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The public consultation about the UK import and export of hunting trophies has now been launched and we urge everybody to take the time to return the questionnaire issued by the Government by the deadline of the 25th February 2020. The link to begin the consultation is here.


This consultation is quite long, 15 questions in all to be answered, and the questions are interspersed with much “explanatory” but perhaps sometimes rather selective text from the UK Government. It also seems to us that a more detailed knowledge of CITES and the EU Wildlife Trade Regulations are assumed, despite the “explanatory” text passages included throughout the questionnaire.

So, in order to help you complete this questionnaire, we have provided you with a summary of points that need to be made in your answers and also we have reprinted the questions you will be asked and shared with you the main points that we consider important that you may wish to consider in your answers.

 Main points, information and background to trends in the information requested of you.

1.       CITES and the IUCN Red List.

There are a number of questions that allude to whether the species to be banned from imports of their hunting trophies should be taken from CITES Appendices or the IUCN Red List. You should be very clear in your answers that CITES is only concerned with trade in plant and animal products and does not consider trophy hunting to be “trade” in wildlife products. Therefore, a large number of species that are trophy hunted are not listed on any CITES appendix and the impact of trophy hunting is not considered by CITES when a species comes up for review in terms of the Appendix that it is listed on. For example, when lions have been considered in the past as a candidate species to be placed on Appendix 1, this was always rejected because the trade in lion products was confined to trade in skins, teeth and claws and did not at all consider hunting trophies. As trade in lion products is minimal compared to trophy hunting offtake, CITES always considers trade in lions to be non-detrimental to conservation of the species. Also CITES has very many shortcomings in terms of their record keeping especially when it comes to numbers of specimens involved in trade as reported by the importer versus the exporter of such products. These discrepancies can be very large and therefore it is almost impossible to derive any meaningful trade statistics from the official CITES trade database. CITES trade database does have a “trophy” category but again a trophy can be listed as a “trophy”, as a “skin”, as a “skull”, as “tusks” etc. So again it is impossible to determine how many hunting trophies have actually been exported and/or imported.


As for the IUCN Red List, this is probably a better source of species from which hunting trophies should be banned. However, the IUCN Red List also contains many flaws – eg the IUCN does not consider sub-species designations of many species like giraffes, elephants, lions, leopards, buffalos etc. Also the red List is not regularly updated for many species and population estimates are often flawed. For lions, which should have been listed in the IUCN “endangered” category, the reviewers used highly contentious data from lion populations

occurring in fenced, private reserves in South Africa to claim that lion populations in all of Africa were not “endangered enough” to be placed in the “endangered” category. Similarly, African elephants with a population of over 400,000 are considered to be endangered while African lions with a population of 15,000 are only considered as “vulnerable”.


2.       Benefits of trophy hunting

Throughout the consultation document, preambles to the questions state frequently and repeatedly that well regulated trophy hunting can bring conservation benefits to both the species being hunted and communities living with those species. There is a wide diversity and large volume of evidence that questions such supposed benefits – for example it has been shown that trophy hunting is the least economically valuable form of land use in Africa, that financial benefits to communities are minimal to non-existent, that in most cases there are still significant questions about the assumed relationship between trophy hunting and conservation that there is no evidence whatsoever that trophy hunting is a sustainable activity simply because there have been no independent wildlife counts in any trophy hunting concession (while there is considerable evidence that trophy hunting operators frequently lure animals out of protected areas to be shot), that trophy hunting does not promote community tolerance of wildlife as evidenced by continued involvement of communities in commercial and bushmeat poaching, that claims of schools, clinics and bore holes provided to communities and funded by trophy hunting profits are often empty and/or exaggerated, that hunting concession tenders have been shown to be frequently corrupt and non-transparent, that there are no penalties for bad stewardship  of hunting concessions resulting in great decreases of all wildlife in hunting concessions across many African nations that permit trophy hunting etc etc. In short, claims of positive benefits of trophy hunting to wildlife conservation are completely lacking in independent scientific proof and are nothing more than rhetoric and propaganda. It is sad to see that, nevertheless, such unsupported statements are frequently repeated in this call for public consultation.


3.       There are several questions to do with enforcement.

It would seem that the UK for some reason is quite concerned about enforcement of any particular ban on the import of hunting trophies. It seems to us that this concern is misplaced as a number of other nations have already instituted similar bans on imports of hunting trophies covering either selected species or a much more comprehensive ban. These nations include the USA, France, Netherlands, Australia, Kenya etc. These nations have not reported any particular difficulties in terms of enforcing their bans and if the UK has any particular concerns in this matter, it would be a simple thing to consult with those nations directly.


Questions 1 to 4 relate solely to your personal details.

Question 5: Is there anything you would consider to be a hunting trophy that falls outside of the definition found in CITES and the EU Wildlife Trade Regulations (WTR)?

  •   We answered yes.
  •  CITES and the EU WTR are concerned with trade in fauna and flora.
  •  They do NOT consider hunting trophies to be part of trade.
  •  Hunting trophies are instead treated as “personal and household effects” and do not generally involve realistic quotas.

 Question 6: Is there anything that falls within the definition used in CITES and the EU WTR that you consider should not be treated as a hunting trophy?

  •  We answered no, meaning no further explanation needed.

 Question 7: Do you envisage any challenges or difficulties which might arise from using the definition in CITES and EU WTR, for example, when it comes to enforcement?

  • We answered yes
  • CITES record keeping falls well below expected and regular standards.
  • Export permits issued by local CITES authorities often fall short of necessary care to ensure accountability and traceability of trophy hunting specimens.
  • A single trophy can be listed under several different categories in the trade database (see general point above on CITES).
  • Country of origin can be confused if a trophy is collected in one country, sent for taxidermy to another country, exported to a third country before finally arriving at the hunter’s country of residence.
  •  It is clear that CITES authorities are often very unclear about “source codes” – meaning that it is impossible to determine by customs authorities of the country of import whether a hunting trophy derives from a captive bred or wild population.

 Question 8: Please state your first and second preferred option

·       Option 1: a ban on hunting trophies from certain species entering or leaving the UK. We rank this as our preferred option

·       Option 2: Stricter requirements for clear benefits to conservation and local communities to be demonstrated before hunting trophies from certain species are permitted to enter or leave the UK. We rank this as our second most preferred option.

·       Option 3 – a ban on all hunting trophies entering or leaving the UK. We ignored this option.

·       Option 4 -  do nothing – continue to apply current controls based on internationally agreed rules. We ignored this option.

Please add any comments on your preferred options, including any reasons for your preference or suggest alternatives.

Option 1:

  • The ban on imports and exports of hunting trophies entering or leaving the UK should be based on how endangered the particular species is and how vulnerable a particular species is to hunting offtake.
  • Certain species are of minimal concern and a blanket ban of hunting imports and exports of those species would nor serve any conservation purpose.
  • Other species are much more highly affected by trophy hunting and the import and export of such species should be completely banned at this time and with immediate effect.

Option 2:

  • The requirement that hunting trophies should benefit the conservation of the species and be based on financial benefits to local communities is almost impossible to monitor.
  • Conservation benefits of hunting offtake for a particular species have never been documented and are unlikely to be independently evaluated in the future. Instead, conservation benefits are largely submitted to CITES as “non-detriment” reports by local authorities and these are susceptible to political influence and corrupt practices.
  • It is well documented that the largest percentage of trophy hunting fees accumulated by hunting operators do not even enter the country of origin of the trophies, that payments to communities largely benefit only the elites within those communities, that associated benefits like schools and clinics are either not built, abandoned at early stages, or are permanently stuck in planning stages.

 Question 9: Options 1 and 2 introduce further restrictions for certain species, Which species do you think these further restrictions should apply to?

  • We answered species listed on the IUCN Red List with the following justification and explanation.
  • Species listed on Annex A or B of the EU WTR are species involved in commercial trade – while there is some overlap with species desirable to trophy hunters, there are many species not involved in commercial trade that are imported and exported as trophies.
  • Species to be considered for bans should be those listed under the categories of “critically endangered”, “endangered” and “vulnerable” on the IUCN Red List.
  •  It should be acknowledged that the IUCN Red List contains many omissions, has many faults and that the status of many species is not regularly updated or is updated using questionable and anecdotal information.

 Question 10: Do you think there should be different restrictions on hunting trophies imported and exported to and from countries to and from countries within the EU compared with countries outside the EU?

  • We answered no

 Question 11: Do you have additional information or evidence on potential impacts of increased restrictions as set out in Options 1 to 3

  • A ban on UK trophy hunting imports will send a very strong conservation message to other nations contemplating this increasingly necessary course.
  • It will encourage expansion of photographic tourism – this non-consumptive form of wildlife utilisation brings in significantly higher financial returns, more durable employment and much greater benefit to communities.

Potential enforcement problems which might arise as a result of using a definition of hunting trophy based on the one used in CITES and the EU WTR?

  • We see no potential enforcement problems – the definition of a hunting trophy has been applied to enforce bans of various species in the USA, the Netherlands, France and Australia without difficulties arising.

Potential barriers to implementation for Options 1 to 3?

  • These questions are all highly speculative. Similar bans on trophy hunting imports have been in existence for several years in many countries without any reported problems arising. We would suggest getting in touch with the customs authorities in those countries to address any concerns about potential problems that the UK might have.

 Question 12: In Options 1, 2 and 3, do you think there should be different restrictions on hunting trophies obtained from wild animals, animals that have been bred in captivity to be hunted, or animals which have been hunted in confined enclosures?

  • We answered no.

 Question 13: For Options 1,2 and 3, do you think there should be any exemptions considered? Please state your reasons why.

  • We answered no.

 Question 14: Do you agree with our proposed enforcement regime?

  • We answered yes.

 Question 15: Overall, how satisfied are you with our online consultation tool?

  • We answered dissatisfied – we thought the questionnaire was unnecessarily complicated and questions framed in ways that could be confusing and unclear. We mentioned that the preambles to the questions contained many unfounded statements often used in pro hunting propaganda and rhetoric.
  • We noted that it is yet to be demonstrated that trophy hunting is largely conducted in a well regulated manner, that communities benefit to any significant extent, that trophy hunting has demonstrably benefitted the conservation of any species and that trophy hunting has led to any increase in tolerance by local communities to depredations caused by wildlife.





1 Comment | Posted by Chris Macsween at 12:41