BONES OF CONTENTION:R E P O R T

July 2015

A
TRAFFIC & WildCRU
Joint
ReportAn assessment of the South African trade in African
Lion Panthera leo bones and other body parts
Vivienne Williams, David Newton, Andrew Loveridge and David Macdonald

TRAFFIC

A
TRAFFIC & WildCRU
Joint
ReportAll rights reserved.
All material appearing in this publication is
copyrighted and may be reproduced withpermission. Any reproduction in full or inpart of this publication must credit TRAFFIC
International and WildCRU as the copyright owners.
The views of the authors expressed in thispublication do not necessarily reflect those of
TRAFFIC, WildCRU, WWF or IUCN. The roleof the authors was to unearth, and impartially topresent, evidence that can inform decisions anddecision-makers on this trade insofar as it might
impact the conservation of wild lions.
The designations of geographical entities in thispublication, and the presentation of the material,
do not imply the expression of any opinion
whatsoever on the part of TRAFFIC, WildCRU
or their supporting organizations concerning thelegal status of any country, territory, or area, or of
its authorities, or concerning the delimitation of
its frontiers or boundaries.
The TRAFFIC symbol copyright and Registered
Trademark ownership is held by WWF. TRAFFIC
is a strategic alliance of WWF and IUCN.
The Wildlife Conservation Research Unit
(WildCRU) is part of the University of Oxford(Department of Zoology) and its mission isto achieve practical solutions to conservation
problems through original scientific research.
Suggested citation: Williams, V.L., Newton, D.J.,
Loveridge, A.J. and Macdonald, D.W. (2015).
Bones of Contention: An Assessment of the South
African Trade in African Lion Panthera leo Bonesand Other Body Parts. TRAFFIC, Cambridge, UK& WildCRU, Oxford, UK
ISBN: 978 1 85850 383 7
Front cover: Main photograph (African Lion skull
part of a consignment en route to Asia) ©Vivienne
L. Williams; Left (from top) Andrew Loveridge,‘Anonymous’ (name is known to author); Andrew
Loveridge; Vivienne Williams (lower two)
The authors gratefully acknowledge the generous
funding support of the Mackenzie Foundation.
The Recanti-Kaplan Foundation, Panthera andthe Robertson Foundation are acknowledged fortheir support of WildCRU’s work on lions. The
University of the Witwatersrand and the National
Research Foundation (NRF) in South Africa arealso thanked for their financial support.

Bones of ContentionAn
B assessment of the South African trade in African
Lion Panthera leo bones and other body parts

By Vivienne Williams1, David Newton2, Andrew Loveridge3 andDavid Macdonald3

1 University of the Witwatersrand
2 TRAFFIC©Jealous Mpofu, Painted Dog Conservation, Hwange

3 WildCRU

African Lions at Ngweshla, Hwange National Park, Zimbabwe

© VIVIENNE L. WILLIAMS

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Bones of Contention: An assessment of the South African trade in African Lion bones

CONTENTS
Acknowledgements
Abbreviation and acronyms used
Maps of South Africa and East–Southeast Asia
Executive Summary
Context: Lion bones and Tiger wine – letting the cat out of the bag
Lion population in South Africa
Legislation
Lion hunting South Africa
Lion trophies and the size of the skeleton resource baseTrade in Lion bones and other body parts
Exporters, importers and trade flows
Value of the Lion bone trade
Illegal trade in LionsTiger trade from South Africa
Impact on wild Lion populations in South Africa
Recommendations
INTRODUCTION – LION BONES AND TIGER WINE
Timelines in the Tiger trade relevant to LionsLetting the cat out of the bag: The immergence of the Lion bone trade in South Africa
Research aims and key activities
METHODS
Literature survey and data collection
Interviews
LION POPULATION IN SOUTH AFRICA
Overview
Wild Lion population in South Africa
Captive Lion population in South Africa
2013 estimates of the South African Lion population
LEGISLATION
Overview
NEMBA and TOPSCITES
Provincial acts and ordinances
National environmental management protected areas act 57 of 2003
The convention on biological diversity
The SADC protocol on wildlife conservation and law enforcement
Other Legislation
Enforcement and compliance concerns
LION HUNTING IN SOUTH AFRICA
Canned hunting, captive Lions & controversies
Lions hunting statistics from DEA
Hunting revenues from Lions
Weighing the sex costs
Client Nationality
LION TROPHY EXPORTS & THE SIZE OF THE SKELETON RESOURCE BASE
Introduction
Comparison of Lion hunting register and trophy export statistics
Estimating the size of the resource base: the number of skeletons that could beexported

Bones of Contention: An assessment of the South African trade in African Lion bones

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CONTENTS
TRADE IN LION BONES & OTHER BODY PARTS FROM SOUTH AFRICA
Introduction
Exports of live Lions from South Africa
Exports of Lion bodies from South Africa
Exports of Lion bones from South Africa
Exports of Lion skeletons from South Africa
Exports of Lion trophies to East and Southeast Asia
Combined exports of Lion body parts to East and Southeast Asia
Estimating the reserves in the skeleton resource baseBased on the number of Lions hunted: 2004-2010
Based on the number of trophies exported: 2004-2010
EXPORTERS, IMPORTERS & TRADE FLOWSVALUE OF THE LION BONE TRADEILLEGAL TRADE IN LIONSIntroduction
Reports of Illegal activities and trade within South Africa
Interviews with provincial nature conservation and law enforcement officials
Interviews with the NSPCAInterviews with various people who requested anonymity
LION PARTS IN SOUTH AFRICAN TRADITIONAL MEDICINE
Overview
Survey of distributers in KwaZulu-Natal (1987)
Survey of traders in the Eastern Cape (c.1994)
Survey of muthi shops in KwaZulu-Natal (2000)
Survey of the Faraday muthi market, Johannesburg (2005)
2013 Interviews
Authenticity of the animal fats
TIGER POPULATION AND TRADE IN SOUTH AFRICA
Overview
Tiger exports from South Africa
Exports of live Tigers
Exports of Tiger trophies and skins
CONCLUSION: IMPACT ON SOUTH AFRICA’s WILD LION POPULATION
Recommendations
REFERENCES
Appendix 1: Asiatic Lion timelines and poaching
Appendix 2: IUCN red list status of the South African Lion population
Appendix 3: Lion population in South Africa c.2013
Appendix 4: Lion anatomy
Difference between Lions and Tigers
Skeletal anatomy of LionsThe mass of Lion skeletons
Appendix 5: A guide to the mass vs. no. of skeletons in consignments of exported Lion………..bones

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Bones of Contention: An assessment of the South African trade in African Lion bones

ACKNOWLEDGEMENTS
We thank our colleagues in TRAFFIC and WildCRU. Four people who played an important role in supplying data are
Thea Carroll and Magdel Boshoff (South African Department of Environment Affairs), Michele Pfab (South African
CITES Scientific Authority), and Rynette Coetzee (Endangered Wildlife Trust). Gina Arena is thanked profusely for the
112 hours it took her to transcribe the recordings of all the meetings verbatim. We would like to thank Dr Peter Lindseyof Panthera, Jane Paumgarten Chairperson of the MacKenzie Foundation, Natasha Pervushina of WWF-TRAFFIC Tigers
Alive Initiative, and Sarah Stoner, Roland Melisch and Steven Broad of TRAFFIC for peer reviewing this manuscript.
There are more than 10 people who wish to remain anonymous that must be thanked who contributed very valuable
information and support. There are also several other people who contributed valuable information, data, photographs
or useful opinions, including Shaw Badenhorst, Werner Boing, Kirsty Brebner, Sheila Broadly, Masiko Buthelezi, Sam
Cross, Neil Crouch, Juan De Beer, Jonathan Denga and colleagues from North West Province, Div De Villiers, Jolene
Fisher, Paul Funston, Greg Gibbard, Kaera Coetzer, Pinky Richman Gqirana, Bongi Hlalukane, Debbie Jewitt, Andrew
Kitchner, Adri Kitshoff, Natasha Kewley, Kelly Marnewick, Tebogo Mashua, Susan Miller, Tyler Morgan, Jealous
Mpofu, Jaap Pienaar, Pieter Potgieter, San-Mari Ras, Tess Rayner, Richard Thomas, Pieter Van Niekerk, and Wendy
Willson. Colleagues from the School of Animal, Plant and Environmental Sciences at the University of the Witwatersrand
are thanked, and so to are the people who attended the meetings from the nature conservation and law enforcement
departments from the provinces of the Free State, Northern Cape, Eastern Cape, Mpumalanga and the North West.

Bones of Contention: An assessment of the South African trade in African Lion bonesv

ABBREVIATIONS AND ACRONYMS USED
BMP
BOD
BON
CBD
CITES
CN
DAFF
DEA
EC
EWT
FS
GR
IUCN
KNP
KZN
LA
LIV
LP
MM
MP
NC
NEMBA
NGO
NP
NSPCA
NW
ORTIA
PHASA
SAPBA
SADC
SANParks
SAPS
SARS
S.D.
SKE
TAM
TCM
TH
TOPS
TRAFFICTRO
UNEP-WCMC
USD
VN
WWF
ZA
ZAR

Biodiversity Management Plan
BodiesBones
Convention on Biological Diversity
Convention on International Trade in Endangered Species of Wild Fauna and Flora
China, or People’s Republic of China (PRC) (Map 2)
Department of Agriculture, Forestry and Fisheries
Department of Environmental Affairs
Eastern Cape (Province) (Map 1)
Endangered Wildlife Trust
Free State (Province) (Map 1)
Game Reserve
The World Conservation Union
Kruger National Park
KwaZulu-Natal (Province) (Map 1)
Laos, or Lao People’s Democratic Republic (Lao PDR) (Map 2)
Live (animals)
Limpopo (Province) (Map 1)
Myanmar, Republic of the Union of Myanmar (Map 2)
Mpumalanga (Province) (Map 1)
Northern Cape (Province) (Map 1)
National Environmental Management and Biodiversity Act (Act 10 of 2004)
Non-Governmental Organization
National Park
National Society for the Prevention of Cruelty to Animals
North West (Province) (Map 1)
O.R. Tambo International Airport
Professional Hunters Association of South Africa
South African Predator Breeders Association
Southern African Development Community
South African National Parks
South African Police Service
South African Revenue Service
Standard Deviation (a statistics term)
Skeletons
Traditional Asian Medicine (including TCM and other East- and Southeast Asian Medicines)
Traditional Chinese Medicine
Thailand, or Kingdom of Thailand (Map 2)
Threatened Or Protected Species regulations of 2007 [Section 56(1) of NEMBA]
The wildlife trade monitoring network
Trophies
United Nations Environment Programme – World Conservation Monitoring Centre
United States Dollar
Viet Nam, or Socialist Republic of Viet Nam (Map 2)
The World Wide Fund for Nature
South Africa
South African Rand

Exchange rates for South African Rand (ZAR) into United States Dollar (USD) are indicative and were
calculated during the drafting of the report between May and July 2013.

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Bones of Contention: An assessment of the South African trade in African Lion bones






MAPS OF SOUTH AFRICA AND EAST–SOUTHEAST ASIA
Abbreviations forSouth African
provinces:







EC:

Eastern CapeFS:Free StateGP:

Gauteng

KZN:

KwaZulu-NatalLP:

LimpopoMP:

Mpumalanga

NC:

Northern Cape

NW:

North WestWC:

Western Cape












Abbreviations forcountries in East
Southeast Asia:



Bones of Contention: An assessment of the South African trade in African Lion bones

CN:

China

LA:

Lao PDR (Laos)

MM:

MyanmarTH:

Thailand

VN:

Viet Nam

vii

EXECUTIVE SUMMARYCONTEXT: LION BONES AND TIGER WINE – LETTING THE CAT OUT
OF THE BAG
In the 1990s, images of Tigers Panthera tigris on some manufactured Chinese medicines were replaced with Lions
Panthera leo, leading to suspicions that parts from Tigers were being substituted with Lions. In 2005, evidence emergedthat African Lion bones were indeed being substituted for Tiger in “bone strengthening wine”, thus confirming thepresence of Lion derivatives in “tiger” products. “Anger over lion bones sales” was the first South African newspaper
headline in December 2009 publicly to proclaim the existence of a legal trade in African Lion bones to supply thesubstitute “tiger bone” market in East–Southeast Asia. The story generated widespread outrage when it emerged that a
CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) permit had been issued to a
local Lion breeder to export the skeletons – however, unbeknownst to the public was that permits to export Lion bones
had been issued a year earlier in 2008. The sharp increase in the export of Lion skeletons from South Africa to Southeast
Asia (especially Lao PDR and Viet Nam) from 2008 led to concerns that bones from wild Lions were being sold into the
Traditional Asian Medicine (TAM) trade and thus negatively affecting vulnerable wild Lion populations. Accordingly, it
became necessary to investigate the trade in Lion bones to: (1) examine the extent to which bones were available
through legitimate and illegitimate sources within South Africa; (2) determine the source of the bones and parts (wild or
captive bred); and (3) assess the potential impacts on wild populations.
The Lion bone trade is a contentious and complex conservation issue spanning continents and cultures and a diverse arrayof role-players. A critical question that emerged during the research was: what events (if any) drove the demand for Lionbones in East–Southeast Asia? When examining the timelines in the Tiger and Lion trades, it appears as if measures
adopted to protect Tigers and Asian big cats (especially in 2002 and 2006/2007) was inadvertently one factor that catalyseda chain reaction of interlinking and unexpected events that resulted in a shift from the traditional use of Tiger bones andproducts in TAM, to including the parts of other Asian big cats (such as leopards), and eventually the bones of Asiatic andthen African Lions. Furthermore, we speculate whether rhino poaching worsened after representatives of a Laotian exportimport company, known for its involvement in wildlife trade and the illicit trade in rhino horn, visited South Africa topurchase lion bones from game farmers c.2008. Thus, are the rhino-lion-tiger trades interlinked, and did measures intended
to protect a charismatic species in Asia have unintended consequences for other species on a different continent? This is
an issue worthy of further debate to avoid similar knock-on effects in the future.

LION POPULATION IN SOUTH AFRICA
The estimates of the Lion population in this report indicate that there are more than 9100 African Lions in South Africa,
approximately 68% of these are in captivity and 32% are free-roaming in reserves. The majority of free-roaming Lionsare protected in SANPark Reserves, with the remainder in provincial and private reserves. There were estimated to bearound 5800 captive-bred Lions in 2013, and this number has almost doubled since 2005. The Free State province is theepicentre of the captive Lion breeding industry and has about 3000 Lions in 70 breeding and two hunting facilities. The
North West province had almost 2200 captive Lions in 64 hunting “reserves”. The number of Lions in the North West andFree State provinces fluctuates because of the large number of Lion translocations, mainly from the breeding facilities tothe hunting reserves.

LEGISLATIONSouth Africa has a well-developed legal framework for the conservation, regulation and sustainable use of its biodiversity.
The legislation includes the National Environmental Management and Biodiversity Act (NEMBA) and various provincial
nature conservation ordinances used by the nine provinces for protecting wildlife and regulating the trade thereof.
However, there are complexities of implementation and inconsistencies resulting from the provincial legislation thathave raised concerns that loopholes exist for illicit activities that thereby present compliance challenges. A broad
overview of the legislation and the enforcement and compliance concerns are presented. The prevailing view of therole-players interviewed was that Lion bone exports are mostly legal – but there are flaws in the regulatory systems thathave created opportunities to exploit weaknesses in the legislation. Moreover, there is questionable provincial capacity tomonitor all aspects of the Lion trade and still contend with the monitoring of other TOPS (Threatened Or Protected Species)
listed species that are more threatened (including rhinos and cycads).

LION HUNTING IN SOUTH AFRICA
Lion hunting in South Africa has been the subject of extensive judicial scrutiny – specifically with regards to “put andtake animals”. In 2007, applicants from the South African Predator Breeders Association (SAPBA) took the Environment
Minister to court over certain TOPS regulations that were to be implemented in 2008. SAPBA challenged the Minister

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Bones of Contention: An assessment of the South African trade in African Lion bones

on the inclusion of Lion on TOPS as a “listed large predator” and specifically the regulation that captive-bred animals
could only be hunted after a 24-month self-sustaining release period. They argued that this regulation would put an
end to the hunting industry, but the courts ruled in 2009 that this 24-month period was not unreasonable. However, SAPBA
appealed the ruling and won and in 2010 the definition of Lions as a “listed large predator” was declared invalid in so far
as it applied to a “put and take” animal that is a Lion – hence the 24-month period was no longer applicable andprovinces would have to apply regulations as per their provincial ordinances or guidelines. The self-sustaining period forLions released on hunting reserves varies across the provinces, but in the North West province, for example, it is 96 hours.
Most Lion trophy hunting in South Africa is from captive-bred animals, and figures of between 0.9% and 5% of the total
successful hunts have been attributed to wild Lions only. These wild Lions were reportedly hunted in reserves bordering
the Kruger National Park or in the Kgalagadi Transfrontier Park. Trophy hunting of captive-bred Lions, however, occurs
mostly in the provinces of North West (82% of hunts in 2010), Eastern Cape (7%) and Free State (6%) – and these were
the primary sources of Lion bones sold to East–Southeast Asia. The revenues generated by Lion hunting topped morethan USD21 million in 2008 (the figures were lower in 2009/10, and no data were available for 2011/2012 at the time ofwriting this report). Accordingly, the value of the industry makes it hard to envisage that the South African government
will shut the industry down in the near future.

LION TROPHIES AND THE SIZE OF THE SKELETON RESOURCE BASE
Permits to hunt Lions in South Africa are issued through the provinces, and Professional Hunters are obliged to record
all completed hunts in a professional hunting register. The hunting register is then used to compile provincial reports on
the number of Lions hunted annually, which they submit to the Department of Environmental Affairs (DEA). The
number of permits issued to hunt Lions is usually more than the number of Lions actually hunted and recorded on theregister; this is because not all the permits that are issued are used. Accordingly, the number of hunting permits issued
cannot be used as a proxy for the number of carcasses potentially available to supply the Lion bone trade, hence one isreliant on the accuracy of the hunting register to estimate: (1) the number of Lions hunted, (2) the maximum number oftrophies that could be exported, and (3) the number of carcasses available for the bone trade via the hunting industry[Note: there are other sources of Lion bone besides those derived from hunting].
Since the African Lion is listed in Appendix II of CITES, all foreign clients must also have CITES permits to export
trophies (usually the skin and skull); the provincial permit Issuing Authority issues these permits once the hunts havebeen registered. From 1977 to 2011, South Africa reportedly issued permits to export 7014 Lion trophies to 100 countries– this figure should be less than the number of Lions hunted since not all hunters take their trophies home. However, when
one compares the number of Lions hunted (indicated by the hunting register) with the number of trophies exported(indicated by CITES permits) between 2004 and 2010, there is a large discrepancy in that 1138 more trophies wereapparently exported than Lions hunted. There may be various legitimate reasons for this discrepancy, but ultimately theaccuracy of the hunting register is called into question.
There are several potential sources of skeletons for the Lion bone trade namely: (1) natural mortalities, (2)euthanized/culled Lions, (3) problem-Lion hunts, (4) carcasses buried/discarded after events in the past that could
potentially be located/exhumed, (5) poaching, and (6) trophy hunts. Information is limited on the number of skeletons
available from the first four sources, and the size of this resource base is assumed to be cumulatively large considering
the number of captive animals and the amount of hunting that took place in the past. Incidences of wild Lion poaching
are rare in South Africa and not believed to be a notable contributor of bones to the trade. Hence, the “best” estimator of
the minimum size of the carcass resource base that could be sold into the Lion bone trade is the number of Lions hunted
annually. It is estimated that from 2004 to 2010 the number of skeletons available from trophy hunts amounted to 2900 to4100 units. Despite rumours that landowners are exhuming Lion skeletons and selling them, there was no information
available on the extent to which that might be occurring.

TRADE IN LION BONES & OTHER BODY PARTS
Besides Lion trophies, South Africa has issued permits to export 19 other categories of Lion products since 1977. Of
most interest, and the focus of this report, are the commodities exported to East–Southeast Asia that are part of theextensive global carnivore trade and feed into the “tiger” bone industry as substitutes. Since 1998 (but especially from2006/2007) China, Viet Nam, Lao PDR, Myanmar and Thailand have imported increasing quantities of live Lions, Lionbodies, bones and skeletons.
Applications to import live Lions to East–Southeast Asia were irregular until 2006, but export permits were issued
consistently thereafter. Thailand imported most of the live Lions, followed by China, Myanmar and Viet Nam. However,since there were few CITES trade data available on the legal cross-border regional trade in Southeast Asia, it wasdifficult to validate the motives for these imports. Are the Lions retained in the possession of the importers or are someof them subsequently trafficked throughout the region?

Bones of Contention: An assessment of the South African trade in African Lion bonesix

In parallel with the increase in the rhino horn trade, there has been an increase in wildlife hunting in South Africa bySoutheast Asian nationals in the last decade. However, unlike rhinos where Vietnamese clients are the main importers ofhorns, the main importers of Lion trophies from 1999 to 2008 were the Chinese. Lion trophies were exported to Lao PDR
for the first time in 2009, despite there being no records of Laotian clients having hunted Lions in South Africa. Since
2010, the number of permits issued to export Lion trophies to Lao PDR has increased exponentially and currently dominate
the export market for this commodity to the region.
The CITES category “bones” is different to “skeletons”, but when discussing the Lion “bone” trade one generally refers
to exports/imports of partially complete or whole skeletons instead of individual bones. Prior to 2008, the only record ofSouth Africa having issued CITES permits to export Lion skeletons was for three units to Denmark in 2001. Furthermore,
the worldwide export of skeletons from 1982–2000 only totalled nine, and these were mainly to Europe. In mid-2008,
South Africa issued its first export permit for 50 Lion skeletons obtained from captive-bred Lions destined for Lao PDR.
In 2011, permits to export approximately 573 skeletons from South Africa to Asia (China, Viet Nam, Thailand and Lao
PDR) were issued – 91% of which were to Lao PDR, and 76% originated from the North West Province in South Africa.
The number of skeletons legally exported to Lao PDR thus grew from zero in 2007 to at least 197 in 2009 and up to 519
in 2011. In a six month period in 2012, 11 shipments of Lion bones to East–Southeast Asia totalled >3800 kg (or >395
Lions). From 2008 to 2011, the official number of skeletons legally exported with CITES permits totalled 1160 skeletons(about 10.8 metric tonnes). National data for 2012 and 2013 were not available at the time of this investigation.
Up to 2006/2007, the combined quantity of live Lions and Lion parts and derivatives exported to East–Southeast Asia
from South Africa was an unremarkable blip in the broader global trade. From 2008, however, the quantities exported
increased almost six-fold from the previous year. Not only did the number of live Lions exported to East–Southeast Asia
reach record levels from this time, but also the first permits to export Lion skeletons were issued. The demand for Lionparts and derivatives appears to have coincided with the strengthened conservation measures adopted in 2006–2007
to protect Tigers and Asian big cats. Accordingly, Tiger parts were increasingly substituted with Lion parts obtained fromAfrica. The trade in Lion parts and derivatives to Lao PDR dominates the exports.

EXPORTERS, IMPORTERS AND TRADE FLOWS
The trade route for bones on the South African side of the supply chain is relatively transparent and there is presumed tobe more legal than illegal trade. In general, the bones follow a linear route with “bone agents” being the middlemenbetween the farm/landowners and the buyers in Asia. A simplified trade flow resembles the following: landowner(breeding or hunting facility)  bone agent (an enterprise or individual who buys Lion skeletons from landowners andsells them to a buyer, usually in Southeast Asia)  freight forwarder (a company or person who organizes the transportand shipment of the bone consignment on behalf of the carrier so that the cargo reaches Asia)  ground handling agent(responsible for handling cargo on behalf of a specific airline)  airline  destination country and buyer/customer.
However, the routes become less linear if the landowners and bone agents bypass the forwarders and/or handlingagents. The number of landowners selling bones to bone agents in South Africa is unknown. Of the bone agents, there are
only 12 known exporters; in the past DEA released the names of six agents, five names were mentioned in confidence
during the interviews for this report, and one new name was mentioned in the media in 2013.
The Asian side of the trade chain is less transparent and understood, and little is known about the fate of Lion bones
once they reach East–Southeast Asia. Since wildlife trade often makes use of the same established networks and supply
lines, the Lion bone trade may have piggy-backed on existing wildlife routes in Lao PDR, Viet Nam, China, Thailand
and possibly Myanmar, and is worthy of further investigation. If Lion bones are being traded between countries in East–
Southeast Asia, then the trade is presumed to be mainly illicit given the absence of CITES export-import permit records
to legitimize the trade. The name of a company that repeatedly appears in reports published by the South African
government and environmental interest groups is Xaysavang Export-Import Company in Bolikhamxay Province, central
Lao PDR. In November 2013, the US Department of State issued a reward of up to USD1 million for information leading
to the dismantling of the Xaysavang Network as part of a larger strategy to disrupt the illicit trade in wildlife (U.S.
Department of State, 2013), estimated at USD8 to USD10 billion per year.

VALUE OF THE LION BONE TRADE
The value of a Lion skeleton is determined by the completeness of the “set” (i.e. whether the skull and/or limb bones areincluded, and accordingly a premium is paid to sellers if these bones are included) and where (and what country) theskeletons are in the supply chain. There are at least two tiers to the South African end of the Lion bone trade chain toconsider when determining the value of the bones: (1) the price paid to landowners for skeletons by the bone agents,and (2) the price paid to the bone agents/wildlife traders/intermediaries by the Asian importers. One must be cautious
when evaluating the South African side of the supply chain not to use erroneously the same US dollar prices that arereportedly paid for Lion parts and products once they enter the supply chain in Asia. The price being paid to South African
farmers/landowners by the bone agents in 2013 was ZAR12 000 to ZAR15 000 (USD1260 to USD1560) per set withoutskulls, and up to ZAR18 000 to ZAR20 000 (USD1890 to USD2100) with skulls (depending on the size of the skeleton).
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Bones of Contention: An assessment of the South African trade in African Lion bones

Thereafter, the bone agents charge the importers a fee of about ZAR3000 (USD315) per set. Thus, the prices paid toSouth African landowners are substantially less than USD10 000 to USD15 000 per complete set that is frequently
alleged to be paid. Ascribing such erroneously high values on the South African side of the supply chain would make itseem plausible that poaching wild Lions would be a cheaper alternative to sourcing bones from hunted captive animals
and thereby incentivize illegal hunting – which is not the case in South Africa.
The value of Lion bones generated as a secondary by-product of the trophy hunting industry have allegedly motivatedfarmers to exhume carcasses that were discarded after past trophy hunts and captive mortalities. And, whereas Lionesses
formerly had little or no value to breeders from a trophy hunter’s perspective, the emergence of the Lion bone trade has
generated a previously unexploited value for females. A concern raised during the research was the incentive to breed
Lions solely for the Lion bone trade. What the representatives from SAPBA, the various provinces and DEA are firm on
is this: there is currently no economic incentive to farm Lions solely for bones, especially given the costs involved inraising Lions and the current prices paid for skeletons. Since a skeleton was worth, at most, ZAR20 000 (USD2100) in2013 and a trophy hunted male Lion of at least six years old generates ZAR160 000 to ZAR170 000 (USD16 800–
USD17 900), it makes no business sense for farmers to breed males for the bone industry and forfeit at least ZAR142 000(USD14 900) in the process. Thus, selling the bones is of secondary benefit to their operation. Lionesses and juveniles
are, however, at risk of being culled – but current data on the average mass of an exported skeleton suggests that thepractice of exporting bones obtained from females and juveniles is in the minority for the time being.

ILLEGAL TRADE IN LIONSThe Lion bone trade in South Africa is juxtaposed within a network of dealers that operate both legally and illegally. The
illegal trade in Lions and their body parts usually involves restricted activities for which offenders are not in possessionof a permit to breed, keep, hunt, catch, sell, convey or export a live animal or parts thereof. Since African Lions arelisted in Appendix II of CITES, any international trade requires a CITES export permit. There have been various reportsof illegal Lion trade over the years, which seems to have escalated since 2008, but there are no specific official figuresavailable for South Africa besides what are reported in the media or by the annual reports on seizures and prosecutions by
TRAFFIC (e.g. TRAFFIC, 2013). Most reports refer to illegal translocations of animals, especially between the Northern
Cape province and Botswana.

TIGER TRADE FROM SOUTH AFRICA
The trade in Tigers was a peripheral aspect to this study and not part of the investigation as set out in the aims. However,concerns were raised towards the finalisation of this report and therefore a preliminary assessment was made. Thereappears to be a growing trade in Tigers and their parts and products from South Africa, and there have been calls formore transparency on the matter. An emerging concern is that Tiger bones from South Africa may be laundered as Lionbones using CITES Appendix II (instead of Appendix I) permits. Limitations in the South African legislation applying
to endangered exotic animals have made it possible for an unregulated domestic trade in Tigers.

IMPACT ON WILD LION POPULATIONS IN SOUTH AFRICA
In South Africa, the trade in Lion bones currently has a negligible impact on wild Lion populations. The trade in bones
appears to be a sustainable by-product of the sizeable trophy hunting industry in South Africa, and Lions that are hunted
are almost exclusively captive-bred. There are few records of wild-hunting and poaching in the country, especially at alevel that could supply the sizeable bone trade. The impact of the bone trade on wild Lion populations outside of South
Africa, however, has yet to be determined.

Bones of Contention: An assessment of the South African trade in African Lion bonesxiRECOMMENDATIONS
While the trade in Tiger bones is an established threat to Tiger conservation and many recommendations have been madein various reports, the emergence of the Lion bone trade between South Africa and East–Southeast Asia to sustain the
demand for parts and derivatives (especially bones) from big cat species is as recent as 2008 and growing. This is thefirst full research report on the matter and many issues and concerns were raised by all of the interviewees during thisinvestigation. Since it seems unlikely that the trade in Lion bones will be banned in South Africa in the near future, orthat syndicates, traders and Southeast Asian consumers will cease consumptive practices involving Lions and Tigers, thepragmatic blanket recommendation is that measures currently in place to impede opportunities for illegal activities arestrengthened across the entire supply chain from Lion breeding to skeleton exports.
In view of the research findings, the following actions are recommended:

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xii

Develop an integrated national system for issuing permits that can be crosschecked by all enforcement and Customs
officials in other provinces.
CITES export permits should record the number of sets of skeletons and the combined mass thereof in a shipment.
There is no benefit to recording the number of individual bones on a permit since this obscures the total number ofbone sets and therefore the number of animals in trade.
National and Provincial permit issuers, law enforcement and Customs officials should use the graph provided inAppendix 5 as a way of cross-checking the accuracy of declared skeleton quantities versus bone/consignment mass
recorded on the applications for CITES export permits and/or the waybills. Recording the mass and number ofskeletons on the CITES permits will assist vigilant Environmental Management Inspectors (EMIs) and freight
forwarders with identifying discrepancies and anomalous declarations in shipments that contain more animals thanwere declared on the export permit and waybill.
Develop a user-friendly means to determine whether a skeleton is that of a Lion or a Tiger. We have recommended
one way to distinguish between Lion and Tiger skulls (Figure A1 in Appendix 4), but other characters may exist andrequire further development.
Since it is not currently possible to determine whether CITES Appendix I Tigers are being illegally shipped as
Appendix II Lion bones, spot checks and DNA tests of the exported consignments should be conducted to determine
whether a skeleton is that of a Lion or Tiger. The relevant officers could be provided with DNA collecting kits andtrained to collect tissue in a manner that would be acceptable to the justice system.
Investigate the use of South African seaports as a gateway for Lion and Tiger product exports.
Conduct a trade study on what happens to Lion bones and derivatives once they reach Asia and especially East–
Southeast Asia, including an assessment of the trade routes and the value of the products along the supply chain.
Investigate the Tiger trade in South Africa, including an assessment of the ex situ population, consumptive and nonconsumptive utilization, national and provincial legislation with respect to keeping and hunting exotic animals, and,the inappropriate use of CITES Appendix II permit to trade products.
Investigate the trade in Lion products (especially bones) in other African countries besides South Africa to determine:(a) the extent to which the products are available through legitimate and illegitimate sources, (b) the origin of the
products (wild or captive bred), and (c) whether there are negative impacts on regional wild Lion populations acrossLion range States in Africa.
Although the compliance of provinces to national and provincial statutes relevant to Lions was researched at a broad
level, time constraints precluded detailed examination of alleged individual transgressions. There remains a need toevaluate and, where necessary, synchronize the South African national and provincial legal frameworks to remove
loopholes creating opportunities for non-compliance and illegal activities.
It appears that more Lion hunting is taking place than is being reported by professional hunters. The sources of thediscrepancies should be determined and various departments must find an appropriate way of “fixing” the hunting
register and not issue permits without the register. The extent of the domestic hunting market for Lion should also
be evaluated.
Improve transparency within the bone trade, by considering a system (possibly including the use of studbooks andmicrochips) that tracks individual captive bred Lions from birth to death and from origin to final destination so that
all exported skeletons and trophies can be traced back to the original source and mode of mortality
The South African Revenue Service (SARS) must insist that all wildlife related cargos be stopped for inspection by
EMIs and not simply released without examination.
Conduct awareness campaigns targeting all cargo handlers/freight forwarders/cargo agents on a regular basis sothat they are aware of sensitive wildlife cargoes and are able to identify illegal or suspicious shipments.

Bones of Contention: An assessment of the South African trade in African Lion bones

INTRODUCTION – LION BONES &TIGER WINE
INTRODUCTION
Severe habitat loss, human-wildlife conflict, poaching, persecution and especially the illegal trade in body parts andproducts have become major drivers in the extirpation of Tiger Panthera tigris subspecies and subpopulations acrosstheir ranges. Of the nine subspecies that once occurred in 24 range States across Asia, only 13 countries currently haveconfirmed subpopulations (Chundawat et al., 2011). Three subspecies are Extinct, two are Critically Endangered andfour are Endangered. The global Tiger population is estimated to have as few as 3200 Tigers in the wild, with fewer
than 2500 being mature breeding individuals and no one subpopulation having more than 250 mature individuals(Chundawat et al., 2011; EIA, 2013; Goodrich et al., (2015); Nowell and Pervushina, 2014; SSN, 2014). In China, thewild Tiger population is estimated at 40–50 individuals (Nowell and Pervushina, 2014; SSN, 2014).
A prevailing opinion is that booming Asian economies, rising “Asian affluence” and an expanding “wealth-not-health”
driven demand for Tiger products by a growing newly rich Asian population, particularly in China, is concurrently
endangering the world Tiger population and thereby facilitating their sharp decline (EIA, 2014a; Graham-Rowe, 2011;
Nowell and Pervushina, 2014; TRAFFIC, 2008; UNODC, 2013; Zabarenko, 2010). While the demand for traditional
medicines is frequently cited as a primary driver in the commercial trade of bones and body parts, a market also exists
for non-essential “luxury” products such as Tiger meat, skins and ornaments. There is a range of products claiming tocontain Tiger bone derivatives available on the market, such as “plasters” (poultices), wine, powder and “gelatin”(Gratwicke et al., 2008; Nowell, 2010; Stoner, 2014). It is likely, however, that many of these products do not actuallycontain Tiger derivatives (Gratwicke et al., 2008) or, the concentrations are so low that detection of the DNA is notpossible (Wetton et al., 2004).
“Tiger bone plasters” and “Tiger bone wine” are two of the products most likely to be purchased by consumers andadvertised on online auction sites (Gratwicke et al., 2008; Stoner, 2014). The “wine”, considered a popular traditional
health remedy, is used in the treatment of rheumatism, arthritis, traumatic injuries, and to give the drinker the “strengthof a Tiger” (Ellis, 2005; Gratwicke et al., 2008; Nowell and Jackson, 1995; Nowell and Ling, 2007; Penman, 2007).
While the “wine” (technically a tincture) is purported to have medicinal properties for treating illnesses, the drink isalso used equally as a high-value nourishing health tonic to promote health and well-being (Gratwicke et al., 2008;
Nowell and Ling, 2007). One newspaper reported that to produce the wine, Tiger carcasses are steeped in vats of ricewine for up to nine years (Penman, 2007), and the price of one bottle depends on how long the bones were steeped inalcohol (Gratwicke et al., 2008).
Despite China outlawing all use and domestic trade in Tigers and their parts and removing Tiger bone from theapproved traditional Chinese medicine (TCM) pharmacopoeia in 1993, there is a persistent demand for medicinal
products and tonics with ingredients claiming to be Tiger (EIA, 2013; Graham-Rowe, 2013; TRAFFIC, 2013a).
Chinese conservation officials have been quoted in newspapers as saying that it is irresponsible to blame the practice ofusing Tiger bones in TCM per se for the drastic decline of wild Tigers because practitioners abandoned the practice ofusing Tiger parts after the 1993 trade ban and are using alternatives instead (Ru and Juan, 2010; Zhuoqiong, 2010).
Rather, they say, it is individual people’s belief in the various products that has driven the demand in China andSoutheast Asian countries (Zhuoqiong, 2010). Moyle (2009) wrote that it is doubtful that the formal TCM sector is
responsible for distributing Tiger parts since criminal organizations in China seem to have avoided the use of the TCM
retail system.
Tiger bones are one of the most lucrative animal products sold on the illegal wildlife market (Haken, 2011), and thepoaching of Tigers is driven by demand principally from China and Viet Nam (Moyle, 2009; SSN, 2014). Tiger
conservation breeding programmes and farms were established in China in the 1980s, ostensibly “to save…subspecies
from doom” in response to the declining wild population (EIA, 2013). However, some farms or their subsidiarycompanies openly sell products such as Tiger bone wine. And, since wild and farmed Tiger products are virtuallyindistinguishable, there are legitimate concerns that products from wild Tigers could be laundered through such
establishments if the trade in products from farmed Tigers were to be legalized (Gratwicke et al., 2008). Chinese

Bones of Contention: An assessment of the South African trade in African Lion bones

1

officials, however, have repeatedly denied that the establishment of these breeding facilities is linked to the illegal tradein Tiger products and the decline of wild populations (e.g. CITES 2010a; Ru and Juan, 2010).
In 1984 there were around 200 wild Tigers left in China and none in captivity, but within 20 years the numbers of
captive Tigers has increased to over 5000 individuals being held in more than 200 facilities (EIA, 2013, 2014a; Nowell
and Pervushina, 2014; SSN, 2014). The disconcerting conditions under which animals are kept in these facilities are acause for concern and have resulted in demands for them to be shut down. But such is the demand for Tiger products(alleged to be millions of consumers across East–Southeast Asia by Graham-Rowe, 2011; Gratwicke et al., 2008;
Moyle, 2009) and an unhurried regional approach to modifying consumptive utilization practices, that shutting downthese facilities in the near future (thus severing the captive source of bones to supply the product manufacturers) could
bring the remaining wild Tigers closer to being extirpated. Gratwicke et al. (2008) reported that 71% of consumers who
had used products claiming to contain Tiger parts preferred products from wild Tigers; thus, if farmed Tigers are a
substitute for wild Tigers, then terminating the supply of farmed Tigers is unlikely to terminate the demand, andpoaching of wild Tigers would almost certainly intensify. One must consider, however, that farming Tigers does notnecessarily reduce or satisfy demand since the availability of captive-sourced products could increase the demand
beyond what the facilities can supply (UNODC, 2010). Thus, measures to limit the utilization and trade of Tiger
products effectively will also have to be accompanied by globally successful demand reduction measures aimed atstrengthening compliance of the trade bans and transforming consumer behaviour by creating awareness regarding theimplications of their consumptive actions. However, as Graham-Rowe (2011) writes “…getting users of traditional
Asian medicines to change their ways is as much about changing tradition as it is about advancing medicine”. But,
while the race is on to protect Tigers and effect constructive demand reduction measures, there are felid substitutes for
Tigers that are maintaining the bone supply and foiling efforts to reduce the demand – notably Lion Panthera leo bones.
As the Chinese Tiger population headed towards extinction, purveyors of Tiger products turned their attention to Tigers
in Russia as well as range States in South and Southeast Asia. Tiger poaching in India, for example, was noted in the
mid-1980s (Badhwa, 2002; EIA, 2013; Ellis, 2005; Johnsingh, 2009) and eventually incidents involving leopards
Panthera sp. and the Asiatic Lion Panthera leo ssp. persica were reported there about 20 years later when Tiger
numbers in States such as Madhya Pradesh and Rajasthan declined considerably (EIA, 2014b; Fair, 2009; Johnsingh,
2009; Wildlife Protection Society of India, 2007) (Appendix 1). The increasing prevalence of Tiger substitutes derived
from felids such as leopards was noted across East Asia and in shops selling TCM in the USA and Australia (Callisterand Bythewood, 1995; Henry, 2004). But one of the earliest predictions that Tigers would eventually be substituted byparts from Lions and leopards was made by Khoshoo (1997) who, in connection with the demand and consumption ofTiger parts for TCM, wrote: “once tiger is decimated, the next target will be lion, followed by leopard (even bear) andall other felines from Asia and Africa”.
Prior to confirmed reports of Asiatic Lions being killed for TCM in 2007, images of Lions began appearing on thelabels of manufactured Chinese medicines in the mid-1990s (Mills, 1997; Nowell, 2000). At the time there was noevidence that bones from wild Lions were being used, but there was speculation that bones from captive Lions werebeing substituted illegally (Nowell, 2000). Nowell (2000) reported: “A medicine labelled as musk and tiger-boneplaster, depicting a tiger on its label has now substituted leopard bone for tiger bone in the ingredients list, beenrenamed as “Heavenly Emperor” plaster, and features a lion on the packet”.
An investigation by TRAFFIC in 2005 found evidence that African Lions were an ingredient in “tiger” “bonestrengthening wine” (Nowell and Ling, 2007). The Xiongsen Wine Producing Ltd in Guilin, Southeast China, wasgiven permission to produce 400 000 bottles of “wine”. While the name sounded like “tiger bone wine” and the bottle
was in the shape of a Tiger, the approved ingredient was “Panthera leo” bones – which only experts knew referred toLion and not Tiger (Nowell and Ling, 2007). The nearby Xiongsen Bear and Tiger Mountain Village (of which theXiongsen Wine company was later revealed to be a subsidiary; China CITES Management Authority cited in EIA,
2013), reported having African Lions in captivity that were being reared with three Tiger subspecies and Asiatic Black
Bears Ursus thibetanus (CITES, 2007a). When Beijing-based news reporters investigated the incident, staff at the wine
producing company and the breeding facility allegedly insisted that the wine was made from Tiger carcasses. However,when the Chinese government subsequently conducted an investigation they reported in October 2006 “only 16 legallyobtained lion carcasses were found, and no tiger bones were used to produce the wine” (Nowell and Ling, 2007)1. By
1 Nowell and Ling (2007) included this footnote about the incident: “The conservation community does not recommend thatany other felid species be used as an alternative to tiger bone; rather, the emphasis has been on eliminating demand.
Allowing the use of lion as a substitute for tiger is a dangerous precedent. The African conservation community is concerned
about the potential for lion bone to serve as a substitute for tiger bone, a concern reflected in two regional lion conservation
strategies developed by African range State governments in partnership with conservationists and stakeholders”. The
strategy proposed by the Cat Specialist Group (2006) was to prevent illegal trade in lion products by reviewing andamending relevant legislation and policies and prohibiting the trade in lion bones.

2

Bones of Contention: An assessment of the South African trade in African Lion bones

2007, the African Lions at the Xiongsen facility numbered more than 200 and were being reared for food and medicine
alongside 1300 Tigers (CITES, 2007a; Penman, 2007).
Khoshoo’s (1997) prediction that Asiatic Lions would eventually be a target of the TCM trade was not confirmed until
a decade later (Appendix 1). In August 2006 a live Asiatic Lion was observed in a market in Mong La (Oswell, 2010) –a town in northern Myanmar less than 2 km from the Chinese border and known for incidents of wildlife trafficking.
Months later in early March 2007 the first of three incidents occurred that implicated TCM and confirmed that AsiaticLions were at risk of being poached and the bones sold into the “tiger” trade (Anon., 2007; EIA, 2014b; Fair, 2009;
Johnsingh, 2009; Kotecha, 2007; T. Ghose, in litt., 11 April 2014) (Appendix 1). TCM was suspected because thebones, skulls and teeth had been removed and the skins were left behind (Ramesh, 2007). A gang of poachers from the
Baheliya tribal community were eventually arrested and convicted for the killing of eight lions, and the TCM trade wasproven to be the motive behind the crime according to the Gujarat Criminal Investigation Department (EIA, 2014b;
Fair; 2009; Srivastava, 2007). Then in April 2009 came the first newspaper reports in South Africa of the illegal“slaughter” of several Lions – by an illegal Vietnamese immigrant, Nguyen van Hai, at a residence in Pretoria(Groenewald, 2009; Hosken, 2009; Miller, 2009; Otto, 2009a). Lion carcasses were reportedly “lying all over the floor,
everywhere in the house” (Miller, 2009). The story made headlines and conservation officials were alerted to a potential
threat to another of South Africa’s big five flagship species. Already in the grips of an escalating rhino poaching crisis,
this event took people by surprise. However, as will be discussed later, permits to export bones to Lao PDR had alreadybeen issued in 2008.
When Nguyen van Hai was arrested on 30 March 2009, several2 “recently-executed lions and…rhino carcasses” were
found in his possession (Anon., 2009a; Miller, 2009). Detectives speculated that van Hai had been killing endangered
African mammals “to-order” for a gang operating from the Far East (Miller, 2009; Otto, 2009b). After that incident,
the face of the Lion bone trade didn’t overtly raise its head again until December 2009 when it was reported that a Free
State Lion farmer had been granted a CITES permit to sell Lion bones (Rademeyer, 2012a; Smith, 2009). Although thepermit only allowed the sale of bones to someone in the adjacent province of Gauteng, the bones were ostensibly
destined for Asia where they were alleged to be sought after as substitutes for “tiger bones”. Smith’s (2009) newspaper
report further claimed that there was a growing demand for Lion bones in the East, and that the “demand in Asia had
suddenly become so great that many farmers in the Free State who practiced illegal lion hunting in the past and buried
the carcasses are now digging up these carcasses to sell to people in the Far East”. What’s more, “The door to theenormous market for ‘tiger bones’ has now been opened” (Smith, 2009).
With the doors to South Africa’s participation in the Tiger bone market now firmly opened, legal exports of Lionskeletons (i.e. with CITES permits) rapidly escalated from approximately 50 skeletons in 2008 to 573 in 2011. To theimporters, bones from Lions were a plentiful, cheaper and mostly legally sourced alternative to Tiger bones that wereusually obtained from the carcasses of captive bred animals following a trophy hunt (where normally only the skull andskin are taken as a token by a hunter). However, concerns were raised about the potential negative impacts on wild
African Lion populations as a result of the trade – and this research report was initiated by TRAFFIC and WildCRU(Oxford University) to examine the basis for these concerns.
One critical question that arises when scrutinising the Lion bone trade is: what events (if any) impelled the adaption
from the traditional use of Tiger bones in Asian zootherapeutic practices, to substituting the bones of other Asian largecats in place of Tigers, and ultimately including the bones of Asiatic and then African Lions as ingredients in traditional
remedies? A retrospective examination of the timelines for key events in Tiger conservation and the regulation of the
Tiger products trade is one constructive way of responding to the question. Accordingly, we speculate on what factors
elicited the Lion bone trade and what unexpected, secondary impacts it might have had.

TIMELINES IN THE TIGER TRADE RELEVANT TO LIONS
Much has been written about the trade in products from Tigers and other Asian big cats. Reports by Callister andBlythewood (1995), EIA (2014b), Gratwicke et al. (2008), Henry (2004), Mills (1997), Mills and Jackson (1994),
Oswell (2010), Shepherd and Nijman (2008), SSN (2014), Verheij et al. (2010), Williamson and Henry (2008), andparticularly by Nowell (2000), Nowell & Ling (2007) and Nowell & Pervushina (2014), are especially comprehensive
2 Newspaper reports differ on the number of lion carcasses discovered in the house. Groenewald (2009) alleges that “10 lion

and rhino carcasses were found”; Otto (2009c) reports that three carcasses, four lion molars, two lion teeth and one lion claw
were found; whereas Miller (2009) alleged that “carcasses of 13 lions and rhinos were found”. Nguyen (Nguxen) van Hai, who

had entered South Africa illegally in November 2007, eventually pleaded guilty to five charges under NEMBA and wasdeported on May 28th, 2009 (Anon., 2009b,c). He stated in a plea agreement to the Pretoria Regional Court: “A few weeks

prior to his arrest, the accused bought the items on the black market. He was planning to sell them to generate cash to send
to his family in Vietnam” (Otto, 2009c).

Bones of Contention: An assessment of the South African trade in African Lion bones

3

with detailing the background and extent of the trade. To explore the theory that the strengthening of regulatory
measures intended to protect Tigers was one factor that might have inadvertently initiated the Lion bone trade, key
measures and events intended to protect Tigers and deter the trade, and the years in which these measures were adopted,
are summarized in Table 1. Accordingly, inferences are made as to how these measures might be relevant to the Lionbone trade (Table 2).
Tigers were first listed in Appendix I of CITES in 1975 (with the exception of the Siberian Tiger, which was initiallylisted in Appendix II before being transferred to Appendix I in 1987) (UNEP-WCMC, 2014; Williamson and Henry(2008), and international commercial trade was thus prohibited. When China acceded to CITES in 1981, theircompliance with the international trade ban thus became obligatory. Five years later in 1986 the Siberian Tiger Park in
Harbin, China, was established when a wildlife biologist “decided to breed captive tigers as a source of tiger-bone
medicine with the hopes of decreasing poaching pressures on wild cats” (Morell, 2007) – but China banned the Tiger
trade before the farms were operational and any captive Tiger parts were sold (Dutton et al., 2013; Morell, 2007).
Table 1 National and international measures adopted to protect Tigers and other Asian big catsYeareffective
1975 –Jul

ActionImplications
International commercial trade in most subspecies of Tigers and their body parts isbanned. However, trade in Siberian Tigers (Panthera tigris ssp. altaica) remained
permissible, with regulation, until 1987.

1987 –
Oct

Most Tiger subspecies
listed in Appendix I of
CITES; Siberian Tiger listed
in Appendix II.1,2,3
Siberian Tiger listed inAppendix I of CITES.1,3

1989

China passes the 1988 Law

1993 –
Mayof the People’s Republicof China on the Protectionof Wildlife.4,5
China promulgates the1993 Notification on
Banning the Trade in Tiger
Bone and Rhino Horn – acomplete domestic banon the trade in/use ofTiger bone and derivatives
implemented by
China.4,5,6,7

1994 –
Nov

CITES adopts Resolution
Conf. 9.13 (CoP9).3,4,6

2002 –
Nov

CITES Resolution Conf.
9.13 was superseded by

Resolution Conf. 12.5
(CoP12).4,8,9,10

Siberian Tiger transferred from Appendix II to Appendix I of CITES, hence theinternational commercial trade in all subspecies of Tigers and their parts/products
is prohibited.
Law passed to protect, develop and rationally utilize wild animal resources. Tigers
listed as a Category 1 species, thereby affording it the maximum level of protection
from hunting, sale, purchase and use of Tigers and Tiger products – but breeding,“domestication” and utilization is encouraged.6
The regulation was meant to strengthen protection measures for Tigers. The 1993
ban reiterated the 1989 ban, and took further measures to extend the ban toderivatives not readily recognisable as Tiger parts – including the manufacturing ofTiger medicines.
Specifically, the notifications forbid “...import and export of…tiger bone and theirproducts, forbids selling, purchasing, transporting, carrying and mailing…tiger
bone and their products (except for uses on researches of substitutes). The
national standard of using…tiger bone in medicines was annulled”.
Tiger bone is removed from the traditional medicine pharmacopoeia.6
The Resolution (i) directed Parties to implement certain Tiger conservation
measures, (ii) urged Parties to voluntarily prohibit the domestic trade and sale ofTigers and Tiger parts and derivatives to stem poaching and illegal trade, and (iii)
recommended bilateral and multilateral co-operation on enforcement andinformation sharing.
The action was taken because there was evidence that as “tiger populations

declined and as illegal trade in tiger parts became more difficult (due to enhanced
enforcement), other Asian big cats were being increasingly used as substitutes”.
Resolution Conf. 12.5 extended many of the recommendations for the Tiger to the

Leopard, Snow Leopard and Clouded Leopard.
From 2006, all activities of hunting wild leopard and purchasing leopard bones
banned. Hence, the loophole that allowed leopards to be used as a substitute for
Tiger bones in Chinese medicines is closed.
CITES CoP approves Decision stating Tiger farms should be phased out and that2007 –
Decision 14.69.11
Tigers should not be bred for trade, including domestic trade, in their parts orJunproducts.6,12
References: 1=UNEP-WCMC (2014); 2= Nowell (2000); 3=Williamson and Henry (2008); 4=Nowell and Ling (2007);
5=People’s Republic of China (2006); 6=EIA (2013); 7=Gratwicke et al. (2008); 8=CITES (2002); 9=Henry (2004); 10=Nowell
and Pervushina (2014); 11=CITES (2007b); 12=SSN (2014)
2006 –
Mar

4

Regulation by the State
Forestry Administration(China) in 2005.4,5
CITES (CoP14) approves

Bones of Contention: An assessment of the South African trade in African Lion bones

In 1993, China implemented a complete ban on the domestic trade in Tiger bones and their derivatives that was aimed
at strengthening protection for the species (Gratwicke et al., 2008; Nowell and Ling, 2007). The ban reiterated the 1988
Chinese Law on the Protection of Wildlife that prohibited the hunting, sale, purchase and use of Tigers and Tiger
products (but which encouraged breeding and domestication) AND extended that ban to include derivatives not
immediately recognizable as Tiger parts – such as Tiger medicines and tonics (EIA, 2013; Nowell and Ling, 2007)(Tables 1 and 2). The ban was necessary in light of the massive trade in Tiger parts and derivatives – estimated to be as
high as 27 million units exported from China between 1990 and 1992 (Gratwicke et al., 2008; Mills and Jackson, 1994).
(Note: all countries except North Korea have since taken similar legal measures to ban the Tiger trade, and the demandis reported to persist among a minority in number of countries. S. Broad, in litt., April 2015).
After the Chinese trade ban was implemented in 1993, there was a continuous and corresponding decline in theavailability of Tiger bone products and medicines in outlets across the world selling Chinese traditional medicines andtonics (e.g. Gratwicke et al., 2008; Henry, 2004; Nowell and Ling, 2007). The declines were proposed to be the resultof: (1) heightened awareness of the illegality of the trade and the protected status of Tigers, (2) increasingly successful
compliance by the Chinese medicinal industry with the trade ban, (3) adaptation by the TCM industry in finding
effective alternatives, and (4) the Chinese medicine community embracing support for Tiger conservation as anecessary social responsibility (Gratwicke et al., 2008; Nowell and Ling, 2007). But by 1994 medicinal substitutes for
Tiger bones were being detected during surveys of pharmacies and markets (Mills, 1997). Leopard bone was the mostcommon substitute, but images of Lions also started appearing on the labels of some manufactured medicines (Mills,
1997; Nowell, 2000) (Table 2). Since sales of products with Tiger bone are not banned in China (Gratwicke et al.,2008), using these labels was one way of avoiding regulatory action for products that did not contain Tiger (S. Broad, inlitt., April 2015).
Less than a decade after the 1993 Chinese trade ban it was noted that as Tiger populations declined, the demand andillegal trade in other Asian big cats such as Leopard Panthera pardus, Snow Leopard Panthera uncia and Clouded
Leopard Neofelis nebulosa increased (Henry, 2004; Nowell and Ling, 2007). And, while market surveys showed there
to be a decreased presence of Tiger products, China’s seizure records indicated a continuing demand (Nowell and Ling,
2007). Further evidence indicated that while trade bans helped protect Tigers in the wild, the “illegal wild tiger trade
would likely persist even if an alternative source of supply (e.g. captive-bred tigers) were available” (Nowell and Ling,
2007), in part because survey evidence indicates that wild Tiger products are preferred by the public (Dutton et al.,2013; Gratwicke et al., 2008). Thus in November 2002, CITES adopted a Resolution to extend the Tiger trade ban toinclude other Asian big cats (Tables 1 and 2). In addition to it becoming clear that many of the Asian big cats were
facing similar threats to Tigers, including the use of their body parts for traditional medicines and tonics, it was further
recognized that “as tigers received greater protection and attention, the demand for tiger parts used in traditional
medicines shifted to other Asian big cats and further threatened their survival” (Henry, 2004) – hence it became
necessary to extend the protection measures to other Asian big cat species. While the main aim of the Resolution was tocounter the skin trade, it also covered medicinal use (S. Broad, in litt., April 2015)
A loophole in the 2002 resolution was that the use of leopards as a substitute for Tigers in traditional medicine was still
permitted in China – so in March 2006, measures to ban leopards as substitutes for Tigers in TCM were implemented in
China (Nowell and Ling, 2007) (Table 1). One year later in 2007, after the number of Tigers in captivity reached over
5000 and surpassed the number of Tigers in the wild, CITES (CoP14) approved Decision 14.69 against Tiger farming
and the breeding of Tigers for their parts and products; the Decision stated that “Parties with intensive operations
breeding tigers on a commercial scale shall implement measures to restrict the captive population to a level supportive
only to conserving wild tigers; tigers should not be bred for trade in their parts and derivatives” (CITES, 2007b; EIA,
2013; SSN, 2014). Thus, in terms of the Decision countries with breeding programmes, such as China, Viet Nam,
Thailand and Lao PDR, were urged to phase out Tiger breeding for any commercial trade in their parts and products
and implement measures to restrict the size of the captive population. That same year, in March/April 2007 the three
confirmed incidents of at least eight Asiatic Lions being poached in India’s Gir National Park was reported –specifically for bones for TCM (EIA, 2014b; Fair, 2009; Ramesh, 2007; T. Ghose, in litt., 11 April, 2014) (Table 2).
And in 2008, the first permits to export Lion bones from South Africa to Lao PDR were issued (see Table 9). From
2009, illegal activities and reports of seizures of African Lion parts were reported with increasing frequency (see Table
13).

Bones of Contention: An assessment of the South African trade in African Lion bones

5Table 2 Notable regulations and activities in the timelines of the Tiger and Lion trade
Activities involving Lions and Tigers

Year

Asiatic Lion (Panthera leo ssp. persica) listed in Appendix II of CITES.1

1975

African Lion Panthera leo ssp. leo in Ghana listed in Appendix III of CITES.1
Asiatic Lion transferred to Appendix I of CITES; African Lion listed in Appendix II of CITES(including Ghana transferring from III to II).1

1976
1977
1978
|
1980
1981
1982
|
1985

The Siberian Tiger Park (Harbin, China) is established as China’s first commercial Tiger farmto breed Tigers for profit, primarily to supply bones for medicinal use.5,6Chinese National Pharmaceutical Bureau gives the Beijing Pharmaceutical Company remit touse Tiger farming to address the shortage of Tiger bones.6

Legislation (details in Table 1)
Most subspecies of Tigers listed in Appendix I of CITES,
except for Siberian Tigers which was listed in Appendix
II.1,2,3

China acceded to CITES.4

1986
1987

Siberian Tigers transferred from Appendix II to Appendix
I of CITES.1,3

1988
1989

1988 Law of the People’s Republic of China on theProtection of Wildlife. Hunting and killing of Tigers
strictly forbidden (May).4,6,7,8

1990
|
1992
The Xiongsen Bear and Tiger Mountain Village (Guilin, China) is established.6

1993
1994

Images of Lions reported to have replaced Tigers on some manufactured Chinese medicines,
but no evidence of wild Lions being used.2,9China implements a complete ban on the domestic
trade in Tiger bone and also removes it from the TCM
pharmacopoeia.4,6,7
CITES adopts Res. Conf. 9.13 (CoP9), the first Tiger
resolution (Nov).3,4,6,8

1995
1996

Khoshoo predicts that Lions and other felines in Asia and Africa will be the next target forparts for TCM once the Indian Tiger “is decimated”.10

1997
1998
|
2001
2002

Mention of Asiatic Lion parts allegedly used in traditional medicine.13
Nowell & Ling report evidence that “tiger bone wine” was being made with African Lionbones by a Chinese wine producing company.4* Live Asiatic Lion observed in a market in Mong La, Myanmar (Aug).14* Alleged by the Gujarat Criminal Investigation Department that since the winter of 2006,
poachers from Madhya Pradesh were specifically targeting Asiatic Lions for use in TCM.15(Appendix 1)* The Gujarat Criminal Investigation Department confirm that eight Asiatic Lions werepoached for bones for TCM in Gir National Park (March/April).15,16,17,18,19,20 (Appendix 1).
* The Xiongsen breeding facility reports that it has more than 200 African Lions in captivity.21
First permit to export African Lion parts to Lao PDR from South Africa issued for 10
skulls/skins & 20 floating bones (Feb). This was followed in July by the first permit issued toexport Lions skeletons – an amount of 35 African Lion skeletons to Lao PDR from South
Africa (Jul), followed by a second permit for 15 skeletons a few months later. Media unawareof this.
* First report in South Africa: Vietnamese man arrested in Pretoria for having illegally“slaughtered” several Lions (Apr).23,24* First report of a CITES permit being issued to legally export Lion bones to an Asian
country.25
Growth of exports of Lion bones to Southeast Asia from South Africa (See Table 9, Figures 23& 24)

CITES Res. Conf. 9.13 is superseded by Res. Conf. 12.5
(CoP12). (Nov).4,11,12

2003
2004
2005

2006

2007

China implements a regulation banning leopard hunting
and the purchase of leopard bones in China (Mar).4,6

CITES (CoP14) approves Decision 14.69 against Tiger
farming and breeding for trade in their parts andproducts (Jun).8,16,22

2008

2009

2010

The State Forestry Administration of China tells CITES
Parties that China’s laws encourage captive breeding
and the use of Tiger products.6,8,16

2011

2012

6

Bones of Contention: An assessment of the South African trade in African Lion bones

References: 1=UNEP-WCMC (2014); 2= Nowell (2000); 3=Williamson and Henry (2008); 4=Nowell and Ling (2007); 5=Morell(2007); 6=EIA (2013); 7=People’s Republic of China (2006); 8=CITES (2010a); 9=Mills (1997); 10=Khoshoo (1997); 11=CITES(2002); 12=Henry (2004); 13=Ali (2003); 14=Oswell (2010); 15=Srivastava (2007); 16=EIA (2014b); 17=Fair (2009);
18=Balakrishna (2008); 19=Wildlife Trust of India (2008); 20=T. Ghose, in litt. (11 April 2014); 21=CITES (2007a); 22=CITES(2007b); 23=Hosken (2009); 24=Miller (2009); 25=Rademeyer (2012a)

When timelines in the Tiger and large Asian felid regulations are overlaid on graphs plotting the growth in Lion productexports to East–Southeast Asia, the events appear to be linked (see Figure 23). Was the establishment of the Lion bone
trade thus inadvertently and directly related to the adoption of regulatory mechanisms intended to diminish the trade in
Tiger products and thereby protect Tigers (and later other Asian big cats)? And, did the sudden surge in the trade oflarge quantities of Lion bones between South Africa and East–Southeast Asia increase as a consequence of thestrengthening of the regulatory measures that gave Asian traders and syndicates a motive to find alternative sources forbones to circumvent the increasingly restrictive measures applicable to a CITES Appendix I species? This
correspondence in the timelines is seemingly too strong to disregard, especially following the measures adopted in 2002
and 2006/2007 (Table 2). The trade in Tigers and other large cats is clearly a global problem; despite the protective
measures implemented by China and CITES, Tiger subpopulations continue to decline (CITES, 2010b) and the numberof Tigers in captivity have quintupled in less than a decade from 2002 (Figure 1). Thus, did measures intended toprotect one popular charismatic species on one continent have unintended consequences that have led to increasing
threats to other Asian big cats and ultimately African Lions on a different continent? Accordingly, in rephrasing thewords of Henry (2004), “did eliminating one problem lead to another”?

Figure 1 Growth of the captive Tiger population in China in relation to the regulatory measures (vertical lines)
adopted to protect Tigers and Asian big cats (Table 1). Solid lines join records available for consecutive years;
dashed lines join non-consecutive records (Source: CITES, 2010a, 2012, 2013; EIA, 2013, 2014a,b; Nowell and Ling,
2007; Nowell and Pervushina, 2014; People’s Republic of China, 2006; SSN, 2014)

LETTING THE CAT OUT OF THE BAG: THE EMERGENCE OF THE LION
BONE TRADE IN SOUTH AFRICA
The first newspaper reports alerting South Africans to an emerging market for Lion bones occurred in March 2009
when the Vietnamese Nguyen van Hai was arrested in Pretoria (and subsequently deported) for being in possession ofLion carcasses and parts (Anon., 2009a,b,c; Hosken, 2009; Miller, 2009; Otto, 2009a,b,c). Eight months later in
December 2009 the public were made aware that a CITES permit had been issued to a Free State farmer to export Lionbones legally (Rademeyer, 2012a; Smith, 2009). It was assumed that the bones were being sold directly to China, butthere are no official records of Lion skeletons/bones being exported there that year or the year thereafter (Source:
UNEP-WCMC CITES trade database; see Figure 23a). Unbeknownst to the public however, and contrary to what has

Bones of Contention: An assessment of the South African trade in African Lion bones

7been publically reported, the first CITES permit to export Lion body parts to Lao PDR was for 10 skulls/skins and 20
floating bones (derived from 10 Lions) in early 2008 (Table 2). Then in mid-2008 the first permits to export skeletons
to Southeast Asia were issued for the sale of 35 skeletons to Lao PDR (Anon., Issuing Authority, in litt., 2013) – but theinvestigation for the current study revealed that the destination country was incorrectly reported as “Viet Nam”
(deduced from in litt. correspondence with Anon., Issuing Authority, June 2013) (see also Table 8). This error was only
detected during our investigation in June 2013. A second permit was issued later in 2008 to export 15 skeletons, also
incorrectly recording the shipment as being bound for Viet Nam instead of Lao PDR.3
Annual CITES fauna/flora import/export statistics are usually compiled about a year or more after the end of a calendar
year. Hence, there was no way of knowing in 2009/2010 that what was believed to be a “limited trade” was growing
rapidly. And, since it was known (1) that markets in East–Southeast Asia were driving the demand, (2) that cat bone
traders were prepared to accept Lion bones as an alternative to Tiger bone, (3) that Lion bones were being passed off as
free-ranging Tiger bones in medicines and tonics, and (4) that it is difficult to distinguish between Lion and Tiger
bones, the conservation world was becoming increasingly nervous about where the trade might be headed and what
impact it would have on wild populations.
In response to several questions from members of the South African parliament to the Minister of Water andEnvironment Affairs in 2011, details of the quantities of Lion bones exported to Lao PDR in 2009 and 2010, as well as
the names of the exporters and recipients of each consignment exported to Lao PDR in 2009 and 2010, were madepublic for the first time and published on the Department of Environmental Affairs (DEA) website (National Assembly,
2011a, 2011b, 2011c, 2011d). The following information was released by DEA and caused a stir across South Africa:
1.
2.
3.

In 2009 and 2010, 85 and 235 carcasses/skeletons were exported to Lao PDR respectively under the provisionsof CITES;
Most of the skeletons originated from the North West Province;
Of the 16 consignments listed as being exported to Laos:a. The importers were:i. Vixay Keosavang – received 9 consignments
ii. S. Durosagham/Duarseram – received 4 consignments
iii. Bounpasong Paphatsalang – received 2 consignments
iv. Jacek Raczka received – 1 consignmentb. The exporters were:i. Mr JJ van der Westhuizen from Letsatsi la Africa – exported 7 consignments
ii. Mr GJ van Zyl from Hatari Taxidermy – exported 3 consignments
iii. Sandra Linde taxidermy – exported 2 consignments
iv. SH Rothman exported – 2 consignments
v. Mr T Cloete and Marnus Steyl (c/o Williamson Savuti Taxidermy) – exported 1 consignment
each.

After Nguyen van Hai’s arrest in March 2009, the next arrests in connection with Lion bones occurred in June 2011
when two Thai men (Phichet Thongphai and Punpitak Chunchom) were found in possession of 59 Lions bones hiddenin a house in Edenvale, east of Johannesburg (Du Plessis, 2011a; South African Revenue Service, 2011). During their
June 2011 court appearance, Thongphai and Chunchom admitted in an affidavit that they worked for “Vichai
Company” in Lao PDR, and that the “main business” of the company was to trade in Lion bones (Du Plessis, 2011a,b).
Furthermore, they “were sent to South Africa by the company to view and approve lion bones to be bought and shippedto the company” (Du Plessis, 2011a,b). Thongphai also revealed that the “company for which I worked is usuallycontacted by farm owners in South Africa and advised that they have lion bones for sale”. There is no information onwhen exactly these visits to South Africa commenced, or when the farm owners allegedly first made contact, however
evidence presented during the court case of Chumlong Lemtongthai suggests that this may have been in 2008 or earlier(inferred from Fuller, 2013). Both men were fined R10 000 each and a heavier sentence was suspended on condition
that they leave South Africa on pre-booked flights within two days of their conviction (Du Plessis, 2011a).
The Lao-based “Vichai Company” that Thongphai and Chunchom admitted working for is the Xaysavang ExportImport Company in Paksane, Bolikhamxay Province, central Lao PDR, which is believed to be led by Vixay
3 The mistakes were detected when the author queried the relevant Issuing Authority about two permits issued to export

skeletons to Viet Nam. When the Issuing Authority re-examined the permits on our request, they realized that both “LaoPDR” and “Vietnam” were listed in the address. Clearly the cargo was destined for Lao PDR, not Viet Nam. In retrospect, no
exports to Lao PDR from South Africa had ever occurred until then and the country was possibly an improbable destination
to the official concerned. In addition, air cargo flies to “Vientiane”, the capital city of Lao PDR – which sounds similar to “VietNam”. It is thus also likely that some of the other initial exports were incorrectly recorded as Viet Nam instead of Lao PDR.

8

Bones of Contention: An assessment of the South African trade in African Lion bones

Keosavang (EIA, 2014b; Rademeyer, 2012a; U.S. Department of State, 2013). Paksane is on the Mekong Riverbordering Thailand and two hours drive from the Laotian capital of Vientiane (see Map 2). Keosavang and/or the
Xaysavang Company have been repeatedly associated with exports of Lion bones to Lao PDR (Source: EIA, 2014b;
National Assembly, 2011d; Rademeyer, 2012a; U.S. Department of State, 2013; anonymous personal communications
accumulated between January and July 2013) – starting in or before 2008. In 2013, the U.S. Department of State (2013)
offered a reward of up to USD1 million for information leading to the dismantling of the Xaysavang Network.
The Xaysavang Company was not only trading in Lion bones however (U.S. Department of State, 2013). Evidence
linking the Lion bone trade to that of rhino horn trade emerged when, seven days after Thongphai and Chunchom were
repatriated, police arrested Chumlong Lemtongthai, the leader of an alleged Thai rhino poaching syndicate, at the same
Edenvale residence on 9 July 2011 (Du Plessis, 2011c; Macleod, 2011; Rademeyer, 2012a; South African Revenue
Service, 2011). During Lemtongthai’s court appearance days later it emerged that he was arrested after a Thai Airways
employee allegedly working with the syndicate for more than three years decided to inform authorities of the
syndicate’s activities, including that a Free State game farmer would source rhinos and inform Lemtongthai of thenumber of animals that were in place to hunt (Fuller, 2013; Macleod, 2011; Rademeyer, 2012a; Smillie, 2011).
Lemtongthai would then contact Chunchom to source the “hunters”, and Chunchom would recruit Thai sex workers to“hunt” and pose with the dead rhinos (Macleod, 2011; Rademeyer, 2012a; Smillie, 2011). Hence, Lemtongthai and
Chunchom were part of the same Edenvale-based Asian syndicate and working for Xaysavang (du Plessis, 2011c;
Rademeyer, 2012a; Smillie, 2011). Details of the activities of Lemtongthai and the Free State game farmer with respect
to the rhino horn trade and factors driving the escalating rhino horn trade are covered extensively by Julian
Rademeyer’s 2012 book “Killing for Profit” (information on the Lion bone trade is also reported therein) (Rademeyer,
2012a) and TRAFFIC’s 2012 report on the rhino horn trade (Milliken and Shaw, 2012). Noteworthy, however, is thelink of the Lion bone trade to some of the key people proven in court to be involved in the illicit trade in rhino horns.
It is curious to note that, despite the connections of Lemtongthai to the Lao-based wildlife export company, the only
two known legal exports of rhino horns to Lao PDR occurred in 2010 and 2011 when four and eight rhino horns
respectively were exported there (UNEP-WCMC CITES trade database, accessed June 2013). Instead, the majority ofexported rhino horn was destined for Viet Nam. The number of Vietnamese hunters and the number of rhino horns
exported to Viet Nam had been on the rise since 2003, but the numbers began escalating in 2006 (see Figures 14 & 16
and Table 9 in Milliken and Shaw 2012; also Figure 2 and Table 5 in this report), and especially from 2009 (UNEPWCMC CITES trade database; Milliken and Shaw, 2012). Disturbingly, incidents of rhino poaching took a turn for theworse in South Africa in 2008 when the number of rhinos killed rose to 83; in 2009 the number killed increased to 122,and by 2011 448 rhinos were killed in one year (Figure 2). Previously the national average for 2003–2007 was 20
rhinos per year (from Figure 21 in Milliken and Shaw, 2012).

Figure 2 (a) The number of rhinos killed in South Africa, (b) the number of rhino horns exported to Viet Namfrom South Africa, and (c) the combined number of Lion skeletons listed on permits issued for export to China,
Lao PDR, Thailand and Viet Nam from South Africa. Vertical lines indicate years that measures were adopted toprotect Tigers and Asian big cats. [Sources: Rhino data obtained from Figure 21 & Table 9 in Milliken and Shaw(2012). Lion data from this report]
Bones of Contention: An assessment of the South African trade in African Lion bones

9

Punpitak Chunchom was rearrested with another Thai national at OR Tambo airport on 4 November 2011 after reentering the country using a passport in which his first name had been changed (du Plessis, 2011d). It was suspectedthat Chunchom had returned to “engage in illicit activities” and to buy Lion bones from South African game farmers toexport to Southeast and East Asia – but this time he was also accused of running the rhino horn smuggling syndicate
with Lemtongthai (du Plessis, 2011b,e; Mail & Guardian, 2011). When the case came to trial a year later, Chunchom
had his case joined with that of Lemtongthai and the Free State game farmer. Lemtongthai was eventually sentenced to
40 years in jail in November 2012 for charges relating to illegal rhino hunting and horn exports. The charges against his
co-accused, including Chunchom, were dropped in exchange for Lemtonghthat’s guilty plea. Less than a month later
however, new charges of illegal hunting were laid against Lemtongthai, Chunchom and the Free State farmer – but
Chunchom had skipped the country on a false passport on 10 November 2012. A warrant for Chunchom’s arrest wasissued, but he remains a fugitive and is listed on INTERPOL as a wanted person.4 Lemtongthai appealed his 40-year
sentence in 2013 and had it reduced to 30 years5; in September 2014 he appealed the sentence again and had it reduced
to 13 years.6
In the court judgement from the 2014 appeal6, the following admissions made by Lemtongthai to authorities in 2012 inconnection with the Lion bone trade were published: (1) Vixay Keosavang is the director of Xaysavang Trading ExportImport company in Bolikhamxay Province, Thailand; (2) the company deals in the trade of rhino horn and Lion bones,
teeth and claws; (3) Lemtongthai is a director of the company and was sent to South Africa by “Mr Qua Savang” (MrKeosavang) to enquire about the purchase of Lion bones; (4) on Lemtonghtai’s arrival in South Africa he saw various
advertisements of the hunting of the big five, including rhino; and (5) Keosavang said that he would fund any trade inrhino horn. It was also reported that Lemtonghtai wanted to buy 300 sets of Lion bones (Fuller, 2013; Rademeyer,
2012b). The admissions made by Lemtongthai, Chunchom and Thongphai to the police during their 2011–2012 trials
indicate that Xaysavang’s involvement in the Lion bone trade precedes their involvement in the rhino horn trade, i.e.
from at least 2008 or earlier, and that the company might have been one of the first to procure Lion bones from South
Africa. This is deduced from their admissions that representatives from the Xaysavang Export-Import Company had
visited South Africa to source Lion bones from game farmers – ostensibly at the invitation of South African farmers.
Since the first known exports of Lion bones to Lao PDR took place in early 2008 (see text for Table 8), representatives
from Xaysavang must surely have visited South Africa in 2007 or earlier to reconnoitre a source for the bones.
While exports of rhino horn had risen from 2006, it was the surge in rhino poaching incidents that is notable from 2008
(Figure 2). Was this increase in poaching related to the activities of Xaysavang in South Africa around that time?
Xaysavang’s involvement in the worsening of the rhino horn trade is hard to refute given their admissions and the court
evidence presented against the company and Lemtongthai. However, we have no evidence regarding the year that
Xaysavang representatives actually first visited South Africa and established ties to South African Lion breeders –hence their involvement in the increased exports of rhino horns to Southeast Asia c.2006/2007 cannot be demonstrated.
If further information one day becomes available that establishes that Xaysavang was procuring Lion bones illegallyc.2006/2007, then their answerability for the increase in rhino horn exports for that period could be interrogated. Basedon the available evidence, however, only rhino poaching and the issuing of permits to export Lion skeletons can becoincided at this time (Figure 2). After Lemtongthai’s arrest in July 2011, Macleod (2011) reported (presumably
quoting the forensic investigator Paul O’Sullivan) that “Before it moved into rhino poaching in South Africa thecompany traded in large quantities of lion carcasses and bones supplied by breeders in the North West and Free
State”. One wonders, therefore, if, when and how many Lion carcasses were illegally exported before 2008?
If the illicit trade in rhino horn worsened after the commencement of the Lion bone trade, then is the trade in Tiger
bones similarly intricately linked to Lions? Furthermore, if, in addition to economic growth in Asia and the demand for
Tiger products, the trade in Lion bones was inadvertently initiated by the measures adopted to protect Tigers, does thismean that the Tiger conservation crisis inadvertently set off a chain reaction of interlinking and unexpected events withsome unforeseen consequences for another species on a different continent? It is an issue worth debating.

4 http://www.interpol.int/notice/search/wanted/2013-33085.

“Punpitak Chunchom” is listed on the INTERPOL website as
being wanted by the South African judicial authorities for prosecution/to serve a sentence in connection with dealing inrhino horns.
5 Lemthongthai v S (A82/2013) [2013] ZAGPJHC 294 (30 August 2013) (http://www.saflii.org/za/cases/ZAGPJHC/2013/294.pdf)
6 Lemthongthai v S (849/2013) [2014] ZASCA 131 (25 September 2014) (http://www.saflii.org/za/cases/ZASCA/2014/131.pdf)

10

Bones of Contention: An assessment of the South African trade in African Lion bones

RESEARCH AIMS AND KEY ACTIVITIESIn light of concerns for the emerging trade in Africa Lion bones as a substitute for Tiger bones in Chinese and Southeast
Asian markets, the aim of the research was to assess the South African trade in African Lion bones and other bodyparts, and to:
1.
2.
3.

Examine the extent to which Lion bones were available through legitimate and illegitimate sources within
South Africa;
Determine the source of the bones and parts (such as wild or captive bred); and,
Assess the potential impacts on South African wild Lion populations.

Key activities that needed to be undertaken:
1.
2.
3.

Review and summarize scientific and grey literature containing reference to the Lion bone trade (but also
summarising where possible trade in other Lion parts) and documenting linkages to the Tiger bone trade.
Compile and analyse South African government data, industry trade statistics, and field research data (forinstance government conservation agencies, private landowners etc.) on the scale and frequency of legal andillegal bone trade within South Africa.
Develop interim research recommendations resulting in a publishable research report.

© ANDREW J. LOVERIDGE

Bones of Contention: An assessment of the South African trade in African Lion bones

11

METHODS
Starting in January 2013, the research was conducted over five months in three phases: (1) the literature survey, (2) acompilation of South African government data and industry trade statistics, and (3) semi-structured and telephonicinterviews with public and private sector stakeholders. The draft report was written and edited over two months andreviewed from August 2013 to August 2014. Except where specified, most quantitative trade data are correct to mid2013.

LITERATURE SURVEY AND DATA COLLECTION
A comprehensive literature and database search was conducted to collect as much information as possible on any
historical and current issues relevant to Tiger and Lion conservation, population size (captive and wild), anatomy andmorphometrics (Appendix 4), legislation, the captive breeding and hunting industries, the legal and illegal trade in large
cat products and bones, trade flows, the value of the bones and derivatives, the impacts of hunting on populations, andthe South African traditional medicine trade. One goal was to crosscheck all information and trace it back to a verifiable
and original primary source, where possible, rather than relying on secondary and tertiary accounts for the information.
Sources of information include: articles in peer-reviewed and non-peer-reviewed journals and books; online media sites
for newspapers and magazines across the world (e.g. http://www.lexisnexis.com); documents from South African
government websites (national and provincial, e.g. National Department of Environmental Affairs [DEA,
http://www.environment.gov.za)], South African National Parks [SANPARKS]); a variety of reports and resourcesfrom inter-governmental organizations such as CITES, INTERPOL, IUCN and others; conservation NGO reports
including from TRAFFIC and WWF; professional hunter websites (e.g. PHASA, African Indaba); informal blogs andopinion pages; anti-poaching groups; university websites; and many others. More than 300 different websites wereconsulted in total. Trade data on legal exports of Lions and Tigers were obtained from the UNEP-WCMC CITES trade
database. In addition to online sources, DEA and the South African CITES Scientific Authority made valuable
unpublished data and reports available on request.
Regarding nominal information, the only names mentioned in this report were for persons: (1) who were arrested,
prosecuted and convicted in South Africa, and their names are recorded in court documents; (2) whose names were
published in publically available South African government documents that can be downloaded from the appropriate
websites; and (3) wanted by INTERPOL and/or the U.S. State Department.
Once the baseline literature survey was completed, the information was synthesized to assess what was known and thegaps in the information. Based on this synthesis, a list of potential people and organizations to be interviewed was
drawn up and a wish list of questions they could be asked was compiled.

INTERVIEWS
Semi-structured interviews were conducted from April to July 2013 with representatives from various government
departments, non-government organizations and people from the private sector. The interviews were semi-structured inthat the list of questions was used as a guide during the discussions. Most interviews were electronically recorded withthe prior consent of the interviewees. The interview recordings, totalling more than 15 hours, were later transcribedverbatim. Where necessary, email and telephonic follow-ups were made to obtain clarity on any matters that required it.
Interviewees included: provincial nature conservation and/or law enforcement officers from the Free State,
Mpumalanga, Northern Cape, Eastern Cape and North West (time constraints prevented interviews with remaining
provinces); the NSPCA (National Society for the Prevention of Cruelty to Animals); PHASA (Professional Hunters
Association of South Africa); SAPBA (South African Predator Breeders Association); various representatives fromSARS (South African Revenue Services); SAPS (South African Police Service), the Endangered Wildlife Trust, andother persons who requested to remain anonymous.

12

Bones of Contention: An assessment of the South African trade in African Lion bones

LION POPULATION IN SOUTH
AFRICAOVERVIEW
Globally, the free-ranging Lion population (including the Asiatic Lion Panthera leo ssp. persica) is estimated to be<20,000 animals across 26 range States (Bauer et al., 2015). According to the most recent global IUCN Red List
Assessment, Lions are Vulnerable (VU A2abcd), having declined approximately 42% over the last 21 years (Bauer etal., 2015). The South African Lion population, however, has not declined and the species is not currently threatened. In
2004 the population was assessed nationally as Vulnerable (VU D1) because there were estimated to be <1000 freeranging mature breeding individuals (Friedmann and Daly, 2004). The status of the South African population will,
however, be downgraded to Least Concern on the national Red List in preparation (Bauer et al., 2015).
Worldwide, one of the biggest threats to the species has been habitat loss, which has reduced the Lion’s range by 75%
in the past 100 years (Riggio et al., 2013). Further threats to Lions include: human-Lion conflicts; prey-based
depletions; a poorly regulated sport hunting industry; and inbreeding (Funston and Miller, 2013; Macdonald and Willis,
2013; Packer et al., 2013). The trade in Lion bones is a potentially “looming” threat (Funston and Miller, 2013), andthe impact on wild populations in South Africa is addressed later in this report.

WILD LION POPULATION IN SOUTH AFRICA
The southern African Lion population is ≈35% of the global population (derived from Riggio et al., 2013), mainly
living in protected areas like the Kruger National Park. Various figures have been cited for the size of the wild/freeroaming population in South Africa, but 2013 estimates by the CITES Scientific Authority (2013) were 2743 Lions.
Introductions and reintroductions of Lions into State- and privately-owned reserves across South Africa haveaugmented the population numbers over the years. While the number of Lions within State-owned reserves in mostprovinces has remained stable, the population in KwaZulu-Natal increased three-fold over a seven year period (2004–2010) due to recent reintroductions to both State- and privately-owned reserves (CITES Scientific Authority, 2013).
There have also been (re-)introductions of Lions within other provinces in the last decade that have similarly increased
population numbers across the region. The Free State is the only province not to have any free-roaming Lions(Appendix 3, Table A11).
Lions reintroduced into South African reserves come from three founder populations: the Greater Kruger ecosystem(the Kruger National Park and surrounding areas), the Kgalagadi Transfrontier Park and surrounding areas, and theEtosha National Park in Namibia (Slotow and Hunter, 2009; Hunter et al., 2012). Secondary populations have been
established by translocating Lions from the smaller, newly restored populations (Hunter et al., 2012), for example theBones of Contention: An assessment of the South African trade in African Lion bones

13

Lions introduced into Mountain Zebra National Park in April 2013 are from the Karoo National Park and theWelgevonden Game Reserve. Hence in South Africa, the Lions from Kruger and Kgalagadi are the only naturally
occurring “wild” populations. In all other areas, free-roaming Lions were locally extirpated as a result of hunting andchanges in land use (mostly to farming) by the mid-20th century (CITES Scientific Authority, 2013). In the 1990s, there
was a change in land-use patterns and a growth in the establishment of private game reserves accompanied by theprivate ownership of game animals. Lions were not only reintroduced into private reserves, but also State-, Statecommunity and State-private owned reserves (Slotow and Hunter, 2009) in all provinces except the Free State and, until
recently, Gauteng.

Africa Lions at Nyamandlovu in Hwange National Park, Zimbabwe.

© JEALOUS MPOFU, PAINTED DOG CONSERVATION, HWANGECAPTIVE LION POPULATION IN SOUTH AFRICA
In addition to Lions occurring within protected areas, the majority of South African Lions are in captivity and thenumbers of animals and breeding facilities have increased since 2005 (Figures 3 & 4). The number of facilities,
however, dropped to 149 in 2013 from the highs of 167–200 between 2008 and 2012. The biggest drop in the number ofbreeding facilities has been in the Free State, where levels reached 98–107 in 2008–2009 but were 70 in 2013 (Cadman
2009; Taljaard 2009; W. Boing, pers. comm., May 2013). Reasons for this drop include the strengthening of regulations
within the province that have made it difficult for some breeders to comply with legislation and they have thus closed
down the facilities or moved them to the North West province (Provincial Gazette [Free State Province] No. 119 of
2012; W. Boing, pers. comm., May 2013).
Most Lions in captivity originate from captive-bred stock that “services” the trophy hunting industry and, since 2008,
the Lion bone trade, as: (1) a source of male Lions for trophy hunters, the skeletons of which are sold to East–Southeast
Asia; and, (2) the females for breeding stock and purportedly the bone trade once they have ceased to be bred. In termsof South Africa’s TOPS (Threatened Or Protected Species) regulations, wild Lions should not be introduced into
captivity – but illegal incidences of adult Lions and cubs being brought into South Africa from the Kgalagadi have been
confirmed (CITES Scientific Authority, 2013; Macleod, 2012a; W. Willson, pers. comm., May 2013).

14

Bones of Contention: An assessment of the South African trade in African Lion bones

Figure 3 Estimated number of Lions in captive facilities in South Africa. Ex situ estimates for 2013 only (seedefinition in Box 1). (Sources: Cadman, 2009; CITES Scientific Authority, 2013; National Assembly, 2009a,b;
Pickover, 2005; Taljaard, 2009; Anon., pers. comm., 2013)

Figure 4 Number of captive breeding facilities in South Africa; data for estimates in 2012 may have beencollected in 2011. (Sources: Cadman, 2009; CITES Scientific Authority, 2013; Macleod, 2012b; Pickover, 2005;
Taljaard, 2009; K. Marnewick and W. Boing, pers. comm., May 2013)
Captive Lion stocks have occasionally been introduced into fenced reserves and erroneously called “wild”. Even moreerroneous, until corrected in early 2012, was the practice by some provincial permit Issuing Authorities of reporting
captive bred Lions hunted for trophies as “wild sourced” on the CITES export permits. This practice led to incorrect
reporting of the CITES trade records (CITES Scientific Authority, 2013) and was related to the regulation that Lionsmust be free-roaming for a specified period before they can be shot (hence, no differentiation is made between “wild”
and “captive” sourced lion derivatives in the trade analyses presented later in this report). However, “free-roaming”

Bones of Contention: An assessment of the South African trade in African Lion bones

15

does not equate to “wild”, and Lions are not transformed into self-supporting wild animals after 96 hours in a hunting
camp (the minimum release period before hunting can occur in the North West Province, for example. See Table 3 for aprovincial comparison of the release periods).
The prevailing view amongst carnivore specialists is that captive-bred Lions do not contribute to the conservation of thespecies, especially for population restoration purposes, since inbreeding is known to occur and thus compromises
genetic integrity and provenance (Slotow and Hunter, 2009; Hunter et al., 2012; CITES Scientific Authority, 2013;
Packer et al., 2013). Lion trophy hunting generates more revenue annually than any other hunted mammals (see Figure11). Accordingly, economic outputs from the captive-bred Lion industry are assumed to have increased significantly(Lindsey et al., 2012a) as exports of products have increased. However, Lion breeding is regarded by many as acontroversial “conservation” tool that purportedly reduces consumptive impacts on wild Lions through the targeting of
captive-bred animals in the trophy hunting industry (CITES Scientific Authority, 2013; Lindsey et al., 2012a;
Macdonald and Willis, 2013).
Most hunting (>95%) takes place on private property in the North West, Free State and Eastern Cape provinces using
captive bred Lions (CITES Scientific Authority, 2013) – areas not normally associated with free-roaming Lions.
Hunting of wild Lions on private properties in Limpopo, Mpumalanga and KwaZulu-Natal is limited, with less than 5%of all successful Lion hunts conducted in South Africa from 2008 to 2010 targeting wild Lions (CITES Scientific
Authority, 2013). Lindsey et al. (2012a) reported that 0.9% and 1.1% of Lions hunted in 2009 and 2010 respectively
were wild/free-roaming). Since wild Lions in small fenced reserves are an important source of non-consumptive
revenue for the tourism industry (e.g. phototourism), especially Limpopo and Mpumalanga, there is no real benefit tohunting wild Lions except as the occasional source of revenue to contribute to the maintenance of areas where these
Lion populations can continue to exist (CITES Scientific Authority, 2013).
Another segment of the South African captive Lion population are animals kept in ex situ facilities (e.g. sanctuaries,
zoos, Lion parks) where roaming is restricted and there is a high level of human contact. For the most part thesefacilities are marketed as tourist attractions. Animals at these facilities: (1) may have been rescued from zoos, the“canned” hunting industry, or other circumstances; (2) may have been born in the wild or in captivity; (3) may or may
not be sterilised; and, (4) may or may not be kept for breeding purposes. For reasons indicated in Box 1, this reporttreats animals in ex situ and captive-breeding facilities separately.

Africa Lion in the Johannesburg Zoo.

© VIVIENNE L. WILLIAMS

The following statement made by Buti Mathebula (Chief Director Free State Environment and Conservation) sums up
one controversial view on the status of captive Lions: “In the Free State, lions bred in captivity are kept for the purposeof trophy hunting. Bones which aren’t used are removed as waste products. Lions in the Free State are not of any value

16

Bones of Contention: An assessment of the South African trade in African Lion bones

to us from an environmental point of view…if someone wants to hunt lions in the Free State, that’s fine. We don’t wantthese lions here. We’re better off without lions in the Free State. There are problems with fences. If they escape, they
kill people” (Smith, 2009).

2013 ESTIMATES OF THE SOUTH AFRICAN LION POPULATION
Lion population numbers for 2013 are updated in this report using information from published and unpublished sources,
information provided by the provinces, personal communications and a non-exhaustive internet search for facilities thatkeep Lions. The population estimates are divided into five categories and summarized for each province. Appendix 3
gives a detailed account of the population per province, whereas Figures 5–7 and Box 2 summarize Appendix 3. The
categories are:
1.
2.
3.
4.
5.

Number of wild and secondary-wild Lions protected within South African National Parks (SANParks);
Number of secondary wild and introduced Lions protected within State-owned provincial game reserves;
Number of Lions of varying genetic origins that are managed in private mainly small, fenced reserves;
Number of Lions in ex situ facilities (i.e. Lions not kept/bred for consumptive purposes);
Number of captive-bred Lions.

The genetic origins of Lions in reserves, where they were born (in captive-breeding facilities or not) and the conditions
under which they were raised beyond adulthood (captive or free-roaming), are important to the classification of what istruly wild, free-roaming and captive. South Africa is unique in terms of the large size of its captive-bred Lion
population, the number of Lions that are privately owned, and the number of (re-)introductions. Lions of different
genetic origins are regularly translocated across the country and owning them has become a big business – both for
hunting and as tourist attractions. The proliferation of consumptive and non-consumptive breeding operations seems tohave fostered ambiguities regarding the definitions of Lions that are “wild”, “free-roaming”, “captive”, and “canned”
and these terms are explained in Box 1 and throughout the report. A further note is that other free-roaming Lions inprivate reserves have not necessarily originated from founder and secondary populations, and broader-level
conservation genetics may not be a consideration in their management.

Figure 5 The number of Lions per province (See Map 2 for abbreviations for the provinces). [Note: the numberof Lions in SANParks in LP is shared with MP]

Bones of Contention: An assessment of the South African trade in African Lion bones

17

Figure 6 The proportion of Lions from different reserves types and facilities per province (See Map 2 forabbreviations for the provinces)

Figure 7 2013 estimates for the number and proportion of Lions in South Africa

18

Bones of Contention: An assessment of the South African trade in African Lion bones

Bones of Contention: An assessment of the South African trade in African Lion bones

19

LEGISLATIONOVERVIEWSouth Africa has a well-developed legal framework for the conservation, regulation and sustainable use of its
biodiversity (http://www.sanbi.org). The legislation includes NEMBA (National Environmental Management andBiodiversity Act, No. 10 of 2004) and various provincial nature conservation ordinances used by nine provinces forprotecting wildlife and regulating the trade thereof. However, implementation complexities and inconsistencies
resulting from the provincial legislation (most of which pre-date 1994) have raised concerns that there are loopholes forillicit activities (Bürgener et al., 2001; Milliken and Shaw, 2012) and thus present compliance challenges.
Instead of a detailed analysis of all the regulatory mechanisms applicable to Lion conservation, breeding, hunting andtrade administered by government departments and agencies such as the Department of Environmental Affairs (DEA)
and the Department of Agriculture, Forestry and Fisheries (DAFF), we present a broad overview of the legislation as ispertinent to Lions. Milliken and Shaw’s (2012) comprehensive review of South Africa’s biodiversity policies (mainly
applicable to the rhino horn trade) is worth consulting to gain a broader awareness of the issues concerning national andprovincial legislation.
There are several legislative regulatory mechanisms applicable to all activities involving Lions (CITES Scientific
Authority, 2013), namely:
1.
2.
3.
4.

The South African National Environmental Management and Biodiversity Act (Act No. 10 of 2004) (NEMBA).
Since Lions are Vulnerable in terms of NEMBA, the permit system is further regulated through Section 56(1)of NEMBA, namely TOPS (Threatened or Protected Species Regulations of 2007),
Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES),
The various provincial nature conservation ordinances and acts,
The National Environmental Management: Protected Areas Act (No. 57 of 2003).

In addition, South Africa is a signatory to two other regulatory conservation instruments:
5.
6.

The Convention on Biological Diversity (CBD),The SADC Protocol on Wildlife Conservation and Law Enforcement.

1. NEMBA and TOPS
Because Lions are vulnerable in terms of NEMBA, a permit (regulated through TOPS) is required with respect to sevenactivities involving Lions ranging from the breeding and hunting of animals to the export of the bodies and parts
thereof. In order to be issued with a provincial hunting permit in the past, for example, most provinces only required ahunter to get written permission from a landowner and a hunting licence. From 2008 the provincial permit became anational permit in accordance with NEMBA and TOPS. The specific NEMBA regulations pertinent to Lions are notlisted in this report, but the following is a summary of the legislation by the CITES Scientific Authority (2013):“A permit is required in terms of NEMBA if a person intends to carry out any restricted activity involving lion; whether
live or dead; whether dead specimens involve the whole animal or any part thereof; and whether dead specimens are
fresh, preserved or processed. These restricted activities include keeping, hunting, catching, breeding, selling,
conveying or exporting from the country. The permit system is regulated through the Threatened Or Protected Species(TOPS) regulations (2007), which have been promulgated in terms of NEMBA. The TOPS regulations also require thecompulsory registration of a person who intends to operate a captive breeding facility, commercial exhibition facility(zoo), sanctuary or rehabilitation facility, or operate as a wildlife trader, involving lion.”
The goal of the TOPS regulations is to “provide a national standard for the utilisation of named threatened orprotected species in both owned and wild populations across South Africa” and to provide “additional protection inprovinces where legislation is not adequate” (Cousins et al., 2010). Guidelines for the implementation andinterpretation of TOPS state, for example, that: (a) TOPS regulations do not replace or repeal any provincial
legislation, but apply in addition to it; (b) a person may not carry out any restricted activity as it applies to TOPS
specimens without a TOPS permit; (c) provincial conservation authorities may apply stricter measures than required interms of the TOPS regulations, but not less strict measures. All permits (including CITES permits) for Lions are“integrated permits” (except Mpumalanga and the Western Cape, which don’t implement TOPS); colloquially put, thismeans “if the provincial ordinance and TOPS speaks to NEMBA, then it’s an integrated permit” (quote from an
20

Bones of Contention: An assessment of the South African trade in African Lion bonesinterviewee, May 2013). The formal description of an integrated permit written in TOPS regulations (Section 92 of
NEMBA and TOPS Regulation 4) is:

If a permit is required for a restricted activity in terms of both provincial legislation …… and the TOPS
regulations, the issuing authority may issue one permit only, which is referred to as an integrated permit.
The integrated permit may be issued on the format of the provincial permit or on the format of the TOPS
permit.
If the issuing authority issues the integrated permit on the format of the provincial permit, the provincial
permit can be regarded as a TOPS permit only if:
o The relevant provisions of the TOPS regulations and the provincial legislation have been complied
with; ando The permit contains all the compulsory information required in terms of the TOPS regulations andspecifies the authority that has issued the permit.

2. CITESCITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora) is an international cooperation agreement between governments that aims, through a system of trade prohibitions and reciprocal permits andcertificates, to ensure that international trade in wild animals and plants does not threaten their survival (AbenspergTraun, 2009; http://www.cites.org). All import, export and re-export of species covered by the Convention has to beauthorized through a licencing system (http://www.cites.org), and the Appendix in which a species is listed informs therequirement for import/export permits. The permits are issued through the Management Authority of the country.
Asiatic Lions, like Tigers, are listed in Appendix I of CITES, and trade in specimens of these species is only permitted
in exceptional circumstances. African Lions are listed in Appendix II – i.e. a species that is not necessarily threatenedwith extinction, but trade must be controlled in order to avoid utilization that is incompatible with their survival(http://www.cites.org, retrieved June 2013). In terms of the regulations, export/re-export permits are mandatory for
African Lions, but import permits are not needed unless a country requires one as part of their stricter domestic
measures.
CITES permits issued in South Africa for exports of live Lions and their derived parts and products are “TOPS
integrated permits” and resemble the sample document in Figure 8. The permits are issued by the Management/Issuing
Authority of the country (generally by the provincial permit issuing official) and consist of four duplicate pages. The
Issuing Authority of the province keeps a copy of Page four of the permit. The quantity recorded on the permit (Item 11
in Figure 8) indicates the quantity that the exporter intends to export to the importing country. Item 14 on the permit(“export endorsement”), however, is to be completed by the official who inspects the shipment at the time of export/reexport. The quantities actually exported/re-exported are to be entered here – and thus verify the quantities listed when
the permits were issued. The official who inspects the shipment is meant to return the third page of the permit to theIssuing Authority, which should thereby enable the total quantity of Lion parts and products exported annually to becompiled. However, one person interviewed for this study said that the third page of the permit is not always returned to
the Issuing Authority and therefore a complete tally of exports is rarely compiled (Anon., pers. comm., July 2013).
Thus, information on exports of CITES-listed species is based on the quantities obtained from the permits issued andnot the quantities actually exported.

3. Provincial acts and ordinances
A tier of complexity is added to the management and trade of Lions (and Tigers, see later in the report) by theindividual provincial acts and ordinances. Each of the nine provinces have regulations that require compliance inaddition to NEMBA, TOPS and CITES. Some provinces use the same ordinances that pre-date 1994 when provincial
boundaries were changed and the number of provinces increased from four to nine (e.g. Eastern, Western and Northern
Cape use the old Cape Nature Conservation Ordinance No. 19 of 1974) (Table 3). The North West Province, which
straddles parts of what were the old Transvaal and Cape Provinces, uses a combination of three old ordinances (Table 3)– and this presents opportunities for transgressions and non-compliance if the Acts have contrary provisions withregards to certain activities. Only Limpopo and Mpumalanga Provinces have promulgated new nature
conservation/environmental management Acts since 1994. According to a summary by the CITES Scientific Authority(2013) on Lions:“Lion is also protected under various provincial ordinances/acts, and provincial conservation authorities often require
ecological management plans when lion is introduced to a property. Utilisation and keeping of lion in the wild is
closely managed in the province of Gauteng due to the dense human population in the province. In the Northern Cape,lion populations are well contained with electrical fencing. Provincial legislation in Mpumalanga regulates the killingof damage causing lions. In all provinces, most lion hunts are attended and monitored by conservation officials.
The Northern Cape Department of Environment and Nature Conservation has adopted a policy for large predators that
ensures Lions (and other large predators) are introduced to areas that are sufficiently large enough to support self-

Bones of Contention: An assessment of the South African trade in African Lion bones

21

sustaining prey populations and a viable group of the predator concerned. Although Lions may still be hunted in theseareas, the animals are free roaming on the property and can interact with other sex and age classes.”

Figure 8 Sample CITES permit issued in South Africa when persons apply to export live Lions, body parts andderivatives. The Management Authority is required to compile an annual report on the CITES permits issued by
the provinces, and then submit this trade report to the CITES Secretariat. The CITES trade database, managed by
UNEP-WCMC, holds all the national records of trade of CITES-listed species. The annual national reports
compiled by DEA for South Africa from 2006–2011, and the data from the UNEP-WCMC CITES trade databasefrom 1975–2011, were used in this report to analyse all trade in Lion products from South Africa
22

Bones of Contention: An assessment of the South African trade in African Lion bones

Table 3 Provincial comparisons concerning the conditions to which a landowner must adhere apropos keeping
and hunting large predators. TOPS integrated permits are required in addition to the provincial ordinancepermits
Province

NW

FS

Releaseperiodbefore dateof hunt
4
days

Minimum area of
hunting campand no. Lions per
camp
Not stipulated,
however a
respondent said
it is >400 ha(Anon., pers.
comm., May
2013)

Waiting
period for
permitOrdinance used, in
conjunction with NEMBA

Notes from interviews and legislation:≈10 days

1) Transvaal Nature

1) TOPS integrated permits apply2) Hunter requires written consent from thelandowner
3) Records of up to 6 Lions hunted a day on thesame farm4) No published policies on activities regarding
Lions by landowners and trophy hunters in the
NW; this policy is being developed by SAPBA

≥30
days

≥1000 ha;?

≤10 Lionsallowed to bereleased per1000 ha at atime;

Conservation Ordinance
12 of 1983
2) Bophuthatswana
Nature Conservation Act
3 of 1973
3) Cape Nature
Conservation Ordinance
19 of 1974

Free State Nature
Conservation Ordinance
8 of 1969≤10 Lionsallowed in a 1000
ha camp1) TOPS integrated permits apply
2) Lions must be micro-chipped or else no
permits are issued
3) Officials must be present during the hunt4) Permits only issued by a permit evaluationcommittee
5) Permits require several signatures
6) Lion may not be released in an area adjacent
to a holding facility for other Lions7) Lions released into a hunting camp may be fed
domestic animals
8) Fences of hunting camps must meet approved
specifications
7) Landowner or owner of the Lion skeleton must

acquire a permit to keep, sell, transport or export
the skeletonEC

6 months

2000 ha per Lion;
adult Lions only

≈30 days

Cape Nature
Conservation Ordinance
19 of 1974
NC

1) TOPS integrated permit2) Hunter requires written consent from thelandowner
3) Regulations for fence height and size ofproperty to release Lions determined “later”
4) Lions are micro-chipped
5) Applications for permits received in any of the
6 regional offices have to go to Head Office to bechecked and signed before the permit is issued
1) TOPS integrated permit

?

?

WC
LP

Unofficial
source says
up to oneyear?
24 months?
?

?
≈30 days

MP

?

?

?

KZN

?

?

?

GT

Currently not applicable, but trophy hunting may be allowed once new populations are established(CITES Scientific Authority, 2013)

Limpopo Environmental
Management Act 7 of2003
Mpumalanga Nature
Conservation Act 10 of1998
KwaZulu Nature
Conservation Act 29 of
1992

1) Not implementing TOPS
1) TOPS integrated permits apply
2) Lions may not be hunted within 24 months
after introduction onto the property
Not implementing TOPSTOPS integrated permit* For captive breeding, the Free State requires a minimum of one ha per two Lions. One person interviewed “thinks” that NW
keeps up to 20 or 30 Lions per hectare (Anon., pers. comm., May 2013)

Some of the differences in the South African provincial ordinances and Acts as they apply to Lion hunting aresummarized in Table 3. One of the biggest differences is the release period prior to hunting. In the North West, trophy
hunters are allowed to hunt Lions four days after being released, whereas in the Eastern Cape the release period is six
months (Table 3). The minimum area of the hunting camp also varies between provinces with North West having no
Bones of Contention: An assessment of the South African trade in African Lion bones

23

stipulated area, but the Eastern Cape requiring there to be 2000 hectares (ha) per Lion. The strength of the provincial
hunting legislation, and the rigour with which it is enforced, has contributed to the extent to which Lion hunting occurs
within the provinces. In recent years, for example, the Free State has implemented and enforced regulations that havediscouraged Lion hunting. Not only have the number of Lion breeding facilities dropped in the province, but also thenumber of Lions hunted has declined (W. Boing, pers. comm., May 2013).

4. National Environmental Management: Protected Areas Act 57 of
2003
Under Section 17 of the Act, three of the 12 purposes for declaring an area as protected are: (1) to protect
representatives of all species naturally occurring in South Africa; (2) to protect South Africa’s threatened or rare
species; and (3) to provide for the sustainable use of natural and biological resources (including animals that are living
or dead or derivatives thereof). In terms of the Act, however, an “indigenous species” within a specific protected areameans a species that occurs, or historically occurred, in a naturally free state within the protected area, but excludes a
species introduced in that area as a result of human activity. Since the meaning of “human activity” is not defined in theAct, it is unclear whether the provisions of the Act apply to Lions that are introduced into a protected area that was notpart of its historical range. With regards to commercial activities within protected areas, the Act allows for theManagement Authority of a park to carry out or allow commercial activities aimed at raising revenue (Section 50).
Since Lion hunting is a commercial activity that raises revenue, the management authorities may authorize hunting
from time to time but subject to the management plan of the protected area concerned.

5. The Convention on Biological Diversity (CBD)The CBD is an international legally binding treaty with three main objectives that requires the signatories to develop
national strategies for the conservation and sustainable use of biological diversity (http://www.cbd.int, retrieved June2013). The implementation of CBD provisions and Decisions of the Conferences of the Parties to the CBD is up to (andvaries between) the individual CBD Parties. All Parties, including South Africa were thus obliged to prepare a NBSAP(National Biodiversity Strategy and Action Plan) to implement the objectives and targets the CBD (NBSAP, 2005).
South Africa’s NBSAP was completed in 2005 and its stated goal is to conserve and manage terrestrial and aquatic
biodiversity to ensure sustainable and equitable benefits to the people of South Africa, now and in the future. The
NBSAP not only satisfies South Africa’s obligations with respect to the CBD but also NEMBA (National
Environmental Management and Biodiversity Act), since Chapter 3 of the latter required a National Biodiversity
Framework to be developed – and the NBSAP was the first stage in the process of developing this Framework(NBSAP, 2005). Thus, while the CBD does not provide specific protection for Lions (Funston and Miller, 2013), thenational legislation does regulate for the management and trade of the species and therefore complies with the terms of
the Convention in order to diminish biodiversity loss. For those animals used for medicinal purposes7, the recently
agreed CBD Decision XI/25 on “Sustainable use of biodiversity”8 provides a framework to evaluate the role of animals
and their products used for medicine in national and local economies and cultures as well as the ecological services
provided by harvested species. In the appended Recommendations, the Decision guides towards the monitoring of
harvest, use and trade in an essential step towards conserving, managing and sustainably using wildlife resources.

6. The SADC Protocol on Wildlife Conservation and Law Enforcement
The 1999 Southern African Development Community (SADC) Protocol on Wildlife Conservation and Law Enforcement
applies to the conservation and sustainable use of wildlife resources, excluding forestry and fisheries. Eleven African
Lion range States have signed the Protocol including South Africa and its neighbouring countries (Funston and Miller,2013). The objectives of the Treaty, as summarized by Funston and Miller (2013) are:“a) To promote the sustainable use of wildlife; b) harmonise legal instruments governing wildlife use and conservation;c) enforce wildlife laws within, between and among state parties; d) facilitate the exchange of information concerning
wildlife management, utilisation and enforcement of wildlife laws; e) assist in the building of national and regional
capacity for wildlife management, conservation and enforcement of wildlife laws; f) promote the conservation of sharedwildlife resources through the establishment of transfrontier conservation areas; and g) facilitate community-based
natural resource management practices for management of wildlife resources.”

7 Note that the CBD’s Liaison Group on Bushmeat defines bushmeat (or wild meat) hunting as the “…harvesting of wild

animals…for food and for non-food purposes, including for medicinal use” (UNEP/CBD/LG-Bushmeat/2/4) (UNEP/CBD, 2011).
8 https://www.cbd.int/decision/cop/default.shtml?id=13186

24

Bones of Contention: An assessment of the South African trade in African Lion bones

The establishment of Transfrontier Parks as a means to promote the conservation of shared wildlife is especiallyrelevant to Lions. The Great Limpopo Transfrontier Park is in the process of being formed and will eventually include
the Kruger National Park and parks within Mozambique and Zimbabwe, but the management of a shared Lion
population in this region is not currently an issue. The Kgalagadi Transfrontier Park straddling South Africa and
Botswana has up to 600 Lions (the bulk of which are on the Botswana side) that can roam across the political boundaryline without the population being artificially fragmented by a fence. Reports of illegal translocations of Lion cubs fromthe Botswana side of the Kgalagadi in to the North West province is a conservation concern for the Transfrontier Park,and are briefly mentioned in the section of this report on the illegal trade.

Other legislation
Regulations by DAFF (specifically those involving the government veterinary service) pertaining to the export of felids
and their parts/derivatives were not thoroughly investigated due to time constraints. Most animals and products ofanimal origin leave South Africa under the cover of a veterinary certificate issued by the provincial State veterinarian
and/or national State veterinarians at the ports of exit (Department of Agriculture, 2008). These regulations thus apply
to: quarantine periods for live animals; export certification for live animals; and, export certification to verify the
preparation of products such as trophies and bones for export. One of the relevant regulations is the Animal Diseases
Act (No. 35 of 1984).
Another piece of legislation, also not investigated here, is the Customs Excise Act No. 91 of 1964, the provisions ofwhich address the storage, clearance, export and transit of goods through ports and airports. In terms of the Act, anofficer (a person employed on any duty relating to Customs and excise) may stop, detain and examine any goods they
deem to be suspect to determine whether the provisions of the Customs Act, or any other law, have been complied with.

Enforcement and compliance concerns
Various people raised numerous concerns about law enforcement and compliance during the interviews. The concerns
ranged from compliance with the acts and ordinances pertaining to the breeding and keeping of Lions, to Lion hunting,and ultimately the paper trail starting with the issuing of permits down to the final shipments of Lion bones destined for
East–Southeast Asia. These issues have not all been investigated and addressed in this report, but certain matters havebeen included for general awareness and discussion.
In one interview, the following concerns were voiced: “If the enforcement and the compliance was better, they would
have a better idea of who should have what and how many at what time…if you look at Limpopo, they only have four
compliance officers, three of which are on suspension. So you know what hope does he have? Even a simple thing likescanning the microchips at the airport or scanning the microchips on a lion farm is virtually impossible for someone
who doesn’t have a microchip reader and who is not allowed to get anywhere close to the lions…So right from the
beginning, from the very ground level, it’s so difficult to enforce and to control and to see who’s doing what and when
and with what lions. And now lions are a dime a dozen” (Anon., pers. comm., May 2013). The matter of microchipping Lions is addressed later.
The role of DAFF in enforcement and compliance has also not been fully investigated, and the concerns presented here
are from brief anecdotes mentioned during the interviews. Furthermore, no officials from DAFF were interviewed to
discuss the matters raised during the interviews by people concerned about the trade in Lion bones. Evidently, “DAFF
officials” working at the airport are required to check and verify export permits before shipments are released, butseveral people alleged that permits are not being adequately checked and suspect cargo with questionable permits are
sometimes being released for export (Anon., pers. comm., May 2013). Furthermore, concerns have been expressed over
the occurrence of fraudulent re-used permits (W. Willson, pers. comm., May 2013). It was also alleged that the main
focus of the new Customs system is to “facilitate trade” and to “get goods shipped out of the country” – and that thisapproach might work in favour of those who are deliberately non-compliant with the legislation.
DAFF recognizes that the veterinary certificates are sometimes forged (not specifically in connection with Lion bone
exports, but this is probably a widespread problem with all animal products). The problem statement of The South
African Policy on Export Certification for Animals and Animal Products (No. 1325, 12 December 2008) acknowledges
that: “Presently, South African veterinarians are issuing health certificates for export purposes. Occasionally, someconsignments are rejected, detained or destroyed in the importing countries because of non-conformance. In someinstances, certificates are forged and negotiated clauses are deleted…”. This matter of forged certificates and permits
should be investigated further.
Another person commented in an interview that: “People involved in organized crime are very aware of the loopholes
in the legislation and will even pay people to help them find the loopholes; people not involved in organized crime are

Bones of Contention: An assessment of the South African trade in African Lion bones

25

more likely to make mistakes and get caught for non-compliance” (Anon., pers. comm., May 2013). The prevailing
opinion of most people interviewed, however, is that Lion bone exports are likely to be legal – but since the illegal trade
is difficult to identify, and bones from captive Lions are indistinguishable from wild Lions, the extent and frequency of
the illicit trade is largely unknown. As a result, while the regulatory framework exists to ensure the legal trade andexport of Lion bones, there are flaws in the system – starting with Lion breeding – that creates multiple cumulative
opportunities for the exploitation of weaknesses in the legislation. Moreover, there is questionable provincial capacity
to monitor all aspects of the Lion trade and still contend with the monitoring of other TOPS listed species that are morethreatened, including rhinos and cycads.

26

Bones of Contention: An assessment of the South African trade in African Lion bones

LION HUNTING IN SOUTH AFRICA“CANNED” HUNTING, CAPTIVE LIONS & CONTROVERSIESFollowing on from the legislation is the matter of Lion hunting in South Africa, which has been the subject of extensive
judicial scrutiny – specifically with regards to “put and take animals”9. In May 2007, applicants from the South African
Predator Breeders Association took the Environment Minister to court over certain TOPS regulations that were to be
implemented from February 2008. They challenged the Minister on the inclusion of Lion on TOPS as a “listed large
predator” and specifically the regulation that captive bred animals could only be hunted after a 24-month release period(National Assembly, 2009c). The applicants sought to overturn the decision to prohibit activities listed in Section 24 of
TOPS involving listed large predators applying to Lions on the grounds that this self-sustaining period would put an
end to the hunting industry and make it financially unviable for them. An initial judgement in June 2009 found that the
24-month self-sustaining period was not unreasonable and could be practically implemented and that it would notnecessarily result in an end to the hunting industry (National Assembly, 2009c). While the court case was pending,Lions were temporarily deleted from the definition of a “listed large predator” but they were not removed from the listof threatened or protected species – hence all permits issued in terms of NEMBA (including exports) still applied toLions, and only the 24-month release period was not applicable (National Assembly, 2010a).
One goal of DEA on implementing these measures was to clean up the hunting industry and to get rid of “canned”10
Lion hunting. However, the appellants launched a successful appeal against the June 2009 ruling, and in November
2010 the Bloemfontein Court ruled that the hunting of captive bred Lions shortly after their release into the wild beallowed to resume and that the definition of Lions as a “listed large predator” was “invalid in so far as it applies to a‘put and take’ animal that is a lion”11. Hence, the 24-month release period was no longer applicable to Lions andprovinces would have to apply regulations as per their provincial ordinances or guidelines, including for hunting.
One of the earliest references to “canned” hunting is in Time Magazine in 1991 (Mitchell, 1991), but the expression
was probably in prior use. The article describes how well-to-do hunters in the United States were paying thousands ofdollars to shoot exotic animals at point-blank range. In May 1997 the Cook Report “Making a Killing” was broadcast
on television in South Africa and exposed the emerging practice of canned Lion hunting in Limpopo province (Lion
Aid, 2014; Mail & Guardian, 1997). By August 1997 at least 129 cases of canned hunting were being speciallyinvestigated by the then Endangered Species Protection Unit (Beresford, 1997). These investigations exposed thegrowing demand for Lion trophies by affluent hunters, mainly from the United States, where hunters were prepared to
pay up to USD17 500 for “good heavy maned lions, preferably black mane” (Beresford, 1997).
Not all hunting of captive Lions is considered “canned” and it would be fair to say that there are landowners andhunters who disapprove of the practice and do not consider it “hunting” per se (McLaren, 2009, refers to the practice as“canned shooting”). A rationale used to justify trophy hunting is that it creates incentives to conserve Lion habitat,
which under canned hunting scenarios is a redundant argument. However, a rationale used to justify the hunting of
captive Lions in South Africa is based on the argument that the sizeable demand for Lion trophies by foreign hunters,
and the accessibility of the large stock of farmed captive Lions, obviates the necessity to shoot wild or naturally freeroaming animals and thereby reduces the pressure on wild populations. This argument is called “substitutability” and isconsidered to be flawed (Macdonald and Willis, 2013). Has Lion farming for the hunting industry really taken thepressure off wild Lions? It would currently appear so in South Africa, but it is hard to know how the industry would
9 Defined in terms of the 2007 TOPS regulations, “put and take” animals are live specimens that are released on a property,

irrespective of the size, for the purposes of hunting – i.e. animals are “put” into a hunting area for the hunting clients to“take” (shoot)10 “Canned hunting” of predators is considered to be any form of hunting where (i) a large predator is tranquilized, artificiallylured etc., or (ii) a captive large predator is hunted (Draft norms and standards for the sustainable use of large predators interms of section 9(1) of NEMBA). McLaren (2009) refers to it as “canned shooting” since the act of killing an animal that is“impaired in its natural inclination to flea from a pursuer either by means of drugs or by restraints such as small fenced
enclosures” etc. is not “hunting” per se. [NEMBA]
11 For more information on the case, see “SA Predator Breeders Association and Others v Minister of Environmental Affairs

and Tourism (72/10) [2010] ZASCA 151”. http://us-cdn.creamermedia.co.za/assets/articles/attachments/30996_151.pdf

Bones of Contention: An assessment of the South African trade in African Lion bones

27

change if captive facilities were closed down. In the past, Lion breeders threatened to euthanize all captive stock(Anon., 2009d).
Officially, wild Lions accounted for 5% of the total successful Lion hunts in South Africa from 2008–2010 (CITES
Scientific Authority, 2013); however, Lindsey et al. (2012a) reported that South African hunting operators estimated the
proportion of wild Lions hunted to be only 0.9% and 1.1% of the totals for 2009 and 2010. These wild Lions werereportedly hunted in reserves bordering the Kruger National Park or in the Kgalagadi Transfrontier Park (Lindsey et al.,2012a). Damm (2005) also confirms the low numbers of wild Lions hunted and estimates it to be up to 10 per year.
Heedful of the number of Lions hunted, there are concerns about the welfare and treatment of captive Lions that service
the trophy hunting industry – especially their living conditions and the manner by which they are killed. Numerous
reports in the media over the years have alerted people to the sub-standard conditions under which some (not all)breeders keep their animals. Despite calls to ban trophy hunting, “canned” hunting and captive breeding, it seems
improbable that all these well-established industries will be shut down in the near future.
Arguments that have been advanced for maintaining the captive-origin Lion hunting industry include: (1) Lion hunting
using captive animals generates millions of Rand (ZAR) for the South African economy (Figure 9); (2) it creates job
opportunities at breeding and hunting facilities; (3) it supports such peripheral business as tourism and the rearing ofanimals by local businesses to feed the Lions (e.g. donkeys, often by communities adjacent to Lion farms) (Multiple
interviewees, pers. comm., May 2013); (4) it generates revenues that can be used to fund conservation and protect Lion
habitat from other land uses (e.g. Lindsey et al., 2012b; Macdonald and Willis, 2013); (5) it offers an alternative tohunting wild Lions and thus provides a substitute source that results in negligible impacts on South Africa’s wild Lion
population. Some of these views are repeated by Taljaard (2009): “In terms of economy-wide impacts…it is clear thatthe captive lion breeding industry contributes significantly, not only to the broader national economy of South Africa,
but more specifically to the rural economy of some of the poorest provinces such as the North West, Free State andLimpopo”. Thus, these arguments suggest that wild Lions are more likely to be protected in South Africa given thehuge demand for captive Lion trophies and the revenue it generates (e.g. ZAR116.8 million in 2010, Figure 9).
Accordingly, this will make it difficult to generate enough support to close the industry down. The supply of Lion bones
from South Africa to markets in East–Southeast Asia is directly linked to the captive breeding and trophy hunting
industries and, from the available evidence, most of the legally exported bones are a by-product of these activities.
As indicated in the Legislation chapter, there are differences in the regulations for the nine provinces with respect to thehunting of Lions and some of these differences are summarized earlier in Table 3. The less stringent regulations in the
North West Province (e.g. a 96 hour release period into a camp of no specified minimum size) have likely contributed
to the province being the source of ±74% of Lions hunted in South Africa from 2006 to 2010.

LIONS HUNTING STATISTICS FROM DEA
DEA collates all hunting statistics provided by the professional hunters and the provinces and compiles the national
trophy hunting statistics report (see Figure 15). While data for 2011 and 2012 had yet to be compiled at the time ofwriting this report, data from 1 November 2003 to 31 December 2010 indicated that:






Lion hunting generated USD76 million (ZAR576 million) – an average of USD10.9 million (ZAR82.3
million) per year (the average from 2007 to 2010 was USD15.2 million or ZAR118.2 million).
The total number of Lions hunted was 2950 (Figure 9).
The total number of Lions hunted annually reached a peak of at least 651 Lions in 2008
The hunting income from Lions is 20% of the total revenue generated for the hunting of all indigenous
mammals in the same time period (total mammal revenue USD386 million or ZAR2.9 billion, or an average of
USD55.1 million per year).
The highest revenue generated from Lion hunting was in 2008 at USD21.3 million (ZAR176.1 million), which
thereafter dropped 54% to USD9.75 million in 2009 and has slowly risen since then (Figure 9).

The 54% drop in Lion hunting revenues in 2009 coincided with the canned hunting court case but cannot be confidently
attributed to this case since total indigenous mammal hunting revenues and the number of animals hunted also dropped
by 39% and 40% respectively that year. Furthermore, the global recession of 2009 could have had side effects for theindustry with fewer hunting packages being purchased. Another explanation could be that the Lion hunting numbers
were underreported in 2009 and 2010, and this possibility is addressed in the chapter that follows.

28

Bones of Contention: An assessment of the South African trade in African Lion bones

Figure 9 Statistics provided by the Department of Environmental Affairs (DEA) on the total number of Lions
hunted and the income generated from the hunts. Revenues exclude the daily rates and the special fees
[Note 1: letters a–e after the years in Figures 9 and 10: (a) data for 2004 are for period 1 Nov 2003 to 30 Sept 2004; (b) datafor 2005 are for period 1 Oct 2004 to 30 Sept 2005; (c) data for 2006 are for period 1 Oct 2005 to 30 Sept 2006; (d) data for2007 are for period 1 Oct 2006 to 30 Sept 2007; (e) data for 2008 are for period 1 Oct 2007 to 31 Dec. 2008. Data for 2009
and 2010 are from 1 Jan to 31 Dec]
[Note 2: The average annual exchange rates for 1USD are: 2004 = R6.30; 2005 = R6.50; 2006 = R7.27; 2007 = R7.16; 2008 =R8.28; 2009 = R8.40; 2010 = R7.24.]

To put Lion hunting from 2004–2010 into perspective, Lions accounted for an annual average of only ±1.0% of thetotal number of indigenous mammals hunted but ±18% of the total corresponding income value (Figure 10). With the
exception of 2009, the income generated by Lions had been increasing annually and rose from 8.3% of the total
revenues in 2004 to a high of 27% in 2010. The average annual unit price of a hunted Lion rose from USD17 500 in
2004 to USD37 600 in 2010. Thus, while Lions usually rank about 18th in terms of the number of animals hunted
annually (Impala Aepyceros melampus and Springbok Antidorcas marsupialis rank 1st and 2nd respectively), they
consistently rank 1st in terms of the total revenues they generate annually (Kudu Tragelaphus strepsiceros or rhino
usually rank 2nd and 3rd) (Table 4) – which is more than any other indigenous mammal (Figure 11).
Hunting in the North West province accounted for 77% of the total number of Lions hunted from 1 November 2003 to
31 December 2010 (Figure 12); these Lions were mostly captive bred. Lions hunted in the Eastern Cape accounted for
9% of the animals hunted, mostly of captive origin. Lion hunts in Limpopo declined from 27% of the total in 2004, toan average of ±4% of the total from 2008–2010; a higher proportion of these Lions are likely to be wild sourced. The
proportion of Lions hunted in the Free State from 2006 rose and was ±7% of the total from 2006–2010; Free State haveno free-roaming Lions and all these animals are of captive origin.

Bones of Contention: An assessment of the South African trade in African Lion bones

29

Figure 10 (a) Lions hunted annually as a proportion of the total number of indigenous mammals hunted; and (b)the income generated from Lion hunts as a proportion of the total income generated from indigenous mammalhunts. [See Note 1 under Figure 9 for an explanation of letters a–e for years 2004–2008 respectively]

Table 4 Hunting statistics 2004–2010: the average annual unit price per Lion hunted, and the rank of Lions inrelation the total revenue generated from those hunts and the numbers of other indigenous mammal species
hunted. (Source: DEA)
Year

Numbers of individual mammal species
huntedLion Rank
Species ranked 1st, 2nd and 3rd
Lion Rank
Species ranked 2nd, 3rd and 4th
after Lionsst2004
17 500110 250
28
Im; Wh; Kd (Rh = rank 38)
3
1 Kd; Gb; Lion; Wb
2005
17 390113 035
19
Im; Wh; Bb (Rh = 36)
1
Kd; Gb; Rh
2006
17 333126 011
18
Im; Sb; Bb (Rh = 34)
1
Kd; Rh; Gb
2007
21 357152 916
18
Im; Sb; Wh (Rh = 35)
1
Kd; Ny; Bf
2008
31 250258 750
18
Im; Sb; Bb (Rh = 36)
1
Kd; Bf; Rh
2009
30 000252 000
20
Im; Sb; Bb (Rh = 38)
1
Rh; Bf; Kd
2010
37 600272 224
18
Im; Sb; Bb (Rh = 33)
1
Rh; Kd; Bf
Abbreviations: Bb=Common Blesbok Damaliscus pygargus; Bf=Buffalo Syncerus caffer; Gb=Gemsbok Oryx gazella;
Im=Impala Aepyceros melampus; Kd=Kudu Tragelaphus strepsiceros; Ny=Nyala T. angasii; Rh=White Rhino Ceratotherium
simum; Sb=Springbok Antidorcas marsupialis; Wh=Warthog Phacochoerus africanus; Wb=Waterbuck Kobus ellipsiprymnus

30

Average unit priceper Lion hunted
USD
ZAR

Total revenue from hunts

Bones of Contention: An assessment of the South African trade in African Lion bones

Figure 11 Total income relative to the number of animals hunted per species in 2010. Unnamed species clusteredin the bottom left of the graph are hunted in smaller numbers and generate lower annual revenues. (Total
indigenous mammal species hunted n=83)

Figure 12 Number and percentage of Lions hunted from each province between 2006 and 2010. No hunting
occurred in WC and GP. (See Map 2 for abbreviations for the provinces)
There are discrepancies in the data on the number of Lion hunted when comparing information supplied by DEA with
figures cited in other literature sources, especially for the North West Province for 2006 and 2007. How accurate theBones of Contention: An assessment of the South African trade in African Lion bones

31

data are from these complementary data sources is unclear, but if they are near-correct then they increase estimates ofLions hunted considerably. For example:

In 2006: data supplied by DEA shows 379 Lions hunted, of which 272 were in the North West (Figures 9 &10)o Cadman (2009) reports 423 Lions hunted in the North West (data supplied to Cadman in writing fromthe province);o If data supplied to Cadman (2009) are correct, then by replacing DEA’s with Cadman’s figures for
the North West, the revised annual total is 530 Lions hunted in 2006.
 In 2007: data supplied by DEA show 641 Lions hunted, of which 484 were in the North West (Figures 9 & 12)o The National Assembly (2008) published figures of 637 Lions hunted in the North West;o Cadman (2009) reports 832 Lions hunted in the North West (data supplied to Cadman in writing fromthe province);o If data supplied to Cadman (2009) are correct, then by replacing DEA’s with Cadman’s figures for
the North West, the revised annual total could have been as high as 989 Lions hunted in 2007 (or, 794
Lions using National Assembly data).
 In 2008: data supplied by DEA show 681 Lions hunted
o Cadman (2009) quotes SAPBA (South African Predator Breeders Association) saying that 1050 Lions
were hunted).
These inconsistencies noted by Cadman (2009) are noteworthy since large discrepancies were observed whencomparing the number of Lions reportedly hunted with the number of permits issued to export Lion trophies. These
discrepancies are discussed in the following chapter in relation to the possibility that Lion hunts are underreported inSouth Africa.
At the time of writing this report, data for 2011 and 2012 had yet to be compiled by DEA; however, the following
provinces provided these figures (from interviews and/or documents sent subsequent to the interviews):Eastern Cape: 40–50 Lions hunted in 2011, which is up from 28 Lions hunted in 2010;
Free State: no more than 20 Lions hunted in 2012, which is lower than in previous years when the provincebegan implementing and enforcing regulations that discourage hunting.
North West: 361 and 553 Lions hunted in 2011 and 2012 respectively. The number hunted in this province in2012 exceeds the high of 528 Lions reported by DEA in 2008.

Based on the preliminary figures for the Eastern Cape, Free State and North West, and other anecdotal evidence
collated from other interviews, the number of Lions hunted in 2011 and 2012 are on a continued upward trend from thealleged low of 2009 (Figure 13). The total number hunted in 2012 seems set to exceed the number of Lions hunted in
2008.

HUNTING REVENUES FROM LIONSWith the exception of rhinos, Lions generate the second highest individual revenue per animal hunted of any species inSouth Africa; however, since fewer rhinos are hunted annually, the total annual income generated is usually second tothat of Lions (Figure 10). The average unit value paid by clients to trophy hunt Lions in South Africa was USD37 600
in 2010 (Table 4), which was an increase of 11.5% from the USD17 500 paid in 2004 (Table 4) (Source: DEA annual
hunting reports). These average values are mainly for captive-sourced animals and include values for both Lions andLionesses. Hunters pay more to hunt male Lions compared to Lionesses; for example, values cited in 2013 were
ZAR160 000–ZAR170 000 (USD16 800–USD17 900) per male and ZAR30 000–R40 000 (USD3150–USD4200) per
female (W. Boing, pers. comm., May 2013). Hunters also pay more to hunt wild Lions.

WEIGHING THE SEX COSTS
Once landowners deduct the costs of tranquilizing and translocating Lions from the breeding facilities to the hunting
camps, the net profits generated from hunting Lionesses are considerably less than males. Females in breeding facilities
that are not hunted and do not die of natural causes are more likely to be put down in a manner that incurs the fewest
costs, bearing in mind that a permit is required to cull Lions and veterinarians charge about ZAR5000 (USD525) toeuthanize animals (there are, however, allegedly cheaper more dubious means). Before the Lion bone trade commenced
c.2008, Lionesses are alleged to have had little value to landowners besides their breeding potential (Anon., pers.
comm., May 2013); accordingly, the market for bones in Asia has created a value for their skeletons that was previously
absent.

32

Bones of Contention: An assessment of the South African trade in African Lion bones

Figure 13 The number of Lions hunted in South Africa from 2004–2010 (solid bars, same as Figure 9) andpreliminary and incomplete tallies for 2011 and 2012 (patterned bars) based on information provided by theprovinces during interviews. The official 2011 and 2012 figures will only be released by DEA towards the end of
2013. (Source: DEA) [Note: No data were provided on the numbers of Lions that were of captive or wild origin –see estimates by Lindsey et al., 2012a]
Prior to 2008 carcasses from all Lions, whether hunted or culled, would have been disposed of. Rademeyer (2012a)
writes that skeletons would be left for vultures and scavengers or be buried in pits to rot in the soil. Since 2008, a value
has been added to the previously discarded bones and landowners/game farmers are allegedly exhuming skeletons.
Some people have stated in the media that females are now the primary source of Lion bones for the foreign market –but there is no evidence for this. According to the landowners, it makes no business sense for them to supply only
Lionesses since the income would only be from the bones and not from the additional revenue generated by the trophy.
And, since hunted male Lions fetch considerably higher prices, a landowner’s first choice would be to obtain theincome from the trophy and then make additional profits from the bones as a secondary income stream from the same
Lions.
While male Lions generate the most revenue for landowners, there are different reports on the proportion of males andfemales hunted. Lindsey et al. (2012a) report that 33.5% of Lions hunted as trophies in South Africa are female.
Currently in the Free State province no Lionesses are hunted, but in the past around 10% of the total were female (W.
Boing, pers. comm., May 2013). Limited data obtained for this study indicated the sex of the hunted individuals: of 416
hunts, 84.1% were males and 15.9% females. The proportion of males and females hunted in a province, and thus theincome generated therefrom, would depend on the number of breeding and hunting facilities per province. Since mostLion breeding occurs in the Free State and most hunting in the North West, the income generated from selling Lions tohunting operations would be higher in the Free State whereas the income from hunting male Lions would be higher in
the North West. Accordingly, the proportion of skeletons available for export and derived from male Lions would behigher where most of the hunting occurs, whereas the proportion of skeletons from Lionesses is higher where most of
the breeding occurs. There are anecdotal reports that >90% of the Lions culled/euthanized in the breeding facilities arefemale (Anon., pers. comm., May 2013) – but the actual number of individual Lions this represents is not known tohave been enumerated. Accordingly, the number of skeletons exported to East–Southeast Asia that were derived fromthis sector of the industry is not actually known – but most reports and people interviewed have said that the skeletonswere mainly obtained from trophy hunted Lions, which are primarily male (Multiple interviewees, pers. comm., May
2013).

CLIENT NATIONALITY
The nationality of foreign hunters, and their activities, in South Africa is of casual interest to this study. Big game
hunters in South Africa are usually from the Americas and Europe. Until c.2006, Asian hunters, particularly from East–
Southeast Asia, were a rarity with no tradition of sport hunting outside of their country of origin. While a few Lion
Bones of Contention: An assessment of the South African trade in African Lion bones

33

trophies were exported to China before 2004, hunting safari services for Chinese hunters became popular from2004/2005. A China-based adventure travel business, for example, started offering wealthy clients the opportunity to goon hunting safaris in Africa and to “bag a trophy and bring it home” (Zhilong, 2012). Viet Nam does not have any
recognized hunting associations (Rademeyer, 2013), yet the number of Vietnamese hunters applying for permits to“hunt” white rhino trophies increased noticeably from 2006 and especially 2007 (See Figure 14 in Milliken and Shaw,2012). PHASA (the Professional Hunters Association of South Africa) first notified authorities in 2007/2008 that a
rapidly increasing number of Asian nationals, under the guise of being sport hunters, started hunting rhino (Damm,2008). The final purpose of the “hunters” was not the trophy but the commercialisation of the rhino horn and derivatives– which, despite the hunts being legal, was in contravention of CITES protocols (Damm, 2008).
National records from the professional hunting register for all hunted indigenous and non-indigenous vertebrates showthat the number of hunters from Viet Nam increased exponentially from 3 in 2004 to 87 in 2010 (Table 5); the numberof hunters from China remains low, and no hunters from Lao PDR and Myanmar were reported. In contrast, the numberof hunters from the USA is normally >2600 per year and these clients usually represent more than 50% of the total
number of hunters to South Africa (Table 5). For the years 2004–2005 and 2009–2010, Vietnamese hunters were most
likely to be issued permits to hunt species in the North West and Eastern Cape provinces (Figure 14); clients from the
USA were most likely to hunt animals in the Free State, North West and Limpopo. However, some provinces like theNorthern Cape no longer allow people from Viet Nam or China to hunt within the province (P. van Niekerk, pers.
comm., May 2013). The chapters that follow unravel the trade and export of Lion trophies and skeletons from South
Africa to East–Southeast Asia and explores the potential linkages to Tiger and rhino exploitation.
Table 5 Number of foreign hunting clients per selected country reported in the South African hunting registers
from 2004 to 2010 (for all species, including Lions).
Selected countries

2004

2005

2006 – 2008

2009

2010

1
61

9
9
1
87

Hunters from selected East–Southeast Asian countries
Cambodia*
China
Lao PDR
MyanmarThailand
Viet Nam

4
1
3

13
6

No data supplied

See Fig. 14 in Milliken and Shaw (2012)

Top three countries with the most hunters visiting South Africa
Denmark
291
394
588
401
Spain
476
628
413
389
No data supplied
USA
3741
3955
3061
2673
Total number of hunters(n>84 countries)
6673
7342
6292
5673
* Cambodian hunters were recorded for the first time in South Africa in 2010. Hunting took place in the North West province.
The only reported legal trade between South African and Cambodia is in live birds and Nile Crocodiles skins between 2001
and 2011 (Source: UNEP-WCMC CITES trade database), hence the species that were trophy hunted cannot be deduced fromthe available records(Source: DEA annual hunting statistics)

34

Bones of Contention: An assessment of the South African trade in African Lion bones

Figure 14 The total number of clients per province from Viet Nam, China and the USA in 2004–2005 and 2009–2010 that hunted indigenous and non-indigenous vertebrates. (Source: DEA annual hunting statistics)© ANDREW J. LOVERIDGE

Bones of Contention: An assessment of the South African trade in African Lion bones

35

LION TROPHY EXPORTS & THE SIZE
OF THE SKELETON RESOURCE BASE
INTRODUCTION
Permits to hunt Lions in South Africa are issued through the provinces and professional hunters are obliged to record allcompleted hunts in a professional hunting register (Figure 15). Since African Lion is listed in Appendix II of CITES,
clients must have permits to export the trophies and the provincial Issuing Authority issues these permits once the hunts
have been registered. Corresponding permits to import trophies are only required if a country requires one as part oftheir stricter domestic measures (http://www.cites.org)
From 1977 to 2011, South Africa reportedly issued permits to export 7014 Lion trophies to 100 countries – but the
number of Lion trophies imported to these countries amounted to only 5246 – a difference of 1768 trophies (Figure 16)(Source: UNEP-WCMC CITES trade database). Up to 2003, the annual differences in exports/imports amounted to 20–
50 trophies per annum, but from 2004 the differences usually exceeded 130 trophies per annum and went up to adifference of 373 in 2009. The increase in the number of permits issued for Lion trophies, especially from 2006,
illustrates the growing demand by foreign hunters (Figure 16).
It is important to be aware that the number of Lion trophies indicated in the CITES records through the permits issued
do not reflect the actual number of trophies exported or imported (Figure 15). A similar principle applies to permits
issued to export skeletons. Reasons why the numbers of Lions/trophies recorded on the permits do not reflect the actual
exports/imports include:
1.
2.
3.
4.
5.

The Lion may have been hunted and the trophy permit issued, but the permit was not used because the trophy
was not exported/imported;
Fewer Lions were exported/imported than specified on the permit – if the application was for more than one
Lion trophy on the permit;
A corresponding import permit was not required by the foreign client’s country, or the client did not declare
the import/export;
Professional hunters were non-compliant and did not apply for a hunting permit, yet they obtained an export
and/or an import permit.
Incorrect and/or forged documentation and/or “re-used” permits were used. Freight forwarding and cargohandling companies and law enforcement officials have found fraudulent permits during inspections. It has
been alleged that some exporters are selling re-used permits for USD100 (W. Willson, NSPCA, pers. comm.,
May 2013).

Another way of corroborating the quantity of legal exports would be if the duplicates of Page three of all issued CITES
export permits were returned to the Issuing Authority with the endorsement by the official in charge of inspecting thecargo. However, as mentioned in previously, these duplicate pages are rarely returned or compiled (Anon., pers. comm.,
July 2013). Given the discrepancies and discontinuities in the paperwork along the value chain from the hunting permit
to the shipment import, it is a challenge determining exactly how many Lions were hunted and how many trophies were
exported and thus how many carcasses there are in stock that could potentially be exported as skeletons (Figure 15).
The number of hunting permits issued cannot be used as a proxy for the numbers of carcasses potentially inreserve/stock since fewer Lions are reportedly hunted than trophy permits issued. While the number of permits issued
for trophy exports should be less than the number of Lions hunted (since the exporter must show a copy of the hunting
register to obtain a permit and thus demonstrate the Lion was hunted), there are more permits issued for trophies than
the number of Lions hunted (Figure 17, discussed later).

36

Bones of Contention: An assessment of the South African trade in African Lion bones

Figure 15 Decreasing number of Lion “units”, from the number of hunting permits issued (top of Figure) to thefinal number of trophies or skeletons exported (bottom of Figure)

Bones of Contention: An assessment of the South African trade in African Lion bones

37

Figure 16 South Africa’s reported exports of Lion trophies (based on the number of CITES permits issued to 100
countries) contrasted with the Lion trophies imported from South Africa (ZA) (based on import permits issued
by 51 countries to import trophies from ZA), and illustrating the difference in the number of trophies reportedly
exported/imported. (Source: UNEP-WCMC CITES trade database)
DEA maintain that “although the hunting stats are just an estimate and not reflected as an absolute figure, thisinformation is a much more accurate reflection of what was hunted, than the reflection of what was exported in the
CITES report” (M. Boshoff, DEA, in litt., July 2013). One reason why the hunting statistics are “an estimate and not an
absolute figure” is because it requires professional hunters to be honest in their legal obligation to complete theprofessional hunting register accurately. Doubts about the absolute accuracy of the information thus recorded are basedon an interview wherein the informant discussed how some hunters and people in the wildlife business allegedly have a“bad attitude towards government and don’t want to have anything to do with officialdom” which extends to refusing
to comply with all permit regulations (Anon., pers. comm., June 2013). Since hunters who are not part of professional
hunting organizations (and can’t be forced to belong to an organization either) cannot be relied on to report all theanimals hunted under their watch, the national hunting statistics are thus assumed to be a lower-bound estimate of theactual number of Lions hunted.
The years that the export permits for Lion products are issued do not necessarily indicate (1) the years the Lions were
hunted, or (2) the years the trophies/skeletons were actually exported. Delays are partly based on the time needed totaxidermy the trophy or prepare the skeleton for export. A subset of n=155 permit records supplied from DEA indicatedthe date of the Lion hunt alongside the year the export permit was issued. From these data, it was estimated that:






62% of export permits were issued in the same calendar year the Lions were hunted;
23% of permits were issued in the subsequent calendar year;
4% of permits were issued in the second calendar year after the hunt;
5% of permits were issued in the third calendar year after the hunt;
3% of permits were issued four or more calendar years after the hunt.

For example, for Lions hunted in 2007: 62% of trophy export permits would have been issued in 2007, 23% issued in
2008, 4% in 2009 etc. How representative this subset of data is for the entire trophy export industry is unclear becausesome people interviewed said that only a small proportion of trophies are exported one or more years after the Lions
were shot and the trophy permits issued.
Various data were used to assess the size of the Lion hunting industry, the number of trophies and skeletons
exported/imported, and the potential size of the skeleton resource base (Table 6). These figures were used throughout
the rest of the report.

38

Bones of Contention: An assessment of the South African trade in African Lion bones

Table 6 Data and source of information available to this study to assess Lion hunting and export/import permits
issued annually

Data available

Provincial
hunting
permits

National trophy
hunting statistics(from theprofessional hunterregister) 1

CITES trade database:imports and exports 2

South Africa’s annual CITES
reports 1

Numberofpermits
issuedIncludes the numberof Lions hunted
annually

Number ofexport/import permits
issued, destination of
the trophy, quantity

Nearly all of the data recorded
on a CITES permit except for
the names and addresses of theimporter and exporter

Actualexports*

No dataYears data?
2004 – 20101975 – 2011
2006 – 2011
available
available
Information
accessed for
No
Yes
Yes
Yes
this study
Sources: 1 DEA; 2 UNEP-WCMC CITES trade database* Information on actual imports is only available: (1) through getting export records from exporters and freight forwarding
companies at airports and harbours; (2) if nature conservation departments recorded the actual number of specimens being
exported at the port of exit on the CITES permit (there is a field at the bottom of each permit available for this purpose but it
is rarely used); or (3) the third duplicate page of the CITES permit is return to the Issuing Authority by the official in charge ofinspecting the shipment.

COMPARISON OF LION HUNTING REGISTER AND TROPHY EXPORTSTATISTICS
There are large discrepancies between the total number of Lions hunted and the total number of Lion trophies recordedon CITES export permits for South Africa in a calendar year (Figure 17). Since hunters are required to show theirhunting registers to the Issuing Authorities before permits are issued to export trophies, there should be more Lions
hunted than trophies recorded on export permits. Between 2004 and 2010, 2950 Lions were registered as having beensuccessfully hunted – yet CITES export permits indicate 4088 trophies for the same period, a difference of 1138 moretrophies than Lions hunted and an average annual discrepancy of 162.6 ± 218.2 more trophies than Lions. The biggest
deficit is 569 in 2009 – which is notable since Lion hunting numbers had been increasing annually until they apparently
dropped in 2009, and yet permits issued to export trophies were higher than previous years (Figure 17). The only years
in which no deficits were recorded are 2005 and 2007 when 58 and 80 more Lions were hunted than reportedly
exported in those years respectively (Figure 17).
Several reasons have been proposed to explain the discrepancies, but it is questionable as to whether these reasons
cumulatively explain the big differences. These reasons include:
1.
2.
3.

If permits expire before the trophies are exported, then new permits are reissued in the same or subsequentcalendar years;
Some exports are incorrectly declared as being trophies instead of a different category, and thus the number oftrophies are over-reported;
Lions are not always hunted in the same year as the permits are issued, hence comparing the two statistics canbe slightly misleading since the total number of export permits issued in a year could also include permits forLions hunted up to five years previously.

Even if the annual export statistics are adjusted to create more of a relatable comparative platform – i.e. a theoreticalscenario that estimates the number of trophies in a year by assuming the permits were issued the same year the Lions
were hunted (i.e. creating a graph similar to Figure 17 using the 62%:23%:4%:5%:3% proportions of trophy permits
issued 0-1-2-3-4-5 years after Lions are hunted) – the large annual deficits between hunting and trophies still exist (datanot shown). If the deficits can’t be entirely explained by the delays in trophy exports, then alternative reasons need to beconsidered.

Bones of Contention: An assessment of the South African trade in African Lion bones

39

Figure 17 Comparative difference between the number of Lions hunted in South Africa and the number of Lion
trophies declared on the CITES export permits issued in South Africa. (Years in italics)
Regarding allegations that some Lion skeleton exports are incorrectly declared as “trophies” and thus the number oftrophy exports are erroneously inflated (Bullet 2 above), Milliken and Shaw (2012) established that early exports ofrhino horns to Viet Nam were being falsely declared as rhino “trophies”, thereby erroneously inflating the number of
permits issued for “trophies”. Despite the trade in Lion bones being legal, questions have been raised as to whether thiswas a tactic used in the early days of Lion bone exports and whether this practice continues, either deliberately or inerror.
If annual trophy figures were being erroneously inflated by falsely listing “trophies” instead of “skeletons” on theexport permits, then “hunters” from East–Southeast Asia might have more motives to pursue this misdeclaration.
However, the only nationals from East–Southeast Asia legally exporting trophies from 1999 to 2007 were Chinese
hunters at an average of 3.4 ± 3.1 trophies per year (see Figure 22). This average has a negligible influence on theannual deficits apparent in Figure 17. Vietnamese clients were only issued permits to export Lion trophies in 2008 and2009 (Figure 21) – although their apparent lack of activity with respect to Lion hunting prior to 2008 is debateable
given their involvement in rhino hunting and their business relationships with Lion breeders that were widely reported
in the media. Nevertheless, the permits issued to export Lion trophies to China and Viet Nam in 2008 and 2009
cumulatively amount to only 27 and 38 trophies respectively and also do not reduce the annual differences in Figure 17
by any notable amount. Hence, potentially false declarations of “skeletons” instead of “trophies” on CITES export
permits do not satisfactorily resolve the deficits observed in Figure 17.
On balance, it would seem that reissued export permits, false permit declarations, and readjustments of the number of
permits that could have been issued the year a Lion was hunted cannot account for all of the large deficits between thenumbers of Lions hunted and the trophies exported. Hence, the discrepancy could lie with other factors, e.g. the numberof Lions hunted and the accuracy of the professional hunting registers. There are a number of questions that should be
addressed in this regard including:







40

Is there more hunting occurring than is being declared?
Are all professional hunters declaring all Lion hunts and being honest with their record keeping?
Despite the legal requirement, are there professional hunters who are not keeping hunting registers and thus
not contributing to the national statistics on the number of Lions hunted?
Are conservation officials attending all hunts and ensuring that they occur for the Lions specified on the permit(so that permits aren’t reused illegally for different Lions)?
Is information being accurately submitted and compiled along the chain of accountability from hunter to DEA?
Are some trophy export permits being issued without a copy of the hunting register being seen? (Somenational nature conservation departments have vigorously denied this contention)
Are trophies originating from outside South Africa exported via the South African system?
Bones of Contention: An assessment of the South African trade in African Lion bonesAre the cumulative discrepancies for 2004–2010 partly a proxy for the number of hunted Lions that have notbeen declared by the professional hunters?
Are the provinces accurately compiling their annual hunting reports?
Alternatively, are non-hunted animals (such as euthanized Lions) being declared as trophies and thereby
falsely inflating the figures on the number of export permits issued?

The merits of these and other questions regarding the sources of the discrepancies should be seriously considered. It is
unlikely that any one factor/variable can be attributed to the deficits, but each variable was mentioned during theinterviews as an area where the reporting of hunting and export statistics should be improved to limit the irregularities.
There is also room for improving the monitoring and reporting of other areas of the Lion trade directly concerning the
Asian bone trade starting, for example, with the birth of Lion cubs in breeding facilities. One conservation official
pointed out the size of the captive Lion population versus the number of Lions hunted and said that there “must be a lotof extra lions that are in the way of somebody” (Anon., pers. comm., May 2013). The inference was that somelandowners are not getting the necessary permits and permission to carry out restricted activities, and that Lionskeletons may enter the system without the necessary paper work that can trace it back to its original source.

ESTIMATING THE SIZE OF THE RESOURCE BASE: THE NUMBER OFSKELETONS THAT COULD BE EXPORTED
There are several potential sources of skeletons for the Lion bone trade: (1) natural mortalities; (2) animals that were
put down for a variety of reasons (e.g. euthanized; culled to manage Lion numbers); (3) problem-Lion hunts; (4)carcasses that were buried/discarded after events in the past (e.g. hunting, natural deaths, etc.) and could possibly be
exhumed for the trade; (5) poaching; and (6) trophy hunts. Information is limited on the number of Lions available fromthe first four sources and the size of this resource base is unknown but presumed to be cumulatively large considering
the number of captive animals and the amount of hunting that took place in the past. Small reserves with Lions may
also cull animals to manage their numbers and prevent over-population – thus, it may arise that the bones are sold torecoup costs (P. Lindsey, in litt., September 2013); however, there were no data available on whether this occurs andthe size of this resource base. Incidents of Lion poaching in national and private reserves are rare and not believed to bea notable contributor of bones to the trade (see chapter on the illegal trade in Lions).
The best source of data on the minimum size of the carcass resource base is the number of Lions hunted annually [Note:the number of permits issued for trophy exports has to be used as a proxy for Lions hunted before 2004 since thenational hunting statistics provided began in 2004]. Trophy hunted Lions appear to be the main source of skeletons for
the Lion bone trade in South Africa. Since most of the Lions hunted in South Africa are from captive stock (>95%
according to several sources), most of the exported bones are reportedly derived from captive, and not wild, Lions
accordingly. Bones from wild Lions hunted in national parks are not sold to buyers. Thus, if bones from wild specimens
are sold into the trade, then the most likely sources would be from wild stock that have been illegally introduced into a
captive population, or wild Lions poached from neighbouring countries.
Thus, excluding bone sources 1–6 above (because the data are highly deficient), and taking into account Lion hunts
conducted from 1977 to 2010, the size of the skeleton resource base from the trophy hunting industry is roughly
estimated to be at least 5000 to 6200 units and growing (Table 7). There is no real information available on the extent towhich carcasses discarded before 2008 are being located and exhumed and whether these decomposed bones are
acceptable to buyers. If one assumes that landowners/game farmers/taxidermists are only selling skeletons from hunts
conducted after 2008, then the potential exportable resource base was 1400 to 2500 units for the period 2008–2010(Table 7). Skeletons available from euthanized animals and those that died naturally would further increase theestimates for the potential size of the resource base from hunted and non-hunted Lions.
Table 7 Estimated size of the Lion skeleton resource base available from trophy hunting, assuming older remains
are accessible. Prior to 2008, most skeletons would have been discardedYears
1977 – 2010
2000 – 20102004 – 20102008 – 2010

Size of the skeleton resourcebase from trophy hunting
5000 to 6200
3600 to 4900
2900* to 4100
1400* to 2500

* Lower estimates calculated from national trophy hunting
statistics compiled annually by DEA. Higher estimates based on
the CITES trophy export permits issued. Estimates exclude
skeletons that might be available from natural mortalities,
euthanized animals, problem-Lion hunts and poaching.

Bones of Contention: An assessment of the South African trade in African Lion bones

41

TRADE IN LION BONES & OTHER
BODY PARTS FROM SOUTH AFRICA
INTRODUCTION
Lion hunting and the subsequent exports of trophies are notable contributors to the income generated by the hunting
industry. Besides Lion trophies, South Africa has exported 19 other categories of Lion products since 1977 ranging
from hair to handbags, feet, leather items and tails (Source: UNEP-WCMC CITES trade database). Of interest, and thefocus of this report, are the body parts and derivatives exported to East–Southeast Asia that are part of the extensive
global large felid trade and feed into the “tiger” bone industry as substitutes. Since 1998, but especially after 2007,
China, Viet Nam, Lao PDR, Myanmar and Thailand have imported increasing amounts of live Lions, Lion bodies andbones from South Africa (Table 11; Figure 24).

Bag of Lion bones in South Africa.

© VIVIENNE L. WILLIAMS

Note: As stated earlier, no distinction in the analyses is made between Lion products that were “wild” or “captive”
sourced. This is because some provincial permit issuing authorities were, for a period of time, erroneously recordingsome captive sourced animals as “wild sourced” on CITES export permits. This practice has since been amended.

42

Bones of Contention: An assessment of the South African trade in African Lion bones

EXPORTS OF LIVE LIONS FROM SOUTH AFRICA
The number of animals recorded on permits issued to export live Lions from South Africa reached a peak of >280
animals in 2010 (Figure 18), and the dominant importing country varied annually. Countries besides those in East–
Southeast Asia that have been issued permits to import more than 50 live Lions each in the period 1990–2011 are:Botswana, Spain, the United Arab Emirates, the USA, Zambia and Zimbabwe.

Figure 18 The number of live Lions recorded on export permits issued by South Africa to (a) “other” countries,and (b) China (CN), Myanmar (MM), Thailand (TH) and Viet Nam (VN) combined. Vertical lines indicate years
that measures were adopted to protect Tigers and Asian big cats. Exports to countries prior to 1990 are notshown. Figure excludes import records for a country when there was no corresponding export record fromSouth Africa (Source: UNEP-WCMC CITES trade database)
Permits to import live Lions to East–Southeast Asia from South Africa were first reported in 1992; two Lions were
imported into Thailand (Source: UNEP-WCMC CITES trade database) – however, no corresponding export permits
issued in South Africa were reported on the CITES database (hence the record is not reflected in Figure 18 because thisgraph only shows the number of live Lions recorded on export permits issued by South Africa). The first permits issued
by South Africa to export live Lions to East–Southeast Asia were issued to China in 1998 for one live Lion, followedby permits in 1999 to export 6 and 15 Lions to China and Thailand respectively (Figure 18). Exports of live Lions toEast–Southeast Asia were irregular until 2006; thereafter, export permits were issued to Thailand every year from2006–2011 (total 115 Lions, average 19 ± 24 per year). In the same period, permits issued to China, Myanmar and Viet
Nam totalled 20, 28 and 22 live Lions respectively.
From 1993 to 2011, 59% of the live Lions destined for East–Southeast Asia went to Thailand, 18% to China, 13% toMyanmar, and 10% to Viet Nam. In Oswell’s report on the big cat trade in Thailand and Myanmar conducted between
2001 and 2010, no mention is made of the presence of live African Lions in the markets (Oswell, 2010). Since there arefew CITES records of legal cross-border trade in live Lions in East–Southeast Asia, it is impossible to ascertain the
purpose of these imports. In other words, are the Lions retained in the possession of the importers or are they
subsequently traded and trafficked illegally throughout the region? Moreover, what is Thailand’s role in the live Lion
trade?
Ostensibly, the Lions remain in Thailand since permits to export live Lions from Thailand to elsewhere in East–
Southeast Asia amount to no more than nine individuals from 1996 to 2003 (and permits to export other Lion products
amount to one specimen and seven claws) (Source: UNEP-WCMC CITES trade database). However, Thailand serves atransit country, conduit and retail centre for buyers of wildlife throughout the region (legal and illegal trade) (Nooren
and Claridge, 2001; UNODC, 2010; various sources from http://www.traffic.org). It was alleged by one intervieweethat there are two big “quarantine stations that bounce a lot of things through from Thailand into China because some

Bones of Contention: An assessment of the South African trade in African Lion bones

43

things aren’t allowed from South Africa into China” (W. Willson, pers. comm., May 2013). Is it thus feasible that Lionsare disposed of in the extensive illegal wildlife trade nexus that exists in the region?
Within South Africa, the provinces that issued permits to export live Lions from 2006–2010 are: North West (40% ofLions recorded on the permits), Free State (29%), Gauteng (15%), Limpopo (8%), KwaZulu-Natal (7%) and the Eastern
Cape (1%). Of these, only the North West, Free State, Gauteng and the Eastern Cape exported live Lions to East–
Southeast Asia (China, Thailand, Myanmar and Viet Nam). Sixty-seven per cent of these Lions were reported on
permits issued in the North West, 17% from Gauteng, 12% from Free State and 4% from the Eastern Cape. All of these
Lions were captive bred.

EXPORTS OF LION BODIES FROM SOUTH AFRICA
There has been an irregular trade in Lion bodies12 since 1984, but exports increased more than 12-fold in 2010 from theaverage of seven bodies per year from 1990–2009 (Figure 19). In 2010, 50% of the bodies were destined for the USA,the reported purpose being “hunting trophy”. All the permits issued to export Lion bodies to East–Southeast Asia from2005 to 2011 were for China; the purposes of 88% of the exports were reported as “educational” and 12% as“personal”.

Figure 19 The number of Lion bodies recorded on export permits issued by South Africa to (a) other countries,(b) China (CN) and Thailand (TH) combined, and (c) the USA. Vertical lines indicate years that measures wereadopted to protect Tigers and Asian big cats. Exports to other countries prior to 1990 not shown
The UNEP-WCMC CITES trade database records that permits were issued to export 80 “bodies” from South Africa to
Lao PDR in 2009. However, on examination of the annual CITES reports supplied to this study by DEA it wasestablished that these were actually “skeletons” 13 that had been incorrectly reported as “bodies”. Hence, these 80“bodies” are not included in the above analysis of bodies (Figure 19), but are included in the analysis of skeletons inFigure 20.

12 The definition of a “body” (BOD) according to CITES (2010c) guidelines is “substantially whole dead animals, including freshor processed fish, stuffed turtles, preserved butterflies, reptiles in alcohol, whole stuffed hunting trophies, etc.” The preferred
unit of measurement is the number of bodies, but alternatively the mass can be recorded.
13 The definition of a “skeleton” (SKE) according to CITES (2010c) guidelines is a “substantially whole skeleton”. The unit ofmeasurement is the number of skeletons. “Carcass” is not a term defined by CITES.

44

Bones of Contention: An assessment of the South African trade in African Lion bones

EXPORTS OF LION BONES FROM SOUTH AFRICA
The CITES category “bones” 14 is different to “skeletons”. Whereas “bones” exported to East–Southeast Asia areusually whole skeletons, in this section of the report “bones” refers to a few individual bones (e.g. patella, floatingbones) and/or a quantity of a specific mass where the equivalent number of skeletons has not been reported.
The annual CITES reports supplied by DEA for 2006–2011 contain most of the information on CITES export permits,
except for the names and addresses of the exporters/importers. It was thus possible to scrutinize the raw data andamend/reclassify the information if necessary. Some errors in the reporting of “bone” exports were detected, usuallythat “bones” were whole skeletons. Ten permit records were subsequently reclassified with the assistance of therelevant provincial Issuing Authorities following requests to clarify information that appeared inaccurate (Table 8).
Hence, the data presented here for bones differ considerably from the information on the UNEP-WCMC CITES trade
database.
Table 8 Reanalysed and corrected data (last column) for permits issued by South Africa to export bones (BON)
and skeletons (SKE) to China (CN), Lao PDR (LA) and Viet Nam (VN)
Year

2008
2009

2010

Description on original
CITES permit (from DEA
annual reports)

Incorrect record
DEA CITES report

1) 35 skull/bones to VN

Corrected record
Data used in this report

1) 35 BON to VN

Recorded on UNEPWCMC CITES trade
database
1) 35 BON to VN

2) Bones of 15 Lions to VN

2) 15 BON to VN

2) 15 BON to VN

2) 15 SKE to LA

3) 250 kg to LA

Correct report

Correct report4) 2 (sets of bones)

4) 2 BON to LA

4) 2 BON to LA

3) 250 kg BON to LA(=26 SKE, Appendix 5)4) 2 SKE to LA5) no record5) no record5) 48 BON to CN*5) 48 BON to CN*6) 232 BON to LA6) no record6) 3 SKE to LA7) 583 BON to LA8) 586 BON to LA

7) 27 SKE to LA

8) 26 BON to VN
9) 1573 BON to LA

8) 26 BON to VN
9) 1573 BON to LA

6) Details of numerous
individuals bones to LA
7) Details of numerous
individual bones to LA8) 13 + 13 bones to VN
20119) 1573 (107.5 kg) bones toLA10) 32 carcasses to VN
Totals for incorrect and correctedrecords

1) 35 SKE to LA

8) 26 SKE to VN
9) 107.5 kg BON to LA(=11 SKE)
10) 32 BON to VN
10) 32 BON to VN
10) 32 SKE to VN
BONES=2498 bones
BONES=2314 bones BONES=48 bones to CN
and 250 kg
and 250 kg
SKELETONS=177 (119 to LA & 58
to VN)(Source: DEA annual CITES reports, and UNEP-WCMC CITES trade database; Anon., Issuing Authority, in litt., 2013)* There is no equivalent record in the DEA report of a permit being issued to export 48 bones to China; this record appears
only on the UNEP-WCMC CITES trade database. “48 bones” is an unusual number of Lion bones to export (Table A14 inAppendix 4), and it is suspected that this record is for 48 skeletons, however no raw data were available to justify changing
the category from BON to SKE

Up to 2007 permits were usually issued to export 2–4 bones per customer and these were probably the floating bones
from trophy animals. From 1990 to 2007 an average of five bones per year were exported, usually to the USA or
Denmark (also the most frequent hunting clients, along with Spain, to South Africa). In 2008 the first permits to export
bones to East–Southeast Asia from South Africa were issued and are reported as “35 & 15 bones to Viet Nam” on thepermits (records 1 and 2 respectively in Table 8). The quantities of 35 and 15 bones were actually the “bones of” 35 and
15 Lions (hence skeletons, not individual bones). Furthermore, as previously mentioned in the Introduction chapter,

14 “Bones” (BON) according to CITES (2010c) guidelines are “bones, including jaws”. The unit of measurement is the number

bones or the mass in kilogrammes thereof.

Bones of Contention: An assessment of the South African trade in African Lion bones

45

while the permits record “Viet Nam”15 as the importing country, “Lao PDR” is also recorded on the same permits. It
was thus presumed that Lao PDR was to be the final destination of the shipment and the records were amended
accordingly in this report to reflect “35 and 15 skeletons to Lao PDR” (Table 8).
Record 9 in Table 8 is for the export of 1573 bones weighing 107.5 kg (from North West province in 2009). By using
the regression in Figure A4 (Appendix 4) and Appendix 5, the shipment quantity of 107.5 kg was converted to an
equivalent of 11 skeletons. Similarly, the consignment of 250 kg of bone (from Free State in 2008) in Record 3 equates
to about 26 skeletons. In total, DEA and CITES records mistakenly reported that permits to export up to 2498
individual bones and 250 kg of bones were issued. The corrected records reveal that up to 48 bones (not skeletons, but
likely so – footnote in Table 8) and 177 skeletons were exported to Lao PDR, Viet Nam and China from 2008 to 2011
instead. The 177 skeletons are thus included in the analysis of the trade in skeletons.

EXPORTS OF LION SKELETONS FROM SOUTH AFRICA
Prior to 2008 the only record of South Africa having issued CITES permits to export skeletons was for three toDenmark in 2001 (Source: UNEP-WCMC CITES trade database). Furthermore, the worldwide exports of Lionskeletons from 1982–2000 only totalled nine and these were mainly to Europe.
In July 2008 South Africa issued its first permit to export Lion skeletons obtained from captive bred animals to
Southeast Asia; the destination of the cargo was mistakenly recorded as Viet Nam instead of Lao PDR and the quantity
recorded as 35 Lion “bones” instead of the “bones of 35 Lions” (i.e. 35 “skeletons”) (Table 8) (Anon., Issuing
Authority, in litt., 2013). A second permit was issued later in 2008, and the export destination and quantity were also
incorrectly captured – this time as “15 bones” to Viet Nam instead of “15 skeletons” to Lao PDR (Anon., Issuing
Authority, in litt., 2013). Thus by the end of 2008, permits to export 50 skeletons to Lao PDR had been issued – which
is a year earlier than the public were made aware of. The importer of both shipments was reportedly from the
Bolikhamxay Province, Lao PDR (Anon., Issuing Authority, in litt., 2013). Five months prior to the permit for 35
skeletons being issued however, a permit had also been issued to an importer in Bolikhamxay Province to receive “10skulls/skins” and “20 floating bones” (clavicles) – an amount that would have been derived from 10 Lions. Given thedate of this permit in early 2008, the Lao-based importer was in all likelihood making enquires about Lion bones inSouth Africa in 2007 or earlier, but whether illegal exports of bones actually occurred then is a matter of speculation.
However, some illegal trade in Lion bones is presumed to have occurred before 2009 when Nguyen van Hai wasarrested for being in possession of Lion parts without permits, and also given the presence of Xaysavang Company
representatives in South Africa from at least 2008 (see Introduction for details).
From 2008 to 2011 CITES permits issued to export Lion bones totalled 1160 skeletons (Table 9) (including ± 177
skeletons from Table 8). Lao PDR was the primary recipient of the bones (85%), followed by Viet Nam (13%). Permits
issued to Thailand and China were only reported in 2011. If the mean mass of a Lion skeleton is ± 9.28 kg (Box 4 inAppendix 4), then the exports are equivalent to 10 765 kg – over 10.8 tonnes in four years.
Table 9 Annual quantities of skeletons reported on CITES export permits issued by South Africa to East–
Southeast Asia.
Year
Lao PDR
Viet Nam
Thailand
2008
50
2009
197
2
2010
221
117
2011
519
32
20
Total
987 (85.1%)
151 (13.0%)
20 (1.7%)(Source: DEA annual CITES reports and the UNEP-WCMC CITES trade database)

China

2
2 (0.2%)

Total
50
199
338
573
1160

At the time of writing this report, the 2012 annual CITES reports compiled by DEA had not been completed. In theinterim, data collected on skeleton exports during the course of this investigation were added to Figure 20 to present the

15 The capital of Lao PDR is “Vientiane”, which sounds similar to “Viet Nam”. Several people interviewed for this study mademention of “Vientiane” but either (1) assumed it was a town in Viet Nam, (2) assumed Vietnam had been spelled incorrectly,or (3) said “that place Vientiane/Vietnam” as if they were the same places. Lack of familiarity with Lao PDR undoubtedly
resulted in some of the initial permit applications incorrectly listing the import country as Viet Nam instead of Lao PDR.

46

Bones of Contention: An assessment of the South African trade in African Lion bones

information known so far. These figures are incomplete, but show that at least 365 skeletons with a combined mass of2768 kg were exported to Viet Nam and Lao PDR in 2012 and 2013 (the official final numbers will be higher).
The only provinces issuing permits to export Lion bones to East–Southeast Asia are the Free State, North West andEastern Cape (24%, 67% and 7% of the skeletons recorded on the export permits respectively) (Table 10). These
provinces dominate the captive breeding/hunting industries (Figure 5) and all the skeletons are from captive bredanimals. It is important to note, however, that Lion skeletons exported from a particular province do not necessarily
originate there. “Bone agents” usually buy skeletons from willing landowners/sources in more than one province(Figure 28); the agents apply for permits from a province to export multiple sets of bones, irrespective of where theLion was hunted. Furthermore, some of the skeletons may not be from trophy hunted Lions and may be derived from
Lions that were put down or died from natural causes. Based on this, a recommendation from one interviewee is thatexport permits are only issued for carcasses with a complete set of supporting documentation in the province of its
mortality (see Recommendations).

Figure 20 The number of Lion skeletons recorded on export permits issued by South Africa to China (CN), Lao
PDR (LA), Thailand (TH) and Viet Nam (VN) from 2008 to 2011. The 2012 annual CITES report from DEA had notbeen released at the time of writing this report, hence the incomplete data for 2012 and 2013 were assembled
from information accumulated from multiple other sources. Vertical lines indicate years that measures wereadopted to protect Tigers and Asian big cats
Table 10 Number of skeletons recorded on the permits issued by three South African provinces to export Lionskeletons to East–Southeast Asia.
Year
Free State
2008
50
2009
41
2010
97
2011
105
Total
293 (25.3%)(Source: DEA annual CITES reports)

North West

Eastern Cape

132
214
436
782 (67.4%)

26
27
32
85 (7.3%)

Bones of Contention: An assessment of the South African trade in African Lion bones

Total
50
199
338
573
1160

47

EXPORTS OF LION TROPHIES TO EAST AND SOUTHEAST ASIA
In parallel with the increase in the rhino horn trade, there has been an increase in hunting by Asian clients in the last
decade (Milliken and Shaw, 2012). However, unlike rhinos where the main clients were Vietnamese “hunters”, themain importers of Lion trophies16 were Chinese customers beginning in 1999 (Figure 21). Even though the number ofVietnamese hunters reached new highs in 2010 (Table 5), the only reports of permits being issued to export Lion
trophies to Viet Nam occurred in 2008/2009 (Figure 21). However, permits issued to export Lion “trophies” to Lao
PDR have dominated trophy exports to East–Southeast Asia since 2010 despite there being no records of clients fromLao PDR having hunted in South Africa in 2009/201017. Vietnamese and Thailand nationals were convicted in South
Africa of illegally possessing Lion body parts and admitted to sourcing wildlife products for importers such as the
Xaysavang Company (see Introduction), hence the following question arises: was the purpose of some of the Lion hunts
by Vietnamese clients for legitimate personal reasons, or were they to supply Lao PDR’s established wildlife trade with
Lion body parts derived from seemingly legal hunts? If so, this latter scenario is similar to the rhino trade.

Figure 21 The number of Lion trophies recorded on export permits issued by South Africa to China (CN), Lao
PDR (LA), Myanmar (MM), Viet Nam (VN), and Thailand (TH). Vertical lines indicate years that measures wereadopted to protect Tigers and Asian big cats. For a complete enumeration of trophy exports to all countries, see
Figure 16.
Of the 241 reported Lion trophies destined for East–Southeast Asia from 1994 to 2010, 45% were for China, 38% for
Lao PDR, 14% for Viet Nam, 2% for Myanmar and 1% for Thailand. There are no records of hunters from Myanmar on
the official hunting registers of 2009/2010. Thus, questions arise as to the motives for five trophies being exported there
in 2011 (Figure 21). Interestingly, exports of Lion trophies to East–Southeast Asia increased markedly after the 2006–
2007 measures to protect Tigers and Asian big cats were adopted and the motives for these exports are also in question(Figure 21). However, not all hunting from Asian clients is to be regarded with suspicion since economic growth in
Asia is leading to increased levels of private wealth and thus more people can legitimately afford to hunt abroad forrecreational purposes (Zhilong, 2012).

16 A “trophy” (TRO) according to CITES (2010c) guidelines is: all the trophy parts of one animal if they are exported together:e.g. horns (two), skull, cape, back skin, tail and feet (i.e. total ten specimens) constitute one trophy. But if, for example, theskull and horns are the only specimens of an animal that are exported, then these items together should be recorded as one
trophy. Otherwise the items should be recorded separately. A whole stuffed body is recorded under “BOD”. A skin isrecorded under “SKI”.
17 The nationality of foreign hunting clients are recorded on a professional hunting register after a hunt, and these data arecompiled and sent to DEA annually. Data were only available for 2004/2005 and 2009/2010.

48

Bones of Contention: An assessment of the South African trade in African Lion bones

The North West province is the source of most Lion trophies exported to China, Viet Nam and/or Lao PDR. From 2006
to 2011, 52% of the trophies reported on permits were issued by the North West, 24% from Mpumalanga, and 15%
from the Free State (Figure 22). However, since Lion hunting is a rare event in Mpumalanga and is not permitted inGauteng, the Lions must have been hunted in different provinces. Permits issued for trophies do not necessarily reflect
the provinces the Lions were hunted in because trophies are routinely sent to taxidermists in a different province towhere the hunts occurred.

Figure 22 The proportion of trophies that China, Lao PDR and Viet Nam imported that were exported from thevarious provinces. The provinces from which trophies are exported do not necessarily indicate where the Lions
were hunted if the landowners and the taxidermists processing the trophies are in different provinces. (See Map
2 for abbreviations for the provinces)

COMBINED EXPORTS OF LION BODY PARTS TO EAST AND
SOUTHEAST ASIA
Exports of Lion products to East–Southeast Asia commenced in 1994 when Thailand was issued a permit to import one
Lion body (Figures 18, 23a, 24; Table 11). From 1993 to 1998 there was sporadic trade in live Lions, bodies andtrophies to China and Thailand (Table 11; Figure 24). The first noteworthy exports occurred in 1999 when permits toexport 6 and 15 live Lions to China and Thailand respectively were issued. The trade in Lion parts to East–Southeast
Asia maintained a steady flow from 2003 to 2005, after which exports increased to their second highest recorded levelin 2006.
The quantities recorded on export permits for Lion body parts to East–Southeast Asia in 2007 were marginally higher
than in 2006 (Figures 24). But in 2008 exports increased almost 6-fold from the year before. Not only did the number oflive Lion imports reach record levels, but also the first permits to export skeletons were issued. Similar to rhinos,
exports of Lion products grew exponentially from 2007 (Figures 23 & 24) – the same year that CITES approved
Decision 14.69 (CITES, 2007b) and the year after China implemented further regulations to protect Tigers and Asianbig cats (see Introduction; Tables 1 and 2). There thus appears to be a correlation with the rise in Lion product exports(especially skeletons) and the years that these protective measures were adopted (Figures 23 & 24). The upward trends
in quantities of all Lion products increased sharply after 2006, especially exports to Lao PDR.
Each of the four selected Asian countries has a different import pattern for African Lions and their body parts (Figure23). Lao PDR is clearly the dominant destination for Lion bones (Figure 23b) and 85% of all skeletons recorded onexport permits from 2008–2011 were destined there. The quantities of skeletons destined for Lao PDR is also 10 times
more than the combined quantities of skeletons destined for China, Thailand and Viet Nam. The next biggest importerof skeletons is Viet Nam with 13% of the total imports. China tends to import more Lion trophies and small quantities
of bones and bodies (Figure 23a), whereas Thailand tends to import live Lions and sporadically the bodies and trophies(Figure 23c). Viet Nam, like Lao PDR, only started importing Lion parts in 2008 and the total quantity of exports aresecond to Lao PDR.

Bones of Contention: An assessment of the South African trade in African Lion bones

49

Figure 23 Selected country comparisons of the quantities of live Lions (LIV) and Lion products (trophies, TRO;
skeletons, SKE; bodies, BOD) recorded on CITES export permits using the same y-axis as Lao PDR. Vertical lines
indicate years that measures were adopted to protect Tigers and Asian big cats

50

Bones of Contention: An assessment of the South African trade in African Lion bones

Table 11 Combined total number of quantities recorded on permits issued by South Africa to export Lioncommodities to China, Lao PDR, Viet Nam, Myanmar and Thailand from 1990
Year

Live

BodiesSkeletons

Trophies

1990

-

1991

-

1992

-

1993*

-

1994*

1

3

4

1995

-

1996

-

1997

-

1998

1

1999

21

2000

2

1
2

2002*

2
2003

2

2004

8

2005
2006*

1
13

2008

67

2009

5

2010

44

2011

2

2

5

7

1

3
8

14

2007*

23
2

2001

TOTAL

Total

1
10

6

7

8

22

7

30

50

27

145

199

38

242

338

67

459

42

21

573

75

711

219

36

1160

241

1656

* Years correspond with the measures adopted to protect Tigers and Asian big cats

Despite the large quantities of Lion bones exported to Lao PDR, there are no records on the UNEP-WCMC CITES
trade database of Lion products being exported from Lao PDR to neighbouring countries. Similarly, there are only one
or two records each of Lions being exported from China, Viet Nam and Thailand. This suggests that the products areeither consumed within the country or they are processed and channelled into the extensive regional wildlife trade andmoved across country borders illegally without CITES permits.

Bones of Contention: An assessment of the South African trade in African Lion bones

51

Figure 24 Combined quantity of live Lions and Lion products recorded on permits issued by South Africa toexport the products to China, Lao PDR, Thailand and Viet Nam (raw data in Table 11). Vertical lines indicate years
that measures were adopted to protect Tigers and Asian big cats

ESTIMATING THE RESERVES IN THE SKELETON RESOURCE BASE
The size of the resource base available from Lion trophy hunts from 1977–2010 was estimated to be 5000–6200
skeletons (Table 7). Before the Lion bone trade started in 2008, game farmers and/or taxidermists would have disposedof the Lion carcasses once the trophy component was removed from the body. If the skeletons were buried then theywould need to be exhumed to retrieve the bones, but it is doubtful whether landowners know the whereabouts of mostold carcasses obtained from hunting activities in the past. A component of the disposed skeletal reserves are therefore
irretrievable and probably unusable. Since the numbers of Lions being hunted are increasing annually, and more than
twice as many Lions were hunted in 2010 compared to 2004 (Figure 9), the numbers of skeletons available from hunted
Lions are increasing at a similar rate and creating a cumulatively larger annual reserve. Skeletons from some nonhunted Lions are also potentially available, but the size of this resource is unknown.
Estimates for the skeleton reserves presented in this section are for 2004 to 2010 and/or 2011, but the number ofskeletons estimated to have been buried or disposed of resulting from Lion hunting prior to 2004 exceeds 2100
carcasses (derived from Table 7).

1. Based on the number of Lions hunted: 2004–2010
The size of the skeleton resource base from 2004–2010 and the number skeletons not yet exported was estimated using:(1) figures for the number of Lions hunted until 2010 (obtained from national hunting register), and (2) the number ofLion skeletons reported on export permits issued to countries in East–Southeast Asia (Source: DEA and CITES trade
statistics). The following results were obtained:




52

The number of Lions hunted from 2004–2010 totals 2950 Lions; the number of skeletons recorded on export
permits from 2008–2010 is 587 – hence a difference of 2363 Lion skeletons in reserve that have not all been
exported (Figure 25, numbers below the axis from 2004 to 2010). Skeleton stocks disposed of before 2007
would need to be located and/or exhumed if required.
Assuming game farmers and breeders are only using the stock generated since the Lion bone trade commenced
in 2008, and at least 1435 Lions were hunted from 2008–2010, then there is difference of 848 Lion skeletonsin reserve that have probably not all been exported and would not necessarily require locating before being
exported (Figure 25, numbers below the axis from 2008 to 2010).

Bones of Contention: An assessment of the South African trade in African Lion bones

Figure 25 The difference between the number of Lions hunted and the number of Lion skeletons reported onexport permits for 2004–2010. The annual differences below the axis indicate the number of skeletons that havenot been exported and are in reserve. (Years in italics) (Source: see text)
Not all skeletons recorded on the permits are exported and not all farmers sell the bones. Furthermore, there are also
skeletons from non-hunted Lions that contribute to the national reserve. Therefore, the number of skeletons in reservethat have not been exported is larger than the estimates presented here. Hence, the exports are currently less than what
can be supplied and there is still a large surplus of Lion skeletons in South Africa. Since these animals are mostly
captive bred, there is inferred to be little impact on wild Lion populations in South Africa. In other African countries,
however, hunting is reportedly of wild Lions and the potential impacts of the Lion bone trade on wild populations
outside of South Africa are likely greater if wild Lions are hunted to supply bones to Asian markets in addition to being
hunted for trophies.

2. Based on the number of trophies exported: 2004–2010
Figure 25 above represents a conservative scenario for the size of the skeleton resource base. In the previous chapter thediscrepancies between the number of animals hunted and the number of trophies recorded on export permits indicatedthat more Lions were being hunted than were being declared on the hunting registers. If true, then the discrepancies also
indicate that the number of skeletons in reserve is even larger than that inferred from Figure 25.
By comparing (1) the number of trophies recorded on export permits from South Africa until 2011 (to get an upperbound estimate of the number of Lions hunted), with (2) the number of Lion skeletons reported on export permits
issued to countries in East–Southeast Asia (obtained from DEA and CITES trade statistics), the following results wereobtained:The number of Lion trophies from 2004–2011 totals 4951; the number of skeletons recorded on export permits
from 2008–2011 is 1160 – hence a difference of 3791 Lion skeletons in reserve that have probably not all
been exported (Figure 26, numbers below the axis from 2004 to 2011).
Assuming that farmers are only using the stock generated since the Lion bone trade commenced in 2008, andthere are 3322 Lion trophies from 2008–2011, then there is a difference of 2162 Lion skeletons that haveprobably not been exported and would not necessarily require locating before being exported (Figure 26,
numbers below the axis from 2008 to 2011).

Bones of Contention: An assessment of the South African trade in African Lion bones

53

Figure 26 The difference between the number of Lion trophies and the number of Lion skeletons reported onexport permits for 2004–2011. The annual differences below the axis indicate the number of skeletons that havenot been exported and are in reserve. (Years in italics) (Source: see text)
As the number of skeletons exported to East–Southeast Asia increased from 2008, the size of the annual skeleton
reserve in a calendar year decreased correspondingly (“difference” in Figures 25 & 26). At a national level, thecumulative size of the skeleton surplus appears large enough to continue to supply the market for skeletons. However
not all farmers sell their Lion skeletons, whether they are derived from hunted or non-hunted Lions or not. Thus an
unknown proportion of the skeleton surplus is not for sale. Furthermore, if there are preferences in Asian markets for“fresher” bones with more bone marrow and soft tissue then importers will be more partial to purchasing bones fromnewer bone stocks and bones derived from hunting activities in previous years are less likely to be sold. But since there
are reports of farmers exhuming old bones, it is unclear how much one should disregard the value of old stock.
At the landowner level, stocks of Lion skeletons will continue to grow annually on properties where farmers don’t sellbones, but the size of the surpluses might decline on properties that regularly supply the trade. If the demand in East–
Southeast Asia continues to increase, then a scenario might arise whereby fresh skeletons are in short supply despite thenational surplus. Various concerned people have been quoted in the media as saying that farmers would probably meetthe demand for Lion bones by resorting to culling healthy Lions. Alternatively, that they (farmers) would increase
reproductive rates in their breeding stock to grow the necessary numbers of Lions as is the practice in Tiger farms.
However, some landowners have denounced these allegations by saying that the bone trade is an opportunistic businessventure whereby more profits are made from selling the Lions twice. Their primary income is made from selling a Lionto a hunter, and a secondary income is generated from selling bones that would have otherwise been disposed of. Under
this scenario, operators might increase the marketing of Lion hunts to foreign hunters to generate an additional supplyof trophy animals and thus carcasses. But, captive females that aren’t hunted are allegedly at risk of being culled. Where
previously there was no value in the skeleton, a consumptive and thus monetary value now exists (see later chapter on
the value of the trade).
Another concern raised is that landowner “Diversification into a lion bone industry…carries the risk of not only
creating but fuelling demand for lion bones in Africa. This in turn creates the obvious risk that merchants may wellchoose to buy wild lion bones from poachers for much lower prices than their captive breeder rivals are charging”(Hargreaves, 2010). While there are reports that these risks exist in several African Lion range countries, in South
Africa, however, there is presently no evidence of increased levels of Lion poaching, and especially not at a rate that
could supply the current export market maintained by the captive breeding and trophy industries. Furthermore, it seems
as if the prices paid in South Africa are not an incentive to poachers (see later chapter on the value of the trade). From
all the discussions held with conservation officials it also appears that the least likely scenario at present is that Lion
poaching in South Africa would increase – this is partly because bone stocks from captive animals are ample, and old

54

Bones of Contention: An assessment of the South African trade in African Lion bones

stocks would be located and/or exhumed if necessary. However, this situation seems to be specific to South Africa
currently and future trends have not been extrapolated.

© ANDREW J. LOVERIDGE

Bones of Contention: An assessment of the South African trade in African Lion bones

55

EXPORTERS, IMPORTERS & TRADE
FLOWS
The authors have not clearly established what happens to Lion bones once they reach East–Southeast Asia. The Asianbased networks and syndicates that trade in Lion products are worthy of further investigation and are presumably
similar to those for other Asian wildlife, especially big cats (Figure 27). Since wildlife trade often makes use of
established networks and supply lines, the Lion bone trade may have piggy-backed on existing wildlife routes in Lao
PDR, Viet Nam, China, Thailand and Myanmar. A description of the trade chain in the flow of Tiger parts andderivatives from source to consumer is illustrated in a report by TRAFFIC (2008, Figure 21, pg 39–41), and the Lion
products exported to East–Southeast Asia are likely to end up in parts of that chain. On the South African side, asimplified representation of one aspect of the trade chain from the landowner/breeder to the airline is depicted in Figure
28 and the text that follows. The routes followed by South African traders appear to be relatively more transparent andthere is presumed to be more legal than illegal trade.

Figure 27 Regional trade flows and trafficking routes for Asian big cats and other wildlife. Lion bone shipments
could follow similar established routes after the cargo is flown to airports in Vientiane, Hanoi, Ho Chi Minh City
and Bangkok. Map derived from Nooren and Claridge (2001) and UNODC (2010, 2013)56

Bones of Contention: An assessment of the South African trade in African Lion bones

Figure 28 Several simplified scenarios of trade flows for Lion bones from the landowner/game farmer/breeder todestinations in the East–Southeast Asia. Airlines are used as an example of a cargo carrier through a gateway
such as OR Tambo International Airport (ORTA), but shipping companies at seaports such as Port Elizabeth
could also be (and are known to be) used as exit points. One interviewee estimated than 99% of Lion skeletons
exit South Africa via ORTA (Anon., pers. comm., July 2013). These scenarios were derived from interviews withpeople in the freight forwarding industry
Trade flows and terminology within the airfreight business are relatively complex. The main actors and their roles
within the bone trade are simplified and summarized as follows:

Landowner: the owner of the facility that breeds and/or allows Lion hunting on the property and thus has bones
for sale. Not all landowners with Lions will sell the bones, and there is anecdotal evidence that some farmers
destroy carcasses after the Lions have been hunted. Landowners are sometimes, but not always, listed as theexporters on the CITES permits.

“Bone agent”: an enterprise or individual who sells the bones to a customer in East–Southeast Asia and who isusually listed as the “exporter” on the CITES permit and the “consignor” on a waybill. “Bone agents” mostly buy

skeletons from farmers and then prepare them for export18. The agents must submit all the necessary paperwork
to the freight forwarders before the export can proceed including the CITES permits, a taxidermy certificate(usually indicating that the consignment consists of “partially processed trophies”) and a certificate from the
18 Mouton (2013) reported that one taxidermy studio north of Pretoria exports around 200 skeletons annually to Viet Nam,which they mostly buy from farmers. The Vietnamese, the bone agent said, “want us to bake the bones, rather than boil
them to get the meat off…They want the cartilage between the ribs that disappears when you boil it”.

Bones of Contention: An assessment of the South African trade in African Lion bones

57

State Veterinarian. The “bone agent” doesn’t necessarily own land and Lions, but they may act as their own
agent for skeletons from their own property. In terms of TOPS regulations, they could also be called “wildlife
products traders” since they engage in the business of acquiring and sourcing dead specimens of listed
threatened or protected species with the express intention to trade the specimens for commercial purposes.
Taxidermists may act as bone agents.

Customer/buyer at a destination in East–Southeast Asia: the customer/buyer to whom the bone agent and/or
landowner sells the bones is listed on the CITES permit as the “importer”, and on the airline waybill as the“consignee”. The importer most frequently reported by the Department of Environmental Affairs for 2009 and2010 (National Assembly, 2011d) is the Xaysavang Company from Paksane, Lao PDR.

Freight forwarder: also known as forwarding and shipping agents, the forwarder is a person or company whoorganizes the transport and shipment of the bone consignment on behalf of the bone agent so that the cargoreaches the customer in the East–Southeast Asia. Forwarders contract with a particular carrier (e.g. an airline orshipping company) through a ground handling agent (GHA) to transport the consignment to the destination.
First, however, the forwarder contacts the GSA (General Sales Agent) of the airline and buys cargo space for theconsignment. The forwarders also prepare and process the necessary documentation including generating the
air waybill (AWB). Thereafter, the forwarder takes the cargo to a GHA. In some cases, a forwarder may take thebones to a second forwarder first (e.g. bones exporter using Airline 5 in Figure 28)
Ground handling agent (GHA): GHAs are responsible for handling cargo on behalf of a specific airline. An airline
will only be the client of one GHA at a time. Some airlines such as South African Airlines and Lufthansa, however,are “self handling agents” – i.e. they do not require the services of a private GHA, and the freight forwarder cantake the cargo directly to them (Airline 7 in Figure 28). Thus, the GHA takes the consignment of bones delivered
to them by the forwarder, keeps it in a warehouse, and then takes the cargo to the aircraft once the necessary
documentation has been generated, checked and the cargo inspected. If the GHA has been directed by theSouth African Revenue Service (SARS) to notify them of certain types of cargo, then a Customs representativefrom SARS will check the consignment. The GHA will also notify the relevant authorities if they notice anythingsuspect or if they do not understand the documentation.
In a simple linear trade flow (e.g. Landowner 4 to Airline 6), the landowner/breeder sells the bones to a bone agent. The
bone agent has probably already arranged for the sale of the bones to an Asian buyer. The agent or the landowner will
apply for a CITES export permit from the Issuing Authority of the relevant province. The permits usually name thebone agents as the exporter and the Asian customer as the importer. Thereafter, the agent takes the cargo to a freight
forwarder, who chooses a GHA. If the GHA only has one airline as a client (which they generally don’t – e.g. Freight
Forwarder 2 in Figure 28), then the GHA will generate the necessary documentation (including the air waybill) and
implement the necessary cargo checks, and then load the cargo on to the airline.
In a less linear trade flow the landowner could sell to more than one bone agent on different occasions. Furthermore,
there is anecdotal evidence that the bone agents do not routinely choose the same freight forwarding company –possibly so as not to draw attention to their potentially controversial activities (which freight forwarders speculate
happens), but also to go with the carrier that has the cheaper rates. Consequently, consignments of Lion bones could
leave South Africa via different gateways and carriers at different times depending on the freight forwarder that thebone agent chooses. This scenario is not unlike wildlife traders in East Asia, for example, who are reported to changeroutes opportunistically to take advantage of new infrastructure, to reduce transaction costs or avoid detection byauthorities (UNODC, 2013).
It was reported during interviews that some bone agents consolidate skeletons purchased from different landowners andship them as one consignment. One example described by an interviewee is depicted in Figure 29; the diagram shows
how Lion bones that were part of a consignment shipped to “Asia” were obtained by a bone agent from threelandowners in two provinces and were reportedly sent to two different importers at the same address (Anon., pers.
comm., April 2013). And, while the landowner’s names appeared on the permits, there was no link to a hunting permitor the cause of Lion mortality. Several people expressed concerns that it is sometimes not feasible to traceconsignments of Lion bones back to their original source, nor to determine the cause of Lion mortality, when permits
restricting various activities with respect to Lions are missing and/or not required before exports can proceed. In orderto improve transparency within the bone trade, it was recommended by one interviewee that a system be put in placethat enables the identification of individual Lions from birth to death and to link this to any activity involving those58

Bones of Contention: An assessment of the South African trade in African Lion bones

specific Lions so that all exported skeletons and trophies can be traced back to the original source and mode ofmortality. In the context of the current regulatory and compliance monitoring frameworks, the feasibility of such asystem should be critically assessed.
In summary, the trade in Lion bones is mainly conducted through middlemen or “bone agents”. Skeletons are typicallysold to bone agents by landowners, breeders and other facilities, and then freighted to East–Southeast Asia. The numberof landowners selling bones and the size of the supply base is unknown. Of the bone agents, there are only 12 known
South African exporters: DEA published six of the 12 names in 2011 (National Assembly, 2011d), five names werementioned in confidence during the interviews with various conservation and law enforcement officials, and one
company was mentioned in a 2013 online newspaper article (Mouton, 2013). People who exported bones in the past are
not necessarily active at present. Apart from the Lao-based Xaysavang Export-Import Company (EIA, 2014b; National
Assembly, 2011d; Rademeyer, 2012a; court judgements in Chunchom and Lemtonghtai’s trials) not much is known
about Lion bone buyers in Viet Nam, Thailand and China. This is largely because the information is confidential. From
the discussions, however, it seems that most of the consignments exported to Lao PDR go to the same addresses, but thename of the importer is allegedly not always the same.

Figure 29 Example of a consignment of 66 Lion bones exported to an Asian country in 2012 that demonstrates
how the “bone agent” consolidated the consignment (Anon., pers. comm., April 2013)
Finally, the Xaysavang Network, believed to be led by Vixay Keosavang, is an international wildlife trafficking
syndicate that facilitates the killing of endangered animals for products such as ivory and rhino horn (U.S. Departmentof State, 2013). Given Xaysavang’s well established links to the Lion bone trade in South Africa, it is unlikely that

Bones of Contention: An assessment of the South African trade in African Lion bones59other Laotian-based companies are procuring the bones. Accordingly, it would appear that some South African bone
agents are dealing directly with this company – which, given the mostly legal trade in South Africa using CITES
permits, is an unusual juxtaposition of interests. What is more, some conservation and law enforcement officials believethat there is some overlap in the landowner supply base trading in rhino horns and Lion bones, in the wildlife products
traders/agents acting as middlemen, and the Asian importers of rhino and Lion products (Interviews conducted from
May–July, 2013). The Xaysavang company, however, is not the only importer of Lion bones and there are, as yet,
unnamed importers purchasing unknown quantities of bones in Viet Nam, Thailand and China.

60

Bones of Contention: An assessment of the South African trade in African Lion bones

VALUE OF THE LION BONE TRADE
There are at least two tiers to the South African Lion bone trade chain to consider when determining the value of thebones: (1) the prices paid to landowners for skeletons by the bone agents, and (2) the prices paid to the bone
agents/wildlife-traders/intermediaries by the Asian importers. One must be cautious, however, when evaluating theSouth African side of the chain not to erroneously use the same US dollar prices that are allegedly paid for parts andproducts once they enter the markets in East–Southeast Asia. Once skeletons reach the Asian market, the values of thebones and derivatives increases incrementally along the sale and resale supply chain from importer  wholesaler
and/or trader and/or manufacturer  middlemen and/or retailer  consumer, but there are no consistent and credible
benchmark values by which to estimate the gross worth of the trade in Asia at the various levels of the chain.
In South Africa, the value of a Lion skeleton is also determined by the completeness of a “set” – i.e. whether the skull
and/or bones from the limbs are included. Bones from Tiger limbs (especially kneecaps) and the skull are highly valued
in TAM and a premium is paid to sellers accordingly if these bones are present in a set. The 2013 price paid to South
African farmers/landowners by the bone agents was ZAR12 000–ZAR15 000 (USD1260 to USD1560) per set withoutskulls, and up to ZAR18 000–ZAR20 000 (USD1890 to USD2100) per set with skulls (depending on the size of theskeleton) (Anon. quoting a South African bone agent, pers. comm., July 2013) (Table 12). Thereafter, the bone agents
charge the importers a fee of about ZAR3000 (USD315) per set, not all of which is profit since the agent has toorganize for the export of the consignment.
Table 12 Various prices reportedly paid to South African landowners, breeders and/or bone agents for sets ofLion bones
Year
2013

Reported valuei) Excluding skulls: ZAR12 000 to ZAR15 000 (USD1260–
USD1560) per set (depending on size and completeness)ii) Including skulls: up to ZAR18 000 to ZAR20 000(USD1890–USD2100)

2012??

2009 –
2010i) Excluding skull and feet: ZAR1000/kg (USD130/kg) forbones (equates to ZAR9300 per set*).
ii) Including skull and feet: an extra ZAR5000 (USD650)
added to the purchase pricei) Excluding skull and feet: ZAR10 000/set (USD1300) of
bones.

Notes
The going rate paid to thelandowner per set.
Bone agents add a mark-up of±ZAR3000 (USD315). Once theskeletons reach the “Far East”
they will fetch upwards of
USD10 000
A Free State farmer was paid
ZAR60 000 (USD7800) for 12 setsof bones (ZAR5000/set), but thebones were small and some were
missing
Information contained inaffidavits leading to the arrest of
Punpitak Chunchom andChumlong Lemtongthai

SourceAnon. (pers.
comm. July2013) (quotefrom a South
African bone
agent)
Rademeyer(2012a)Macleod (2012b)ii) Including skull and feet: extra ZAR5000 (USD650)
added* Assuming a mean skeleton mass of 9.28 kg per skeleton (for lions of mixed age, sex and completeness) (see Box 4 inAppendix 4)

Bones of Contention: An assessment of the South African trade in African Lion bones

61

The prices paid for South African Lion bones were first alleged by the media to be ZAR600–R800/kg (USD72–
USD96/kg) in 2009 (Smith, 2009). In affidavits leading to the arrest of Punpitak Chunchom and Chumlong
Lemtongthai for organizing illegal rhino poaching expeditions, they stated they were buying Lion bone sets for about
ZAR10 000 (USD1300) each from game farms in the Free State and North West, and paid an extra ZAR5000(USD650) if the skull and bones from the feet were present c.2009–2010 (Macleod, 2012b) (Table 12). Rademeyer(2012a) cites a similar figure, but also reports that the going rate was ZAR1000/kg (USD130/kg) plus an extra
ZAR5000 (USD650) if the skull and feet were intact (Table 12). However, a Free State farmer was paid ZAR60 000 for
12 incomplete sets of bones (about ZAR5000 each) by the same buyers (Rademeyer, 2012a). The Chairman of theSouth African Predator Breeders Association (SAPBA) said that of the ±800 Lions hunted on the farms he was awareof, the total annual value of bone sales to the farmers was ±ZAR20 million (which translates to ZAR25 000/skeleton)(USD2.45 million total, or USD3060/skeleton) (P. Potgieter, pers. comm., June 2013) [Note: no time period was given
for these sales]. This latter total value probably included the fees paid to the bone agents and may be the combined
value for landowners and bone agents.
The alleged value of Lion bones once they reach the Asian supply chain is mostly anecdotal and unconfirmed. A set of
Tiger bones was quoted to be worth as much as USD7000 each c.2011 (Graham-Rowe, 2011). Given that Lion bones
are sold into Asian markets as Tiger bone fakes, the resale values along each tier of the supply chain equates to apotentially high-value business. Lion Aid (2012a,b,c) reported on the following values for Lion bones in 2010, 2012
and 2013:2010: USD300/kg or USD4000 per skeleton “in the Asian countries” (Lion Aid, 2012a);
2012: USD10 000 (ZAR84 000) per skeleton in Asian countries (Lion Aid, 2012a)
2012: A minimum value of USD15 000 per skeleton earned by wildlife traffickers in Lao PDR (Lion Aid,
2012b);
2013: USD400–USD500/kg for captive bred Lion bones, and a skeleton is worth USD15 000 to TCM
practitioners (Lion Aid, 2012c).

The value of a set of Lion bones in South Africa is substantially less than USD10 000 to USD15 000 per set that isfrequently alleged to be paid. Ascribing such erroneously high values on the South African side of the supply chain
would make it seem plausible that poaching wild Lions would be a cheaper alternative to sourcing the bones fromhunted captive animals and thereby incentivize illegal hunting – which appears not to be the case in South Africa.
However, the relatively low prices paid for South African Lion bones could potentially promote a sustained demand to
supply an allegedly lucrative Asian market with Tiger bone fakes that are sold at high prices in black markets.
The value of bones generated as a secondary by-product of the trophy hunting industry has allegedly motivated farmers
to dig up previously discarded carcasses originating from trophy hunts and captive mortalities. Whereas female Lions
formerly had little or no value to breeders from a trophy hunter’s perspective, the emergence of a market for bones has
generated a previously overlooked value for females. There are concerns, however, that the breeding cycle of thefemales will be abused to generate additional income for the farmer. From discussions with the various provinces, theseconcerns are supported by anecdotal evidence – but these practices appear to be in the minority for the time being.
Further concerns about the breeding of Lions specifically for the income generated from the bone trade have beenraised. What the representatives from the various provinces and the Department of Environmental Affairs are clear on is
this: there is no economic incentive to farm Lions solely for the bones, especially given the costs involved in raising
Lions and the current prices paid for skeletons. The bones alone are worth, at most, ZAR20 000 for a complete skeleton,
whereas a trophy hunted male Lion of at least six years old will generate ZAR160 000 to ZAR170 000 (USD16 800–
USD17 900). That the farmer can sell the bones is of secondary benefit to their operation, but it makes no businesssense for them to put down a male and thus forfeit about ZAR142 000 (USD14 900) in the process. Females are,however, at risk of this practice since a farmer will only get ZAR30 000 to ZAR40 000 (USD3150–USD4200) for her
from a trophy hunter. Also at risk are juvenile Lions where cumulative expenditure on their rearing is still relatively
low. However, current data suggest that it is the skeletons from adult Lions that are mainly being exported (see Table
A16 in Appendix 4 for average mass of exported skeletons). Hence, monitoring of Lion breeding facilities is arecommended step to restrict opportunities for abuse of the system for financial gain.
The global illicit wildlife trade (excluding timber and fish) was estimated to be worth one-third of the legal trade, which
put it in the range of USD7.8–USD10 billion (Haken, 2011). By contrast, Nguyen (2008, cited in Drury, 2009)
estimated that revenues from Viet Nam’s illegal wildlife trade are 12 times greater than revenues from the legal trade.
The Lion bone trade in South Africa is regarded as mostly legal; some predator breeders have reportedly said that they
do not release Lion bones unless they come from legally hunted Lions (Liou, 2012). Therefore revenues generated fromthe legal trade in bones in South Africa will probably be larger than those generated by the existing illegal trade, butthese values have not been determined as yet.

62

Bones of Contention: An assessment of the South African trade in African Lion bones

ILLEGAL TRADE IN LIONSINTRODUCTION
Transnational wildlife crime syndicates often establish and maintain vast trade networks, usually in developing
countries where they can evade trade tariffs and environmental regulations by exploiting regional weaknesses in law
enforcement, border and Customs control and the corruptibility of people within the public and private sector (Haken,
2011; Hübschle, 2013). The Lion bone trade in South Africa is juxtaposed within such a network of dealers that operate
both illegally and legally. The illegal trade in Lions in South Africa usually involves restricted activities for which
offenders are not in possession of permits to breed, keep, hunt, catch, sell, convey or export live animals or parts
thereof. Cases involving illegal trade are detected, frequently at airports, when persons found in possession of Lionparts do not have the necessary CITES permits. Incidents of confiscations, seizures and/or prosecutions from illegal
international trade and possession of wildlife are reported annually on the CITES UNEP-WCMC trade database and by
TRAFFIC (TRAFFIC, 2013b).
The number of confiscations/seizures of African Lions (live and parts thereof) reported to CITES totalled 199 incidents
worldwide from 1982 to 2011 (Figure 30) (Source: UNEP-WCMC CITES trade database). Lion trophies, skins, live
animals and claws were the most frequently seized products. None of these incidents involved countries in East–
Southeast Asia as the importer, but China and Thailand were the exporters in five cases. The USA was reported as theimporter in 57% of the total seizures, and South Africa was the exporter in 43 (22%) seizures (Figure 30). The
commonly seized products originating from South Africa were trophies, skins and claws. These results, however, must
be viewed in the context of the sources for this information: many countries do not include records of confiscations on
their annual reports to CITES, and the USA has a long history of providing this information to CITES (Nowell and
Pervushina, 2014). Therefore, while CITES seizure records are a useful measure of illegal trade and are suggestive of
enforcement effort (Nowell and Pervushina, 2014), more incidences of confiscations occur than are captured on the
CITES trade database.

Figure 30 Number of African Lion confiscations/seisures (live and body parts) recorded over three decades
across the world (Total) and where South Africa is identified as the exporter. The mean annual number ofconfiscations per decade is in brackets. (Source: UNEP-WCMC CITES trade database) Note: many countries do

not include confiscations in their annual reports to CITES (Nowell and Pervushina, 2014), hence these data are asubset of the total unquantified number of seizures worldwide

Bones of Contention: An assessment of the South African trade in African Lion bones

63Trends in confiscations indicate an increase in the average annual number of incidences reported worldwide to CITESin the last 13 years (Figure 30). This trend is indicative of both the increase in illegal trade and the detection thereof.
The number of seizures of Lion parts in the forthcoming decade looks set to be greater than the number reported from2000–2009.
Selected cases of seizures and prosecutions that took place from 1997 are compiled and published by TRAFFIC
annually. Incidents involving African Lions that were detected outside South Africa from 1998 to 2013 are listed inTable 13, for example in 2001 an Asian national was detained at Hong Kong International Airport for being inpossession of Lion body parts originating in South Africa. In 2009 Chinese nationals were arrested in Tanzania and
Kenya in possession Lion claws and/or teeth.
Table 13 Cases of seizures and prosecutions outside South Africa relating to Lion products
TypeYear ofincident
1996
1998
2001

Place ofarrestMozambique
BelgiumHong Kong

Body

2003

UK

Live
Trophy2004
2008

Indonesia
FranceClaws and
teeth
Teeth
Skin
Skin andhead
Skull
Skeletons

2009

Tanzania

2009
2010
2010

Kenya
Gabon
Swaziland

2010
2011

UK
Viet Nam

Body
Not specified

2012
2013

Indonesia
Republic ofGuineaLive
Skull
Body andbones

Description
6 Lions from a circus. Allegedly transported wildlife in contravention of CITES.
1 skull; origin and source unknown
Customs officers at the airport discovered the stuffed head of a male adult Lionwith its skin, four limbs and tail still attached in a box carried by a businessman
arriving from Johannesburg. The man claimed the specimen, which weighed
11.9 kg and measured 3.32 m from head to tail, was for decoration in his home.
An export permit had been issued by South Africa but the traveller was unable
to produce an import permit.
After examination of a hunting trophy shipment in transit from Zimbabwe tothe USA, an adult stuffed Lion was seized owing to the absence of CITES
permits.
Lions seized at an animal rehabilitation centre. Owner didn’t have licence.
2 stuffed Lions were seized from a taxidermist’s premises. The taxidermist was
unable to produce the requisite CITES permits.
4 people were arrested in Dar-es-Salaam airport on suspicion of trying to
smuggle ivory to China. The suitcase contained 60 Lion claws and teeth.
Three Chinese men destined for China charged with illegal possession of teeth.
Raids conducted by government officials yielded a portion of Lion skin.
Two siSwati ladies were arrested and later prosecuted for being in possessionof Lion skin (for local use for traditional medicine).
The skull of 1 cub smuggled from South Africa.
Searches at properties in Ho Chi Minh City turned up large amounts of wildlife
bones and processed animals. DNA tests concluded that items included theskeletons of 6 Lions
1 stuffed Lion seized from the premises of a taxidermist
A man prosecuted for the illegal trade in Lions (and other species) over the
past decade(Source: TRAFFIC, 2013b)

Published incidences of illegal trade in Lions and their parts that were detected in South Africa were obtained fromTRAFFIC (2013b), government documents and media reports (Table 14). The first arrest (and subsequent prosecution)of an Asian national in South Africa was the Vietnamese man (Nguyen van Hai) in 2009 (Table 14). Other undetected
and/or unreported incidences involving restricted activities occurring without permits are known to have occurred from
anecdotal reports and personal observations. Examining the cases listed in Tables 13 and 14, it appears that incidencesof Asian nationals trying to smuggle African Lion body parts (especially bones) into their respective countries werereported with increasing frequency from c.2009. While undetected illegal trade in Lion bones to South-East Asia islikely to have occurred before 2009, the year this trade was initiated is unknown.

64

Bones of Contention: An assessment of the South African trade in African Lion bones

Table 14 Published incidences of illegal activities pertaining to Lions reported in South Africa. This list excludes
incidences reported during interviews with provincial law enforcement and conservation officials
Type
Poaching

Year ofincident
2004

Poaching

2006

Poaching

2008

Translocationc.2008

Traditional
medicine

2008

Traditional
medicine
Carcass parts
and bones

c.2008

Carcass parts

2010

Gauteng

Carcass parts
and bones

2011

Gauteng

Translocation

2012

Northern
Cape and
Botswana

2009 –
firstreportedcase

Place ofincident
KrugerNP
KrugerNP
Kruger
NP
Free
State
KwaZuluNatal
KwaZuluNatal
Gauteng

Traditional
medicine /poaching

2014

KwaZuluNatal

Hunting

GeneralPoaching

GeneralPoaching

General

Muthi

General

Trade

GeneralTranslocation

GeneralSouth
AfricaSouth
AfricaSouth
AfricaSouth
AfricaSouth
AfricaSouth
AfricaDescription

Reference

1 Lion poached that year in the park. No indication ofwhether arrests were made.
3 Lions poached that year in the park. No indication ofwhether arrests were made.
3 Lions poached that year in the park. No indication ofwhether arrests were made.
7 illegally translocated Lions seized while in transit to theNorth West province
A Pietermaritzburg Sangoma (traditional healer) sentenced
to community service for being in possession of Lion andleopard skins
Uncovered poisons used to kill Lions for skins, teeth, claws,
fat and tails
Vietnamese man (N. van Hai) arrested in Pretoria after
allegedly “slaughtering” several Lions on residential
premises. There were 13 Lion heads and several Lion teeth.
He was arrested on five charges of contravening NEMBA by
being in possession of “threatened/protected species
without permits” and deported
A range of animal parts, including Lion, was confiscatedfrom Asian and traditional healers during a police operationthat involved INTERPOL and nature conservation groups
Two Thai men (P. Chunchom and P. Thongphai) arrested in
Edenvale (near Johannesburg) with 59 Lion bones without apermit. The bones were mostly claws and paws parts. They
admitted to police in an affidavit that the Lao-based
Xaysavang Company employed them and received fines of
ZAR10 000 and deported. Chunchom was subsequently
wanted by INTERPOL
Report of SA farmers smuggling adult wild Lions and cubsfrom Botswana in to the Northern Cape via cattle-rustlingroutes. The article alleges that smuggling was occurring “toNational Assembly(2008)
National Assembly(2008)
National Assembly(2009d)Abader (2009)
Anon (2008)

Abader (2009)
Miller (2009)
Otto (2009b)

TRAFFIC (2013b)

Du Plessis (2011a,b)South African
Revenue Service(2011)
http://www.interpol.int

Macleod (2012a)

supply a growing demand for lion bone potions in the Far
East”. The article further alleges that smuggling frequency

increased from c.2007, and that Lions supply captive
breeding facilities.
Male Lion in Tembe Elephant Park caught in snares and thehead cut off for suspected traditional medicine (“muthi”)
purposes. A Lioness was also caught in the snares but was
not decapitated.
See Box 3
See Box 3
Poaching is a problem in some provinces. Snares at borderfences are removed on a routine basis during patrols.
See Box 3
See Box 3
See Box 3

Bones of Contention: An assessment of the South African trade in African Lion bones

Mngoma (2014)

CITES Scientific
Authority (2013)
CITES Scientific
Authority (2013)
CITES Scientific
Authority (2013)
CITES Scientific
Authority (2013)
CITES Scientific
Authority (2013)
CITES Scientific
Authority (2013)

65

REPORTS OF ILLEGAL ACTIVITIES AND TRADE WITHIN SOUTH
AFRICA

1. Interviews with provincial nature conservation and law enforcement
officials
Several incidences of illegal activities and trade were reported during more than 15 hours of interviews with various
provincial conservation and law enforcement agencies. Some of the salient points that emerged from these interviews
were also mentioned in a report by the CITES Scientific Authority (2013), hence a section of the Scientific Authority’sreport is quoted in Box 3. One of the most revealing statements made during the interviews by a law enforcement
officer with respect to “canned” hunting and the Lion bone and rhino horn trades was: “…everyone is too afraid of thisindustry. This industry is like the mafia. If you’re on the right side, you’re alone. If you’re on the wrong side, there’s
lots of people with you…” (Anon., pers. comm., May 2013).

2. Interviews with the NSPCA

The discussion with the NSPCA19 was lengthy. Some of the points raised during the discussion did not arise during theinterviews with other research participants, including:






Some exporters are allegedly selling re-used permits for about USD100
Poaching and illegal translocation: a case in South Africa in 2012 when a Lioness in Kgalagadi (on the
Botswana side) was killed and two cubs taken and illegally smuggled to an unknown farm in the Free State.
The breeder wanted the wild genes to strengthen the genetic diversity of his stock.
There are very few instances of poaching of wild Lions in South Africa, and hence there is little threat to wild
populations with respect to the bone trade. Wild Lions are safer than captive Lions, but concerns about animal
rights and the welfare of Lions in captivity have been raised. The legislation allows farmers to breed Lions, butsome regulations in some provinces do not allow for the humane treatment of the animals. For example: cubs
are taken away from the Lioness too early to force them into frequent oestrus; females are bred repeatedly andend up in poor physical condition; inbreeding depression causes deformations etc. When it comes to the Lionbone trade, these weaker individuals are dispensable and likely to be put down.
There is a need to investigate the Lion trade in Namibia, Botswana and probably Mozambique because
poached Tanzanian Lions transit through Mozambique.

3. Interviews with various people who requested anonymity
There are a diversity of people at the coalface of the legal trade and illegal trafficking of wildlife as participants,
witnesses or stewards. For a variety of reasons they requested anonymity. Sometimes the incidents reported here are
primary or secondary accounts, and sometimes the incidents were mentioned by more than one source. The illicit
activities reported include:








Attempts at smuggling rhino horns by wrapping them in Lion skins from trophy hunts;
Tiger cubs falsely declared as dogs to avoid having to acquire a CITES permit;
Lion cubs declared as dogs in a container of live birds;
A large consignment of Lion skeletons of mixed sex destined for East–Southeast Asia that was falsely declared
as “samples and documents”;
Falsely declared quantities on the CITES permit;
Incorrect and/or forged documentation, re-used permits, and exporters offering to courier missing
documentation;
Exports not accompanied by the original documentation and CITES permits.

Some freight and cargo companies are less concerned about the cargo they ship out compared to other companies. As
businesses, their mandate is mainly to export cargo on behalf of a client and to search for explosives, weapons anddrugs. But, “rhino horns don’t explode” and are therefore not a physical threat to airport and passenger security. At thevery least they might scan the documentation for irregularities, and if none are blatantly obvious then they are obliged
to release the cargo. Other companies, however, are more vigilant and scrutinize the CITES permits and other
19 The NSPCA has the mandate to support the South African Police Service in enforcing the Animals Protection Act of 1962and other legislation related to the protection of animals.

66

Bones of Contention: An assessment of the South African trade in African Lion bones

documentation more closely. Given this gradient of conscientiousness, there is a tendency for “less truthful” exporters
to seek out freight companies with weak spots that they can exploit, or to find a company prepared to turn a blind eye tocompliance irregularities so that they can export products in a manner that is not entirely legal.
Freight forwarding is a colossal industry with tonnes of goods being exported hourly to hundreds of global destinations– hence it is not practically feasible for companies to scrutinize every shipment looking for signs of illegal trade
specifically concerning Lions and thus some illegal exports will go undetected. The prevailing opinion among theinterviewees is that there are probably fewer unlawful exports of Lion compared to other wildlife such as rhinos andreptiles (few Customs officials are prepared to open a box of live snakes to verify their contents, for example).
Moreover, some interviewees said that they would like to see the trade in Lion bones stopped if they had the capacity.

Bones of Contention: An assessment of the South African trade in African Lion bones

67

LION PARTS IN SOUTH AFRICAN
TRADITIONAL MEDICINEOVERVIEW
Called iBhubese in Zulu and iNgwenyama in Xhosa, Lion body parts and derivatives are used in African traditional
medicine (“muthi”) preparations and have routinely been recorded in South African muthi market surveys since the1980s (Cunningham and Zondi, 1991; Mander et al., 1997 cited in Marshall, 1998; Ngwenya, 2001; Simelane, 1996;
Simelane and Kerley, 1998; Whiting et al., 2011). Lion “fat” (most of it imitation) is most prevalent in the markets
compared to the skin and bones. There are two large informal, urban, open-air markets for traditional medicine in South
Africa: the Warwick Street Market in Durban, KwaZulu-Natal, and the Faraday Street Market in Johannesburg,
Gauteng. There are over 300 traders in both markets, but fewer than 20% of the traders sell animal parts and thethroughput is relatively low; parts of some species remain at stalls for years with only small pieces being sold at
irregular intervals. Given the small quantities of Lion parts in the markets, the impact of the traditional medicine tradeon Lion populations in South Africa is believed to be negligible (especially in comparison to the trade in bones inmarkets in Asia). White et al. (2004) allege that species such as Lions are often smuggled into South Africa from
Zimbabwe or Mozambique, and that the body parts and derivatives are sold through markets in Swaziland and thentraded through Faraday and Warwick before reaching small towns along this trading route.

© VIVIENNE L. WILLIAMS

A large Felid skull in the Faraday traditional medicine market, Johannesburg, c.2002

68

Bones of Contention: An assessment of the South African trade in African Lion bones

There is believed to be a limited demand for Lion parts by traditional healers outside of urban markets in the rural areas.
Healers routinely use pairs of bones (usually the phalanges) as instruments of divination, but citations of their use inthis manner are uncommon. This demand by rural healers has not been formally documented and the frequency ofacquisitions is not fully known. Incidences of seizures of Lion parts from healers are infrequent and the quantities they
have been found with amount to no more than a small part of one Lion at a time.
The expansion of human settlements on the western boundary of the Kruger National Park in Mpumalanga has been
cited as a reason for the recent increase in Lion poaching for African traditional medicine (CITES Scientific Authority,2013). There is also anecdotal evidence that healers in areas adjacent to Kruger purchase animal parts from traditional
healers working for SANParks and other reserves (T. Mashua, pers. comm., July 2013). When dead animals become
available, employees of the parks who also happen to be healers get access to the body parts and then sell them to otherhealers at healer association meetings.
Four surveys of the urban trade in animal parts are known to have been conducted in three provinces in South Africa
since 1987. The surveys focused on sales in traditional medicine markets, muthi shops and by wholesale distributers. In
addition to these surveys, Mander et al. (1997) investigated animal species using primary data sources (viz.
Cunningham and Zondi, 1991; Simelane, 1996) for the TRAFFIC report by Marshall (1998) on medicinal wildlife
resources used in East and southern Africa. Despite Lions being reported as priority species in Malawi, Mozambiqueand Uganda (and being utilized in six other countries), they were not on the list of top 25 priority animals in South
Africa in 1997 (Marshall, 1998).

© LENKE BRUYNS

Lion phalanges included in a set of bones used by a healer in the Bushbuckridge area (July 2013)

SURVEY OF DISTRIBUTERS IN KWAZULU-NATAL (1987)
The 1987 survey conducted by Cunningham and Zondi (1991) recorded Lions as the seventh most “popular” animal
species used by 52% of the traditional healers (the Southern African Python Python natalensis ranked first). As a proxyof the demand, the sales made by a major national wholesaler were analysed and a slightly different picture of thedemand emerged: Lions ranked second after hippopotamus in the quantity of animal fat sold per year (42 litres/y and
109 litres/y respectively). The fats, however, were almost certainly not genuine. The proportion of fake Lion fat
available in urban areas was alleged to be higher than in rural areas where authentic ingredients were more easily
obtained. Even though many animal fats are imitation, consumers are unaware of this and consider the products to be
the real thing. The physical strength of Lions was cited as a reason for their use.

Bones of Contention: An assessment of the South African trade in African Lion bones

69

SURVEY OF TRADERS IN THE EASTERN CAPE (c.1994)
The study in the Eastern Cape province was conducted c.1994 with more than 19 traders (Simelane, 1996; Simelane andKerley, 1998). Similar to the 1987 survey, 53% of traders “mentioned it” – however the study did not list the bodyparts used. Instead, the authors describe how Lion fat, skin and bones are usually included as an ingredient in medicines
to treat kings and chiefs in the absence of parts from preferred spotted predators such as leopards, genets and cheetahs.
These species are selected for their predatory behaviour since it is believed that their strength and agility in attacking
prey can be conferred to community leaders and thus provide them with the necessary power to rule their people.
Traditional leaders frequently wear traditional attire decorated with these skins to signify and/or manifest that power.

SURVEY OF MUTHI SHOPS IN KWAZULU-NATAL (2000)
The 2000 survey of animal products sold in muthi shops in 12 towns in KwaZulu-Natal by Ngwenya (2001) is by far
the most comprehensive for South Africa. Lion parts were recorded in nine towns, especially bottles of “lion” fat (Table
15). Lion bone was the second most frequently observed part (n=7), followed by the skin (n=6) and the skull (n=4).
Table 15 Lion parts used, frequency of observations, and price range of the parts (from Ngwenya, 2001)
Lion part used
Bile
Bones
Claws
Eye-lashes
Fat
Head/skull
Heart
Liver
Meat
Skin
Toes

Frequency(n=9 out of 12 towns)
2
7
1
1
9
4
1
1
1
6
2

Price range* (all ZAR=R)
R10 – R25 per 5-10 ml bottle
R5 – R20 per piece
R10 – R20 eachR5 per pieceR3 – R25 per 5-10 ml bottle
R5 – R25 per pieceR5 per pieceR5 per pieceR5 – R20 per pieceR5 – R25 per piece
R10 – R25 each

* Average exchange rate in 2001: ZAR1 = USD0.1177

SURVEY OF THE FARADAY MUTHI MARKET, JOHANNESBURG (2005)
A survey of animal species and parts was conducted in the Faraday Market, Johannesburg, in 2005 by Whiting et al.
(2011). The survey excluded the documentation of the animal fats, partly because the species could not be verified. Of
the sample of 32 traders, three (9%) sold Lion parts and three different body parts were recorded (Table 16; Figure 31).
Potentially, more parts (such as bones) were present in the market than were observed or identified. Compared to otheranimals present in the market, Lions are not a highly utilized species (Figure 31)
Table 16 Lion parts recorded in the Faraday market in 2005
Trader no.
Part sold
1
1 x skull2
1 x bone3
1 x skin piece(Source: Whiting et al., 2011)

Use
Cranium “mixed with tears to make one to be feared”“For strength and instilling fear”
No use recorded

A pilot survey conducted in Faraday with 10 traders in 2001 did not record the presence of Lion parts and further
indicates that the frequency and volume of sales of non-fat Lion body parts were low in the region at the time. Given
that Lion parts are relatively difficult to obtain (especially from wild populations), the incidence in the markets was
expected to be low. There are occasionally reports of traditional healers from the eastern side of South Africa having
being arrested with Lion parts, but these instances are sporadic and the material in their possession is usually derived
from no more than one Lion. Whether traditional healers from areas adjacent to nature reserves in Limpopo andMpumalanga, and the captive breeding facilities in the provinces of the Free State and North West, have greater accessto Lion parts is merely speculation at this stage.

70

Bones of Contention: An assessment of the South African trade in African Lion bones

Figure 31 The trade in Lion parts in relation to other species in the Faraday market in 2005. (The total number ofanimal parts per species excludes feathers, quills, scales, teeth, horns and crocodile osteoderms) (Derived from
Figure 5 in Whiting et al., 2011)2013 INTERVIEWS
An informal telephone interview was conducted with the Chairman of the Faraday market in June 2013, the purpose ofwhich was to establish informally whether Asian customers visit the market and what they enquire after. A similarinterview was conducted with the Chairman of the Makokoba Market in Bulawayo, Zimbabwe, in February 2013.
There have been Asian visitors to both markets, but no Lion parts were requested. The visitors to Makokoba tend tolook around and not purchase anything. In Faraday, the “Chinese” buy prepared medicines that exclude Lion parts.
The trade in Lion bones as a substitute for Tigers in Asian countries was discussed with the Faraday chairman. He said
that it was not a good idea to mix Lion and Tiger bones together since it would make a person “more violent”. On
further enquiry about the sale of Lion parts in Faraday, he said that very few healers sell Lion parts because they are
difficult to obtain – mainly because “papers” are needed to (legally) hunt one. Furthermore, he was “veryuncomfortable with the killing of lions” and that farmers were the only ones involved. The chairman was concerned that
traders and healers would be implicated in supplying Lion carcasses to Asian traders. He stressed that they are not in thebone trade since they have limited capacity to do so.

AUTHENTICITY OF THE ANIMAL FATS
Almost all animal fats sold in 5–10 ml labelled bottles in South Africa are imitations. Synthetic fats manufactured byherbal suppliers have been “indigenized” and these products are considered highly effective in ensuring protection fromevil spirits (Cocks and Dold, 2000). In 1996, one of the authors of this report visited the premises of one of the largest
distributers of traditional medicines in southern Africa. In the process, the recipes for “making” animal fats were
unwittingly revealed. Lion fats were Product No. 7 (Bhubhesi), and the recipe was as follows: Take dry pork fat; cut
into very small flaked strips (15 mm in length); put into a 10 ml glass bottle; cap with a 10 ml cork. Labels with thewords FAT IMIT (fat imitation) were then affixed to the bottles.
Animal fats sold at the muthi markets are usually in old and unlabelled 250 ml alcohol bottles filled with fetid
substances of dubious identity (Figure 32). These fats are purchased from rural suppliers to the urban markets, but theprovenance cannot be authenticated and the incidence of genuine Lion fat cannot be determined without DNA testing.

Bones of Contention: An assessment of the South African trade in African Lion bones

71© VIVIENNE L. WILLIAMS

Figure 32 A variety of non-manufactured animal fats in the Faraday traditional medicine market, Johannesburg

72

Bones of Contention: An assessment of the South African trade in African Lion bones

TIGER POPULATION AND TRADE IN
SOUTH AFRICAOVERVIEW
There are estimated to be more than 280 Tigers (mainly Bengal Tigers) in at least 44 facilities20 in South Africa. The
total size of the ex situ Tiger population in South Africa is not known and is believed to be higher than estimated here
from the partial survey that was conducted. Because of inbreeding, some people view Tigers in South Africa to be oflittle conservation value to the global ex situ population; accordingly, given the demand for Tigers in East–Southeast
Asia, Tigers may face some future risk of exploitation for market-driven consumptive purposes by a few breeders.
One of the most well-known private ex situ conservation facilities is “Tiger Canyons” in the Free State with at least 14
Tigers. The mission of the facility is to “create a free-ranging self-sustaining population of tigers in the hands ofprivate enterprise in and out of the Asian continent” (http://www.jvbigcats.co.za). Another organization in the Free
State with similar numbers of Tigers is “Save China’s Tigers” (http://savechinastigers.org). The charity have a “rewilding” project for the Critically Endangered South China Tiger Panthera tigris ssp. amoyensis that reportedly sends
captive-bred animals to South Africa for the purposes of “rehabilitation” so that they can be reintroduced into China
with the skills to hunt.
Like captive Lions, most Tigers are in the Free State and North West provinces. There have recently been unverified
rumours that Tigers are being made available to trophy hunters. Information on the UNEP-WCMC CITES trade
database records that permits were issued to export Tiger trophies (especially after 2006), but there are no records ofhunts in the national consolidated hunting reports (however, other exotic species are listed). The current provincial
legislation is variable on where and whether hunting can occur (Table 17).

Siberian Tigers Panthera tigris ssp. altaica at Johannesburg Zoo© VIVIENNE L. WILLIAMS

20 Derived from a non-exhaustive Internet search in May 2013 and from personal communications with representatives fromthree provinces

Bones of Contention: An assessment of the South African trade in African Lion bones

73

74

Bones of Contention: An assessment of the South African trade in African Lion bones

CNC 1974

FSNC1969

TNC 1983

KZNNC 1992

LEM 2003

MNC 1998

CNC 1974 & NCNC
2009
TNC 1983

CNC 1974

EC

FS

GT

KZN

LP

MP

NC

NW

WC

A1

Ex

A1

Ex

Ex

Ex

Ex (Live) &A1 (live &derivatives)
Ex

A1

Defined as
Exotic (Ex) or
Endangered
CITES Appendix
1 (A1)

y

y

y

y

y

y

y

y

y

Writtenpermission

y

n

y

n

y

Authorisation*

n

n

y

PermitHunt/Catchyny - import/
convey;n - possess/ sellyy, convey

Authorisationn

Y & n: depends
on activity

yPermitLive: convey,
keep, possess,sell, buy, donate

?

y

y

?

?

y

y

?

PermitLive:
Set freey, carcass

no regulationsy, carcass

no regulations

no regulations

Authorisation

no regulations

ny, carcass

Permitderivatives

Possession ofyno regulationsyno regulations

no regulations?

no regulationsnyPermitProcessing ofcarcassyno regulationsyno regulationsnyno regulationsnyPermitSale/ trade ofcarcass &derivatives

y, carcass

no regulationsy, carcass

y, only lawfully
dead Tigers
no regulationsyno regulations

Y & n: depends
on activityy, carcass

Export/ convey:
live, carcass &derivatives from Province
Permit

"

"

"

"

"

"

"

"

"

"

"

"

"

"

"

"

y, in terms of
CITES regulations

Export: live,
carcass &derivatives –inter-national
CITES

Notes:
1. Exotic mammal (Ex): any live vertebrate that is not a recognized domestic species or subspecies and the habitat of which is not in the Republic (of South Africa). The KZN
act specifies that the regulations apply to animals that are dead or alive, or any part thereof. Some provinces have specially listed exotic animals in Schedules to the ordinances,
but Tigers are not specially listed. Provinces: FS, GT, KZN, LP, MP, NW
2. Endangered wild animal (A1): means any wild animal of any species that is in danger of extinction and is specified in Appendix I of CITES. The regulations don’t specify if
the animals are alive or dead. Provinces: FS, EC, NC, WC.

Abbreviations for Ordinances or Acts: CNC1974: Cape Nature Conservation Ordinance No. 19 of 1974; FSNC 1969: Free State Nature Conservation Ordinance No. 8 of 1969; KZNNC 1992:
KwaZulu-Natal Nature Conservation Act No. 29 of 1992; LEM 2003: Limpopo Environmental Management Act No. 7 of 2003; MNC 1998: Mpumalanga Nature Conservation Act No. 10 of 1998;
NCNC 2009: Northern Cape Nature Conservation Act No. 9 of 2009; TNC 1983: Transvaal Nature Conservation Ordinance No. 12 of 1983.
* Authorization: Ordinance does not specifically state that permits are required

Ordinance or Act(abbreviation)

Province

Table 17 Summary of South African provincial legislation as it applies to Tigers. Depending on the province, restricted activities are determined by a Tiger’s definition as either(a) an “exotic animal”, or (b) as an “endangered wild animal” that is listed in Appendix I of CITES. (y=yes; n=no; ?=uncertain)

Several permits for the keeping, breeding and exhibition of Tigers have been issued in South Africa. Many of these
permits were issued to private collectors and are not linked to any zoological, research, tourism or educational
institution. Legislation in South Africa is extremely fragmented and renders very little protection to these nonindigenous animals without a regulatory framework. While CITES controls the trade of Tigers and their parts andderivatives, it is very easy to mix Tiger with Lion bones because the current approval and checking system is ineffective
and thus opportunities for illicit activities are available. As an example, the Transvaal Nature Conservation Ordinance
12 of 1983 currently in effect in Gauteng and North West only deals with the import and release of Tigers (Table 17).
This implies that all other activities such as hunting, processing and the sale of body parts within South Africa is not
regulated or monitored. No information is generated by the current regulatory system on the statistics of Tigers in
captivity, mortalities and the subsequent management of carcasses of the animals. This raises a serious question on theactual objective of some Tiger operations and the sustainability thereof. The North West Province has, for example, aVietnamese national who owns a farm with more than 50 Tigers in captivity (Anon., pers. comm., July 2013) –however, little is known about the actual activities being conducted on this farm. If Tigers are being bred on this facility
for international trade in their parts and derivatives, then this would be in contravention of CITES Resolution Conf.
12.10 (Rev. CoP15) for the “Registration of operations than breed Appendix I animal species in captivity forcommercial purposes”, due to its non-registered status, and CITES Decision 14.69 which states that “Parties withintensive operations breeding tigers on a commercial scale shall implement measures to restrict the captive population
to a level supportive only to conserving wild tigers; tigers should not be bred for trade in their parts and derivatives”(CITES, 2009). Furthermore, Resolution Conf. 12.5 (Rev. CoP16) urges “Parties and non-Parties on whose territories
tigers and other Asian big cat species are bred in captivity to ensure that adequate management practices and controls
are in place to prevent parts and derivatives from entering illegal trade from or through such facilities”. Although
aimed primarily at Tiger range States, this Decision clearly also applies to South Africa.
Anonymous tip-offs to conservation officials in the Free State have alerted them to incidences of Tigers possibly being
hunted in small enclosures, followed by applications shortly thereafter for permits to export products such as skins (W.
Boing, pers. comm., May 2013). The Free State does not allow the hunting of exotic animals, and so Tiger hunting isillegal in this province. The anonymity of the informants has meant that cases of mortality allegedly caused by hunting
and “pneumonia” could not be confirmed.
Applications for permits to export Tiger bones to Lao PDR have been received by the Free State, in particular by atleast two bone agents (no information was provided on the year of the application) (W. Boing, pers. comm., May 2013).
Permits to export 11 Tiger skeletons from the province have been issued to date, and it is believed that this market willgrow in future (W. Boing, pers. comm., May 2013). Up to the end of 2011, however, there were no records in theannual CITES reports provided by DEA of any Tiger bones being exported (DEA, 2013). Hence, these reports ofpermits to export Tiger bone should be examined when South Africa compiles its 2012 CITES report.
That Tiger bone exports from South Africa to East–Southeast Asia are known to have happened means that it is not
improbable for Tiger skeletons to have been exported as “lion” using CITES Appendix II permits instead of Appendix I– but there is currently no evidence to prove that false species declarations have occurred. Tiger and Lion bones aremorphologically very similar, and to the untrained eye it would be hard to make a correct determination of a species in aconsignment. Morphological differences in the skulls are a subtle, but not a fool proof, detection method (Figure A1 in
Appendix 4). Hence, random DNA testing remains the only way to get an incontestable identification.
It seems improbable that non-Asian South African breeders are engaged in specific programs to rear Tigers for theirbones or other products/derivatives, but the intentions of the Vietnamese-owned Tiger facility in the North West are
unknown and should be investigated. The Free State banned the establishment of new Tiger breeding facilities about
five years ago (W. Boing, pers. comm., May 2013). Free State farmers can thus keep the Tigers they have, but nopermits will be issued to new breeders. Whether this clampdown on breeding facilities in the Free State has led, like theLions, to breeders shifting their operations to the North West to exploit weaknesses in the regulations should beconsidered.
The opinion of law enforcement and conservation officials in the North West is that there is currently no evidence ofTigers being hunted to supply the bone industry (Multiple interviewees, pers. comm., May 2013). However, theprovince has had many enquiries from people wanting to hunt Tigers (especially in the last three years) and they feelthat eventually the bones will end up in trade after the trophy has been exported. When questioned on how the province
handles the management of Tigers given its CITES Appendix I status, the response was that Tiger management is not
regulated – hence a person can hunt a Tiger if they so want. Only the export of the body parts and derivatives would be
subject to the necessary CITES regulations and permits. That said, one respondent didn’t think that the province was
openly selling any of their Tiger bones (i.e. with CITES permits) – but, IF the bones were being exported, then they
were probably being illegally “smuggled out as lion bones”.

Bones of Contention: An assessment of the South African trade in African Lion bones

75Tiger breeding has not been on the radar of concerns for the provinces. In relation to the awareness generated by thisLion bone investigation, however, some respondents in the North West agreed that there was a need to monitor thetrophy hunting of Tigers and to scrutinize what Tiger breeders say they do with their dead Tigers. And, while live
animals are the bulk of the exports, there is a growing trade in skins and trophies that are likely to be generating notablerevenues (Figure 33).

Figure 33 Combined quantities of Tigers recorded on permits issued by South Africa to export live Tigers,
trophies, bodies and skins to various international destinations. Exports are mainly for Bengal Tigers Panthera
tigris ssp. tigris. Vertical lines indicate years that measures were adopted to protect Tigers and Asian big cats.
(Source: UNEP-WCMC CITES trade database, and DEA annual CITES reports)

TIGER EXPORTS FROM SOUTH AFRICA
The bulk of South Africa’s Tiger exports are live animals – mainly from the Free State and North West provinces(Table 18; Figure 33). There is a growing trade in trophies (officially none from the North West) and skins – mostly all
from the Free State (Tables 19 & 20) [Note: as with Lion parts, Tiger products do not necessarily originate from theprovinces that the export permits are issued in]. No permits to export bones and skeletons had been recorded in thenational CITES reports up to the end of 2011. The trade records show that apart from three live animals in 2004, a bodyin 2008, and a claw in 2011 being exported to China, the only other exports of Tigers to Southeast Asia were live
animals destined for Viet Nam, Myanmar and Thailand.
Table 18 Number of Tigers recorded on permits issued by the provinces to export live animals
Year
2006
2007
2008
2009
2010
2011
Total

76

North West
2

5
2
2
11

Limpopo1010

DEA annual CITES reports for the provinces
Free State
Gauteng
Mpumalanga
2
2
6
6
9
25

KwaZulu-Natal
3
2

14
6
6

14

4
7
16

Total
5
4
2
25
12
34
82

Bones of Contention: An assessment of the South African trade in African Lion bones

Table 19 Number of Tiger trophies recorded on export permits issued by the provincesYear
North West

Limpopo

2006
2007
2008
2009
2010
2011
Total

DEA annual CITES reports for the provinces
Free State
Gauteng
Mpumalanga
2

1
1
3
7

KwaZulu-Natal

5

5

1
1

Total
2

6
1
4
13

Table 20 Number of Tiger skins recorded on export permits issued by the provincesYear
North West
2006
2007
2008
2009
2010
2011
Total

Limpopo1
1

DEA annual CITES reports for the provinces
Free State
Gauteng
Mpumalanga
1
1

1
2
7

KwaZulu-Natal

Total
1
1

2
2
6

1. Exports of live Tigers
From 2002 to 2011 permits were issued to export 58 live Tigers to the United Arab Emirates (AE or UAE) from South
Africa (Figure 34), which is 39% of the total number. Exports of live Tigers to Botswana (BW) average four per year,
and they are reportedly the second largest importers. Viet Nam and Myanmar have so far applied to import eight live
animals each, starting in 2009 and 2010 respectively. Tiger exports to Myanmar are especially noteworthy since thecountry is known to have a thriving trade in wild cat species (Oswell, 2010; Schmidt, 2012; Shepherd and Nijman,2008). Reports of imports of three and two Bengal Tigers to China and Thailand occurred once in 2004 and 2009
respectively.
The fate of live Tigers exported from Africa to Asia has not been widely documented. The non-profit environmentalpressure group “Annamaticus” allege that the UAE is “a transit route increasingly used by wildlife traffickers to deliver
contraband to consumers in east and Southeast Asia” (Pappin, 2012a). Macleod (2012a) further claims that “the UAE
is a well-known staging point for the illegal trade in wildlife from Africa, and any live tigers sent to Vietnam will end up
in an Asian traditional medicine pot to be stewed for some tonic”.
A question put to the National Assembly (2012) confirmed that in 2009 and 2010 permits were issued to four and twosellers respectively to export Tigers to the UAE (National Assembly, 2012). Exports to Botswana are a conundrum:
Tigers do not naturally occur there and they do not appear to be exported from Botswana, yet there have been
allegations in the media that South African breeders are using Botswana as a laundering point for wildlife trade(Macleod, 2012a). Also, 11 of the 28 Tigers known to have been exported to Botswana were sent back – either because
they were refused entry or were confiscated by authorities (Macleod, 2012a).
Free State granted permission for the most number of live Tigers to be exported, followed by KwaZulu-Natal andMpumalanga (Table 18). All permits issued by KwaZulu-Natal are for Tigers to be exported to Botswana, whereas mostTigers from the Free State are destined for the UAE. Mpumalanga has issued permits for Tigers going to UAE, Viet
Nam and Thailand.

Bones of Contention: An assessment of the South African trade in African Lion bones

77

Figure 34 Number of live Tigers and their destination recorded on export permits issued by South Africa for
2002–2011 (n=148 Tigers in total). (Country codes from left to right: AE=United Arab Emirates, UAE; BE=Belgium;
BF=Burkina Faso; BW=Botswana; CN=China; ES=Spain; GA=Gabon; MM=Myanmar; MU=Mauritius;
PK=Pakistan; SZ=Swaziland; TH=Thailand; TM=Turkmenistan; TZ=Tanzania; UA=Ukraine; VN=Viet Nam;
XX=unknown; ZM=Zambia) (Source: the national CITES report and UNEP-WCMC CITES trade database)

2. Exports of Tiger trophies and skins
Permits issued to export Tiger trophies and skins might be increasing, but there are insufficient records to establish
whether there are notable trends – except that exports increased after 2002 when regulations inhibiting the Tiger trade
would have made it impossible for hunters to hunt Tigers and export trophies from within Tiger range States (Tables 19& 20). Most of the permits were issued in the Free State, and none of the trophies were destined for Southeast Asia.
In conclusion, there are concerns about the growth of the trade in Tigers and associated products from South Africa andcalls by the media for transparency in the matter (Pappin, 2012b). Although trade from South Africa seems to havelargely excluded East–Southeast Asia, with the exception of a few live animals to three countries, some of the countries
to which the exports were destined have been implicated as being on transnational trade routes for illicit wildlife
activities. Limitations in the South African legislation applying to endangered exotic animals have made it possible foran unregulated domestic trade in Tigers and for them to be “euthanized” under dubious circumstances. Furthermore,
given the similarity of Lion and Tiger skeletons, Tiger bones originating from South Africa may be laundered as Lionbones using CITES Appendix II permits.
The trade in Tigers was a peripheral aspect of this study and not part of the investigation as set out in the aims.
However, concerns were brought to the fore near the finalisation of this report when a set of “lion” bones with a verylarge skull that had features resembling a Tiger were observed. The photo of the skull was shown to an experienced
predator breeder who was undecided as to its identity. As a result, this preliminary investigation into the matter was
conducted and is not a comprehensive assessment of the South African Tiger trade nor the legislative instruments thatgovern their consumptive and non-consumptive utilization. Therefore, further research into the matter would beappropriate given the growing Asian trend in sourcing wildlife from African countries.

78

Bones of Contention: An assessment of the South African trade in African Lion bones

CONCLUSION: IMPACT ON SOUTH
AFRICA’S WILD LION POPULATION
There is a concern that the use of African Lion as a substitute for Tiger could stimulate a demand that would impact
wild lion populations (Nowell and Ling, 2007). Another concern expressed in the media is that wild populations will beaffected because consumers in East–Southeast Asia are allegedly prepared to pay more for bones from free-ranging
Lions because of a belief that the effects are more potent than those of captive animals (Macleod, 2012a). From all theinterviews conducted with the provincial conservation authorities, however, Lion skeletons of South African origin arealmost certainly all derived from captive bred, not wild, animals. The trophy hunting industry, which is mostly from
captive animals, is the main source of carcasses once the trophy hunter has taken the skin and skull. There thus appears
to be little evidence that the Lion bone trade is currently adversely impacting the wild Lion population in South Africa –but this situation is not adequately known for the rest of Africa and future trends based on current trade levels have notbeen extrapolated to determine whether there would be “spill over” into poaching wild Lions in South Africa in the
future to meet the demand.
Reports of poaching incidents involving wild South African Lions are sporadic and have not been conclusively linked
to the Lion bone trade. Poaching has been associated instead with subsistence use by rural communities rather thancommercial trade, for example the traditional medicine trade. Illegal exports of Lion bones are occurring, usually
involving (1) people who have not obtained all the necessary permits to carry out all restricted activities involving
Lions and thus the causes of mortality, and the legality thereof, cannot be established; (2) an exporter not having thecorrect documentation, or (3) traders trying to smuggle the Lion parts out of South Africa without the required permits.
Official records on the incidences of illegal activities have not been obtainable, largely because this is a confidential
matter involving law enforcement officers. However, the Lion parts being exported illegally are believed to come from
captive animals since this is the cheapest source of the bones and involves less personal risk to theexporter/importer/poacher. There was also no evidence of a premium being paid for South African wild Lion bones –instead, a premium is paid for complete skeletons with the skull and floating bones.
Further evidence that the Lion bone trade is having little impact on wild populations in South Africa comes from theprovinces issuing the CITES export permits. The North West, Free State and Eastern Cape are the only provinces
issuing export permits for Lion bones, and the Lions in these provinces are nearly all captive bred.
One statement made by a former government official that captures an opinion on the Lion bone trade and its impact is
by Buyelwa Sonjica (former South African Minister of Water and Environmental Affairs). When asked if thegovernment would consider the banning of the export of Lion bones and if not, why not, the minister said “No. The
banning of the export of lion bones will only be considered if the export has a negative impact on the survival of species
in the wild. This is not currently the case” (National Assembly, 2010b).
After consulting with many stakeholders, the South African CITES Scientific Authority (2013) made the following
succinct statements about hunting and the Lion bone trade:
1.
2.
3.
4.
5.
6.
7.

Utilization of lion in South Africa is considered to be sustainable, and wild populations are stable toincreasing.
No hunting is allowed in national parks or provincial state reserves, which collectively represents almost all
the original wild populations and accounts for >75% of the total lion population.
Utilization of lion for commercial purposes is mostly restricted to private game reserves where lions have been
reintroduced since the 1990s.
Trophy hunting of lions is popular in South Africa, although hunted lions are predominantly sourced from
captive bred populations, thereby reducing the hunting pressure on wild lion.
Captive breeding facilities are located primarily in the Eastern Cape, Free State and North West provinces,where the majority of lion hunts takes place.
Hunting of wild lion on private property is limited, with <5% of successful lion hunts conducted over the 2008
to 2010 period targeting wild lions.
Private landowners that conduct legal hunts of wild lions have an interest in ensuring the stability of their lion
populations.

Bones of Contention: An assessment of the South African trade in African Lion bones

79

8.
9.

The revenue generated through hunting contributes to the maintenance of areas where these lion populations
can continue to exist.
The economic benefits to the private sector of keeping and trading wild lion may provide a strong incentive forconserving the species and the habitat.

If the bone trade has little or no impact on South Africa’s wild Lion populations, then the question is: is the bone trade
fuelling the demand for Lion bones in other parts of Africa and negatively affecting wild populations as some havesuggested? The question cannot yet be answered, although it needs addressing in the immediate future. There is no
doubt, however, that Asian wildlife trafficking syndicates are operating in developing African countries – sometimes
under the guise of legitimate businesses that are providing economic opportunities in underdeveloped areas whilst
systematically exploiting local natural resources. Thus a priority now is to investigate the trade of Lion body parts andproducts in other African countries.

80

Bones of Contention: An assessment of the South African trade in African Lion bones

RECOMMENDATIONS
While the trade in Tiger bones is an established threat to Tiger conservation and many recommendations have been madein various reports, the emergence of the Lion bone trade between South Africa and East–Southeast Asia to sustain the
demand for parts and derivatives (especially bones) from big cat species is as recent as 2008 and growing. This is thefirst full research report on the matter and many issues and concerns were raised by all of the interviewees during thisinvestigation. Since it seems unlikely that the trade in Lion bones will be banned in South Africa in the near future, orthat syndicates, traders and Southeast Asian consumers will cease consumptive practices involving Lions and Tigers, thepragmatic blanket recommendation is that measures currently in place to impede opportunities for illegal activities arestrengthened across the entire supply chain from Lion breeding to skeleton exports.
In view of the research findings, the following actions are recommended:

















Develop an integrated national system for issuing permits that can be crosschecked by all enforcement and Customs
officials in other provinces.
CITES export permits should record the number of sets of skeletons and the combined mass thereof in a shipment.
There is no benefit to recording the number of individual bones on a permit since this obscures the total number ofbone sets and therefore the number of animals in trade.
National and Provincial permit issuers, law enforcement and Customs officials should use the graph provided inAppendix 5 as a way of cross-checking the accuracy of declared skeleton quantities versus bone/consignment mass
recorded on the applications for CITES export permits and/or the waybills. Recording the mass and number ofskeletons on the CITES permits will assist vigilant Environmental Management Inspectors (EMIs) and freight
forwarders with identifying discrepancies and anomalous declarations in shipments that contain more animals thanwere declared on the export permit and waybill.
Develop a user-friendly means to determine whether a skeleton is that of a Lion or a Tiger. We have recommended
one way to distinguish between Lion and Tiger skulls (Figure A1 in Appendix 4), but other characters may exist andrequire further development.
Since it is not currently possible to determine whether CITES Appendix I Tigers are being illegally shipped as
Appendix II Lion bones, spot checks and DNA tests of the exported consignments should be conducted to determine
whether a skeleton is that of a Lion or Tiger. The relevant officers could be provided with DNA collecting kits andtrained to collect tissue in a manner that would be acceptable to the justice system.
Investigate the use of South African seaports as a gateway for Lion and Tiger product exports.
Conduct a trade study on what happens to Lion bones and derivatives once they reach Asia and especially East–
Southeast Asia, including an assessment of the trade routes and the value of the products along the supply chain.
Investigate the Tiger trade in South Africa, including an assessment of the ex situ population, consumptive and nonconsumptive utilization, national and provincial legislation with respect to keeping and hunting exotic animals, and,the inappropriate use of CITES Appendix II permit to trade products.
Investigate the trade in Lion products (especially bones) in other African countries besides South Africa to determine:(a) the extent to which the products are available through legitimate and illegitimate sources, (b) the origin of the
products (wild or captive bred), and (c) whether there are negative impacts on regional wild Lion populations acrossLion range States in Africa.
Although the compliance of provinces to national and provincial statutes relevant to Lions was researched at a broad
level, time constraints precluded detailed examination of alleged individual transgressions. There remains a need toevaluate and, where necessary, synchronize the South African national and provincial legal frameworks to remove
loopholes creating opportunities for non-compliance and illegal activities.
It appears that more Lion hunting is taking place than is being reported by professional hunters. The sources of thediscrepancies should be determined and various departments must find an appropriate way of “fixing” the hunting
register and not issue permits without the register. The extent of the domestic hunting market for Lion should also
be evaluated.
Improve transparency within the bone trade, by considering a system (possibly including the use of studbooks andmicrochips) that tracks individual captive bred Lions from birth to death and from origin to final destination so that
all exported skeletons and trophies can be traced back to the original source and mode of mortality
The South African Revenue Service (SARS) must insist that all wildlife related cargos be stopped for inspection by
EMIs and not simply released without examination.
Conduct awareness campaigns targeting all cargo handlers/freight forwarders/cargo agents on a regular basis sothat they are aware of sensitive wildlife cargoes and are able to identify illegal or suspicious shipments.

Bones of Contention: An assessment of the South African trade in African Lion bones

81

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TRAFFIC. (2008). What’s Driving the Wildlife Trade? A review of expert opinion on economic and social drivers ofwildlife trade and trade control efforts in Cambodia, Indonesia, Lao PDR, and Viet Nam. Washington DC: East Asia
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Zhilong, Z. (2012). Big money tracks big game. http://english.people.com.cn/90882/7755435.html. Viewed 14 January
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Appendix 1: ASIATIC LION TIMELINES AND POACHING
There have been sporadic reports of Gir/Asiatic Lions (Panthera leo ssp. persica) being poached in India’s Gir
National Park since the mid-1990s, allegedly for their claws since these were typically missing when carcasses
were found (Anon., 2005; Anon., 2006; Dutt, 2006). For example: two Lions were poached in 1996 (Pati et al.,2002); one Lion skin was recorded during a seizure/prosecution incident in India in June 1996 (TRAFFIC, 2013);
one injured Lion was found in April 2004 with its right paw nearly ripped off – a sign that a leg-hold jaw trap
typically used to kill Tigers had been used (Johnsingh, 2009); and, at least four Lions were poached between
August and December 2005 (Anon., 2005; Dutt, 2006). Since usually only the claws were missing, the motives forpoaching were attributed to the local demand for amulets and not traditional medicine. However, inMarch/April 2007, at least eight Lions were killed in three incidents21 – and for the first time the TCM trade was
implicated (and eventually proved) to be the motive for the killings because the bones and skulls, in addition to
the claws, were removed (Anon., 2007; EIA, 2014b; Fair, 2009; Johnsingh, 2009; Kotecha, 2007; T. Ghose, in litt., 11
April 2014). The “dearth of tigers” was purported to be the reason why the gang of poachers targeted the Lions(Fair, 2009).
The incidents in March/April 2007 seem to have taken the Indian conservation authorities by surprise. Even
though Tiger poaching for bones for TCM had spread to India and had contributed to the extirpation of Tigers
in reserves such as the Sariska Tiger Reserve by 2004, Johnsingh (2009) wrote “No one thought that thisdemand for tiger bones [for TCM] would lead to the traders promoting lion poaching”. References for the
alleged use of Asiatic Lions in traditional medicine surfaced in the 1990s. In connection with the demand andconsumption of Indian Tigers for TCM, Khoshoo (1997) predicted “once tiger is decimated, the next target will
be lion, followed by leopard (even bear) and all other felines from Asia and Africa”. At that stage, images ofLions had already replaced Tigers on some manufactured Chinese medicines (Mills, 1997) and so it was valid topresume that Tiger parts could eventually be substituted with parts from Asiatic Lions.
After a six-year gap in the literature, mention of Asiatic Lion use in traditional medicine reappeared in theavailable online sources again in April 2003 when Ali (2003) alleges, “tigers and lions are killed for their skin andbones. The skin ends up as a wall decoration in homes while the bones are used to make medicinal balm”.
Shortly thereafter, Singh et al. (2004) published a paper on novel microsatellite markers for forensically
identifying big cats (including Asiatic Lions) in India that are “continually facing the danger of extinction mainly

due to poaching and hunting for their body parts, which are greatly valued by apothecaries marketing
traditional Chinese medicines” – it would thus seem that these authors had some basis for their concern thatbones from Gir Lions were a target for TCM. Similarly, the observation of a live Asiatic Lion in a wildlife market inMong La on the Myanmar-China border in August 2006 (Oswell, 2010) signposted an incipient market for the
species in Southeast Asia.
The three incidents that resulted in at least eight Lions being caught and killed in March/April 2007 led to arrest
and the conviction of more than 20 people from the Baheliya community (a hunting tribe from Madhya Pradeshthat specializes in poaching activities in India and are known for poaching Tigers) (Balakrishna, 2008; Bukhari,
2007a; Dubey, 2007; Fair, 2009). Members of the tribe had been arrested in Gir before for hunting leopards: in
2001, 10 members of a gang were apprehended in possession of iron traps and other hunting implements, andin May 2004 another gang was arrested for being in possession of four leopard skins and iron traps (Bukhari,
2007b; Srivastava, 2007).

21 Incident one: 3 skinned carcasses of lionesses (two adults and one subadult) found on March 3rd. The claws, skulls, teeth

and bones were removed but the skins were left behind. Incident two: skinned remains of two adult males and one cub
found on March 29th. Incident three: body parts belonging to at least two lions found on April 14th. Some reports list the total
number of lions found during that period as 10, but most literature reports the total as eight. The poachers that werearrested only admitted to killing eight lions, but the kingpin arrested later confessed that more than eight lions were killed(Bukhari, 2007c). The same modus operandi was used in all three incidents.

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93

Before the Baheliya suspects were arrested and convicted, the Chief Conservation Officer at Gir, Mr Bharat
Pathak, was quoted saying, “We suspect a (poaching) gang involvement…The traps that we found are similar innature to those used by poachers in (the neighbouring state of) Madhya Pradesh. (The bones) could have beentaken for Chinese medicine which is why the skins were left behind” (Ramesh, 2007). A month later, the Wildlife
Protection Society of India (WPSI, 2007) released a statement that included the following: “…since Tigers are so
scarce in the wild, these poachers are now targeting the last remaining Asiatic Lions…Their bones are also
virtually indistinguishable from those of Tigers. There is no market for big cat parts in India, and their poaching
and trade is entirely driven by demand from outside India’s borders, for use in traditional Chinese medicine…”.
After the tribe members were arrested for the Gir Lion killings, an investigator from India’s Criminal Investigation
Department was quoted as saying: “Since the winter of 2006 they are now specifically targeting lions”(Srivastava, 2007). Furthermore, Belinda Wright (head of WPSI) viewed these incidents as a new phase inpoaching India’s wildcats that could lead to the Asiatic Lion being “wiped out” and said, “It is still too early to saythat lion body parts are being passed on as that of tigers. But it is also true that the organized poachers are incommunication with the traders in India and China, and there appears to be an increased demand for lion partsin the Chinese mainland”22 (Srivastava, 2007). The kingpin of the poachers was arrested less than a month after
the gang and admitted “he along with the other poachers targeted Gir Lions ‘as there were no Tigers left inSariska’“ (Bukhari, 2007c). At the conclusion of the trial, more than 20 people were sentenced to three years
imprisonment and fined INR10 000 each (about USD200) (Balakrishna, 2008; HuntersNetworks, 2008; Wildlife
Trust of India, 2008). The accused admitted that trade in body parts was the motive for hunting. Keshav Kumar,
the Inspector General of Police, proclaimed “This is the first known case in India in which lions were hunted for

trade. Tigers are the first preference as each part of it is highly valuable. But with tigers disappearing, thepoachers thought that lions would have to do…” (Balakrishna, 2008; Wildlife Trust of India, 2008).
The 2007 poaching incidents led officials to re-examine earlier incidents of Lion and leopard poaching in theregion to establish whether the culprits were the same. There were similarities between the case involving theLion injured in April 2004 and the activities of Baheliya’s from Madhya Pradesh who were arrested in 2004 forbeing in possession of leopard skins and traps. Furthermore, those arrested in 2004 and 2007 belonged to thesame tribal community, and the traps used in all cases were similar (Bukhari, 2007b). This led officials toconclude that the Lion injured in April 2004 may have been the first (unsuccessful) target of the poaching gangfrom Madhya Pradesh (Bukhari, 2007b).

22 The article by Sravistava (2007) goes on to say “The information from China suggests that Wright’s apprehension could betrue…Now that tigers are hard to find, lions are being made effective substitutes. In all likelihood, lion bones fetch the same
prices as the tiger’s as there is no visual difference. To meet the demand [for TCM] China has a huge stockpile of dead andalive tigers and lions…The soaring prices of tiger/lion bones and rapid increase in demand have become a powerful incentive
to poach. The price is estimated to be between US$140–$370 per kilogram depending on the size of the bones…Powderedtiger humerus bone…brings up to $1,450 per pound in Seoul”.

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Table A1 Summary of notable regulations and activities in the timelines of the Asiatic Lion with respect to TCM
Activities involving Gir/Asiatic Lions

Year
1993
1994
1995
1996

Khoshoo predicts that Lions and other felines in Asia and Africa will be thenext target for parts for TCM once the Indian Tiger “is decimated”.4

1997
1998
1999
2000
2001
2002

Mention of Asiatic Lion parts allegedly used in traditional medicine.7* Paper published on novel microsatellite markers for forensically
identifying big cats (including Asiatic Lions) in India. The rationale for
conducting the study was that Asian big cats in India were threatened byhunting for body parts used by Chinese “apothecaries”.8* An injured Lion was found with its paw nearly ripped off (April). The casewas reopened in 2007 by authorities investigating the 2007 March/April
poaching incidents. Officials were trying to establish whether the culpritswere the same. They concluded that this may have been the gang’s firstunsuccessful attempt at poaching Lions.9

Legislation (details in Table 1)
China implements a complete banon the trade in Tiger bones.1,2
CITES adopts Resolution Conf. 9.13.1,3

CITES Resolution Conf. 9.14
superseded by Resolution Conf.
12.5.1,5,6

2003

2004

2005
* Live Asiatic Lion observed in a market in Mong La, Myanmar (August).10
Regulation banning leopard hunting* Alleged by the Gujarat Criminal Investigation Department that poachers
2006
and the purchase of leopard bones
from Madhya Pradesh were specifically targeting Gir Lions for use in TCM
in China.1,2
11
since the winter of 2006.
Eight Asiatic Lions poached in Gir National Park and their skulls and bones
Decision 14.69 against Tiger farming
removed (March/April). The motive for their killing was confirmed as being
2007
and breeding for parts andfor TCM.12,13,14,15
products.5
The poachers arrested for killing 8 Gir Lions in 2007 are sentenced to three2008
years imprisonment and fined INR10 000 each.14,15
References: 1=Nowell and Ling (2007); 2=People’s Republic of China (2006); 3=Williamson and Henry (2008); 4=Khoshoo(1997); 5=CITES (2007a); 6=Henry (2004); 7=Ali (2003); 8=Singh et al. (2004); 9=Bukhari (2007b); 10=Oswell (2010);
11=Srivastava (2007); 12=EIA (2014b); 13=Fair (2009); 14= Balakrishna (2008); 15=Wildlife Trust of India (2008).

Bones of Contention: An assessment of the South African trade in African Lion bones

95Appendix 2: IUCN RED LIST STATUS OF THE SOUTH AFRICAN LION POPULATION•The 2004 IUCN Red List assessment for South African Lions classified the species as Vulnerable according to
the D1 criteria – i.e. that the number of mature individuals was <1000 (Friedmann and Daly, 2004).

•

The 2004 assessment was based on a total population estimate of 2520 free-ranging individuals of all ages,
and thus <800 mature individuals if adults are one-third of the population.

•

Our conservative estimates for the 2013 wild population size is 2939 – and it is suspected that the counts forLions are based on mature individuals since provinces usually record the adults and not the cubs – but thisrequires confirmation. There are thus more than 1000 adults.

•

The conservation status of Lions in South Africa can only be assessed based on the size of the mature
population since they don’t meet the criteria for population decline (Criterion A: ≥30% decline in three
generations – 21 years) or restricted geographic range (e.g. Criterion B1: an Extent Of Occurrence <20 000
km2).

•

Since the size of the South African Lion population has grown in the last decade and there are >1000
mature individuals, the South African national Red List status of Lions requires downgrading to Near
Threatened or Least Concern.

•

In the next Red List assessment in preparation, Lions in South Africa will be categorized as Least Concern(Bauer et al., 2015).

•

One thing to consider in the assessment of the number of Lions in South Africa (and thus the number ofadults) is the Kgalagadi population that straddles South Africa and Botswana. If one does a country-bycountry assessment – then the number of Lions in the South African side is about 190 according to latest
figures (CITES Scientific Authority 2013; P. van Niekerk, in litt., June 2013). The total Lion population in the
Kgalagadi is about 600 individuals (P. van Niekerk, in litt., June 2013). However, Lions in Kgalagadi are notgeographically constrained by the Nossob River border and the population is contiguous across theTransfrontier park (P. Funston, in litt., July 2013). Since the adults are free to roam across the park there is no
artificial fragmentation of the population, one can’t limit the adult population to being one-third of 190, butrather one-third of 600. This pushes the number of wild Lions up to over 3000 for the region and thus anadult population of >1000 individuals•

Downgrading to Least Concern would not change the status with respect to TOPS regulations since thespecies would still be protected.

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Bones of Contention: An assessment of the South African trade in African Lion bones

Appendix 3: LION POPULATION IN SOUTH AFRICA C.2013
The following tables show the raw data on the size of the Lion population in South Africa and the source of
those data. Tables A2 to A6 show the breakdown of the number of Lions per reserve type and captive facility.
Tables A7 to A11 further summarize these data.
Table A2 Total number of wild Lions protected within South African National Parks (SANParks) (excludes Lionsprotected within the provincial State-owned game reserves – see Table A3)
S.A. National Park
(NP)

Province

Kgalagadi
Transfrontier NP1

Northern
Cape/
Botswana
Limpopo/Mpumalanga
Eastern Cape
Western Cape
LimpopoLimpopoEastern Cape

Kruger NP2
Addo Elephant NP3
Karoo NP3
Mapungubwe NP
Marakele NP3
Mountain Zebra NP4
Total

1.

2.

3.
4.

Naturally occurring“founders” orreintroduced
Naturally occurring

Naturally occurring

Estimated no. Lions

Reference

190 – South African side
600 – total in park (SeeAppendix 2)
2000

P. van Niekerk (pers. comm.,
June 2013)
See Table footnote.

Reintroduced
Reintroduced
Reintroduced
Reintroduced
Reintroduced

14 CITES Scientific Authority (2013)
8 CITES Scientific Authority (2013)<10 Funston and Miller (2013)13 CITES Scientific Authority (2013)
3 SANParks Media Release (2013)≈ 2238 (conservative estimate) [or, 2648 IF the Kgalagadi
population is considered to be 600 since the Lions on the
Botswana “side” of the park are free to move to the South
African “side”]≈ 97.9% are naturally occurring from founder populations
The Kalahari Gemsbok National Park in South Africa and the Gemsbok National Park in Botswana were amalgamated in
May 2000. The higher estimate of Lion numbers provided by Pieter van Niekerk from the Department of Environment
and Conservation, Northern Cape, was used. However, Funston and Miller (2013) and Miller et al. (2013) estimate about
450 Lions reside in the whole park, with about 125 individuals in the South African section. There are plans to count theLions in the park in the near future (P. van Niekerk, pers. comm., May 2013). See Appendix 2
The estimate is for the greater Kruger National Park ecosystem, and includes Lions living on national and private
reserves where the border fences have been removed between the reserves and the Kruger NP allowing Lions to roam
freely within the ecosystem. The report by the CITES Scientific Authority (2013) estimated the Kruger portion of the
population size to be 1617–1751 Lions, with a median of 1684, in 2004/05. Miller et al. (2013) and P. Funston (in litt., July2013) report that there are 1700 Lions in Kruger and an additional 300 Lions in private reserves bordering Kruger. The
Lions living on the private reserves are part of the greater Kruger National Park ecosystem and part of the founderpopulation. Hence, after some deliberation, we have reported the total population to be approximately 2000 Lions.
The estimates by the CITES Scientific Authority (2013) for c.2011.
Three Lions introduced in April 2013 from the Karoo National Park and the Welgevonden Game Reserve in Limpopo(http://www.sanparks.org/about/news/default.php?id=55509)

Bones of Contention: An assessment of the South African trade in African Lion bones

97

Table A3 Total number of secondary wild and free-roaming Lions protected within provincial State-owned gamereserves
Provincial Game
Reserve (Stateowned)
Hluhluwe-Umfalozi
Park
Tembe GR

Province

Genetic origin of Lions

KwaZulu-Natal

Mthethomusha

Mpumalanga

Reintroduced;
Kruger origin
Reintroduced;
Etosha origin via
Pilanesburg/Madikwe
Reintroduced;
Kruger origin

Pilanesberg GR

North West

Introduced in 1994;
Etosha origin

60

Madikwe GR2 (partstate-owned)

North West

Introduced in 1995;
Etosha origin

80

KwaZulu-Natal

Estimated
no. Lions

References

<2001
34

0

CITES Scientific Authority (2013)
Funston and Miller (2013)
CITES Scientific Authority (2013);
Slotow and Hunter (2009)
Had 2 Lions until 2013 (J. deBeer, pers. comm., May 2013).
Lions may be reintroduced infuture.
CITES Scientific Authority (2013);
Slotow and Hunter (2009)
CITES Scientific Authority (2013)

Other

There are a number of provincial nature reserves in Limpopo and Mpumalanga adjoining thewestern boundary of the Kruger National Park. The boundaries with Kruger are not fenced, and Lionscan roam freely across the greater Kruger ecosystem. These numbers are included in Table A4.
Total
<374
1. A participant of the Lion Biodiversity and Management Plan (BMP) workshop in Pretoria on 17 June 2013 stated that
there are currently fewer than 200 Lions.
2. A joint State-private-community run reserve.

Table A4 Estimated number of Lions within small, fenced private game reserves. For Limpopo and Mpumalanga,these figures exclude reserves that are unfenced systems and part of the greater Kruger National Park
ecosystem. Most stock originates from Etosha, Kruger and Kgalagadi (determined from Slotow and Hunter,2009). Some reserves have introduced captive-bred Lions in the free-roaming system, but the actual numbers
are not known. Some hunting might take place on a limited number of these properties
Province
Eastern Cape (EC)No. private
Reserves
12

Introduced orreintroduced
Introduced &reintroduced

Gauteng (GT)KwaZulu-Natal (KZN)

1
5

Limpopo (LP)20

Mpumalanga (MP)North West (NW)1??

Introduced
Introduced &reintroduced
Introduced &reintroduced
Reintroduced

Northern Cape (NC)1

Reintroduced

Estimated
no. Lions

Reference
61

8
82

CITES Scientific Authority (2013);
Eastern Cape Province interviews (pers. comm.,
May 2013)
CITES Scientific Authority (2013)
CITES Scientific Authority (2013);

122

CITES Scientific Authority (2013).

4??

J. de Beer (pers. comm., May 2013)
Unclear if there are any private fenced reserves
that do not allow hunting
CITES Scientific Authority (2013);
P. van Niekerk (pers. comm., May 2013)
Multiple internet sources (April 2013)

301

Western Cape (WC)6
Introduced
>20
Total
>46
>327
1. Does not include the fenced reserve that allows hunting – see Table A5

With the large number of facilities that breed and release Lions into reserves for hunting purposes in the NorthWest province, it has been difficult to establish whether there are any facilities (excluding sanctuaries and zoos)
98

Bones of Contention: An assessment of the South African trade in African Lion bones

that do not have any connection to the hunting industry. Hence, the number of Lions than might exist in a small,fenced, non-hunting reserve is indeterminate at this juncture.
Table A5 The number of captive-breeding and hunting facilities, and the number of Lions within these facilities.
Some hunting facilities do not breed Lions
Province

No. breeding
Estimated no. No. hunting
Reference
facilities
Lions
facilities
Eastern Cape
10250 >2
CITES Scientific Authority (2013)1
Free State70 breeding only
3000 2
W. Boing (pers. comm., May 2013).
Gauteng0
0 0
CITES Scientific Authority (2013)
KwaZulu-Natal0
0 0
CITES Scientific Authority (2013)
Limpopo2
2
350 ?
CITES Scientific Authority (2013)
Mpumalanga0
0 0
North West642196 12
CITES Scientific Authority (2013)
Northern Cape0
20 1
CITES Scientific Authority (2013)
Western Cape0
0 0
CITES Scientific Authority (2013)
Total
146
>5816 >17 excl. Limpopo3 Total hunting and breeding facilities ≈152.
1. Free State do not allow breeding and hunting on the same facility, and the number of breeders and hunting facilities inthis province have recently declined. The number of facilities in the province has dropped from the 98 reported by the
CITES Scientific Authority (2013).
2. Not validated yet. Occasional hunting of wild Lions appears to take place on some private land, but these Lions are notcaptive sourced and the total number of Lions hunted is less than 5% of the annual national total (CITES Scientific
Authority, 2013).
3. Professor Pieter Potgieter, Chairman of the South African Predator Breeders Association, said that there were no morethan 15 hunting facilities in South Africa (pers. comm., June 2013).

Table A6 Minimum estimates for the number of Lions in ex situ facilities (private sanctuaries, Lion parks, zoos,etc.). The information is inferred from a non-exhaustive Internet search.
Province
Eastern CapeNo. offacilities
5

Estimated
no. Lions>72

Reference
Multiple internet sources (accessed April 2013); meeting with EC
conservation officials
Multiple internet sources (accessed June 2013)
Multiple internet sources (accessed April 2013);
Multiple internet sources (accessed April 2013);
Multiple internet sources (accessed April 2013)
J. de Beer (pers. comm., July 2012)
Multiple internet sources (accessed April 2013)
P. van Niekerk (pers. comm., May 2013)
Multiple internet sources (accessed April 2013)

Free State
1
6
Gauteng>6>118
KwaZulu-Natal*
1>10Limpopo4>64
Mpumalanga
3
10North West
6
>40
Northern Cape
12
Western Cape*
4
>50
Total
31
>372
* In July 2009, DEA published an account on the number of TOPS species in captivity per province (National Assembly
2009d). The numbers reported for the Eastern Cape, Free State and North West corresponds with number of Lions inbreeding facilities in the provinces at the time. However, it was further reported that there were 50 Lions in KwaZulu-Nataland 70 in the Western Cape. These numbers have not been included in these estimates since there is uncertainty as towhether these are breeding facilities or ex situ facilities.

Bones of Contention: An assessment of the South African trade in African Lion bones

99

Table A7 Summary of the number of wild/free-roaming Lions in different reserve types
Reserve/facility type
SANParks National Parks(Table A2)
Provincial Nature
Reserves (Table A3)
Private small fenced
reserves (Table A4)
Total

1.

Number of
facilities
7

Estimated no.
Lions>22381

Average no. Lionsper facility
319.7

4

>374

93.5

Naturally occurring (wild/founder) andreintroduced
Reintroduced and free-roaming

46

>327

7.3

Reintroduced and free-roaming

57

>2939

 2190 (74.5%) Lions are in naturally occurring (“founder”)
populations
 422 (14.4%) are (re)introductions into state-owned reserves(incl. SANParks)
 327 (11.1%) are (re)introductions into privately-owned small
fenced reserves
Assuming Kgalagadi population is 190 on the South African side and not 600 for the total population

Table A8 Summary of the number of Lions in ex situ facilities
Facility type

Number of facilities

Captive-breeding facilities(Table A5)
Hunting facilities
Private sanctuaries, parks, zoos
(Table A6)
Total

146

Estimated no.
Lions
>5816

>17
31

See above>372>194 (excl. 17 hunting thatmight be breeding)>6188

Average no. Lions per facility
39.8
Included above
12.0
 5816 (94.0%) captive bred
 372 (6.0%) are ex situ

Table A9 Summary per province of the number of wild/free-roaming Lions in different reserve types (Province
acronyms listed in Table A4 and Map 2)
Province

SANParks National
Parks (Table A2)
No. parks
No. Lions

Provincial Reserves(Table A3)
No. reserves
No. Lions

Private Reserves(Table A4)
No. reserves No. Lions

Total

No. reserves

EC
2
17
12
61
FS
GT
1
8
KZN
2
234
5
82
LP
3
2023
20
122
MP
1
4
NW
2
140
??
??
NC
1
190
1
30
WC
1
8
6
>20
Total
7
2238
4
374
>46
>327
1. Assuming Kgalagadi population is 190 on the South African side and not 600 for the total population

100

14
0
1
7
23
1
2
2
7
57

No. Lions
>78
0
8
316
2145
4
>140
2201
>28
>2939

Bones of Contention: An assessment of the South African trade in African Lion bones

Table A10 Summary of the number of Lions in captive or hunting facilities per province (Province acronyms
listed in Table A4 and Map 2)
Province

EC
FS
GT
KZN
LP
MP
NW
NC
WC
Total

Captive breeding and hunting(Table A5)
No. facilities
No. Lions

10
72
0
0
2
0
64
1
0
149

Ex situ

Total(Table A6)

No. facilities
5
1
>6
1
4
3
6
1
4
31

250
3000
0
0
350
0
2196
18
0
5816

No. facilities

No. LionsNo. Lions

15
73
>6
1
6
3
70
2
4
180

>72
6
>118
10
>64
10
>40
2
>50
>372

>322
3006
>188
10
>414
10
>2236
22
>50
>6188

Table A11 Summary of the number of free-roaming and captive Lions in South Africa (Province acronyms listed
in Table A4 and Map 1)
Province

Wild and free-roaming

No. reserves

No. Lions

In captivity (breeding and ex situ)

No. facilities

No. LionsTotal
No. facilities

EC
14
>78
15
>322
29
FS
0
0
73
3006
73
GT
1
8
>6
>118
>7
KZN
7
316
1
10
>8
LP
23
2145
6
>414
29
MP
1
4
>3
>10
>4
NW
2
>140
70
>2236
72
NC
2
2201
2
22
4
WC
7
>28
4
>50
11
Total
57
>2939
180
>6188
>237
1. Assuming Kgalagadi population is 190 on the South African side and not 600 for the total population

Bones of Contention: An assessment of the South African trade in African Lion bones

No. Lions
400
3006
>126
326
2559
>14
2376
242
78
>9127

101

Appendix 4: LION ANATOMY
Differences between Lions and Tigers
While Lion bones are substituted for Tiger bones in East–Southeast Asian markets, there are also justified
concerns that bones from captive Tigers in South Africa are being illegally exported and falsely declared as “lion”
bones. It is thus important to be able to distinguish between the two species. The bold, brown-black stripes
across a Tiger’s body make it easily recognisable compared to the plain tan colouring of a Lion. However, Lionsand Tigers share the same skeletal structure and are anatomically extremely alike – making it difficult for usuallyanyone but an expert to discern the differences between the species on the basis of internal form and structure.
Untrained Customs officials intercepting consignments of Panthera spp. bones are even less likely to be able totell bones from the species apart.
While body size is an age- and sex-related morphological variable difficult to detect in skeletons, Lions areusually smaller than Tigers (Table A12). In addition, Lions have two fewer hyoid bones (Weissengruber et al.,2002) and their skulls are broader and flatter across the bridge of the nose. The position and alignment of theposterior projections of the naso-frontal and maxilla-frontal sutures on the skull might, however, offer the best
rule for identification and allow quick determinations to be made (Figure A1). Ultimately, forensic DNA testing
would be the most dependable method for correctly determining the species (Cao et al., 2011; Tobe and Linacre,
2010)
Table A12 Comparative morphological differences of Lions and Tigers
FeatureBody
weight(kg)
Head/bodylength(mm)

Skull

Maxillofrontal &nasofrontal
sutures
Hyoid
bones

Lion*

Tiger

Notes and information source♂ mean: 189.6 (range 150.0–225.0)♀ mean: 103.8 (range 83.0–165.0)♂ mean: 225 (range 195–325)♀ mean: 121 (range 96–160)

Lions in captivity are normallylarger than those in the wild.
Macdonald et al. (2010)♂ mean: 1949 (range 1835–2000)♀ mean: 1710 (range 1425–1850)
Generally broader and flatter across thebridge of the nose, and the face isupturned.
In dorsal view, the apex of the nasals iseither in line with the apices of themaxilla-frontal processes or moreanterior to these.
7♂ mean: 2300 (range 1900–
2900)♀ mean: 1711 (range 1460–1770)
Generally more rounded skullthat is narrower and sharper
along the bridge of the nose.
The face tends to tilt sharply
downwards.
In dorsal view, the nasal
projections extend significantly
more posterior than theposterior projection of themaxillae9

Macdonald et al. (2010)

Source: Raptor’s Nest (2008),
who derived the informationfrom identification criteria
published by Merriam andStock (1932).
This is a more consistentfeature. See Figure A1.

Source: De Iuliis and Pulerà(2007); Weissengruber et al.
(2002)* For southern African Lion populations; Lions in East Africa are generally larger (Macdonald et al., 2010)

Skeletal Anatomy of Lions
Provinces issuing permits to export Lion bones variously record the quantity being exported as either thenumber of skeletons, and sometimes the mass thereof, or the number of bones (Source: DEA annual CITES
reports for 2006–2011). In one case a permit listed all the names of the bones in the “set” and the numbers
thereof (e.g. 3 x xiphoid process; sets of carpels in wrist). However, the Management Authorities in charge of
issuing CITES permits currently have no practical identification guide describing the skeletal anatomy of Lionsthat would be useful for evaluating permit applications. To address this need, a guide to the names andnumbers of the bones was produced (Figure A2; Tables A13 & A14).

102

Bones of Contention: An assessment of the South African trade in African Lion bones

Bones of Contention: An assessment of the South African trade in African Lion bones

103

Caudal vertebrae
SacrumPelvis
Tarsals
Metatarsals & hindphalanges

Thoracic vertebrae
PatellaRibs
Thoracic vertebrae
Sternebrae (sternum)
ScapulaHumerus
Ulna and radius
Cervical vertebrae‘Floating bones’ (clavicle)
Carpals
Metacarpals & front
phalanges
Cranium & mandible

Figure A2 A reassembled Lion skeleton. Colours correspond to columns in Tables A13 & A14. Bones labelled inblue and orange are important to buyers in East–Southeast Asia; bones labelled in green are not always
exported
There are up to 309 bones in a Lion skeleton – including the ossicles in the ear, the hyoid bones in the throat,the sesamoid bones in the digits and joints, and the teeth (Table A13). The ossicles, sesamoids and hyoid bones
are not typically included in sets destined for export given their small sizes. Assuming the bones came from a
non-trophy hunted Lion, a typical “set” of bones exported to East–Southeast Asia could comprise up to 240
bones and teeth plus the claws (Figure A2, Table A13).
Trophy hunters, usually take the skull and teeth, and sometimes the floating bones, as mementos from theirhunts (Table A15) – hence only 14% of skeletons obtained from trophy hunted Lions are likely to have acomplete set of bones available for export (data derived from the annual CITES reports for 2006–2011 suppliedby DEA). The “floating bones” (a pair of clavicles), considered a symbol of power in Tigers (Nowell, 2000), areless frequently taken with the hunter as a memento, and only 10% are exported (Table A15). Accordingly, a set ofbones obtained from most trophy-hunted Lions would typically have up to 206 bones (Table A14). The skulls,
along with the patellas (knee caps), are important since these are the most valuable bones in a Tiger skeleton

104

Bones of Contention: An assessment of the South African trade in African Lion bones

(Nowell, 2000) and a Lion skeleton from South Africa could sell for an additional ZAR3000 to ZAR5000 (USD315–
USD525) if these bones are present in the set (see Table 12).

Cranial skeleton

Table A13 Typical skeletal anatomy of an adult Panthera leo. Colours of the shaded cells correspond with thelabel lines in Figure A2. Bones in the blue and orange cells are important to buyers in East–Southeast Asia;
bones in the green cells are not always exported; bones in the purple cells are seldom or never exported
Name

Numberof bones

Cranium

1

Mandible

1

Ossicles (ear)6

Hyoid bones (throat region)

9

Set of teeth30

Set of cervical (neck) vertebrae

7

Set of thoracic (chest) vertebrae

13

Set of lumbar vertebrae

7

Sacrum1

Set of caudal (tail) vertebra

up to 26

Ribs

26

Sternum/sternebrae

8

Notes

Tigers have 7 hyoid bones (Weissengruber et al., 2002)

Three fused sacral vertebrae
Cited variously as 18-20, 23, or 25-26 bones by several sources

Postcranial skeleton

Forelimbs
Scapula2

Clavicle (“floating bones”)

2

Humerus

2

Ulna

2

Radius2

Set of carpals in forepaw

14

Set of metacarpals

10

Set of phalanges (digits/toes)

28

Frequently mistakenly referred to as “floating ribs”

Incl. pisiform bones

Hind limbs
Pelvis

2

Femur

2

Set of patella (knee caps)

2

Tibia

2

Fibula2

Set of tarsals in hind foot14

Set of metatarsals

10

Set of phalanges (digits/toes)

24

Sesamoids (in digits and joints)

54

Set of claws
Total

Paired innominate bones, each with a fused ilium, ischium and pubis
Lions only have 2 knee caps, not 4 as has been erroneously
reported by consignors on some export permits

Incl. calcaneus heel bones(digits: 9+4 per front foot; 8+4 per hind foot) + (joints: 2 per hindleg) (see Evadiugan, 2011). 32 of these bones are the mostdiscernable
18 (10 on forepaws; 8 on hind paws)

Up to 309

Source: Information derived from examining permit records sent by DEA; from De Iuliis and Pulerà (2007); Evadiugan (2011);
Weissengruber et al. (2002); Andrew Kitchener (Principal Curator Vertebrates, National Museums Scotland; in litt., 2013);

Multiple internet sources.

Bones of Contention: An assessment of the South African trade in African Lion bones

105Table A14 Lion bones likely to be included in a “set” from trophy and non-trophy animals. Green-shaded cells
indicate differences in bone numbers from Table A13. See text for explanation for information in the last column
and how the information was derived
Bones likely to
be in a “set” froma non-trophy
animal (Figure
A2)

Bones likely to be in a“set” from a trophy
animalCranium

1

85.8% exported bytrophy hunters (seeTable A15)

Mandible1

Cranial skeleton

Name

Example. Orange cells: unnamed parts ofa Lion skeleton that total “117” bones
recorded on a 2010 CITES permit. Bluecells: bones named on the permit. Greencells: bones not named and unlikely to bepart of a set of 117 bones.
(1)(1)

Ossicles
Hyoid bones
Set of teeth

30

Variable inclusion

7

7

13

13

Set of lumbar vertebrae

77

Sacrum1

1

Set of caudal (tail) vertebra

26

26

Ribs

26

26

Sternum/sternebrae

88

Set of cervical (neck)vertebrae
Set of thoracic (chest)
vertebrae(30)

Forelimbs

Postcranial skeleton

Scapula222

Clavicle (“floating bones”)

2

10.0% exported bytrophy hunters (Table
A15)

2

Humerus

2

2

2

Ulna

2

2

2

Radius22

2

Set of carpals in forepaw

14

14

16

Set of metacarpals

10

10

10

Set of phalanges(digits/toes)

28

28

28

Pelvis22

2 halves or 1 fused

Femur

2

2

2

Set of knee patella22

Hind limbs

(2)

Tibia

2

2

2

Fibula2

2

2

Set of tarsals in hind foot

14

14

14

Set of metatarsals

10

10

8

Set of phalanges(digits/toes)

24

24

24

Sesamoids
Total

106

up to 240 bones,
including teeth

up to 206 bones,
excluding teeth

up to 117 bones

Bones of Contention: An assessment of the South African trade in African Lion bones

Table A15 The proportion of Lion trophies that are exported with or without the skull and floating bones andthus the proportion of “complete” sets of skeletons (with ±240 bones) likely to be represented in the total
number of Lion skeletons exported annually% of skeletons obtained fromtrophies that exclude thesebones% of “complete” skeletonsobtained from trophies that
include these bones

Sample size, n (i.e. no. of
permits used to estimate the %completeness skeletons)

85.8%

14.2%

n=1464 of 1706 permits

10.0%

90.0%

n=135 of 1356 permits

Trophies exported with orwithout the skull
Trophies exported orwithout floating bones

DEA supplied detailed information from the 2006–2011 CITES Lion reports (T. Carroll, in litt., May 2013); thereports list the permits issued per province to export/re-export Lions and Lion products. The information
supplied excluded the names and addresses of the importers and exporters, but included a description of thespecimens(s) (e.g. “full skins & 2 pairs floating bones”), the quantity of each specimen, the country of export/reexport, and the unique CITES permit number. A critical evaluation of the permits issued to export Lion products(especially bones to East–Southeast Asia) could thus be conducted. For example, in 2010 four CITES permits
were issued to export bones to Lao PDR; the following information was recorded in the Description (D) and
Quantity (Q) fields on the permit:
a)
b)
c)
d)

117x9 bones (D); 9 (Q)117x9 bones (D); 9 (Q)117x3 bones (D); 117 (Q)117x6 bones (D); 117 (Q)The question is: which bones from a Lion would make up a set of 117 bones? To answer the question, bonenumbers from Table A13 were added up in various combinations. If one counts the pelvis as one fused bone
instead of two halves, then a set of 117 bones:

Includes: all the bones in the orange-shaded cells in the last column of Table A14 (mainly limb bones);
Excludes: the cranium, mandible, teeth and patellas (indicated in blue-shaded cells);
Excludes: all the ribs and vertebrae (indicated in green-shaded cells in the last column of Table A14).

Unlike the ribs and vertebrae, however, the cranium/mandible/teeth/patella were exported with the four
consignments (a–d above), but they were specifically itemized on separate lines of the permits (judging from thepermit numbers accompanying the report). Furthermore, the quantities recorded in permits a–d above add up
to 27 partially complete skeletons (with ≈3159 bones, excluding skulls, teeth and patella) and not 252 bones as
the total for Q seems to indicate. Tiger bones are generally sold in one of three forms in East–Southeast Asia: (1)as whole joints (usually from one of the limbs to treat arthritis and joint pain), (2) dry fragments, or (3)derivatives rendered into another product such as wine (Nowell, 2000). Skulls, teeth and claws are alsopreferred. The apparent absence of the ribs and vertebrae in the consignment of 27 Lion skeletons (Table A14),and the inclusion of the bones from the hind- and forelimbs, is thus indicative of the greater worth of the limbs
to Traditional Asian Medicine.
In another example from four consecutive CITES permit issued in 2010, an exporter went to great lengths to list
the scientific names of the bones (e.g. 6 pisiform bones, 3 sets of caudal vertebrae; 6 sets of metacarpals; 3 setsmanubrium/illium/ischium/pubis; etc.). In the process, however, they incorrectly named and numbered some of
the “bones” – for example 6 x “calcaneus/clavicle/olecranon/shoulder blades” – and thereby obfuscated the real
number of bones and thus skeletons being exported. The olecranon, for example is not an individual bone, but
a process extending from the top of the ulna (and the ulna was recorded in a separate entry); the calcaneus is
the heel bone. It was this series of permits that prompted the development of the guide to Lion skeletal
anatomy. By comparing the entries on the permit with Figure A2 and the terminology for parts the postcranialskeleton of cats from De Iuliis and Pulerà (2007) and Table A13, it was determined that the four permits were for

Bones of Contention: An assessment of the South African trade in African Lion bones

107bones from three Lion skeletons totalling about 720 bones (and not 586 bones as was finally captured on the
UNEP-WCMC CITES trade database).

The Mass of Lion Skeletons
Knowledge of the average mass of a cleaned skeleton is necessary for: (1) interpreting approximately how manyskeletons are being exported when only the mass of a consignment is recorded on a CITES permit; (2)standardizing and consolidating the total quantities exported as either x-number of skeletons or y-total-mass ofskeletons; and (3) verifying whether an exporter is being honest in their declarations of the quantities being
exported (this is especially useful for the Management Authorities issuing CITES permits). Tiger skeletons are
estimated to weigh 12 kg (Nowell, 2000), but there were no data available with a large enough sample size toindicate the average mass of a Lion skeleton. Given the smaller body size of Lions (Table A12), the skeletonswere expected to weigh less than that of a Tiger.
Most CITES permits issued to export Lion bones record the quantity only as the number of skeletons and/or
bones and do not include the mass of the consignment. In some cases where mass was recorded, there was no
indication of the number of skeletons the mass was equivalent to. Occasionally both the mass and the numberof skeletons were recorded on a permit, and information from 16 permits to export what was originally believed
to be 433 skeletons to Southeast Asia were obtained (Table A16). In addition, two skull-less skeletons from male
Lions were weighed at the Ditsong National Museum of Natural History in Pretoria as a reference. The museum
specimens weighed 6.25kg and 8.99kg.
The mean mass per skeleton was initially calculated to be 10.81 ± 3.66 kg (S.D.) (Table A16). However, the mass
per skeleton of two records appeared anomalous and unusually high (Permits 1 and 2, Table A16, where
skeletons on Permit 1 were 2.3 times heavier than the heaviest museum specimen), suggesting that the numberof skeletons being exported had been incorrectly or falsely declared on the permit. To test this presumption of a
false declaration, a simple linear regression of the relationship between the number of skeletons and the massof the consignment indicated an R2=0.716 and two possible outliers (n=16 consolidated consignments and “433”skeletons) (Figure A3). When data from these two anomalous exports were excluded from the calculations, theaverage mass of a skeleton in a consolidated consignment was 9.53 ± 1.05 kg, which was only 540 grammes
heavier than the heaviest museum specimen. An assumption was thus made that twice as many skeletons werein these two consignments than was declared on the permit. When the number of skeletons was doubled forthese permits and the linear regression was revised, the correlation increased to R2=0.991 and the average mass
per Lion skeleton was 9.57 ± 1.00 kg (n=16 consignments, and the number of skeletons revised to 513) (Figure
A4; Table A16).
When data on skeleton mass obtained from the museum, the 16 consolidated consignments and 34 bags ofindividually weighed Lion bones (Table A17) were combined, the mean mass of a Lion skeleton was recalculated
and estimated to weigh 8.95 kg ± 1.78 kg (n=551 skeletons). The skeletons were assumed to be mostly skull-lesssince about 86% of exported skeletons are inferred to be incomplete (i.e. missing the skull) if they are derived
from trophy hunts (Table A15). However, the actual proportion of exported Lion bones derived from non-trophy
animals is not known, and so the proportion of skull-less skeletons cannot be verified without having viewed theconsignments.

108

Bones of Contention: An assessment of the South African trade in African Lion bones

Table A16 Permit data on the declared mass of a consignment and the number of skeletons. The skeletons wereassumed to be of mixed age, sex and completeness (i.e. some were missing skulls). The number of skeletonsdeclared on Permits 1 and 2 were presumed to be anomalous (see Figure A3) and thus corrected for (Figure A4)
Permit No.
Permit 1
Permit 2
Permit 3
Permit 4
Permit 5
Permit 6
Permit 7
Permit 8
Permit 9
Permit 10
Permit 11
Permit 12
Permit 13
Permit 14
Permit 15
Permit 16

Declared mass of theconsignment (kg)
661.0
947.0
47.6
144.0
146.0
129.0
409.0
651.0
192.0
76.0
47.6
137.6
364.0
247.0
380.0
366.0
Provisional result

Declared number ofskeletons
32* (64)
50* (100)
5
19
13
12
46
66
19
10
5
14
39
25
43
35
n=433 skeletons

Mass per skeleton ± S.D.
(kg/skeleton)
20.66* (10.33)
18.94* (9.47)
9.52
7.58
11.23
10.75
8.89
9.86
10.11
7.60
9.52
9.83
9.33
9.88
8.84
10.46
Mean=10.81 ± 3.66 kg/skeleton* likely to be incorrect
Mean=9.57 ± 1.00 kg/skeleton corrected

Corrected: the results after the quantities declared on
n=515 skeletons
Permits 1 and 2 were doubled* Anomalous mass and thus probably a false declaration on the CITES permit for the number of skeletons declared to beexported. The number of skeletons was thus revised and doubled to correct the anomaly (see text).

Figure A3 Linear regression for data in Table A16. Two of the exports appeared anomalous for the number ofskeletons declared

Bones of Contention: An assessment of the South African trade in African Lion bones

109

Figure A4 Revised linear regression with the anomalous data two exports corrected for. See Appendix 5 forlarger version of this graph that can be used to crosscheck declared quantities of exported skeletons

The assumptions made thus far when calculating the average mass of a Lion skeleton are that the skeletons are:(1) of mixed sex, (2) of mixed age, and (3) are derived from a mixture of non-trophy hunted and trophy hunted
animals (i.e. with and without skulls respectively). Therefore, the estimate takes into account normal variations in
the mass of skeletons of different sexes, ages and skeleton completeness.
A subsample of 34 bags of skeletons derived from two consignments that were being exported with skulls(Figure A5a), without the skulls (Figure A5b), and unknown skull presence/absence was made available to thisstudy (Table A17). The skeletons with skulls weighed on average 2.15 kg more than the skeletons without skulls.
Table A17 Average mass of a subsample of 34 bags of Lion bones with and without skulls (refer to Box 4 foroverall mean)

Skeletons with skulls

Number of bags
10

Mean ± S.D
9.05 ± 2.34 kg/bag

Skeletons without skulls
Skull presence/absence not recorded

1014

6.90 ± 0.74 kg/bag
9.83 ± 1.43 kg/bag

110

Bones of Contention: An assessment of the South African trade in African Lion bones

(a)!

(b)!
(a) © VIVIENNE WILLIAMS; (B) © “ANONYMOUS”

Figure A5 Bags containing one Lion skeleton each with (a) a skull, and (b) no skull, en route to East–Southeast
Asia

Bones of Contention: An assessment of the South African trade in African Lion bones

111

Appendix 5: A GUIDE TO THE MASS VS. NUMBER OF SKELETONS IN CONSIGNMENTS OF
EXPORTED LION BONES

Figure A6 A guide for CITES permit issuers and others on what a consignment of a specified number of cleaned
lion skeletons of varying completeness should weigh. The information is derived from 515 skeletonsconsolidated into 16 consignments. Dashed lines parallel to the regression (solid line) indicate the range within
95% of the mean. y=9.6456x–1.4851; R2=0.993

112

Bones of Contention: An assessment of the South African trade in African Lion bones

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