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.