Ivory Bill

Written evidence submitted by Animal Defenders International (IVB06)

Executive summary

· Elephant populations have been suffering from decline in recent decades.

· Allowing profit to be made from ivory places a value on the product, contributing to demand, the illegal market and poaching.

· The exemption categories leave an opening for illegal markets to operate. Documentation providing proof that the item falls within an exempted category can be faked and items tampered with.

· As the largest supplier to the world’s ivory markets, it is the responsibility of the UK to lead the international community in helping to restore the world’s elephant populations through the adoption of a full ban without exemptions.

Evidence

1. Animal Defenders International (ADI) works to end the suffering of animals in captivity and protect wild animals and their environments. We believe that a full ban on the trade in ivory without exemptions is required to have a significant impact on the illegal trade and elephant poaching.

2. Since the mid-2000s there has been a sharp upward trend in elephant poaching, peaking in 2011, alongside a decline in savannah elephant populations between 2007-2014. ‘The Great Elephant Census’ found that elephant numbers are currently declining at a rate of 8 per cent per year, mainly because of poaching [1] . The rise in demand for ivory since 2009 is mirrored by a rise in poaching in Africa. In the early 2010s, around 30,000 elephants were killed per year [2] with the illegal ivory trade more than doubling since 2007 [3] , despite a CITES international ban from 1989 on the trade in unworked ivory. The most recent figures reveal high, unsustainable levels of elephant poaching and global ivory trafficking, with a record quantity of ivory that may have been illegally traded [4] .

3. The legal trade in ivory fuels consumer demand, and provides a cover for an illegal market to operate [5] . The international trade in illegal ivory has tripled since 1998 [6] . It is thought that only a fraction is seized and documented, with tens of thousands of elephants estimated to be killed each year [7] .

4. Any trade in ivory contributes to maintaining demand, with the legal trade making ivory socially acceptable and even a desirable product to own [8] . A full ivory trade ban would contribute to reducing demand; for example, since the Chinese government’s decision to ban ivory there has been a notable fall in the price of ivory in Asia [9] .

5. Interpol estimated that in 2013 a significant portion of ivory reaching international markets was derived from elephants killed since the late 2000s, and that the increase in large scale shipments indicated the role of organised crime networks, where traffickers operated in multiple countries simultaneously [10] , [11] . The internet has been identified as having a significant role in such illegal trade, however the legislative framework at CITES and EU level is not capable of addressing it [12] .

6. There are also issues in distinguishing legal from illegal items as smugglers employ methods to disguise recently poached ivory as antique or pre-convention ivory, such as staining specimens with tea in order to make them look aged [13] , faking documentation relating to a specimen’s age [14] , and even selling illegal ivory as "synthetic" [15] . As a result, strict regulation of ivory sales is not practically enforceable and will not stop the trade in ivory from recently killed elephants, which only a full ban without exemptions can achieve.

7. A recent analysis reveals that the UK is the largest supplier to the world’s legal ivory market, with more than 36,000 legal ivory items exported from the UK between 2010 and 2015 [16] , and one of the largest importers to China and Hong Kong [17] Alongside the legal market, seizure data show that the UK plays an increasing role in illegal ivory trade, in terms of import, export and as a transit country [18] . Between 2010 and 2014 the UK saw a considerable increase in the number of seizures of ivory, although it is unclear whether this is due to better enforcement efforts or increased criminal activity [19] .

8. The antiques trade has been identified as a major route for the illegal trade of ivory [20] , and worryingly the demand for antique ivory is increasing [21] . It has even been suggested that there is "widespread flouting of the law by many auction houses" with regards to ivory [22] . Major UK antiques dealers, including Christie’s, have been found selling apparent antique ivory illegally, such as ivory that had been wrongly dated. Online auctions are particularly prolific with up to 1000 ivory pieces estimated to be sold weekly just in the UK [23] , with potentially countless illegal sales going undetected; these include sales on Facebook [24] and eBay [25] .

9. Antiques dealers, including those in the UK, have acknowledged that any continued sales in ivory can fuel demand and consequently poaching, and for this reason are against selling ivory [26] . It is vital that, if exemptions are put in place, these types of sales are policed to minimise the opportunity for illegal trade.

10. It is vital that ivory is "de-commercialised" [27] . Any legal trade in ivory contributes to maintaining demand for the product and makes ivory socially acceptable and a desirable product to own [28] . A recent article notes that "The problem is that any legal trade in ivory, even if the ivory wasn’t recently obtained from illegally killed elephants, sends mixed messages to consumers, stimulating demand and undermining law enforcement efforts to address ivory trafficking. It also provides a mechanism by which illegal ivory from recently killed elephants can be laundered into trade. Studies have repeatedly exposed outlets in many countries offering legal and illegal ivory products side-by-side" [29] .

11. Restricting the ivory trade around the same time as other international governments (e.g., China [30] , Hong Kong [31] , EU [32] ) will likely have a substantial positive impact upon reducing the demand for ivory, reducing trade and, consequently, reducing poaching.

12. In light of the evidence, ADI calls on parliament to pass a full ban on the trade in ivory to protect elephant populations in the wild and tackle the illegal trade.

Yours sincerely

Christina Dodkin

Research Director

June 2018


[1] The Great Elephant Census Final Results http://www.greatelephantcensus.com/final-report

[2] TRAFFIC. ( n.d. ).Elephant conservation and the global trade in ivory. http://www.traffic.org/elephants-ivory/

[3] European Commission. (2016). Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions. http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52016DC0087&from=EN

[4] TRAFFIC. (2017). New analyses reveal elephant poaching and global ivory trafficking continue at high unsustainable levels in 2016. http://www.traffic.org/home/2017/10/25/new-analyses-reveal-elephant-poaching-and-global-ivory-traff.html

[5] Environmental Investigation Agency. (2017). Illegal trade seizures: Elephant ivory in Europe. Mapping the crimes. https://eia-international.org/illegal-trade-seizures-elephant-ivory-europe

[6] Mundy (2014) The Re-export of pre-Convention/antique ivory from the European Union. Report prepared for the European Commission. http://ec.europa.eu/environment/cites/pdf/Ivory%20report_Nov%202014.pdf

[7] United Nation Office on Drugs and Crime. (2016). World Wildlife Crime Report: Trafficking in Protected Species. https://www.unodc.org/documents/data-and-analysis/wildlife/World_Wildlife_Crime_Report_2016_final.pdf

[8] Ban UK Ivory Sales (2017) Why action is needed. http://banukivorysales.co.uk/why-action-is-needed/

[9] IFAW ( nd ) EU ivory trade kills elephants. http://www.ifaw.org/sites/default/files/eu-ivory-kills-elephants_0.pdf

[10] Ban UK Ivory Sales (2017) Why action is needed. http://banukivorysales.co.uk/why-action-is-needed/

[11] European Parliament (2016) EU trade policy and the wildlife trade. http://www.europarl.europa.eu/RegData/etudes/STUD/2016/578025/EXPO_STU(2016)578025_EN.pdf

[12] European Parliament (2016) EU trade policy and the wildlife trade. http://www.europarl.europa.eu/RegData/etudes/STUD/2016/578025/EXPO_STU(2016)578025_EN.pdf

[13] Independent. (2017).Ivory stained with tea to make it look older and bypass the law sold in UK, WWF says. http://www.independent.co.uk/news/uk/home-news/ivory-tea-stained-1947-law-uk-parliament-debatea7564171.html

[14] IFAW. (2017). Ivory seizures in Europe: 2006-2015. http://www.ifaw.org/sites/default/files/ifaw_ivory_seizures_europe_proof_4.pdf

[15] Collins, A., Cox, C. and Pamment , N. (2017). Culture conservation and crime: regulating markets for antiques and crafts. Ecological Economics, 135, 186-194 http://www.sciencedirect.com/science/article/pii/S0921800916308515

[16] EIA. (2017). UK is the largest supplier to the world’s ivory markets. https://eia-international.org/uk-largest-supplier-worlds-ivory-markets

[17] Environmental Investigation Agency. (2017). UK is the largest supplier to the world’s ivory markets. https://eia-international.org/uk-largest-supplier-worlds-ivory-markets

[18] TRAFFIC. (2016). A rapid survey of the UK ivory market. http://static1.1.sqspcdn.com/static/f/157301/27217988/1472570776477/UK-ivory-markets.pdf?token=Fg3bnYkIchjLE0%2BBdQKLzTMZxBI%3D

[19] IFAW. (2017). Ivory seizures in Europe: 2006-2015. http://www.ifaw.org/sites/default/files/ifaw_ivory_seizures_europe_proof_4.pdf

[20] IFAW. (2017). EU ivory kills elephants. http://www.ifaw.org/sites/default/files/eu-ivory-kills-elephants_0.pdf

[21] Collins, A., Cox, C. and Pamment , N. (2017). Culture conservation and crime: regulating markets for antiques and crafts. Ecological Economics, 135, 186-194. http://www.sciencedirect.com/science/article/pii/S0921800916308515

[22] Two Million Tusks. (2017). Ivory: The Grey Areas. A study of UK auction house ivory sales - the missing evidence. http://nebula.wsimg.com/6f0b004320ee4728dbddfe1b283dd4ec?AccessKeyId=2128905E8DEC809DE8B5&disposition=0&alloworigin=1

[23] Pro Wildlife, et al. (2017). EU ivory trade: the need for stricter measures. Paper submitted to the European Commission, January 2017. https://www.prowildlife.de/wp-content/uploads/2017/08/EU_IvoryTradeBrief.pdf

[24] The Guardian. (2016). Wildlife smugglers using Facebook to sell ivory and rhino horn. https://www.theguardian.com/environment/2016/nov/14/wildlife-smugglers-using-facebook-sell-ivory-rhino-horn?CMP=Share_iOSApp_Other

[25] Mongabay . (2017). eBay is outselling the darknet in the illegal wildlife trade, fret researchers https://news.mongabay.com/2017/11/ebay-is-outselling-the-darknet-in-the-illegal-wildlife-trade-fret-researchers/

[26] Robin Des Bois. (2017).On the Trail. Issue 15, page 105. http://www.robindesbois.org/wp-content/uploads/ON_THE_TRAIL_15.pdf

[26]

[27] Yu, Y., Wetzler , A., Yang, X., Tang, R., & Zhang, L. (2017). Significant and timely ivory trade restrictions in both China and the United States are critical to save elephants. Conservation Letters, 10(5), 596-601. http://onlinelibrary.wiley.com/doi/10.1111/conl.12279/pdf

[28] IFAW. ( n.d. ). Ivory seizures in Europe: 2006-2015. http://www.ifaw.org/sites/default/files/ifaw_ivory_seizures_europe_proof_4.pdf

[29] Hepworth, R. & Jones, M. (2017). What has the EU got to do with elephant protection? New Europe. https://www.neweurope.eu/article/eu-got-elephant-protection/

[30] Environmental Investigation Agency. (2017). Illegal trade seizures: Elephant ivory in Europe. Mapping the crimes. https://eia-international.org/illegal-trade-seizures-elephant-ivory-europe

[31] The Guardian. (2018). Hong Kong votes to ban domestic ivory sales . https://www.theguardian.com/environment/2018/jan/31/hong-kong-votes-to-ban-domestic-ivory-sales

[32] MEPs for Wildlife. (2018). MEPs Call for a Total Ban on Ivory Trade and Import in the EU . http://meps4wildlife.eu/meps-call-total-ban-ivory-trade-import-eu/

 

Prepared 11th June 2018