In 2021 we undertook an immense research project to better understand the extent of the captive predator industry in South Africa. Through our research, we hoped to gather information to gain insight into the unregulated nature of predator breeding, keeping and trade across the country. We wanted to get a better understanding of the extent and nature of the industry which meant we needed to get a sense of the sheer numbers of big cats in facilities and the types of activities that involved these predators, such as captive hunts, euthanasia, breeding, transport, and trade. It was also necessary to understand how officials carry out their responsibilities, like inspecting these facilities. With this information we could comprehend more fully the efficiency and compliance of provincial regulations and officials with regard to the captive breeding, keeping, and trade of big cats in South Africa.
South Africa’s Legislative Landscape and Captive Lions
At this point, it’s necessary to contextualise our findings by understanding South Africa’s stance on captive predators. South Africa is still one of the few countries that allow the intensive breeding of predators in captivity. But, this poses an immense risk not only to the welfare of these animals, but it is now also considered a threat to South Africa’s reputation as a leading conservation and ecotourism destination. This means it may actually present more opportunity costs than the income it generates.
Between 2005 to 2013 the number of lions held in captivity more than doubled from 2500 to 6200 to meet the ever-increasing demand for lions used for captive hunting, the bone trade, interactive tourism, like cub petting and walking with lions, and the live trade (see commodity chain diagram below).
In 2019 Minister Barbara Creecy stated that there were 7979 lions in 366 registered captive facilities in South Africa, but this information is likely an underrepresentation of the true numbers due to the existence of unregistered facilities and those operating with outdated permits. It is also extremely concerning that this does not account for the largely unknown number of other indigenous and exotic big cats that are bred and kept in captivity for commercial purposes.
South African legislation governing conservation and captive big cats is complex. To start, we will define the most important terms you need to know to better understand our legislation. Defining the acronyms used by government and provincial departments is a necessary first step.
Overall, there are nine provincial departments governed by their own provincial statutes, with national legislation on environmental matters, and legislation like animal welfare under our national department for agriculture and rural development. This is a key challenge, referred to as 9+1+1, as it has resulted in policy and legislation lacking coordination across a wide variety of departments. 
To complicate matters further, nature conservation on a provincial level is often combined with portfolios for economic development, agriculture, and tourism, like in Gauteng, North West, Free State, Limpopo, Mpumalanga and Eastern Cape. This is particularly concerning since the variety of mandates and a lack of resources and capacity across these departmental portfolios may hinder conservation, where it is one portfolio of many to deal with.
Overall, legislation governing the captive predator breeding industries in South Africa is outdated and inconsistent across our nine provinces. With this lack of standardisation, there is an absence of transparency and coordination that results in legal loopholes that can have a negative impact on the captive wildlife involved.
For example, each province has its own regulations regarding the minimum release time for captive-bred lions to be hunted. These decisions have not been based on clear scientific evidence and appear to be arbitrary decisions. In turn, hunting outfitters, particularly in the North West province, have exploited such differences and taken full advantage of the short 96-hour minimum release time in this province. As a result, the majority of captive-bred lion hunts in South Africa take place in the North West.
South African legislation also works in coordination with CITES, which is an international body that governs the worldwide trade in wildlife in such a way that their survival is not threatened with extinction.
African lions are listed as Appendix II species according to CITES, which means that they are the only big cats that may be traded legally for commercial purposes. However, in 2016 a CITES decision was made that there would be a zero quota for trade in wild lion body parts, but the South African government could set a quota for trade in bones, parts and derivatives from the captive lion population only. Prior to this decision, more than 6,000 lion skeletons were traded since 2008. In 2017 and 2018 DFFE set an annual quota of 800 lion skeletons for commercial trade. However, in 2019 this decision was ruled unlawful by a High Court Judge as it did not account for the lions’ welfare. Despite this, no new considerations have been confirmed regarding a lion bone quota going forward.