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Wednesday 21st January 2015

CITES, Elephants and Zimbabwe - a shocking loophole for the ivory trade?


6 tons in 2 years from Zimbabwe to China


This is about elephants and CITES and Zimbabwe. It is not a petition, but I hope that you will take a few minutes to find your CITES country representative on the list below, copy and paste the suggested letter into an e-mail, and send it off. It is something YOU can do to assist in closing loopholes that could be used in the illegal ivory trade.

You can find all details of your CITES country representative on this list.

You will see that countries have a Management Authority and a Scientific Authority and the letter should be sent to both.

I cannot emphasize enough how IMPORTANT it is to send these sorts of letters to CITES. It shows not only that you are concerned about their actions on important wildlife trade issues but that you are aware of these issues, and that you as a taxpayer who ultimately supports CITES with your money should have the opportunity to receive answers to your concerns.

OK, that was the preamble. Now to the main course. CITES, in their wisdom, allowed Zimbabwe a so-called “annotation” to export ivory carvings all over the world. Prior to 2010, anyone could buy ivory from Zimbabwe dealers and be issued with what was called a “Short Export Permit” issued by the dealers themselves. Presenting that document to customs allowed export and import of ivory products. In 2010, CITES changed the regulations – the purchased ivory had to be taken to one of three CITES offices in Zimbabwe to be issued with a proper CITES permit. Prior to 2010, nobody had any idea how much ivory was exported from Zimbabwe as there was no record lodged with CITES.

In case you are wondering about the amounts of ivory being shipped out of Zimbabwe with the recent change in CITES permits between 2010 and 2012 (records for 2013 and 2014 are not yet available), consider these numbers:

Individual ivory carvings: 7,334
Kilos of ivory carvings: 6,193
Grams of ivory carvings: 318,485
“Carvings”: 261
Kilos of “carvings”: 1209

Where does all the ivory come from that forms the basis for all these exports? That is not known, and creates a wonderful loophole to launder illegal ivory.

In addition, in the ten years between 2003 and 2012, Zimbabwe exported the following ivory products with CITES permits via hunting trophies:

Tusks: 3,969
Kilos of tusks: 20,535
Trophies: 2,621

These numbers do NOT include the “one off sale” amounts sold to Japan and China from stockpiles in 2007 and 2008.

These numbers should worry you, concern you and perplex you. If you are concerned about elephant conservation in Africa and closing loopholes facilitating the illegal trade in ivory, please take a few minutes to send the letter below to your CITES representatives. I am particularly interested in targeting such representatives in the Americas, Europe, Kenya, India, Australia, New Zealand, etc. If you live, or have friends living in those countries/regions, please send and ask your friends to send the following suggested letter:

Dear xxxx

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:

“Tusks”: 3,969
“Kilos of tusks”: 20,535
“Trophies”: 2,621

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.

Yours Sincerely,



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Add a comment | Posted by Chris Macsween at 15:02