Ivory Trade in The United Kingdom

Stephen Wiggins Article, Petition 3 Comments

Banner Image “Elaborately Carved Tusks” Courtesy of  Kate Wong

UK Petition –  “Shut down the domestic ivory market in the UK

The United Kingdom Ivory Trade – Should there be a blanket ban on all ivory trading?

Let’s take a look at the high end of the ‘legal’ antique ivory trade.

Antique Trader Gazette

Figure 1 – Antiques Trade Gazette, No. 2252, “The Great Ivory Debate – Seeing the elephant in the room: both sides of the ivory trade debate,” 26 July 2016


In July 2016, Action for Elephants (Endangered Species Protection Campaigners – Jane Alexandra and Louise Ravula) met with antique industry representatives to “test the perceived role of ivory-based antiques in fuelling demand for modern ivory” (“modern ivory” in this context of course means ivory sourced from elephants post 1989).

Does the continued practice of holding antique ivory in highly elevated esteem perpetuate the desire for ‘modern ivory,’ fuelling demand and the inevitable poaching of present day elephants to meet that nonsensical demand? Does ‘legal’ ivory trading provide cover for ‘illegal’ infiltration?


Figure 2 –   Example of antique ivory held in high esteem – “The government has imposed an export bar on two ivory statuettes by Balthasar Permoser (1651-1732), allowing UK buyers the opportunity to match the £1.8m price before they leave the country,” Antique Trade Gazette, 15 August 2016


I say “nonsensical demand,” because the demand for ‘modern ivory’ is predominantly being carried on a wave of new Asian wealth (where ivory is also seen as status symbol), but at the same time the buyers predominantly want the donor species (elephants) to survive! There is a clear contradiction, the obvious answer being, well don’t worship/buy ivory then, let the elephants keep it.


Figure 3 – “Young people see ivory as a way to project an image of wealth and high social status” – Photograph by James Morgan, Panos


Would releasing stock-piles of stored ivory help quell the demand? History says ‘no,’ seeking to ‘quell’ demand has had very much the opposite effect, with any ivory ‘trade’ sending the tacit message that it’s acceptable to treat ivory (and its unwilling donor, the elephant) as a highly valued commodity.


Figure 4 – Stock-piled ivory

The same ‘debate’ is currently being mooted for rhino horn harvesting to ‘quell’ demand and attempt to  alleviate alarming rhino poaching statistics, but the approach runs the significant risk of doing anything but quelling demand/poaching. However, rhino horn, which is made of keratin (like one’s own fingernails), grows back after harvesting (with the donor, farmed rhino under aesthetic). An elephant’s tusk is a tooth, thats removal in any form is unlikely not to result in the elephant’s death through infection, but of course poachers just kill the elephant (or rhino) in the first place, with no regard for sustainability or any animal welfare concerns whatsoever.

So, let’s get back to our ‘antique ivory’ traders and any anecdotal evidence that this continuing trade also sends out the message that it’s acceptable to treat all ivory (and its unwilling donor, the elephant) as commodity. The ‘antique ivory’ trade thinks not:

For one thing, there was little evidence produced of a real link between modern poaching and antique ivory”  (Antiques Trade Gazette, Comment),  continuing to firmly reassure that the antiques trade “has no interest whatsoever is selling modern ivory and believes only in the controlled trade of genuine works of [ivory] art, made across the millennia”  (Antiques Trade Gazette, No. 2252).

Of course, it is important to try to make a distinction between the illegitimate trade in ‘modern ivory’ and trade in ‘antique’ ivory. But this distinction is irrelevant to the traders that do not care about whether the ivory they seek to sell is “pre-convention” or otherwise. There is clear evidence that poached ivory has infiltrated elements of the ‘legal’ trade:

An IFAW report (2004) on United Kingdom ivory trading practices found that “nearly all ivory being sold in antique shops, fairs, auctions and art centres in the UK is being sold illegally, without either the required proof of age or necessary permits from the Government’s Department for the Environment, Food and Rural Affairs (Defra).”

Plus, the report highlighted the burgeoning arena of internet based trading in ivory of dubious source –  “In over 90% of cases followed up by IFAW, Internet sellers – often frequent dealers in ivory – said they were either unaware of the laws about selling the substance, or were aware of the laws but ready to forge documents or break the law in other ways in order to make a sale.”

The IFAW report was also damming, concluding that “The UK is the third biggest source of intercepted illegal ivory entering the United States of America (US),which has been singled out by CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora) as a ‘problem country’ with a large domestic ivory trade likely to provoke illegal elephant poaching if not regulated and brought under control. London’s Portobello Road – the biggest antiques market in the world – has been identified as the single major source of this illegal ivory” – IFAW report (2004)

The UK’s domestic ivory market provides ample cover for illegal activity. Between 2009 and 2014, 40% of all the seizures made by the UK’s Border Force were ivory items and in 2015, 110kg of ivory were seized at Heathrow airport in one of the UK’s largest hauls of illegal ivory. This is just the tip of the iceberg as ivory sold legally in the UK domestic market is exported to illegal markets in other countries, contributing to high prices and fuelling demand for elephant products” – “Britain is hastening the extinction of the African elephant,” The Guardian, 7 August 2016


The British Antique Dealers’ Association (BADA) representative (Mark Dodgson) choose to reference(2) a 2005 report (“The Ivory Markets of Europe,” E Martin & D Stiles, 2005) where the majority of “776 shops and stalls” visited for the report “about 98% of the ivory items seen in London were antiques” or 98% was “pre-Convention” (pre-1975 CITES “Convention,” or pre-1989 CITES ivory ban implementation)* as Mark Dodgson puts it. However, it should be noted, that it’s not entirely made clear in the report(6) how the provenance of  the “pre-Convention” (all called “antiques” by E Martin & D Stiles(6)) ivory observed in the many “shops and stalls” by Martin and Stiles  was ‘categorically’ established in every case. The exact ivory dating/definition applicable needs to be clear and consistent, so let’s clarify the correct use of definitions(8) here:

* “Pre-Convention” – Within the EU(8) this means the 1989 CITES/EU Wildlife Trade Regulations ban implementation date in the Country/State where a given “worked” or “raw” ivory item was acquired, but in CITES terminology , “pre-Convention” means pre-CITES “Convention,” when CITES came into being in 1975,  (hence, why 1989 is the antique market’s  preferred benchmark);

Antique” is supposed to mean “worked” specimens acquired before 3 March 1947.

Perhaps the “pre-Convention” and “Antique” trade through legitimate auctioneers and dealers is  scrutinised with ‘good reputations’ at stake, but this does not mean there are no exceptions, or mistakes made through inexperience (wilful complicity even). The wider United Kingdom market is clearly not so scrutinised, regulated or reputable(5).

The whole question of reliably defining the age of any ivory piece (be that pre-1989 CITES ivory ban implementation, pre-1975 “Convention“, or pre-1947) often comes down to an appraiser’s opinion (by eye) of the carving style and ‘patina’ as key indicators of an ivory piece’s age, not any scientific based ageing techniques. Which begs the question, how easy would it be for a forger to recreate an “Antique” style and ‘patina’ that would fool an appraiser/auctioneer/dealer keen to facilitate a lucrative sale? Nobody wishes to cast aspersions, but the ‘integrity’ of any appraiser that uses their eye and ‘expertise’ to validate a valuable commodity must be questioned  (in the absence of any independent, third-party’s oversight).

Martin Levy (H Blairman & Sons Ltd.) suggests(2)The universal view was that the authentication of ivory is just not an issue.” Without scientific backing  for such a statement, I can only assume that this reliance on in-house ‘expertise’ provides the industry’s internal comfort.


The plight of the elephant is compelling (please refer to Appendix I below).

The United States has moved to ban ivory importation  with the final ruling coming into force on 6 July 2016. Since the IFAW’s (2004) damming conclusion that much of the illegal ivory entering the United States came via the United Kingdom, the United States has at least moved to try to stem any such illicit trade.

In April 2016, more than 100 tonnes of ivory (worth an estimated £70m) and 1.35 tonnes of rhino horn was stacked up in pyres in Nairobi National Park in a symbolic gesture to show Kenya’s determination and commitment to saving African elephants and rhino. The ivory/horn burnt represents nearly the entire stock confiscated by Kenya, amounting to the tusks of approximately 6,700 elephants and 450 rhino executed by poachers in the name of greed. The debate is whether such symbolic burnings increase poaching to satisfy demand for ivory, but at least it shows the contempt and distaste there is for the poachers and the ivory trade. This must be contrasted with the alternative stance being displayed by Zimbabwe and Namibia (refer to Appendix I) to expand ‘legal’ ivory trading from stock-piles and sustainable “utilisation.”


Figure 5 – On Saturday, 30 April 2016, Kenyan President Uhuru Kenyatta set fire to a huge stockpile of confiscated ivory


British antique dealers may be confident that the high end of the market for ivory is only in ivory pieces that pre-date the 1975 CITES “Convention,” or pre-1947 (“Antique“) caveats. But clearly, the entire United Kingdom market is not restricted to just BADA members; there are a whole range of outlets (on the high street and on-line) that fall outside of the ‘ideals’ and regulatory resource to ensure even the remotest level of compliance.

Is there the likelihood of a complete ban of all ivory trading (“Modern,” “pre-Convention” and “Antique“) anytime soon? In May 2016, the French minster of the Environment, Energy and the Sea, Ségolène Royal took the decision (after Kenya’s stock piled ivory burning, 30 April 2016) to announce an initiative to push for a total ban on ivory sales in France. The United States will purportedly be pushing for such a complete ban on ivory trading at the forthcoming (CITES), Conference of Parties (CoP17).

Update: “A near total ivory ban finalised in France,” IFAW, 17 August 2016

When any ‘ban’ is spoken of with exemptions mooted, it is the opportunistic space such exemptions offer where the rouges find room to find justification to infiltrate, prosper and tarnish all that participate. Unless exemptions are rigorously and independently vetted in minute detail (which implies vast resources and pre-requisite funding), then such exemptions become the yawning chasms that criminal syndicates rapidly envelop and exploit. Is there any realistic prospect that exemptions for “pre-Convention” and  “Antique” ivory could be accommodated with any ivory trade ban without on-going illicit infiltration? I think not.

The question must be, is there time to find out if any exemptions from a total ban on all ivory trading can be made to work? Wild elephant populations are being decimated at an alarming rate (reference Appendix I), which suggest there just simply isn’t the time to find out.

The world needs to decide very, very soon if it wants to value “Antique” ivory ‘trinkets’ more highly than living, sentient elephants that just want to survive and peacefully share planet Earth.

Does any trade in ivory (“pre-Convention” “Antique” or otherwise) legitimise the whole market, with ‘legal’ trade providing a cover for ‘illegal’ infiltration? The link might be anecdotal to some extent and inferred by association, but not entertaining the notion that there can be any such link (and its pressingly dire consequences for elephants) is a fallacy.


  1. WWF Ignores History at All Elephants’ Peril,” Dave Currey, 12 August 2016
  2. Seeing the elephant in the room: both sides of the ivory trade debate,” Antiques Trade Gazette, No 2252, 26 July 2016
  3. COMMENT: As the clock ticks on ivory antiques, there are three things the industry must do,” Noelle McElhatton, Antiques Trade Gazette, 26 July 2016
  4. The Theatre of Wildlife Decimation,” IWB, 7 March 2016
  5. Elephants on the high street an investigation into ivory trade in the UK” International Fund for Animal Welfare (IFAW) Report, 2004
  6. The Ivory Markets of Europe,” E Martin & D Stiles, 2005
  7. The Re-export of Pre-convention/Antique Ivory from the European Union,” Report prepared by TRAFFIC for the European Commission, August 2014
  8. The Re-export of Pre-convention/Antique Ivory from the European Union,” Page 6 – “In the EU, the trade in ivory is strictly regulated through the provisions of Council Regulation (EC) No. 338/97. Within the EU, trade is allowed under prescribed conditions for antique ivory (“worked” specimens acquired before 3 March 1947) and pre-Convention ivory (“raw” or “worked” items acquired before the date on which CITES or the EU Wildlife Trade Regulations became applicable to them in the country in which they were acquired.) It is noted that the EU Wildlife Trade Regulations do not include the concept of “pre‐Convention” specimens as understood by other CITES Parties. Consequently, CITES pre‐Convention certificates issued by third countries are normally not accepted in the EU. The rules in the EU are based on the date when the provisions of the EU Wildlife Trade Regulations or CITES became applicable to the specimen in the EU Member State of concern (i.e. when the EU Member State joined CITES or became a Member of the EU), and not only on the date the species was listed in the CITES Appendices or the EU Wildlife Trade Regulations Annexes. Therefore, for example, the relevant “pre-Convention” reference date for African Elephant ivory items acquired or imported into the EU is not necessarily January 1990 when the species was up-listed to CITES Appendix I – for further details see Figure 8 of the Reference Guide to the EU Wildlife Trade Regulations (European Commission and TRAFFIC, 2013, at p.71) on the application of the derogation relevant for export or re‐export of “pre‐Convention/pre‐Regulation” specimens from the EU, contained in Article 5(6)(ii) Regulation (EC) No 338/97. It should be ensured that this derogation is being implemented uniformly across the 28 EU Member States.”

Appendix I – The Elephant and CITES 

In Africa and Asia elephants are being poached for their tusks in unprecedented numbers – between 35,000 and 50,000 every year – simply to satisfy consumer demand for ivory trinkets” – Action for Elephants

Based on CITES (Convention on International Trade in Endangered Species of Wild Flora and Fauna) data, African elephant poaching might be stabilising (2015 data), but not at a level that will allow elephant population numbers to recover.

It is estimated that there might be 500,000 elephants left. Back in the early part of the 20th century, there may have been as many as 3-5 million elephants. The decline is cited as due to range loss (since 1979,  elephants have lost over 50% of their range), trophy hunting and poaching for the illegal ivory trade.

So, how has elephant poaching become so prolific and the trade in ivory so widespread when the African elephant is a CITES Appendix I protected species? Well, one needs to look back at the history and CITES’ naïve belief that it could ‘quell’ demand from ivory stockpiles and hence ‘manage’ the elephant poaching issue.

So, what is being done to try and save the wild elephant from the threat of extinction?

Convention on International Trade in Endangered Species of Fauna and Flora (CITES), Conference of Parties (CoP17)

CITES CoP17 Logo

As we approach CITES CoP17 (Proposal 14, 15 and 16) (24 September – 5 October 2016), some parties wish to expand ivory trading (notably Namibia and Zimbabwe), whilst others seek to ‘Uplist’ the African elephant (Loxodonta africana) to Appendix I to curtail ivory trading:

In Proposal 14, Namibia is seeking removal of restrictions on its elephants from CITES Appendix II listing annotation, but has also joined Proposal 15 with Zimbabwe, which also seeks to remove the same  annotation that restricts trade in elephant ivory:

no further proposals to allow trade in elephant ivory from populations already in Appendix II shall be submitted to the Conference of the Parties for the period from CoP14 and ending nine years from the date of the single sale of ivory that is to take place in accordance with provisions in paragraphs g) i), g) ii), g) iii), g) vi) and g) vii).

Meanwhile, Proposal 16 seeks to add the current Appendix II populations of Botswana, Namibia, Zimbabwe and South Africa to Appendix I listing. The proposal is supported by 29 African states of the African Elephant Coalition.

Zimbabwe has threatened to withdraw from CITES if its wish to be free to trade ivory is not granted by the international community. Zimbabwe’s ‘plea’ has been somewhat embarrassingly tarnished by its own flawed economic argument in support:

Zimbabwe’s Environment minister, Oppah Muchinguri has stated in parliament (30 July 2016) that Zimbabwe’s ivory stock-piles are worth some “$9.6bn USD” (based upon ivory being worth $100,000 USD/kg by Finance minister Patrick Chinamasa). This would equate (based upon Billion = 109) to a Zimbabwe having an ivory stock-pile of some 96 tonnes.

At an average male bull tusk weight of 62.5kg (137lbs), and an adult female tusk weight of 19kg (41 lbs), then taking a weighted average (of tusk weight of 45kg) we can assume the mooted Zimbabwean “ivory stock-pile” equates to a minimum of some 2,134 tusks (or a minimum of some 1,067 elephant lives, but probably a much, much higher mortality level was required).

However, in reality, ivory is reportedly selling for around $1,000 USD/kg (some $2,000/kg on the black market), a whole massive tusk maybe worth some $50,000 USD. So this would give a value to the Zimbabwean “ivory stock-pile” of between $96m USD and a theoretical maximum of $192m USD – which makes Zimbabwe’s claim of a value of “$9.6bn USD” look absurd.

Zimbabwe’s economy is in freefall, but the ability of its ministers to even present reliable, basic numbers appears to perhaps point to where the fault lies with the country’s economic mismanagement.

Surprisingly, the opening up of ‘legal’ trade in ivory has its supporters in unexpected circles; the World Wildlife Fund (WWF) being vocal in “Uniting Against the Illegal Ivory Trade” but at the same time, ignoring the historical perils of continuing to advocate for ‘legal’ ivory trading routes being opened up.

Petition – “High Time for a Complete and Permanent Ban on All Ivory Trade



Petition – Europe: Stop the slaughter” – Call for a global ban on Ivory


Comments 3

  1. Dominique

    I wonder if the UK exiting the European Union, at the same time resisting a ban on all ivory trading is now a tool for them to continue to be the ones to hasten the Elephants, Rhinos demise and extinction for the special interests of London’s Portobello Road. I really hope that Cites can establish a complete ban on all Wildlife “parts” trading at CoP17, disgust and shame on the UK, Zimbabwe, Namibia and China forever for what they have done.

  2. Pingback: Unmanageable Animal Exploitation – International Wildlife Bond

  3. Pingback: UK Auction Houses Ignoring ‘Legal’ Ivory Trading Requirements – International Wildlife Bond

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