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Subject: Ivory, concerns about Loopholes, facilitating illegal trade
Dear Sir, Madam:
In the last few years, there has been increasing and growing concern about the illegal trade in ivory and the massive slaughter of elephants in a diversity of range states. Such concern has precipitated a number of international conferences and summits to begin to address the illegal trade and close available loopholes that could facilitate such illegal trade.
I am concerned about an authorization afforded to Zimbabwe by the CITES Parties to trade in ivory carvings for “non-commercial” purposes. As you will know, before 2010, licensed domestic traders were authorized to issue customers with a document called a “Short Export Permit”. This document was provided by the Zimbabwe Management Authority and when endorsed by a Customs officer prior to export, allowed the customers to legally export their ivory products.
This practice was terminated by CITES Notification to the Parties No. 20010/024 and replaced with a requirement to apply for an official export permit from one of the three Zimbabwe CITES Management Authority offices.
Consequently, there are no records of the amount of ivory carvings exported from Zimbabwe before 2010. However, the CITES Trade Database reveals that such exports were likely substantial as revealed by records from 2010, 2011 and 2012 (the CITES Trade Database does not yet list statistics for 2013 and 2014).
In those three years, the Trade Database shows that 7,334 ivory carvings, 6,193 kilos of ivory carvings, 318,485 grams of ivory carvings, 261 “carvings” and 1,208 kilos of “carvings” were exported from Zimbabwe to a diversity of nations but mainly China.
I am concerned, given the export of such amounts of ivory carvings authorized by CITES, where all the raw ivory was obtained for the manufacture of these carvings. Also, I am concerned that CITES does not define what an “ivory carving” is except that it has been “worked” in some unspecified manner.
The amount of ivory exported from Zimbabwe under the CITES authorization clearly indicates to me that this is far from a “non-commercial” enterprise. It stretches the imagination that almost six tons of ivory exported to China in about two years was conducted by Chinese residents and/or Chinese tourists in Zimbabwe for “non-commercial” purposes. It also raises the distinct possibility that the ivory, once in China, is sold on to commercial enterprises at a profit.
In a proposal to COP15, a document presented by Kenya, Ghana, Liberia, Mali, Sierra Leone, Togo, Republic of Congo and Rwanda raised similar concerns. The document quotes:
“Paragraph f) of the elephant annotation [permitting trade in ivory carvings from Zimbabwe and “ekipas” from Namibia] … has created a grey area and opened up loopholes for illegal trade in ivory… in Zimbabwe ivory from government owned stocks has repeatedly been exported in contravention of CITES … no quantitative limits [are defined] for ivory carvings … from Zimbabwe. (page 7)”
I would therefore appreciate your response to these concerns, and I would urge you and other Parties to raise this issue at the next Conference of Parties in Cape Town, 2016. In addition, I would hope you raise concerns about this issue at upcoming CITES Animals Committee and Standing Committee meetings.
Also, I would like your reply on another issue of concern arising from reporting methods used by Zimbabwe for exporting elephant ivory.
For example, in the ten years 2003-2012 (the CITES Trade Database does not yet list statistics of 2013 and 2104), Zimbabwe exported the following ivory products according to the CITES Trade Database in addition to the “ivory carvings” mentioned above:
“Kilos of tusks”: 20,535
“Kilos of tusks”: 20,535
These numbers exclude the “one-off” trade allowance afforded Zimbabwe to trade stockpiled ivory to China and Japan in 2007/2008, and are therefore most likely tusks exported by trophy hunters.
Such confusing reporting categories do not allow any conclusions to be drawn about the numbers of elephants shot as trophies in Zimbabwe, and therefore does not allow any inferences to be drawn about the sustainability of trophy hunting and/or the contribution that trophy hunting makes to the conservation of Zimbabwe’s elephant population.
Thank you for your attention to these matters, and I would very much appreciate your earliest reply to these concerns.