Ivory Bill

Written evidence submitted by Neil Davey (IVB15)

Dear Sirs

I write with regard to the proposed ban on the sale of ivory including antique works of art that is being discussed in Parliament.

While I, along with all antique dealers, specialist auctioneers and collectors, find the slaying of elephants merely for their tusks is abhorrent and should be stopped, I am firmly of the opinion that the banning of all sales of ivory including antiques is not the answer to this problem. The ban, as suggested, will do nothing to save the elephant population of Africa. However, I do agree with supporters of the ban that online sales of ivory should definitely be banned, as they are the most difficult to regulate.

Having worked with auctioneers, antique dealers, collectors and museum curators all my working life, I can honestly say that there are no collectors of antique ivory. Rather, there are collectors of Japanese netsuke (toggles, part of the male dress accessories) and okimono (free standing sculptures), Western sculpture, fans, Art Deco and tribal art, etc., many of which are coincidentally carved from ivory. The value of these works of art is several times greater than the cost of the raw material which has been used by modern machine-assisted sculptors in the last few years, mainly in China. If the ban is brought in, the market for legitimate antique ivory works of art will immediately go abroad, thus losing the country a large amount of taxable revenue.

It is suggested that, should the ban be enforced, any antique dealer, auctioneer or collector who wishes to sell an ivory item would be required to submit it to the Animal and Plant Health Agency who would in turn, if the object is passed, forward it to a museum or other institution for verification. This is not only unwieldy but is completely unworkable. There are simply not enough suitably qualified individuals in the museums to cope with the myriad requests for their expertise that they will undoubtedly receive.

As an alternative, I would suggest that all antique dealers and auctioneers be licensed to sell ivory works of art, in the same way that licenses are issued for dealers in firearms. The license should be applied for and perhaps renewed every 10 years, with a fee payable (I would venture to suggest £10,000). Unannounced spot checks should be made to license holders who, if found in breach of the law, would have their license revoked. With the banning of online sales, and revenue from licensing going towards the policing of vulnerable areas, almost no post-1947 works would reach the market in the UK

In addition I would further suggest a tax or levy of, say, 5% on every ivory work of art that is sold. That, together with the license fee, should be sent straight to wherever it is needed to police the game parks in Africa. I note that the current budget for the Wildlife Crime Unit of this country is annually £250,000. The fees and levy that I am putting forward would produce several times that figure which could be directed to where it is most required. It has been shown recently that this course of action works well and I understand for instance that, due to intensive policing in Chad, not one elephant has been slaughtered for its tusks in the last eighteen months.

While I can see there is a need for greater regulation in the sale of antique ivory works of art, I regret to say that the proposal that has been put forward is not the right way to go about it and I hope that it is not too late to amend it.

Yours faithfully

Neil Davey

Japanese art consultant

June 2018


Prepared 19th June 2018