Their Future Is Dark. The Rhino Horn Trade in 2019
Megan Carr
16th August 2019

The Department of Environment, Forestry and Fisheries

Environment House

473 Steve Biko Road

Arcadia

Pretoria

0083

email:  fshaik@environment.gov.za

           tzikalala@environment.gov.za

15thAugust 2019

Attention: The Minister of the Environment, Forestry and Fisheries

“Their Future is Dark” THE RHINO HORN TRADE 2019

The history surrounding the demand for African rhino horn is complex.  During the European colonial era trophy hunting was largely responsible for the decimation of the rhino populations, for decades thereafter the uncontrollable illegal rhino horn trade between Africa and Vietnam and China is to blame. 

Traditionally, once removed the horn was polished to a beautiful translucent hue and carved to make magnificent ornaments, or the horn was ground down into a fine powder and used in traditional Asian medicine, but increasingly rhino horn is now being used as a status symbol to display success and wealth.  

Recent studies published in May 2019 by Professor Vu Hoai Nam Dang and Professor Martin Reinhardt Nielsenhave from the University of Copenhagen have further determined that the discerning consumers prefer rhino horn that is derived from wild rhino not farmed rhino. Furthermore, Douglas Cookes and James Blignaut point out that game farms may harvest horn every 1.5 years, whereas for poachers it is optimal to kill a rhino and harvest its horn, even at very low rotation intervals: “This suggests that, even if a rhino poacher encounters a dehorned rhino, it is still optimal to kill the rhino and take what is left of the stump.  This casts further doubt on the effectiveness of a legalized trade”.

Seventy-percent of the world’s remaining rhino population live in Southern Africa. We are therefore the key role player in determining the future of the species. The enormous responsibility to conserve this species rests firmly with us.During the five-year period 2012-2017 51% of the white rhinos population have been obliterated from the Kruger National Park and a further 26% from other state-owned parks. 

Despite this alarming decline of rhino numbers and instead of using this unique opportunity to harness exacting tourism and job creation, South Africa has chosen to trade in rhino horn which benefits only a few private owners.  Information about the state owned stockpile of rhino horn is unfortunately not freely available.  South Africa has undergone a period of systemic political corruption commonly referred to as state capture  Various state owned  rumors abound about the possible pilfering of the stockpile, urgent transparency in this regard is imperative.   

We, the undersigned organisations and individuals belonging to the Wildlife Animal Protection Forum South Africa, are not confident that those in favour of legalizing the domestic or international trade in rhino horn trade prior to 2017 have adequately considered and or resolved the complex issues at hand.  We do not not support the domestic or the international trade in rhino horn. 

The international legal trade in rhino horn is regulated by the Convention on International Trade of Endangered Species (CITES).  The international trade of rhino horn has been banned since 1977.  Individual countries are able to determine their own laws about the domestic trade of rhino horn.  At the CITES Conference of the Parties (CoP) held in 2016, Swaziland tabled a last minute proposal to unban the international trade in rhino horn.  This proposal was overwhelmingly rejected 100-26 with 17 abstentions. 

In 2009 a ban of the domestic trade in rhino horn South Africa was introduced because of the poaching crisis.  This ban was opposed by some private rhino owners including John Hume and Johan Kruger. Hume and Kruger successfully ligated against the ban.  The High Court ruling stated that the incorrect due process was followed during the public consultation process by the Department of Environmental Affairs before imposing the ban. The decision taken against the DEA was upheld by the Constitutional Court.  After defending the ban through all the legal processes it remains unclear why the DEA did not attempt to re-advertise its intention to ban the domestic trade in rhino horn with required notice period and circulation of information. 

Instead, the DEA, under the leadership of Minister Molewa, chose to focus on developing new legislation which included setting out the requirements for the domestic sales of rhino horn.  Numerous organizations in South Africa and internationally appealed against this decision. 

A Committee of Inquiry was appointed by the DEA and tasked with producing a report on the viability of the domestic rhino horn trade in South Africa.  Apparently the full report was completed in 2016 but only a summary report has ever been made available. We would appreciate access to full report in order for us to understand and evaluate the COI’s findings. 

“The primary recommendation from the Committee was that the government should do everything possible to create an environment conducive for rhino conservation in South Africa, to effectively address rhino poaching and the illegal trade in rhino horn, and to reach a point where any potential trade in rhino horn would contribute to conservation outcomes”.

It is a well documented fact that the illegal killing of rhino and the illegal trade in rhino horn continues unabated across Africa and Asia.  The rate of killing in parts of Africa has continued to increase dramatically over the past decade and this has threatened the continued survival of the rhino species and negatively impacted the ecosystems in which they live. The rhino poaching figures presented by the DEFF on the 31stJuly 2019 do not, we believe, necessarily represent a decline in poaching but rather highlight the fact that there are less rhino to poach. 

The scale of the rhino poaching crisis poses a threat to the national security of our country and to the other range states.  Rhino poaching fuels conflict and unrest, it destroys livelihoods, it promotes corruption and negatively impacts wildlife based economies and all conservation efforts.  

Of the fifty-seven proposals to amend on the lists of species, two relate to the white rhino and will once again be on the agenda at CoP18 which will be held in Geneva, in Switzerland in August 2019.  Parties attending CoP18 will once again address the contentious issue of the rhino horn trade with proposals to further restrict commercial trade, and counter-proposals intending to remove trade restrictions.  Parties attending CoP18 will also consider a proposal on the establishment of a database for the storage and management of illegal trade data collected through CITES annual illegal trade reports.

eSwantini, formally known as Swaziland, has tabled a proposal to remove the existing annotation on the Appendix II listing of its white rhino population which would allow international trade in rhinos and their products including horn. Namibia has tabled a proposal to allow for a live animal trade in white rhino and for trophy hunting, in other words they have proposed to change the status of their white rhino population from Appendix I to Appendix II.    

The legal domestic market in South Africa, we believe, is contributing to the poaching of rhinos in South Africa and in neighboring African countries. The legal domestic trade has undermined demand reduction campaigns and enforcement efforts and it has provided potential routes through which illegally obtained rhino horn might be laundered.  

The domestic trade in rhino horn weakens the international trade ban under CITES.  Over the past two years frequent shipments of farmed rhino horn from South Africa have been intercepted at international border and recently there have been large scale illegal shipments of farmed rhino horn intercepted within South Africa.

The poaching of rhinos and the illegal trade of rhino horn is an organized transnational crime, it is organized by criminal syndicates that profit from the sale of rhino horn and horn products to satisfy consumer demand principally in Asia. 

We are in agreement with a number of parties to CITES in their request to destroy government stockpiles of rhino horn.   Public stockpile destruction events have taken place in China, Czech Republic, India, Kenya, Mozambique, Nepal, Taiwan, United Arab Emirates, USA and Vietnam. 

In the interim we ask that the DEFF identify, mark, register secure stockpiles and declare the results. Rumors that South African state stockpiles might have been compromised during State Capture period abound, South Africa’s conservation reputation is at further risk. 

Wehereby formally request that the Minister re-considers the negative impact of the domestic rhino horn trade in South Africa which includes the export internationally of rhino horn for “personal purposes”.  

We have attached the petition signed more than half a million people asking for the ban on the domestic trade of rhino horn to be re-introduced in South Africa. 

SIGNED

Global March for Elephants and Rhinos Organisation

OSCAP

Ross Harvey

Elephant Reintergration Trust

BAN ANIMAL TRADING 

SAFFR

Beauty Without Cruelty South Africa

Voice4Lions 

Humane Society International Africa

Animal Welfare Reform

Landmark Foundation

EMS Foundation 

Global White Lion Protection Trust

Animal Law Reform

Sea Shepherd South Africa

Future 4 Wildlife 

Baboon Matters

Vervet Monkey Foundation

IMAGE CREDIT Harman Singh Heer