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.





7TH MAY 2020


The captive breeding of wild animals and the use of their products for food, clothing and medicine has played an important role in the Chinese culture.

China has shut down domestic wild animal traders on fears that their goods sparked the coronavirus pandemic. China’s National People’s Congress imposed a ban on the sale and consumption of wild animals in the country on the 24th February 2020.

Captive wildlife industries in China have experienced unprecedented growth in recent decades. The Wildlife Animal Protection Forum South Africa, in their invited submission to the Chinese government, has chosen to focus on four such industries:

The Chinese fur industry is the largest in the world. According to International the Fur Federation data, Chinese retail sales of fur are worth nearly US $17 billion per year. The image below shows workers skinning minks at a farm in China. In addition to being a major exporter of mink pelts and garments, China also imports a large number from Europe and North America. Image Credit National Geographic




WRITTEN BY: Jared Kukura

Dare to criticize the opinions of those promoting the exploitation of wildlife for economic benefit, and you will likely find yourself engulfed in frivolous drama that takes away from the real issues facing conservation. Craig Packer, and many others, know this all too well.

Packer was once Tanzania’s leading lion conservationist with decades of research experience. That is until he was banned from the country for his outspoken criticism of the trophy hunting industry. His criticism was well supported though, his studies showed that trophy hunting was the leading cause of declining lion numbers in his areas of study.

Subsequent research confirmed Packer’s studies and noted lion numbers declined most in areas with short-term hunting leases. The short-term leases were both the most unsustainable and the most profitable for the government (surprise, surprise). Additional research also suggested Tanzania’s policies failed to adequately protect habitat and reduce illegal harvest of other species, leading to continual declines in wildlife numbers.

But, conveniently for Tanzania, trophy hunting is largely portrayed in a positive light when it comes to conserving the country’s wildlife. Trophy hunting, proponents state, protects more land than any other industry and creates economic benefits for rural communities. However, the difference in perspective has less to do with the promotion of trophy hunting’s positives and more to do with the silencing of trophy hunting’s negatives.

Criticism of the trophy hunting industry and Packer’s dismissal, while dramatic, failed to spur changes in Tanzania’s conservation policies. This happens all too often in conservation but it cannot happen now with the wildlife trade considering the implications of the COVID_19 pandemic. The debate over whether we should ban the wildlife trade can be dramatic. But we must ensure the debate goes not detract us from acting and transforming conservation to benefit humans and wildlife.

We are in the midst of a global pandemic likely caused by a virus jumping from wildlife to humans. To date, COVID-19 has killed more than 240,000 people and has ramifications beyond an increasing death toll. Global poverty is expected to rise for the first time in decades because of mandated shutdowns aimed at stopping the spread of the virus.




 WRITTEN BY: Jared Kukura

There is a clear divide in the conservation world. Despite most organisations agreeing wildlife trade caused the COVID-19 pandemic, there is no consensus on the path forward.

An open letter released by the Lion Coalition called on the World Health Organisation (WHO) to “release a formal position statement containing clear advice to governments to institute comprehensive and rigorously enforced bans on live wildlife markets and to close down the commercial wildlife trade which poses a risk to public health.”

However, a rebuttal in the form of another open letter addressed to the WHO and United Nations Environment Programme (UNEP) cautioned against banning wildlife trade. This letter, published by Resource Africa, stated “It is vital that any actions taken are appropriate and lead to socially just outcomes which contribute to – not detract from – the development of economically resilient livelihoods for those hundreds of millions of the world’s most vulnerable who depend on wild resources for their survival.”

On the surface, it sounds like the position taken by Resource Africa’s letter is an appropriate middle ground. They warn not to imperil those impacted most by the current pandemic with a solution that makes their lives even worse. However, the stance taken by the Resource Africa letter fails to grasp a problem inherent in today’s world, economic growth.

Economic growth is not compatible with the conservation of biodiversity. Additionally, people living in rural communities are most at risk of adverse impacts from biodiversity loss and it is clear economic growth is not the answer for improving rural livelihoods.

Promoting wildlife trade as an economic benefit does a disservice to those hundreds of millions of vulnerable people the Resource Africa letter claims to want to help. The Lion Coalition letter has the correct position, we must ban wildlife trade to protect biodiversity and those living in rural communities all around the globe.



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