"This appears to be a consultation born not of ecological necessity and evidence but a perceived need for Government to be seen to respond to an ill-informed populist agenda about trophy hunting", says NGO as it files its response to Defra's consultation on controls on the import and export of hunting trophies. Read the NGO's full reponse here


This is the formal response of the National Gamekeepers’ Organisation (NGO) to Defra’s public Consultation on Controls on the Import and Export of Hunting Trophies(Closing date 25/1/20). It is submitted as a written commentary rather than via the online survey form, which we found too restrictive to express the strong views of our members on this issue.

Opening Remarks

To the NGO, this appears to be a consultation born not of ecological necessity and evidence but a perceived need for Government to be seen to respond to an ill-informed populist agenda about ‘trophy hunting.’ Largely driven by media misreporting of a few high-profile incidents, some involving minor celebrities and most of which could and should have been dealt with under exiting national and international regulations, this has fueled a campaign by animal rights extremists.

The proposals will have no effect on what these campaigners have been objecting to, nor will they address, “Biodiversity declining at a dangerous and unprecedented speed, with species extinction rates accelerating and up to 1 million species threatened,” to quote the introduction to Defra’s consultation on Gov.UK.

In fact, as Defra goes on to make clear on its website, “There are a number of controls already in place on the import and export of hunting trophies. The UK Government will not issue an import permit for a trophy unless the importer can show there has been no detrimental impact on the endangered species and the trophy has been obtained from a sustainable hunting operation.

“All applications for import permits for trophies are individually scrutinised by the Joint Nature Conservation Committee (JNCC), as the UK’s CITES Scientific Authority, to determine there has been no detrimental impact on endangered species and the trophy has been obtained from a ‘sustainable’ hunting operation.”

Provided all these existing rules are followed and enforced, nothing needs to be changed. There is little or no evidence of a genuine problem and indeed no factual case for action is made in the consultation papers. There is certainly no evidential link to ‘biodiversity loss and extinctions’. All we have in the consultation document by way of a supposed justification for change are vague references to meeting ‘public concern’.

But ‘public concern’ cuts both ways. To judge from the reaction of members of the National Gamekeepers’ Organisation (NGO), this unnecessary consultation is being seen, rightly or wrongly, by quite a few people as (to quote one of them), “Another calculated attack on shooting sports.” Indeed, the existence and tone of the consultation are already making the Government unpopular, in rural circles, especially with deer managers in the UK (see below).

The Proposals would Solve Nothing but would Cause Significant Harm

If the proposed options for change are taken, UK wildlife management, the rural economy and conservation will all take a big hit, as figures later in this response demonstrate.

Governments that want to be popular sometimes over-react to publicity about far away things like the killing of ‘Cecil the Lion.’ Strong leaders resist such temptations and judge controversial issues on evidence rather than emotion and the populist agenda.

The fact is that options 1 to 3, proposed in the consultation paper, could all have a devastating impact on wildlife management here in the UK. There is no accompanying Impact Assessment, which would have revealed these harmful effects, let alone anything that shows how options 1 to 3 would contribute to slowing biodiversity decline and stopping extinctions.

It is much more likely that the proposals being made would be counterproductive, restricting ‘hunter tourism’ which is valuable not only to the UK economy and countryside but is also important overseas in giving managed wildlife a value, thereby encouraging its conservation.

The Importance of Being Able to Export Trophies From the UK

Many international hunters travel to the UK to enjoy this country’s unrivalled game shooting and fishing. They pay significant sums to do so, creating employment for gamekeepers, stimulating the rural economy and allowing landowners to pay for habitat management and conservation work.

These visiting sportsmen often like to take home a particularly fine specimen as a memento of their visit. It’s a long tradition, particularly valued by overseas sportsmen. ‘Trophies’ taken home, or more usually subsequently exported to the hunters after mounting and preservation) include unusual gamebirds, fine game fish and - by far the most important numerically and in terms of knock-on benefits - the antlers of the six deer species present in the UK.

The views of the NGO on this matter are thus very important because a 2012 survey showed that members of our organization (covering England and Wales) and the Scottish Gamekeepers’ Association combined, are responsible for 75% of all deer culling in the UK - either by virtue of the gamekeepers doing the culling themselves or through arranging and supervising paying stalkers.


Join the National Gamekeepers Organisation and Support Gamekeeping

Trade & Corporate


Gamekeeper Member


Supporter Member




Joining the NGO is easy and can be done now online.
Or if you prefer, call 01833 660 869


Join our newsletter mailing list: