The “800 skeletons” – “captive produced lion bone trade under the quota system”

Petition –  “End the export of captive-bred African lion parts from South Africa“ – Humane Society International

Petition – “URGENT: Stop the Export of 800 Lion Skeletons from South Africa to Asia

Petition – “Lions denied proper protection at CITES CoP17” – Captured in Africa Foundation

Lion bones

During the October 2016 Conference of the Parties (CoP17) to the Convention on the International Trade in Endangered Species of Wild Fauna and Flora (CITES),  behind closed doors it was decided to permit a ‘legal’ trade in commercially bred lions to perpetuate with an:

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.”

On the 25 January 2017, the Republic of South Africa, Department of Environmental Affairs (DEA) launched “Public invited to make written submissions on proposed lion export quota to the department in line with CITES requirements.” So, please feel free to review the DEA’s proposals and make your thoughts known on, or before 2 February 2017 deadline for submissions.

Via e-mail:

Dear Mr Mpho Tjiane,

With regard to the proposed “captive produced lion bone trade under the quota system,” please find comments below for “consideration by the CITES Management Authority and Scientific Authority before the final quota is communicated to CITES Secretariat in March 2017.”

Risk to Wild Lion Populations

There is an obvious risk of any newly sanctioned (Update: yes, lion bone export has been going on for decades via natural and ‘hunted (canned’) lion deaths etc., but this is a proposed formal expansion) captive lion skeleton quota/trade encouraging the increased poaching of wild lions, as others seek to illicitly cash-in on the immoral trade to abate a nonsensical Asian demand for unproven potions.

I understand that there is a proposed “3 year study” to be conducted by the South African National Biodiversity Institute (SANBI), with the “aim to increase the understanding of the lion bone trade in South Africa and the captive lion breeding industry, and will investigate how the trade in captive produced lion bone under a quota system affects wild lion populations“ with an imperative “to inform the Scientific Authority on a sustainable annual quota.”

So, from this statement it is clear that any risk to wild lion populations of the “captive produced lion bone trade under the quota system” is going to be taken regardless of any inevitable, or even perceived risk – a fait accompli. If/when it is found during this ‘lion skeleton trade quota’ experiment that wild lions are being poached in higher numbers, then what mitigating, or remedial action is proposed?  Will the “captive produced lion bone trade under the quota system” be curtailed if certain wild lion poaching limits are breached and if so, what are these pre-determined thresholds, or is that not going to even be considered and stated in advance? Of course, the option to take a zero trade quota would not put wild lions at such risk in the first place from this causal source.

What consideration has been given to the risk that “captive produced lion bone trade under the quota system” has even remotely predictable market dynamics?

There is a concern that the assumption that ‘legal’ wildlife trade can always be predicted and controlled to meet demand is not borne out by history, or by independent academic study. For example, the ivory trade and the ‘legal’ supply from ivory stockpiles has arguably done nothing but perpetuate demand and unsustainable poaching levels that seek to cash-in. Based on CITES  (MIKE) data, African elephant poaching might be stabilising (2015 data), but not at a level that will allow elephant population numbers to recover.

The objective of Alejandro Nadal’s and Francisco Aguayo’s 2014 paper (“Leonardo’s Sailors: A Review of the Economic Analysis of Wildlife Trade“) was to “…evaluate the scope and limitations of the economic analysis of wildlife trade that has been carried out in the past three decades.” A few extracts sum up this paper’s hard hitting assessment of the use of ‘misguided’ economic theory when applied to the wildlife trade:

The pro-market argument starts from the premise that poaching and illegal trade are a consequence of trade bans imposed by bodies like CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora).“

One of the most striking features in the economic analysis of wildlife trade is the level of misinformation concerning the evolution of market theory over the last six decades. To anyone who comes in contact with the corpus of literature on wildlife trade, and in particular the literature recommending the use of market-based policies, the uncritical use of theoretically discredited analytical instruments is a striking revelation. Perhaps the most important issue here is the conviction that markets behave as self-regulating mechanisms that smoothly lead to equilibrium allocations and therefore to economic efficiency. This belief is not sustained by any theoretical result, a fact that is well known in the discipline since at least the early seventies.

How will the proposed trade quota for ‘captive’ lion skeletons be monitored for adherence to lion skeletons being sourced from ‘captive’ lions only as stipulated by CITES? This CITES stipulation implies a categorical, independently verifiable distinction needs to be made between ‘captive’ and ‘wild’ lion skeletons/bones submitted for ‘trade’ that cannot be fraudulently manipulated.

There is a proposal within the DEA’s 25 January 2017 overview stating:

  • Lion “Skeletons will be packed separately at source (CBO/hunting farm), weighed, tagged and a DNA sample will be taken”; and
  • The lion skeleton “Consignment [is] to be inspected (and weighed) and permit endorsed at port of exit; random DNA samples will be collected.”

In order for proposed DNA samples to be of value, then the entire captive lion population needs to be independently DNA sampled, catalogued and managed on a database that can be scrutinised publically. Then, perhaps there can be credibility established behind any proposal to take DNA samples of consignments to ensure consignments match verified ‘captive’ bred lions. However, to mitigate against any laundering of poached ‘wild’ lions, then the consignment sampling would need to be 100% – any ‘random’ approach just opens up potential loop-holes, inviting corruption to exploit the void.

The ‘Captive’ Lion Skeleton Quota Market

Within South Africa, there are reportedly 200 breeding farms housing some 8,000 lions. How will these lion ‘farmers’ selling into any CITES’ perpetuated capped ‘skeleton’ market decide how any quota will be divided between all these lion ‘farmers’ and their suggested stock of some 8,000 lions? With the proposed quota of 800 skeletons per annum, that’s 4 lions per farm……..or is there a more elaborate market mechanism proposed?  Will this ‘lion skeleton market’ mechanism be based upon:

  • Lowest bidder submissions – ie. The lion farmer that can supply lion skeletons at the lowest cost wins. If so, this will inevitably negatively impact money spent on ‘acceptable’ captive lion stock welfare, as the captive industry is based purely on profit and income;
  • First come, first served – ie. There will be a rush for lion farmers to kill lions to supply the market before the quota is filled. Is this likely to advocate humane action, or a mass scramble to cash-in before the quota gate closes?
  • Some other approach….

What consideration has been given to potential ‘quota’ market dynamics and the potential negative risk to animal welfare?

Regulatory Oversight and Animal Welfare

At the moment, the regulatory oversight/compliance of the entire captive breeding industry is questionable.

How will welfare standards be independently verified within the captive lion breeding industry if/when such a skeleton quota is introduced?

When the South African Environment Minister tried to enforce a 24 month wilding rule (under Threatened or Protected Species Regulations) to ensure no previously captive (’canned’) lion or big cat could be ‘hunted’ unless it had be freed from captivity for 24 months, or more, the Predator Breeders Association (PBA) (the PBA supplies the ‘canned’ industry) sued the Environment Minister for this attempted regulation of their activities, but the PBA lost in the South African High Court.

However, after the PBA applied to the South African Supreme Court of Appeal (SCA), the SCA ruled  (Case No. 72/10, 29 November 2010) in November 2010 (of its own volition, “mero motu”), that ‘since no captive bred lions have ever been released back into the wild, then lion farming had nothing to do with conservation.’ Therefore, in the SCA’s view, the Environment Minster had no jurisdiction to impose welfare restrictions on what was essentially being declared animal ‘farming.’

‘Farming’ logically forms part of the Republic of South Africa’s Agriculture, Forestry and Fisheries (DAFF) remit, with its stated aim “to manage the risks associated to animal health” in accordance with the Animals Protection Act, 1962 (Act No. 71 of 1962) – how and when will this Act be applied to captive lion and predator breeding by the DAFF, or is the DEA still “liaising” (ref: DEA, Para 9 ‘Questions and Answers’) on this issue?

Since the 2010 SCA ruling, the DEA has maintained a limited oversight of the burgeoning captive predator breeding industry. The breeding of lions and other big cats in captive (‘canned’) breeding facilities within South Africa and its many Provinces, requires the issuing of a “Permit” in accordance with section 57(1) of National Environmental Management:  Biodiversity  Act,  2004  (Act  No.  10 of  2004)  (NEMBA).

The registration of any captive (‘canned’) breeding facility is compulsory in terms of South Africa’s ‘Threatened or Protected Species’ (TOPS) regulations and legislation, with TOPS compliance overseen by the DEA.

Each ‘Province’ in South Africa has their own specifics under Province Ordinances, Regulations and Notice Sections. The Province is allowed a great deal of flexibility by the DEA to set standards for captive enclosures, eg. minimum hunting enclosure sizes and how long after being tranquilised an animal victim can then be ‘hunted’ etc.

The DEA’s own ‘Questions and Answers’ section states that the “Provincial conservation authorities are mandated in terms of their provincial legislation to regulate the manner in which lions are kept” in accordance with Section 10(1) of the Animals Protection Act 1962 (Act No. 71 of 1962):

(a) the method and form of confinement and accommodation of any animal or class, species or variety of animals, whether travelling or stationary;

(b) any other reasonable requirements which may be necessary to prevent cruelty to or suffering of any animal; and

(c) the seizure, impounding, custody or confining of any animal due to any condition of such animal, the disposal  or  destruction  of  such  animal  and  the  recovery  of  any  expenses  incurred  in  connection therewith from the owner of such animal.

But in just one example, the Walter Slippers’ case (Afrcia Geographic, 8 July 2016) this captive breeding facility in Limpopo Province housed emaciated lions even before any potential lowest bidder, skeleton capped quota market has been introduced. This example has instilled a lack of faith in the DEA’s/DAFF’s/Provincial regulatory oversight of the captive lion/predator breeding industry from an animal welfare perspective that needs to be urgently addressed, or the industry declared beyond redemption.

Of course, there is the option for lion farmers to voluntarily apply for membership to the South African Predator Association (SAPA) – a self-declared arbiter of industry standards funded privately by the industry itself, so hardly an independent reassurance. Therefore, the SAPA should not be considered a substitute for official regulatory oversight. So where has that reassurance been historically, or where is it likely to manifest in the future to provide reassurance that animal welfare is currently managed, or even a consideration in the “captive produced lion bone trade under the quota system” proposals?


These initial points and risks need “consideration by the CITES Management Authority and Scientific Authority before the final quota is communicated to CITES Secretariat in March 2017” before even the remotest ‘faith’ can be established in another proposed market expansion based on animal exploitation, to meet a nonsensical demand for profit (and everyone is expected to pretend it is acceptable).

As the renowned body of scientists, the International Union for Conservation of Nature (IUCN) concluded in September 2016 “the prohibition by the South African Government on the capture of wild lions for breeding or keeping in captivity“ and “terminating the hunting of captive-bred lions (Panthera leo) and other predators and captive breeding for commercial, non-conservation purposes.

As the South African Supreme Court of Appeal (SCA) ruled  in November 2010 ‘since no captive bred lions have ever been released back into the wild, then lion farming had nothing to do with conservation.’

No matter what attempts are made by the captive breeding industry and its supporters to try and create and perpetuate an illusion, no one not profiting from the captive breeding industry is fooled by any current, or proposed practices:

  • A captive bred lion ‘could’ one day perhaps be successfully (by independent assessment) be released into the wild; or
  • The income generated from the captive breeding industry somehow aids lion species conservation – if so, where is the independent scientific proof that the United States Fish and Wildlife Service, the IUCN and others seek?

Captive lion breeding and the “captive produced lion bone trade under the quota system” proposed is nothing but profiteering “for commercial, non-conservation purposes” and is scientifically unproven as “a risk-averse intervention” as claimed by the DEA.

Update 16 February 2017 (background):

Update 16 February 2017 (background):

No the export of lion bones is nothing new:

The lion bone trade from South Africa is conducted almost entirely with Laos and Vietnam. CITES trade records show that while there was no bone trade before 2008, the quantity of items in this trade has increased dramatically. During the five years 2010-2014 South Africa exported 1,555 kg of bones, 2,886 individual bones and 3,018 skeletons to Laos and Vietnam. The totals were most likely higher as evidence has come to light that such exports are frequently under-reported. These sorts of numbers indicate that the proposed quota is not much higher than the existing volume of exports.”

However, it is important to consider the source of this proposed export. In the past, such bones were largely provided as by-products from trophy hunting of captive bred lions. While such hunting provided many carcasses (an average of 862 per annum from 2006-2014), recent changes in legislation and increased global public condemnation indicate that there will be a significant reduction in such trophy hunts in the future” – Lion Aid

Wild CRU has stated:

“[African] lions are in crisis…..Their numbers have been devastated by loss of habitat and wild prey, poaching, conflict with farming communities, unsustainable legal hunting, and emerging threats including the use of lion bones in traditional Asian medicine. Lions are being killed daily in Africa.

Based upon feedback in ‘comments,’ let’s be clear “independent assessment” means independent academic, scientifically proven rewilding.

The captive breeding industry has had literally decades to prove any ‘conservation’ credentials, but through its own machinations, resisted at every turn, because it would imply effective regulation of the industry’s activities and dent the industry’s ability to exploit and profit (or resistance for some other unknown, inexplicable reason, but I doubt it).

The best ‘example’ Professor Pieter JJS Potgieter (ex-president of the SAPA) could come up with in his March 2016 piece “9 myths about captive-bred-lions“ was to cite Elsa the lioness as the key example of successful rehabilitation (one example from the 1960s duly noted). Elsa’s rehabilitation was of course the theme of the 1966 ‘Born Free’ film and the Professor states “Elsa the lioness made the transition from pet lion to wild lion mama pretty easily.” However, according to Professor Pieter JJS Potgieter “There are numerous cases where captive-bred lions have successfully made the transition to become wild lions. And they did it with little fuss and with little if any coaxing. Currently there are two studies of note, one on captive-bred lions in the wild in Zambia and another in the Zambezi River region,” but he failed to provide any independent citations.

Rewilding is anything but easy, to imply otherwise is to obfuscate – lion dynamics in their natural environment – wild lions live in strong prides structures, highly territorial, complex social interactions, hunt over wide territory, hunt their own prey, have the risks and challenges of such a wild, natural existence – all of that is (obviously) denied the lion/big cats species when bred in confinement for commercial purposes.

The SAPA in its sudden and dubious epiphany (a self-interested ‘business’ ambition) to re-invent itself as some kind of pseudo -‘conservation’ effort by demonstrating rewilding is a late awakening from past wrong-doing– the suspected motivation is of course, the lack of genuine conservation credentials is denting the captive industry’s bottom line.

How much did the Predator Breeding Association (PBA) (superseded by the SAPA) recently (2010) care about any captive lion having a chance to be wild? When the South African Environment Minister tried to enforce a 24 month wilding rule (under Threatened or Protected Species Regulations) to ensure no previously captive (’canned’) lion or big cat could be ‘hunted’ unless it had be freed from captivity for 24 months, or more, the PBA sued the then Environment Minister for this attempted regulation of their activities.

There is no ‘believable’ altruistic, conservation endeavour in the SAPA/captive breeding industry, which has always been about farming product for profit. The only recent, plausible motivation for the SAPA/captive breeding industry to try and prove any ‘conservation’ credentials is because the truth of the lack of ‘conservation’ credentials has dented the captive breeding industry’s business model (with canned lion hunting trophy import restriction because there is no proven conservation element/contribution).

Any disingenuous goading, seeking others opposed in principle (on moral, ethical grounds) to captive breeding to come help verify any such SAPA rewilding demonstrations “are conservation” is to ask those opposed, to actively help the SAPA in attempt to reinstitute the trophy killing of ‘canned’ lions for USA (France, Australia, The Netherlands…..all ban trophy imports) hunters and the potentially unrestricted importation of such trophies.

Any other SAPA attempt to offset killing captive lions for fun/profit via donations to real conservation, is to try and off-set wrong-doing via a cheque-book (a deceit).

Does the SAPA believe there is a crisis with wild lions? According to Professor Pieter JJS Potgieter (ex-President, SAPA) the African lion’s imminent extinction is clearly ‘nonsense:’

The lion population is stable at between 20,000 and 30,000 cats world-wide” – Prof Pieter JJS Potgieter (SAPA ex-President), “9 myths about captive-bred-lions,“ March 2016

Of course, anyone that thinks differently is an ‘over-emotional’ “alarmist.” Exuding all the charm he could muster, The Professor singled out Virginia McKenna (of ‘Born Free’ fame) for a patronising put-down based on The Professor’s superior wisdom:

Relax, love, your alarm is misplaced………The lion will continue to roar long after Virginia McKenna’s final screech of alarm” – Prof Pieter JJS Potgieter (SAPA ex-President), “9 myths about captive-bred-lions,“ March 2016

The SAPA’s/Professor’s ‘wild lion population stability’ delusions are not widely shared (reference “9 myths about captive-bred-lions“), but regardless this suggests that the SAPA’s sudden epiphany is not based on an understanding of the need for lion conservation. So how can the SAPA’s current motives for ‘conservation’ credentials be anything but a self-interested ‘business’ ambition to recover income from captive lions?

Further Reading:

Zero confidence in SA’s lion farming & lion bone trade,” Captured in Africa Foundation, SABC, 29 January 2017

Permission to drink a lion,” Don Pinnock, Daily Maverick, 1 February 2017


Campaign Against Canned Hunting – “LION BONES TO ASIA”

Despite indicating that it will give permits for 800 lion skeletons, without the slightest pretence of scientific enquiry, the SA government has belatedly called for public participation.

Herewith our input to the South African government on the issue of export of lion bones to Asia.

Dear Mr Tijiane,

We should like to add our support for the points made by wildlife documentary film producer Karl Amman, motivating for a zero quota for all lion body parts, wild and captive bred. In particular, he stresses the following arguments:

Most of the key importers, in Laos and Vietnam, of lion bone from South Africa are well known wildlife dealers who are involved in a wide range of wildlife trafficking activities going beyond bones. (Previously most exports were going via Mr. Vixay Keosavang but now new Vietnamese players with operations in Laos are involved)

Cross border trafficking is based on a well-established bribe price per 100 kg of any such commodity, with all the lion bones having been imported into Laos ending up going across the border into Vietnam or via Boten into China. All these onward shipments are in contravention of CITES rules.

Dealers are captured on camera saying that none of their clients can tell the difference between a lion and a tiger skeleton and as such it is very easy to sell lion bones, teeth and claws as coming from tigers. The end consumers of all these lion bone products are thus being defrauded.

These are just some of the down the line consequences relating to the lion bone export. There is no doubt that the trade further enriches criminals deeply involved in a wide range of illegal wildlife trade activities.

Making wildlife trafficking more profitable clearly encourages more of the same. (some of these dealers have already approached Tanzanian professional hunters offering to buy their lion bones).

SA lion farms sell a full skeleton for U$ 1800. At the time Karl Amman published a full analysis of the value chain for lion skeletons from the farm in South Africa to the consumer of tiger cake in Vietnam.  Clearly South Africa is a minor beneficiary and it is the traffickers who make all the big money.

800 skeletons a year at U$ 1800 for a complete set is less than U$ 1.5 million income per annum. In terms of a cost and benefit analysis, this policy can not be justified.

Chris Mercer

Campaign Against Canned Hunting.

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s