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

Memorandum Of Demand

The Presidency


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. 

As far back as 2016, the International Union for the Conservation of Nature (IUCN) called on the government to terminate the industry, a motion that has been ignored. 

There is grave public concern, both locally and internationally, that both DEFF and the Minister ignored a Parliamentary instruction and that they continue to allow this truly repulsive industry, which threatens our country’s tourism and conservation reputations, which are indivisibly linked. Reducing wild animals – icons of conservation, on which South African tourism ultimately depends – to mere agricultural commodities, as was witnessed through the bizarre passing of the amended Animal Improvement Act, is a notable embarrassment, not least because nobody in the Environmental Governance ambit knew that the Department of Agriculture had squeezed the Bill through parliament without any environmental oversight. 

In a matter of a few weeks almost a million people signed petitions in 2017 and in 2018 specifically against South Africa’s lion bone trade[1] while between 2016 and May 2019 over three million eight hundred thousand people signed against the Captive Cat Industry.[2]

There is a tsunami of domestic and international criticism against South Africa, with many conservation bodies, lion scientists and NGOs affirming that the government’s unfettered support for this rogue industry cannot be supported scientifically, or from a tourism, economic, conservation, ethical or welfare perspective.

Controversially, South Africa is the largest exporter in the world of ‘lion’ skeletons, bones and other body parts to countries that are at the nexus of the illegal wildlife trade. South Africa’s lion bone trade has strong links to international criminal networks, is providing a legal channel for the trafficking of illegal big cat parts, and is fuelling the demise of wild big cat populations. 

The legal quota creates and promotes parallel illegal markets for illegally obtained body parts to be laundered through “legal” markets. The legal export of bones from farm-bred caged lions allows the illegal export of wild lion bones to continue, and allows the market to thrive. It is also impossible to differentiate between body parts from wild and captive animals, not that law enforcement officials would have the time or technological capacity to do so even if they could.  

Failure of the Minister of Environment to ban the industry, or at least to take intra-government measures to do so, damages Brand South Africa’s image and tourism. One in every seven South African workers rely on continued employment in the tourism sector to sustain their incomes. Their livelihoods are in the firing line in order to benefit only the few predatory elite in the industry. Tourism itself is a National Asset. South Africa faces an onslaught of bad publicity because of all the elements involved in this shocking trade. Tourists will rather choose to spend their money elsewhere. A new peer-reviewed scientific report undertaken by the South African Institute of International Affairs reveals that the Big Cat breeders could cost South Africa over R54-billion over the next 10 years in loss of tourism brand attractiveness, provided the assumptions behind the quantification hold true.  

South Africa only has somewhere between 1,300 and 1,700 adult lions remaining in the wild. Between 1993 and 2014 Africa lost 43% of its wild lion population, and it keeps plummeting. For DEFF to say that captive lions will serve as a buffer to potential threats to wild lion population survival, is irresponsible in the extreme and empirically untested.  There is also not one lion scientist that has gone on record to say that this trade has any legitimate scientific or conservation basis. Most of them say that the decision is likely to do harm by encouraging trafficking in African lion and other Big Cat body parts. Evidence marshalled by DEFF to suggest that the illegal trade in parts would expand if the ‘legitimate’ industry were shut down indicates the willingness of predatory elites to flout the law. Instead of being held ransom by these elites, our government should have the courage to terminate an industry that is well past its sell-by date. 

DEFF claims that the industry is permissible because it is part of its ‘sustainable use’ paradigm. This simply is not good enough.  DEFF has not properly defined what sustainable use is. It has become a smokescreen behind which controversial decisions are rationalised, based on a narrow reading of section 24 of South Africa’s Constitution, at the expense of broader biodiversity preservation commitments made in the same section. Moreover, a recent Constitutional Court Judgement clearly points to the need for a more ‘integrative’ approach, which requires the adoption of an attitude of respect to the individuals who make up a species, an eco-system or the components of biodiversity. But this is a discussion for another day. 

The current coronavirus pandemic sweeping across the world is believed to have originated from wildlife, and to have been transmitted to people via wildlife markets.  Previous global epidemics have also been associated with wildlife markets and spread to humans via wild mammals commonly traded live in markets in Southeast Asia. The Ebola virus epidemics in West and Central Africa are also thought to have originated from wild mammals believed to be intermediate hosts through which people were infected; many such animals are also traded live in wildlife markets in the countries in which the outbreaks first occurred. Because the slaughter of captive lions is not regulated in South Africa, the probability is extremely high that we are exporting lion TB to human consumers in Asia, in addition to the fact that poorly paid ‘lion farm’ workers are susceptible to the contraction of disease from handling lion bone in South Africa prior to export. One only has to imagine the repercussions of a global shutdown on the Corona scale being attributed to South Africa’s unwillingness to terminate the big cat breeding industry. 

The trade in wildlife not only threatens human health; it is also a major contributor to the global decline in wildlife and biodiversity. According to the Global Biodiversity Assessment published by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES) in 2019, nature’s decline is “unprecedented in human history” with a million species at risk of extinction. Direct exploitation is identified as the second most important driver of biodiversity loss, behind changes in land and sea use. The report described the current global response to this crisis as insufficient, urged that “transformative changes” are needed to restore and protect nature, and asserted that “opposition from vested interests can be overcome for the public good.” The extraction of wild animals for domestic and international trade forms a significant part of the direct exploitation identified by IPBES. In many countries, animals are taken from the wild to be traded live, or slaughtered at markets, with severe negative consequences for the welfare of many millions of individual animals. 

People in Southeast Asia are consuming lion body parts from South Africa and this is happening solely because the Minister of the Environment is allowing the trade in and human consumption of lion bones and has created an expectation by the industry that such a trade will continue and flourish. By doing this the Minister is not only facilitating cruelty but is promoting illegality and a public health nightmare.

As NGO’s and civil society, we have a fundamental desire to work with the government to secure South Africa’s future and image; to fight corruption and crime; and to ensure that ethical and transparent policies are in place – policies we can all be proud of, and which serve to protect the wild animals in our collective care.  

We therefore demand that the Cabinet: 

  1. Place an immediate ban on the lion and other Big Cat bone trade for commercial purposes, including from captive sources. This needs to be applied nationally and provincially (provinces need to be instructed not to issue any CITES export permits for lion bones/skeletons). Included in this ban should be the destruction of all Big Cat bone stockpiles, as stockpiles are susceptible to raiding and expensive to maintain. 
  • All proposed amendments to NEMBA do not contain any mention to welfare. We demand that the Cabinet urgently ensure that animal protection, welfare, “five freedoms”, care and respect are included in the appropriate environmental legislation, particularly in relation to the issuing of permits for the keeping, sale, hunting and exporting of wild animals and their body parts. 
  • Close down the Big Cat captive industry by issuing urgent regulations restricting the keeping and breeding of Big Cats. 
  • Convene stakeholder meetings to discuss the dismantling of the captive Big Cat industry, including experts from the fields of animal welfare, sanctuary management and forensics, as well as NGOs.
  • Introduce and enforce legislation to close wildlife markets, particularly those at which trade in live wild animals is commonplace.
  • Introduce mechanisms designed to significantly and demonstrably reduce demand for live wild animals and their body parts, domestically and for export to Southeast Asia.




The EMS Foundation

South Peninsula Koi

The Global March for Elephants and Rhinos Organisation

The Ban Animal Trading South Africa

Big Cat Youth Ambassadors

The Global White Lion Protection Trust

Beauty Without Cruelty

Centre for Animal Rehabilitation and Education 

Humane Society Africa

Four Paws South Africa

Voice 4 Lions


Baboon Matters

Future 4 Wildlife

Vervet Monkey Foundation

Green Girls in Africa

Panthera Africa

Sea Shepherd South Africa

Cape Town Unites for Animals

The Institute for Critical Animal Studies

Animal Talk Africa

For The Love of Wildlife

Blood Lions

WildAid Africa

Born Free Foundation

Campaign to Ban Trophy Hunting

Cape Leopard Trust

Captured in Africa Foundation

IAPWA Claws Out

Coalition of African Animal Welfare Organisations

No Foie Gras South Africa

Lionsrock Big Cat Sanctuary 

Southern African Fight for Rhinos

Drakenstein Lion Park

Southern African Faith Communities Environment Institute

Cape Animal Welfare Forum

Voice 4 African Wildlife 

Animal Law Reform

International Wildlife Bond

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