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Tomomi Kitade IVORY TRADEINJAPAN AN UPDATEDREVIEWOFONLINE 4 Kitade, T. and Toko, A(2016). 3 Milliken, T. Underwood, F.M., Burn R.W., and Sangalakula, L.(2016). 2 Excluding whole tusks and semi-processedivory. Multiple items offered inasingle lot were countedseparately as individual pieces. Law1 The Conservationfor the of Endangered of Species Wild Fauna and Flora (LCES), reformed in June 2017 for enactment in2018, completelycases, without regulatory control. The proof of legality the at product level LCES regulations leave other domestic all with only trade ivory limited and, insome possession. While such measures build on existing the controls over businesses, the non-compliance and mandating businesses ivory to register whole tusks all intheir businessthe notification system to a registration systempenaltieswith increased for Endangered Speciesof Wild Fauna and Flora (LCES). Amendments include updating regulations trade ivory for businesses under Law the for of Conservation the the In June Japanese 2017,the government of strengthened internal aspects certain elephant was ivory introduced under CITESin1989. of Japan’slegacy former sustained boom trade ivory until international the ban of trade amongsttraded and dealers individuals. Thewide availability of old ivory products is a substantial and largely unregulated domestic market inold products ivory are which industry Asidesales. from estimated the USD19 million annual production by carving the importer alegal to be of context inthe ivory of two the CITES-approved one-off ivory in Endangered Speciesof Wild Fauna and Flora (CITES).Japan allowed hasbeen twice Information System process (ETIS) review andindustry is listed of as acountry “importance to watch” under Elephant the Trade Japan is home to along-standing domestic market ivory significant with astill carving BACKGROUND Trade in Ivory: Areport to the 17th meeting of the Conference of the Parties strengthenwill business ivory regulations. 4 , amajority on of is which based Setting Suns: The HistoricalDecline of Ivory andRhino Horn Markets in Japan hanko 3 of Convention the on International Trade The Elephant Trade Information System (ETIS) and the Illicit or name seal sales, there or sales, exists name a seal . CoP17. Doc. 57.6 (Rev.1). Doc. . CoP17. Annex. . TRAFFIC, Tokyo, Japan
©Steve Morello / WWF
1 TRAFFIC BRIEFING PAPER 本象牙
2 TRAFFIC BRIEFING PAPER 9 http://furimaalert.webcrow.jp/ 8 Matsumoto, T. (2015). 7 Xiao, Y., Jing, G.,and Xu, L.(2017). 6 CITESDecisions 17.92-17.96 5 Includes polished/unpolished tusks carved/uncarved, retaining curvature the of atusk 2017) was used. due to lack the of search functions for ratecurrency The purpose. this of JPY1=USD0.00900 (at 2nd June excluding wrappings, containers The or pedestals). results sales andof finalprice were trackednot on Mercari using final bidding price records of ivory items comprisingalmost exclusively (90% of ivory by appearance, a traditional Japanese musical instrument). OnYahoo Auction, total the value of was compiled trade ivory comprised one unit functional (e.g. apair of chopsticks, apair of or earrings, of aset bridges for the photos.the Individual items were counted separately offered when samethe in lot unless multiple parts authenticity the to ascertain of ivory, the but descriptions by were sellers adopted it when was not clear from as(ivory)” akeyword were day checked using asmartphone every app over previous the 120days). For CtoC the market site, Mercari, advertisement containing new alerts “zouge were using retrieved akeyword “zouge record and types number the of products. For Yahoo Auction, records of bidding successful during period this Ivory was monitored trade on Yahoo Auction and Mercari for four weeks May (8th to June 4th 2017)to Monitoring survey Inc. later introduced aban on of sales Rakuten-Ichiba ivory on 1st July 2017). total ivoryThese sales. aspects were supplemented theby monitoring survey. (It shouldbe noted that Rakuten, was intendedsurvey as aquick characterization and not as acomprehensive or representative sampling of searchedon specifically Yahoo Auction and Mercari sites to check compliancewiththe LCES. The snapshot advertisements were sampled for auction and CtoC market sites. Furthermore, whole tusks ivory were sellers/businesses. From search the shop results, was sampled every for shopping top the while 100 malls, and analysed information on products offered,the status of compliancewiththe LCES, theand nature of In May sample 2017,TRAFFIC collected webpages using akeyword “hon-zouge CtoC market, with latter the and anew being growing form of online trading. trends ine-commerce. Thetypes of online platforms werecategorized into: 1) shopping 2) mall; auction; 3) platforms was again employed but extended to include other major several platforms inorder to capture new used by TRAFFIC The methodology Snapshot analysis SURVEY METHODOLOGY inJapantrade and highlighted areas where lack the of regulatory provisions presents still seriouschallenges. Customer) and sector of increased use smartphone apps. This studypatternthe reassessed of online ivory likelywhich current affectthe pattern of trade, including online ivory growththe the of CtoC (Customer to Whileactivities. some other unaddressed issues continue to raise concerns, issues new have arisen also spots, major led which e-commerce companies to enforce relevant for rules users through their monitoring warrants scrutiny to prevent illicit TRAFFIC’s activities. in2014elucidated review enforcement certain weak to prevent trade wildlife illegal Globally, is increasingly as recognized cybercrime aseriouschallenge wildlife underminesefforts which the accordingly to eliminate potential loopholes for flows. ivory illegal other than whole tusks is delegated to avoluntary certificationscheme for new products, and regulation overtrade in any ivory items 3) CtoC markets: Mercari (https://www.mercari.com/jp/), (https://rakuma.rakuten.co.jp/) Rakuma 2) Auction: Yahoo Auction (https://auctions.Yahoo.co.jp/) 1) Shopping Rakuten-Ichiba malls: (http://www.rakuten.co.jp/), Yahoo Shopping (http://shopping.Yahoo.co.jp/) A Review of OnlineA Review Ivory Trade in Japan. Tokyo, TRAFFIC, Japan. 5 is non-existent.grey These areas in Japan’s domestictrade ivory be addressedmust Wildlife Cybercrmie in China: E-commerce and social media monitoring in 2016 6, 7 . While remain online sales ivory inJapan, legal of trade the sheer the scale 8 in the 2014study inthe of online on trade ivory major Japanese e-commerce 象牙 (ivory)” (Yahoo (ivory)” Auction’s search engine allows records viewing 9 . Advertisements were checked visually . TFAFFIC, Briefing Paper 本象牙 (genuine ivory)” koto , 11 http://www.meti.go.jp/policy/mono_info_service/mono/paper_consumergoods/20150812tebiki.pdf 10 https://about.yahoo.co.jp/pr/release/2014/09/01a/ http://topic.auctions.yahoo.co.jp/promo/infographic/#exhibits followed and by furnishings. carvings was found CtoC inthe market comprised sites, majority where the jewellery ivory of items offered forsale, by jewellery.patterns These were more or less similarwhat to was foundthe 2014 in survey. third The pattern whereas on auction the site, and furnishings such as carvings sites 1).For (Fig. shopping where malls products new are offered, The snapshotpatterns distinct revealed survey of trade online for shopping malls, auction and CtoC market Pattern oftradeacrossonlineplatforms time.this diversified channelsthough sincethe 2014, identifyingdefinitive characteristics this of result is possiblenot at abundance of advertisements on sites new like Mercari indicates that online inJapan trade ivory is using much larger. increased number the Overall, of hits inYahoo Auction may indicator, not agood be but the isivory not exhaustive to designed be and, therefore, number actual the of products ivory on eachsite is advertisements were found on It Rakuma. should emphasized be that keyword the “hon-zouge” for genuine though total the number of hits could not due determined be to nature the of technology. the Only 45 present study, Mercari is substantially larger and returned numerous advertisements with keyword, the expansion of overall activity on site. this two Ofthe CtoC market for sites first surveyed the thetime in million in2017 of advertisements on Yahoo Auction at agivenfrom time, shifted which roughly 32million in2014 to 50 52% compared to 2014(from 2,737hits to 4,158hits). This increase followsthe in rise a overall number in2014.Searchwas not results surveyed on Yahoo Auction for “hon-zouge” (genuine increased by ivory) (from 107to 55shops), but asimilar number of shops were found on Yahoo Shopping (58shops), which The number of shopsselling nearlyivory thehalved in comparedrecent survey Rakuten-Ichibato 2014 on Overall resultsofsearchtrends RESULTS ANDDISCUSSION Figure 1. Types of ivory products advertised on Japanese e-commerce platforms in May 2017 searched using keyword “hon-zouge (genuine ivory)”: Rakuma (N=45)). Products were categorized according to the scheme used by METI (Ministry of Economy, Trade, and Industry) of each category are listed in Table 1. A) shopping malls (Rakuten-Ichiba (N=55), Yahoo Shopping (N=58)); B) auction (Yahoo Auction (N=100); and C) CtoC markets (Mercari (N=100), A) ONLINESHOPPING 10 . Thus, any increasethe in number of hits for “hon-zouge” could simply the general reflect B) INTERNETAUCTION netsukes hanko were largest the product followed type shops by far constituted majority, the C) ONLINECtoCMARKETS 11 . The examples
3 TRAFFIC BRIEFING PAPER 4 TRAFFIC BRIEFING PAPER over afour-week May 8th between and period June 4th 2017. Multiple items same inthe sold lot were counted individually. Table 1.Count of containing ivory items on Yahoo Auction bidding (successful records) and Mercari advertisements) (new on Mercari. total of tusks 22polished and were carved on sold Yahoo Auction, whereas one polished tusk was advertised pieces, 20edge pieces and one slice of unknown weight. Whole tusks ivory on weresites. both A observed unknown weight. There were a also few offerings semi-processed of onivory Mercari, including 1kg edge of amounting to atotal of 59.5kgof pieces small of various shapes and over 5,000pieces of (mostly beads) for traditional hanging scrolls. Furthermore, was semi-processedivory on sold everyday Yahoo Auction, item inquestion, namely lids ivory on inteaceremonies traditional used pottery and weights ivory used were categories certain also of products that were numerous, with comprising ivory only of part the asmall of were them offered in Similarly,bulk. there were bulk offerings of up to70 were marked as “sold”. In Yahoo Auction, comprised largest the jewellery number (5,410pieces), and alot volume ofsales traffic. actual onAlthough Mercari tracked, could be not 27% of items the in snapshot sample Yahoo Auction are transactions actual that during four-weeks, occurred the represents this aconsiderable items 573new while (an average of week) were 143per on advertised Mercari. Given that 9,788items the on dwarfed latter the Atotal of inscale. 9,788items (an average of week) were 2,447per on sold Yahoo Auction, Four-weeks of monitoring an revealed on active trade ivory Yahoo both Auction and Mercari, but former the Trade monitoring were 2),which (Fig. large, elaborate carvings. (USD900) or evenover JPY1million (USD9,000) offered rangeat ahigh price of over JPY100,000 JPY10,000 (USD90), there were items certain items offered on CtoC market sites were under antique items. While to close 70%of ivory provided aready channel for re-selling of such individuals using smartphones to seems have and rise 1980s.The of CtoCtrading amongst well as import of such products during 1970s the as aresult of massive domestic production, as a characteristic of Japan’s antiques ivory market The extensive availability is of jewellery old ivory Daily goods Kitchen utensils Buddhist articles Indoor amusement goods ear ornamental Carvings & furnishings Other Other musical instruments incense tuning Hanko Whole tusk Smoking goods Stationary Semi-processed pieces Japanese musical instruments Jewellery Tea ceremony utensils Total (excluding whole tusks and semi-processed ivory)
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, ONLINE CtoCMARKETSALESPRICE
surveyed in May 2017 (Mercari (N=100), Rakuma (N=45)). Figure 2. Sales price of ivory items in online CtoC market advertisements (new 1 21
1 kg
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(%) 12 LCES mandates businesses all that manufacture, trade, or retail products inivory apart from whole tusks such METI. to All notify businesses receive asticker showing making display of acompany’s registration number obligatory, and guaranteeing public access to information strengthenedbeen by government the to upgrade notification the system into a proper registration system, following publication the of TRAFFIC’s first in2014. report In addition, regulatory requirements have also This significant improvement comes asa result of monitoring initiativestaken bye-commerce companies Auction could not checked be due to lack of business information. displayed issued anewly notification number.actual The notification status the of three shops on Yahoo tradingivory regulations and, as of June 27th 2017,one of had them removed products ivory all and another shops about state their of non-compliance with from TRAFFIC, Yahoothree these notified to have made notifications in2017. Upon notice knifes, accessories, shoehorns) were confirmed pieces smaller ofsold (e.g. handled ivory ivory butall three shops inYahoo Shopping who operated without making notifications in2014, 4).While in2014(Fig. amajoritydid so indeed minoritysmall (11%and 22%,respectively) that notification numbers in2017compared the to Rakuten-Ichiba, respectively, displaying with 88%and 85%on Yahoo Auction and regarding obligatory business notifications significant improvement in the LCES compliance Comparison with 2014data a revealed legality signs 2014-2017 comparisonof distinguish from elephant ivory. bones, or antlers are sometimes difficult to mammoth as ivory well as other animal tusks, Japanese(small traditional figurines) made of ivory. Furthermore, it is known that with explicit identificationobserved as mammoth offerings of mammoth figurines wereivory also certainty through online advertisements. In fact, impossible to distinguish genuine products with here may include some fake as ivory it is mind that counts both and value trade recorded and furnishings. Itcarvings should kept be in products consisting largely of jewellery, ivory remaining 92%of comprised trade the other processed 6%of ivory by trade the value. The whole tusks represented only 2%and semi- to over JPY45.2million (USD407,000). Ofthese, on Yahoo Auction over four-weeks the amounted tusks. Finally, total value the trade of items ivory end of price the ranges were figurines wholeand (USD90 to 3).Items 450)(Fig. at sold high the followed by JPY10,000to 50,000 30%between Auction, 42%were less than JPY5,000(USD45), atLooking price the range of on sales Yahoo LCES amendment notification upgraded this scheme to a “registration”sometime be enacted scheme in2018. withwhich penalties,will enhanced a designated operator’s number and are obligated to record transactions all and resulting balances of stockpiles and submit to them METI on aregular basis. The 2017 netsukes 12 ,
YAHOO AUCTIONSALESPRICE BUSINESS NOTIFICATIONNUMBER wrappings, containers were or pedestals) included. comprising almost exclusively of (90%by ivory appearance, excluding a four-week May 8th between and June period 4th 2017.Onlyitems Figure price 3.Sales of items ivory on Yahoo Auction monitored over (N=19, N=24);Yahoo Shopping (N=58). Rakuten-Ichibaunder category: each (N=107, N=55);Yahoo Auction in2014.Numberswas not surveyed indicate counts the of businesses visibility of notification status on websites.respective ShoppingYahoo Figure 4.Comparison May between 2014and May 2017of the
5 TRAFFIC BRIEFING PAPER 10 15 20 25 30 0 5
6 TRAFFIC BRIEFING PAPER using internet auctions for commercial purposes most of (18out them of inferred 22)could be to be Auction didnot themselves identify as businesses, (22 outhalf of 47)of auction the on sellers Yahoo and emerging online CtoC markets. While nearly evident in the current study, both on internet auction Thelack of control over CtoCtrading become has Regulatory loopholes enforcement challenges of trade inthe whole tusks. tusks”. asthem “ivory In any there case, remain that would sellers not necessarily have recognized with extensive curvature, pointing to apossibility of offers the without registrationcards were tusks opening for trade. Across illegal websites, both many monitoring and enforcement could provide an it remains apossibility that platforms with looser monitoringtheir programme. other Onthe hand, a registration card, highlighting effectiveness the of in Yahoo Auction’s biddings successful records had found with keyword “hon-zouge (genuine ivory)” to ensure registration. whole tusk In every fact, to conduct regular monitoring of whole tusks ivory Yahoothe concerted reflects effort that by company compliance with registration the card system on registration cards 6).The rate (Fig. higher of of nine tusks were accompanied by requisite the emergingthe CtoC market giant, only three out under LCES, the whereas on Mercari the site, accompanied by registration the cards required on Yahoosurvey Auction, but all four tusks were 27 whole tusks offered timethe at the snapshotof items is regulated concerns whole tusks. Ofthe The whichtrade type only in of of individualivory products.ivory certification system to ensurethe legality of worked and there are no moves to establish acompulsory yet considered certificationscheme the reviewing online trading.However, government the has not legality of worked items ivory marketed through not constitute an effective tool for establishingthe suggestsevidence that product certification does thanhigher visibility their on websites, current of use actual the product certificatesbe could unchanged 5).Whilst (Fig. from 2014survey the voluntary product certification system remained In contrast, usage of government-issued the in2018. enacted on registered businesses. These new reformsbe will Figure 7. Identities of sellers offering ivory items on Yahoo Auction active auctions was checked to deduce theyif were merely selling off individuals (no indication of business entities), their list of other in a snapshot survey in May 2017 (N=47). For sellers appearing as Figure 5. Comparison of voluntary product certification use operation. of a product certification seal was displayedalong with business personal items or using the auction site for business. notification numbers asthough it was a certificateof business Numbers indicate the count of businesses indicating that they N=55). Yahoo Shopping was only surveyed in 2017 (N=57). provide product certifications. “Wrong use” waswhere the image between May 2014 and May 2017 for Rakuten-Ichiba (N=107, WHOLE TUSKREGISTRATION PRODUCT CERTIFICATION legal documents (registrationlegal cards) zouge (genuine inMay ivory)”) 2017and accompaniment their of Mercari at timeof the snapshot the (using keyword survey “hon- Figure 6.Number of whole tusks offered on Yahoo Auction and as business Operating 51% Implied business 2% Yahoo Auctionsellers individual Appears 47% as individuals Of thoseappearing Unlikely tobeusing Likely tobeusing auction site auction site for business for business 38% 9% need forneed appropriate regulation and awareness-raising amongst Japanese tourists and consumers domestically. Although the extent of import illegal in the above seen examples remains unknown, there is a clear and urgent different ofstyles aswith well carving types figurines as certain fromjewellery traditional Japanese motifs. impossible sure to be item ivory that is aparticular of bona fide pre-Convention for especially origin, ivory pre- and post-Convention products ivory without freely can be traded any requirement of proof, it is often whole tusks, only case inwhich registered pre-Convention tusks legally. traded can be Therefore,both since any requirement for proof of legality (e.g. CITESimport or permit LCES the registration)—unless are they CITES regulations, domestic their remain sales underwithout LCES, the legal allows which traded to them be Asia with andexplicit Africa statements about origins their are 8).While (Fig. these clear infringements of example, surveyors found on Mercari afew advertisements recently for brought jewellery ivory back from whole tusks was found to present severe challenges inidentifying and preventing flows. ivory illegal For Furthermore, as function abusiness sellers the whether or not, lack the of regulation for products other than amendments. effective enforcement the of strengthened ivory business regulations broughtthrough forth recent LCES findingsThese needthe highlight thefor government scrutinize to businessesivory operating online to ensure are evidently operating businesses on platforms, these evenpromoting items ivory for increasing their rarity. of offering sellers multiple ivory items (23% and 25%in MercariRakuma, and respectively) someand sellers multiple items. ivory Furthermore, snapshot the of CtoC survey markets asignificant revealed also proportion of individual items ivory trade sellers regularly, at least four out of “appearing 22sellers as individuals” offered using auction sites for business. Although it cannot from determined be snapshot the what proportion survey Japanese swords and Japanese musical instruments, respectively); thus, were they grouped withlikely sellers but products only sold were which specialized highly belongings personal unlikelyto be all (i.e. of parts mostly antiques and Two collectables. shops had fewer simultaneous active auctions (8and 16respectively), none inivory, of specialized them held at they least 25active auctions simultaneously (up to 1,480lots) of rather than off selling personal items,thebased liston of other auctionsthey were holdingAlthough 7). (Fig. souvenir….received five years ago”). ago inThailand”, with anecklace “boughtseveral years ago inThailand”, “My uncle went Congo to with Africa in work and brought back asa Figure offered 8.Examples of jewellery on ivory Mercariwith clear statements abouttheir recent (fromorigin left“bought right: to fouryears
7 TRAFFIC BRIEFING PAPER 8 TRAFFIC BRIEFING PAPER 2016, recommended: CITES Parties, inResolution Conf. 10.10(Rev. on CoP17) apparentthe significant number of ivory productsbeing offered traded onlineand in Japan is of concern. The In spite of the methodological limitations in establishing of the scale online trade through monitoring surveys, RECOMMENDATIONS Table of 2.Summary applicable LCES regulation on eache-commerce model into Japan’s domestic market. ivory networking sites, and physical trading are into taken account. TRAFFIC intends to conduct research further outsidefalling current the control system is significant all whenforms of trading, online suchsocial ivory as of onlinethe on trade ivory aspect major e-commerce platforms inJapan, extent the of domestic trade ivory and inbonadiscerning fide difficulties pre-Convention items.current Whilst the study investigated only therefore completely outside of LCES the control. This situation is of concerngiven the active trading online offered almostall on websites, thelarge so quantities of other productstraded by non-businesssellers are outside regulatory the radar. In terms of products, whole tusks represent atiny proportion of trade the unidentified businesses and individualswidely trading in auctions and CtoC market sitescurrently remain as only business operations and inwhole tusks trade are subject to law the (Table 2).In terms of sellers, In sum, coverage the of current the LCES regulation withto respect online trading ivory is patchy at best Regulation Regulation products c) introduce recording and inspection procedures to enable the Management Authority and other b) register or license all importers, exporters, manufacturers, wholesalers and retailers dealing in raw or a) regulate the domestic trade in raw and worked ivory; legislative, regulatory, enforcement and other measures to: designated asivory importing countries, to ensure that they have put in place comprehensive internal trade in ivory, an unregulated market for or illegal trade in ivory, or where ivory stockpiles exist, and Parties FURTHER URGES those Parties in whose jurisdiction there an is ivory carving industry, alegal domestic to implement the above recommendation asamatter of urgency; poaching or illegal trade and that have not closed their domestic ivory markets for commercial trade in ivory URGES those Parties in whose jurisdiction there alegal is domestic market for ivory that contributing is to should not contribute to poaching or illegal trade; thatRECOGNIZES narrow exemptions to this closure for some items may be warranted; any exemptions to close their domestic markets for commercial trade in raw and worked ivory asamatter of urgency; contributing to poaching or illegal trade, take all necessary legislative, regulatory and enforcement measures … that all Parties and non-Parties in whose jurisdiction there alegal is domestic market for ivory that is ii) comprehensive and demonstrably effective stock inventory, reporting, and enforcement systems for i) compulsory trade controls over raw and ivory; means of: appropriate government agencies to monitor the movement of ivory within the State, particularly by worked ivory;
worked ivory;
of of
traded sellers
limited Only certifications Yes Online
(businesses)
whole
use
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of
tusks
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and
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whole Trade in elephant specimens Internet
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R UK R T F TR g s u e o e lo g lep s r f i st b AFFI t a e er ur al g h in i e st o l d L t y o ab er h n C, t er inf e: e i m d Ch le de n t i t e h d C rade inw a o e w r v i r ty N o m e m lop i p a ld o a t . 1076722, n io lif m y N n co e t en i o ld a . 3785518. rade m t. n t nim ac t: a o l s a ni t n o d p r in g n l a n et ts int w o r h k, i e co s t n h t e l ext o adin f b g n o t h b o n-g io di o v v er er nm si t y co en t ©1986 Pandasymbol WWF ®“WWF” isaWWF Registered Trademark Registered Limited Company No. 3785518. UK Registered Charity No. 1076722, Website: www.traffic.org (EN) E-mail: [email protected] Telephone: (81)337691716 Tokyo, JAPAN 6Fl. 3-1-14Shiba, Minato-Ku, 105-0014 c/o WWF Japan Office TRAFFIC For information further contact: sustainable development. animals on inwild andglobally trade plants context inthe of biodiversity both conservation and monitoringTRAFFIC, trade wildlife the network, is leading the non-governmental organization working TRAFFIC recommendsthefollowing: regulatory challenges for Japan and addressed to with urgency. need be not does inivory contributetrade to poachingor trade. Internet to illegal trading channels are creating new As aCITESParty, Japan has an obligation these requirements to fulfill effectively to ensure that domestic a n l o s er E-commerce companies and NGOs should assist inawareness-raising• amongst users of e-commerce E-commerce companies and relevant stakeholders industry ivory should consider• adopting stricter The Japanese government should urgently capture• identities the of, and register offering sellers ivory The Japanese government should assess feasibility the of measures installing• stricter to address all r ga va is a wildlife trade and wildlife cybercrime as aseriouscrime. and trade wildlife cybercrime wildlife sites not only to disseminate CITESand LCES regulations but to mainstream also issues the of illegal consequences.legal To end, this e-commerce platforms should consider banning online trade. ivory measures than LCES provides, with an aim to preclude without origintraded being of ivory illegal compliance with CITESResolution Conf. 10.10. … wholesalers and retailers dealing in raw or worked ivory through online platforms. CITESrequirements explicitly for call registration the or licensing of “ pieces, and forms all of worked and new ivory), old, and by trade and amongst non-business entities. of itsaspects internal effectively, trade ivory including all (wholetrade in product types tusks or t niza s tr io www.trafficj.org (JP) a t n a egic allianceof t io n n w d o r k in g This projectwas supportedbyWWFJapan
”. Failure would to considered doso be non- all
9 TRAFFIC BRIEFING PAPER