International trade controls in elephant ivory in Canada
Discussion document: range of potential actions pertaining to trade controls in elephant ivory in Canada
Open - accepting input
2021-07-24
2021-09-22

Monitoring of Illegal Hunting of Elephants (MIKE)

The most recent report from MIKEFootnote 4 (2019) indicates that poaching levels in Africa increased starting in 2006 and peaked in 2011. This was followed by a slow but steady declining trend up to 2018. The MIKE report advises caution in interpreting the recent decline in poaching levels, as there have been continental declines in elephant numbers over the same period. Poaching remains of particular concern in Central Africa and West Africa, which account for 6%, and 3%, respectively, of the African elephant population. Declines observed in poaching levels may reflect, in part, decreasing numbers of elephants, and increasing natural mortality from drought, the latter is suspected in Eastern Africa. Poaching levels in Asia have experienced some fluctuation but have been relatively constant since 2006. The report notes that human-elephant conflict is an important element of illegal killing for this species. Canada is not an elephant range state and is therefore not involved in this monitoring process.

Elephant Trade Information System (ETIS)

The most recent report from ETISFootnote 5 (2019) report indicates an increase in illegal trade, starting in 2008 and peaking 2015, particularly for large pieces of raw ivory. Organized crime is implicated in both poaching and illegal trade. Data for 2016 and 2017 suggest incremental reductions in illegal trade from the 2015 peak but data for 2017 was incomplete. The ETIS report also analyzed illegal trade for individual countries to identify countries in which illegal trade or illegal transit were particularly serious over the period from 2015-2017. Canada was grouped with Austria, Switzerland, Spain, Australia and New Zealand as not generally involved in significant illegal ivory trade. Most seizures in these countries involve worked ivory in trade as personal items, which are not linked to large scale movements associated with organized crime. More specifically, most seizures of ivory specimens imported into Canada involve personal items without the necessary permits.

Twenty-eight countries, including the United Kingdom and the United States of America were identified as having higher levels of illicit trade from 2015-2017.

National Ivory Action Plan (NIAP)

The ETIS report identifies countries that should participate in the NIAP process. These countries must develop a NIAPFootnote 6 that addresses the concerns identified in the ETIS report through legislation and regulations, enforcement action and inter-agency collaboration at the national, regional and international level, outreach, public awareness, education and reporting. Countries that are not making progress with the development and implementation of their plans may be subject to compliance measures, including a recommendation to suspend trade. Canada has never been identified by ETIS for participation in the Ivory Action Plan process.

Current ivory trade in Canada

Canada's import of elephant ivory is lowFootnote 7 compared to the global trade in elephant ivory. Most elephant ivory imported into Canada is Appendix I pre-Convention ivory and includes antique pianos, bagpipes, chess sets and carvings as commercial or non-commercial trade. Legal, non-commercial trade could include elephant ivory moving between countries as part of a household move such as in a piano with elephant ivory keys, elephant ivory tusks acquired in a legal hunt, and elephant ivory used for scientific research. A smaller portion of Canada’s legal, non-commercial ivory trade includes hunting trophies that originate from legal, sustainable harvest of African elephant populations that may be listed in either Appendix I or Appendix II.

There are two main categories of elephant ivory traded to and from Canada, raw ivory and worked ivory. As defined by CITES, raw ivory means “All whole elephant tusks, polished or unpolished and in any form whatsoever, and all elephant ivory in cut pieces, polished or unpolished and howsoever changed from its original form, except for ‘worked ivory’”, and worked ivory means "Ivory that has been carved, shaped or processed, either fully or partially. This expression does not include whole tusks in any form, except where the whole surface has been carved".

Canada issues import (Appendix I only) or re-export permits (Appendix I and Appendix II) for raw ivory as a trophy resulting from a sport hunt, or as personal items (either inheritance or gifts). In the case of personal items, the whole or mostly whole tusks can be worked (fully carved, partially carved or minimally carved), unworked but mounted on a stand, or raw (as is). These tusks may have been in the family for a long time, or purchased or received as gifts while overseas. 

Some examples of worked items with ivory imported or re-exported from Canada:

  • ivory piano or organ keys (typically 52 ivory keys per piano)
  • ivory sculptures
  • accents on sculptures (e.g., face, hands, decorations)
  • completely made of ivory (e.g., Japanese netsuke)
  • portrait miniatures with ivory inlays or painted on ivory
  • religious artifacts
  • chess pieces (32 pieces per chess set)
  • mahjong game pieces (100+ pieces per set)
  • ivory ferrules or mounts on bagpipes (7 to 13 per bagpipe)
  • cutlery handles
  • decorative accent pieces on coffee or tea pots
  • ivory used for violin, cello or bass bows (e.g., frogs, tips)
  • buttons for garments
  • jewelry

When CITES permits are issued for import or re-export of worked ivory, it is typically the individual pieces of ivory that are counted and reported on the permit (when possible). Analysis on the quantity of ivory imported or exported from Canada can give the impression of large volumes of ivory, however the pieces are often small and decorative in nature. From 2015 to 2020, Canada issued 185 import permits and 214 export/re-export permits for elephant ivory.

Range of potential actions pertaining to trade controls in elephant ivory

This section summarizes the range of potential actions that Canada could consider pertaining international elephant ivory trade controls, including maintaining the status-quo, or increasing Canadian controls to include measures stricter than those required under CITES. It benefits from review of elephant ivory restrictions currently in effect in other countries, particularly the United States and the United Kingdom.  To note, this consultation does not apply to other elephant items. Canada will continue to apply the current CITES provisions pertaining to trade in non-ivory items such as elephant hair, skins and leather goods, and allow such trade with the appropriate import and export/re-export permits.

There are three categories of trade to be considered: (1) commercial trade, (2) non-commercial trade and (3) personal and household items that consist primarily of raw ivory tusks from hunting trophies, other forms of raw ivory, and worked ivory. These ivory specimens may have originated from elephants that were removed from the wild before the elephant species were listed on CITES (pre-Convention), after they were listed on CITES or from elephants that were bred in captivity. All of these factors will need to be considered when evaluating elephant ivory trade control options in Canada.

Commercial trade