The EMS Foundation and Ban Animal Trading, authors of the investigative report called the Breaking Point Report: Uncovering South Africa’s Shameful Live Wildlife Trade with China, the second in the Extinction Business series, have expressed their disappointment at the inadequate official response from the Minister of Forestry, Fisheries and the Environment in an open communication.

The Report published in 2020, highlighted the fundamental problems which are systemic in nature and relate to overarching policy issues. At the time, the authors welcomed the Minister’s commitment to investigating the serious issues raised in the Report.

The matter of the Report related to South Africa’s legal wildlife trade with China, at the time of the publication in the Minister committed to investigate the serious issues raised in the Report, within a three-month period and committed to: strengthening the permitting system, greater transparency within governmental systems and access to information. The Minister also acknowledged that civil society has a role to play in holding government to account and therefore government should be transparent.


Image Credit: Smaragda Louw / South African Rhino in Chinese Zoo

©The EMS Foundation 2021. All Rights Reserved.




8th June 2020

On the 21st of May 2020 Minister Barbara Creecy publicly responded to the EMS Foundation and Ban Animal Trading Report on the legal wildlife trade between China and South Africa. The EMS Foundation and the Ban Animal Trading organisation have drafted a memorandum regarding the measures that should be taken in response to the aforementioned report.

©The EMS Foundation 2020. All Rights Reserved.





The Minister of Environment, Barbara Creecy, initiated a meeting with the EMS Foundation and Ban Animal Trading in response to the publication of The Breaking Point Report which highlighted the shameful live wildlife trade between South Africa and China. The meeting was held this morning.

We welcome the Minister’s commitment to investigate the serious issues raised in our Report, within a three month period. 

We also welcome the Minister’s commitment to strengthening the permitting system, her commitment to greater transparency within governmental systems and access to information produced by the Department, and the provinces. The Minister acknowledged that civil society has a role to play in holding government to account and therefore government should be transparent. 

The Minister recognised that national government has the overall responsibility and the obligation to ensure that the system implementing CITES complies with CITES regulations. 

The Breaking Point Report showed the fundamental problems which are systemic in nature and relate to overarching policy issues. We were disappointed that the Minister was not willing to engage in policy discussions at this stage but she did commit to doing so in appropriate forums. 

The Minister would not agree to a moratorium on the international export of live wild animals. We believe a Moratorium is an appropriate first-step response to addressing the expansive systemic problems. Given the degree and nature of the failings of the current system, it would be irresponsible to continue exporting wild animals until the investigation has been completed and the problems have been addressed. For these reasons, particularly given the fallout from COVID-19, we will continue to push for a Moratorium. 

We believe our Breaking Point Report contains sufficient information to enable the Minister and her Department to identify the transgressions immediately. Over and above our Report, which is the tip of the iceberg, the Minister’s Department has all the information to hand to begin with their investigation immediately.  

The organisations agreed to provide the Minister with a Memorandum that will highlight issues to be included in her investigations as well as recommendations that will address the inadequacies in the systemic framework.  

We look forward to the results of the investigation.  As environmental, social justice and animal protection organisations we will continue to speak up for animals and the environment. 

The report can be sourced here:

Contact Details:


 Michele Pickover, DIRECTOR, THE EMS FOUNDATION                                                      




© 2020 EMS Foundation. All rights reserved.





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.




A SPECIAL REPORT BY: The EMS Foundation and The Ban Animal Trading Organisation

17th May 2020


The wild animals within the borders of South Africa are part of the heritage of every South African and we have the right to demand that our government protects wild animals against exploitation and to demand accountability from government as to what it does in this regard. Government is empowered by a cogent body of laws to perform this function and it is obliged to do so by international treaties. It is urgently necessary for government to comply with its responsibilities not only because of the ethical, moral and legal compunction to do so but also because the export of our wild animals for the financial gain of a few has become big business.

South Africa has become the largest exporter of live wild animals to Asia, where many wild animals are killed to extract potions from their carcases and are eaten as delicacies. Some are sent to languish in atrocious zoos. Some are inserted into the murky world of the illegal wildlife trade. The reality is that the South African government fails to apply its strong regulatory powers and by design or neglect allows strikingly large numbers of animals to be exported.

The EMS Foundation and Ban Animal Trading, both NGOs, have investigated the export of a large sample of wild animals to China and their findings are set out in the Breaking Point Report which is hereby released. 

The legal trade with China is extensive, with glaring violations overlooked by authorities and benefits flowing to a few wealthy traders. The legal trade also acts as a cover for illicit trade. CITES legal wildlife trade monitoring systems contain extensive loopholes, gaps and opportunities to launder illegal items into the legal market.



EMS Foundation

PO Box 3018, Honeydew 2040
South Africa
168-304 NPO

Contact Us

Get Involved

Interested in becoming a Supporter, Partner or Sponsor or want to find out other ways to get involved? Find out more