TRAFFIC In Transition:
Bangkok’s Ivory Market
R

E

P

O

R

T

An 18-month survey of Bangkok’s ivory market

SEPTEMBER 2016

Kanitha Krishnasamy, Tom Milliken and Chution Savini

TRAFFIC REPORTTRAFFIC, the wild­life trade monitoringnet­work, is the leading non-governmentalorganization working globally on trade inwild animals and plants in the context of bothbiodiversity conservation and sustainable
development. TRAFFIC is a strategic allianceof WWF and IUCN.
Reprod­uction of material appearing in thisreport requires written­permission fromthe publisher.
The designations of geographical entities inthis publication, and the presentation of thematerial, do not imply the expression of any
opinion whatsoever on the part of TRAFFIC
or its supporting ­organizations con­cern­ing
the legal status of any country, territory, or
area, or of its authorities, or concerning thedelimitation of its frontiers or boundaries.
The views of the authors expressed in thispublication are those of the writers and do notnecessarily reflect those of TRAFFIC, WWF
or IUCN.
Published by TRAFFICSoutheast Asia Regional Office
Unit 3-2, 1st Floor, Jalan SS23/11
Taman SEA, 47400 Petaling Jaya
Selangor, Malaysia
Telephone: (603) 7880 3940
Fax: (603) 7882 0171
Copyright of material published in this report
is vested in TRAFFIC.
© TRAFFIC 2016.
UK Registered Charity No. 1076722.
Suggested citation: Krishnasamy, K.,
Milliken, T. and Savini, C. (2016).
In Transition: Bangkok’s Ivory Market –An 18-month survey of Bangkok’s ivory
market. TRAFFIC, Southeast Asia Regional
Office, Petaling Jaya, Selangor, Malaysia.
Front cover photograph: African Elephant
Loxodonta africana
Credit: Kanitha Krishnasamy/TRAFFICIn Transition: Bangkok’s Ivory Market
An 18-month survey of Bangkok’s ivory market© Kanitha Krishnasamy / TRAFFIC

Kanitha Krishnasamy, Tom Milliken and Chution Savini

African Elephant Loxodonta africana© Kanitha Krishnasamy / TRAFFIC

insert image or leave blankTABLE OF CONTENTS

Acronymsiii

Acknowledgementiii

Executive Summaryiv

Background and Introduction

1

Methodology

4

Results and Dicussion

5

Retail Outlets

5

Ivory Products

6

Surveys Compared10

A Shift to Online Marketing and Sale of Worked Ivory Products

17

A Shift in Thailand’s Raw Ivory Trade Patterns

20

Conclusion and Recommendations

23

References

25

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory marketii

ABBREVIATIONS AND ACRONYMS
CITES
		

Convention on International Trade in Endangered 				Species of Wild Fauna and Flora CoPConference of the Parties (to CITES)

DNP

Department of National Parks, Wildlife and Plant Conservation

ETIS

Elephant Trade Information System

NIAP

National Ivory Action Plan

SC

Standing Committee

WARPA

Wild Animal Reservation and Protection ActACKNOWLEDGEMENTS
TRAFFIC thanks WWF International, U.S. Agency for International Development (USAID) andthe U.S Fish and Wildlife Services for generously funding this work.
Colleagues from TRAFFIC, particularly Chris R. Shepherd, James Compton, Elizabeth John,
Maethinee Phassaraudomsak and Richard Thomas are thanked for providing useful input andreviews of the report. Janpai Ongsiriwittaya from WWF-Thailand is also thanked for reviewing
this report.
Individuals from the Thai DNP are thanked for their continued willingness in sharing information
with TRAFFIC regarding their ongoing ivory regulatory processes, particularly Mr Adisorn
Noochdumrong, Deputy Director General of DNP and Ms. Apinya Jaitae, Senior Forestry
Technical Officer of DNP.
Lastly, Aqeela Abdul Jalil and Elizabeth John are thanked for their continued support with thereport layout and design, without which this report would not have been possible.

iii

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

EXECUTIVE SUMMARY
At the 64th Meeting of the CITES Standing Committee in March 2013, Thailand, along witheight other countries and territories, was identified as a country of “primary concern” due to its
significant role in the global ivory trade. These countries and territories were subjected to an
oversight process that required the development of a time-bound National Ivory Action Plan
(NIAP). This was an unprecedented accountability mechanism introduced by CITES for countries
most seriously implicated in global illegal ivory trade to put in place strict measures to address arange of issues that served to facilitate illegal trade in ivory. Thailand’s NIAP was submitted to the
CITES Secretariat in May 2013, though this Plan was deemed insufficient to address domestic ivory
trade regulation effectively. The 65th Meeting of the Standing Committee (SC65), at its meetingin July 2014, adopted a Decision, calling on Thailand to revise its NIAP and to include clear anddeliverable measures for its implementation before 31 March 2015. Among other issues requiring
attention, Thailand’s revised NIAP needed to include measures concerning legislation revision andregistration of domestic ivory trade.
In response to this Decision, Thailand announced in December 2014 the revision of its primary
wildlife and CITES-implementing law, the Wild Animal Reservation and Protection Act (WARPA)
B.E 2525 (1992), by listing the African Elephant Loxodanta africana as a nationally protected
species. Thus Thailand finally introduced a legal means to implement CITES within the country
for African Elephant parts and products; the import, export, trade and sale of ivory from African
Elephants was now prohibited.
A month later in January 2015, a new law was also enacted, the Elephant Ivory Act B.E 2558
(2015), to govern the regulation of Thailand’s domestic ivory trade, limiting it exclusively to Asian
Elephant Elephas maximus ivory from registered captive animals. Following this, Thailand
successfully conducted a nationwide registration process, with more than 40 000 people registering
670 984 ivory products, weighing a combined 200 358 kg (totals as at August 2015). Products
registered included stocks that were held both privately and commercially. Items for commercial
purposes amounted to less than 2% of the total weight registered, but represented 53% of the total
number of worked (carved) ivory items that was deemed to enter the national marketplace. The
average weight of the worked ivory registered as commercial stock was only 9.31 grams per piece,
indicating that most finished products for sale were extremely small items.
Since these regulatory amendments took place in Thailand, the 2016 Elephant Trade Information
System (ETIS) report has recognized it as a country of “secondary concern”. This is reflectiveof Thai government efforts to tackle ivory trade, perhaps the most impressive progress madecompared to any other CITES Party in addressing ivory trade issues since 2013. Apart from thenotable legal and regulatory reforms, a contributing factor to this new positioning as of “secondary
concern” was that Thailand was not a primary destination for any large scale-seizures for theperiod 2012-2014. Outside this period assessed by ETIS however, the Royal Thai Customs made atleast seven known seizures from April to August 2015 amounting to almost 6.5 tonnes of ivory.
To better understand the effects and effectiveness of Thailand’s newly introduced regulatory
regime, TRAFFIC conducted an 18-month survey of open market availability of ivory in Bangkok
from December 2014 through June 2014. This exercise was done to assess market trends during
the period immediately before the Elephant Ivory Act came into effect and after the law came into
force. Surveys were conducted across nine different retail market locations: Chatuchak Market,
Chatuchak Mall, River City, Amulet Market, MBK Plaza, Amarin Plaza, Big C Rama 2, Central
Rama 2 and Central Rama 3. The number of shops surveyed ranged between 143 and 169 shops.

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory marketiv

A steep decline in the number of retail outlets offering ivory and the number of ivory products
found for sale was observed since Thailand’s legislative reform. A monthly high of 7421 ivory
products was recorded in December 2014, but this declined to a record low of 283 ivory products
in June 2016. Similarly, the highest number of shops selling ivory was recorded in December 2014
and the lowest number of retail outlets selling ivory (5) was in June 2016. An average of 2662 ivory
products per month were recorded in trade over this 18 month period. However, when averaging
the number of products in trade since April 2015, when the law came into place, this figure reducesslightly to a total of 2049 products. September 2015 saw the highest number of products (3227)
recorded in Bangkok since the law was enforced, while November 2015 saw the highest number(18) of shops selling ivory. The biggest jump in availability of worked ivory items occurred in
November 2015, when an increase of 1096 ivory products was noted at the Chatuchak Market,
compared to the previous month; one shop alone had 2285 products for sale at that time. The top
two locations with the highest number of retail outlets were Chatuchak Market and the Amulet
Market. Throughout the survey period, several shops which previously sold ivory were closed(both that were temporary and some that were permanently closed down), with a clear reduction in
the number of observable ivory product on display.
This report provides a summary overview of Bangkok’s ivory marketplace, and provides
comparisons with TRAFFIC’s previous market surveys in 2013 and early 2014. Thailand’s
efforts in the last 15 months since its legislative reform took place have shown considerable andevident progress. A clear reduction has been observed in the open availability of ivory productsin Thailand’s capital city after trade has been regulated, compared to the preceding months of
unregulated trade. The number of ivory products in trade averaged 10 469 per month over the 13
months before the Elephant Ivory Act came into place, compared to an average of 2048 products
per month for the 15 months where trade was subjected to regulation.
The transformation of Thailand’s regulation and trade control policy in Bangkok is evident in
the marketplace over a two and a half years period. The overall effort taken to reach this stage,
due to the oversight process imposed by CITES, is admirable. Indeed, the CITES Elephant Trade
Information System (ETIS) report in June 2016 evaluated Thailand as a country of “secondary
concern”. However, the situation requires continued regulation and enforcement, particularly
given the active trade that appears to be occurring on online platforms. A separate online survey
on Facebook and Instagram accounts conducted by TRAFFIC between June and July 2016 showsthat at least 2550 ivory products, mainly jewellery, were recorded for sale on 42 sites/groups on
Facebook and Instagram. This figure is comparative to the average number of ivory productsthat were recorded in Bangkok’s marketplace from March – August 2015. At least 232 unique
individuals were identified to be offering ivory for sale. It is unknown if any of these traders
are legally allowed to sell ivory, though this clearly points to a need for continued vigilance,
particularly with online ivory trade.
Other key issues to address include the roll-out of a robust product marking system to track thedisposal of all registered worked ivory products and ensure that unregistered products are notlaundered into the system. Further, because none of the registered ivory was forensically examined
to ensure that no African Elephant ivory was inadvertently registered and made eligible for retailtrade in Thailand, there is a need to randomly test ivory products to demonstrate the integrity ofThailand’s management system for legal ivory trade. TRAFFIC stands prepared to work with theThai authorities to undertake DNA testing to ensure the highest levels of compliance with the newpolicy framework.

v

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

BACKGROUND AND INTRODUCTION
Thailand is an Asian Elephant range State and a country in which elephants hold great cultural
significance and have long been revered. Yet, for over 30 years, Thailand’s weak wildlife tradelegislation has enabled the country to function as one of the world’s largest unregulated domestic
markets for elephant ivory (TRAFFIC, 2009; and 2016). This state of affairs not only demonstrated
poor compliance with requirements under the Convention, but also became a major driver for
elephant poaching in Africa. Successive analyses of data held by the Elephant Trade Information
System (ETIS) since 2002 have consistently identified Thailand as a significant problematic end-use
market for illicit ivory (Milliken et al., 2002; 2004; 2007; 2009; and 2012).
This persistent scenario captured world attention at the 16th Meeting of the Conference of theParties to CITES (CoP16), hosted by the Government of Thailand in Bangkok during March
2013. At that meeting, and the follow-on 64th Meeting of the CITES Standing Committee (SC64),
decisions were taken to subject Thailand, along with eight other countries/territories1, to anintersessional oversight process to address illegal ivory trade under the direction of the Standing
Committee. Consequently, Thailand was required to develop and implement a time-boundNational Ivory Action Plan (NIAP) to address a range of outstanding issues that facilitate ongoingillegal trade in ivory, including components concerning legislation and policy, law enforcement,
monitoring and public awareness. Although Thailand’s NIAP was submitted to the CITES
Secretariat in May 2013 in compliance with the established deadline, it was only approved by Thai
Cabinet in September 2013, with the Ministry of Natural Resources and Environment (MoNRE)
designated as the lead agency for implementation. Thailand subsequently submitted its firstprogress report to the CITES Secretariat in October 2013.
Initially, Thailand’s overall intentions with the NIAP, especially the scope and timeframes for
fundamental legislative reform in the regulation of ivory trade, became a contentious issue at SC66
in July 2014. This meeting presented the first opportunity for the Standing Committee to review
the NIAP process and the outcome was severe for Thailand. Indeed, an apparent lack of progressand scepticism concerning the Thai Government’s commitment to fundamental change led theStanding Committee to adopt a decision calling for the country to enact appropriate legislation,
establish a comprehensive registration system, increase efforts to monitor and control ivory traders
and ivory data, and take law enforcement actions. The decision further contained a request for
Thailand to submit a progress report by 31 March 2015 and, if efforts were not satisfactory, the
CITES Secretariat was instructed to instigate a postal vote procedure in accordance with provisions
in Resolution Conf. 14.3, paragraph 30 that could lead to sanctions under the Convention.
Thailand was the only country or territory in the NIAP process against which such far-reachingaction was taken.
Paragraph 30 of Resolution Conf. 14.3 on CITES compliance procedures allows for the impositionof sanctions as follows: In certain cases, the Standing Committee decides to recommend thesuspension of commercial or all trade in specimens of one or more CITES-listed species, consistent
with the Convention. Such a recommendation may be made in cases where a Party’s compliancematter is unresolved and persistent and the Party is showing no intention to achieve complianceor a State not a Party is not issuing the documentation referred to in Article X of the Convention.
Such a recommendation is always specifically and explicitly based on the Convention and on any
applicable Resolutions and Decisions of the Conference of the Parties.

1

Kenya, Tanzania and Uganda (as Source countries); Hong Kong, Malaysia, Philippines and Viet Nam (as Transit countries) and China and Thailand (as Destination countries)

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

1

In response, Thailand re-submitted a revised NIAP on 15 January 2015 before the required
deadline, and has since provided two updates in January and September 2015 on the progress of
implementation of activities. The revised NIAP comprised an agenda addressing five main areas:
1) Enactment of laws and regulation to curb African Elephant ivory trade and to control
domestic trade and possession of elephant ivory;2) Implementation of three registration systems for: a) ivory traders and products, b) 		
legal ivory possession and c) confiscated ivory;3) Scaled-up law enforcement, including the creation and deployment of ivory trade patrol
teams to increase vigilance and enforcement;
4) Roll out of public awareness amongst main target groups, including foreign tourists, 		
traders, owners of ivory and the general public; and5) Instigation of a national mechanism comprising sub-committees by which ivory trade
can be addressed and resolved and be reported on to Thailand’s National Committee on 		
CITES and its Prime Minister.
In terms of concrete actions emanating from this revitalised NIAP process, a variety of activities
have diligently unfolded in a timely manner. In terms of legislation, two major developments
have occurred. Firstly, in December 2014, Thailand amended the Wild Animal Reservation andProtection Act (WARPA) B.E 2525 (1992) by listing the African Elephant Loxodanta africana asa protected species, thereby prohibiting the import, export, trade and sale of ivory from African
Elephants. This legal amendment came into effect in March 2015, establishing total protection
for another non-indigenous species; currently very few non-native species are afforded protection
by Thai law (Moore et al., 2016). As a result, legally-acquired African Elephant ivory could be
registered for legal possession under WARPA, but it was ineligible for commercial trade in the Thai
market under any circumstances.
Next, an entirely new law, the Elephant Ivory Act B.E. 2558 (2015), took effect on 22 January
2015 for the regulation and control of possession and trade of ivory that could be shown to haveoriginated from registered domesticated Asian Elephants in Thailand, which are managed under
the Draught Animal Act of 1939. The Elephant Ivory Act mandates anyone in possession of ivory,
including owners, dealers and traders, to register it, whether for commercial purposes or not, with
the Department of National Parks, Wildlife and Plant Conservation (DNP). Those who acquired
ivory, by any means, before the Act was gazetted, had 90 days to register it, with the final date forregistration established as 21 April 2015.
Further, under the law, anyone who subsequently acquires Asian Elephant ivory on or after 22
January 2015 is mandated to register their business and ivory stocks within 30 days of the dateof acquisition. This applies not only to traders, but also anyone coming into possession of ivory,
with an obligation to provide evidence of legal acquisition. Failure to register for possession ofdomesticated Asian Elephant ivory can result in heavy fines of up to three million Thai Baht
(approximately USD90 000). Significantly, failure to register for commercial trade in ivory may
result in up to three years imprisonment or up to a six million Thai Baht (approximately USD
186,000) fine, or both.
Following enactment of the Elephant Ivory Act, Thailand’s DNP successfully conducted anationwide registration of ivory stocks. Throughout the country, some 400 government officials
participated in the exercise with at least one registration office in every province. As of the end ofJune 2015, 40 324 people had reportedly registered ivory stocks in Thailand, of which about 15 000

2In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

(some 37%) were residents of Bangkok. Although some database issues have subsequently been
identified in terms of the accuracy of the aggregated values of collected information (Mr. Adisorn
Noochdumrong, Deputy Director General, Department of National Parks, Wildlife and Plant
Conservation, pers. com., 12 September 2016), the following summary was provided concerning
the status of the registration process in June 2015:
•
•
•
•
•

Number of people who registered ivory stocks nationwide 				40 324
Approximate number of people who registered ivory stocks in Bangkok		
15 000
Number of applicants registered for the intention to trade ivory 			247
Number of ivory products registered						670 984
Weight of ivory products (tusks, raw ivory pieces, worked products) registered (kg) 200 3582

Table 1 presents a summary of the registered stocks held commercially and privately, according to
Department of National Parks, Wildlife and Plant Conservation records in June 2015:
Table 1: Summary of Thailand’s ivory registration as at June 2015

Privately-heldCommercially-held
TOTAL

No of ivory pieces % of total
Weight (kg)% of total
315 13746.97
196 501.55
98.07
355 84753.03
3857.221.93
670 984
100.00200 358.77
100.00

Table 2 provides a more detailed account of the quantity of ivory that had been reportedly
registered at June 2015, with most stocks being identified as “personal effects”, indicating thatthe consumption of ivory has enjoyed considerable popularity in Thailand. At the same time, a
total of 2013 applications had reportedly been received from individuals who wished to engage incommercial ivory trade. Ivory for commercial purposes was declared at the time of registration,
comprising slightly less than 2% of the total quantity by weight, but represented 53% of the total
number of ivory items registered (Table 1). The average weight of the worked ivory registered ascommercial stock was only 9.31 grams per piece, indicating that most finished products for sale
represented extremely small items. As stated, only domesticated Asian Elephant ivory is eligible forcommercial sale in Thailand, but it should be noted that none of the commercial stocks registered
were subjected to forensic analysis to determine the species of the elephant involved.

2This weight may change due to issues concerning units of measurements used in the database3

It should be noted Thailand has reported to CITES that 247 trader applications have been recorded as at June 2015 (CITES, 2015).

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

3

Table 2: Stocks of ivory registered in Thailand as at June 2015 pursuant to the Elephant Ivory Act
Item

No. of Pieces

Privately-held Ivory Stocks
Raw ivory tusks
33 695.00
Raw ivory pieces
9548.00
Worked ivory pieces
271 894.00
Subtotal
315 137.00
Commercially-held Ivory Stocks
Raw ivory tusks96
Raw ivory pieces317
Worked ivory pieces
355 434.00
Subtotal
355 847.00
Total: All Ivory Stocks RegisteredRaw ivory tusks
33 791.00
Raw ivory pieces
9865.00
Worked ivory pieces
627 328.00
TOTAL
670 984.00% of total
pieces

Weight (kg)% of total
weightAverage Weightper Piece (kg)

10.69
3.03
86.28
100.00153 005.65
11 066.37
32 429.53
196 501.55

77.86
5.63
16.50
100.00

4.54
1.16
0.12

0.03
0.09
99.88
100.00200.81344.773311.643857.22

5.21
8.94
85.86
100.00

2.09
1.09
<0.01

5.04
1.47
93.49
100.00153 206.46
11 411.14
35 741.17
200 358.77

76.47
5.70
17.84
100.00

4.53
1.16
0.06

Source: Department of National Parks, Wildlife and Plant Conservation

More recently, according to information by DNP on 29 August 2016, some 32 ivory trading shops
in Bangkok remained in operation, while others had reportedly closed their ivory business; thenumber of ivory products held by these 32 shops is unknown. Throughout the registration period,
ivory continued to be sold in the Thai marketplace. This report provides a summary of the market
availability for ivory in Bangkok during the period before the Elephant Ivory Act came into effect,
and then tracked market developments through June 2016.

METHODOLOGYTRAFFIC conducted ivory market monitoring in Bangkok over an 18-month period from
December 2014 through June 2016 (with the exception of February 2015 when no surveys wereconducted). The sample of retail outlets surveyed was based on past surveys conducted in 2002,
2004, 2009, 2013 and 2014. Surveys were generally conducted during the last week of every monthover four or five days, across nine different retail market locations in the capital city: Chatuchak(also referred to as “Jatujak”) Market, Chatuchak Mall, River City, Amulet Market, MBK Plaza,
Amarin Plaza, Big C Rama 2, Central Rama 2, Central Rama 3. For the purposes of analysis, thelast three named locations have been merged under a single category of “others”, due to the very
low number of ivory products observed.
Data collected included the number of retail outlets (including permanent shops and temporary
stalls), ivory product types and the estimated number of items per product type. Surveys wereconducted by Thai native speakers, who were able to identify ivory reliably. As much as possible,
vendors were engaged in conversations informally, to gain some insight into sources, buyers andprices, as well as their general thoughts on the ongoing roll out of regulatory processes. Price
information was collected whenever possible, but was often difficult to obtain as traders noted therepeated presence of surveyors every month without making any purchase, and therefore weregenerally reluctant to share such information freely.
A conversion rate of THB 100 to USD 2.83 has been used, as at 30 June 2016 (https://www.oanda.
com/currency/converter/
4

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

RESULTS AND DICUSSION
Overall, survey results indicate a downward trend in terms of the number of shops selling ivory, as
well as the number of products recorded in trade, from December 2014 to June 2016 (Figure 1). The
top two locations with the highest number of retail outlets were Chatuchak Market and the Amulet
Market. From TRAFFIC’s previous surveys (Doak, 2014), the Chatuchak Market was the location
with the greatest number of retail ivory outlets, but the Amulet Market was in the fourth position,
being surpassed by the Chatuchak Mall and River City, two market locations which now show aconsiderable reduction in ivory product availability.
Figure 1: Number of shops selling ivory and the number of products found for sale from
December 2014 - November 2015
8000

50

7000

45
40

6000

35

5000

30

4000

25

3000

20
15

2000

10

1000

5

0

0
Dec Jan Mar Apr May June July Aug Sept Oct Nov Dec Jan Feb Mar Apr May Jun
2014 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2016 2016 2016 2016 2016 2016
No of estimated ivory products

Number of shops found selling ivory

Retail Outlets
From the range of 143 to 169 shops that were surveyed, an average of 17 shops sold ivory over the
18-month period. A high of 28% (or 47 shops) in December 2014 and a low of 3% (or 5 shops) in
June 2016 were found to be selling ivory (Figure 2). These findings shows a sharp contrast whencompared to surveys that were conducted over a 12-month period between January 2013 and May
2014, where the number of shops selling ivory ranged from 61 to 120, with an average of 93 shops
selling ivory during the entire period (Doak, 2014). Thus, overall the number of retail outlets
selling ivory had already significantly diminished by December 2014, the starting point of thepresent study, and has continued to decline markedly towards the end of the survey period. Since
the laws regulating ivory trade came into effect in Thailand in April 2015, the highest number ofshops (18) selling ivory was recorded in November 2015 and the lowest number (5) was in June
2016.

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

5Figure 2: Trend in the number of shops surveyed against those found to be selling ivory

Ivory Products© Kanitha Krishnasamy/TRAFFIC

Like the number of shops selling ivory, the survey data shows a high of 7421 ivory products in
December 2014 and a low of 283 in June 2016 (Figure 3). Although numbers have remained
low, the biggest jump in availability of worked ivory items occurred in September 2015 when an
increase of 1096 ivory products was noted at the Chatuchak Market, compared to the previous
month; this result was observed even though the number of retail shops increased by only a single
outlet compared to the previous month. September 2015 was also the month with the highest
number of products recorded in Bangkok since the new law came into force, but ivory productavailability has steadily declined ever since.

Ivory bangles are commonly sold in Bangkok.

6

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

Figure 3: Number of estimated ivory products in trade in Bangkok from December
2014-June 2016

7421

6950

3657
2811

2807

2279

2260

2536

3227

2575

2883
1609

Dec
2014

Jan
2015

Mar
2015

Apr
2015

May
2015

June July
2015 2015

Aug
2015

Sept
2015

Oct
2015

Nov
2015

1800

Dec Jan2015 2016

1527

1612

Feb
2016

Mar
2016

1239

Apr
2016

354

283

May
2016

Jun
2016

Consistent with the data on the number of retail shops found to be selling ivory, products were also
concentrated in two key locations: Chatuchak Market and the Amulet Market. Figure 4 is shownas the average number of products (for all 18 months) observed in all the surveyed locations, withan overall average of 2662 products being recorded monthly. However, when averaging the numberof products in trade since April 2015, when the law came into place, this monthly figure reducesslightly to a total of 2049 products.
Figure 4: Average monthly number of ivory products, by location, observed for trade in
Bangkok from December 2014-June 2016
No of ivory products

No of ivory products

2500

35
30

2000

25
1500

20

15

1000

10
500
5
0

0
Chatuchak Weekend Market

Amulet Market

Amarin Plaza

Chatuchak Mall

River City

Mahboonkrong Center

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

7© TRAFFIC

Figure 5: Typical ivory products sold in Chatuchak Market in September 2015

A total of 32 ivory product types were observed for sale during this period, which can be broken
down into three broad categories (Table 3).
Table 3: Categories and ivory product types observed for sale8

Jewellery

Accessories

Handicrafts, Decorative andFunctional items

1.

Bangles8.

Belt buckles

15.

Figurines (< 5 cm)

2.

Bracelets

9.

Combs

16.

Miniature sculptures (> 5 cm)

3.

Earrings

10.

Ear picks

17.

Stupas4.

Necklaces

11.

Hair pins

18.

Carved ivory boxes

5.

Pendants

12.

Brooches

19.

Chopsticks

6.

Rings

13.

Brushes

20.

Toothpicks

7.

Beads

14.

Ivory fans

21.

Cigarette holders/ smoking pipes

22.

Gun handles

23.

Knife handles

24.

Fiddle handles

25.

Name seals

26.

Name plates

27.

Chess pieces28.

Key rings

29.

Other carved products

30.

Raw tusks

31.

Carved tusks

32.

Polished tusks

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

Table 4 summarises the top 10 most abundant products available for sale, the most numerous
being ivory beads. These were likely loose items that were due to be strung into other products,
such as necklaces or bracelets. The general absence of bangles in recent surveys is a remarkabledevelopment given the numbers observed in the past.
Table 4: Top 10 most abundant ivory product types for sale
Month

Beads

Pendant

Bangle Necklace

Ring

BraceletFigurine(height<5cm)

Earring

Miniature
sculpture(height>5cm)

Dec-14

1171

981

1341

Jan-15

1400

800

1138

Mar-15860

641

Apr-15550

330

Carved TOTAL
ivory

550

941

278

227

102

734

614

7059

582

848

348

920

102

285

343

6835

252

277

175

47

33

157

6

152

2613

186

146

315

116

400

0

53

140

2253

May-15

750

580

223

361

190

140

180

70

88

81

2679

Jun-15

815

235

221

156

285

226

155

0

77

67

2244

Jul-15

870

250

253

192

275

227

130

58

85

60

2407

Aug-15

950

312

188

307

197

349

95

25

81

15

2520

Sep-15

840

1067

389

192

427

217

23

99

55

144

3464

Oct-15

1130

607

226

379

120

341

103

87

95

32

3120

Nov-15

860

557

266

256

215

329

106

73

70

65

2799

Dec-15

0

197

950

188

307

312

81

349

25

1

2505

Jan-16

0

427

840

389

192

1067

55

217

99

11

3320

Feb-16

0

215

860

266

256

557

70

329

73

2

2734

Mar-16

455

380

44

218

105

112

84

60

59

15

1542

Apr-16

480

290

37

75

100

49

57

55

27

30

1202

May-16

12

54

17

27

30

19

16

15

11

10

212

Price information was collected whenever possible. However, as noted, most vendors werereluctant to share information with individuals who had previously visited their shops without
making any purchases. A summary of prices observed from November 2015 onwards is provided
in Table 5.
Table 5: Ivory product priceType of products

Size

Bangles
Bracelets
Necklaces
Pendants
Pendants
Rings
Earrings
Figurines
Figurines
Miniature sculptures
Large ivory skull (approximately 4cm)
Small ivory skull (approximately 1cm)

<5 cm
>5cm

<5 cm
>5cm

Price range/piece) (THB)

USD

5000-25000
2000-5000
3000-6000
300-1000
2000-4000
400-1,200
500-1500
800-2000
2500-50 000
7000-25 000
3800
400

141-708
57-14285-170
8.5 - 28
57-113
11-34
14-42
23-57
71-1417
198-708
113
12

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

9Over the current survey period there was a pronounced reduction in the open availability of ivory
products being sold. An average of 2049 ivory products were observed over the previous 15 months
since the completion of the ivory registration in April 2015. On 2 May 2015, when TRAFFIC staff
visited Chatuchak Market, just as the ivory registration process was wrapping up, for the first timeever not a single ivory product was observed for sale. But by the end of the month, over 1500 ivory
products were again being offered for sale, presumably after they had been registered. Many of the
shops that sold ivory in May 2014 no longer sold ivory products 12 months later but instead hadother decorative items on offer. However, since March 2016, the last four months of the current
survey period, the number of ivory products observed in the market has continued to decline.
Although very few new shops have emerged in some locations in Bangkok, more appear to haveclosed or moved to different locations. A number of the shops closed that are no longer in businesswere those who were not selling ivory as their main product; most were selling other jewellery
and handicrafts. It is unknown if any of these shops that are no longer in business had legally
registered with the government and were permitted to trade in ivory. This reduction appears tobe the result of increased law enforcement action to ensure strict regulation of Bangkok’s physicalivory market in accordance with Thailand’s new laws. While these trends on the open availability
in Bangkok show a positive sign, it is important to be vigilant and monitor how ivory might bemoving to other platforms, such as online or social media trade, or to other locations in Thailand
historically notable for ivory trade, such as the provinces of Surin, Uthai Thani and Nakhon Sawan(Stiles, 2009). This is discussed further below.

Surveys compared

It is clear that Thailand has seen a major reduction in the open availability of both ivory products
and the number of shops selling them its capital city over a two and a half year period at a time
when the country was subjected to unprecedented oversight pressure under CITES and theinternational community. Surveys conducted in the past found far more ivory trade activity.
For example, in December 2013, a peak of over 14 500 ivory products were available for sale in
Bangkok, while in May 2014 over 13 000 ivory products were observed. Similarly, the number ofoutlets selling ivory was high, with March and May 2014 recording the highest number of shops
selling ivory, 120 shops each month (Figure 6).
Figure 6: Trend in retail outlets selling ivory in Bangkok over 30 (non-consecutive) months
between January 2013 and June 2016
Number of retail outlets

10

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

When comparing the survey results over two distinct periods – when there was no law governing
ivory trade (until March 2014) and then after ivory trade became legally controlled (April 2014
onwards) – a marked reduction is apparent. From January 2013 to December 2014, when ivory
trade was completely unregulated in Thailand, an average of 10 723 ivory products per month
were recorded in the 13 months in which surveys were conducted (it should be noted however, thatduring this 24-month period, a hiatus in market monitoring occurred from May-September 2013
and June-November 2014). In contrast an average of 2049 ivory products per month were recordedin trade from April 2015 – June 2016, over the 15 months assessed (Figure 7a). Similarly, thenumber of shops selling ivory averaged 89 over the 13 assessed month when ivory was unregulated
in Thailand, compared to only 14 shops selling ivory in the succeeding 14 months (Figure 7b).
The timeline for ivory registration was 22 January - 21 April 2015; TRAFFIC’s market monitoring
activities were conducted during the last week of the month, therefore the month of January 2015
is excluded, while April 2015 is included in this count. Interesting insights are also evident whenoverlaid with notable incidents and milestones regarding Thailand’s ivory trade issues vis-à-vis
CITES (Figure 8).
Following completion of the registration exercise and the resumption of ivory sales in local
markets, DNP reported to have undertaken regular inspection of local markets. In late January
2016, shortly after Thai government representatives had returned home from the 66th Meetingof the CITES Standing Committee (SC66) where they had presented another update on theimplementation of their NIAP, a “crackdown by the Department of National Parks resulted in 13
of 24 ivory shops being closed in Nakhon Sawan province because they could not show prove they
were legal” (Mokkhasen, 2016). TRAFFIC’s 2009 survey of Thailand’s ivory trade identified the
Phayuha Kiri and Uthai Thani area south of Nakhon Sawan as second to Bangkok, in terms of
the availability of ivory products (Stiles, 2009). As these areas fall outside of TRAFFIC’s current
market monitoring, effort to document the scale of ivory trade in areas outside Bangkok, such as
the Surin Province in northeast Thailand or Nakhon Sawan in northwest Thailand.
More recently, in Bangkok, DNP also reported that spot checks of retail ivory dealers have resulted
in the confiscation of ivory products that were suspected of being crafted from African Elephantivory, which is now completely illegal under Thailand’s new ivory trade laws. In this regard, on
an experimental basis, a hand-held device that was reportedly developed by researchers at Chiang
Mai University was used by the Wildlife Conservation Office of DNP in a series of trial tests todifferentiate African from Asian Elephant ivory in the marketplace. Using this tool, DNP officers
were able to establish “probable cause” concerning the illegal origin of ivory products found for salein the market and on that basis obtain such specimens for further forensic testing (Mr. Adisorn
Noochdumrong, Deputy Director General, Department of National Parks, Wildlife and Plant
Conservation to Tom Milliken, pers. comm., 12 September 2016). As the Elephant Ivory Act places
the burden of proof for establishing the legal provenance of ivory products on their owners, failure
to produce compelling evidence to assert legality would result in the seizure of the product inquestion. Seized items can then be forensically tested using DNA methods to establish the elephantspecies from which the product originated and the results of such tests would be admissible in
Thailand’s courts as evidence, if prosecution becomes necessary.
As a result of market monitoring and testing, DNP reported that a number of outlets have been closed
down for selling African Elephant ivory products and many others have terminated displaying and sellingivory in the country’s physical markets because they fear being compelled to prove the legal origin of theirivory. Whilst it remains unclear how this development relates to the market survey results in this report,these trials nonetheless serve as proactive illustration of the deterrent value of market surveillance whenlinked to burden of proof consequences on the retail ivory vendors. Strict implementation of Thailand’s
prohibition on any retail sales of African Elephant ivory products remains essential and must form partof Thailand’s continued effort in addressing illegal ivory trade.

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

11Figure 7a (top): Number of average ivory products observed in Bangkok; 7b (bottom):
Number of average shops observed selling ivory in Bangkok

17%

83%

Unregulated (Jan 2013 - Dec 2014)
Regulated (Apr 2015 - Jun 2016)

14%

86%

Unregulated (Jan 2013 - Dec 2014)
Regulated (Apr 2015 - Jun 2016)12

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

© Tom Milliken / TRAFFIC

In its report on the progress of the NIAP implementation, the DNP reports that 247 traders havebeen registered (CITES, 2015). In some cases, traders informed surveyors that they had registered
their shops in order to conduct legal ivory trade and, in one case, the trader showed researchers
the registration document. Some traders felt that the new registration process, which requires
both traders and buyers to be registered, would affect their business as this added procedural
requirements that were previously absent, and may serve to dissuade consumers. Other traders
indicated that they should not be selling products to foreigners due to prohibitions concerning thecarrying of ivory products across borders. Some traders felt that the registration process institutedby the government invited more Thai purchasers, while in the past clientele were predominantly
foreigners from China, Japan, United States and Europe. Other vendors also declared that buyers
will need to register with them upon purchase using their national Identification Cards; thesevendors reported that they only sell to Thai nationals. One vendor claimed that the ivory fromwhich skulls were carved (pictured in Figure 9) originated from domesticated Thai elephants andthe seller was very open to discussing the carving quality and prices. These ivory skull carvings
were not common in Bangkok’s ivory market previously, and appear to be a new product type.
Observations in the market by other TRAFFIC staff, however, has found Chinese speaking tourists
purchasing jewellery, including earrings, which would be in violation of Thailand’s regulatory
policy.

Thousands of ivory products were recorded during Thailand’s nationwide registration programme.

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

13

14

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

0

2000

4000

6000

8000

10000

12000

14000

16000

Elephant Ivory
Act begins
enforcement

Elephant Ivory
Act established

Thailand amends
WARPA, prohibiting
African Elephantivory trade

CITES SC 66: Thailand asked toamend legislation andestablish ivory registration
system, or face potential CITES
trade sanction

Thailand registers 355 847
commercially-heldivory stocks

CITES ETIS reportconsiders Thailand acountry of “secondary
concern”

Thailand’s unregulated ivory market

Graceperiod*Thailand’s regulated ivory market

Jan Feb Mar Apr Oct Nov Dec Jan Feb Mar Apr May Dec Jan Mar Apr May June July Aug Sept Oct Nov Dec Jan Feb Mar Apr May June2013 2013 2013 2013 2013 2013 2013 2014 2014 2014 2014 2014 2014 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 2016 2016 2016 2016 2016 2016

Thailand submits
NIAP, assessed as
unsatisfactory

CITES SC 64: Thailand
identified as country ofprimary concern,
subjected to NIAP

Figure 8: Trend in ivory product availability in Bangkok over 30 (non-consecutive) months between January 2013 and June 2016, against key
milestones regarding Thailand’s compliance with CITES and subsequent implementation against the National Ivory Action Plan process© Serene Chng / TRAFFIC

Figure 9: Ivory skull carvings that traders reported to have originated fromdomesticated Thai elephantsMoving beyond Thailand’s domestic market, vigilance at the airport, including the authorities
increased frequency of passenger luggage inspections also seem to be yielding some results incurtailing illegal ivory trade in Thailand. The country’s Elephant Ivory Act has also introduced
a number of measures to better regulate domestic trade, including notably transportation of raw
ivory between provinces, and a process has been established to monitor movement, including
vehicles used to transport ivory, and the specific routes through which transport is allowed. Thisis all in addition to the registration process, with the aim of controlling illegal trade. The Thaigovernment has also erected signs at its international airport, including in the Chinese language,
warning tourists not to buy or take ivory products out of the country. However, monitoring andensuing enforcement to counter trade activity occurring online is required and could be a factor
serving to undermine the regulatory controls enacted by the Thai government.

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

15

A SHIFT TO ONLINE MARKETING AND SALE OF
WORKED IVORY PRODUCTS
A separate study conducted by TRAFFIC between June and July 2016 found at least 2550 products
being offered for sale online (Nguyen et al., in prep). This survey monitored 22 Facebook groups,
seven individual Facebook accounts and 13 Instagram accounts. A summary of findings ispresented in Table 6.
Table 6: Summary of ivory trade observed on Facebook and Instagram from June to July 2016
in Thailand
Key Element

Findings

Monitoring Period
Number of Facebook
Groups and Instagram
accounts monitored

25 days (one hour every weekday from 20 June – 22 July 2016)
42 in total•

22 Facebook groups•

7 Individual Facebook accounts•

13 Instagram accounts

Number of posts offering ·•ivory or elephant products·•

653 posts offering a total of 2550 ivory products
56 posts offering non-ivory elephant products (such as tail, teeth,
elephant oil/placenta)

Predominant product type Jewellery (48%)
for sale
Location of seller

A majority of the sellers appeared to note their location (of the post) as
Bangkok, recording at least 31 individuals with 186 ivory items being offered
for sale. This was followed by Surin (in north-eastern Thailand) at 14
individuals with a minimum of 462 ivory products offered for sale

Price

Prices that were shown in sale posts ranged from hundred to millions ofThai Baht (approximately USD2.90 to USD28 895).

Forms of communication

Facebook private message, Telephone call, Line Messenger, SMS/Text

Payment method type

Payment methods varied but most sellers requested a prospective buyer totransfer the agreed amount of money to their bank accounts after the deal.
It was found that some sellers even provided their national identification
card (ID card) details in order for them to directly be able to access andverify the items they were interested in purchasing.

Source: Extracted from Nguyen et al., in prep.

The number of products recorded in internet trade (2550) was in fact higher than what wasrecorded over the last seven months in Bangkok’s physical markets in the period from December
2015 through June 2016. The average number of ivory items recorded during those months was1203 products, about half of what was observed during the internet survey, whilst even the highest
number recorded in January 2016 (1800) is still less. The fact that a high number of products were

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

17

observed for sale online serves to confirm earlier concerns regarding a potential market shift fromthe physical marketplace to online platforms as has been the case in China (Xiao and Wang, 2015).

© TRAFFIC

Figure 10: Bangles mixed with gold and other gemstones found for sale on Facebook in
Thailand in July 2016

The internet has clearly evolved to become a key global platform facilitating illegal wildlife trade(Chng and Bouhuys, 2015; CITES, 2016; Krishnasamy and Stoner, 2016). In China, a TRAFFIC
study in 2013 found over 115 elephant tusks, over 276 ivory segments, at least 77 whole rhino horns
or pieces and at least 46 Helmeted Hornbill Rhinoplax vigil casques for sale on social media, over a
one month period (Xiao and Wang, 2015). Movements of ivory trade to online trading platforms
is clearly becoming a more popular choice for conducting business in endangered wildlife species,
and this seems to be the case in Thailand too. For example, Thai authorities have made a numberof arrests where Thai citizens were involved in the online sale of Burmese Star Tortoises Geochelone
platynota, Leopard Cat Prionailurus bengalensis, Dusky Leaf-monkey Trachypithecus obscurus aswell as ivory (Bangkok Post, 2015; CITES, 2015; Wildlife Conservation Society, 2015; Anon, 2016;
Samart, 2016).

18

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

© Kanitha Krishnasamy / TRAFFICWhile a direct relationship with the situation in the physical market place is not yet established,
the high presence of ivory trade on the internet is a worrying development in Thailand. A small
number of traders noted that they were legally registered with the government to trade in ivory,
but a vast majority of them did not provide this information in their posts. Research by TRAFFIC
noted that only one post showed an ivory product was registered with the DNP, while a further
25 posts showed their ivory trading licenses (Nguyen et al., in prep). This research also found that
only a small number of traders claimed to have registered with the DNP, yet no proof of this wasoffered. Indeed, a vast majority of the posts did not mention any documentation or permits. It
is also not yet clear if prices differ significantly online compared to the same products found in
Bangkok’s physical market, as internet traders usually ask prospective buyers to contact them
via private messaging. The volume of products appearing for sale online is a concern especiallysince Southeast Asia has been noted to have some of the highest social network usage in the world(eMarketer, 2015). Cybercrime has been recognized by CITES, as described in the CITES CoP
17 Doc.29 regarding Combating Wildlife Cybercrime: “the growth of the internet has facilitatedcommunication and commerce between individuals and institutions at a global scale, and there is aneed to continually scale up efforts to address wildlife crime linked to the Internet” (CITES, 2016).

A shift in Thailand’s raw ivory trade patterns
Thailand was identified as a “country of primary concern” in the ETIS analysis to CITES CoP16
owing to its role as an end-use destination for illegal consignments of ivory. In this regard, withsome frequency, large-scale shipments of raw ivory were periodically being directed from Africa
to Thailand for the production of ivory products sold on the domestic market. Whilst China wasidentified as the primary end-use destination globally, Thailand held the second most prominent
position as an unregulated ivory market in Asia (Milliken et al., 2012). Based on raw data of ivory
seizures reported to ETIS, Figures 11 and 12 map the movements of large-scale ivory shipmentsthat were 500 kg or more in two three-year periods of time.
Figure 11 covers ivory trade flows in 2009-2011, which reflect the raw data used in the ETIS
analysis to CITES CoP16, whilst Figure 12 addresses the years 2012-2014, which reflect the large
seizures in the ETIS analysis to CITES CoP17. The trade routes depict the reported pathways theseivory consignment followed regardless of where the seizure itself actually occurred. In Figure 11,
Thailand can be seen as the final destination for various shipments of ivory coming from Kenya,
Uganda and Ethiopia in Africa, Qatar and the United Arab Emirates in the Middle East, and from
Malaysia and Singapore in Southeast Asia. Whilst the scale of this trade is certainly less than what
can be seen going into China, Thailand was nonetheless a significant destination.

20

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

Figure 11: Observed trade routes for large-scale ivory seizures, 2009-2011(ETIS 25 January 2016)

In sharp contrast, in Figure 12, Thailand does not register as part of any trade chains for large
movements of ivory that were seized and reported to ETIS in the more recent period, (hence,
Thailand is not highlighted in green or labeled TH on the map). Whilst undetected consignmentsof ivory were certainly possible, if law enforcement effort remained constant in Thailand during
this period, a real decline in the importation of raw ivory could have resulted. In fact, the country’s
domestic ivory market was under constant attack in the build up to CITES CoP16 and then,following the momentous decisions under the Convention to launch a National Ivory Trade Action
Plan process, the pressure only increased thereafter. The ETIS data seem to lend credence to theview that uncertainty about the future of local ivory industries resulted in a sustained lapse infurther investment in raw ivory which potentially could become a future liability. In any event,largely because of the absence of large movements of ivory in the period 2012 through 2014,
Thailand’s position in the ETIS analysis to CITES CoP17 changed to a “country of secondary
concern” for the first time.

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

21

Figure 12: Observed trade routes for large-scale ivory seizures, 2012-2014(ETIS 25 January 2016)

In 2015, movements of raw ivory to Thailand once again resumed but with a notable caveat. All
three of the interdicted consignments which contained over 500 kg of ivory were in transit when
they arrived in Thailand and were bound for the Lao People’s Democratic Republic, according to
the shipping documentation. These seizures, which originated in Kenya, the Democratic Republicof the Congo and Nigeria, totalled 6052 kg of raw ivory (587 kg of pangolin scales were also seizedfrom the Nigerian shipment). These seizures could be suggesting that the role of Thailand in theivory trade may be changing to that of transit country, similar to Malaysia and Singapore; however
ongoing monitoring will be necessary to confirm any such development.

22

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

CONCLUSION AND RECOMMENDATIONS
The affirmative decisions taken by the CITES Standing Committee to push the NIAP process
have thus far led to positive results in terms of curtailing ivory trade in the markets of Thailand’s
capital city. The responsive efforts of the Thai government to promulgate and implement far
reaching legislative and regulatory reform appears to demonstrate a considerable and progressive
reduction in the number of ivory items observed for sale. This unprecedented transformation ofThailand’s trade control policy for ivory is clearly evident in the marketplace; while there is little
reason to believe that a resurgent physical market in Bangkok would arise in the future, this canonly be achieved if strict implementation continues to unfold, along with adaptive management
by law enforcement agencies in response to any shifts in trade trends, both involving physicalmarkets throughout the country, as well as those occurring on online platforms. The new andgreatly strengthened legislation in place effectively bans any and all trade in African Elephant ivory
without exception. This legal basis, along with a suite of supportive regulatory measures to ensurecompliance, has changed the situation markedly since the July 2014 CITES Standing Committee
meeting where decisive action put Thailand on notice. Thailand now stands as an inspiring
example of what can be achieved on a relatively short time scale to curtail and prevent illegal ivory
trade in the context of the CITES-orchestrated NIAP process.
Thailand’s challenge now is to consolidate and institutionalise the remarkable progress that has
been made to date with focused attention on a number of key issues that remain to be addressed.
The government’s allowance of retail ivory sales to commence prior to the roll-out of an ivory
marking system for products in the marketplace needs to be reconsidered. Whilst the overall effort
taken to reach this stage in a fairly short period of time is admirable, Thailand’s domestic ivory
trade still requires attention to ensure that it fully complies with CITES requirements for domestic
trade in ivory. Key issues to address, which therefore constitute priority actions for attention
include:• The roll-out of a robust product marking system to track the disposal of registered worked
ivory products in the marketplace and ensure that unregistered products are not laundered
into the system.
• Continuation of the random forensic DNA testing of products being sold in the market
place to verify that they originate from Asian Elephants, as allowed by law. At the timeof registration it was not possible for ivory to be forensically examined to differentiate
African from Asian Elephant ivory. That challenge should now shift to the retail trade in
Thailand, where spot checks need to continue on a regular basis to ferret out any illegal
products in local markets. Such efforts are seen to be critical in demonstrating the integrityof Thailand’s management system for legal ivory trade. TRAFFIC stands prepared towork with the Thai authorities to undertake DNA testing to ensure the highest levels ofcompliance with the new policy framework.
• Ongoing physical market monitoring in Bangkok, including a revisit of shops that haveclaimed to have shut their businesses down, must continue. Efforts thus far have been
instrumental in tracking the impact of policy, regulatory and law enforcement interventionsin the marketplace.
• Monitoring of other notable ivory trade locations in Thailand outside Bangkok (such as
the provinces of Surin, Uthai Thani and Nakhon Sawan) to document any possible shiftof market availability from Bangkok. Subsequent law enforcement as necessary will beequally important to maintain deterrents to illegal activity. Monitoring by Thai government
authorities of any possible shift of ivory stocks from Thailand into neighbouring countries
with active market availability, such as Lao PDR or Viet Nam, will be important for regional
co-operation in response to changes in ivory trafficking dynamics.
In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

23© TRAFFIC• The regular monitoring of ivory trade occurring on the internet and social media
in Thailand needs to continue, both law enforcement agencies as well as NGOs, andappropriate law enforcement strategies need to be developed for this avenue of ivory trade.
Internet and social media trading poses and clear threat to Thailand’s ivory trade controls
and will require focused attention to combat effectively. Measures to scale-up enforcement
action should include engagement with relevant social media platforms (such as Facebook),
search engines and e-commerce platforms.

Thailand crushed two tonness of confiscated ivory in August 2015.

24

In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

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December. http://newsroom.wcs.org/News-Releases/articleType/ArticleView/articleId/8442/FacebookInvestigation-Leads-to-Turtle-Thieves.aspx
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In Transition: Bangkok’s Ivory Market – An 18-month survey of Bangkok’s Ivory market

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© By Laszlo1801 (Own work) [CC BY-SA 3.0 (http://creativecommons.org/licenses/by-sa/3.0)], via Wikimedia Commons

SEPTEMBER 2016

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