Ivory Bill

Written evidence submitted by Alastair Gibson (IVB21)

Dear Sirs

I understand that the Ivory Bill has already had its second reading and has now passed to the Public Bill Committee stage and is now able to receive written evidence.

Therefore I would like to submit my views on this matter:

My name is Alastair Gibson, MRICS. I am a Chinese Ceramics and Works of Art specialist and after a career at Sothebys for sixteen years (Head of the Chinese and Japanese Departments, London), I set up my own business, Gibson Antiques Ltd, dealing in Chinese and Japanese Ceramics and works of Art. Within this context I sell museum-quality Chinese ivory works of art which were carved in Canton (modern day Guangzhou) for the European markets during the 18th and 19th Centuries. I am also a ‘Fine Arts Surveyor’ a Member of The Royal Institute of Surveyors. I also sit on the Council of the British Antique Dealers Association and have been a Director of Asian Art in London.

Currently within my stock I have approximately sixteen objects of this type with a combined retail value of £198,000.

I have already exported the majority of these objects to Hong Kong and have applied and received the necessary Cities Licences for me to be able to do so legally.

Last week whilst the second reading took place I was on a three day symposium in Dresden studying the collections of Augustus the Strong, (1670-1733) The Elector of Saxony and the subsequent Kings of Poland amassed an amazing collection of paintings, porcelain, works of art, silver, which includes a significant amount of endangered species material from the 16th century onwards. These objects have been turned, carved, embellished and mounted in gold, enamel and silver and are true treasures of a Golden Age, where the exotic was indeed marvelled at and the value of these materials were true luxuries.

Ivory has been held in high esteem as the carvers choice since time began. Flourishing at the height of its popularity in the 18th century, 19th and early 20th century where it has been used to produce secular and important religious works of art.

With the implementation of the Ivory bill you are likely to be accused in the future of cultural vandalism….proposing an outright ban on genuine Antiques, musical instruments it is madness! It will have no impact on what happens on the ground in Africa where the problem of illegal poaching needs to be addressed by the international community which we all agree upon.

By banning/inteferring with the legal antique trade within the UK I believe it will have no sway on what happens to a peasant farmer with a snare or a rifle in his hand, the problem needs to be solved there, not in the legitimate antiques businesses here or in Europe.


The antiques trade is not an easy business to be in, and whilst I support the sentiment of the Ivory Bill, the stance of the NGO’S such as Action for Elephants does not help a trade also in endanger of extinction within the UK. We should value the dealers, auction houses and specialists based here in the Uk. Their combined knowledge and history is remarkable. The majority of whom do care in getting right, in terms of dating, attribution and selling genuine museum-quality works of art.

It has been suggested by the lobbying bodies of the Antiques Trade that the ‘deminimis’ exemption is not broad enough, and this needs to be extended. I would support a working percentage of around 40%

From a personal perspective the only grey area of dating ivory carvings are the ones which were made close to and around circa 1947. The 1947 date has in my opinion worked very well until now, although I would agree in the past that there have been low value tourist souvenirs available on the www. which we all detest.


I and many of my colleagues have suggested that specialist panels should police the British Antiques Market on the endangered species trade. The police force, HMRC and for that matter many of the museums do not have the specialists available to judge correctly the date and age of questionable pieces. In such cases a nominated panel (consisting of all elements of the antiques trade, museums, dealers, auctioneers and conservators) should be resorted to, for example the British Antiques Dealers dating panel, or as the very last resort carbon-dating as the ultimate scientific test.

A data-base of objects as suggested by Action for Elephants is a good idea, and one similar to the certificate system the BADA have suggested. However, it needs to be flexible. You cannot just say that there is a one-off opportunity to register the piece, and if it isn’t it will be confiscated and destroyed. Many private owners of ivory objects will be completely oblivious to the objects they have, material, value etc. So it seems rather draconian to implement a fixed date. The fact that they say ‘including for museums’ if they do not register the objects by the deadline date will be destroyed reminds me of the Nazi’s burning certain books which did not fit in with their ideology. We seem to be going against the British value of tolerance which we have always adhered to, especially on the global stage.

I do hope that the Public Bill Committee will see sense on this matter and not simply go along with the emotional argument that has been peddled by the likes of the NGO’S and Action for Elephants Uk.

Alastair Gibson MRICS

Gibson Antiques Ltd

June 2018


Prepared 19th June 2018