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TACKLINGTHE IVORIES:

The Status of the US Trade inElephant andHippo Ivory

Douglas F. Williamson

A TRAFFIC North America Report

TACKLING THE IVORIES:

The Status of the US Trade in Elephant and Hippo Ivory

By Douglas F. Williamson

September 2004

TRAFFIC North AmericaWorld Wildlife Fund

1250 24th Street NWWashington DC 20037

Visit www.traffic.org for an electronic edition of this report, and for moreinformation about TRAFFIC North America.

© 2004 WWF. All rights reserved by World Wildlife Fund, Inc.

ISBN 0-89164-174-2

All material appearing in this publication is copyrighted and may be reproducedwith permission. Any reproduction, in full or in part, of this publication must creditTRAFFIC North America.

The views of the authors expressed in this publication do not necessarily reflectthose of the TRAFFIC Network, World Wildlife Fund (WWF), or IUCN-The WorldConservation Union.

The designation of geographical entities in this publication and the presentation ofthe material do not imply the expression of any opinion whatsoever on the part ofTRAFFIC or its supporting organizations concerning the legal status of any country,territory, or area, or of its authorities, or concerning the delimitation of its frontiersor boundaries.

The TRAFFIC symbol copyright and Registered Trademark ownership are held byWWF. TRAFFIC is a joint program of WWF and IUCN.

Suggested citation: Williamson, D. F. 2004. Tackling the Ivories: The Status of theUS Trade in Elephant and Hippo Ivory. TRAFFIC North America. WashingtonD.C.: World Wildlife Fund.

Front cover photos from the top, clockwise, are: pygmy hippopotamus,Hexaprotodon liberienis, © Martin Harvey; forest elephant, Loxodonta africanacyclotis, © Martin Harvey; confiscated ivory and muzzle-loaders on display, © MegGawler.

Back cover photo, confiscated elephant ivory and rhino horn, © Martin Harvey.

TABLE OF CONTENTS

ACKNOWLEDGEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

BACKGROUND: THE LEGAL FRAMEWORK FOR TRADE IN IVORY . . . . . . . . . . . . . .7

CITES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7

US FEDERAL LAWS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9

THE ENDANGERED SPECIES ACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9THE LACEY ACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10THE AFRICAN ELEPHANT CONSERVATION ACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10THE CRIMINAL CODE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10

IMPLEMENTING REGULATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11

Raw Ivory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11Antique African Elephant Ivory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12Antique Asian Elephant Ivory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12

GENERAL REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

US STATE LAWS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .13

METHODS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15

THE US ELEPHANT IVORY MARKET . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

CUMULATIVE TRADE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

IVORY IMPORTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

Ivory Carvings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18Trophies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20Tusks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21Ivory Pieces and Piano Keys . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22

IVORY EXPORTS AND RE-EXPORTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24

THE DOMESTIC MARKET FOR WORKED IVORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25

THE DOMESTIC MARKET FOR RAW IVORY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .29

ILLEGAL TRADE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .30

Carved Ivory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31Ivory Jewelry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32Trophies and Tusks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32Smuggling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .33

SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .34

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US COMPLIANCE WITH CITES RESOLUTION CONF. 10.10 (REV. COP12) . . . . . . . . . . . . . . .35

THE IMPACT ON ELEPHANT POPULATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .36

THE US HIPPO IVORY MARKET . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39

THE GLOBAL HIPPO TRADE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39

THE CUMULATIVE US TRADE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39

US HIPPO IVORY IMPORTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .40

Countries of Origin . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .40

TRADE ROUTES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41

Carved Hippo Ivory . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41Hippo Teeth . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .42Hippo Jewelry and Pieces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43Hippo Trophies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43

THE DOMESTIC MARKET . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44

ILLEGAL TRADE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .46

THE IMPACT ON HIPPO POPULATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .47

CONCLUSIONS AND RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .49

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .53

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LIST OF TABLES

TABLE 1 ELEPHANT IVORY IMPORTED/EXPORTED/RE-EXPORTED BY THE USA BY SHIPMENT, 1995–2002 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17

TABLE 2 ELEPHANT IVORY IMPORTED BY THE USA BY PIECE,1995–2002 (NO. OF ITEMS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

TABLE 3 IMPORTS OF ELEPHANT IVORY INTO THE USA BY SPECIES,1995–2002 (NO. OF ITEMS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18

TABLE 4 COUNTRY OF EXPORT FOR SHIPMENTS OF CARVED ELEPHANT IVORY LEGALLY

IMPORTED INTO THE USA, 1995–2002 (NO. OF SHIPMENTS) . . . . . . . . . . . . . . . . . . . . . .19

TABLE 5 COUNTRY OF ORIGIN FOR ELEPHANT TROPHIES IMPORTED INTO THE USA BY SHIPMENT, 1995–2002 (NO. OF SHIPMENTS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21

TABLE 6 COUNTRY OF EXPORT FOR ELEPHANT TUSKS IMPORTED INTO THE USA BY PIECE, 1995–2002 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22

TABLE 7 COUNTRY OF EXPORT FOR ELEPHANT IVORY JEWELRY IMPORTED INTO THE USA BY PIECE, 1995–2002 (NO. OF ITEMS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .23

TABLE 8 DESTINATION COUNTRIES FOR CARVED ELEPHANT IVORY EXPORTED FROM THE

USA BY PIECE, 1995–2002 (NO. OF ITEMS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24

TABLE 9 IVORY FOR SALE ON EBAY, FEBRUARY–MAY 2004 . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26

TABLE 10 ELEPHANT IVORY SEIZED BY ITEM, 1995–2002 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31

TABLE 11 TOTAL GROSS EXPORTS OF HIPPO TEETH, TUSKS, CARVINGS, AND TROPHIES

FROM AFRICAN RANGE STATES, 1995–2002 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .39

TABLE 12 HIPPO IVORY IMPORTED INTO THE USA BY SHIPMENT, 1995–2002 . . . . . . . . . . . . . . . .40

TABLE 13 HIPPO IVORY IMPORTED INTO THE USA BY UNIT AND YEAR, 1995-2002 . . . . . . . . . . . .40

TABLE 14 COUNTRY OF ORIGIN FOR HIPPO IVORY CARVINGS AND TEETH CLEARED FOR

ENTRY INTO THE USA BY SHIPMENT, 1995–2002 (NO. OF SHIPMENTS) . . . . . . . . . . . . . .41

TABLE 15 COUNTRY/JURISDICTION OF EXPORT FOR SHIPMENTS OF CARVED HIPPO IVORY

IMPORTED INTO THE USA, 1995–2002 (NO. OF SHIPMENTS) . . . . . . . . . . . . . . . . . . . . . .42

TABLE 16 COUNTRY OF EXPORT FOR SHIPMENTS OF HIPPO TEETH IMPORTED INTO THE USA,1995–2002 (NO. OF SHIPMENTS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .43

TABLE 17 COUNTRY OF ORIGIN FOR SHIPMENTS OF HIPPO TROPHIES IMPORTED INTO THE USA,1995–2002 (NO. OF SHIPMENTS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .44

TABLE 18 SEARCH RESULTS FOR HIPPO IVORY AVAILABLE VIA EBAY,FEBRUARY 13–MAY14, 2004 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .45

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TRAFFIC North America wishes to express itsgratitude to Frances H. Lane, whose generoussupport made this report possible.

TRAFFIC would like to thank those whoprovided valuable insights and input during theearly stages of this project, as well as thosewho reviewed initial drafts of the report,including Samuel Lee and Hongfa Xu ofTRAFFIC East Asia; Rob Parry-Jones ofTRAFFIC Oceania; Tom Milliken of TRAFFICEast/Southern Africa; and Kevin Adams, EdGrace, and Andrea Gaski of USFWS.

The author would also like to thank severalpeople who helped steer this report toconclusion. These include Craig Hoover ofUSFWS, formerly of TRAFFIC NorthAmerica, who was there at the beginning ofthis project and provided critical guidancethroughout. Simon Habel and Leigh Henry ofTRAFFIC North America provided invaluable

assistance and support both substantively andeditorially in producing the final product. TinaLeonard of TRAFFIC North America deservesspecial thanks for spending many hourssearching Internet auction sites to find ivoryfor sale, and tabulating the results.

TRAFFIC would like to thank Patricia Wantfor teaching our researchers the workings andintricacies of Internet auction sites, and eBayin particular. Her pro bono help contributedsignificantly to the findings of this report.TRAFFIC is also deeply grateful to D.J. Mashof Image Works Creative Group for his speedyand solid work in preparing the layout andgraphics to produce the final product.

Finally, TRAFFIC North America expresses itsthanks to Aziz Gokdemir of Grammarians,Inc., as well as Steve Broad and Julie Gray ofTRAFFIC International, for their importanteditorial contributions.

ACKNOWLEDGEMENTS

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The international ivory trade remains one ofthe world’s most controversial wildlife tradeissues. In recent decades, public attention hasfocused primarily on trade in ivory derivedfrom the African Elephant Loxodonta africana.Following a decade in which African Elephantpopulations may have decreased by as much as50% because of widespread hunting andpoaching for ivory, in 1989 the internationalcommunity acted through the Convention onInternational Trade in Endangered Species ofWild Fauna and Flora (CITES) to list thespecies in Appendix I, the maximum level ofprotection afforded by the treaty. Prior to thatdecision, the USA acted unilaterally throughthe African Elephant Conservation Act(AECA) to ban almost all imports to the USAof African Elephant ivory (Peter Thomas,Chief, Division of Management Authority, USFish and Wildlife Service [USFWS], in litt. toWillem Wijnstekers, CITES Secretariat,August 2003). The Asian Elephant Elephasmaximus had previously been listed in CITESAppendix I in 1976 (O’Connell-Rodwell andParry-Jones, 2002).

The CITES decision to list the Asian andAfrican Elephants in Appendix I, along withthe AECA, have commonly been interpreted tohave effected a ban on all commercial trade inelephants, including their parts and derivativessuch as ivory. That is only partially true.Many nations, including the USA, continue toallow the trade of antique ivory products thatwere in trade before the CITES decision wasreached, subject to strict conditions.Therefore, some legal international trade ofelephant ivory carvings, jewelry, and otherproducts continues.

In addition, elephant ivory is not the only ivoryin the international marketplace. There is alsotrade in ivory and ivory substitutes derivedfrom sources ranging from the CommonHippopotamus Hippopotamus amphibius, toMammoths Mammathus, Walruses Odobenusrosmarus, Warthogs Phacochoerus africanus,Tagua Nuts Phytelephas equatorialis, and evenHornbills Bucerotidae. When the AfricanElephant was listed in CITES Appendix I, aparticular concern emerged as to whether amarket shift from elephant ivory to

hippopotamus ivory might come to threatenAfrican hippo populations. In 1995, theParties to CITES decided to list the CommonHippopotamus in the Convention’s AppendixII, which includes species that are not rare orendangered at present but could become so iftrade is not regulated.

As one of the world’s largest markets forwildlife products, the USA has long played asignificant role in the international ivory trade.Even after the 1989 passage of the AECA andthe decision to list the African Elephant inCITES Appendix I, the USA continued toallow the legal importation of AfricanElephant ivory in the form of antique carvings,jewelry, worked tusks, pieces, and piano keyswhose presence in trade pre-date the USlegislative and CITES actions. The USAfurther continued to allow the importation ofraw ivory in the form of sport-hunted tusksfrom certain African range states. The USAalso remained a major destination for illegalivory along with such legal ivory. Forexample, between 1996 and 2002 the USAreported nearly five times as many seizures ofillegal ivory as did any other nation, primarilyfrom the introduction of ivory curios aspersonal effects by US citizens returning fromabroad (Milliken et al., 2002). In addition toelephant ivory, the USA also imports largequantities of hippo ivory in the form ofcarvings, jewelry, teeth, and hunting trophies.

Between January and mid-April 2004,TRAFFIC researched and analyzed thecontemporary role of the USA in theinternational trade of elephant and hippo ivory,focusing in particular on the internationalaspects of the trade. As this report describes indetail, some of TRAFFIC’s major findingsregarding elephant ivory include the following:

• Between 1995 and 2002, the USAimported more than 5400 shipments ofworked ivory in various forms, involvingmore than 32 500 ivory items. Themajority of these imports took the form ofivory carvings, with smaller numbers ofimports of tusks, jewelry, ivory pieces,and piano keys.

• The principal source of this ivory isEurope—the UK in particular. Imports of

TACKLING THE IVORIES: The Status of the US Trade in Elephant and Hippo Ivory 1

EXECUTIVE SUMMARY

worked elephant ivory entering the USAare heavily concentrated among arelatively small group of importcompanies, galleries, antique dealers, andauction houses in New York City andelsewhere.

• The USA also continues to import rawivory in the form of African Elephanttusks from sport hunters returning from ahandful of African countries. Between1995 and 2002, at least 1328 AfricanElephant trophies entered the USAlegally, potentially representing the importof as many as 2656 tusks.

• The USA is also a re-exporter of workedelephant ivory, again primarily in theform of antique carvings.1 From 1995 to2002, the USA exported 1055 elephantivory shipments involving close to 8600carvings, as well as a smaller amount ofivory in the form of tusks, jewelry, andpiano keys.

• The domestic trade of ivory inside the USAis not closely monitored, and its full extentis unknown. Along with ivory availablefrom retail outlets, there is significant tradein elephant ivory conducted via theInternet, with little oversight.

• The domestic ivory trade involves bothworked and raw ivory. Worked ivoryreadily available in the US market is mostoften in the form of carvings, jewelry,piano keys, and other items. Raw ivory isbought by companies and individuals forfashioning into specialized commercialitems including knife handles, gun grips,and pool cues, as well as for non-commercial purposes.

• The absence of specific, strict regulationof the domestic US ivory market andcarving industry have led the CITESSecretariat to indicate that the USA is notfully implementing the requirements ofCITES Resolution Conf. 10.10 (Rev.

CoP12), discussed in detail below,regarding compliance with control ofinternal trade.

• Along with legal trade, there is evidencethat the USA continues to serve as a majordestination for illegal ivory. Much of thisillegal activity is believed to involve UScitizens, who may or may not be awarethat they are breaking the law, attemptingto bring in curios or souvenirs from tripsabroad. However, TRAFFIC also foundrecurring instances of seizures involvingthe antique trade from Europe, as well ascases involving larger-scale smuggling ofivory for commercial purposes.

• TRAFFIC also found an active Internettrade in ivory advertised as being derivedfrom elephant tusks via sellers based inChina. TRAFFIC found that theoperators of these Web-based “stores”routinely ship elephant ivory to the USAvia express delivery service, and evenoffer to falsely label the shipments ascontaining “bone carving.”

Comparing the US trade in hippo ivory to thatin elephant ivory, TRAFFIC found somesimilarities, but also many differences.Specifically:

• The USA imports significant quantities ofhippo ivory, primarily in the form ofcarvings, but also recorded as tusks, teeth,trophies, and, to a much smaller degree,jewelry.2 Although far fewer shipments ofhippo ivory entered the USA between1995 and 2002 than did shipments ofelephant ivory, the cumulative amount ofhippo ivory imported far exceeded that ofelephant ivory. This reflects the fact thattrade in hippo ivory involves primarilybulk commercial shipments, whereas theelephant ivory trade mostly involves theimport of individual antique items.

• The primary African range states listed ascountries of origin for hippo ivory

2 TACKLING THE IVORIES: The Status of the US Trade in Elephant and Hippo Ivory

1 Because the USA has no indigenous elephant population, all ivory exported from the USA to other nations can bepresumed to have originally entered the USA as ivory imports. Therefore, while USFWS data record these shipments asexports, they are more appropriately termed re-exports. For the purposes of this document, all exports should beinterpreted as including re-exports.

2 USFWS data, as well as data reported by CITES and the United Nations Environment Programme’s World ConservationMonitoring Centre (UNEP/WCMC) all have separate categories to report imports and exports of both hippo tusks andteeth. However, TRAFFIC found that at least in the USFWS data these terms appeared to be used interchangeably. Forthe purposes of this report, hippo tusk and tooth imports are combined and described simply as teeth.

entering the USA are Tanzania, Uganda,South Africa, and Zimbabwe, withsmaller amounts coming from a handfulof other countries in Africa.

• Most of the worked hippo ivory enteringthe USA comes through Hong Kong, withthe trade dominated by a small number ofcompanies identified as craft shops,carving factories, and import and exportfirms. There is also some Internet tradedirectly from Hong Kong-based outlets tobuyers in the USA. A secondary, lesssubstantial route for hippo ivory enteringthe USA involves companies, curio shops,and individuals in African hippo rangestates that export directly to the US market.

• At the import end, hippo ivory enteringthe USA flows through a relatively smallnumber of companies that regularlyimport hippo ivory carvings in bulkshipments, primarily on the East and WestCoasts. TRAFFIC found in a couple ofcases that these importers do retailbusiness in the USA through Internet sitesthat offer a consistent stream of hippoivory for sale to US customers.

• Unlike elephant ivory, there are very fewrecords of hippo ivory exports from theUSA to other nations, suggesting that theUSA is primarily a destination market forhippo ivory products, absorbing virtuallyall of the ivory imported.

• Unfortunately, USFWS data on importsare recorded such that it is impossible todetermine precisely how many of theshipments listed as teeth may representraw or worked ivory, but TRAFFIC’sanalysis of these records showed thatalong with worked ivory there alsoappeared to be numerous cases of hippoivory imports into the USA directly fromAfrica that were most likely raw teeth (inparticular those shipments listed as“tusks”). TRAFFIC also found cases ofraw hippo ivory being carved within theUSA for commercial sale, and of rawteeth being offered for retail sale in wholeform. However, the available data did notenable TRAFFIC to determine how manyindividual teeth, or hippos, wererepresented in the data.

• Illegal trade in hippo ivory appears to beless substantial than is illegal trade inelephant ivory. Whereas USFWS recordsshowed an overall seizure rate of 21% forelephant ivory, the seizure rate for hippoivory was four per cent. Some of theseseizures involved small amounts of hippoivory confiscated from individualsentering the USA; however, most seizuresinvolved commercial shipments of carvedivory from Hong Kong and elsewhere.

Recommendations• USFWS, in cooperation with state

wildlife authorities, should undertake aninitiative to determine the nature andscope of the US domestic ivory carvingindustry. Although TRAFFIC found noevidence of a significant domestic carvingindustry, the scattered examplesdiscovered in the research for this reportindicate that there continue to becompanies and individuals carving rawivory for commercial purposes within theUSA. This raises obvious questions aboutthe source of the tusks, the volume of thetrade, and whether the activity is beingcarried out in compliance with relevantfederal and state laws and regulations.Even if this aspect of the US ivory marketis very limited as is likely, understandingits extent and dynamics would assist notonly in efforts to monitor and regulate theUS trade in raw ivory, but would alsoenhance US compliance with theprovisions of CITES Resolution Conf.10.10 (Rev. CoP12).

• Funding for the USFWS wildlifeinspection program and related activitiesby US Customs and Border Protectionneeds to increase. USFWS has noted thatthe USA’s focus on monitoring andpolicing the ivory trade concentrates onfederal efforts at the border. Furthermore,to the extent that continuing illegal tradein ivory is driven by tourists who areknowingly or unknowingly breaking thelaw by trying to import elephant ivorysouvenirs or curios into the USA, themost effective line of defense remainsborder inspections. Although the USAhas perhaps the most effective lawenforcement system in place today to


handle this problem, the fact that in recentyears USFWS has not had a fullcomplement of trained wildlife inspectorsmay be undercutting this vital element ofthe US response to illegal ivory trade.

• Enhanced funding is also needed to expandspecial operations and undercoverinvestigations to identify and eliminatemarkets for illegal ivory within the USAand abroad. Although infrequent, thecontinuing phenomenon of cases of ivorybeing smuggled into the USA incommercial quantities suggests thecontinuing presence of an undergroundmarket. The presence of operations innations such as China sending a steadystream of elephant ivory into the USA viaInternet sales would also suggest the needto enhance cooperative internationalinvestigations to address the illegal trade insource nations as well as within the USA.

• At the same time, USFWS,nongovernmental organizations, andothers should work with companies suchas eBay to better police the sale ofelephant ivory across internationalboundaries via the Internet. Eliminatingthe ready access to Internet “stores” suchas those doing business from China wouldhelp to enhance overall US enforcementof its CITES obligations. If effectivemeans cannot be found to ensure thatsuch trade is carried out in compliancewith CITES and domestic US wildlifelaws, major sites such as eBay shouldconsider prohibiting international ivorysales through their services.

• Public agencies such as USFWS shouldincrease efforts to heighten awarenessamong consumers (tourists, etc.) andpotential vendors (Internet sites, antiquedealers, auction houses, retail operators,etc.) within the USA and abroad aboutwhat is legal and illegal with regard totrade in ivory. Nongovernmentalorganizations (NGOs) can assist theseefforts by disseminating informationthrough membership and publicinformation bulletins or other media,publishing accurate and impartial updateson ivory trade issues, and conductingeducation and public awareness programs

to inform the public about the ongoingproblem of illegal ivory trade.

• To help accomplish this, the USA shouldconsider the feasibility and efficacy ofincreasing the penalties for those caughtbringing illegal ivory or other illicitwildlife products into the country, andthen placing those funds into a dedicatedaccount to enhance public awarenessregarding illegal wildlife trade. Undersuch a scenario, those caught illegallyimporting wildlife or wildlife productswould not only face substantiallyincreased monetary penalties for eachitem seized as a deterrent, but theproceeds from those violations would godirectly to financing programs to bettereducate US tourists and others about theillegal wildlife trade. USFWS and othersshould study whether such an approachmight generate sufficient resources tohave a tangible effect on public educationand enforcement efforts.

• The USA should consult with nationsidentified as major sources of ivoryentering the country about ways to bettercoordinate and standardize rules regardingongoing legal trade in ivory. Forexample, while the USA considers“antique” ivory to be ivory that is at least100 years old, the European Union (EU)sets the standard for antique ivory at 50years. Such differing definitions andrules have created potential confusion andconflict regarding what ivory is allowed inthe marketplace. To the extent that legalinternational trade in elephant ivory is tobe allowed to continue, the internationalcommunity should work to create a singleset of standards.

• Finally, USFWS should improve the waythat it records imports and exports ofboth elephant and hippo ivory into andout of the USA. Specifically, LEMISdata available for this report did notenable TRAFFIC to determine the precisenumber of elephant tusks entering thecountry annually as trophies, which is animportant measure because such trophiesrepresent the only raw elephant ivoryentering the US legally at present. Someelephant trophy shipments were reported


as a single unit, while other recordsshowed a single shipment of multiple“trophies.” USFWS should change theway it records such shipments to specifythe number of raw or unprocessedelephant tusks being imported. USFWSshould make the same distinctionregarding the number of hippo teethbeing imported in trophy shipments.Also regarding the hippo ivory trade,

TRAFFIC could not always distinguishwhether imports of “teeth” representedraw or worked ivory, making itimpossible to calculate the amount of rawhippo ivory entering the USA on anannual basis. USFWS should clarify itsmethod of recording hippo tooth importsto clearly distinguish between raw andworked ivory.


International trade in ivory derived from bothelephants and hippos is regulated byinternational treaty, as well as by the domesticlaws of importing and exporting nations. In thecase of the USA, the conditions under whichtrade in ivory from these species is or is notallowed are dictated by the nation’s obligationsas a signatory to CITES, and also by therequirements of US wildlife laws, particularlythose used to implement the Convention.

CITES requirements and several domestic lawsenacted by the USA severely restrictinternational trade in elephant ivory, and alsoimpose conditions on the legal trade in hippoivory. However, a series of special rules andexceptions promulgated by USFWS inaccordance with US laws have allowed for thecontinuation of trade in worked ivory fromboth African and Asian Elephants into, out of,and within the USA under certain conditions.To understand the terms under which the USAcontinues to participate in the internationaltrade in ivory, and particularly elephant ivory,the following provides some basic backgroundon CITES, relevant US domestic laws, andspecific implementing regulations that pertainto ivory.

CITESCITES, which entered into force in 1975, wasdeveloped to safeguard species vulnerable toover-exploitation through international trade.As of June 2004, 166 nations (known as“Parties”) had acceded to the Convention(CITES, 2004a).

CITES established a worldwide system ofcontrols on international trade in threatenedand endangered wildlife and wildlife products.At present, some 5000 species of animals and28 000 species of plants are covered by theConvention. Protection for species is providedunder the Convention’s three Appendices,which describe the status of the species anddetermine what species may enter internationalcommercial trade. The most endangeredspecies are listed in Appendix I, whichincludes all species threatened with extinctionthat are or may be affected by trade.

According to the Convention, commercialtrade is not permitted for these species, andother trade for purposes such as scientificresearch is strictly controlled through importand export permits. Appendix II species arethose that are not rare or endangered at presentbut could become so if trade is not regulated;international trade in such species requires theissuance of a CITES export permit by theexporting country. Appendix III species arenot endangered but are subject to regulationwithin the listing nation for the purposes ofpreventing or restricting exploitation, and, asrequested, promoting the cooperation of otherparties in the control of trade (CITES, 2003a).

The Asian Elephant Elephas maximus, AfricanElephant Loxodonta africana, and CommonHippopotamus Hippopotamus amphibius cameto be listed under CITES in different years andunder different circumstances. Steep declinesin elephant populations in the 1970s,particularly in East Asia, led to the AsianElephant’s listing in Appendix I in 1976. TheAfrican Elephant was listed in Appendix II atthe same time (CITES, 2003b). The primaryconcern that prompted this initial listing wasthe threat posed to elephant populations by theworldwide demand for ivory. Continuingdeclines of African Elephant populationsthrough the 1980s, during which the overall


BACKGROUND: THE LEGAL FRAMEWORKFOR TRADE IN IVORY

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numbers of the species were believed to havebeen reduced by as much as 50%, led theCITES Parties to transfer the African Elephantto Appendix I in 1989 (O’Connell-Rodwelland Parry-Jones, 2002).

The Common Hippopotamus was listed inCITES Appendix II in 1995; prior to that thisspecies had been listed in Appendix III forGhana since 1975. Although the hippo wasnot immediately threatened with extinction,several factors suggested that it could becomeso unless action was taken. Among thesefactors were increased subsistence hunting formeat, a possible increase in the demand forhippo tooth ivory because of the shiftingdynamics of the elephant ivory trade, and thefact that the sedentary nature of the speciesmakes the hippo particularly vulnerable tolarge-scale poaching, especially with automaticweapons. CITES and Customs data alsoappeared to show an increase in internationaltrade in hippo ivory after the ban oninternational trade in elephant ivory took effectin 1990. This development raised concernsthat the trade could pose a serious threat tohippo populations, justifying the species’inclusion in Appendix II (TRAFFIC andIUCN/SSC [World Conservation Union’sSpecies Survival Commission], 1994).

With these decisions, by 1995 the CITESParties had conferred the strongest traderestrictions available under CITES to bothAsian and African Elephants, while providingwild hippo populations with a lesser but stillimportant degree of trade regulation.Unfortunately, the variance in timing betweenthe CITES listings for the African Elephantand the Common Hippopotamus precluded anattempt to directly compare the US market forivory derived from African and Asian elephantsto that for hippo ivory during the interveningyears. Although gross reported exports ofhippo teeth from African range states increasedoverall from 1991 to 1996, and peaked in 1994at approximately 25 mt, the USA did not beginto keep detailed track of imports of hippo ivoryuntil 1995 (CITES, 1999). Therefore, whilethe USA may have been a major destinationfor ivory derived from hippo teeth in the yearsbetween the listing of the African Elephant in1989 and the Common Hippopotamus severalyears later, data are not available to showwhether hippo ivory imports to the US market

increased significantly following the AfricanElephant’s listing.

Furthermore, beginning in 1997 the CITESParties began to modify trade restrictionspertaining to ivory and other products fromsome African Elephant populations, while alsotaking other actions regarding trade inelephant ivory that relate directly or indirectlyto the USA.

First, at the Tenth Conference of the Parties toCITES (CoP10), held in Harare, Zimbabwe inJune 1997, the Parties began to downlist theAfrican Elephant populations of selected rangestates from Appendix I to Appendix II.Initially, the Parties downlisted the populationsof Botswana, Namibia, and Zimbabwe,specifically authorizing the export of huntingtrophies for non-commercial purposes, andalso allowing specific quantities of raw ivoryto be exported to Japan on a one-time basisbeginning in 1999. The initial ivory quotasunder this change were 25.3 mt for Botswana,13.8 mt for Namibia, and 20 mt for Zimbabwe(UNEP/WCMC, 2004a).

In 2000, South Africa’s elephant populationwas similarly downlisted, although with a zeroquota for commercial exports of ivory. In2003, Botswana, Namibia, and South Africafurther received tentative permission to tradecertain ivory from registered government-owned stocks (excluding seized ivory and ivoryof unknown origin). If certain conditions weremet, this ivory could be exported no soonerthan in May 2004 to trading partners that hadbeen verified by the CITES Secretariat to havesufficient national legislation and domestictrade controls to ensure that the imported ivorywould not be re-exported and would bemanaged in accordance with the requirementsof CITES Resolution Conf. 10.10 (Rev.),which is described below. Under this program,Botswana, Namibia, and South Africa receivedone-time ivory quotas of 20, 10, and 30 mt,respectively, to be dispatched in singleshipments from each country under thesupervision of the CITES Secretariat(UNEP/WCMC, 2004a).

Second, at CoP10 the Parties also adopted theaforementioned Resolution Conf. 10.10 (Rev.at the Twelfth meeting of the Conference ofthe Parties to CITES [CoP12]), which includeda section regarding compliance with control of


internal trade. The resolution directed theCITES Secretariat to identify those Partieswith an ivory carving industry and internalivory trade whose domestic measures did notprovide them with the authority to (1) registeror license all importers, manufacturers,wholesalers and retailers dealing in raw, semi-worked or worked ivory products; (2) assertcompulsory trade controls over raw ivory; and(3) establish a comprehensive anddemonstrably effective reporting andenforcement system for worked ivory. Theresolution further directed the Secretariat toseek information from each Party indicatingthe procedures, action and time frames neededto establish such measures. Finally, theresolution called for the Secretariat to report itsfindings, recommendations or progress to theCITES Standing Committee, which wouldconsider appropriate measures, includingrestrictions on the commercial trade inspecimens of CITES-listed species to or fromsuch Parties (CITES, 2004b).

Third, at CITES CoP12, held in Santiago, Chilein November 2002, the Parties adopted anothermeasure, CITES Decision 12.39. The decisioncalled on the Secretariat to assess whethercountries with active internal ivory markets(defined as Cameroon, China, the DemocraticRepublic of the Congo, Djibouti, Ethiopia,Japan, Nigeria, Thailand, Uganda, and theUSA) have established the comprehensiveinternal legislative, regulatory and enforcementmeasures regarding compliance with control ofinternal trade that were specified in ResolutionConf. 10.10 (Rev. CoP12). The decisionfurther stated that where such assessmentsdemonstrate that a Party does not haveadequate measures, the Secretariat shall seek anaction plan outlining the Party’s plan to adoptmeasures enabling it to adequately regulatetrade in ivory. The purpose of such plans is forthe Party in question to establish and commit toa timeframe for developing, approving,enacting, and implementing such measures(CITES, 2004c).

In response, USFWS provided a summary ofthe legislative, regulatory, and enforcementmeasures currently in place in the USA thatwould satisfy the CITES Resolution Conf.10.10 (Rev.) and Decision 12.39. Thefollowing outlines the legal framework in placein the USA in relation to the international anddomestic trade in ivory.

US Federal Laws The USA relies primarily on three federal lawsto regulate the import, export, and domesticsale of ivory—the Endangered Species Act(ESA), the Lacey Act, and the AfricanElephant Conservation Act (AECA).

The Endangered Species Act

Enacted in 1973, the ESA established the legalbasis for the USA to protect and conservespecies in danger of extinction, and theecosystems upon which such species depend.Under the ESA, species may be listed as eitherendangered or threatened. According to thelaw, endangered species are those that are indanger of extinction throughout all or a portionof their range. Threatened species are definedas those that are likely to become endangeredwithin the foreseeable future if measures arenot taken to ensure their conservation(USFWS, 2002).

The ESA relates to the ivory trade in threeways. First, both the Asian and AfricanElephants are listed under the Act, andtherefore are directly subject to its provisions.The Asian Elephant was listed as endangered in1976; the African Elephant was listed asthreatened in 1978. Under the ESA, it is illegalfor any person subject to US jurisdiction toimport, export, deliver, receive, carry, transport,ship, sell, or offer for sale in interstatecommerce and in the course of a commercialactivity, any species of plant or animal that hasbeen listed as threatened or endangeredpursuant to the Act (Hoover and Tarr, 1997).As is discussed below under implementingregulations, USFWS promulgated a SpecialRule under the threatened listing for the AfricanElephant allowing for the trade of sport-huntedtusks and antique ivory, provided certainconditions are met.

Second, the ESA also serves as the USdomestic enabling legislation forimplementation of the provisions of CITES.The ESA makes it unlawful to engage in tradecontrary to CITES, or to possess any specimenthat was “traded contrary to the provisions ofthe Convention” (Hoover and Tarr, 1997).Consequently, because the Asian Elephant,African Elephant, and CommonHippopotamus are all CITES-listed species,trade in ivory from any of these species must


be conducted within the parameters of CITESto be legal under the ESA, even though thehippo is not currently listed under the Act asthreatened or endangered.

Furthermore, the ESA makes it illegal for anyperson to engage in business as an importer orexporter of fish, wildlife, or plants unless thatperson first obtains permission from theSecretary of the Interior. USFWS has usedthis provision to establish a licenserequirement for wildlife importers andexporters. The Act specifies that any personrequired to obtain permission to do businessshall keep adequate records of the animals andplants imported or exported, and theirsubsequent disposition; allow USFWS toexamine those records and his or her inventory;and file any report required by the Secretary.The Act also makes it illegal for any importeror exporter to fail to file any declaration orreport deemed necessary by the Secretary tofacilitate the Act’s enforcement or meet theobligations of CITES (Hoover and Tarr, 1997).

Another section of the ESA makes it illegal(with certain exceptions) to import or exportany fish, wildlife, or plants at ports of entryother than those designated for wildlifeshipments by the Secretary of the Interior.USFWS has identified 50 US ports of entrywhere wildlife imports and exports may beprocessed. These include 15 designated ports(through which the majority of all shipmentspass), 30 border ports, and five special ports(USFWS, 2004a).

The Lacey Act

Originally enacted by Congress in 1900, theLacey Act prohibits the import, export,transport, acquisition, receipt, sale, or purchasein interstate or foreign commerce of any fish orwildlife taken, possessed, transported, or soldin violation of any wildlife law or regulation ofany state, or in violation of any foreign wildlifelaw. It also prohibits the import, export,transport, sale, receipt, acquisition or purchaseof fish, wildlife, or plants taken, possessed, orsold in violation of any wildlife law, treaty, orregulation of the USA, or in violation of anyIndian tribal law. Further, the Act prohibitsattempts to commit any of these acts (Hooverand Tarr, 1997).

In addition, the Lacey Act prohibits the actualor attempted falsification of information,records, or accounts regarding species thathave been imported, exported, transported,sold, purchased, or received in interstate orforeign commerce. The Act makes it illegal toimport, export, or transport in interstatecommerce, any container or packagecontaining fish or wildlife unless it has“previously been plainly marked, labeled, ortagged” in accordance with USFWS markingregulations, and authorizes USFWS to detainany package or container (and accompanyingpapers) being imported into or exported fromthe USA (Hoover and Tarr, 1997).

The African Elephant Conservation Act

The AECA was enacted by Congress in 1988,in recognition of the particular threat posed towild elephant populations in Africa because ofpoaching for the ivory trade. The Act makes itillegal to import raw ivory from any countryother than an ivory producing country, orexport any raw African Elephant ivory fromthe USA. It further makes it unlawful toimport raw or worked ivory that was exportedin violation of an ivory-producing country’slaws. It is unlawful to import worked ivory,other than personal effects, unless theexporting or re-exporting country has certifiedthat the ivory was from legal sources.

The AECA also makes it illegal to import rawor worked ivory from a country for which amoratorium is in effect. There are three suchmoratoria. A moratorium on the import ofAfrican Elephant ivory from non-CITESParties was established on December 27, 1988.A moratorium on the import of Africanelephant ivory from Somalia was establishedFebruary 24, 1989. And a moratorium(excluding sport-hunting trophies) on theimport of all African raw or worked ivory fromall ivory-producing nations was established onJune 9, 1989 (USFWS, 1989).

The Criminal Code

In addition to these laws relating specifically towildlife, federal prosecutors routinely useseveral provisions of the Criminal Code (Title18, US Code), to prosecute CITES violations.The provisions of Title 18 most often used toprosecute violations of CITES, in addition to


penalties for violations of the wildlife lawsthemselves, include the following:

• “Document” smuggling, which makes itillegal to import or otherwise entermerchandise into the USA by means offalse or fraudulent declarations ordocuments, or by means of any false oralor written statement;

• Clandestine smuggling, under which it isillegal to knowingly and willfully importor clandestinely introduce into the USAany merchandise contrary to law (it is alsoillegal to buy, sell, receive, conceal, orfacilitate the transportation of merchandisethat has illegally entered the USA);

• False statements, which makes it illegal toknowingly and willfully falsify a materialfact, or make a false or fraudulentstatement or entry (this section is oftenfiled in conjunction with document-smuggling charges); and,

• Conspiracy, which occurs when two ormore persons conspire to commit anyoffense against the USA, or to defraud theUSA, and one of the conspiratorscommits any act to implement theconspiracy (Hoover and Tarr, 1997).

Implementing Regulations This combination of federal laws severelyrestricts most trade in elephant ivory, and alsoregulates the US trade in hippo ivory.However, along with sport-hunted trophies, theUSA allows the import of commercial andnon-commercial antique elephant ivory, non-commercial pre-Convention ivory, and personaland household effects. Special rulesestablished by USFWS pursuant to theirstatutory mandates govern the legality of suchimports. In addition, rules differ on whetherimported ivory can be legally resold after it hasentered the USA. The basic rules governingthe import, export, and sale of different formsof elephant ivory are as follows.

Raw Ivory

As a general rule, it is illegal to import rawAfrican Elephant ivory into the USA with theexception of personal sport-hunted trophies.Even with trophies, rules differ on the needfor import permits. Sport-hunted trophies

taken in four African countries—Botswana,Namibia, South Africa, and Zimbabwe—areexempt from import permit requirements. Asnoted above, elephant populations in thesecountries are listed in CITES Appendix II toallow for trade in certain products, one ofwhich is the non-commercial export ofpersonal sport-hunted trophies. Under aSpecial Rule promulgated as part of theAfrican Elephant’s listing under the ESA,USFWS must ensure that each country has anivory quota for the year of export anddetermine that the import of a sport-huntedtrophy will enhance the survival of the species(50 Code of Federal Regulations [CFR] Ch. 1,§17.40). These findings have been made forthe four countries in question, and will remainin effect unless new information reveals thatthe conditions of the Special Rule are nolonger met. In addition, although all parts of asport-hunted African Elephant may beimported, the ivory may not be re-exportedfrom the USA (USFWS, 2003a).

The USA requires an import permit for sport-hunted trophies from all other African nations.Before issuing such a permit, USFWS looks atthe overall management program for thespecies in each country. Factors consideredmay include the biological needs of thespecies, possible threats to the population,current population estimates, quotas,management plans, local communityinvolvement, and the use of hunting fees forconservation. The process of making such adetermination can be lengthy; however, lesstime is generally needed to processapplications from countries for which USFWShas recent information indicating thatmanagement plans meet US CITESobligations. As of the summer of 2003, theonly country to which the latter appliesregarding African Elephants is Tanzania(USFWS, 2003a).

Finally, USFWS has established a markingrequirement for trophies as part of the SpecialRule under which the African Elephant waslisted as a threatened species under the ESA.Under this part of the rule, to be legallyimported the trophy must be legibly marked bymeans of punch-dies, under a marking andregistration system established by the country oforigin. The marking must include informationon the country or origin, followed by the


registration number assigned to the last twodigits of the year of registration and the weightof the ivory to the nearest kilogram. The markmust be placed on the lip mark area (defined asthe area where the tusk emerges from the skulland is usually denoted by a ring of staining) andindicated by a flash of color that serves as abackground (50 CFR Ch. 1, §17.40).

Antique African Elephant Ivory

The USA also allows the import, export, andsale of antique African Elephant ivory, subjectto certain restrictions. An ivory item can beimported or exported for commercial ornoncommercial purposes if it meets USFWScriteria as a “bona fide” antique. To makesuch a determination, USFWS requiresdocumentation showing that the item is atleast 100 years old and has not been repairedor modified with any new ivory since theeffective date of the ESA (December 28,1973). USFWS also requires a Pre-Convention Certificate from the CITESManagement Authority of the exportingcountry (USFWS, 1999).

Rules governing the purely noncommercialimport of African Elephant ivory have slightlymore latitude. Worked ivory for non-commercial purposes may be imported if it isaccompanied by a CITES Pre-ConventionCertificate from the exporting country showingthat the ivory was acquired before February 4,1977. Worked ivory acquired and/or possessedby US residents for noncommercial purposesand exported from the USA withdocumentation from USFWS can also be re-imported as personal effects or householdgoods. For non-US residents, worked ivorycan be imported as personal effects orhousehold goods provided that the ivory waslegally acquired in the country of usualresidence and legally exported from thatcountry (USFWS, 1999).

Antique Asian Elephant Ivory

Rules on the import, export, and sale ofantique Asian Elephant ivory differ onlyslightly from those covering African Elephants.As with ivory from the African Elephant,special provisions in the ESA allow AsianElephant ivory to be imported into, exportedfrom, and sold within the USA under certain

limited circumstances. Requirements for legalsale include a determination that the ivory is abona fide antique, and that the sale of ivory isallowed within the relevant US state ofresidence. Under these rules, an AsianElephant ivory article can be imported orexported for commercial or noncommercialpurposes if it is accompanied bydocumentation that shows the article is at least100 years old; has not been repaired ormodified with any new ivory since December28, 1973 (the effective date of the ESA); and isalso accompanied by a CITES Pre-ConventionCertificate from the Management Authority ofthe exporting country (USFWS, 2003b).

By their listing as endangered under the ESA,Asian Elephants and their parts or products alsocannot be sold across state lines or overseas, orimported or exported, unless the requirementsof that law are met. Under the ESA, worked orraw pre-Act Asian Elephant ivory must meetseveral criteria. First, it must have beenacquired or removed from the wild prior toJune 14, 1976, the listing date of the AsianElephant under the ESA. Second, it may nothave been held in the course of a commercialactivity (i.e., bought, bartered, offered for sale,or leased) since that time. Third, it must beaccompanied by a pre-Act affidavit as outlinedin the relevant regulations detailed in the USCode of Federal Regulations (50 CFR 17.4).And fourth, it must be imported or exported for noncommercial purposes and accompaniedby a CITES Pre-Convention Certificateshowing it was acquired before July 1, 1975(USFWS, 2003b).

Furthermore, pre-Act Asian Elephant ivory canbe sold only to others residing in the samestate, and once the ivory has enteredcommerce, it loses its pre-Act status. If theivory does not qualify as antique or pre-Act, aperson may apply for a permit for scientificresearch, or for enhancement of propagation orsurvival of the species for the followingactivities. For import and export, CITESimport and export permits are required inaddition to ESA permits. CITES permits areissued when the export or the purpose of theimport will not be detrimental to speciessurvival, the specimens have been legallyacquired, and the import is not for primarilycommercial purposes. In addition, AsianElephant ivory in interstate or foreign



commerce may be advertised for sale onlyprovided that the advertisement contains astatement that the item may not be sold untilan ESA permit has been obtained fromUSFWS. The ESA does not restrict the sale ofivory to another resident of the same US state;however, as is noted below there may be staterequirements (USFWS, 2003b).

General RequirementsIn addition to satisfying these basicrequirements for both Asian and AfricanElephant ivory, anyone engaging in business asan importer or exporter of ivory must obtain anImport/Export License pursuant to the ESA.Ivory shipments must enter or leave the USAthrough a port designated for wildlifeshipments or a non-designated port if there is avalid Exception to Designated Port Permit. Ifthe item is a bona fide antique, it may beshipped through a Customs Service portdesignated for the import/export of antiques.All shipments must be marked on the outsideof the container with the names and addressesof the exporter and importer, as well as anaccurate identification of the species andnumber of items in the container. Thefollowing documents must be provided at theport: CITES permits or certificates; antique orpre-Act documentation, as appropriate; aWildlife Declaration Form; and copies of theairway bill, or bill of lading and invoice(USFWS, 1999 and 2003b).

US State Laws A number of US states have enacted laws that,along with these federal statutes, supportfederal endangered species and wildlife tradelaws. Some of these state laws includeprovisions specific to the import or sale ofelephant ivory. For example, California lawprohibits the import of elephant ivory into thestate for commercial purposes, to possess suchivory with intent to sell, or to sell it within thestate. Connecticut law provides the state withthe authority to regulate trade in raw elephantivory or products if the trade in Connecticut isdetermined to contribute to the extinction orendangerment of elephants (Peter Thomas,Chief, Division of Management Authority,USFWS, in litt. to Willem Wijnstekers, CITESSecretariat, August 2003).

In addition, 22 states (Connecticut, Hawaii,Idaho, Illinois, Iowa, Kansas, Louisiana,Maryland, Massachusetts, Michigan, Missouri,Nebraska, New Hampshire, New York, NorthCarolina, Oklahoma, Oregon, Rhode Island,South Dakota, Tennessee, Vermont, andVirginia) either incorporate federally-listedthreatened species into the state list or havespecific provisions or permit requirementsregarding threatened species or federallyregulated wildlife (Peter Thomas, Chief,Division of Management Authority, USFWS,in litt. to Willem Wijnstekers, CITESSecretariat, August 2003). Therefore, alongwith federal restrictions and conditions, theimport, export, sale, or purchase of ivorywithin the USA may be prohibited or subjectto the permitting requirements of theseindividual states.

TRAFFIC conducted primary research for thisreport between January and March 2004, withsome follow-up information collected as late asSeptember 2004. Data were collectedprimarily through published and unpublishedreports, import and export data provided byUSFWS, CITES trade records and documents,records and documents obtained through theUnited Nations Environment Programme’sWorld Conservation Monitoring Centre(UNEP/WCMC), and a review of relevant USfederal and state laws and regulationspertaining to the international and domestictrade of both elephant and hippo ivory.TRAFFIC collected some further informationthrough press releases, media outlets, andpersonal communications. Through thesesources, TRAFFIC attempted to identify thevolume, trade routes, major importers andexporters, and destination markets for ivoryentering the USA, both legally and illegally.

TRAFFIC also made extensive use of theInternet, primarily to examine how thisrelatively recent phenomenon has emerged as amajor vehicle through which elephant and

hippo ivory is imported into and then sold ordistributed within the USA. TRAFFIC’sInternet research encompassed two majorelements. The first involved a regular weeklysurvey of elephant and hippo ivory availablefor sale from both domestic and foreignsources through eBay—http://www.ebay.com—the world’s largest online auction site.TRAFFIC chose to examine eBay in particularbecause of the dominant position that the siteplays in the Internet auction business, bothdomestically and internationally.

The second involved a specific investigation ofseveral China-based sellers using eBay thatTRAFFIC found to be routinely shippingcarvings, jewelry, and other items identified asderived from elephant tusk ivory to customersin the USA in apparent contravention ofCITES and US wildlife trade laws. Thespecific methods employed by TRAFFIC aredetailed in the body of the report below.Finally, TRAFFIC reviewed other Web sitesthat are advertising and selling raw and workedivory, from elephants and hippos, both via theInternet and at retail locations.


METHODS

With the aforementioned basic background onthe legal framework for the ivory trade in mind,TRAFFIC examined the current status of the UStrade in elephant ivory. As is detailed below, theUSA remains an importer of both raw andworked elephant ivory, with the majority of thetrade consisting of carved ivory items. TheUSA also continues to export worked elephantivory in various forms. TRAFFIC found thatwhile the legal international trade shows someclear patterns, less is known about the dynamicsof the domestic trade in ivory once it enters theUSA. Such trade is only loosely regulated ormonitored. TRAFFIC also found that illegaltrade in elephant ivory continues to be aproblem, although the full extent of such traderemains unknown.

Cumulative TradeBetween 1995 and 2002, data providedthrough the USFWS Law EnforcementManagement Information System (LEMIS)showed some 7908 records of legal imports,exports or re-exports of elephant ivory into andout of the USA, as well as 1440 records ofshipments that were refused, with the items inquestion either seized, abandoned, or re-exported. These overall shipments includedboth raw and worked elephant ivory in variousforms, including carved ivory items, trophies,tusks, pieces of ivory, and piano keys. Table 1shows the total number of shipments ofelephant ivory during this period by type ofitem, including legal (cleared) and illegal(refused) ivory, and shipments for bothcommercial and non-commercial purposes.

LEMIS data showed an additional 205records (145 cleared imports, 16 refusedimports, and 44 cleared exports) for which thetype of elephant product was not specified inthe database. TRAFFIC’s analysis of theserecords suggested that some may havecontained ivory, based on factors such asvaluation, origin, importer/exporter, andothers that were similar to identified ivoryshipments. However, because TRAFFICcould not make a positive determination thatthe shipments were in fact elephant ivory,those records are not included in the totalsprovided below. It should be noted that theirabsence means that the figures herein may notrepresent a truly comprehensive estimate ofthe amount of elephant ivory reported aslegally entering and leaving the USA between1995 and 2002 (TRAFFIC analysis ofUSFWS LEMIS data, March 2004).

Ivory ImportsTRAFFIC analyzed the available LEMIS datato determine how many ivory items wererepresented in the records of cleared shipmentsshown in Table 1, which species wereinvolved, and what patterns were evident in thetrade. As is shown in Table 2, this analysisshowed that the legal trade in elephant ivorycumulatively accounted for the importation ofa minimum of 33 864 ivory items in the formof carvings, trophies, tusks, jewelry, ivorypieces, and piano keys between 1995 and 2002(TRAFFIC analysis of USFWS LEMIS data,March 2004).


THE US ELEPHANT IVORY MARKET

Commodity Import Shipments Import Shipments Export/Re-export Export/Re-export Cleared Refused Shipments Cleared Shipments Refused

Carved Ivory 4874 730 1055 3Trophies 1328 10 10 0Tusks 180 134 6 1Ivory Pieces 128 32 40 0Ivory Jewelry 71 520 10 1Piano Keys 166 9 40 0Total 6747 1435 1161 5

Table 1: Elephant Ivory Imported/Exported/Re-exported by the USA byShipment, 1995–2002

Source: TRAFFIC analysis of USFWS LEMIS data, March 2004.

TRAFFIC attempted to determine how muchthis trade in elephant ivory involved African asopposed to Asian Elephants. LEMIS recordsidentify imports of ivory by species (African orAsian) where that information has beendetermined. In cases where the specificspecies is not identified, LEMIS classifies theimport simply as “Elephantidae.” Byseparating these three categories ofinformation, TRAFFIC’s analysis found thataccording to the available import data, thepreponderance of the trade is in AfricanElephant ivory—with the second largestamount unspecified. Table 3 shows thecumulative breakdown of ivory imports intothe USA by item and species between 1995and 2002.

TRAFFIC’s analysis also showed differentsources, trade routes, and principal players forthe various commodities listed in the tablesabove. By commodity, the primary patterns oftrade appeared to be as follows.

Ivory Carvings

During the period 1995 to 2002, the USAcleared 4874 shipments identified as ivorycarvings, from at least 51 countries.TRAFFIC’s review of LEMIS import data,other information supplied by USFWS, and thefindings of other studies (HSUS, 2002; IFAW,2004) all indicate that most of this tradeinvolves countries in Europe, and the UK inparticular. For example, USFWS noted that in2002, 88% of the ivory carvings imported into


Table 2: Elephant Ivory Imported by the USA by Piece, 1995–2002 (no. of items)

Item 1995 1996 1997 1998 1999 2000 2001 2002 Total

Carved Ivory 1373+ 2588+ 2523 2926 2526 3325 3015 1800 20 076+

Trophies 99 125 121 144 191 223 231 194 1328Tusks 78 18 12 57 61 59 54++ 44 383++

Ivory Pieces 0 0 0 345 274 1025+++ 101+++ 53 1798Ivory Jewelry 13 40 46++++ 31 21 31 68 6 256Piano Keys 54 367 1107 2952 1600 2967 436 540 10 023

Total 1617 3138 3809 6455 4673 7630 3905 2637 33 864

Source: TRAFFIC analysis of USFWS LEMIS data, March 2004.+ Minimum figure—does not include shipments involving 84.532 kg of ivory carvings imported in 1995 and 1996 because the number of

carvings these shipments represent could not be determined.++ Zimbabwe also exported one shipment identified as two kilograms of tusks to the USA in 2001. +++ Total for 2000 does not include a shipment of 18 kg from Canada. Total for 2001 does not include a shipment of 10 grams.++++ Total does not include a shipment of 25 kg from France.

Table 3: Imports of Elephant Ivory into the USA by Species, 1995–2002(no. of items)

Commodity African Elephant Asian Elephant Unspecified

Carved Ivory 15 136 2682 2239+86kg +532 gm

Trophies 1327 1 0Tusks 368 8 7Ivory Pieces 1559 8 229

+ 10 gm + 18 kgIvory Jewelry 190 34 32

+25 kgPiano Keys 7240 54 2728Total 25 820 2787 5235

+ 86.010 kg +43.532 kg

Source: TRAFFIC analysis of USFWS LEMIS data, March 2004

the USA legally came from European countries(Peter Thomas, Chief, Division of ManagementAuthority, USFWS, in litt. to WillemWijnstekers, CITES Secretariat, August 2003).That pattern showed itself consistently in the

data in every year reviewed for this report.Table 4 shows the country of export for carvedivory shipments (combined African Elephant,Asian Elephant, and unspecified) entering theUSA from 1995 to 2002.


Exporter 1995 1996 1997 1998 1999 2000 2001 2002 Total

EuropeUK 178 282 313 427 647 669 785 583 3884France 6 12 22 32 23 40 30 27 192Germany 3 15 37 4 5 31 28 25 148Netherlands 2 4 5 0 3 9 49 3 75Switzerland 1 7 5 5 12 15 3 6 54Belgium 2 1 17 5 8 8 2 3 46Italy 2 1 2 1 5 7 5 0 23Russia 0 1 2 3 2 5 0 1 14Spain 0 0 0 0 0 2 2 5 9Austria 1 1 2 0 1 0 0 1 6Sweden 0 0 0 0 0 1 0 2 3

Subtotal: 195 324 405 477 706 787 904 656 4454AsiaJapan 4 13 12 8 5 19 6 7 74Hong Kong 1 2 4 1 1 0 3 2 14Taiwan 1 5 0 0 0 2 0 0 8China 0 0 3 0 1 1 0 0 5India 1 0 0 1 0 0 0 0 2Sri Lanka 0 0 0 0 1 0 0 0 1

Subtotal: 7 20 19 10 8 22 9 9 104AfricaGuinea Biss. 0 0 0 0 0 11 0 0 11South Africa 1 1 0 0 0 3 1 0 6Burkina Faso 0 0 0 3 0 0 0 0 3Kenya 2 0 1 0 0 0 0 0 3Egypt 0 0 0 0 0 0 0 1 1Guinea 0 0 0 0 0 0 0 1 1Congo 0 0 0 0 0 0 0 1 1Nigeria 0 0 0 0 1 0 0 0 1Sierra Leone 1 0 0 0 0 0 0 0 1Zambia 0 0 0 0 0 1 0 0 1Zimbabwe 0 0 0 0 0 1 0 0 1

Subtotal: 4 1 1 3 1 16 1 3 30N. AmericaCanada 32 35 30 30 5 11 6 8 157Mexico 1 0 1 1 0 1 0 0 4

Subtotal: 33 35 31 31 5 12 6 8 161OceaniaAustralia 1 3 3 2 3 0 10 8 30New Zealand 0 0 0 0 0 2 4 1 7

Subtotal: 1 3 3 1 3 2 14 9 37

Others++ 2 8 9 3 1 12 14 2 51

Unspecified 0 21 0 5 3 4 4 0 37

Total 242 412 468 531 727 855 952 687 4874

Table 4: Country of Export for Shipments of Carved Elephant IvoryLegally Imported into the USA, 1995–2002 (no. of shipments)

Source: TRAFFIC analysis of USFWS LEMIS data, March 2004.++ Other countries with recorded exports to the USA include Argentina, Colombia, Denmark, Finland, Greece, Grenada, Israel, Lebanon,

Liberia, Mauritius, Monaco, Palau, Peru, Portugal, Serbia, United Arab Emirates, Uruguay, and the Vatican.

TRAFFIC further found that, along with theheavy concentration of imports coming fromthe UK and other European countries clearlyshown in Table 4, the import trade in ivorycarvings is dominated by a small number ofcommercial art importers, antique dealers, andauction houses. For example, of the 583imports of carved ivory imported from the UKin 2002, 167 (29%) were imported by just twoNew York–based operations, which alsoimported shipments from Germany andSwitzerland in the same year. If a handful ofother entities identified in LEMIS records asantique dealers, commercial galleries, andmajor auction houses are included in theanalysis, roughly half of the imports camethrough fewer than 10 companies or dealers.This pattern suggests that, despite restrictionsplaced on the ivory trade by CITESrequirements and US domestic legislation,there continues to be an active commercialtrade in ivory certified by USFWS to beantique, and that trade is dominated by arelatively small number of players. A smallerproportion of the trade appeared to involveother small-scale commercial importers,individuals importing carved ivory for likelynon-commercial purposes, and some tradeamong museums and cultural institutions(TRAFFIC analysis of USFWS LEMIS data,March 2004).

Attempting to determine the value of the tradein elephant ivory carvings proved difficult.The value of individual shipments of carvingsfor different purposes varied so widely in thedata that there was no useful way to determinean average value for the commodity. Forexample, LEMIS records indicated that themost valuable pieces were often those beingexchanged by museums and therefore non-commercial in nature. Some individual piecesin the LEMIS records were valued at upwardsof USD1 million; however, because suchpieces frequently represented items beingtransferred between museums or culturalinstitutions, it appeared likely that they wereintended for public display or researchpurposes rather than commercial sale. At thesame time, individual shipments identified inthe data as imports for commercial purposesvaried from the hundreds to the tens-of-thousands of dollars, making it difficult toportray accurately an average value. In

addition, some shipments represented just oneivory carving, while others included multiplecarvings, without specifying the individualvalue of each piece. It therefore did not proveuseful to assign an overall or average value tothe trade (TRAFFIC analysis of USFWSLEMIS data, March 2004).

Trophies

The second category of legal elephant ivorytrade into the USA involves imports identifiedas sport-hunted trophies. As was noted in theprevious section, such African Elephanttrophies represent the only legal source of rawor unprocessed elephant ivory allowed into theUSA under current rules (USFWS, 1999).

Unfortunately, LEMIS data do not allow for aprecise determination of the number ofelephant tusks being imported under the trophycategory. In some cases, LEMIS records listthe importation of a single “trophy,” withoutspecifying whether that trophy might representone tusk or two. In other cases, LEMISrecords the importation of multiple items in thesame “trophy” shipment. For example, a 2001record showed an individual simultaneouslyimporting two shipments identified as “trophy”but consisting of a combined 31 items from ataxidermy business in Zimbabwe (TRAFFICanalysis of USFWS LEMIS data, March2004). Because it proved impossible given thenature of such records to isolate exactly howmany elephant tusks are included, Table 5shows only how many shipments identified astrophies were imported into the USA legallybetween 1995 and 2002. If each of these 1328trophy records included two tusks, theseshipments would represent as many as 2656raw tusks entering the USA.

As Table 5 indicates, the countries mostheavily involved in sending trophy shipmentsto the USA are Zimbabwe, Botswana, SouthAfrica, Tanzania, and Namibia. LEMISrecords show that these trophies are non-commercial in nature as required by CITESand US law, and are imported almostexclusively by individuals, with the exporterstypically listed in the records as being safaricompanies, hunting outfits, or taxidermyenterprises. Moreover, unlike the trade incarved ivory, these shipments mostly arrive inthe USA directly from the African elephant


range state listed as the country of origin aswell as the country of export. In a few cases,the ivory transited to the USA through a thirdcountry, either a neighboring range state oranother intermediary nation (examples in thedata included Canada, Mexico, Saudi Arabia,and Turkey). Such cases, however, were rare(TRAFFIC analysis of USFWS LEMIS data,March 2004).

Tusks

LEMIS records also showed 180 shipmentsidentified as elephant tusks legally importedinto the USA between 1995 and 2002, from 22exporting nations, with a cumulative total of383 tusks. Although LEMIS data do notclearly identify how many of these tusks areraw ivory and how many represent worked,pre-Convention ivory, a close examination ofthe countries of origin, the exporting countriesand individuals or enterprises involved, and theimporting parties, led to the conclusion thatthere are two primary patterns to the trade.The first group, which represents the majorityof the tusks legally imported, enters the USAfrom Africa, and likely comprises the tusks ofsport-hunted African Elephants that are enteredinto the LEMIS system under the productcategory of “tusk” rather than “trophy.”TRAFFIC surmised this because the pattern ofthe trade in these tusks is the same as that seenfor trophies (i.e., imported by individuals fromAfrican range states, with the exporters listedas safari companies, hunting outfits, or

taxidermy enterprises). Indeed, a cross-checkof trophy and tusk import records showed thata preponderance of both came from a fairlylimited set of the same African exporters(TRAFFIC analysis of USFWS LEMIS data,March 2004).

The second major group of ivory identified aselephant tusks comes from Europe andCanada, with a small number being importedfrom other sources. Because these shipmentswere cleared, TRAFFIC surmised that theimports likely represented worked antique orpre-Convention elephant tusks (TRAFFICanalysis of USFWS LEMIS data, March2004). Table 6 shows the number of tusksimported into the USA between 1995 and 2002broken down by the country of export.

Jewelry

Jewelry derived from African and AsianElephants is perhaps the most problematicivory product being imported to and exportedfrom the USA. As Table 1 showed, whereas71 shipments listed as ivory jewelry werecleared to enter the USA, 520 were refusedand the items either seized or abandoned.Furthermore, cleared shipments representedonly 256 items plus one 1997 shipment fromFrance identified in LEMIS records ascontaining 25 kg of jewelry for commercialpurposes. As with ivory carvings, the majorityof elephant ivory jewelry entered the USAlegally through Europe, and appeared to be a


Table 5: Country of Origin for Elephant Trophies Imported into the USAby Shipment, 1995–2002 (no. of shipments)

Exporter 1995 1996 1997 1998 1999 2000 2001 2002 Total

Zimbabwe 75 85 73 97 111 113 111 101 766Botswana 0 1 22 22 51 76 71 63 306South Africa 12 13 5 5 14 12 28 17 106Tanzania 6 8 11 10 11 9 16 10 81Namibia 2 11 8 4 3 11 3 3 45Cameroon 1 3 1 6 0 0 0 0 11Zambia 1 3 0 0 1 0 1 0 6Mozambique 0 1 0 0 0 0 0 0 1Kenya 1 0 0 0 0 0 0 0 1Other+ 1 0 1 0 0 2 1 0 5Total 99 125 121 144 191 223 231 194 1328

Source: TRAFFIC analysis of USFWS LEMIS data, March 2004.+ Other countries for which there were records of trophy imports included Costa Rica (1), and no specified origin (5).

mixture of pieces for commercial sale andpersonal effects being brought into the countryby individuals for noncommercial purposes(TRAFFIC analysis of USFWS LEMIS data,March 2004). Table 7 shows the countries ofexport for elephant ivory jewelry entering theUSA between 1995 and 2002.

Ivory Pieces and Piano Keys

TRAFFIC’s analysis of LEMIS data showedthe import of 166 shipments of ivory identifiedas consisting of elephant ivory piano keysbetween 1995 and 2002, with a total byquantity of more than 10 000 keys. However,the totals when measured by quantity in thedata may be misleading. In some cases,shipments in the records appeared to measurethe number of individual keys, often in lots of52 or 88 keys per shipment. In other cases,shipments of elephant ivory piano keys wereentered into the database with the quantitymeasured as one, which could represent asingle piano key or, more likely, one piano orone set of elephant ivory piano keys. Forexample, LEMIS data for 2000 (the peak year

for imports of piano keys in the data) showed21 cleared imports of elephant ivory into theUSA identified as piano keys. Of theserecords, 13 involved shipments of multipleelephant ivory keys, in lots ranging from 50 to104 keys. One shipment alone in that yearconsisted of the import of 1861 keys fromFrance, valued at USD65 744. Five LEMISrecords consisted of shipments reported in thedata with the quantity of one “key,” althoughthe values for those shipments ranged fromUSD3200 to 51 362. Given those valuations, itcould be assumed that the records indicated theimport of a piano with elephant ivory keys inunspecified quantities, rather than the importof individual keys. The final three records in2000 fell in the middle. One shipmentindicated the import of 12 “keys” fromGermany, with a valuation of USD26 487,which TRAFFIC surmised may haverepresented the import of 12 pianos or key sets(TRAFFIC analysis of USFWS LEMIS data,March 2004).

This pattern of varying quantities andvaluations for elephant ivory piano keys



+ In addition to 12 tusks, Zimbabwe exported one shipment identified as two kilograms of tusks to the USA in 2001.++ Other European nations exporting tusks to the USA included Denmark (2), Belgium (1), Germany (1), and Portugal (1).+++ Other nations exporting tusks to the USA included Palau (3), Hong Kong (2) Jordan (2), India (1), Ethiopia (1), Morocco (1), Russia (1), and

Singapore (one shipment listed as 18 kg).

Table 6: Country of Export for Elephant Tusks Imported into the USA byPiece, 1995–2002

Exporter 1995 1996 1997 1998 1999 2000 2001 2002 Total

AfricaZimbabwe 28 4 0 7 11 17 12+ 20 99Botswana 0 0 0 8 25 16 27 10 86Cameroon 35 0 0 26 2 0 0 0 63South Africa 0 0 2 6 7 2 11 7 35Namibia 4 2 0 0 8 4 0 2 20

Subtotal: 67 6 2 47 53 39 38 39 303EuropeUK 8 3 2 6 0 2 2 3 26Netherlands 0 0 3 0 1 14 0 0 18France 0 1 2 0 2 0 0 0 5Switzerland 1 0 0 0 3 0 0 0 4Other Eur.++ 2 1 0 1 1 0 0 0 5

Subtotal: 11 5 7 7 7 16 2 3 58N. AmericaCanada 0 1 0 0 1 4 2 2 10Others+++ 0 6 3 2 0 0 0 0 12Total 78 18 12 57 61 59 54 44 383

repeated itself throughout the data set from1995 to 2002. Therefore, the figure of 10 023“keys” identified in LEMIS records should beconsidered a minimum figure. Assuming thatsome of the imports were measured in theform of pianos with multiple keys or key setsas indicated in the example above, the numberof individual keys imported may have beenmuch higher. However, it proved impossible tomeasure with any accuracy the true number ofkeys being imported, or the quantity ofelephant ivory such imports represented(TRAFFIC analysis of USFWS LEMIS data,March 2004).

Similarly, TRAFFIC had difficulty identifyingthe exact nature of elephant ivory “pieces”

being imported into the USA between 1995and 2002. Overall, TRAFFIC found records of128 cleared shipments of ivory pieces into theUSA during this period, with a total quantityof 1798 pieces of ivory. However, the vastmajority of these pieces (1025) entered theUSA in 2000, and it proved difficult given thelot sizes and valuations reported in the data todiscern whether the ivory objects beingimported were carvings, piano keys, or otheritems. Given the lack of specificity in theavailable information, TRAFFIC did not try tosurmise the exact nature of each shipmentrepresented (TRAFFIC analysis of USFWSLEMIS data, March 2004).


Table 7: Country of Export for Elephant Ivory Jewelry Imported into theUSA by Piece, 1995–2002 (no. of items)

Exporter 1995 1996 1997 1998 1999 2000 2001 2002 Total

EuropeUK 0 7 4 0 6 12 2 2 33Italy 0 0 0 22 0 0 0 0 22Germany 0 0 0 0 13 0 0 0 13Belgium 0 11 0 0 0 0 0 0 11Switzerland 0 0 0 7 0 2 0 1 10Netherlands 0 0 8 0 1 0 0 0 9France 0 4 1+ 0 1 0 0 0 5Austria 0 0 0 0 0 4 0 0 4Sweden 4 0 0 0 0 0 0 0 4Ireland 0 0 1 0 0 0 0 0 1

Subtotal: 4 22 14+ 29 21 18 2 3 112AfricaSouth Africa 7 0 1 1 0 12 23 0 44Zimbabwe 4 1 0 0 0 0 0 0 5Cameroon 1 0 0 0 0 0 0 0 1

Subtotal: 12 1 1 1 0 12 23 0 50AsiaHong Kong 0 0 17 0 0 0 0 0 17Thailand 0 6 2 0 0 0 0 0 8Japan 0 1 0 0 0 0 0 1 2Taiwan 0 0 1 0 0 0 0 0 1


Subtotal: 0 10 9 1 0 1 1 2 24Oceania 0 0 0 0 0 0 42 0 42Unspecified 0 0 3 0 0 0 0 0 3Total 13 40 46+ 31 21 31 68 6 256+

Source: TRAFFIC analysis of USFWS LEMIS data, March 2004.+ France exported a shipment recorded as 25 kg of ivory jewelry in 1997.

Ivory Exports and Re-exportsIn addition to importing elephant ivory in thesevarious forms, the USA is also an exporter (orre-exporter) of ivory for both commercial andnoncommercial purposes, with the majority ofthe trade going to Europe. As with imports,carved ivory is the dominant product in trade,and the UK is the principal destination market.Overall, TRAFFIC identified 1055 records ofivory carvings involving approximately 8600pieces that were exported legally from the USAbetween 1995 and 2002 to at least 43 countries

around the world (some shipments did notspecify the country to which the ivory wasexported) (TRAFFIC analysis of USFWSLEMIS records, March 2004). Table 8 showsmajor destination countries for ivory carvingsexported from the USA between 1995 and 2002.

As with the import trade, the export trade inelephant ivory involves a mix of players.Some of the trade appears to benoncommercial in nature, with exportersincluding individuals shipping ivory forpersonal purposes as well as public and private


Table 8: Destination Countries for Carved Elephant Ivory Exported fromthe USA by Piece, 1995–2002 (no. of items)

Source: TRAFFIC analysis of USFWS LEMIS data, March 2004.+ Other countries in Europe that imported carved ivory from the USA included Bulgaria (2), Cyprus (1), Denmark (6), Finland (1), Greece (8),

Ireland (1), Monaco (1), Norway (2), Portugal (14), Sweden (1), Turkey (29), and the Vatican (2).++ Other Asian nations that imported carved ivory from the USA included China (8), Singapore (5), and Mongolia (3).+++ Other nations around the world that imported carved ivory from the USA included Brazil (130), Egypt (1), French Guiana (3), Israel (4),

Lebanon (1), Qatar (68), Reunion (2), Saudi Arabia (2), South Africa (6), Zimbabwe (1), and Various (i.e., unspecified) (3).

Importer 1995 1996 1997 1998 1999 2000 2001 2002 Total

EuropeUK 567 591 874 1051 757 529 331 432 5132Germany 18 8 75 3 1 55 128 65 353Netherlands 25 15 24 9 81 77 20 47 298Switzerland 3 19 10 7 51 47 8 76 221Belgium 0 2 56 40 67 21 2 4 192Austria 127 0 2 9 2 0 1 0 141France 2 31 26 4 7 27 2 17 116Russia 0 0 3 0 42 13 7 0 65Italy 2 4 3 1 11 4 2 18 45Spain 0 0 0 0 2 10 15 6 33Other Eur.+ 1 0 7 7 1 10 34 8 68

Subtotal: 745 670 1080 1131 1022 793 550 673 6664AsiaJapan 84 199 38 169 83 164 138 80 955Hong Kong 3 3 8 14 0 30 24 0 82Taiwan 13 3 29 9 0 2 4 1 61Other Asia++ 0 1 1 0 0 5 1 0 16


Subtotal: 59 75 69 23 31 75 12 3 347OceaniaAustralia 27 3 0 4 1 2 30 36 103New Zealand 0 19 0 0 7 2 0 0 28

Subtotal: 27 22 0 4 8 4 30 36 131Other+++ 2 132 5 3 1 6 2 70 221Unspecified 0 0 6 0 105 0 0 0 111Total 933 1105 1236 1353 1250 1079 761 863 8588

museums, cultural institutions, and othernonprofit organizations exchanging carvedivory pieces. The repeated involvement ofsuch museums and similar institutions in thedata indicates that some of the re-export trademay involve the movement of travelingexhibits of antiques for display or researchpurposes. Such cases further indicate thatthere may be some overlap in the data betweennoncommercial imports and re-exports, withthe same ivory pieces entering the country forexhibit or other reasons and then beingsubsequently re-exported either directly backto the country from which they came or to athird country (TRAFFIC analysis of USFWSLEMIS data, March 2004).

However, it should also be noted that,particularly concerning the trade with Europe,a number of the exporters were the sameimport/export businesses, antique dealers, andauction houses that appeared repeatedly in theimport records as bringing in carved ivory forcommercial purposes. This suggests that,although the volume of imports exceeds thevolume of exports, the commercial trans-Atlantic trade in carved ivory cleared byUSFWS as being antique runs both ways. Itshould be further noted that a significantpercentage of the carved ivory exports to Asiaand Australia appeared to be commercial(TRAFFIC analysis of USFWS LEMIS data,March 2004).

Along with carved ivory, the USA exportedsmall quantities of elephant ivory tusks andjewelry between 1995 and 2002. As with ivorycarvings, the primary destinations for theseproducts were in Europe; however, the smallnumber of export records (a total of sixshipments of tusks and 10 of jewelry) madeany meaningful trade pattern difficult todiscern. TRAFFIC identified the small numberof exports as likely being primarily personaleffects or trade for other noncommercialpurposes. The primary focus of the US exporttrade is ivory carvings (TRAFFIC analysis ofUSFWS LEMIS data, March 2004).

The Domestic Market forWorked IvoryUnfortunately, the extent of the US domesticmarket for ivory cannot be gauged with anyprecision. Elephant ivory is available at the

retail level in many states and cities, and canalso be readily purchased from domesticsources over the Internet. However, majorgaps remain in our knowledge about the fullextent of the market, for three primary reasons.

First, the USA’s focus on monitoring andpolicing the ivory trade concentrates on federalefforts at the borders. Under the USConstitution, the federal government haslimited authority to regulate or prohibitintrastate commerce, and there is no federaldatabase comparable to LEMIS that tracks thesale or trade of ivory once it enters the USA.USFWS and other agencies therefore do notknow how much ivory is actually being tradedin US markets. Furthermore, according to itssubmission to the CITES Secretariat inresponse to CITES Conf. Res. 10.10 (Rev.) andDecision 12.39, USFWS is not aware of anyUS state that has assessed or quantified ivorymarkets within its jurisdiction (Peter Thomas,Chief, Division of Management Authority,USFWS, in litt. to Willem Wijnstekers, CITESSecretariat, August 2003).

Second, as noted in the last section, there are23 US states that have either enacted legislationspecific to trade in elephant ivory and otherproducts or have incorporated federalthreatened and endangered species (such as theAfrican and Asian Elephants) into theirthreatened and endangered species lists (PeterThomas, Chief, Division of ManagementAuthority, USFWS, in litt. to WillemWijnstekers, CITES Secretariat, August 2003).That leaves 27 states without specificprovisions or permit requirements related to thetrade in elephant ivory, making it very difficultto discern the extent of trade in those states.

Third, the advent of Internet-based trade ofelephant and other ivory has in recent yearsadded a new dimension to the trade in thatvirtually anyone with a computer can now buyand sell ivory largely anonymously fromanywhere in the country (or, as will be seenbelow, outside the USA), and deliver it throughthe postal service or a shipping company. Thelargest Internet auction site, eBay, has a policythat states:

This area is complex, and sellers shouldconsult with the U.S. Fish and WildlifeService and their state wildlife regulatoryagency to ensure that the particular item


involved may lawfully be sold. Generally,ivory from African elephants may be soldwithin the United States so long as it waslawfully imported into the United States.Wooly mammoth ivory may be sold inside oroutside the United States. Hippo ivory maybe sold within the United States, but mayonly be imported/exported in compliancewith CITES (eBay, September 2004).

TRAFFIC monitored eBay from February toMay 2004 to try to determine how muchelephant ivory is available in an average week.The specific purpose of the exercise was toestablish the quantities, types of items, prices,and sources of elephant ivory readilyaccessible to the public through this majorInternet auction site. After an initial search todetermine which keywords would provide thebest data set, TRAFFIC conducted regularsearches using the terms “ivory carving”,“ivory carvings”, “ivory jewelry”, ivory piece”,“ivory pieces”, “ivory tusk”, “ivory tusks”, and“elephant ivory”. To allow turnover of items,TRAFFIC conducted these searches on asingle day each week. Table 9 shows theresults of TRAFFIC’s searches, and the dateson which they were conducted. Some ofcategories and keywords used are combined inthe table (i.e., ivory carving and carvings, ivorypiece and pieces, ivory tusk and tusks).

As the table shows, in most weeks during thesurvey period more than 1000 items advertisedas being elephant ivory in one of these majorforms was available through eBay.TRAFFIC’s periodic review of the site duringthe survey period indicated that some of thetrade occurs within the USA, and may be legal.However, TRAFFIC also found regularshipments of elephant ivory carvings andjewelry being sold over eBay to US customersfrom vendors based in China undercircumstances that may be illegal.

Though some of the elephant ivory offered tothe US market from China came from sellerslisted as being located in Shanghai, the mostsignificant source of elephant tusk ivoryentering the USA from China via eBayinvolved vendors in Guangzhou, a city insouthern China near Hong Kong. TRAFFICdetermined that the two Guangzhou sites wererun by the same operator(s), based on the factthat some items advertised referred shoppers tothe other “store”, both vendors having beenregistered in Hong Kong in the same year, thesimilarity of the site graphics and layout, theirnearly identical product lines and pricing, thesimilarity of product descriptions and shippingdetails, and other such factors.

The presence of such Internet operationsselling ivory carvings and jewelry advertised as


Date “Ivory “Ivory “Ivory “Ivory “Elephant Carving(s)” Jewelry” Piece(s)” Tusk(s)” Ivory” Total

2/5/04 228 70 127 266 308 9992/13/04 253 67 119 297 371 11072/20/04 263 64 109 306 318 10602/27/04 280 83 140 276 356 11353/5/04 259 75 119 261 314 10283/12/04 284 97 145 281 341 11483/19/04 275 79 151 269 330 11043/26/04 334 97 195 340 374 13404/5/04 243 70 122 200 296 9314/9/04 254 69 145 262 338 10684/19/04 227 67 118 229 286 9274/23/04 271 76 131 230 301 10094/30/04 291 114 127 226 294 10525/14/04 299 94 110 269 316 1088

Table 9: Ivory for Sale on eBay, February–May 2004

Source: Pers. comm., T. Leonard, TRAFFIC North America, June 4, 2004.

being derived from elephant tusks in China isof particular concern. In a 2002 study onChina’s management and trade in elephantsand elephant products, TRAFFIC East Asianoted that with the state-run Chinese ivory-carving industry in decline following theCITES Appendix I listing of African Elephantsin 1989, it is likely that much of the industry isnow run by private, and illegal, familyoperations. That study also found that themain buyers of the ivory are believed to beChinese nationals, with the cities of Shanghai,Guangzhou, and Beijing the main centers ofivory consumption (O’Connell-Rodwell andParry-Jones, 2002).

A survey conducted by Stiles and Martin(2003) came to similar conclusions. Thatstudy found that stockpiles of elephant ivoryheld by private and government businesseslisted in a 2002 survey by China’s governmentwere so incomplete that no estimate of thenational stockpile could be made. However, itcited an estimate by the China CITESManagement Authority (CMA) that between1991 and 2002 some 110 mt of elephant ivorywent missing from the national ivory stockpile,suggesting to the CMA that illegal selling hastaken place. The survey further found that theivory being processed in China in privateworkshops today must be for the most partsmuggled African Elephant ivory, based onseizure records and the fact that neither privateindividuals, companies, nor the governmentcan import legal ivory.

The precise status of the ivory-carving industryremaining in cities such as Shanghai,Guangzhou and Beijing is not known, as muchof the information is anecdotal. Stiles andMartin (2003) estimated that there may be nomore than 30 ivory carvers working inGuangzhou, maybe one in Shanghai, and aboutfive to 10 in Beijing. That study alsoestimated that there were perhaps 10 largerivory workshops still operating in China in2003, with fewer than 200 craftsmen, includingsmall family workshops. In 2000, workers atthe largest ivory-carving factory in Guangzhoureported to TRAFFIC investigators thatapproximately 30% of their production wassold internationally (O’Connell-Rodwell andParry-Jones, 2002; Stiles and Martin, 2003).Stiles and Martin (2003) also found 3855 ivory

elephant ivory items for sale at the retail levelin Guangzhou, and 2045 items in Shanghai.

Research for this report showed that as of early2004, ivory from sellers located in Shanghaiand especially Guangzhou was also enteringthe USA via eBay. In reviewing eBay auctionsconducted between January 1, 2004 and April15, 2004, TRAFFIC found at least 46 sales ofcarvings and jewelry items advertised aselephant tusk ivory from the Guangzhouvendors alone to buyers located in the USA, aswell as numerous sales to buyers in othercountries including the UK, France, Canada,Germany, the Netherlands, Sweden, andAustralia. TRAFFIC also documented smallernumbers of sales from vendors listed as beinglocated in Shanghai. Furthermore, a sellerprovided TRAFFIC with the address of a retailstore in Guangzhou should we prefer topurchase ivory in person, rather than throughthe Internet.

TRAFFIC suspects that the number of actualrecent sales of elephant ivory from these sitesto buyers in the USA may be higher, for tworeasons. First, our review of eBay recordsshowed only those sales for which the buyersin the USA posted feedback confirmingdelivery of the ivory items purchased. It ispossible that there were other auctions duringthe period in question for which no feedbackwas posted, and those would not show up inthe overall total. Second, beginning in March2004, many of the auctions involving the twoprimary Guangzhou vendors were taken“private”, which meant that TRAFFIC couldnot ascertain the nature of the item beingpurchased or the price that was paid for it.Because of the large number of itemsadvertised as being elephant tusk ivory beingoffered by these vendors, TRAFFIC surmisesthat some percentage of these private auctionsmay well have involved elephant tusk ivory;however, because this could not be confirmedsuch auctions were not included in the totals.

TRAFFIC took several steps to try todetermine the nature of this apparent pipelineof elephant ivory into the USA. As an initialstep, we contacted two vendors in China usingeBay—one in Shanghai and the other inGuangzhou—posing as a potential buyer to askwhether the sellers shipped to the USA, andwhat paperwork or permit we would need to


import one of their ivory pieces. The firstvendor contacted replied simply that becausethey are selling antique ivory carving ratherthan “modern” ones, there would be noproblem sending ivory from China, and indeedthey had sent carvings to the USA beforewithout any problems. The second vendorresponded that they always say the shipment is“bone carving” when it is sent to thecustomers, and offered to refund the money ifwe did not receive the item.

We then contacted buyers in the USA to learnwhat we could about whether the ivory wasgenuine and whether they thought permitswere necessary for its importation. Againposing as potentially interested buyersinquiring about the experience of others indoing business with the China-based sites,TRAFFIC sent e-mails to 18 US buyers ofitems advertised as elephant tusk ivory whohad purchased their items in March or earlyApril. Although most either did not respond orresponded only in generalities confirming thatthey had satisfactorily received the ivory itemthey had bid on, several replies proved useful.

For example, TRAFFIC learned from severalbuyers that the time between purchase anddelivery is two to three weeks, and confirmedthat the ivory pieces in question are sent by anexpress delivery service. Three buyers alsoconfirmed that they did not believe that theyneeded to obtain any permits for the importsand did not do so. In two of these cases, thebuyers indicated their belief that because theywere buying items they believed to beantiques, no permits were necessary. Onebuyer indicated his belief that sale of ivoryobtained after the late 1960s or early 1970swould be illegal, but that these sites werelegitimate sellers. The buyer also warned us tomake sure that the item being purchased wasreal ivory instead of bone, and indicated thathe was able to distinguish between the two andthe items he purchased were genuine. Yetanother buyer noted that the item he originallybid on turned out not to be available, so he wassent a similar piece instead.

TRAFFIC noted two other interesting patternsin this segment of the trade in elephant ivoryfrom China. First, in reviewing the auctionsfor the items purchased by US buyers,TRAFFIC found that of the 46 confirmed

purchases between January and April, only afew involved competitive bidding. Most of thepurchases involved either only one bid beingsubmitted, or the item was purchased at theadvertised “Buy It Now” price. This patternheld for many of the buyers identified asresiding in Europe and elsewhere as well,suggesting to TRAFFIC that these Guangzhou-based vendors using eBay are acting almost asa global retail ivory outlet, with littlecompetition for the individual items sold.

Second, while it was impossible for TRAFFICto view any of the items purchased firsthand,the prices and types of ivory being purchasedcall into question whether the ivory is actuallyantique. For example, TRAFFIC found thativory jewelry in the form of finger rings,bangles and brooches was being purchased forprices ranging from USD4.99 to 24.99. Pricesfor ivory netsuke carvings purchased fromthese sites ranged from USD19.99 to 99.00,with most at the lower end of that range.Furthermore, TRAFFIC found that the supplyof similar items being advertised wasconsiderable. Once an item was sold, it wastypically replaced on the seller’s Internet storewith an item very similar in carving and price.While not definitive, this pattern suggested toTRAFFIC that these items represent fairly low-end merchandise that is easily obtainable,rather than unique antique pieces.

Finally, TRAFFIC attempted to ascertainwhether any of the ivory purchased throughthese outlets was being resold in the domesticUS market. To do this, TRAFFIC examinedthe items offered for sale by those peopleconfirmed to have bought ivory from thevendors utilizing eBay, and also reviewed thefeedback comments these buyers had receivedon past sales to determine whether any of theitems they sold consisted of ivory. TRAFFICfound that the majority of the buyers of ivorywere just that, individual buyers, rather thanpeople engaged in regular buying and sellingactivities. For those buyers who had beenselling items as well, TRAFFIC was unable tofind any re-sale of the ivory objects in theUSA. However, TRAFFIC did find one casein the UK of an individual who regularlypurchased items advertised as elephant tuskivory from one of the Guangzhou vendors.Viewing feedback from that individual’s itemssold, TRAFFIC discovered two instances of


items sold to other people in the UK as“mammoth ivory” that bore a strong semblanceto items being sold from China as “elephanttusk ivory.”

Unfortunately, there were limitations to howmuch TRAFFIC was able to learn about theextent of this trade. For example, becausefeedback comments linked to specific itemssold are only available on eBay for a couple ofmonths, TRAFFIC was unable to determinehow many ivory items entered the USAthrough this route over a longer time period.Also, as noted above, the number of auctionsconducted privately restricted TRAFFIC’sability to get a comprehensive count on howmany ivory imports there may have beenduring the period examined. Furthermore, thelargely anonymous nature of the eBay systemmakes it difficult to determine whether thosebuying the ivory lived in states with their ownpermit requirements for such trade. Forexample, under the eBay system, buyers’locations remain anonymous unless they arealso selling items through the system, inwhich case it is possible to determine thestates in which they live. TRAFFIC’s reviewof those buying ivory from China showed thatmost were not also sellers, making itimpossible to determine their location beyondthe fact that they were in the USA. Therefore,while TRAFFIC concluded that there is anactive market for elephant ivory from theseforeign-based sources as well as domesticones, not enough information was available todetermine the specific location of the buyersin the USA.

The Domestic Market for Raw IvoryTRAFFIC also conducted an Internet search toestablish whether there remains a trade in rawivory in the USA, and whether there is still adomestic carving industry. In its 2003response to the CITES Secretariat to satisfythe requirements of Resolution Conf. 10.10(Rev. CoP12) and Decision 12.39, USFWSnoted its awareness that there may be a smalland probably declining market for raw ivoryfrom legal imports before the 1989 USprohibition on the domestic sale of suchelephant ivory elephants (Peter Thomas,Chief, Division of Management Authority,

USFWS, in litt. to Willem Wijnstekers, CITESSecretariat, August 2003). However, as withthe domestic trade in worked elephant ivory,the full extent of such trade is difficult todetermine, as the ivory was not tracked once itentered the country.

TRAFFIC was able to find some examples ofthe carving and sale of raw elephant ivorybeing conducted as of Spring 2004. Forexample, TRAFFIC identified two operationsthat were advertising the sale of raw elephantivory pieces, as well as custom-carved gungrips. One of these operations, based inMississippi, advertised a variety of rawelephant tusk solids in various sizes sellingfor USD250 to 600 each (also available atUSD150/pound); raw tusk hollows in varioussizes selling for USD80 to 650 each (alsoavailable at USD145/pound); and rawelephant tusk tips selling for USD250 475each. The site advertised raw elephant ivoryslabs ranging from three to six inches inlength and at varying weights and thicknessesfor USD25 to 150 per slab (or USD50 to 300per pair of slabs). Also advertised werecustom-carved elephant ivory pistol gripsselling for USD200 to over 500 per pair,depending on the model of the gun. Beyondselling raw ivory for customers to fit customgrips themselves, the site also offerscustomers the opportunity to send the gun tothe operator of the Web site and have thegrips custom fitted.

Another internet site that also has a retailoutlet in Washington State offered a variety ofraw elephant ivory products ranging fromwhole tusks to roughed “blocks,” tusk hollows,cross-cut sections, scraps, and slabs at a wideranged of prices measured by piece, linealinch, and weight. Advertised purposes forthese various raw elephant ivory productsincluded knife handles, gun grips, pool cuebutts, joints, duck calls, pen blanks, and otheritems. The site also offered three sets of fulltusks for sale, ranging from a matched pairfour inches in diameter and 46 inches in lengthfor USD3700 to a matched pair 5 3/4 inches indiameter and 67 inches in length for USD8745.Finally, the site also offered raw elephant ivoryslabs and custom-made pistol, rifle/shotgun,and knife grips and grip cap pieces at a varietyof prices.


TRAFFIC found other examples of companiesand individuals offering to purchase rawelephant tusks for both commercial andpersonal purposes; however, TRAFFIC couldreach no broad conclusions about the fullextent of such domestic trade. As noted byUSFWS, any legal commercial trade in suchraw elephant ivory would have to derive fromtusks imported into the USA before the 1989trade ban under the AECA. Sport-hunted ivoryimported legally under CITES, the ESA, andthe AECA since 1989 cannot be carved andsold commercially, although it can be carvedfor personal use (Peter Thomas, Chief,Division of Management Authority, USFWS,in litt. to Willem Wijnstekers, CITESSecretariat, August 2003). Unfortunately,because the amount of legally imported, pre-1989 African Elephant tusks that may be incirculation domestically is unknown, and nostate has conducted a survey of its ivorymarket or the potential number of remainingivory carvers, it is impossible to determine thefull extent of this trade.

Illegal TradeA review of what is documented about theUSA’s involvement in the global illegal ivorytrade reveals both negative and positive aspectsregarding the extent of such trade and theeffectiveness of country’s wildlife tradeenforcement system. On the negative side,according to data from the Elephant TradeInformation System (ETIS),3 from 1989 to2001 (inclusive), the USA reported nearly fivetimes as many ivory seizures (2628) as did anyother country. Namibia was second with 545seizures. The global total recorded in ETISwas 7817 seizures as of August 2002, meaningthat the USA accounted for slightly more than33% of the world’s seizures during the period,with 161 nations represented in the overalldata. Although the individual seizures tendedto be small in terms of the weight of ivoryrepresented, cumulatively they accounted forsome 4211 kg, a substantial volume of ivory(Milliken et al., 2002).

On the positive side, an analysis of the USA’srecord prepared through ETIS for CITES

CoP12 in 2002 noted that the USA has thestrongest law enforcement ratio of any countrybetween the number of seizures made andreported by a particular country, and thenumber of seizures made elsewhere but whichreportedly involve the same country. Theanalysis reasons that a relatively large volumeof ivory moving into, through, and out of acountry provides numerous opportunities forseizures, and that countries with well-developed law enforcement capabilities arelikely to demonstrate a fairly consistent recordof in-country seizures. By this measure, theUSA’s high ratio would indicate a relativelyeffective law enforcement program, with theprimary challenge being the introduction oflarge numbers of ivory curios by US citizensreturning from overseas (Milliken et al., 2002).USFWS made a similar argument in itsresponse to the CITES Secretariat regardingCITES Conf. Res. 10.10 (Rev.), in which itnoted that 2002 law enforcement recordsindicate that 22% of the imported ivoryinspected was intercepted and confiscated inthat year. USFWS also noted the continuingchallenge presented by US tourists purchasingivory abroad and attempting to carry it into thecountry (Peter Thomas, Chief, Division ofManagement Authority, USFWS, in litt. toWillem Wijnstekers, CITES Secretariat,August 2003).

For this report, TRAFFIC conducted its ownanalysis of USFWS import and export data totry to determine the extent to which the touristtrade alone accounts for elephant ivoryentering the USA illegally. TRAFFIC alsoexplored whether there are other clear patternsor routes for the illegal trade. Thisexamination revealed that unlike the legaltrade, the illegal trade in ivory is not as heavilyconcentrated among a few source nations ormajor players, although a few nations showmore frequent cases of ivory shipments beingintercepted. Instead, between 1995 and 2002,shipments of illegal ivory in various quantitieswere intercepted and seized from more than 80countries spread across every continent exceptAntarctica. Table 10 shows the types andoverall quantities of illegal ivory that were


3 ETIS, which is managed by TRAFFIC, is a comprehensive international monitoring system operating under the auspicesof CITES to track the illegal trade in elephant products, particularly ivory. ETIS was mandated by the CITES Parties inResolution Conf. 10.10 (Rev.) (Milliken et al. 2002).

recorded as seized by US authorities for theyears 1995 to 2002.

As with legal imports, TRAFFIC examined thesource of these illegal shipments of ivory bycommodity.

Carved Ivory

As Table 10 shows, LEMIS records indicatethat more than 4000 carved ivory items wereseized between 1995 and 2002. LEMISrecords include interceptions of carved ivoryfrom 73 nations all over the world, indicatingthe truly global nature of the illegal ivorytrade. For example, illegal ivory carvingsintercepted from African nations involvedimports from Angola, Burundi, Cameroon, theCentral African Republic, Congo, Côted’Ivoire, the Democratic Republic of Congo,Egypt, Ethiopia, Gambia, Ghana, Guinea,Kenya, Liberia, Malawi, Morocco,Mozambique, Nigeria, Senegal, South Africa,Sudan, Tanzania, Togo, Zambia, andZimbabwe. Countries in the Middle East fromwhich carved ivory imports were seizedincluded Iran, Israel, Kuwait, Syria, and theUnited Arab Emirates. Illegal carved ivoryentering the USA from the Asian and Pacificregion included imports from Australia,Cambodia, China, Hong Kong, India,Indonesia, Japan, Lao PDR, Malaysia,Mongolia, Pakistan, the Philippines, Singapore,the Republic of Korea, Taiwan, Thailand,Uzbekistan, and Viet Nam. European nationsfrom which carved ivory was seized include

Austria, Belgium, Bulgaria, Denmark, France,Germany, Greece, Ireland, Italy, Luxembourg,Monaco, the Netherlands, Portugal, Russia,Spain, Sweden, Switzerland, and the UK.Finally, illegal ivory carvings were interceptedand seized from North, South, and CentralAmerican nations, as well as from Caribbeannations, including Argentina, Canada, Chile,Costa Rica, the Dominican Republic, Mexico,and Peru (TRAFFIC analysis of USFWSLEMIS data, March 2004).

LEMIS data indicate that much of this illegalivory entered the USA carried by individuals insmall quantities, consistent with the findings ofETIS and USFWS that it likely representedtourist curios or souvenirs. However, otherrecords indicate that at least some of the ivoryseized was commercial in nature, and wassometimes imported by the same antiquedealers, auction houses, and other businessesthat regularly recorded legal ivory imports.TRAFFIC found instances in every one of theyears between 1995 and 2002 in which suchshipments were seized, abandoned, orrepatriated scattered in the import records. Forexample, one 1996 case involved the seizure of12 carvings from a company that importedsuch ivory carvings into the USA regularlyfrom the UK. In another 2001 instance, one ofthe two largest importers of ivory carvingsbetween 1995 and 2002 had 112 carvingsrefused entry from the UK.

One explanation for such seizures may lie inthe conflicting definitions of “antique” used by


Item 1995 1996 1997 1998 1999 2000 2001 2002 Total

Carved Ivory 385 377 243 609 516 320 735+ 849 4034+540 gm 540 g

Ivory Jewelry 420 767 312 367 515 221 224 71 2897

Tusks 30 37+ 41 26 39 24 22+ 60+ 279+~8 kg ~1 kg ~1.2 kg ~10.2 kg

Ivory Pieces 0 0 9 7 23+ 14 405 128 586+495 gm 495 g

Trophies 0 2 3 0 3 1 1 0 10

Piano Keys 0 0 0 146 272 0 103 465 gm 521+ 465 g

Total 835 1183+ 608 1155 1368+ 580 1490+ 1108+ 8327+~8 kg 495 g ~2.5 kg ~1.7 kg 11.7 kg

Table 10: Elephant Ivory Seized by Item, 1995–2002


the USA and the European Union (EU).Whereas the USA defines antique as anywildlife product (such as an ivory carving) thatis 100 years or older, the EU defines antique asany item that is 50 years or older. Because ofthis conflicting definition, an item that may bedeclared as an antique in the EU andsubsequently exported to the USA may beseized upon import because the item does notmeet the definition of antique as required bythe USA (Kevin Adams, Chief, Office of LawEnforcement, USFWS, in litt. to Craig Hoover,TRAFFIC North America, August 2004).

Although TRAFFIC did not attempt to sum upevery one of these instances, the repeatingpattern of importers identified as antiquedealers, galleries, auction houses, and othercommercial entities having some importscleared while others are seized indicates thatthe tourist trade is not the only part of UScommerce in ivory carvings that has provedtroublesome.

Ivory Jewelry

Seizures of elephant ivory jewelry showed asimilarly broad pattern, and one that is evenmore troubling. As Table 7 noted, between1995 and 2002, the USA permitted the legalimportation of only 256 items of ivory jewelry,plus 25 kg of jewelry, in 71 shipments.Conversely, during the same period USauthorities confiscated 520 shipments totalingalmost 2000 jewelry items, indicating a ratio ofapproximately 10 seizures for every legalimport (TRAFFIC analysis of USFWS LEMISrecords, March 2004).

LEMIS records show that these confiscatedshipments entered the USA from 61 countries.As with carved ivory, illegal imports of ivoryjewelry come from multiple sources. Most ofthe shipments involved small individualquantities of jewelry with fairly low valuations,and the majority came from Africa, suggestingthat the pattern of this trade is indeed largelydriven by individuals importing curios.Interceptions of illegal jewelry directly fromAfrica included seizures of imports fromAngola, Benin, Cameroon, Central AfricanRepublic, Congo, the Democratic Republic ofCongo, Côte d’Ivoire, Egypt, Ethiopia, Ghana,Guinea, Kenya, Malawi, Mali, Namibia,Nigeria, Rwanda, Senegal, Sierra Leone, SouthAfrica, Sudan, Tanzania, Togo, Uganda,Zambia, and Zimbabwe. Asian and Pacificcountries or administrative regions from whichillegal ivory jewelry was intercepted includedAustralia, China, French Polynesia, HongKong, Indonesia, Japan, Malaysia, NorthKorea, the Philippines, Singapore, the Republicof Korea, Taiwan, Thailand, and Viet Nam.European countries involved in the tradeincluded Belgium, Bulgaria, France, Germany,Italy, the Netherlands, Poland, Spain, Sweden,Switzerland, the UK, and Yugoslavia. Nationsin the Middle East from which shipments wereseized included Lebanon, Saudi Arabia, Syria,and the United Arab Emirates. Finally,shipments were intercepted from Canada,Jamaica, and Mexico in North America and theCaribbean (TRAFFIC analysis of USFWSLEMIS records, March 2004).

Unlike the illegal trade in carved ivory,however, for which the number of intercepteditems was broadly distributed around theglobe, interceptions of jewelry were moreconcentrated among a specific subset ofcountries. One was Nigeria, which accountedfor 55 intercepted shipments involving 349jewelry items, or more than one-tenth (12%) ofthe overall total. Other countries that figuredprominently in the LEMIS records of ivoryseizures included South Africa, Zimbabwe, andThailand.

Trophies and Tusks

LEMIS records for the survey period showedonly 10 records of trophies, presumably in theform of tusks, being refused clearance into theUSA between 1995 and 2002. Compared to


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the 1328 elephant trophy shipments cleared,this indicated that illegal trade in the form ofsport-hunted trophies does not appear to be amajor concern regarding illegal internationaltrade, at least as far as this aspect of US ivoryimports is concerned (TRAFFIC analysis ofUSFWS LEMIS data, March 2004).

More frequent were seizures listed in the dataas tusks, or sometimes “teeth,” from countriesaround the world (TRAFFIC assumed thatelephant teeth listed in LEMIS referred totusks). TRAFFIC found records of 279 tusksthat were seized or abandoned after beingintercepted entering the USA, along with theseizure of approximately 10 kg of ivory enteredinto the database as being elephant tusk. Theseseizures involved ivory entering the USA from39 countries in Africa, Asia and the Pacific,Europe, the Middle East, and North, Centraland South America (TRAFFIC analysis ofUSFWS LEMIS data, March 2004).

Nations in Africa or the Middle East fromwhich such tusks entering the USA wereconfiscated included Botswana, theDemocratic Republic of Congo, Egypt,Cameroon, Côte d’Ivoire, Ethiopia, Gabon,Ghana, Kenya, Morocco, Nigeria, SaudiArabia, South Africa, Sudan, Tanzania, Togo,and Zimbabwe. Illegal tusks were seized orabandoned after arriving from Asian andPacific nations, including Australia, Cambodia,China, India, Indonesia, Japan, Lao PDR,Thailand, and Viet Nam. European nationsincluded in the seizure records were Belgium,France, Germany, Poland, Spain, Switzerland,and the UK. Finally, in the WesternHemisphere, illegal tusks were interceptedentering the USA from Argentina, Brazil, ElSalvador, and Mexico (TRAFFIC analysis ofUSFWS LEMIS data, March 2004).

Unfortunately, LEMIS records did not specifywhether the ivory involved in these seizureswas raw or worked. It could be surmised fromthe available data that it was likely acombination of both, based on the countries oforigin and the pattern of legal trade in tusks.However, the precise proportion of the ivorythat was raw or worked could not beascertained. The pattern of the trade appearedto be similar to that for illegal trade in ivoryjewelry, in that those listed as importing the

ivory were overwhelmingly individuals,bringing in items listed as tusks in quantities ofone or two items (TRAFFIC analysis ofUSFWS LEMIS data, March 2004).

Smuggling

The above instances of elephant ivory enteringthe USA illegally illustrate two forms of theillicit trade—individuals bringing in items insmall quantities as curios or possibly for sale,and, in the case of ivory carvings, commercialshipments from routine importers, mostlyinvolving the antique trade from Europe, thatare occasionally seized by authorities. Inrecent years there have also been several casesand prosecutions involving both raw and workivory being smuggled into the USA in largerquantities for commercial purposes.

For example, in 1999 USFWS inspectorsassisted by inspectors from US Customs (nowCustoms and Border Protection, known asCBP) discovered 19 ivory carvings and otherwildlife concealed in a shipment of furnitureand ceramic vases imported from China. Afterthe post-seizure investigation revealed that theitems were destined for a commercial business,search warrants for that operation led to therecovery of another 100 smuggled ivorycarvings valued at more than USD100 000.Three defendants pleaded guilty to felonysmuggling charges and a misdemeanor LaceyAct violation and were sentenced to payUSD190 000 in fines and another USD99 000in restitution (Peter Thomas, Chief, Division ofManagement Authority, USFWS, in litt. toWillem Wijnstekers, CITES Secretariat,August 2003).

In September 2000, a citizen of Côte d’Ivoirewas arrested for attempting to smuggle 57African Elephant carvings valued at more thanUSD150 000 into the USA through NewYork’s John F. Kennedy Airport. Anexamination of the man’s luggage revealed thecarvings, which had been concealed inside asand and paper substance designed to resemblestone carvings and hide the ivory’scharacteristics. Agents identified theconcealment techniques because they wereidentical to those used in a January 2000smuggling attempt by another Ivorian citizenwho was serving a year in prison for the


offense. That individual had written the recentoffender and provided business cards listingAfrican art dealers in New York City. The manwas sentenced to serve 11 months and 10 daysin prison (USFWS, 2001).

In a similar, even larger case in Los Angeles in2001, two individuals were arrested forrunning one of the largest elephant smugglingrings ever discovered on the West Coast whenUSFWS and US Customs inspectorsintercepted two shipments containing some250 pounds of raw and worked ivory. Theshipments, which were imported into LosAngeles from Nigeria, had been declared ashandicrafts and furniture. Ivory pieces wereconcealed in beaded cloth in the shipment,while whole tusks were found inside pieces offurniture. In that case, the individuals werecharged with smuggling and conspiracy andsentenced to one year and six months inprison, respectively (USFWS, 2003c).

More recently, USFWS inspectors, along withCBP inspectors intercepted two individualsreturning from China who were found to be inpossession of ivory as well as other wildlife.After further investigation revealed that theindividuals operated an art gallery, searchwarrants were served and items with a totalvalue of more than USD1 million wererecovered. Agents estimated that the pairtraveled abroad several times per year onbuying trips for their shop, and may have beendoing so for some time. Yet another caseinvolved the apprehension of an individualwho smuggled 22 ivory carvings disguised andhidden in a shipment of wooden carvings.Post-seizure investigation revealed that theindividual operated a store in Dallas, Texaswhere the African curios were sold (PeterThomas, Chief, Division of ManagementAuthority, USFWS, in litt. to WillemWijnstekers, CITES Secretariat, August 2003).

Finally, in March 2004 a Canadian residentfrom Cameroon was indicted on two counts ofviolations of the Lacey Act and two counts ofAiding and Abetting the Smuggling of Goodsinto the USA for alleged activities relating toillegal ivory trade. According to theindictment, in November of 2002 and again inDecember 2003, the woman, who operatedseveral Internet-based wildlife and African artbusinesses, smuggled raw ivory and tusks into

the USA from Cameroon in two separateshipments. The ivory was concealed in terracotta pottery. The first shipment contained tworaw elephant tusks in a shipping package thatwas falsely labeled and identified as containingwood and terra cotta sculptures. The secondshipment was falsely labeled as containingterra cotta flower pots (USFWS, 2004b).

SummaryTaken together, the examples above suggestthat the illegal trade in ivory entering the USAtakes several forms. Small-scale, tourist-drivenimportation of illicit ivory, while certainly aconcern, is not the only challenge. The regularoccurrence of seizures of commercial ivoryshipments from established dealers operatingin the trans-Atlantic market suggests thatwildlife trade enforcement officials mustremain vigilant in monitoring the trade inantique ivory. USFWS inspectors, CBPinspectors, and others involved in bordersecurity must also remain vigilant againstlarger-scale concealment and smuggling ofivory in commercial quantities for the USmarket. Lastly, TRAFFIC is particularlyconcerned that wildlife enforcement agentsmust closely monitor the trade in ivory throughthe Internet from China and elsewhere toprevent illegal ivory from entering the USA insubstantial quantities.

Unfortunately, in confronting such challenges,the US wildlife trade control and enforcementprogram faces gaps in funding and staffing.Although USFWS estimated in 2003 that itsinspectors typically process more than 117 000wildlife shipments each year with a declaredvalue in excess of USD1.25 billion, that thistrade has nearly doubled over the last 20 years,and that in the past five years the number ofwildlife shipments declared has increased bynearly 30 percent, staffing and funding hasremained constant in recent years. In fact, byJuly 2001 the total number of USFWS specialagents had dropped below 190, reducing thenumber of personnel available to its lowestlevel since 1986. Although USFWS has sincehired a number of new special agents, theagency remains short of its authorized level.USFWS does not expect to achieve a fullcomplement of staffing in the near termthrough new hires, even as agent ranks maycontinue to drop as veteran officers reach


retirement age. Funding cutbacks or continuedflat budgets could jeopardize, if not undermine,USFWS efforts to create and maintain anadequately staffed investigative program.USFWS also faces staffing challenges for thewildlife inspection program. While USFWShas maintained overall port staffing levels, anumber of the Service’s veteran inspectorshave reached or are reaching retirementeligibility. In 2003, USFWS also reporteddifficulty in recruiting and retaining wildlifeinspectors, particularly on the East Coast(USFWS, 2003).

US Compliance with CITESResolution Conf. 10.10 (Rev. CoP12) As was noted earlier, at CITES CoP10, theParties adopted Resolution Conf. 10.10 (Rev.CoP12). The resolution directed the CITESSecretariat to identify those Parties with anivory carving industry and internal ivory tradewhose domestic measures did not provide themthe authority to strictly regulate the trade inelephant ivory. Such countries were defined asthose without the authority to register andlicense all importers, manufacturers,wholesalers and retailers dealing in raw, semi-worked or worked ivory products; assertcompulsory trade controls over raw ivory; andestablish a comprehensive and effectivereporting and enforcement system for workedivory (CITES, 2004b).

In 2004, the CITES Secretariat indicated thatthe USA was not fully implementing therequirements of Resolution Conf. 10.10 (RevCoP12), and had written seeking an action planas required in CITES Decision 12.39. TheSecretariat based its action on the grounds thatthe USA does not have all of the regulatorymeasures identified in the resolution (CITES,2004d; Milliken et al., 2004).

For the purposes of this report, TRAFFIC didnot attempt to undertake an extensive analysisof all the legal and Constitutional issues thatimplementing the requirements of CITESResolution Conf. 10.10 (Rev. CoP12) to thesatisfaction of the CITES Secretariat wouldraised for the US government. However,TRAFFIC’s research for this report suggestedthat it would be a challenge, for severalreasons.

First, as has been noted above, the US federalgovernment has only limited authority toregulate or prohibit intrastate commerce (PeterThomas, Chief, Division of ManagementAuthority, USFWS, in litt. to WillemWijnstekers, CITES Secretariat, August 2003).The USA does have domestic legislation suchas the ESA, Lacey Act, and AECA thatregulate and in some cases proscribe interstateor international commerce in designatedwildlife and wildlife products, including ivory,but registering wholesalers, retailers, andothers in individual states may not be legallyfeasible at the federal level.

Second, the fact that the US ivory marketappears to be very diffuse, with ivory productsavailable from multiple sources (e.g., retailoutlets, auction houses, estate sales, theInternet, etc.) poses a significant challenge toany attempt to establish a comprehensivereporting and enforcement system. Forexample, as was shown above regarding theInternet, approximately 1000 ivory items invarious forms are available on a weekly basisthrough eBay alone, mostly from domesticsources. How to effectively monitor and policesuch a large volume of small-scale trade wouldrepresent a significant challenge.

Third, regarding domestic ivory carving, thereis room for question about whether it isextensive enough to constitute a true“industry.” Although research for this reportuncovered examples of ivory being carved andsold in several US states, the activitiesappeared to be small-scale. TRAFFIC foundno examples of companies or individualsderiving their business or livelihood solelythrough the carving of ivory, although thepossibility that some such enterprises mayexist cannot be ruled out. Further investigationwill be needed to determine to scope ofsignificance of this activity in the USA.

Finally, it should be noted that even though theCITES Secretariat has indicated that the USAis not fully implementing the requirements ofCITES Resolution Conf. 10.10, it regards theUSA as a low priority in the initiative tocontrol internal trade in ivory. The Secretariatnotes that in the case of the USA, althoughofficial policies do not prohibit trade in ivory,they certainly do nothing to encourage it, makeclear that imports are rigidly restricted to what


is allowed by CITES, and limit domestic tradeto pre-Convention ivory. Furthermore, theSecretariat has noted that it is primarilythrough the USA’s reporting of a significantnumber of ivory seizures, indicative of a stronglaw enforcement program, that the countryfeatures prominently in ETIS and was thuslisted in Decision 12.39 (CITES, 2004d).

The Impact on ElephantPopulationsDetermining whether the US elephant ivorymarket is a significant factor driving ongoingpoaching of elephants proved difficult, becausethe link between illegal ivory imports into theUSA and the situation in African range statesis often indirect. As was noted above, there iscertainly reason for concern that the USAremains a destination market for illegal ivoryentering the country through China-basedInternet sellers, tourists, shipments of“antiques”, and commercial smuggling.Assuming as Stiles and Martin (2003) did thatthere is a positive correlation between ivorydemand and elephant poaching, the scale of theUS ivory market should indicate the level ofelephant killing needed to supply that demand.However, several factors combine toundermine efforts to directly correlate USmarket demand with contemporary levels ofelephant poaching.

First, the precise relationship betweenunregulated ivory markets and illicit trade inivory, particularly in Africa and Asia, remainsunknown. Stiles and Martin (2003) noted thatEast Asia is likely the main destination pointfor illegal elephant ivory, most of it of Africanorigin. According to the findings of that study,China has emerged as the largest illegalmanufacturer and importer-exporter of ivory.However, Hunter et al. (2004) found thatunregulated ivory markets in Africa appear toconsume a higher volume of ivory than dothose in Asia, although that study did notdetermine the exact source of the ivory. Thatstudy found that 13 countries in Africa(Cameroon, Central African Republic, Côted’Ivoire, the Democratic Republic of Congo,Egypt, Ethiopia, Gabon, Nigeria, Mozambique,Senegal, South Africa, Sudan, and Zimbabwe)require 32–81 mt of raw ivory per year tosustain their domestic ivory markets. Bycontrast, 12 countries or administrative regions

in Asia (Cambodia, China, Hong Kong, Japan,Lao PDR, Myanmar, Nepal, Sri Lanka,Taiwan, Thailand, and Vietnam) require 13–34mt. If the regulated ivory requirements ofSouth Africa, Zimbabwe, and Japan areexcluded, Africa still requires some 26–65 mtof raw ivory compared with 7–18 mt for Asia.That finding runs contrary to manyconventional notions about contemporary ivorytrade dynamics, and raises questions about theworkings of the market.

Second and closely related, there are questionsabout who is purchasing worked ivory fromsources in both Asia and Africa. Stiles andMartin (2003) and O’Connell-Rodwell andParry-Jones (2002) both noted that in 1999,main buyers reported in six cities in Chinawere from Japan, China, Hong Kong, Taiwan,and Thailand. From Europe, the main buyerswere from Italy, Spain, France, and the UK.By 2001, O’Connell-Rodwell and Parry Jones(2002) reported that Chinese nationals hadbecome the main retail ivory buyers, and in2002 Stiles and Martin (2003) indicated thatbuyers of worked ivory were primarily foreignChinese and Japanese. From Africa, Hunter etal. (2004) cited Martin and Stiles (2000), Stilesand Martin (2001), and Courouble et al. (2003)in noting that buyers of worked ivory includedEuropean and Asian diplomats, Frenchmilitary, Asian businessmen, United Nationsstaff, West African traders, expatriates, andtourists from Europe, the USA, and Asia.

Such reports lead to two potentially conflictingconclusions regarding the specific role of theUSA in the illicit ivory trade from these


Forest Elephant killed by poachers for tusks. Dzanga-NdokiNational Park, Central African Replublic (CAR).

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sources. On the one hand, the US market isnot specifically listed in any of these sourcesas a primary destination market, apart from therole of US tourists. On the other hand, Hunteret al. (2004) also noted that these reportsindicated that such trade likely represents notonly individual demand for personal effects,but also potentially significant amounts ofcarved ivory being purchased for commercialsale elsewhere. Furthermore, as was notedabove, the USA recorded seizures of illegalivory in various forms and quantities from all25 of the countries examined by Hunter et al.(2004) and also from numerous other countriesin Africa, Asia, and Europe. It is thereforepossible and even likely that some of the illicitivory moving through these various channelsmay be destined for the US market; however,precisely quantifying how much ivory is beingprocured to meet US demand as opposed toother global buyers cannot be determined.

Third, the numbers of elephants being poachedto serve these unregulated or illicit marketsremains unknown. Within Africa, Hunter et al.(2004) cited the belief that almost all of theivory used in the carving industries of Westand central Africa comes from elephants thathave been killed illegally, because tusks fromnatural mortality are rarely found in foresthabitats. Some small quantities of ivory fromnatural mortality may come from savannahhabitats, although such ivory cannot legallycross international borders without CITESpermits. Other ivory may derive from various

government-owned stockpiles, while yet moremay derive from elephants killed for meat forhuman consumption or in defense of life orproperty. In the latter case, obtaining ivorymay not be the primary motive for killing theelephants, but the ivory may subsequently endup in trade (Hunter et al., 2004). In Asia, aswas previously noted, in China alone some 110mt of elephant ivory went missing in the yearsbetween 1991 and 2002, and as of 2002 noestimate of the national stockpile could bemade (Stiles and Martin, 2003).

Given such variables, quantifying the numberof elephants being killed each year to supplyunregulated domestic markets or illegalinternational trade is extremely difficult.Hunter et al. (2004) used one set of data andextrapolation methods to estimate that theivory from between 4862 to 12 249 AfricanElephants and 123 to 349 Asian Elephants isrequired annually to supply the unregulatedmarkets examined in their report. Even takingthose figures as an accurate range, however,the question of what percentage of thoseelephants may be taken to serve the US marketremains unknown. With no accurate surveyson the extent or nature of the US domesticivory trade, legal or illegal, and onlyincomplete information on potential sourcesand routes of illegal ivory entering the USA, itis not possible to find definitive evidencelinking the US ivory market to a quantifiablelevel of poaching of wild elephants.


The global trade in hippo parts includes a widerange of products ranging from skin andleather products to bone, trophies, skulls, feet,shoes, and raw and carved ivory. TRAFFIC’s2004 examination of the hippo tradeconcentrated on the import and export ofcarved hippo ivory, tusks/teeth (canine andincisor teeth),4 trophies, and jewelry, focusingin particular on the USA’s role in theinternational marketplace. TRAFFIC foundthat the USA is a significant importer of theseproducts, with the primary exportingjurisdiction being Hong Kong. TRAFFIC alsofound a second, smaller trade flow of hippoivory products coming directly from Africannations. TRAFFIC’s examination furtherrevealed that the trade of hippo ivory into theUSA is dominated by a relatively smallnumber of importers and exporters whoaccount for the overwhelming majority of theproducts entering the US market.

The Global Hippo TradeThe contemporary international trade in hippoivory differs from the elephant ivory trade infundamental ways. Most significantly, becausethe hippo is currently only listed in CITESAppendix II and is not otherwise prohibitedfrom trade by US or international law, thereremains an ongoing legal commercial trade inhippo ivory and other products. Thecommercial trade in hippo ivory that existedbefore the species was listed in CITESAppendix II in 1995 continued afterwards,albeit under closer international monitoring.

However, as Table 11 shows, gross exports ofvarious hippo ivory products from African

range states declined following the 1995listing, especially regarding the amount ofivory measured by individual teeth and thenumber of carvings exported from Africa.These figures show that while there have beensignificant fluctuations in the trade from Africaof various ivory commodities during theseyears, substantial amounts of ivory havecontinued to come out of Africa to feed the USand other world markets.

The Cumulative US TradeThe USA imports significant amounts of hippoivory in the form of carvings, teeth, trophies,and, to a lesser degree, jewelry and pieces.Between 1995 and 2002, for example, USFWSLEMIS data show that the USA cleared some2479 shipments of hippo ivory in variousforms, while refusing 93 others. Table 12shows the total number of hippo ivoryshipments cleared and refused by the USA forthe period 1995 to 2002.

Although the USA imported far fewershipments of hippo ivory than elephant ivoryduring this period, the amount of actual hippoivory imported far exceeded that of elephantivory, demonstrating a distinct difference inthe pattern of trade between the twocommodities. For example, between 1995 and2002 the USA reported 6796 clearedshipments of elephant ivory—almost threetimes the number of cleared hippo ivoryshipments. However, as Table 13 shows, thehippo shipments cumulatively representedclose to 87 500 individual ivory items, as wellas 1436 kg of hippo ivory reported by weight.There were also a total of 1160 trophy


THE US HIPPO IVORY MARKET

Item 1995 1996 1997 1998 1999 2000 2001 2002 Total

Teeth 42 295 28 046 2459 3939 11 091 4570 4299 1037 97 736Teeth (kg) 5250 24 477 14 695 8642 12 766 19 631 12 500 8840 106 801Carvings 2543 560 297 187 3613 2 396 212 7810Trophies 248 377 315 196 257 384 617 334 2728

4 For the purposes of this report, hippo “tusk” and “tooth” imports are combined and described simply as teeth.

Table 11: Total Gross Exports of Hippo Teeth, Tusks, Carvings, andTrophies from African Range States, 1995–2002

Source: TRAFFIC and IUCN/SSC (2004).

imports. Added together, those shipmentstotal well more than three times the 33 864ivory items and approximately 125 kg of ivoryby weight represented in the elephant ivoryshipments (see Table 2 in the previoussection). The primary reason for thejuxtaposition of these totals is that, whereasthe majority of shipments of elephant ivoryincluded small numbers of items, often justone antique ivory carving or tusk, hippo ivorytended to be imported in bulk commercialshipments, with sometimes hundreds ofindividual ivory carvings or teeth included ineach (TRAFFIC analysis of USFWS LEMISdata, March 2004).

These data show that, as with elephant ivory,the preponderance of US trade in hippo ivoryconsists of carved pieces. The trade in theseitems peaked in 1999 and then decreasedsubstantially in the years 2001 and 2002. Thistrend is roughly consistent with the fall-off ofreported exports of hippo ivory from Africarange states shown in Table 11 (CITES, 2004c).

US Hippo Ivory ImportsAnalysis by TRAFFIC of available trade datafrom CITES, UNEP-WCMC, and USFWSrevealed several other broad patterns in the UScommercial hippo ivory trade regardingcountries of origin for the ivory, majorimporters and exporters, trade routes, anddestination markets in the USA.

Countries of Origin

Far more information is available about thecountries of origin for hippo ivory imported tothe USA than is known about the origin ofelephant ivory. Whereas current legalcommercial trade in elephant ivory is restrictedto antiques for which the original source mayno longer be known, the trade in hippo ivoryinvolves a continuous, contemporary stream ofivory from range states to world markets.

Tanzania is identified by USFWS LEMIS dataas the country of origin for the vast majority ofhippo ivory commercially imported into theUSA, which is consistent with that nation’s


Commodity Shipments Cleared Shipments Refused

Carved Ivory 810 41Trophies 1160 4

Hippo Teeth 502 46Ivory Jewelry 5 2

Pieces 2 0Total 2479 93

Item 1995 1996 1997 1998 1999 2000 2001 2002 Total

Carved Ivory 7957 + 9548 + 7477 + 11 340 + 12 813 + 9330 + 3866 + 3402 + 65 733 +31.35 kg 154 kg 332.3 kg 576.6 kg 25.7 kg 27.3 kg 23 kg 12.8 kg 1183 kg

Trophies 91 94 107 143 175 205 174 171 1 160Teeth 3872 4600 3262 2083 + 1476 2089 + 1455 + 1630 + 20 467 +

3.35 kg 60 kg 80 kg 116.5 kg 260.1 kg

Jewelry 0 0 0 1 + 77 5 0 0 83 +290 g 290 g

Raw/Pieces 0 0 0 6 0 0 0 12 18

Total 11 827 + 14 148 + 10 736 + 13 429 + 14 364 + 11 431 + 5318 + 5041 + 87 468+31.35 kg 154 kg 332.3 kg 580.2 kg 25.7 kg 80.3 kg 103 kg 129.3 kg 1 436 kg

Table 12: Hippo Ivory Imported into the USA by Shipment, 1995–2002


Table 13: Hippo Ivory Imported into the USA by Unit and Year, 1995-2002


prominent role as an exporter of hippo tusksand teeth. Other nations that figureprominently in the trade include Zimbabwe,South Africa, Uganda, Zambia, Burundi, theDemocratic Republic of Congo, and Malawi.For example, of the 810 shipments of carvedivory recorded as entering the USA legallybetween 1995 and 2002, Tanzania wasidentified as the source country for 517 (64%)of those shipments. Similarly, LEMISrecorded Tanzania as the country of origin for199 (40%) of the 502 imports identified asconsisting of hippo teeth. Table 14 shows therecorded country of imports for hippo ivorycarvings and teeth for the years 1995 to 2002.

Trade RoutesTRAFFIC also examined the routes throughwhich commercial shipments of carved ivoryand hippo teeth reached the USA. TRAFFIC’sanalysis of LEMIS data showed three broadpatterns in the trade. First, the overwhelmingmajority of shipments of carved hippo ivoryand hippo teeth that entered the USA legallybetween 1995 and 2002 passed through HongKong. Second, there is a smaller segment ofthe trade in shipments recorded as carvedhippo ivory that entered the USA directly fromAfrica. And third, the majority of shipmentsrecorded as hippo teeth entered the USAdirectly from African range states (TRAFFICanalysis of USFWS LEMIS data, March

2004). The following examines each of thesetrade patterns.

Carved Hippo Ivory

Of the 810 shipments of carved hippo ivoryreported in LEMIS as cleared between 1995and 2002, 699 (86%) listed Hong Kong as theexporting jurisdiction. An additional 22shipments that list Tanzania as the country ofexport also show the foreign supplier to be acompany identified by TRAFFIC as based inHong Kong. If shipments from HongKong–based companies are used to determinethe trade route of the ivory, therefore, HongKong’s role in the trade becomes even moresignificant. Using that analysis, 721 (89%) ofthe 810 shipments of carved hippo ivoryimported into the USA between 1995 and 2002involved Hong Kong–based suppliers(TRAFFIC analysis of USFWS LEMIS data,March 2004). Table 15 shows the countries ofexport for shipments of carved hippo ivory intothe USA by year between 1995 and 2002.

The countries of origin recorded for theseshipments were primarily Tanzania, Uganda,Burundi, the Democratic Republic of Congo,Malawi, and China (likely ivory exported fromAfrica to China and then re-exported throughHong Kong). This trade pattern suggests thatcarved hippo ivory entering the USA originatesin East, Southern, and to an extent CentralAfrica, flows to Hong Kong or China to be


Country of Origin Carved Ivory Hippo Teeth Total

Tanzania 517 199 716Zimbabwe 30 127 157South Africa 40 88 128Uganda 93 13 106Zambia 4 34 38Burundi 35 3 38Dem. Rep. of Congo 22 5 27Malawi 13 6 19Other 56+ 27++ 83Total 810 502 1312

Table 14: Country of Origin for Hippo Ivory Carvings and Teeth Cleared forEntry into the USA by Shipment, 1995–2002 (no. of shipments)

Source: TRAFFIC analysis of USFWS LEMIS data, March 2003+ Other countries identified in LEMIS as origins of shipments of carved hippo ivory include China (23), Hong Kong (7), Belgium (4),

Botswana (2), Russia (3), Korea (1), Egypt (1), Saudi Arabia (1), Ethiopia (1), Brunei (1), and unspecified/unknown (12). ++ Other countries identified in LEMIS as origins of shipments of hippo teeth include Botswana (3), China (2), Hong Kong (2), Kenya (2),

Belgium (1), Saudi Arabia (1), Colombia (1) and unspecified/unknown (15).

worked, and is then re-exported from HongKong to the USA (TRAFFIC analysis ofUSFWS LEMIS data, March 2004).

Furthermore, TRAFFIC’s examination of whoin Hong Kong is listed as the foreign suppliershowed that the trade is dominated by a smallnumber of companies. For example, between1995 and 2002, 13 Hong Kong–basedcompanies accounted for 642 (79%) of allcarved hippo ivory shipments to the USA. Thetop five listed exporters alone accounted for 443of these shipments (54%). The remainder ofshipments of carved hippo ivory imported intothe USA that listed Hong Kong as thejurisdiction of export came primarily from othersuppliers recorded in LEMIS as being craftshops, carving factories, and trading companies,although in some cases the ivory was importedby individuals (TRAFFIC analysis of USFWSLEMIS data, March 2004).

A second, smaller trade route for carved hippoivory involves shipments entering the USAdirectly from African range states, in particularSouth Africa and Zimbabwe. Shipments fromthese nations accounted for 63 LEMIS recordsbetween 1995 and 2002. The foreign suppliersfor these carvings were primarily a smallnumber of curio shops, safari companies, andtrading companies. In addition, LEMISrecords indicate that while some of theseAfrican shipments are commercial in nature,involving company-to-company transactions,the majority appeared to be noncommercial innature. These involved small numbers ofcarved ivory pieces, often imported by

individuals, perhaps as souvenirs or curios.There were also several records in LEMISshowing a specialty trade in carved ivory bycompanies identified as custom knife-makers(TRAFFIC analysis of USFWS LEMIS data,March 2004).

Hippo Teeth

Similar to records listed as carved hippo ivory,a significant trade route for shipments of hippoteeth from African range states to the USmarket passes through Hong Kong, andinvolves the same limited number of suppliers.As Table 16 shows, Hong Kong–basedcompanies accounted for 160 (32%) of the 502reported shipments of hippo teeth into theUSA between 1995 and 2002.

However, as the table shows, TRAFFIC foundthat the majority of shipments of hippo teeth(often coded in LEMIS as “tusks”) that enteredthe USA between 1995 and 2002 wereimported directly from African range states.These records indicated that these importsconsisted of a mixture of hippo ivory forcommercial and noncommercial purposes.TRAFFIC’s analysis of the import data showedthat hippo teeth imported into the USAcommercially from Africa came in shipmentsof multiple pieces from Zimbabwe and, to asmaller extent, South Africa. These samenations dominated the trade in hippo teethentering the USA in smaller quantities forpurposes identified in the records asnoncommercial, likely as tourist curios orsouvenirs. Foreign suppliers for these records


Exporter 1995 1996 1997 1998 1999 2000 2001 2002 Total

Hong Kong 58 88 99 108 141 103 61 41 699South Africa 3 6 5 5 5 5 5 0 34Zimbabwe 0 2 8 7 1 5 4 2 29Tanzania+ 9 2 5 1 4 1 0 0 22China 1 2 0 5 2 1 0 0 11Others++ 0 2 0 3 3 4 3 0 15

Total 71 102 117 129 156 119 73 43 810

Table 15: Country/Jurisdiction of Export for Shipments of Carved HippoIvory Imported into the USA, 1995–2002 (no. of shipments)

Source: TRAFFIC analysis of USFWS LEMIS data, March 2004.+ Although Tanzania is listed as the country of export for these shipments, TRAFFIC’s examination of LEMIS records shows that the foreign

suppliers listed for all of these records are Hong Kong–based companies.++ Other countries of export for carved hippo ivory shipments include Malawi (2), the UK (2), the Netherlands (2), Taiwan (2), Ethiopia (1),

France (1), Switzerland (1), and unspecified/unknown (3).

included primarily safari companies, curio andart shops, and taxidermists. Unfortunately, asnoted above for elephant tusks LEMIS data donot clearly differentiate between raw andworked ivory in recording imports into theUSA. TRAFFIC could not therefore definitelydetermine how many of the imports listed asteeth may have represented raw as opposed toworked ivory (TRAFFIC analysis of USFWSLEMIS data, March 2004).

Hippo Jewelry and Pieces

Along with these major commodities,TRAFFIC found a few import recordsidentified as hippo ivory jewelry or pieces.Some of these shipments appeared to becommercial in nature. For example, in 1998there was one shipment totaling 290 grams ofhippo ivory identified as jewelry from an artscompany in Hong Kong to an importeridentified by TRAFFIC as a US–based Internetsite dealing in hippo ivory. In 1999 there weretwo commercial shipments, one consisting of35 pieces from Zimbabwe, the other of 42pieces from Hong Kong, also to regularimporters in the USA. In 2000 there was alsoa shipment of five pieces from a hunting outfitin South Africa to a US African arts store, withthe origin of the ivory listed as Malawi. Inaddition to those shipments, TRAFFIC alsonoted one case of an individual importing asingle piece of jewelry from an exportcompany in Zimbabwe. Although it cannot bediscounted that some hippo ivory jewelry may

be entering the USA listed in the importrecords under different categories, the rareoccurrence of jewelry in LEMIS appears toindicate that such items do not appear torepresent a significant feature of the overalltrade (TRAFFIC analysis of USFWS LEMISdata, March 2004).

Similarly, TRAFFIC found only two importrecords identified as ivory pieces. One was ashipment of six pieces from a South Africancompany to a U.S. machinery company, whilethe other consisted of 12 pieces, likely teeth,from a curio shop in Zimbabwe to a USindividual (TRAFFIC analysis of USFWSLEMIS data, March 2004).

Hippo Trophies

In addition to the commercial and non-commercial trade in carvings, teeth and otheritems, the USA also reported 1160 imports ofhippo trophies between 1995 and 2002. Aswith the trade in African Elephant trophies thatwas described in the last section, it was notpossible to determine exactly how many ofthese imports involved hippo ivory, or in whatquantity. In fact, determining the amount ofivory included in hippo trophy shipments iseven more difficult than it is in the case ofelephants. Whereas the complication inestimating the amount of ivory included inelephant trophies involves the differencebetween one or two tusks, with hippos a trophyshipment may range anywhere from one or twotusks to several teeth. This complication has


Source: TRAFFIC analysis of USFWS LEMIS data, March 2004.+ Although Tanzania is listed as the country of export for these shipments, TRAFFIC’s examination of LEMIS records shows that the foreign

suppliers listed for all of these records are Hong Kong–based companies.++ Other countries of export for shipments of hippo ivory shipments include the UK (10), Japan (2), Kenya (2), Botswana (1), Canada (1), the

Democratic Republic of Congo (1), Malawi (1), Peru (1), and Switzerland (1).

Exporter 1995 1996 1997 1998 1999 2000 2001 2002 Total

AsiaHong Kong 29 30 36 18 15 10 14 8 160AfricaZimbabwe 7 12 13 23 20 19 21 11 126South Africa 7 11 6 13 9 28 21 17 112Tanzania+ 5 11 4 11 9 8 4 6 58Zambia 2 2 4 9 6 2 1 0 26Others++ 1 0 5 1 2 3 1 7 20Total 51 66 68 75 61 70 62 49 502

Table 16: Country of Export for Shipments of Hippo Teeth Imported intothe USA, 1995–2002 (no. of shipments)

vexed attempts to determine the amount ofivory involved in international trade in theform of hippo trophies since before the 1995decision to list the species in CITES AppendixII (TRAFFIC and IUCN/SSC, 1994 and 2004;CITES, 1999).

The largest source of hippo trophies importedinto the USA between 1995 and 2002 wasTanzania, which accounted for 495 (43%) of thetotal number of imports. Zimbabwe, Zambia,and South Africa were other prominent sources.Trophy imports entered the USA almostexclusively from the identified country of originfor the hippo. As with the trade in elephanttrophies, listed importers tended to be individualUS citizens, and listed exports were safaricompanies, hunting outfits, or taxidermyenterprises. Not surprisingly, a cross-checkbetween listed exporters of elephant trophiesand hippo trophies found many of thesecompanies, outfits, and taxidermy shops werethe same in both sets of data. This likelyreflects the fact that significant sport-hunting forAfrican Elephants and Hippos occurs in a fairlydefined subset of African range states, served bya fairly specialized pool of hunting guides(TRAFFIC analysis of USFWS LEMIS data,March 2004).

Table 17 shows the number of hippo trophies imported into the USA by year from1995 to 2002.

The Domestic MarketThe domestic market for hippo ivory in theUSA differs from that seen for elephant ivory

in several ways. First, as was noted above,unlike the legal elephant ivory trade, whichtends to concentrate on the import of carvings,tusks, and other items in individual shipmentsor small lots of antiques, hippo ivory tends tobe imported in larger bulk shipments forcommercial resale. It also proved far easier tolink imports of hippo ivory to specific physicaland Internet retail operations.

Second, because there are no restrictions onthe legal import or resale of raw hippo ivoryfor commercial purposes similar to thoseplaced on elephant ivory, TRAFFIC found agreater variety of hippo ivory for sale. Alongwith pre-carved ivory items imported fromHong Kong and elsewhere, raw ivory is readilyavailable at the retail level.

Third, unlike the trade in elephant ivory, in thecase of hippo ivory the USA appears to bealmost exclusively a destination market. Aswas discussed in the previous section on theUS elephant trade, along with importingelephant ivory, the USA also exported (or re-exported) close to 8600 elephant ivory itemsbetween 1995 and 2002—carvings inparticular. By contrast, in the same eight yearsof LEMIS data analyzed for hippos, TRAFFICfound only 24 total records of hippo ivoryexports from the USA, and 10 of thoseinvolved the export of trophies for commercialor noncommercial purposes. TRAFFIC foundonly eight export records for carved hippoivory (totaling 81 pieces) that appeared to becommercial in nature, as well as two carvedivory shipments totaling three pieces that were


Source: TRAFFIC analysis of USFWS LEMIS data, March 2004.+ One 1995 record did not specify the country of origin or the country of export.

Table 17: Country of Origin for Shipments of Hippo Trophies Importedinto the USA, 1995–2002 (no. of shipments)

Origin 1995 1996 1997 1998 1999 2000 2001 2002 Total

Tanzania 29 35 46 59 71 86 74 95 495Zimbabwe 33 14 23 43 36 48 55 49 301Zambia 20 34 32 33 56 52 20 3 250South Africa 7 8 6 7 6 16 17 20 87Mozambique 0 2 0 0 3 3 6 4 18Cameroon 1 1 0 0 2 0 2 0 6Botswana 0 0 0 1 0 0 0 0 1Ethiopia 0 0 0 0 1 0 0 0 1Other+ 1 0 0 0 0 0 0 0 1Total 91 94 107 143 175 205 174 171 1160

exported for likely noncommercial purposes.The remaining four exports were listed asteeth. Two of these exports were commercialin nature, including 25 teeth exported to acustom knife-making company in South Africaand two kilograms of teeth exported toIndonesia. The other two appeared to be apersonal effects shipment involving one toothby an individual to Greece, and the shipmentof a tooth to a Japanese museum. Thus, notonly is it apparent that the USA now importssignificantly more hippo ivory than elephantivory, it would also appear that the US marketis absorbing virtually all of the hippo ivorycoming in (TRAFFIC analysis of USFWSLEMIS data, March 2004).

TRAFFIC found several major domesticchannels of trade for various hippo ivoryproducts. One is direct retail through physicalstores. For example, TRAFFIC located abusiness in New York City that advertises itselfas a major importer carrying more than 6000items in stock, including carvings made fromelephant, hippo, and mammoth ivory that rangein price from USD39 to 4000. LEMIS recordsshowed that between 1995 and 2002 thisbusiness imported 102 shipments of hippoivory carvings and 14 shipments listed ashippo teeth, all but one of which were frommajor exporters in Hong Kong. Cumulatively,the imports attributed to this company included6693 ivory carvings and 618 kg of carvings,and 1181 teeth plus 3.35 kg of teeth

(TRAFFIC analysis of USFWS LEMIS data,March 2004). TRAFFIC found similar recordsof other importers of hippo ivory doingbusiness at the retail level; however, as withelephant ivory, it was not possible to puttogether a nationwide, comprehensive list ofsuch outlets.

The Internet is another significant outlet forhippo ivory in the US market. As with elephantivory, TRAFFIC monitored the availability andprices of hippo ivory available through eBay,and found that the amount of hippo ivoryavailable through this major site ranged from 94to 184 items per week between mid-Februaryand mid-May. That is only about 10–20 percentof the amount found by TRAFFIC in thecomparable evaluation of the averageavailability of elephant ivory on eBay weekly.Table 18 shows the results of periodic eBaysearches during the survey period using theterms “hippo ivory” and “hippopotamus ivory.”

TRAFFIC noted a couple of interesting thingsabout this aspect of the trade. First, much ofthe hippo ivory available from domesticvendors through eBay was attributable to twovirtual “stores”, one based in Maryland and theother in Pennsylvania. LEMIS data showedthat the operators of both of these stores hadlegally imported carved hippo ivory from HongKong (TRAFFIC analysis of USFWS LEMISdata, March 2004). Other hippo ivoryavailable through eBay for which TRAFFIC


Date “Hippo Ivory” “Hippopotamus Ivory” Total

2/13/04 90 4 942/20/04 97 1 982/27/04 142 0 1423/05/04 106 4 1103/12/04 161 2 1633/19/04 170 5 1753/26/04 182 2 1844/05/04 158 5 1634/09/04 176 5 1814/19/04 139 4 1434/23/04 159 5 1644/30/04 147 3 1505/14/04 142 3 145

Table 18: Search Results for Hippo Ivory Available via eBay, February13–May14, 2004

Source: Pers. comm., T. Leonard, TRAFFIC North America, June 4, 2004.

found records of US purchases came from sitesbased in Hong Kong, suggesting some level ofretail trade in hippo ivory carvings entering theUSA directly from overseas.

Second, there was a parallel between theseUS–based vendors selling primarily hippoivory carvings and the China-based vendorsselling similar elephant ivory items that weredescribed in the last section. TRAFFIC foundthat the domestic vendors selling carved hippoivory and the China-based vendors sellingcarved elephant ivory appeared to share amarket niche. For example, both sets ofvendors offered various items of two-to-threeinch netsuke carvings at prices ranging fromapproximately USD25 to 50, with some itemspriced above that level. Various jewelry itemswere offered by both sets of vendors in therange of USD10 to 20. Thus, on at least onelevel it would appear that the domestic vendorsselling hippo ivory and the vendors based inChina selling elephant ivory are competing forwhat might be termed the low-end ivorymarket, given that ivory carvings imported intothe USA from Europe as antiques aresometimes valued in LEMIS records in thethousands of dollars each. On another level,however, there is a major difference. WhereasTRAFFIC could trace the hippo ivory offeredby the domestic stores on eBay to ivoryshipments cleared by USFWS, TRAFFIC hasserious reservations about the legality of theongoing trade in elephant ivory carvings fromthe vendors based in China.

And third, there is an active market for hippoivory being sold through the Internet outsideeBay. TRAFFIC found numerous sites sellingboth raw and worked ivory, catering todifferent parts of the US market. Some ofthese sites advertised pre-carved netsuke andother pieces of hippo ivory art similar to thoseadvertised on eBay, but typically at higherprices. Others advertised ivory dolls, figurines,and other items that had entered the USA asraw ivory that had been then carved inside thecountry. Still others advertised specialty itemssuch as custom ivory knife handles and gungrips. In one case, TRAFFIC found anoperation that encouraged customers to sendtheir knives or guns to the dealer who would,for varying prices, custom carve the handle orgrip and return the finished product.

Yet another segment of the US market forhippo ivory involves the sale of raw tusks.TRAFFIC found whole tusks available both oneBay and through other Internet sites, cateringto those who might want to carve itemsthemselves for various purposes. Unlike pre-carved hippo ivory, which would be priced bythe retailer or those who did the actual carving,this end of the market was largely priced bythe size and quality of the individual tusks.For example, TRAFFIC found one business inWashington State, mentioned earlier, that soldraw tusks in three varieties: “lower curved,”“hippo straights,” and “upper curved.” Lower-curved tusks available ranged from 1 1/4inches in diameter and 7 1/2 inches in lengthto 2 1/2 inches in diameter and 17 inches inlength, and varied in price from USD20 to 130.Hippo straights ranged from 1 1/8 inches indiameter and seven inches in length to 1 3/4inches in diameter and 14 inches in length, andsold for USD38 to 215. Upper-curved tusksranged in size from 1 1/4 inches in diameterand six inches in length to 1 1/2 inches indiameter and 7 1/2 inches in length to 1 1/2inches in diameter and 11 inches in length, andranged in price from USD20 to 65. TRAFFICnoted that the business offering these tusks hadimported 36.5 kg of hippo ivory identified asteeth between 2000 and 2002 (TRAFFICanalysis of USFWS LEMIS data, March2004). Another Internet site, based inMississippi and also mentioned earlier, offeredhippo tusks seven to eight inches in length,with prices ranging from USD65 to 70.

Illegal TradeThe patterns and routes of illegal trade inhippo ivory take some of the same forms seenin the illicit elephant ivory trade. In bothcases, a percentage of the seizures reported byUSFWS stem from small amounts of illegalivory being discovered in the possession ofindividuals entering the USA. As withseizures of antique elephant ivory betweenEurope and the USA, TRAFFIC also found theoccasional seizure of shipments of hippo ivoryfrom major suppliers in Hong Kong andelsewhere, destined for regular commercialimporters in the USA. One difference betweenthe two trade patterns was the apparentabsence of instances of attempts to smugglelarge quantities of hippo ivory into the country.


Overall, TRAFFIC found far fewer recordedseizures of hippo ivory than elephant ivory.The ratio of seizures to cleared imports wasalso far lower. Whereas between 1995 and2002 LEMIS showed an overall 21% seizurerate for elephant ivory (1435 seizures ofelephant ivory compared to 6796 clearedimports), for hippo ivory the seizure rate wasapproximately 4% (93 seizures compared to 2481 cleared imports) (TRAFFIC analysis ofUSFWS LEMIS data, March 2004). That isnot surprising, given the greater level ofprotection afforded to elephants under CITESand the more elaborate rules governing legalimportation of elephant ivory under US law.

Of the hippo ivory shipments seized,TRAFFIC determined that that 62 (66%) werelikely noncommercial in nature, while 31(34%) were commercial; however, thecommercial shipments accounted for themajority of the ivory confiscated. Forexample, the noncommercial seizures totaledonly 133 pieces, including carvings, teeth, andjewelry. These items tended to be seized insmall quantities from individuals entering theUSA from African range states, mostprominently South Africa and Zimbabwe.Other nations or jurisdictions from whichapparently non-commercial shipments wereconfiscated included Belgium, Cameroon,Canada, Ethiopia, Hong Kong, Kenya, LaoPDR, Nigeria, Singapore, Tanzania, Viet Nam,and Zambia (TRAFFIC analysis of USFWSLEMIS data, March 2004).

By contrast, the 31 commercial hippo ivoryshipments seized accounted for 1067 ivorypieces, including 677 carvings, 254 teeth, and18 jewelry items. The majority of these items(737, or 69%) entered the USA from HongKong, often destined for companies thatappeared in LEMIS records as regularimporters of hippo ivory. Other countries fromwhich apparent commercial shipments ofillegal hippo ivory were confiscated includedBelgium, China, Ghana, Malaysia, Morocco,South Africa, the UK, and Zimbabwe(TRAFFIC analysis of USFWS LEMIS data,March 2004).

This seizure pattern suggests that individuals—perhaps tourists—account for the majority oftotal seizures by shipment. However, becausesuch seizures involve only individual pieces or

small lots of ivory, the majority of the overallhippo ivory seized comes from commercialsources. The fact that the importers andexporters from which the ivory was seizedwere often the same as those that reportedregular legal shipments of hippo ivory suggeststhe need for continued vigilance of this aspectof the trade.

The Impact on HippoPopulationsBecause it is difficult to calculate with anyprecision how many hippos the US trade datarepresent, it is similarly difficult to determinethe possible impact that the US trade in hippoivory may be having on the species in thewild. In 1995, TRAFFIC’s statement insupport of the CITES Appendix II listing forthe species noted estimates by Eltringham(1993) that the total hippo population inAfrica was conservatively estimated atapproximately 157 000 animals (TRAFFICand IUCN/SSC, 1994).

In 1999, the CITES Animals Committeeinitiated a Significant Trade Review for thespecies, to determine the potential impacts oftrade and other activities on hippo populationsin Africa. That report found that, among theprimary countries of origin for hippo ivoryentering the world market—and by implicationthe US market—hippo populations wereconsidered stable in South Africa, Tanzaniaand Zimbabwe, and increasing in Zambia. Theonly country that has appears regularly inrecent hippo ivory trade data for which the


Upper and lower canines and incisors are the mostcommon sources for hippo ivory, which may be used incarvings, scrimshaw, and knife handles.

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Significant Trade Review found a decreasingpopulation was Uganda; however, thedocument noted that much of the poaching hadtaken place in earlier decades during a periodof civil strife (CITES, 1999).

The Animals Committee issuedrecommendations for Botswana, theDemocratic Republic of Congo, Malawi,Mozambique, Rwanda, South Africa, Tanzania,Zambia, and Zimbabwe (TRAFFIC andIUCN/SSC, 2004). Most significant amongthose recommendations was the imposition ofa CITES export quota for exports of hippoteeth from Tanzania, which as seen above wasby far the largest source of supply for theworld hippo ivory market between 1995 and2002. Consequently, CITES established an

export quota for Tanzania beginning in 2001 of10 598 kg of teeth per year, composed of theteeth and hunting trophies of 1200 animals(UNEP/WCMC, 2004b).

Recent concerns have also been expressedregarding population declines in Burundi andin parts of the Democratic Republic of Congo(TRAFFIC and IUCN/SSC, 2004). However,beyond concerns for declines in specificpopulations, which may involve both huntingfor hippo ivory and other concerns in strife-torn countries, TRAFFIC detected noindications that trade levels during the period1995 to 2002 had a significant impact onoverall hippo populations. Both trade andpopulation levels deserve continued monitoringand regulation.


Based on the above information, TRAFFICdrew several conclusions regarding the statusof the US trade in elephant and hippo ivory.

• The USA remains an active player in theinternational ivory trade. Between 1995and 2002, the USA legally imported morethan 5400 shipments of worked ivory invarious forms, involving more than 32 500 ivory items in the form ofcarvings, worked tusks, jewelry, pianokeys, and other items. During the sameperiod, the USA exported 1055 shipmentsof elephant ivory involving some 8600carvings as well as smaller amounts ofitems in the form of tusks, jewelry, andpiano keys.

• This trade is dominated by a fairlylimited number of primary importers andexporters, and involves both commercialand non-commercial activity. Europe—the UK in particular—is the principalsource of worked elephant ivory enteringthe USA legally. The UK and otherEuropean nations are also the primarydestination for ivory exports from theUSA. The USA engages in far morelimited legal ivory trade with nations inAsia, Africa, and other regions aroundthe world.

• The USA also continues to import raw orunprocessed ivory in the form of sport-hunted African elephant tusks. Between1995 and 2002, the USA reported 1328such trophy imports. However, the exactnumber of tusks actually imported couldnot be determined, because USFWSimport data did not specify whether eachsuch trophy import represented elephanttusks, and if so whether the shipmentincluded one tusk or two. If each trophyshipment included two tusks, theseimports would represent as many as 2656raw tusks entering the USA during theeight year period analyzed.

• The full extent of the US domestic ivorymarket remains difficult to quantify.Because the US federal government hasonly limited authority to regulate orprohibit intrastate trade, and individualUS states have not assessed or quantified

ivory markets in their jurisdictions, thereis no reliable information about howmuch ivory is actually being traded in USmarkets. TRAFFIC’s research indicatedthat the domestic trade appears to bediffuse, with ivory products available atthe retail level from shops and galleries,auction houses, estate sales, and otheroutlets. Elephant ivory in various formsis also readily accessible over the Internetthrough eBay and specialty sites.

• In addition to the sale of workedelephant ivory in the form of antiquecarvings and other objects, TRAFFICfound evidence of a limited domesticcarving industry for raw ivory. Items inthe trade include ivory components forpool cues, knife and gun grips, and othercommercially available items. As withthe antique trade, the full scope of thedomestic trade in raw ivory amonghobbyists and those buying and sellingthe commodity for commercial purposesis not known. Further investigation willbe required to determine the extent andpossible significance of this aspect of theUS market.

• Along with legal trade, there is ampleevidence of continuing illegal trade inivory into the USA for both commercialand non-commercial purposes. USFWSand other agencies that monitor wildlifetrade at the nation’s borders recorded theseizure of more than 1400 ivoryshipments between 1995 and 2002 fromsome 80 different nations. Many of theseseizures were individual ivory piecestaken from individuals, and likelyrepresented curios or souvenirs beingbrought into the USA by tourists or otherUS citizens for non-commercialpurposes. Other seized ivory came fromcommercial shipments between antiquedealers, auction houses, and othersinvolved primarily in the ongoing trans-Atlantic ivory trade. In addition, inrecent years there have been casesinvolving the smuggling of commercialvolumes of ivory concealed in variousways into the USA.


CONCLUSIONS AND RECOMMENDATIONS

• TRAFFIC also found a disturbing patternof Internet trade in apparently illegalworked ivory in the form of carvings,jewelry, and other items entering the USAfrom China. The ready availability ofsuch ivory to US customers represents apotentially significant gap in efforts tomonitor and regulate the ivory trade.

• The contemporary US trade in hippoivory is larger by volume than is thecurrent trade in elephant ivory. Importsof this commodity in the form of itemsrecorded as ivory carvings, tusks, andteeth enter the USA primarily throughHong Kong, with a secondary pipeline ofhippo ivory imports directly from Africanrange states.

• The primary source countries for hippoivory entering the USA were Tanzania,South Africa, Zambia, and Zimbabwe.Although some imports came directlyfrom these nations and others in the formof trophies, the majority of the traderepresented commercial shipments oflikely pre-worked ivory.

• As with the trade in elephant ivory, thetrade in hippo ivory is dominated by alimited number of export and importcompanies. However, unlike elephantivory, hippo ivory tends to be imported intothe USA in bulk shipments of sometimeshundreds of pieces. The ivory is thendistributed and sold within the USAthrough both retail and Internet outlets.

• The trade in hippo ivory also differs fromthat of elephant ivory in that raw ivory inthe form of tusks and teeth can be legallyimported and sold. Although USFWSimport records do not specify whatpercentage of hippo ivory is imported intothe USA in raw form, TRAFFIC foundcompanies importing hippo tusks and thenselling them domestically to customersinterested in converting the ivory intofigurines, knife and gun grips, and otheritems.

• TRAFFIC found that carved hippo ivoryserves a market niche similar in form andprice to the carved elephant ivory beingimported into the USA from China. Thishippo ivory, which is carved primarily in

Hong Kong, is available from both USand foreign sources.

• Along with legal trade, TRAFFIC found adegree of illegal trade in hippo ivoryentering the USA. As with elephantivory, this trade involved both smallamounts of ivory seized from individualsat US points of entry, and bulkcommercial shipments occasionallyconfiscated by authorities. However,TRAFFIC did not find evidence ofcommercial smuggling of hippo ivorysimilar to that seen in recent yearsinvolving elephant ivory.

Based upon these conclusions, TRAFFICmakes the following recommendations:

• USFWS, in cooperation with statewildlife authorities, should undertake aninitiative to determine the nature andscope of the US domestic ivory carvingindustry. Although TRAFFIC found noevidence of a significant domestic carvingindustry, the scattered examplesdiscovered in the research for this reportindicate that there continue to becompanies and individuals carving rawivory for commercial purposes within theUSA. This raises obvious questions aboutthe source of the tusks, the volume of thetrade, and whether the activity is beingcarried out in compliance with relevantfederal and state laws and regulations.Even if this aspect of the US ivory marketis very limited as is likely, understandingits extent and dynamics would assist notonly in efforts to monitor and regulate theUS trade in raw ivory, but would alsoenhance US compliance with theprovisions of CITES Resolution Conf.10.10 (Rev. CoP12).

• Funding for the USFWS wildlifeinspection program and related activitiesby US Customs and Border Protectionneeds to increase. USFWS has noted thatthe USA’s focus on monitoring andpolicing the ivory trade concentrates onfederal efforts at the border. Furthermore,to the extent that continuing illegal tradein ivory is driven by tourists who areknowingly or unknowingly breaking thelaw by trying to import elephant ivorysouvenirs or curios into the USA, the


most effective line of defense remainsborder inspections. Although the USAhas perhaps the most effective lawenforcement system in place today tohandle this problem, the fact that in recentyears USFWS has not had a fullcomplement of trained wildlife inspectorsmay be undercutting this vital element ofthe US response to illegal ivory trade.

• Enhanced funding is also needed to expandspecial operations and undercoverinvestigations to identify and eliminatemarkets for illegal ivory within the USAand abroad. Although infrequent, thecontinuing phenomenon of cases of ivorybeing smuggled into the USA incommercial quantities suggests thecontinuing presence of an undergroundmarket. The presence of operations innations such as China sending a steadystream of elephant ivory into the USA viaInternet sales would also suggest the needto enhance cooperative internationalinvestigations to address the illegal trade insource nations as well as within the USA.

• At the same time, USFWS,nongovernmental organizations (NGOs),and others should work with companiessuch as eBay to better police the sale ofelephant ivory across internationalboundaries via the Internet. Eliminatingthe ready access to Internet “stores” suchas those doing business from China wouldhelp to enhance overall US enforcementof its CITES obligations. If effectivemeans cannot be found to ensure thatsuch trade is carried out in compliancewith CITES and domestic US wildlifelaws, major sites such as eBay shouldconsider prohibiting international ivorysales through their services.

• Public agencies such as USFWS shouldincrease efforts to heighten awarenessamong consumers (tourists, etc.) andpotential vendors (Internet sites, antiquedealers, auction houses, retail operators,etc.) within the USA and abroad aboutwhat is legal and illegal with regard totrade in ivory. NGOs can assist theseefforts by disseminating informationthrough membership and publicinformation bulletins or other media,

publishing accurate and impartial updateson ivory trade issues, and conductingeducation and public awareness programsto inform the public about the ongoingproblem of illegal ivory trade.

• To help accomplish this, the USA shouldconsider the feasibility and efficacy ofincreasing the penalties for those caughtbringing illegal ivory or other illicitwildlife products into the country, andthen placing those funds into a dedicatedaccount to enhance public awarenessregarding illegal wildlife trade. Undersuch a scenario, those caught illegallyimporting wildlife or wildlife productswould not only face substantiallyincreased monetary penalties for eachitem seized as a deterrent, but theproceeds from those violations would godirectly to financing programs to bettereducate US tourists and others about theillegal wildlife trade. USFWS and othersshould study whether such an approachmight generate sufficient resources tohave a tangible effect on public educationand enforcement efforts.

• The USA should consult with nationsidentified as major sources of ivoryentering the country about ways to bettercoordinate and standardize rules regardingongoing legal trade in ivory. Forexample, while the USA considers“antique” ivory to be ivory that is at least100 years old, the European Union (EU)sets the standard for antique ivory at 50years. Such differing definitions andrules have created potential confusion andconflict regarding what ivory is allowedin the marketplace. To the extent thatlegal international trade in elephant ivoryis to be allowed to continue, theinternational community should work tocreate a single set of standards.

• Finally, USFWS should improve the waythat it records imports and exports of bothelephant and hippo ivory into and out ofthe USA. Specifically, LEMIS dataavailable for this report did not enableTRAFFIC to determine the precisenumber of elephant tusks entering thecountry annually as trophies, which is animportant measure because such trophies


represent the only raw elephant ivoryentering the USA legally at present.Some elephant trophy shipments werereported as a single unit, while otherrecords showed a single shipment ofmultiple “trophies.” USFWS shouldchange the way it records such shipmentsto specify the number of raw orunprocessed elephant tusks beingimported. USFWS should make the samedistinction regarding the number of hippo

teeth being imported in trophy shipments.Also regarding the hippo ivory trade,TRAFFIC could not always distinguishwhether imports of “teeth” representedraw or worked ivory, making it impossibleto calculate the amount of raw hippoivory entering the USA on an annualbasis. USFWS should clarify its methodof recording hippo tooth imports toclearly distinguish between raw andworked ivory.


CITES (1999). Trade in Wild-caught Animal Specimens: A Review of Selected Animal Species.Draft Report to CITES Animals Committee prepared by WCMC, IUCN/SSC and TRAFFICInternational. AC15.14.4.

CITES (2003a). How CITES works? http://www.cites.org.

CITES (2003b). The CITES species. http://www.cites.org.

CITES (2004a). What is CITES? http://www.cites.org.

CITES (2004b). CITES Resolution Conf. 10.10. Trade in elephant specimens.http://www.cites.org/eng/resols/10/10_10.shtml.

CITES (2004c). CITES Decisions 12.36–12.39. Elephants—control of internal ivory trade.http://www.cites.org/eng/decis/valid12/12-36_39.shtml.

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Courouble, M. Hurst, F., and Milliken, T. (2003). More Ivory than Elephants: Domestic IvoryMarkets in Three West African Countries. Traffic International, Cambridge, UK.

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Martin, E. B. and Stiles, D. (2000). The Ivory Markets of Africa. Save the Elephants, Nairobi andLondon.

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Milliken, T., Burn, R. W., Underwood, F. M., and Sangalakula, L. (2004). The Elephant TradeInformation System (ETIS) and the illicit trade in ivory: A report to the 13th Meeting of theParties to CITES. TRAFFIC East/Southern Africa, August 2004. COP 13 Doc. 29.2.

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REFERENCES

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TRAFFIC and IUCN/SSC (2004). Taxa Identified as Possible Candidates for Inclusion in theReview of Significant Trade in Specimens of Appendix-II Species. Paper prepared byTRAFFIC and the IUCN/SSC Wildlife Trade Programme for the Twentieth Meeting of theCITES Animals Committee, Johannesburg, South Africa, 29 March–2 April 2004. AC 20,Doc. Inf. 12.

UNEP/WCMC (2004a). Loxodonta africana. CITES-listed species database. http://www.sea.unep-wcmc.org/isdb/CITES/Taxonomy.

UNEP/WCMC (2004b). Hippopotamus amphibius. UNEP-WCMC Species Database.http://www.sea.unep-wcmc.org/isdb/Taxonomy.

USFWS (1989). Moratorium on importation of raw and worked ivory from all ivory producing andintermediary nations. Federal Register, Vol. 54, No. 110. Friday, June 9, 1989, pp.24758–24761.

USFWS (1999). African Elephant ivory fact sheet. US Fish and Wildlife Service Division ofManagement Authority, Arlington, VA, November.

USFWS (2001). Ivory Coast citizen convicted in New York federal court. USFWS Press Release,August 1.

USFWS (2002). ESA basics fact sheet. US Fish and Wildlife Service Endangered Species Program,Arlington, VA, October.

USFWS (2003a). Importing your leopard or African Elephant trophy fact sheet. US Fish andWildlife Service Division of Management Authority, Arlington, VA, Summer.

USFWS (2003b). Asian Elephant ivory fact sheet. US Fish and Wildlife Service Division ofManagement Authority, Arlington, VA, Summer.

USFWS. (2003c). FY 2004 law enforcement budget request. US Fish and Wildlife Service,Washington, D.C.

USFWS. (2004a). Wildlife ports of entry and exit.http://www.le.fws.gov/Info_Importers_Exporters.htm.

USFWS. (2004b). West African art dealer indicted on ivory smuggling charges. USFWS PressRelease, March 3.


TRAFFIC, the wildlife trade monitoring network, works toensure that trade in wild plants andanimals is not a threat to theconservation of nature. It hasoffices covering most parts of theworld and works in close co-operation with the Secretariat of theConvention on International Trade inEndangered Species of Wild Faunaand Flora (CITES).

For further information contact:

The DirectorTRAFFIC North America

c/o World Wildlife Fund-US1250 24th Street, N.W.

Washington, D.C. 20037Telephone: 202-293-4800

Fax: 202-775-8287Email: [email protected]

Web Site: www.traffic.org

tackling the ivories - traffic · 2018-06-29 · hippopotamus hippopotamus amphibius,to mammoths...

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