The High-Level Panel of Experts Report 2020

On Sunday the 2nd of May 2021, Minister of Environment, Barbara Creecy, released the High-Level Panel of Expert’s Report, which contains recommendations in relation to policies and regulations on the hunting, trade, captive keeping, management and handling of elephants, lions, leopards, and rhinos in South Africa.  

After the EMS Foundation/Ban Animal Trading publication of The Extinction Business: South Africa’s Lion Bone Trade in July 2018 was sent to the Parliamentary Portfolio Committee on Environmental Affairs (PPCEA),  the Committee took the decision to hold a Colloquium on Captive Lion Breeding for Hunting in South Africa: harming or promoting the conservation image of the country on the 21st  and 22nd August 2018. Presentations to the Committee were made by animal protection organisations and the breeding and trophy hunting industries. On the 8th November 2018 the Committee’s Report was tabled and it clearly stated that the captive lion breeding and hunting industry did not contribute to the conservation of lions and that the industry was damaging South Africa’s conservation and tourism reputation. The Portfolio Committee instructed that the Department initiate a review of policy and legislation in order to stop the captive lion industry. 

To this end, on the 25th February 2019, the Minister gazette the Notice of intention to appoint a high-level panel for review of policies on matters related to management of elephant, lion, leopard, etc. On the 10th October 2019 Minister Creecy gazette the establishmentof the High Level Panel.  A report by this Panel was submitted to the Minister in December 2020, the report was accepted by Cabinet in March 2021.  

On Sunday 2nd May 2021 Minister Creecy announced that: “the Panel envisages secured, restored, and rewilded natural landscapes with thriving populations of elephant, lion, rhino and leopard as indicators for a vibrant, responsible, inclusive, transformed and sustainable wildlife sector”. Minister Creecy, in an interview with Stephen Grootes on SAFM on the 4th May, also said that South Africa is moving away from from domestication and agricultutrisation of wild animals –  a practice that has brought us into conservation, environmental and tourism disrepute internationally. 


In our statement, today,  the EMS Foundation concentrates on one of the recommendations of the High-Level Panel“The ending of certain inhumane and irresponsible practices that greatly harm the reputation of South Africa and position of South Africa as a leader in conservation. 

The captive lion industry poses risks to the sustainability of wild lion conservation resulting from the negative impact on ecotourism which funds lion conservation and conservation more broadly. The panel recommends that South Africa does not captive breed lions, keep lions in captivity, or use captive lions or their derivatives commercially.”

Minister Creecy has requested that the Department of Fisheries, Forestry and Environment (DFFE) action this recommendation to ensure that the necessary consultation for implementation is conducted.

The EMS Foundation has been actively lobbying government on this issue since its inception in 2014. On the 27th of March 2020, the High-Level Panel of Experts, publicly requested written submissions to be made in respect of the management, breeding, hunting, trade, handling and related matters of elephant, lion, leopard, and rhino. On the 15th June 2020 the EMS Foundation and Animal Law Reform South Africa made a submission to the panel of experts, as did sixty-nine other organizations and individuals.  

On the 6th of October the EMS Foundation and Animal Law Reform South Africa made oral submissions and answered questions from the High Level Panel of Experts with a number of other organizations.

Further written questions were communicated to the EMS Foundation and Animal Law Reform South Africa on the 20th of October and these were extensively answered on the 2nd November 2020. 

A Basic Framework for the Resolution of Issues Relating to the Commercial Captive Breeding of Lions and Other Big Cats in South Africa 

The captive bred lion industry was originally exposed and highlighted in 1997 by the Cook Report.  Three successive environmental Ministers in South Africa made undertakings to investigate the industry, these include Dr Pallo Jordan, Mr Valli Moosa and Mr Marthinus van Schalkwyk.  While this industry continued to expand it has continued to attract worldwide, negative attention and criticism. 

In November 2020, the EMS Foundation, Humane Society International-Africa and Blood Lions submitted to the High Level Panel a basic framework for the resolution of issues relating to the commercial captive breeding of lions and other big cats in South Africa. 

These are the key points, in relation to this issue, that the EMS Foundation and Animal Law Reform made in October 2020 to the High Level Panel, these are some of the examples of immediate actions that can be taken by the South African government:

  • Announce that no new permits to keep captive lions will be issued and that existing permits will not be renewed.
  • Amend the conditions in the existing permits to protect the welfare of captive lions.
  • Amend the conditions in the existing permits to require the sterilization of all captive lions.
  • Set a zero quota for the export of lion bones in terms of CITES in order to remove the financial incentive to circumvent the law. Allowing the industry to continue to kill lions for the trade in lion’s bones as a means of limiting the number of lions while government is closing down the industry should NOT be considered as this will be endorsing criminality and supporting the illegal wildlife trade. Research has clearly shown that the legal trade of lion bones is part of the illegal trade.
  • Conduct an independent forensic audit of all lions and big cats in captive breeding facilities and the industry as a whole.
  • Develop a comprehensive national plan for dealing with the current captive lion population in a way that is humane and promotes both the conservation of the species as a whole as well as the well-being of those animals as far as possible. It should be done in such a way that regulates people to create infrastructure for true sanctuaries, repurposes jobs and reskills workers. Government must collaborate with animal welfare and protection organizations, civil society and other stakeholders who have the skills to deal with animal welfare matters and repercussions. 


Following on from the High-Level Panel of Experts Report, and in relation to the captive lion industry, the EMS Foundation cautiously welcomes the Minister’s statement that: “the breeding, petting and hunting of captive lions and the trade in their “derivatives” is something that the government does not want.” The government has been saying that it does not want this industry since 2018, when Parliament endorsed the Portfolio Committee on Environment report calling for the closure of the industry and the end to the lion bone trade.

Notwithstanding the need to follow procedural processes and the actual adoption of policy outlawing it, what we need to see is action. We are therefore urging the Minister to take swift, corrective, and practical steps so that this abhorrent industry is closed down once and for all and with no loopholes.

If this is not done as soon as possible it may have massive welfare implications for the many of thousands of lions held in captivity in South Africa who could in the interim by inhumanely treated and killed for their bones.  It could also mean a rise in the illegal bone trade.

We are also very concerned about the other big cats, particularly tigers, in the captive industry. Minister Creecy needs to include them in her Plan of Action.

For enquiries contact: Michele Pickover, Director EMS Foundation

IMAGE CREDIT: The South African Police Service

© 2021 EMS Foundation. All rights reserved





22ND APRIL 2021

Tigers (Panthera tigris tigris) are included in Appendix I of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), which assembles 183 Parties, including South Africa.

On several occasions since early 2016 we had been asking your Department (DFFE) if it knew the number of Asian tigers in South Africa and if they monitor and audit the facilities in South Africa that keep Asian Big Cats. They continuously and consistently replied that they do not have any information as tigers are ‘exotics’ and therefore not their responsibility. This despite the fact that they are CITES Appendix I animals.

In 2016 CITES Decision 17.229 forewarned the Parties that the Secretariat was going to conduct a review of the number of facilities keeping Asian big cats in captivity in the territories of Parties and the number of Asian big cats kept in these facilities; and to review legal and illegal trade in Asian big cats from or through such facilities to identify any facilities which may be of concern.

On the 16th February 2018 we became aware that the CITES Secretariat has issued a Notification to the Parties to seek such information from the Parties, we emailed your department on the same day asking if they had this information available and the reply was, “we will be communicating with Secretariat on how we will deal with this matter as you can appreciate that there are 9 Provinces in South Africa and we have to coordinate the information”. On the 28th February 2018, together with Ban Animal Trading, we sent a letter to the CITES Secretariat in relation to Decision 17.229. Appended to our 2018 letter to CITES was a non-exhaustive list of 66 facilities/individuals keeping tigers in South Africa that we were able to trace as a result of internet searches and on-site investigations.

According to DFFE, in response to an EMS Foundation Promotion of Access to Information Act (PAIA) request1 there are 72 facilities/individuals keeping 451 Asian big cats in captivity.2 

This information has not been independently verified. Nonetheless, it is clear that South Africa is allowing intensive operations breeding tigers on a commercial scale.

The increasing trade in tigers and tiger parts is part of the unsustainable growth in the legal global wildlife trade. The The commercial flow of captive-bred tigers is largely driven by the increasing demand for live tigers and tiger parts and derivatives from Asia. This demand is therefore one of the most important factors for the current high levels of tiger poaching, captive breeding, and trafficking. Any trade in captive-bred specimens from South Africa is having an indirect but significant impact on tiger species whose populations are already depleted. In addition, allowing such trade obstructs global anti-poaching and trafficking endeavours.




An Open Letter to the Minister of the Environment, Forestry and Fisheries Barbara Creecy

25th March 2020

Dear Honourable Minister Creecy,

Since at least as far back as the late 1990s, various NGOs have warned your department about the harmful and negative effects of breeding lions (and other big cats) in captivity. Yet, the South African government has done nothing to slow the growth of the captive lion breeding industry, nor has it given any indication of wanting to do so. This letter lays bare the facts and calls for immediate action.

First, it details the risks embedded in captive lion (and other big cat) breeding and why the industry should be terminated.

Second, we note that letter after letter to your Ministry and Department goes unheeded. It seems that industry voices – those with a vested interest in acquiring short-term benefits from exploitative breeding of lion (and other big cat) cubs for human interaction, canned hunting and the lion bone trade – provide the tune to which the policy fiddle dances.

Finally, tourism – the goose that lays the golden egg in the South African economy – is dead for the foreseeable future. Not only has South Africa’s willingness to supply Asian wildlife markets created zoonotic disease spillover risks, which have led to the need for travel bans, but the imposition of the latter means that thousands of captive lions (and other big cats) will now be left to starve to death without tourism dollars. Had the government acted in 2009 (when a plan was presented to your Department) and when there were far fewer lions (and other big cats) in captivity, this catastrophe would have been avoided.



The South African Captive Bred Lion Industry and Associated Global Health Risks

Memorandum Of Demand

The Presidency


Cape Town



Minister of Tourism

Private Bag X424




Minister of Health 

Private Bag X828




Minster of the Environment, Forestry and Fisheries

Private Bag X447




Ambassador to South Africa

25 Rhodes Avenue





21ST March 2020

The Honorable Mr President Cyril Ramaphosa, Minister Kubayi-Ngubane Mmamoloko, Minister Zweli Mkhize, Minister Barbara Creecy, Ambassador Lin Songtian,

On the 21st and 22nd August 2018 a number of wildlife organisations made detailed and compelling presentations to Parliament on the massive problems and concerns with South Africa’s Captive Lion Breeding industry. 

This included a presentation on an 18-month research and investigation report into South Africa’s role in the international lion bone trade. 

As a consequence of the extensive evidence presented against the captive big-cat breeding industry and its abhorrent offshoots such as canned hunting and the unregulated lion bone trade, Parliament instructed the Minister of Environmental Affairs (at the time) and her Department – in December 2019 – to shut down the industry, which is a major ethical, legal and administrative embarrassment for South Africa. 



Alleged Smuggling of Lion Bones Called “Legal” by Minister’s Spokesperson

Media Release from Members Of The Wildlife Animal Protection Forum South Africa (WAPFSA)

The recent news release of 342 kg of lion bones discovered on an outbound flight at OR Tambo Airport on 1st October 2019 which was subsequentially confiscated, has had extensive media coverage.

The comment from the Director of Communications at the Department of Environmental Affairs, Albi Modise was that “although the export of lion bones born in captivity was legal, a special permit was required to send them out.” This statement was reported by a number of media outlets, including World News, The Straits Times, BBC News, EWN, MSN, Business Standard, 7D News, and This is Money UK, Getaway, Jacaranda FM, and NST.

The export of lion bones from South Africa is currently illegal. In order to be legal, a yearly quota is supposed to be proposed by the South African Scientific Authority including the South African National Biodiversity Institute (SANBI) through the National Convention on the international Trade in Endangered Species of Wild Fauna and Flora (CITES) Management Authority, then approved and communicated to all provincial conservation departments and managed at National level under the authority of the Minister of Forestry and Fishery and Environmental Affairs, Barbara Creecy.



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