Comments on the Notice of Intention to set Zero Export Quota for Trade in Lion Bones 2025

The Director-General: Department of Forestry, Fisheries and the Environment
FAO: Ms Malepo Phoskoko
Private Bag X447
Pretoria 0001

Delivered by email to: cites@dffe.gov.za 

21 October 2025

Comments on the Notice of Intention to set Zero Export Quota for Trade in Lion Bones 2025

Dear Ms Phoskoko,

Thank you for the opportunity to comment on the Notice of Intention to set a zero export quota for trade in lion bones sourced from captive breeding operations in South Africa for the 2025 calendar year, gazetted under notice 53394.

CITES

At CoP17, an annotation was added to the Appendix II listing of Panthera leo, specifying that: “…a zero annual export quota is established for specimens of bones, bone pieces, bone products, claws, skeletons, skulls and teeth removed from the wild and traded for commercial purposes. Annual export quotas for trade in bones, bone pieces, bone products, claws, skeletons, skulls and teeth for commercial purposes, derived from captive breeding operations in South Africa, will be established and communicated annually to the CITES Secretariat.”

The CITES lion bone export quota has never specified the export of bone products, such as lion bone cakes, and claws and teeth. Lion bone cakes are made by boiling cleaned bones for several days to condensing down the gelatine. The bone pieces are removed, and the remaining liquid is gradually reduced to a glue-like consistency, which hardens into an odourless cake. It is normally cut into squares for sale and generally consumed by dissolving small pieces into medicinal wine. Teeth and claws are made into expensive jewellery, commanding much higher prices than in their raw form. 

These smaller parts and derivatives are currently still legal to export with a CITES permit, are in high demand and have a high market value in Southeast Asia, particularly in Vietnam. 

At CoP17, Decisions 17.241 relating to Panthera leo were adopted, stating among others the intent:

  • to undertake studies on legal and illegal trade in lions, including lion bones and other parts and derivatives, to ascertain the origin and smuggling routes, in collaboration with TRAFFIC and/or other relevant organisations;
  • to undertake a comparative study of lion population trends and conservation and management practices, such as lion hunting, within and between countries, including the role, if any, of international trade.

To our knowledge, this still has not been undertaken and we therefore do not have a reasonable indication what impact the legal trade has on the conservation of Panthera leo across its range states.

Research

Blood Lions in collaboration with the World Animal Protection have recently published a peer-reviewed paper that looked at whether the commercial captive breeding of lions in South Africa, to satisfy the commercial demand for lions and their body parts, could provide a sustainable solution for wild lion conservation. An existing evaluation framework was adapted to assess the impact of commercial captive lion breeding on wild lion populations, considering five criteria: consumer preferences, market supply and demand, cost efficiency, breeding stock maintenance, and protection from criminal activity. 

We ​reviewed 126 peer-reviewed articles and 37 public reports published between 2008-2023. The analysis identified several red flags suggesting that lion farming may harm wild lion populations by accelerating – and potentially facilitating – commercial demand for lions and their body parts, including bones, claws and teeth. The review also highlights key knowledge gaps that must be addressed to better understand the wider implications of the captive lion industry. Recommended areas for future research include: consumer preferences for lion products sourced from either captive or wild populations, supply and demand interactions relating to captive lion products, economic comparisons between farmed and wild lion products, the genetics and genetic health of captive lion populations, and the extent of illegal activity taking place between Africa and destination countries in Southeast Asia.

In the 2018 Non-Detriment Finding Assessment for African lions, the Scientific Authority of South Africa concluded that exporting captive-bred lion trophies, live captive-bred lions for zoological or breeding purposes, and/or trading lion skeletons from the captive population did not negatively impact South Africa’s wild lion population. While wild lion populations in South Africa are currently considered stable, this new research shows that using captive breeding as a tool to meet the demand for lion commodities may pose potentially detrimental effects on already vulnerable lion populations and other big cat species across other range states.

Even though we are in full support of the Minister’s decision to set a zero lion bone quota, we have considered whether a zero quota or a deferred quota is better from a legal perspective. We believe that a zero quota is an explicit prohibition written into the CITES framework, which is stronger from a strictly international / CITES perspective than leaving the quota undefined. However, we are in the process of obtaining an independent legal opinion on this matter.

Furthermore, we would urge the Minister to consider taking this zero lion bone export quota one step further and explicitly include bone products, teeth and claws. These would be important steps to pave the way for South Africa to phase out its commercial captive lion industry entirely. 

We sincerely hope that you will take the above comments into consideration taking the final decision on the 2025 CITES lion bone export quota.

Stripes, Manes & Myths: Liger Facts

What are ligers?

Ligers are the offspring of a male lion and a female tiger, whereas the offspring of a male tiger and a female lion are called tigons. Male ligers are commonly sterile, but females can be fertile.

Ligers are generally much larger than their parent cat species due to what is called growth dysplasia. Under natural conditions, the male lion carries a growth-promoting gene and the lioness a growth-inhibiting gene, which counteracts the male gene and keeps the off-spring’s growth in check. However, the liger lacks the growth-inhibiting gene, because the female tiger doesn’t carry such a growth-inhibiting gene. Read more HERE.

In the late 1800s/early 1900s, zoos around the world started breeding ligers for exhibition purposes, including Bloemfontein Zoo where many ligers were born. The most famous Bloemfontein liger was called Tokkelos and allegedly weighed around 360-400 kg!

Welfare issues

Breeding ligers can create a myriad of health issues, including neurological defects, sterility, cancer, arthritis, organ failure, and diminished life expectancy. Many ligers are born with (often fatal) birth defects and their abnormal growth rate puts immense stress on their internal organs and skeleton. In addition, ligers often suffer from obesity.

The tiger mother may experience birth complications, due to the unnaturally large size of her cubs, and C-sections are often required. Furthermore, their behaviour is completely different: lions are social animals and tigers are solitary cats, making it difficult for a hybrid to interact with its peers.

Can ligers exist in the wild?

The vast majority of lions and tigers cannot mate in wild, as they are geographically spread across different continents (Africa vs Asia). Hence, lions and tigers do not co-exist in the same habitat and their behavioural differences also prevent them from cohabiting, i.e. lions are social and tigers are solitary cats.

There is a small population of lions in Gir National Park (India) that live in the same protected area as tigers, where theoretically ligers could exist in the wild. However, there is no proof that ligers exist here naturally or have ever existed in the wild on the Indian continent. Even if breeding in the wild could occur, this goes against the natural rule of the survival of the fittest, as it would result in compromised genetics that would make the species less likely to survive.

What is hybridisation and how does it occur?

Hybridisation (or “interbreeding”) means the cross-breeding of individuals from two different species, subspecies, breeds, or varieties. The individuals are generally related (of the same genus) but are genetically different species. Hybridisation results in decreased genetic diversity. Human intervention is the primary cause of hybridisation. The hybridisation of lions and tigers are solely due to accidental or purposeful mating in captivity.

Since most male hybrids are born sterile, and the lineage stops with the offspring. Additionally, offspring that are not sterile would not share breeding traits, geographical ranges, or reproductive characteristics with potential mates in a wild setting. This would only occur in forced captive situations. For all these reasons, captive-bred hybrids have no conservation value.

Hybrids such as ligers are bred in captivity purely for commercial gain and human entertainment. 
They have no conservation value. Efforts should instead focus on the conservation of lions and tigers in the wild.