February 13, 2020

Mr. Alexandre de Juniac Director General and CEO

Mrs. Andrea Gruber Head, Special Cargo

800 Place Victoria PO Box 113 Montreal – H4Z 1M1 Quebec – Canada

33, Route de l’Aeroport PO Box 416
1215 Geneva – 15 Airport Switzerland

CITES Decision Regarding Transport of African elephants from Zimbabwe and Botswana

Dear Mr. de Juniac and Mrs. Gruber:

We write to inform you of a decision adopted by the parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) restricting the transport of live, wild caught elephants from Zimbabwe and Botswana soley to countries within the species natural and historical range in Africa, with limited exceptions. We respectfully request that the International Air Transport Association (IATA):

(1) update the 46 edition of its Live Animal Regulations accordingly with an addendum, and revise any other relevant rules, guidance and standards; and

(2) inform its members and strategic partners, including exporters, importers, transport companies and carriers, of this decision as appropriate.

CITES regulates international trade in endangered and threatened animals and plants through the listing of species on one of three Appendices. African elephants in Zimbabwe, Namibia, South Africa, and Botswana are listed on CITES Appendix II, which limits trade to avoid uses that are incompatible with species’ survival. The listing of elephants in Zimbabwe and Botswana includes an annotation(1) allowing live elephants to be exported to “appropriate and acceptable

1 Annotations define which commodities are covered by the listing or are excluded from it.

destinations.” Pursuant to this annotation, Zimbabwe has captured live baby elephants from the wild and exported to zoos and entertainment facilities in China and elsewhere (2)

At the 18th meeting of the CITES Conference of the Parties held in August 2019, the parties to the Convention voted to modify the definition of “appropriate and acceptable destinations” contained in Resolution Confidential.11.20 (Rev. CoP17) to encompass only in-situ conservation programs or secure areas in the wild. The revised definition thereby restricts shipments of wild-caught elephants from Zimbabwe and Botswana to foreign countries outside the species’ natural and historical range, with certain exceptions. This revised definition became effective on November 26, 2019 (3). Specifically, the decision states:

[W]here the term “appropriate and acceptable destinations” appears in an annotation to the listing of Loxodonta africana in Appendix II of the Convention with reference to the trade in live elephants (* Excluding elephants that were in ex- situ locations at the time of the adoption of this resolution at CoP18) taken from the wild, this term shall be defined to mean in-situ conservation programmes or secure areas in the wild, within the species’ natural and historical range in Africa,except in exceptional circumstances where, in consultation with the Animals Committee, through its Chair with the support of the Secretariat, and in consultation with the IUCN elephant specialist group, it is considered that a transfer to ex-situ locations will provide demonstrable in-situ conservation benefits for African elephants, or in the case of temporary transfer in emergency situations[.]

See Attachment 1 (emphasis in original).

This amendment reflects a growing international consensus that the forcible capture and removal of wild elephants from their home ranges and social groups for export to zoos and entertainment facilities is unethical, and provides no direct in situ conservation benefits.(4) Elephants suffer both physically and psychologically from capture and captivity. Elephants are extremely intelligent, sentient animals, with a highly organized social structure. Young elephants are dependent on their mothers and their herds to acquire necessary social and behavioral skills. Disruption of this bond is highly traumatic for both the calves and remaining herds.

(2) See, e.g., Jane Flanagan, Baby Elephants Torn From Mothers and Shipped 7,000 Miles to China, The Times, Feb. 9, 2019. Available at: elephants-drugged-and-sent-to-china-dgd37svw3; Humane Society International, Video: Elephant Experts Condemn Zimbabwe’s Inhumane Capture of Wild Baby Elephants for Chinese Zoos as Video Emerges Showing Animals in Distress, Feb. 25, 2019. Available at: elephants-terrified-in-pens/

(3) Res. Conf. 11.20 (Rev. CoP18).
(4) IUCN SSC AfESG: Statement on the removal of African elephants for captive use. Mokuti Lodge, Namibia, 2003. Available at: elephant-specialist-group/afesg-statements/removal-african-elephants-captive-use.

Updating the IATA Live Animal Regulations, as well as any other relevant rules, guidance, and standards, will comport with Memorandum of Understanding (MOU) entered into between the CITES Secretariat and IATA, dated June 2015. The purpose of the MOU include: facilitating and strengthening cooperation and collaboration in order to better implement the Convention; improving transport conditions for CITES specimens; ensuring that trade is legal, sustainable, and traceable, and combatting illegal trade in CITES specimens.(5) Pursuant to the MOU, IATA agreed to maintain and update standards, guidelines and recommendations in line with current or future requirements. (6) IATA also agreed to bring the IATA Live Animal Regulations, together with other guidance and standards.(6) IATA also agreed to bring the IATA Live Animal Regulations, together with other guidance and standards for CITES specimens, to the attention of exporters, importers, transport companies, carriers, and other entities that regulate conditions of carriage.(7)

Outreach efforts are particularly important because, despite the decision by the majority of CITES parties to limit this trade, Zimbabwe has flouted the vote of the international community by continuing to ship wild-caught African elephants outside the species’ range after the decision went into effect. In January 2020, Zimbabwe shipped two young, wild-caught African elephants to Pakistan.(8) This action came after Zimbabwe informed the CITES Secretariat that the country“reserves its right” not to comply with Resolution Conf. 11.20 (Rev. CoP18), despite the fact that CITES does not allow parties to take reservations to resolutions, and after Botswana, the Democratic Republic of Congo, Eswatini, Namibia, the United Republic of Tanzania, and South Africa all declared that they were not in a position to implement Resolution Conf. 11.20 (Rev. CoP18).(9) Notably, all these countries are parties to CITES. This willingness to defy the decision of the parties to this Convention should not be facilitated by IATA members and strategic partners.

We therefore respectfully request that IATA update its Live Animal Regulations to reflect the revised definition of “appropriate and acceptable destinations” for wild-caught elephants from Zimbabwe and Botswana, and that IATA reach out to exporters, importers, transport companies, and carriers to inform them of this change to the Live Animal Regulations, as appropriate. We recommend that any such outreach efforts focus on:

(1) Chinese and Pakistani government officials responsible for regulation of live animal transportation and issuance of CITES import permits, due to China’s and Pakistan’s role as the primary recent destinations for wild-caught elephants from Zimbabwe; and

(2) transport companies that have participated in past trade, such

as SAUDIA Airlines, via its subsidiary, SAUDIA Cargo, which shipped wild-caught elephants from Zimbabwe to China in October 2019. (10)

(5) MOU at 1.1-1.2. Available at:
(6) Id. at 2.2.
(7) Id. 2.14.
(8) Oscar Nkala, Zimbabwe Baby Elephants Smuggled to Pakistani Zoo, Jan. 6, 2020. Available at:
(9) Notification No. 2019/077, Reservations with Reference to the Amendments to Appendices I and II of the Convention and Related Communications (Dec. 20, 2019).

(10) Roland Oliphant, Young elephants flown out of Zimbabwe after being ‘secretly’ removed from national park, The Telegraph, Oct. 24, 2019. Available at: removed-national-park/Zim Baby Elephants: from the comfort of the jungle to ‘steel prisons’ in China, The Standard, Nov. 10, 2019. Available at: china/

Thank you for your attention to this matter. If you have any questions or if there is any additional information we can provide, please do not hesitate to contact me.


Johanna Hamburger
Wildlife Attorney
Animal Welfare Institute
900 Pennsylvania Ave, SE Washington, DC 20003
Phone: 202-446-2136

On Behalf of the Following 52 Individuals and Organizations:

Cathy Liss
Animal Welfare Institute

Daniela Freyer Co-Founder Pro Wildlife

Teresa M. Telecky, Ph.D. Vice President Wildlife Humane Society International

Karen Botha
David Shepherd Wildlife Foundation

Heike Henderson Member of the Board Future for Elephants

Adam Grogan
Head of Wildlife
Royal Society for the Prevention of Cruelty to Animals

Dr. Lucy Bates
Director and Independent Researcher
Elephant Specialist Advisory Group of South Africa (ESAG)

Allan Thornton
Environmental Investigation Agency, U.S.

Vera Weber
Franz Weber Foundation

Will Travers
Species Survival Network

Charlotte Nithart Director
Robin des Bois

Elly Pepper
Deputy Director, International Wildlife Conservation Initiative Natural Resources Defense Council

Dr. Jan Schmidt-Burbach
Head of Wildlife Research and Animal Welfare World Animal Protection International

Belinda Stewart-Cox Head of Conservation Elephant Family

Mark Jones, veterinarian Head of Policy
Born Free Foundation

Mary Rice
Executive Director
Environmental Investigation Agency, UK

Carol Buckley
Elephant Aid International

Suparna Baksi-Ganguly
President and Co-Founder
Wildlife Rescue & Rehabilitation Center, Bangalore, India

Dr. Brett Bard Veterinarian South Africa

Dr. Jessica Bell Rizzolo
Postdoctoral Researcher
Conservation Criminology Lab
Department of Fisheries and Wildlife, Michigan State University

Dr. Gay Bradshaw
Michele Franko
Senior Research Associate – Elephant Care & Wellbeing Kerulos Center for Nonviolence – USA

Megan Carr
Global March for Elephants and Rhinos

Lenin Chisaira
Linda Masudze
Advocates 4 Earth – Green Law Connect, Zimbabwe

Dr. Betsy Coville
Wildlife Veterinarian – USA

Ed Stewart
Catherine Doyle
Director of Science Research and Advocacy Performing Animal Welfare Society USA

Nomusa Dube
Zimbabwe Elephant Foundation

Stefania Falcon
Future 4 Wildlife, South Africa
Chief Stephen Fritz
Traditional Leader
Members of the South Peninsula Customary Khoisan Council, South Africa

Brett Mitchell Director Elephant Reintegration Trust South Africa

Dr. Marion Garai Trustee Elephant Reintegration Trust South Africa

Georgina Groves
Independent Elephant Behavior Specialist

Rachel Harris
Managing Director
Elephant Human Relationship Aid Namibia

Dr. Ross Harvey
Wildlife Economist Botswana

Dr. Michelle Henley
ElephantsAlive!  Elephant Specialist Advisory Group South Africa

Alok Hissarwala Gupta
Elephant Specialist
Federation of Indian Animal Protection Organizations

Lynne James
Committee Member Mutare SPCA Zimbabwe

Dr. Paula Kahumbu Chief Operating Officer Wildlife Direct

Mary Morrison Advocate WildlifeDirect, Kenya

Professor Mohan Kharel
Tribhuvan University Kathmandu, Nepal

Jim Karani
Lawyers for Animal Protection in Africa

Dr. Winnie Kiiru Founder Conservation Kenya

Rob Laidlaw Executive Director Zoocheck Canada

Kahindi Lekalhaile
Africa Network for Animal Welfare Kenya

Dr. Smaragda Law
Ban Animal Trading South Africa

Dr. Keith Lindsay Conservation Biologist Kenya

Giorgio Lombardi
Warden Vogelgat Private Nature Reserve M.S. Rhodes University South Africa

Varda Mehrotra
Executive Director
Federation of Indian Animal Protection Organizations

Dr. Cynthia Moss
Amboseli Trust for Elephants Kenya

Michele Pickover
EMS Foundation South Africa

Sharon Pincott
Elephant Behavioural Specialist ex-Hwange Zimbabwe

Dr. Yolanda Pretorius
SA Wildlife College Elephant Specialist Advisory Group Elephant Reintegration Trust South Africa

Peter Stroud
Independent Zoological Consultant   Former Zoo Director Australia

Professor Dan Wylie
Rhodes University South Africa

Antoinette Van de Water
Bring the Elephant Home Elephant Specialist Advisory Group South Africa

CC: Muhammad Ali Albakri Regional Vice President, Africa and the Middle East

Ma Tao Regional Vice President, North Asia

Conrad Clifford Regional Vice President, Asia-Pacific

Tony Concil Vice President Corporate Communications

Jeffrey N. Shane General Counsel

Image: with grateful appreciation to sources on the ground in Zimbabwe, the containers used for the 33 elephants 2019

© Copyright Pro Elephant Network 2020. All rights reserved.