animal rightist’ (God forbid!) and somehow ‘unscientific’. This is partly a function of the effective propaganda employed by the likes of the SCI, among the world’s most powerful lobby groups. 

It is indeed fascinating that hunting lobbying groups accuse ‘western’ NGOs of unduly influencing conservation policies in African countries. But the very western SCI Foundation (SCIF) – that carries out the second arm of the SCI’s mission – has long had its tentacles in African conservation policy formation. A recent article, for instance, articulates the SCIF’s interest in the 2019 Botswana elections. A win for President Masisi was good news for the SCI, as he controversially reinstated trophy hunting in what had become a veritable wildlife haven. Anti-hunting sentiment has successfully been brandished as ‘Western’ and the SCI has managed to paint itself as a messiah for Africa’s rural communities, as if trophy hunting is somehow African. The subversion of concepts to advance a killing cause is astounding in itself, but the depth of the SCIF’s influence goes far beyond writing articles: ‘SCI and SCIF have met with President Masisi… to express our support for Botswana in these [hunting reintroduction] efforts.’ 

They have had to wait for some time – 5 years – but ultimately appear to have been successful. But it turns out that this is hardly a new engagement in Botswana. A recent book notes that ‘until 2007, SCI’s primary support to conservation in Botswana to date had been the sponsorship of a 2002 Southern African Wildlife Consultative Forum (AWCF) chaired by the director of Botswana’s Department of Wildlife and National Parks, Joseph Matlhare. SCI has generated some notoriety in international conservation circles for lobbying against Botswana’s ban on lion hunting’ (emphasis added). No wonder the SCI has made a fuss about ‘animal rightists’ meeting with CITES delegates – it doesn’t like other voices stepping on its turf. 



South Africa’s Positional Play at CITES is Poor Form

Written by Dr Ross Harvey, PhD (Economics)

On 6 November 2019, the South African National Biodiversity Institute (SANBI) and the Department of Environment, Forestry and Fisheries (DEFF), provided feedback to interested stakeholders on the outcomes of proposals submitted to the 18th Conference of the Parties (CoP18) of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Meeting in Geneva in August 2019, due to tragic circumstances preventing the meeting from taking place in Sri Lanka in May, the South African delegation doggedly fought for its version of ‘sustainable use’ to be adopted, but was roundly defeated, much to its chagrin. Stakeholders in the wildlife ranching industry were at pains to moan about how ‘western’ NGOs have ‘captured CITES’, which in their view is a trade convention as opposed to a conservation convention. It might be worth reminding everybody that the very first part of the preamble to the Convention text recognises ‘that wild fauna and flora in their many beautiful and varied forms are an irreplaceable part of the natural systems of the earth which must be protected for this and the generations to come.’ Every element of the trade regime is premised on this need for protection.



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