The African elephant proposal by South Africa to the 12th meeting of the Conference of the Parties (COP) to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES):

Proposal by South Africa to amend the annotation attached to the Appendix II listing of the South African population of African elephant to allow the initial sale of the Kruger National Park (KNP) stockpile of ivory, 18-months after the adoption of the proposal and a subsequent annual quota of two tonnes. This proposal is for the exclusive purpose of allowing:
trade in hunting trophies for non-commercial purposes
trade in live animals for re-introduction purposes into protected areas formally proclaimed in terms of the legislation of the importing country
trade in hides and leather goods
trade in raw ivory of whole tusks of any size, and cut pieces of ivory that are both 20 cm or more in length and one kilogram or more in weight of government owned stocks originating from the Kruger National Park. An initial stockpile of 30 tonnes is proposed and a subsequent annual quota of two tonnes accumulated each year through annual mortalities and management practices
all other specimens shall be deemed to be specimens of species included in Appendix l and the trade in them shall be regulated accordingly

The African elephant, the largest of all land mammals, is one of the symbols of the African continent and is regarded as the flagship species for wildlife conservation in Africa. Its aesthetic value arouses public emotion and attracts strong support for conservation activities. Elephants play a significant role in Africa influencing and impacting on biological diversity. They also have an economic value, traditionally as a source of ivory, and more recently, as an attraction for the growing tourism and hunting industries.

The African elephant has experienced rapid declines in some countries as a consequence of land-use conflicts between elephants and man. An increasing demand for ivory, much of which is obtained illegally, has also contributed to the decline. The African elephant population has decreased from ± 1,2 million in 1981 to approximately 770 000 in 1988 to about 620 000 in 1995. One of the causes of the rapid decline has been poaching of the animals (mainly for their ivory) in countries north of South Africa where there have been long periods of civil strife. The table below illustrates the decline in elephant numbers in some of these countries:







12 400

12 400

8 200



4 500

2 400

2 300

3 800


54 800

18 600

14 900

13 300


160 000

41 000

33 000

29 000

It must be noted, further, that the decline in the whole of Africa is not a recent phenomenon as the elephants in East Africa had already lost the majority of their 1925 range by 1975.

In an effort to reverse the decline, the 7th COP to CITES in 1989 passed a resolution to list all populations of the African elephant in Appendix I. The listing in Appendix I prohibited any form of commercial international trade in elephants or their products, including ivory and hides. It was thought that the Appendix I listing would halt illegal ivory trade by cutting off its source, and this in turn would reduce poaching and allow the elephant populations to increase again.

The Southern African countries, with a stable elephant population, argued that their population status did not warrant inclusion in Appendix I. Botswana, Namibia and Zimbabwe argued that their elephant populations were stable and, in some instances, increasing in numbers as illustrated below:






South Africa

8 000

8 200

12 000

13 000


20 000

51 000

106 000



2 300

5 000

10 000



49 000

43 000

70 000


In South Africa the elephant population is located in formally proclaimed protected areas or on private game farms. These areas are fenced and the animals are confined to the specific areas, which allow for efficient protection and effective implementation of anti-poaching programmes. This is a major difference from the situation in other parts of Africa where elephants are free-roaming and come into conflict with human settlement.

The Southern African population of the African elephant has increased from as little as 120 in 1920s to more than 13 000 in 2002 (of which 9 000 are in Kruger National Park). The population is spread throughout the country in more than 20 locations. The South African National Parks (SANP) is custodian to more than 80% of the population, but the numbers in private possession are rapidly increasing.

The listing in Appendix I in 1989 ended the trade in ivory and hides, which generated a considerable amount of revenue, particularly for the SANP. In the period 1985 to 1989 the sale of ivory generated more than R7.2 million at an annual average of approximately R1.5 million. In the same period the sale of hides earned SANP an annual income of more than R2 million. Of all wildlife products sold by the SANP in the period before 1989, elephant hides were the second largest income earner, surpassed only by ivory sales. When the African elephant was listed in Appendix I this source of revenue suddenly ended.

Law enforcement and elephant management in South Africa
CITES requirements are administered and enforced through the old provincial ordinances:
Gauteng, North-West and Northern Province: Transvaal Nature Conservation Ordinance 12 of 1983
KwaZulu-Natal: Natal Nature Conservation Ordinance 15 of 1974
Western-, Eastern- and Northern Cape: Nature and Environmental Conservation Ordinance 19 of 1974
Free State: Free State Ordinance 8 of 1969

A network of agencies and organizations enforce adherence to CITES. On a provincial level all nine nature conservation agencies have law enforcement officers, with six having established Special Investigation Units to gather intelligence and investigate the trade in CITES-listed species. In eight of the nine provinces, the old provincial ordinances provides and enables CITES enforcement. Mpumalanga province has implemented separate legislation, the Mpumalanga Nature Conservation Act 10 of 1998.

In the national parks, the National Parks Act (Act 57 of 1976) provides and enables the South African National Parks to enforce law. Furthermore, the Endangered Species Protection Unit (ESPU) of the South African Police Service (SAPS) is a specialized investigation unit mandated in terms of the South African Police Service Act 68 of 1995 to enforce CITES at national level.

Controls on poaching in South Africa are effective and since1997 there have been only five recorded incidents of elephant poaching in the Kruger National Park. Each incident involved the killing of one elephant, and over the past five years only on elephant has been illegally killed in all the other national parks. The table below indicated the occurrence of poaching incidents in Kruger National Park for the period 1980 – 2002.

According to the ESPU the cases involving illegal dealing in ivory are now rare in South Africa. The table below gives an indication of the number of ivory seizures by the ESPU for the period from 1990 – 1999:


Total no incidents

Total no raw ivory

Total no pieces

Total no ivory cubes

Total worked ivory (kg)

Total ivory (kg)












3 782


1 399.44





1 304


3 480.00





22 379


20 527.92





2 580


2 856.99







24 432.00







1 104.00








































30 595


56 364.05

The incidents above range from the confiscation of a whole tusk to the illegal possession of a piece of jewelry. Given the low incidents of poaching in South Africa, most of the ivory tusks and cubes must originate north of us in countries that have been embroiled in civil wars and where the management of conservation areas has long since collapsed.

Elephants in South African conservation areas die as a result of natural causes or management actions. Through this SANP has accumulated approximately 30 tons of ivory and more than 152 tons of hides over the past 10 years. More than 50 toms of hides were sold following the downlisting of the population at COP11. The ivory under consideration is therefore not "new" ivory and no animals would have been killed to add to the stockpile. Furthermore, no ivory from animals, which were poached or died of unknown causes, are to be traded in.

The elephant management programme by SANP is aimed at conserving the biodiversity of the area. The impact of elephants, and for that matter any animal, on the natural resources can be devastating if the numbers exceed the carrying capacity of the environment. Elephants have a considerable effect on the trees in the Kruger National Park, particularly trees with soft trunks, such as the boabab (Adansoni digitata) and the Common Star Chestnut (Sterculia rogersii). The impact of elephants on trees has further complications. For example, boabab trees are the nesting sites of the endangered Mottled Spiney Tail. Only a few nests have been found in the Kruger National Park, the only known nesting sites in South Africa. It is in this context that it is crucial for the biodiversity of our parks to be able to export elephants to other recognized conservation areas.

The elephants are mostly held in protected areas with limited carrying capacity. The increase in population in these areas has resulted in overpopulation in certain areas. To alleviate this problem a number of management options such as translocation to other less populated areas and culling have been used.

The map below shows the number and destination of the elephants translocated from the Kruger National Park from 1980 to 2002.

Translocation does, however, have its own problems due to the limited range of habitat in South Africa suitable to sustain elephants. The second option, culling, is controversial and is the subject of debate in conservation circles. There has been no culling of elephants since 1994.

Of central concern is that the conservation of biodiversity as a whole cannot be neglected to the advantage of a single species, which might reach numbers that the habitat cannot sustain. While most species adapt to changing conditions (such as drought or limited resources) by changing their reproductive patterns, the elephant changes its source of food while reproducing at the same rate thereby exacerbating any imbalances in nature.

Details of the South African Proposal to the 12th Conference of the Parties to CITES:
Sale of ivory will be restricted to ivory originating from the Kruger National Park stockpile
Trade will be limited to ivory registered in the database of the South African National Parks, which has been accrued over the past 10 years and is ongoing
No animals will be killed to supplement the existing stock
Only ivory that were obtained through legal means (which include management actions, problem animal control and natural mortality) will be eligible for trade
Ivory that has been confiscated or is of unknown origin will not be eligible for trade
Trade in raw ivory will be restricted to trade partners who can ensure strict control over the sale and the domestic handling of the tusks
The following basic conditions will apply to the sale of the raw ivory:
Sale will take place by means of an auction of the approved stock
Transport of the raw ivory will be in sealed containers
Containers will be opened in importing country under the supervision of the Secretariat and the relevant customs officials
Ivory will not be for re-export
Control measures in the importing country must be in place
Commercial international trade in live animals will be restricted to re-locating animals to conservation areas that have been established in terms of legislation in the importing country. This in effect means commercial trade within Africa and then only to protected areas.
Trade in leather goods will be allowed
Foreign hunters will still be allowed to export hunting trophies in terms of the standing relevant CITES provisions and national quota
All other items or specimen of African elephant origin will be treated as being of an animal in Appendix I and will be dealt with in term of the relevant articles of CITES. This implies that:
Commercial export of live animals will not be allowed
No commercial international trade in ivory curios will be allowed

The ivory in the Kruger National Park is under strict control and accurate records are maintained on each tusk and ivory piece accumulated. During a review visit by a Panel of Experts, appointed in terms of the provisions of CITES, it was possible to trace the origin of tusks right back to the specific locality where the animal died. All ivory is also marked in accordance with the provisions of CITES.

Income generated from the proposed sale would have been use by SANP to:
The monitoring and research necessary for the implementation of the new elephant management programme in the Kruger National Park. This programme will help to determine best practice in the management of elephant populations in protected areas and will have wide applications beyond the boundaries of South Africa (for more information see the SANP website:
Increased monitoring and control of the illegal killing of elephants (particularly intelligence networks)
The acquisition of more land to promote the conservation of elephants in other national parks in South Africa, including transfrontier conservation areas.

Rationale of four southern African countries (Botswana, Namibia, Zimbabwe and South Africa) for submitting proposals for trade in elephant products
The elephant populations in all four South African countries are increasing and viable. Habitat availability is also increasing through private ownership and therefore these populations of Loxodonta Africana clearly fit the criteria of an Appendix II listing allowing for regulated trade.
The ivory on the quotas has already been accumulated from natural mortality and management programmes, and as such no elephant shall to be killed for its ivory. Ivory from these two sources is continuously being accumulated, and there are high financial costs involved in storing the ivory in terms of both security and housing. All countries have registered their stock of ivory with the CITES Secretariat and all specimens are marked to make them individually recognizable.
The biggest threat to the elephant populations in Southern Africa remains the loss of habitat through conflict with human activity. Controlled ivory trade will directly benefit the survival of the elephant populations by making elephants valuable to the communities with which they share resources as revenue is to be used exclusively for elephant conservation and community development programmes. The four southern African countries recognize that illegal killing may pose a threat in many other range states. Therefore we encourage such states to make progress in strengthening national legislation; enforcing national hunting regulations and domestic trade prohibitions; controlling domestic ivory markets; registering national ivory stocks; complying with reporting systems established by CITES for illegal hunting of elephants and illegal trade in elephant products. The southern African countries are willing to share their expertise and experience in the successful management of elephant populations.
Ivory and elephant hides are valuable by-products of conservation, but are of no benefit whatsoever to conservation in storage, and lose value over time. It therefore makes sense to add their value to the list of economic and social benefits that can be derived from wildlife within and outside national parks and game reserves. The need to generate benefits from protected areas was clearly recognized at the 1992 World Park Congress. Since then the concepts of integration of protected areas within their economic and social milieu, and the generation of benefits for local communities, has gained impetus virtually throughout the world. The theme of the 2002 World Park Congress, "Benefits Beyond Boundaries", recognizes that this is central to the very survival of many of the world’s protected areas in the 21st century.
The experimental export of raw ivory in 1999 from Botswana, Namibia and Zimbabwe (conducted under rigorous CITES supervision) was successful in all respects and took place under intense international scrutiny. It can categorically be stated that no ivory, other than the registered stocks was exported to Japan.
No linkage between the allegations of poaching and the resumption of highly controlled legal trade can be proven. Our countries do not believe that we should be penalized while ivory is still traded in large quantities in many African countries that do not have sufficient control and management measures. Monitoring conducted in all four southern African countries does not support this allegation. We are confident of our capacity to control poaching and illegal trade in ivory.
The southern African countries acknowledge that illegal killing in some of the elephant range States does constitute a threat to their populations. The international community needs to provide every possible support to elephant range States to deal with illegal killing through the scientific analysis of the causes without harming the countries that have succeeded in getting this problem under control. This will not be achieved by stopping the flow of benefits to conservation from the legitimate international trade in elephant products. This is one the reasons way the proposals make provision for an 18-month period before the sale takes place. This period would be adequate to obtain information on perceived and actual occurrence of illegal activities involving elephants through the MIKE programme.

Extensive lobby actions were taken before and during the COP and although it was clear that the other Parties acknowledged the conservation efforts by South Africa, the perceived increase in poaching was the greatest concern. The ineffective monitoring of African Elephant populations and the uncertainty whether the sale of Botswana, Namibia and Zimbabwe’s ivory stocks after COP 10 led to increased poaching, resulted in most Parties voting for the precautionary principle.

South Africa played a very important role in the decision made at COP 11 regarding the African Elephant proposals submitted not only by South Africa, but also the other southern African countries. Although South Africa does have sufficient control and management measures in place to combat poaching, other African countries must be supported to enable them to deal with the illegal killing of their elephant populations. South Africa made it clear at the COP that it will not jeopardize the African Elephant by demanding the right to sell our ivory, but rather assist the rest of Africa to find a solution for this problem threatening the survival of the African Elephant in it’s natural distribution range.

South Africa consequently amended its proposal to a zero quota for ivory, but emphasized that there was no apparent threat to current South African elephant populations. Furthermore, South Africa stressed the need for appropriate monitoring systems for all elephant range States. South Africa committed to initiate the implementation of the monitoring system, Monitoring of Illegal Killing of Elephants (MIKE), and to co-operate with other African countries to ensure effective monitoring to enable the next conference of the Parties to make its decision based on sound scientific evidence.

MIKE and the implementation thereof in South Africa
At the 10th COP (9 – 20 June 1997, Harare, Zimbabwe) Resolution Conf 10.10 on Trade in Elephant Specimens was adopted. Among other things, it calls for the establishment, under the supervision and direction of the Standing Committee, of a comprehensive international system to monitor the illegal killing of elephants.

The objectives of this monitoring system are:
Measuring and recording current levels and trends of illegal hunting in African and Asian range States;
Assessing whether and to what extent observed trends are a result of changes in the listing of elephant populations in the CITES Appendices and / or the resumption of legal international trade in ivory; and
Establishing an information base to support the making of decisions on appropriate remedial action in the event of any problems with compliance or potential detriment to the species

The Resolution is unique in that it provides a long-term mechanism whereby elephant range States, with the assistance of the CITES Secretariat, can develop the skills and technology required to effectively manage their elephant populations.

Elephants are a wide-ranging keystone species in the habitats in which they occur. For the first time, at an international level and on a consistent scientific basis, MIKE will assess, in the selected sites, the levels and trends of elephant populations and illegal killing. This will assist not only elephant conservation but the benefits of improved resource management will flow to other species, sharing habitat with them. It will significantly increase the capacity of conservation staff in governments and NGOs to monitor this and other threatened species and this expertise will be directly transmissible to other sites and other countries.

MIKE has been developed in recognition of the fact that the resources and capacity to monitor and manage elephant populations and to enforce CITES decisions are generally not available in the range States in Africa and Asia. MIKE’s aim is to strengthen the capacity of these range States to manage their elephants in order to increase the benefits for local people and to enhance the related biodiversity advantages that will flow from any improved management of such a keystone species.

The main target groups for the output from MIKE are national wildlife management authorities and international decision-makers in CITES. These agencies need to assess the likely effect of decisions to trade or suspend trade in elephant products and they need to be able to adapt their management strategies in the light of MIKE reports about trends in elephant numbers, mortality and enforcement effort.

Although South Africa has good data on changes in our elephant populations and on levels of illegal killing, in most range States the coverage and quality of data vary immensely. This disparity prevents any well-founded assessment of changes in population status at the continent level, much less their possible or probable causes. In order to achieve the objectives of MIKE there will be a need for major improvements in the capacity to organize surveys on a rigorous scientific basis and to implement surveys efficiently. For both Asia and Africa, MIKE will help increase the range State’s understanding of each others opportunities and problems, previous ignorance of which has contributed to a lack of unity when international debates on elephants take place.

In November 1999 the Secretariat conducted a workshop in Namibia to initiate MIKE in southern Africa. Four range States (Botswana, Namibia, South Africa and Zimbabwe) committed to implementing MIKE immediately in their countries (self-funded) and Namibia was selected as the sub-regional coordinator for MIKE implementation in southern Africa.

In September 2000, a southern African MIKE training workshop was held in Mopane Camp in the Kruger National Park to review the implementation of MIKE in the southern African sub-region and to ensure full implementation in the region by involving Mozambique and Zambia.

The workshop programme covered the background on MIKE and the specific requirements for full implementation. Each form required by the MIKE system was presented and the need to customize the forms to be better suited to the southern African situation was identified. The forms were customized to reflect the local conditions.

The national and site coordinators for all six countries were identified and a steering committee comprising the six national coordinators was established to coordinate the implementation of MIKE in the sub-region. All countries committed themselves to continue the implementation of MIKE at the selected sites and each country identified new sites to be considered for MIKE implementation.

MIKE was officially implemented in South Africa as from 1 April 2001 and the annual report for the period has been submitted.