For the attention of:
The Honourable Minister David Maynier
Minister of Forestry, Fisheries and the Environment
2 November 2026
Dear Honorable Minister Maynier,
The recent judgement in the High Court in Pretoria in the South African Predator Association case, heard on 20 October 2026, has once again drawn attention to South Africa’s international lion bone trade with the judge explicitly stating that the Department of Forestry, Fisheries and the Environment (DFFE) must determine a CITES annual export quota.
As captive predator specialists and wildlife welfare researchers, we urge you to consider the implications of this decision and to set a CITES annual lion bone export quota of zero, as initiated on the 22nd September 2025 by former Minister Dr Dion George with a Notice of Intention (no 6663).
While the Court determined that an annual quota must be set, it does not mean that commercial exports need to be authorised and thus a zero quota remains a legitimate decision. This is particularly relevant given the DFFE has not established a formal structure to implement NEMBA’s well-being clause as well as South Africa’s established policy direction towards closing the commercial captive lion industry, which has been ongoing for almost a decade.
Over this time, South Africa has made significant progress toward this objective, including Parliament’s 2018 resolution calling for an end to captive lion breeding, the 2020 High Level Panel Cabinet approved recommendations and the subsequent decision of former Minister Barbara Creecy to end the commercial captive lion industry, the 2023 Ministerial Task Team on Voluntary Exit Cabinet approved recommendations, and Cabinet’s 2024 Policy Position, all of which demonstrate a clear policy direction towards a phase-out of the commercial captive lion industry.
However, reintroducing a positive CITES lion bone export quota risks undermining these evidence-based and democratically driven processes that occurred before your tenure as Minister. This risks creating renewed economic incentives for captive breeding and expanding an industry that the South African government has made clear commitments to phasing out.
It is necessary to underscore that animal welfare and well-being needs to be central to your decision. The 2019 High Court judgement in NSPCA v Minister of Environmental Affairs and Others in which the court found that the setting of the lion bone quota at the time was unlawful and constitutionally invalid. Judge Kollapen stated that “…if as a country we have decided to engage in trade in lion bone…then at the very least our constitutional and legal obligations that arise from Section 24, NEMBA and the Plan require the consideration of animal welfare issues”.
This obligation now carries more significance in light of the animal well-being provisions in NEMBA, which have been upheld by the Constitutional Court in October 2026. Well-being must inform decisions affecting wildlife and biodiversity, rather than being subordinate to commercial interests, and must be interpreted at an individual rather than species level.
The recent judgement indicated the role of South Africa’s Scientific Authority in the setting of a lion bone quota. To this end we would like to know when the draft Non-Detriment Findings (NDF) for African lion will be published, as the current and outdated 2018 NDF still states that the export of lion skeletons will not be detrimental to the survival of the species whereas new research, has demonstrated otherwise.
South Africa has engaged in years of building policy and legislative change to end the commercial captive lion industry. We urge you to consider that the current quota-setting process must not become a mechanism that reverses the progress achieved so far.
With this in mind, we urge you to take a position of powerful leadership and continue years of democratically informed and evidence-based processes initiated by your predecessors and to demonstrate consistency in South Africa’s environmental commitments, constitutional responsibilities, and wildlife policies.
We support the recent judgement that clear direction is required from your leadership and we therefore call on you to:
- Set the annual lion bone export quota to zero, consistent with South Africa’s existing policy commitments.
- Ensure that the animal well-being clause is enforced through a clear implementation plan that will become part of future provincial and national compliance inspections, as required by the 2019 High Court judgement and subsequent developments.
- Commit to transparent and inclusive stakeholder engagement, including animal welfare and well-being experts, that extends beyond representatives from the captive wildlife industry.
- Promulgate the Lion Prohibition Notice approved by NCOP in March 2026.
- Create a clear implementation plan and pathways for the phase out of the commercial captive lion industry.
We look forward to your response and continue to seek the opportunity for meaningful engagement with you and your Department.
1. Green, J., Elwin, A., Jakins, C., Klarmann, S.-E., de Waal, L., Pinkess, M., & D’Cruze, N. (2025). Reviewing Evidence for the Impact of Lion Farming in South Africa on African Wild Lion Populations. Animals, 15(15), 2316. https://doi.org/10.3390/ani15152316
2. Lindsey, P., Nicholson S.K., et al. (2026) Increasing Targeted Poaching of Lions for Trade Has the Potential to Pose an Existential Threat to the Species in Africa. Conservation Letters, 19(1), e70014. https://doi.org/10.1111/con4.70014