Appeal to Government High-Level Panel to Review Existing Wildlife Policies, Legislation & Practices

Dr Simon Morgan urges members of the panel to consider what precedent their recommendations represent for other traded wildlife species, not just in Africa but across the globe, specifically to review existing wildlife policies, legislation & practices related to the management, handling, breeding, hunting & trade of wildlife

Click below to read the full response

To the Chairperson of the Advisory Committee
c/o Department of Environment, Forestry and Fisheries


What precedent would South African policies represent for other traded wildlife species, not just in South Africa but across the continent and globally? I query whether it will ever be possible to trade, farm and harvest any of these species successfully. What kind of message are we wanting to deliver to the Asian and global community at large about the use of wildlife species? And do we really want to create small, heavily secured farmed populations at the expense of our wild populations?

Zoonosis Risk

We must remember it is not just Covid-19 that has impacted us, but a myriad of wildlife spillover pathogens that have impacted us globally in the past. The bad conditions and mixed species environments that captive animals are generally kept in, is undeniably a perfect breeding ground for pathogens and the unregulated mechanisms of slaughter, transport and consumption ideal spillover conditions.

Further to that, we know lions are capable of contracting Covid-19, although not currently a direct re-transmission threat to us. They also harbor Feline Coronavirus2, FIV (the cat equivalent of HIV – feline immunodeficiency virus) and importantly, bovine tuberculosis (which can be passed to humans and has been identified as a growing threat, while also having resistance to a key TB antibiotic).

It is clear that South Africa does not have the resources to effectively police and control the captive wildlife industry, so managing the ongoing zoonotic risks associated with the trade in high-risk species as presented by the captive lion population and bone trade for consumptive use in Asia, does not seem plausible. Does South Africa really want to risk being the center of future Zoonotic outbreaks? We need to be seen to take decisive action in this regard, and the only way we can do so is to shut it down.

Tourism Recovery & Community Support

This further speaks to ‘Brand South Africa’ and tourism recovery from Covid-19 impacts. We have essentially lost the tourism industry in South Africa, and to ensure rapid recovery of these jobs (supporting 1 in 7 South Africans) and revenue (valued at over R120 billion annually) South Africa really needs to be seen to be putting its best foot forward.

The torrid practices in the wildlife farming and trading industries and lack of community beneficiation and job creation through captive wildlife, really means we should be focusing our efforts on tourism recovery and community support. This means we need to shut down the captive breeding and exploitation of predators in South Africa and focus on a tourism model that speaks to keeping wildlife wild (a major reason people travel to Africa), and distance ourselves from predator exploitation through canned hunting and selling of their bones to Asia.

Lions Header 23

By agreeing to trade in the wildlife products proposed, you would essentially be condoning the non-effective consumptive use of wildlife products. The proposed parts are not products that contain any real value from a medical perspective. We cannot continue to support the use of such products, especially when the global community is putting pressure on Asian governments to recognize the same, especially know under Covid-19 pressures.

For example the recent Chinese government ban on pangolin scales for use in Traditional Chinese Medicine, should be applauded and we should further support awareness around these products and their lack of medicinal value – whether it be rhino horn, lion bone or pangolins. Engaging in debates around trade undermines these efforts.

Damage to Demand Reduction Strategies

There has been great success in behavioural change campaigns and initiatives (the only way to reduce poaching to zero). How can we possibly make gains with end-users while some members from the wildlife community push for trade in some species while others pour millions of dollars in changing these behaviours, and the South African government tries to do both?

CoP17 urged us to develop and implement well–targeted, species-specific, evidence-based demand reduction campaigns by engaging key consumer groups and targeting the motivations for the demand (including the speculative nature of the demand) and develop specific messaging approaches and methods for target audiences.

Dehorning of Rhino is a sad state of affairs… Photo by Kelvin Trautman

How does the proposed stance from South Africa of allowing domestic trade (consenting that rhino horn has value) and the potential export of rhino horn, lion bones and ivory to these end-user countries, in any way support the long or short-term strategy of demand reduction agreed upon and suggested by all CITES members, including South Africa?

We need to devalue these products and not allow for criminals to benefit through speculating, while also ensuring that any stockpiles are not available for illegal use, whether privately or state owned. State claimed ownership or destruction of these products would go a long way in sending a clear message to end users and criminals.

Farming Wildlife for Human Exploits

By developing trade in a place where the animal is in abundance and/or farmed (for example in our case with lions and rhino), you will drive the species to local extinction where they are less well protected and numbers are unstable. Can we seriously consider African and Asian range states with even lower levels of governance than ourselves will be able to protect their populations, and/or trade effectively and above board with any of these and other species?

Pressure will start being applied to these and other legal and illegally traded wildlife species inside and outside of South Africa. This will always happen when the cost of farming wild animals is more than the cost to illegally harvest them, poor communities exist in the same landscape, corruption is rife and it is easy to create grey areas of what is legal vs illegal, as is the case for our lion and rhino. This has been famously noted with the Vićuna in South America, previously the poster child for sustainable wildlife utilisation, where poaching continues to wreak havoc for this species even though they extensively farm them.

Tiger have been poached to near extinction for their body parts. The subsequent market has been continuously fuelled by their farming and substituted with lion parts, and the 7,000+ tigers in farms and lion bone substitution has done nothing to allow the tiger population to recover across their range. How can we accept that profiteering from lion bone or rhino horn will put wild lions and rhino here and elsewhere on the continent at risk?Already we are seeing an upsurge in poaching of lions in Mozambique.

Photo © Blood Lions / Facebook

We are also currently suffering the impacts of the sustainable use of white rhino through trophy hunting. This practice effectively leaked horns into Asia, renewing the demand, had limited value for local communities and ultimately stimulated the rhino poaching we have endured the brunt of for over a decade now.It would seem we would have been better off with growing our wild rhino populations and being happy with a lower global number of rhino, rather than trying to exploit them for human entertainment and ultimately creating the perfect storm for poaching – leaving us now with small, privately owned and heavily secured populations while we watch our large wild populations being decimated.

The Uptake of Poaching

Rhino horn leaking from South Africa through trophy hunting mirror the now infamous ‘once-off’ ivory trades which were done, specifically that of 2008, which have been a catastrophic failure as the research soundly shows – stimulating illegal markets with a resultant increase in elephant poaching across the continent, which continues unabated today with recent upsurges into South Africa and our neighbours.

International efforts to reduce the demand for illegal wildlife products are seriously hampered when we grow small, legal markets that we cannot control due to limited capacity for regulation or enforcement in both source and destination countries.

Botswana Elephant Poaching Report
Photo sourced from www.conservationaction.co.za

Poaching hasn’t abated in South Africa. Our ability to control the illegal movement of horn hasn’t improved. The prosecution of poachers and illegal smugglers of rhino horn is still very weak. We have seen that the CITES permitting system has been exploited from South Africa. And now we propose to open up legal channels which can be further exploited by the criminal elements outside and within our enforcement and control channels.

Rhino horn and ivory sales are illegal in China and other end-user countries. The process that it would take to legalise this trade is going to be more than onerous, and over the course of this effort we will continue to show a lack of a united front against the ongoing poaching and exploitation.I previously wrote about the waste of time and division this trade debate has had since 2010, and continues to have.

Unite on a Global Front

We need to stop the debating, time-wasting and division of effort by finally putting this to rest. There is just not enough sound research, or local and global support to consider trade of ivory rhino horn and lion bone anymore. Our efforts in South Africa need to fall into place with this greater conversation.

Let us unite with a single objective and forge a path to develop stronger political will to halt the illegal wildlife trade. It doesn’t help just doing that in South Africa, we need it to include Asian states and global partners. Let the world, who is holding summits and symposiums on the matter, see that we are standing together and appreciating their efforts.

For the sake of the people, we trust that you will use your combined time, energy and influence to develop and implement initiatives which will have long-lasting impacts, not just on the wildlife populations secured by privileged private owners in South Africa, but those in our nationally protected areas, along with the myriad of other wildlife species in South Africa and beyond our borders, the demise of which hangs on the precedents suggested here by yourselves.

Yours in conservation,
Simon Morgan, PhD
Co-founder and Trustee, Wildlife ACT Fund