World Environment Day 5th June 2021

The EMS Foundation will be making a series of statements, the contents of which are in the public’s best interest. We are focusing our attention on the conservation of South Africa’s wildlife, especially with regard to the essence of the decision making process following the release of the Report by the High-Level Panel of Advisors to the Department of Forestry, Fisheries and the Environment.


How are laws and policies about wildlife, the biodiversity and the natural environment made in the South African government?

Making new laws and policies involves a number of stages during which times key issues are debated and negotiated before being finalised as official government policy or being passed as a new law. This process can take years from the proposal stage until it’s impactful. 

A government policy outlines what DFFE hopes to achieve and the methods and principles it will use to implement them. A policy document states the goals and laws required to achieve these goals. 





Endangered Species Day 21st May 2021

The EMS Foundation will be making a series of statements, the content of which is in the public’s interest. We are focusing our attention on the conservation of South Africa’s wildlife, especially with regard to the essence of the decision making processes.


Exquisitely beautiful and elusive, leopards unsurprisingly form part of South Africa’s so-called iconic ‘Big Five’, yet their current conservation status is a population in persistent decline[1] and, alarmingly, they are extinct in 67% of South Africa[2].  

According to peer-reviewed research papers human-mediated leopard mortality is widespread, especially amongst private agricultural and wildlife ranches in South Africa. Climate change, trophy hunting, illegal hunting, killing for skins,’ legal destruction’, revenge killings, by-catch from snares for the bush meat trade and lack of adequate protection from government, are pushing leopards in South Africa to the brink of extinction.  Moreover, unreported and illegal killing of wildlife is widespread across southern Africa and therefore also extremely pertinent. 

Nonetheless, it appears that the Department of Fisheries, Forestry and Environment (DFFE) is attempting to appease the powerful hunting lobby by steamrolling through a trade and trophy hunting agenda of leopards without adequate scientific evidence. 





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




© 2021 EMS Foundation. All rights reserved

The EMS Foundation, represented by Environmental lawyers Cullinan and Associates, submitted comments on the Draft Guidelines for the Transportation of Live Animals by Sea to the Department of Agriculture, Land Reform and Rural Development in South Africa on the 30th April 2021.

The position of the EMS Foundation is that South Africa should ban the live export of animals by sea (“live exports”) due to the nature of this mode of transportation, the exportations cannot be regulated to ensure that the welfare of animals can be protected during such a process.

Consequently, the EMS Foundation is of the view that neither regulations nor the Guidelines will be able to achieve the purpose which the Guideline purportedly aim to achieve.

Image Credit: Trevor Collens/AAP Published in The Guardian

© 2021 EMS Foundation. All rights reserved




© 2021 EMS Foundation. All rights reserved


The nineteenth regular meeting of the Conference of the Parties (CoP19) is tentatively scheduled to be held in Costa Rica March 3rd-14th 2022. The US Fish and Wildlife Service invited submissions to include information and recommendations on animal and plant species for which the United States should consider submitting proposals to amend Appendices l and Appendices ll of CITES at CoP19.

The EMS Foundation has exposed deficiencies in the legal wildlife trade and has published the same in a number of reports after completing exhaustive research.

The relevant South African and American government agencies are allegedly conducting their own investigations as a result of the findings of these reports.

The World Health Organisation, the World Organisation for Animal Health and the United Nations Environment Programme have recently made an unprecedented call to governments and national authorities asking them “to suspend the trade in live caught wild animal of mammalian species for food or breeding purposes and to close sections of food markets selling live caught wild animals species as an emergency measure.

© 2021 EMS Foundation. All rights reserved



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