Proposed return to ivory and rhino horn trading

Stephen Wiggins Article 2 Comments

Banner image courtesy of Environmental Investigation Agency

Petition: “Don’t let CITES delist Elephants and Rhinos as endangered animals!,” Care2Petitions


The Convention on International Trade in Endangered Species of Flora and Fauna (CITES), will be holding its eighteenth Conference of the Parties (CoP18), Colombo, Sri Lanka, 23 May – 3 June 2019 [Update: CoP18 Postponed (26 April 2019) and moved to Geneva, Switzerland, 16 – 28 August 2019 – relevant message from the CITES Secretary General].

There is a preliminary list of submissions for consideration at CoP18. Of those submissions, two relate to the African elephant (Loxodonta Africana):

CoP18  Prop. – “Amendment to Annotation 2 pertaining to the elephant populations of Botswana, Namibia, South Africa and Zimbabwe

This submission’s proposal promotes trade in ivory and elephant derivative products. The submission proposes the removal of Annotation 2, Clause h), which potentially allows  Botswana, Namibia, South Africa and Zimbabwe to seek to trade in government registered stockpiled ivory 9 years after CoP14 and the last CITES sanctioned sale of ivory in 2008.

How does the proposal to increase the supply of elephant ivory not risk stimulating/legitimising demand and thus potentially promoting more poaching of elephants to illicitly obtain and supply such products? Where is the independent science that says allowing ivory to be traded from registered stockpiles at this time will not be detrimental to the species?

Note: There is a counter submission to remove the Appendix I exemption that the elephant populations of Botswana, Namibia, South Africa and Zimbabwe are currently subject to (downlisted to Appendix II) – “This amendment is justified according to the following criteria under Annex 1 of Resolution Conf. 9.24 (Rev. CoP16), Criteria for amendment of Appendices I and II: “…. A marked decline in population size in the wild…” It is hoped that this submission might be successful, but a similar submission (CoP17 Prop. 16) was rejected in 2016.

CoP18 Prop. – “Zambia proposes that the population of African elephant (Loxodonta africana) of Zambia be downlisted from Appendix I to Appendix II

The concern is that this submission seeks to open up trade by downlisting Zambia’s elephants from Appendix I to Appendix II – thus allowing export permit only trade in registered raw ivory, trade in hunting trophies (supposedly) for ”non-commercial purposes” and trade in hides and leather goods.

At the moment, there is no submission from South Africa regarding the white rhinoceros (Ceratotherium simum) and black rhinoceros (Diceros bicornis) and opening up international trade in farmed/harvested rhino horn.

However, the Kingdom of Eswatini (formerly Swaziland, which made a submission to CoP17 Prop. 07) has  resubmitted a submission, “To remove the existing annotation on the Appendix II listing of Eswatini’s southern white rhino population and for “… Eswatini to sell from existing stock 330 kg of rhino horn to licenced retailers in the Far East and also up to 20 kg p.a., including harvested horn, to those retailers” along with arguments in support of such trade and rhino farming/horn harvesting – but with no independent science that support such trade as not risking stimulating demand and poaching. Acceptance of this submission would open the way for others (such as South Africa) to follow suit.

Namibia has sought via its submission to CoP18 to downlist its white rhino from Appendix I protection (to Appendix II) “For the exclusive purpose of allowing international trade in:

a) live animals to appropriate and acceptable destinations; and
b) hunting trophies”

Note: The reasons given by Namibia are: “Hunting for trophies (referred to as conservation hunting in Namibia) is recognized as a valuable management tool which provides much-needed revenue for rhinoceros conservation. Trade in live animals is similarly important for income generation in support of protection measures. Transferring the population to Appendix II will enable Namibia to export live animals and hunting trophies to more countries and will increase revenue through sustainable use.”

“Hunting for trophies is recognized as a valuable management tool (sic)…” – where is the science to back that and the 100% guarantee that such income leads directly to conservation? Putting some of the income so derived into a Game Product Trust Fund does not equate to conservation.

Conf. 11.20 (Rev. CoP17) defines ‘appropriate and acceptable destinations’ for live animals should be those that ensure that the animals are “humanely treated” – how does endorsing the potential export of live rhinoceros (elephants, lions, tigers etc. for that matter) to China for commercial gain (whether it is masked as scientific, or zoo exhibits) ensure such animals are and always will be, “humanely treated?” For example, China has inhumane tiger farms in contravention of CITES Decision 14.69 (2007), so what’s to stop the inhumane exploitation of any live specimens, such as rhino so exported to China?

What can we do? Write to your country’s CITES representative and urge them not to support the referenced submissions seeking to trade raw ivory and derivative elephant products (rhino trophies, horn and specimens etc.). For the United Kingdom of Great Britain and Northern Ireland, the contact details are given as:

Elaine Kendall
Head of CITES Policy Team
Department for Environment, Food and Rural Affairs (Defra)
Natural Environment Policy
Floor 2
Horizon House
Deanery Road,

Email: [email protected]

IWB’s letters to the UK Head of CITES Policy Team:

“Elephant Ivory and Derivative Products Trade CITES CoP18 , 23 May – 3 June 2019, Sri Lanka,” IWB, 14 January 2019

Rhino Trophy Hunting and Rhino Horn Trade CITES CoP18, 23 May – 3 June 2019, Sri Lanka,” 17 January 2019

Further reading:

CITES – the trade system that doesn’t know that it doesn’t know,” Lynn Johnson, Daily Maverick, 17 January 2019

Undercover investigation exposes illegal wildlife items, including elephant skin furniture, hippo skull table and stingray belts, for sale at Safari Club International’s 2019 convention,” The Humane Society of The United States, 18 January 2019


Comments 2

  1. Pingback: Trophy Hunting Culture – International Wildlife Bond

  2. Pingback: “Their Future Is Dark.” The Rhino Horn Trade in 2019 – International Wildlife Bond

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