Lobbying for Wild Animals



The EMS Foundation has obtained official information from the South African Department of Forestry, Fisheries and the Environment via the Promotion of Access to Information Act also known as PAIA about lion exports from the Oliver Tambo International’s Airport situated in Johannesburg, South Africa.

The detailed and specific information contained in this document illustrates the magnitude of this South African industry over a very specific time frame.

Please read the full document:


Each year hundreds of thousands of wild animals are killed by trophy hunters.

The true meaning of the word trophy is a memorial of a victory in war, consisting of spoils taken from the enemy as a token of victory and power.

Trophy hunters kill wild animals for their body parts, including heads, skins, claws and in some instances the whole animal.

In South Africa international trophy hunters hunt wild and captive bred lion.

Between August 2018 and the 7th of April 2021, 80 wild lion body part shipments were exported from South Africa.






On the 2nd of May 2021 Minister of Forestry, Fisheries and Environment, Barbara Creecy, released the report from the High Level Panel (HLP) of experts, which was appointed in 2019, to review policies, regulatory measures, practices and policy positions that relate to the hunting, trade, captive keeping, management and handling of elephant, lion, leopard and rhinoceros in South Africa.

The decision to appoint a panel of experts was taken as a result of the Portfolio Committee on Environmental Affairs Colloquium that was held in Parliament in August 2018 on Captive Lion Breeding. Parliament adopted the findings of Portfolio Committee Report whose overall view was that the captive lion breeding industry did not contribute to conservation and was doing damage to South Africa’s conservation and tourism reputation.

The High Level Panel of Experts was asked to review the lion breeding industry, the rhino horn trade, rhino poaching, the elephant ivory trade, trophy hunting, the trade in leopard skins for religious and traditional use.

The HLP submitted a 600-page report to Minister Creecy and to the Cabinet in December 2020. This report was duly accepted and approved for release and implementation.





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 michele@emsfoundation.org.za https://emsfoundation.org.za

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.






South Africa bears the enormous responsibility of being the custodian of ninety percent of the world’s southern black and white rhino population. 

Yesterday the Department of Environment, Forestry and Fisheries (DEFF) published a graphic stating  that during 2020, 394 rhinos were poached for their horn in South Africa. This is apparently 33% less than the 594 rhinos that were killed in 2019, and furthermore it marks the sixth year that rhino poaching has continued to decrease in South Africa. 

Minister Barbara Creecy stated: “While the extraordinary circumstances surrounding the battle to beat the COVID_19 pandemic contributed in part to the decrease in rhino poaching in 2020, the role of rangers and security personnel who remained at their posts, and the additional steps taken by the government to effectively deal with these and related offences, also played a significant role.”

There is no mention or published graphic, however, stating that from 2011 there has been a 67% decrease in the number of white rhino, from an estimated 10 621 rhino to an estimated 3529 rhino. 

According to DEFF there were an estimated 415 black rhino in 2013 and now there are an estimated 268 black rhino, a 35% decrease in numbers.  

The confirmation of the decimation of the wild rhino population, was published, for the first time in many years, and is available in the South African National Parks Annual Report 2019/2020. 



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