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Objections to the setting of a lion bone export quota

This letter and the subsequent submission was prepared by the Coalition to Stop the Captive Breeding and Keeping of Lions and Other Big Cats for Commercial Purposes and submitted to the Department of Environment, Forest and Fisheries.


Dear Honourable Minister Creecy, Honourable Deputy Minister Sotyu and Ms Phoshoko,

Thank you for the opportunity to provide information to be considered for the determination of the 2019 lion bone export quota. This is a matter of great public concern involving our national heritage, and the protection of same for future generations, in accordance with the guaranteed Constitutional right to environment. The importance of this cannot be underestimated.

The initial establishment of a legal export quota of lion bones in 2017 was based purely on purported market dynamics in the preceding years of unregulated and uncontrolled lion bone exports, i.e. an annual average export quantity of 800 lion skeletons. However, applying some form of data to an issue does not equate to science and hence this quota had no grounding in science or research.

At the time, lion bones were predominantly a by-product of the trophy hunting industry, a situation which has changed dramatically since the USA’s 2016 restrictions on trophy imports. This was a significant turning point for the industry that reacted by starting to breed lions purely for the bone export market. This had further grievous animal welfare implications, as a lion bred for its bones does not require to be in good physical health.

We believe that the setting of a lion bone quota should not be considered in a silo of CITES permits, nor is it the mandate of just the Department of Environment, Forestry and Fisheries (DEFF). The establishment of such a quota has much wider implications for, inter alia, wild lion and other wildlife conservation, animal welfare, ethics, Brand SA, and potentially human health, that concern all members of the public, as well as other government departments.

Not only is the export quota decided in isolation, it is now also presented as a science-based consideration with a so-called public participation process based on scientific expert opinion and scientific peer-reviewed publications only, thus excluding the views and values of South Africa’s wider citizenry, and preventing critical ethical considerations from being taken into account. In addition, such scientific expert opinions are often sponsored or financially reliant on the very same industries, who benefit from such research.

View the full submission here:


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