South Africa’s Proposed CITES Trophy Hunting Export Quotas for Elephant, Black Rhino and Leopard

On 23 March 2026, the Biodiversity Law Centre submitted detailed comments to the Department of Forestry, Fisheries and the Environment on the proposed 2026 and 2027 Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) export quotas for elephant, black rhinoceros, and leopard hunting trophies, in terms of the National Environmental Management: Biodiversity Act 10 of 2004 (NEMBA).

As the third most biodiverse country in the world, South Africa’s biodiversity is of global significance. The species subject to the quotas include African elephant, listed on CITES Appendix II for South Africa, and black rhino and leopard, listed on CITES Appendix I, meaning these species are threatened with extinction or may become threatened with extinction as a result of unregulated trade. Their protection is further a constitutional imperative under section 24 of the Constitution, and the statutory duties under NEMBA. Their protection is also vital for meeting South Africa’s international obligations under the Kunming-Montreal Global Biodiversity Framework.

The BLC submits that the proposed Hunting Trophies Export Quotas are invalid on both procedural and substantive grounds and must be withdrawn.

Particular concern is raised about:

• Unconstitutionality: The Quotas fail to fulfil the section 24(b) constitutional right to have the environment protected for present and future generations as they do not demonstrate how trophy hunting of species threatened with extinction promotes conservation or ecologically sustainable development. The Quotas also fail to account for the intrinsic value of animals, which the Constitutional Court has recognised as integral to the section 24 environmental right.

• Invalid administrative action: The Quotas rely on outdated and inaccessible information and are more closely aligned with economic objectives than the conservation and ecological objectives they purport to serve.

• Failure to comply with CITES Regulations: No non-detriment findings are referenced for black rhino or leopard, as legally required before export quotas can be set. For elephant, updated non-detriment findings were only published after the Quotas, depriving the public of the opportunity to engage with critical scientific information.

The BLC calls for the Hunting Trophies Export Quotas to be withdrawn in their entirety, and for no export permits to be issued for these species. Read our full submissions below: