EMS FOUNDATION, ANIMAL LAW REFORM COMMENT ON VARIOUS RHINO HORN REGULATIONS AND NOTICES 2018 

The conclusive comments include but are not limited to the following points:

1. The Documents are problematic as they still allow legal loopholes in both the domestic trade and regulation of rhino horn as well as across borders. 

2. In some instances, the provisions are contrary to South Africa’s CITES obligations and believe these can be exploited by persons involved in the trade. These loopholes need to be closed prior to being promulgated. 

3. Furthermore, we reiterate our problems in allowing the legal domestic trade of rhino horn. 

4. The Documents make exemptions for the State which appear to be limitless in their application. This grants Government too much leeway with no transparency as to what is done with these horns. There needs to be complete transparency and accountability of government and any other institutions that receive exemptions from the general application. 

5. Permitting needs to be transparent and the national database accessible. 

6. We strongly support the need for job creation and the redress of apartheid-era injustices. However, in the efforts to create a more equal society the State should not be supporting a transfer of wealth from the poor to the rich or confuse wealth extraction with wealth creation which is a likely outcome of its market-based operationalisation of sustainable development and ‘sustainable use’. 

©EMS Foundation 2018. All Rights Reserved