TRAFFIC CLOSING STRATEGYR E P O R T

APRIL 2017

ENDING IVORY TRADE IN HONG KONG

Lau, W., Xu, L., Guan, J. and Xiao, Y.

TRAFFIC REPORTTRAFFIC, the wildlife trade monitoring
network, is the leading non-governmentalorganization working globally on tradein wild animals and plants in the context
of both biodiversity conservation andsustainable development. TRAFFIC is a
strategic alliance of WWF and IUCN.
Reproduction of material appearing in thisreport requires written permission from thepublisher.
The designation 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 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
not necessarily reflect those of TRAFFIC,
WWF or IUCN.
Published by TRAFFIC.
TRAFFIC, East Asia Regional Office, No. 1
Tramway Path, Central, Hong Kong.
© TRAFFIC 2017. Copyright of material
published in this report is vested in
TRAFFIC.
ISBN no: 978-1-85850-418-6
UK Registered Charity No. 1076722

Suggested citation: Lau, W., Xu, L, Guan, J.
and Xiao, Y. (2017). Closing Strategy: Endingivory trade in Hong Kong. TRAFFIC, Hong
Kong.
Cover photos: ivory objects on sale in Hong
Kong © TRAFFIC
Design:ADB Design Studio, Beijing
jihuatang99@163.com

CLOSING STRATEGYENDING IVORY TRADE IN HONG KONG

© TRAFFIC

Lau, W., Xu, L., Guan, J. and Xiao, Y.

With the support of:ACKNOWLEDGEMENTS
The author thanks TRAFFIC colleagues, especially Tom Milliken, Yannick Kuehl, James Compton,
Zhou Fei, Sabri Zain, Richard Thomas, Julie Gray, as well as Gavin Edwards, Cheryl Lo and Ken Chanfrom WWF Hong Kong for their reviews and ongoing support during the drafting process.
Preparation and implementation of this report was made possible with funding support from
Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) on behalf of the German Federal
Ministry for Economic Cooperation and Development (BMZ) and the German Federal Ministry for
Environment, Nature Conservation, Building and Nuclear Safety (BMUB), WWF Hong Kong, andthe Rufford Foundation.

T A BLE OF CON T E N TS

Executive Summaryvii

List of Boxes and Figuresx

1. Background1

2. Recent Developments

4

3. State of Licensing and Reporting of Ivory Stockpiles

7

3.1. Licence to possess ivory

7

3.2. Stockpile and transaction records

8

3.3. Other forms of selling

89

4. Methodology
4.1. Targeted ivory outlets

9

4.2. Survey method

910

5. Results
5.1. Status of shops

10

5.2. Outlet types and the types of ivory items on display

11

5.3. Outlet types and size of ivory stocks on display

12

5.4. Licence and poster display

13

5.5. Prices of displayed ivory

14

5.6. Willingness to promote illegal behaviour

15

5.7. Licences displayed and willingness to promote illegal behaviour

16

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong iii

5.8. Number of ivory items displayed and willingness to promoteillegal behaviour
6. Challenges In Phasing Out Hong Kong’s Ivory Trade

1718

6.1. Local ivory trade under the existing regulatory system

18

6.2. Recent escalation of the ivory trade18

6.3. Challenges to phasing out Hong Kong’s ivory trade23

6.4. Challenges in tackling organized crime24

7. Conclusions

26

8. Recommendations

27

8.1. Bring forward proposed plans to ban local ivory trade28

8.2. Regular reporting and monitoring28

8.3. Expand system of stockpile labelling28

8.4. Regulating the trade in antique ivory

28

8.5. Review Hong Kong's stockpile management system for
confiscated ivory

29

8.6. Tackling ivory and other wildlife crimes: enhancing
enforcement30

8.7. Tackling ivory and other wildlife crimes: penalties to suit a
serious crime
8.8. Demand reduction strategies
9. References

iv TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

30
31
32

ABBREVIATIONS AND ACRONYMS
AFCD

Agriculture, Fisheries and Conservation Department

Cap.

Chapter number of Hong Kong Ordinances (Legal Acts)

Cap. 586

Protection of Endangered Species of Animals and Plants Ordinance

CITES

Convention on International Trade in Endangered Species of Wild
Fauna and Flora

COBRA IIIOperation COBRA III was a collaborative international law
enforcement operation aimed at combating wildlife crime andbringing criminals to justice. The operation was completed in May
2015.

ETIS

Elephant Trade Information System

EU

European Union

EU-TWIX

European Union – Trade in Wildlife Information eXchange

Hong Kong SAR

Hong Kong Special Administrative Region of the People’s Republicof China

Mainland China

People’s Republic of China

NIAP

National Ivory Action Plan

NICE-CG

China’s National Inter-Agency CITES Enforcement Collaboration
Group

PICE-CG

China’s Provincial Interagency CITES Enforcement CoordinationGroup

Pre-banIvory acquired before Hong Kong implemented the international
trade ban in 1990 and have been registered by AFCD (Environment
Bureau and AFCD, 2016)

Pre-Convention

Ivory products that were acquired before 1975 for Asian Elephants and1976 for African Elephants (Environment Bureau and AFCD, 2016)

UK

United Kingdom of Great Britain and Northern Ireland

USA

United States of America

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong v

© TRAFFIC

Large ivory figurine displayed in a licensed ivory outlet in Hong Kong
TRAFFIC report: A rapid survey of UK ivory markets iii

iivi TRAFFIC
TRAFFICreport:
report: AArapid
rapidsurvey
surveyofofUK
UKivory
ivorymarkets
markets

EXECUTIVE SUMMARY
Elephant poaching and illegal ivory trade have increased considerably in the past decade. This has
occurred despite international control measures through the listing of the Asian Elephant Elephas
maximus and African Elephant Loxodonta africana in the appendices of the Convention on
International Trade in Endangered Species of Wild Fauna and Flora (CITES), which restricted theinternational commercial trade of ivory from 1990. It has resulted in calls for urgent deterrent actions
that go beyond CITES requirements, including domestic measures to address the illegal trade.
CITES is given effect in Hong Kong through the Protection of Endangered Species of Animals andPlants Ordinance (Cap. 586) which controls the import, (re-)export and local trade of ivory. Hong
Kong was once a prominent trading centre for ivory in the 1970s and 1980s, but the industry contracted
considerably following the implementation of CITES trade restrictions in 1990, and waning demand
from traditional overseas consumers. However, resurgence in international ivory trade activity in thepast decade, both legal and illegal, have also reinvigorated Hong Kong’s local ivory market. This has
led many conservation advocates to campaign for a ban on ivory trade in Hong Kong. The Hong Kong
Government’s proposal to phase out local ivory trade, which was first announced in January 2016
and developed in June 2016, as well as additional enforcement and licensing measures, would be asignificant commitment if passed through Hong Kong’s Legislative Council, in line with ambitions in
China, the USA and elsewhere to take drastic actions against illegal ivory.
This report presents an assessment of commercial ivory trade in Hong Kong. Market surveys of ivory
outlets were conducted during two periods—August and December 2015—with a rapid survey inNovember 2016 revisiting most of the same shops. These surveys occurred during a period when
denouncements of the local ivory trade were at their most vocal, with new government measuresand the possible cessation of local ivory trade bringing about significant uncertainties for local ivory
traders. In this respect, this report captures the market conditions and sentiments at a critical momentin Hong Kong’s ivory trading history. In addition, CITES trade data on import and re-export of preConvention ivory from Hong Kong between 2000 and 2015, as well as government seizure reports,
were analysed to examine the extent to which Hong Kong plays the role of a trading hub for theinternational ivory trade, and discrepancies with local sentiments about the state of Hong Kong’s
ivory industry.
Physical market surveys in the two main survey periods in 2015 found that while ivory is still readily
available in Hong Kong, the vast majority of ivory retail outlets have to supplement their operations
by selling a range of other goods, whether it is mammoth ivory, stone and timber carvings, otherprecious jewellery or antiques. Dealers generally spoke of a sluggish ivory market at the time of thesurveys. When these ivory outlets were revisited in 2016, seven outlets appeared to have closed down
for business, and two dealers spoke of plans to downsize by closing branch stores and to focus on thewholesale side of their ivory business. Overall, a consolidation of the market appears to be occurring.
Larger specialist outlets were still making sales, but smaller outlets with a few ivory items displayed
had fewer active transactions.
Local ivory trade is controlled through a licensing system whereby premises have to be licensed
before they can commercially trade in pre-ban ivory (pre-1990), and the licence must be displayedon their premises. Market surveys found that only 38% of outlets had licences displayed or had
claimed to possess one. When questioned about whether ivory items can be taken out of Hong Kong,
36% of local ivory dealers were willing to sell ivory to buyers intending to depart from Hong Kong,
encouraging the smuggling of small ivory items as personal effects without going through the due
process of acquiring a CITES permit. 42% of traders accurately mentioned the need to have adequate
CITES documentation with their purchase. Outlets that had licences displayed were only slightly

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong vii

less likely to suggest that smaller pieces of ivory might go unnoticed by enforcement authorities iftaken across Hong Kong’s borders. These findings present the shortcomings in the existing regulatory
system, both in terms of compliance with existing regulations, as well as current perceptions of any
law enforcement deterrent.
According to CITES trade data, a considerable quantity of pre-Convention ivory has been imported
into Hong Kong between 2010 and 2014, totalling 6,056 ivory pieces plus 4,554 kg. The majority ofthese imports were sourced from European countries. More than half of the ivory imported was raw
ivory. Meanwhile, declared re-exports of pre-Convention ivory amounted to 323 ivory pieces plus
3,264 kg during the same period. Data from the CITES trade database show that raw ivory re-exports
during this time were all destined for mainland China, indicating that the market in China is probably
a driver for Hong Kong’s raw ivory imports. It is puzzling, however, that part of the inflows of raw
ivory into Hong Kong remained in the city, according to CITES data, even though there are no moreivory carving factories in Hong Kong and most carvers only operate on a part-time basis undertaking
repair and bespoke work.
The current proposal to phase out the local ivory trade, which as of the report’s publication has still
to be passed by the Hong Kong Legislative Council, will be a monumental step towards ending Hong
Kong’s once prominent role in the global ivory trade. However, a potential scenario that may develop
even before a local trade ban is in place is that it could cause a surge in ivory trade out of Hong Kong. It
is pertinent that law enforcement agencies remain vigilant that it does not lead to an increase of illegal
trade activities. Several major ivory markets around the world have already imposed restrictions on
the import of pre-Convention ivory, which would make Hong Kong’s re-exports of ivory to thosecountries illegal, especially that of mainland China, which has had a blanket import ivory ban in placesince 2016. Online ivory trade could be one method by which ivory dealers attempt to liquidate theirstock, and much greater effort is required of Hong Kong’s enforcement agencies to work with social
media and e-commerce platforms to prevent illegal ivory transactions from taking place. Current
plans to maintain an antique ivory trade, which would restrict trade to only a small pool of ivory itemsin Hong Kong, should also be monitored closely in future to prevent the laundering of non-antiqueivory, or inadvertently encourage consumer demand for that ivory.
The report recommends that the Agriculture, Fisheries and Conservation Department (AFCD) takethe following actions immediately to improve management of local ivory trade in Hong Kong while
the trade is being phased out:
• Assess the status, use and possible re-export of pre-Convention raw ivory that has been legallyimported into Hong Kong in recent years, through follow up with licensed traders that had
imported the items;• Ensure that aggregate figures and trends in Hong Kong’s ivory stockpiles are published in the
public domain not more than two months after year end, with a high degree of data resolution that
includes quantities of raw/worked ivory, quantities by weight class, and types of ivory products;• Develop information circulars on recent legislative changes and domestic measures in key trading
markets such as China, Europe and the USA, to make certain that licensed ivory dealers in Hong
Kong are aware of the rapidly evolving changes to international and domestic trade measures,
particularly new restrictions that are either now in place or being planned;• Require ivory traders to display an AFCD notice and poster in all licensed premises, and increase
enforcement of this requirement so that potential customers have the means to identify lawful
practices prior to the implementation of the proposed phase out plan;• Clarify with licensed ivory dealers the conditions for selling through online platforms.
viii TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

In addition, the Hong Kong SAR Government is encouraged to implement the following measures totackle illegal ivory trade:• Following the example of China’s implementation of its ivory ban, Hong Kong should hasten thelocal ivory trade phase out process, starting with the cessation of ivory possession licences being
issued or renewed, in order to lessen the opportunity for laundering of illegal ivory from othermarkets into Hong Kong if a long grace period was provided;• Require regular monthly reporting of transactions by licensed ivory dealers to AFCD, which would
enable ivory stock movements to be closely tracked;• Expand the current hologram system for labelling registered ivory to all registered stockpiles, for allcommercial pre-ban ivory over 100 g, to minimise confusion about product legality for consumers;• Regulate the trade in antique ivory with a product marking and record keeping system so that
future antique ivory trade can be managed and overseen by government authorities;• Review Hong Kong’s stockpile management system for confiscated ivory, ensuring that there is asystem in place for electronic record-keeping, safe storage and periodic audit of stockpiles.
• Enhance co-operation of law enforcement agencies on wildlife crimes, including working withoverseas counterparts and taking advantage of innovative communication and information sharing
models that exist in other regions of the world, as well as local co-operation between AFCD, theHong Kong Police Force and the Customs and Excise Department through joint operations andskills training;• Review maximum penalties for wildlife crimes to levels that reflect the seriousness of organizedcriminal involvement;• In line with the CITES Resolution on Demand Reduction (Resolution Conf. 17.4), develop
supportive policies to encourage evidence-based strategies and campaigns targeting specificconsumer groups to change behaviours about the consumption of ivory.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong ix

Li s t of Bo xe s an d F ig u r es
Box 1: Measures to Combat Smuggling and Strengthen Control of Local Ivory TradeBox 2: Trends in the Possession of Registered Ivory
Figure 1: Quantity of ivory registered with AFCD from 1989 to 2016
Figure 2: Quantity of ivory items on display
Figure 3: Quantity of ivory items on display by outlet typeFigure 4: Licence and poster display
Figure 5: Licence display by outlet typeFigure 6: Response to the question of whether ivory items can be taken to mainland China
Figure 7: Comparing shopkeeper’s willingness to promote illegal behaviour based on whether
licences were displayed on the premises
Figure 8: Comparing willingness to promote illegal behaviour based on quantity of ivory displayed
Figure 9: Imports of worked and raw ivory for commercial purposes into Hong Kong, 2005–2014
Figure 10: Declared “purpose” of worked ivory imports to Hong Kong by number of records,
2005–2014, according to importer data
Figure 11: Declared “purpose” of raw ivory imports to Hong Kong by number of records, 2005–
2014, according to importer data
Figure 12: Declared “source” of worked ivory imports to Hong Kong by number of records, 2005–
2014, according to importer data
Figure 13: Declared “source” of raw ivory imports to Hong Kong by number of records, 2005–2014,
according to importer data
Figure 14: Declared source country of worked ivory imports to Hong Kong by number of records,
2005–2014, according to importer data
Figure 15: Declared source country of raw ivory imports to Hong Kong by number of records,
2005–2014, according to importer data
Figure 16: Ivory seizures in Hong Kong by weight and value, 2005–2015
Table 1: Number of shops visited during August and December 2015 surveys

x TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

1. BACKGROUND
Hong Kong remains one of the world’s major ivory trade hubs, an unbroken legacy of having beena major player in the global ivory trade since the latter half of the 19th century. As a British colonial
gateway to the Chinese mainland, Hong Kong’s commercial linkages with British India and East
Africa, especially Kenya, Sudan, Zanzibar and Tanganyika (the latter two now comprise modern day
Tanzania) made the city a key staging post for raw ivory trade to Imperial China’s vibrant ivory
carving industry, particularly the manufacturing centres in nearby Guangdong province, for nearly
100 years (Milliken and Melville, 1989). Whilst Hong Kong’s local ivory carving industry remained
small for nearly a century, it was abruptly transformed in the late 1940s by a massive influx of ivory
craftsmen fleeing civil war and political upheaval on the Chinese mainland. Indeed, in the 1970s and1980s, Hong Kong assumed prominence —and then notoriety—as the world’s largest ivory carving
centre and foremost supplier of worked ivory products (Milliken and Melville, 1989), with as many as
3,575 carvers supporting this output (Martin and Vigne, 2015).
From 1979 through 1988, nearly 4,000 tonnes of raw ivory was imported into Hong Kong, of whichjust over 30% was re-exported to Japan, China, India, Taiwan and Thailand which largely depended
upon Hong Kong for raw ivory supply (Milliken and Melville, 1989). Of the ivory that remained in
Hong Kong for processing, 75% of the production was exported outright to a reported 102 countries/
territories worldwide, totalling nearly USD350 million (HKD2.4 billion) over the period, according
to Customs statistics; another 20% of the ivory production was directly purchased by tourists who
returned home with ivory souvenirs, leaving only about 5% of the output for local consumption(Milliken and Melville, 1989). Hong Kong’s trade in this period represented the deaths of between
414,554 and 445,171 elephants (Milliken and Melville, 1989).
Over the following decades, however, a significant decline in Hong Kong’s ivory trade occurred. Thisdecline was precipitated by the halving of the African Elephant Loxodonta africana population during
the 1980s (Douglas-Hamilton, 1989) which led to the imposition of an international commercial
ivory trade ban under the Convention on International Trade in Endangered Species of Wild Fauna
and Flora (CITES), which took effect in January 1990. The concurrent rapid fall in consumer demandfor ivory throughout the world severely impacted the local ivory industry at the same time an
economic recession hit Hong Kong (Lemieux and Clarke, 2009). The industry further contracted
when many prominent ivory trading families closed shop and migrated abroad prior to Hong Kong’s
reversion to China in 1997. Today, the ivory carving industry in Hong Kong has all but collapsed andrecent studies indicated that only a handful of individuals engage in part-time repair work as carvers(Martin and Vigne, 2015).
But at the time of the CITES trade ban, Hong Kong’s ivory dealers arguably possessed the largest
quantity of pre-ban ivory stock globally, which remained eligible for local trade. In June 1989, justprior to the CITES trade ban, 497 tonnes of raw ivory and 168 tonnes of worked ivory was registeredwith the Hong Kong Government (Milliken and Melville, 1989). Following the CITES trade ban
decision, the UK Government, on behalf of Hong Kong, placed a reservation against the listing of
all African Elephant populations in Appendix I of the Convention, in order to afford Hong Kong
authorities a six-month “grace period” before full implementation of the international ivory tradeban (Anon., 1990). Accordingly, a licensing system was subsequently introduced by the Hong Kong
Government to allow legitimate pre-ban stocks to be sold domestically. Exports of pre-Convention
ivory from Hong Kong were also possible under certain circumstances but required considerable
paperwork and time, which acted as a kind of deterrent for trade through legal channels (Martin andVigne, 2015). Over the next 15 years, the local ivory trade increasingly declined and stagnated (Lee etal., 1997; Martin and Vigne, 2015). Since the mid-2000s, however, increasing demand from mainland
China, according to some observers, has reinvigorated the trade with Chinese tourists propping up

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 1

retail ivory sales in Hong Kong for export—legal or otherwise—back home (Martin and Vigne, 2015).
This surge in interest for ivory products has led to concerns that demand in Hong Kong itself could
also be a driver of African Elephant poaching (Lo and Edwards, 2015), with recent forensic evidence
confirming at least one case of ivory from poached elephants being laundered into the city’s legal
market (Information Services Department, 2017).
In recent years, commercial-scale consignments of worked ivory products manufactured mostly in
Africa have been seized with increasing frequency by the Hong Kong authorities and many of theseseizures have reported Hong Kong as the “destination”. Data from the Elephant Trade Information
System (ETIS)—the elephant product monitoring system managed by TRAFFIC on behalf of theParties to CITES—show that, from 2009 through 2012, Hong Kong reported making only six
commercial-scale seizures of worked ivory products (i.e. seizures which totalled 5 kg or more); theseseizures totalled 156 kg. Between 2013 and 2015, however, the number jumped to 100 seizures, totalling
1,533 kg of worked ivory products (T. Milliken, in litt. to TRAFFIC’s East Asia Regional Office, 20
March 2017). In fact, the “final” destination could be different from the “reported” destination ofthese shipments, but even if only some of this worked ivory were destined for Hong Kong’s local
market, wholesale laundering would appear to be occurring in contravention of local laws and CITES.
The culmination of worked ivory and raw ivory seizures, whether meant for the local market or intransit mostly to the Chinese mainland, has in recent years resulted in Hong Kong being identified
in two successive ETIS analyses to CITES as one of the countries or territories of “primary concern”
in the illicit ivory trade (Milliken et al., 2012; 2016). As a result of this finding, Hong Kong has been
subjected to an ongoing oversight process by the CITES Parties. Accordingly, Hong Kong has been
compelled to take urgent action to address illegal flows of ivory within their jurisdiction, and to
produce a National Ivory Action Plan (NIAP) which outlines a series of steps to address a range ofivory trade issues through time-based actions (CITES, 2013). This development has placed renewedinternational attention on Hong Kong’s ivory trade policies, compliance with CITES requirements
and local law enforcement capabilities.
With Africa’s elephants currently in serious crisis, many conservation advocates have called for aban on ivory trade in Hong Kong. This campaign has garnered significant media attention, both
locally and worldwide, and appears to have gathered majority support from Hong Kong’s citizens,with a recent survey finding that 75% of Hong Kong people back an ivory trade ban (HKU-POP and
WildAid, 2015). Further, more than 90,000 individual pledges support WWF Hong Kong’s “rewrite
their future” campaign to end ivory sales in Hong Kong1. The potential linkage between the local
trade and the unrelenting elephant attrition in Africa clearly fuels negative sentiments towards Hong
Kong’s ivory trade, fostering a community of resistance against the status quo (Martin and Vigne,2015). With this background, the market surveys presented in this report were developed several
months prior to the announcement by the Hong Kong Government to propose a ban on the local
ivory trade in January 2016 (see section 2: Recent Developments). Therefore, the study was developed
to assess possible market reactions to any potential regulatory changes.
A status update of Hong Kong’s ivory market was conducted through market surveys, as well as
assessments of trade data and ivory seizure data. The survey results were compared with data fromprevious studies of the Hong Kong ivory market (Martin and Stiles, 2003; Lam and Xu, 2009; Martin
and Martin, 2011; Martin and Vigne, 2015).
Section 2 of the report explores recent policy developments, outlining the proposed plan to phase out
local ivory trade, and current efforts to tighten controls over licensed traders. Section 3 summarises

1

As at 31 December 2016. See: https://rewritetheirfuture.wwf.org.hk/

2 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

the licensing conditions for local ivory traders. Section 4 provides details of the methodology used for
conducting a physical market survey of ivory retailers/traders in Hong Kong, while section 5 presents
the findings of the survey. In section 6, the status of the local physical market for ivory is discussed
in the context of trends in CITES trade of commercial ivory and ivory seizures, and the possibility
that ivory is being held for speculative investment purposes is suggested. Assertions that have been
made about Hong Kong ivory trade are addressed, and gaps in current licensing and enforcement
measures are highlighted. Finally, section 7 concludes with recommendations for the Hong Kong
SAR Government to consider in light of proposed plans already announced to ban local ivory tradein the city.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 3

2. RECENT DEVELOPMENTS
On 27 June 2016, the Legislative Council’s Panel on Environmental Affairs discussed a proposal fromthe Environment Bureau and AFCD (2016) for a plan to phase out the local trade in elephant ivory. The
proposed plan has since been approved by Hong Kong’s Chief Executive in Council on 21 December
2016 (Information Services Department, 2016), an important step prior to the submission of anamendment bill to the Legislative Council where it will be considered for enactment. Furthermore,
the proposed phase out plan is consistent with CITES Resolution Conf. 10.10 (Rev. CoP17) “Tradein Elephant Specimens”, which recommends that Parties close domestic ivory markets that arecontributing to poaching or illegal trade. A three-phase process towards a complete ban has been
proposed:• Step 1: A ban on the import and re-export of hunting trophies2 and remaining post-Convention(1976) ivory items that are currently permissible under CITES—effective immediately when thebill is enacted;• Step 2: A ban on the import and re-export of pre-Convention ivory—effective three months after
the bill is enacted;• Step 3: A ban on the possession of ivory for commercial purposes, prohibiting all local ivory sales(with the exception of antique ivory)—effective on 31 December 2021, after a five-year grace
period.
Key issues, such as the timeframe towards a complete ban on local ivory trade, will be discussed whena bill to amend legislation is tabled with Hong Kong’s Legislative Council during 2017. An alternative
independent legal assessment by WWF-Hong Kong recommended that a two-year phase out plan
could be achievable, if the Hong Kong SAR Government ceases to issue and renew ivory possession
licences immediately (WWF-Hong Kong, 2016).
Hong Kong’s move follows signals from other countries with significant ivory markets, most notably
China and the USA, where policy changes to tighten domestic ivory trade have recently taken place.
The phase out proposal also represents an example of the broader international intent to phase out
domestic ivory markets that may be contributing to poaching or illegal trade, which was the subjectof amendments to Resolution Conf. 10.10 “Trade in Elephant Specimens” which Parties adopted
at the 17th Conference of the Parties to CITES. In the face of a growing tide of criticism against
governments that remain idle towards elephant poaching and ivory trafficking crimes, and in lightof the considerable local public awareness, the Hong Kong SAR Government decided to join, rather
than resist, prevailing international trends.
China’s evolving trade regulations on ivory also are of consequence to Hong Kong since buyers frommainland China are purportedly the main consumers of Hong Kong’s ivory (Martin and Vigne, 2015).
CITES is implemented separately in Hong Kong, therefore the border between Hong Kong and China
is considered an international border for CITES trade purposes (Article 116 of Hong Kong’s Basic
Law). China’s State Council has recently issued a directive to stop domestic processing and sales ofivory and ivory products by 31 December 2017, with some processing and sale activities to end earlier
on 31 March 2017 (State Council, 2016). This is in addition to an international ivory trade ban thatis currently in place in China, covering all ivory products obtained prior to 1975, with the exception

From 2000 to 2014, only a single ivory trophy was imported into Hong Kong (UNEP-WCMC, CITES Trade Database), therefore, the impact of the ban
on hunting trophies is primarily symbolic as Hong Kong is rarely a destination for sport hunted elephant trophies.

2

4 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

of some ivory artefacts for the purpose of “teaching and scientific research, cultural exchange, public
display and for law enforcement” (State Forestry Administration, 2016). This ban will remain in effectthrough 31 December 2019 (State Forestry Administration, 2016).
In October 2015, prior to Hong Kong’s announcement of a proposed phase-out plan, AFCD publishedseveral measures to combat smuggling and strengthen enforcement of Hong Kong’s local ivory trade(AFCD, 2015). The 10 measures (see Box 1 below) reinforced actions that Hong Kong had committed
to under the CITES-mandated NIAP process to improve local regulation and enforcement. Further, theHong Kong SAR Government agreed to additional measures, such as the incineration of confiscatedivory and awareness-raising initiatives (CITES, 2015).

Box 1: 10 Measures to Combat Smuggling and Strengthen Control of Local Ivory
Trade
Further to the publication of 10 measures to assist law enforcement and control local ivory trade(AFCD, 2015), the following elaborates on each of these measures, drawing from a discussion between
TRAFFIC and AFCD, and in some instances identifies the progress in achieving these measures(AFCD, pers. comm., 21 January 2016). Headings of each measure correspond with AFCD’s “10measures” document (AFCD, 2015).
1.Enhanced liaison with the Customs and Excise Department and overseas enforcement agencies
against smuggling of ivory
AFCD and China’s CITES Management Authority typically meet once a year to discuss licensing
and enforcement issues. Additional efforts will be made between AFCD, Hong Kong Customs andcounterparts in Guangdong province to meet more frequently, so that joint operations, informationexchange and other collaborative activities can increase.
2. Sniffer dog programme to assist detecting and preventing smuggling of ivory
The Quarantine Detection Dogs programme was initiated in 2008 and currently employs about 8–9 dogs
that are on duty at different border control points. While not previously trained to detect endangered
species products, these working canines have now been trained to do so, focusing on identifying
elephant ivory, dried seahorse and pangolins, amongst other products.
3. Enhanced interdepartmental collaboration
The Endangered Species Protection Liaison Group currently meets twice annually and provides theopportunity for AFCD to liaise with the Hong Kong Police and the Customs and Excise Department on
wildlife trade issues. The frequency of these meetings will increase, to enhance their ability to organize
joint operations, discuss smuggling issues and trends, and develop joint strategies.
4. Comprehensive stocktaking of pre-ban ivory (pre-1990)
Stocktaking of commercial ivory has been ongoing since the beginning of 2015. Of the 370 current
possession licences, AFCD approximates that around 200 relate to ivory held in retail shops. Others holdcommercial ivory privately. A comprehensive stocktake of ivory held by all licensees will be completed
by the end of 2016.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 5

5. Stepping up import and re-export control on pre-Convention ivory (pre-1976)
Previously, Hong Kong followed the CITES method of marking serial numbers with permanent markers
on pre-Convention raw ivory only, for any items that were over 20 cm in length and/or over 1 kg in
weight. CITES has not established marking requirements for scraps or worked ivory products. However,in order to improve AFCD’s ability to control the import and re-export of pre-Convention ivory, it
will implement an additional ivory marking system using hologram stickers on worked and raw ivory,which is apparently tamper-proof and leaves an indelible mark in the event of attempts to remove it.
6. Extending the use of tamper-proof holograms to pre-ban worked ivory under Licenses to Possess
The new hologram stickers will also pertain to pre-ban worked and raw ivory of more than 0.1 kg,
to improve the tracking of ivory items held under a Licence to Possess. Anything smaller than this isconsidered not to be worthwhile, according to AFCD, as there is insufficient space to put a sticker andthe item itself is unlikely to be worth very much. A new serial numbering system will also be introduced
through the holographic stickers, in addition to previous serial numbers given to individual ivory tusks
under the CITES numbering system. Photographic records of individual pieces will also accompany the
new labelling process, and everything will be recorded in AFCD’s databases accordingly.
The new hologram labelling system was only implemented from September 2015. This means that thelicensees that have renewed their licences before this date will not have applied holographic labels totheir stock. The licensees that have renewed their possession licences prior to the hologram labelling
will still be able to sell their stocks without hologram labels, legally under the Protection of Endangered
Species of Animals and Plants Ordinance (Cap. 586).
7. Use of radiocarbon-dating to determine the age of ivory
Radiocarbon-dating technology has become relatively cheap to apply, and yields results in a shortamount of time, according to AFCD. For this reason, it will be employed by AFCD for determining theage of suspicious ivory stocks or imports, thus clarifying the legality of the ivory in question and support
enforcement and conviction.
8. Enhance transparency for tracking licensed ivory stock
Relevant statistics, such as the quantity of licensed ivory, will be published on the AFCD website.
9. Licensees to report change in stock quantity at specified intervals
Licensees have to keep a transaction record of changes to their ivory stockpiles, which was previously
inspected by AFCD officers during surprise visits or at licence renewal periods (every five years). AFCD
has proposed to ask licensees to report transaction records instead on a more regular basis.
10. Raising awareness of potential customers on the control of ivory
Many licensees do not display their possession licences, despite it being a legal offence not to do so,
because of a reluctance to display their only original copy of the licence. Some dealers have used a
photocopy of the licence instead. Still others are disinclined since the licence includes personal orcompany addresses, which they may not want to share publicly.
In addressing this issue, two new items will be required to be displayed at licensed premises: a noticethat outlines that the specific premises are licensed for holding ivory for commercial purposes, as well
as a poster that carries the message that ivory cannot be taken out of Hong Kong without a CITES
permit. The notice conceals personal addresses but still includes the total ivory quantities registered by
the licensee under their Licence to Possess, which is a requirement by law, thus making its inclusion
unavoidable. Both of these items will need to be displayed at licensed premises once their licences are
renewed, i.e. from September 2015 onwards.

6 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

3. STATE OF LICENSING AND REPORTING OF IVORYSTOCKPILESWith the proposed ban currently outlining a five-year grace period for ivory traders, licensed ivory
traders are able to continue commercial trade in ivory until the year 2021. The current conditions forlicensed local ivory trade is summarized as follows.
3.1. Licence to Possess
Ivory possession licences were originally issued under the
Animals and Plants (Protection of Endangered Species)
Ordinance (Cap. 187) to those in possession of ivory in theearly 1990s. Pre-Convention ivory for commercial and noncommercial possession was registered with AFCD, althoughthose who owned less than 5 kg of worked ivory were exempt
from having to obtain possession licences. Despite thisexemption, the ivory licensing conditions in Hong Kong went
beyond CITES requirements at the time.

© AFCDAn update of items held or modified (e.g. from raw to worked
ivory) were reported to AFCD each time possession licenceswere renewed, and licence renewal initially occurred every
two years. However, this changed after five-year licenceswere issued for ivory possession around the year 2000, andpersisted after the licensing rules were amended with theintroduction of Cap. 586. Furthermore, the amendments
Poster discouraging the smuggling
meant that licences were now only required for those holdingof ivory out of Hong Kong, forivory for commercial purposes. Those holding ivory for nondisplay in licensed ivory outlets andborder points.
commercial purposes (in private use) were no longer required
to obtain a licence. Consequently, in terms of tracking ivory
stock values over time, the more limited requirements of the new registration system for licensed
ivory dealers effectively rendered such data incomparable with data on registered ivory collectedprior to 2006, which included privately-held non-commercial stocks (see Figure 1).
Box 2: Trends in Levels of Registered Ivory
700
600 665
500
400

463
404

300

345

307

286 278 268

264 261 2602 60 260

236 238 237 236 232
178
78 75

2016

2014

2013

2012

2011

2009

2008

2007

2006

2005

2003

2004

2002

2001

1999

2000

1998

1997

1996

1994

1995

1993

1992

1990

1991

Commercial & Non-commercial Ivory

2010

121 117 119 117 111

0

2015

100

1989

tonnes200

Commercial Ivory

Figure 1: Quantity of Ivory registered with AFCD from 1989 to 2016 (Source: Legislative Council ofHong Kong, 2015; AFCD, 2016; 2017)

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 7

New legislation (Cap. 586), which came into effect in 2006, was not fully reflected in AFCD’s
record of registered ivory until 2010, as a large majority of licensees renewed their licences
between 2009 and 2010. This explains major drops in registered ivory seen in both of theseyears, due to the exemption of non-commercial ivory from official registration.
Overall, the use of registered ivory as a measure of ivory trade trends, particularly of thecomparison of records from 1990 to 2016, is problematic, given that two different ways ofaccounting for registered ivory transpired over this period (initially for both commercial andnon-commercial ivory, and then commercial ivory only). Stockpiles were relatively stable, with
only modest annual declines observed in the years when only commercial ivory levels wererecorded (2010–2016).

3.2. Stockpile and Transaction Records
It is a requirement for all transactions of ivory products in Hong Kong to be recorded on a Records Sheetthat is provided by AFCD to licensees. The record must be made within three days of a transaction,and these records can be requested for inspection by AFCD at any time. Surprise inspections are
typically done when AFCD is alerted of suspicious activity at licensed premises.
The number and weight of ivory stockpile pieces are recorded: tusks, cut pieces, worked ivory andscrap are treated separately. Small discrepancies in the total weight of ivory stockpiles is allowed given
the loss generated through processing, e.g. residue from cutting tusks and carving worked items.
3.3. Other Forms of Selling
Hong Kong licensees can sell registered, pre-Convention stocks of ivory online, as long as thesellers are in possession of a Licence to Possess. However, it is not always clear whether ivory items
advertised online from Hong Kong sellers are from licensed premises, as there are no requirements
for this information to be shared or for retail licences to be displayed with such advertisements. In a
recent (November 2016) rapid survey of Hong Kong-based online platforms, 11 advertisements andposts for ivory items were found (TRAFFIC, unpublished). At least three of these advertisements andposts did not include any mention of having the requisite certificates or indication that the seller wasa licensed dealer. None of the advertisements provided proof of the possession of a licence, whether
with a photo of the licence itself or their unique possession licence number, and therefore provide
grounds for further investigation.
Monitoring of the ivory trade through online platforms is understandably challenging for thesereasons, especially as e-commerce and social media platforms have been known to facilitate the tradein illegal ivory (Xiao and Wang, 2015; Guan and Xu, 2015). This area of trade will need further
attention and improved oversight by Hong Kong authorities to ensure online trading is legal, and toprevent the laundering of illegal unregistered products. Monitoring and enforcement of online trade
will be of greater relevance as shifts in avenues of trade may be expected after the announcement of a
proposed ban and timeline for implementation (see section 6).

8 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

4. METHODOLOGY
4.1. Targeted Ivory Outlets
A survey of legal ivory dealers was conducted in Hong Kong during August and December 2015. The
August survey included 60 priority shops, which were identified through four methods3:••••

Yellow pages, under “wholesalers and manufacturers”;
A list of ivory outlets provided by WWF-Hong Kong;
Hong Kong NGOs that further highlighted six major ivory dealers; andPrevious data about key shops and locations from TRAFFIC’s 2009 survey.

A further 78 shops were visited in the December 2015 survey. These shops were identified with thehelp of information shared by other NGOs on credible ivory-selling outlets. There was limited overlap
in the shops visited during the two survey periods.
4.2. Method of Survey
The August survey was conducted by two TRAFFIC researchers fluent in Mandarin and English.
The December survey included four TRAFFIC researchers, who between them could converse in
Cantonese, Mandarin and English.
A covert survey method was adopted whereby the surveying team presented themselves as tourists
with an interest in buying ivory, whether for themselves or asking on behalf of a relative.
When shops were either closed or inaccessible, the researchers called the shop owner (if a phone
number was available) to inquire about the status of the business and/or a time to visit.
Several pieces of information from ivory dealers were sought:
Shop status—whether it was open/closed for business;
Display of AFCD licence;
Availability of elephant ivory;
Possibility of taking ivory out of Hong Kong;
Willingness to promote illegal behaviour;
Number of ivory items on display;
Prices of select ivory items;
Opinions of ivory dealers—on issues ranging
from future ivory business prospects, thestatus of ivory carving in Hong Kong,
solutions to the ivory problem, and public
opinion against ivory trade.

Market surveys were conducted according
to TRAFFIC’s established methodology formonitoring wildlife markets. It is noted that forging
a relationship with the traders can be important—to first win their trust—in understanding illegal
behaviour. However, the rapid nature of the market
surveys conducted for this report did not allow timeto establish relationships with individual traders,which may have affected the recorded responses.
3© CHERYL LO

•
•
•
•
•
•
•
•

Ivory figurines and cup sets on display in a
Hong Kong ivory outlet.

These methods for identifying ivory retail outlets were used, as AFCD does not publicly disclose the list of registered ivory traders.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 9

5. RESULTS
5.1. Status of Shops
No. of Shops

Open, withivory

Aug 2015
Dec 2015
TOTAL

27
47
74

Open, but no Not open on
Closed down
ivory found day of survey4
5
17
22

4
8
12

17
4
21

Unknown5

TOTAL

2

55
76
1316

2

Table 1: Number of shops visited during August and December 2015 surveys

A total of 131 retail shops were targeted for visitation during the survey. Of these, 96 shops (73%) werein operation on the day of the survey, and only 74 shops (56%) were found to have ivory products on
display. This number is comparable to a December 2014/January 2015 study that found 72 shops withivory on display in Hong Kong (Martin and Vigne, 2015). Twenty-two (17%) out of 131 shops visited
no longer displayed any ivory, but presumably once had ivory for sale.
Ivory shops tend to be concentrated in two main areas of Hong Kong: along Hollywood Road andUpper Lascar Row in the Central and Western district; and in several isolated hotspots in the Yau Tsim
Mong district. These locations suggest a number of differentiated micro-markets that serve different
consumer segments. Hollywood Road possesses a high concentration of art and antique galleries inHong Kong, and the ivory products displayed and sold in this area are likely to be targeting high-end
antique buyers. Also along Hollywood Road and Upper Lascar Row are numerous shops that sellivory trinket pieces targeting the tourist trade, although large showcase pieces of carved ivory are alsoavailable for the more affluent buyers.
Shops in the Yau Tsim Mong district of Kowloon also tend to target tourists, with ivory found insouvenir shops, shopping areas inside hotels, or tourist malls in areas such as Tsim Sha Tsui East and
the Jade Market. A limited number of specialty ivory stores were also found in both districts, catering
to local middle class buyers seeking utilitarian pieces such as ivory chopsticks or name seals.
At least 21 shops (16%) were found to have vacated their premises, presumably having moved orclosed for business. These shops would have closed within the last six to seven years, since the oldest
data used to identify ivory-selling outlets came from a previous TRAFFIC survey in 2009. This survey
confirmed the well-publicized withdrawal of ivory stocks for sale by four department stores, and theirchain stores around Hong Kong7 in 2014 and 2015. The reason for shops closing was not elicited during
this survey, but discussions with current ivory dealers suggest that very few could make a profit fromthe local ivory trade alone. Many have switched to selling ivory alternatives such as mammoth ivory,or a variety of precious stones such as jade, diamond, or alternative materials used in the productionof trinkets such as precious woods.

These shops were not opened for business on the survey day. In addition, attempts to contact the shopkeepers by phone went unanswered. This figure
included shops that were in the process of renewing their licence, hence selling was temporarily suspended.

4

5

Locations of the shops were not known. Attempts to contact shop by phone was also unanswered.

Seven shops were visited in both the August and December 2015 surveys. For the sake of clarity, these shops were only counted once. Where shops were
not opened during either the August or December survey, the count went towards the survey period in which it was opened (four out of seven shops).
Where shops were either opened during both the survey periods, they were counted towards the December survey (three out of seven shops).

6

The four department stores are: Wing On Department Store, Yue Hwa Chinese Products Emporium, Chinese Arts and Crafts, and Chinese Goods
Centre Ltd (Kao, 2015)7

10 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong5.2.Outlet Types and the Types of Ivory Items on Display
Retail ivory shops can be grouped into several categories of ivory outlets, each category offering asimilar range of ivory products:
Antique Galleries
A large proportion of antique galleries had displays of carved tusks and ornamental figurines carved
entirely out of ivory. Popular household utensils such as chopsticks and tea sets, and accessories suchas hair brushes, beaded necklaces, pendants, fans and snuff bottles were also found at several galleries.
Ivory was also used in chess sets, card and pen holders, either with ivory inlaid or carved entirely withivory. An ivory chandelier was also found in one store.
Gift Shops
The majority of ivory items found in gift shops were trinket jewellery pieces such as pendants, bangles
and earrings. Selected large figurines, made into dragons and elephants were found, as were large
carved tusks. Chopsticks and name seals were also displayed in some gift shops. A number of theseshops were also selling items made from mammoth ivory.
Hotel Souvenir Shops and Jewellery Stores
A large array of jewellery items were found in hotel souvenir shops compared with the typical jewellery
shop. Bracelets, pendants, bangles and earrings were found. Animal motifs such as elephants andcamels were most common. A select few had ivory figurines for sale.
Mah-jong and Name Seal Shops
Mah-jong and name seal shops specialize in these items respectively, with some of their selection
made entirely of ivory. These tend to be the most expensive items in their collections. One mah-jongshop surveyed that had ivory items was also selling trinket pieces, chopsticks and Christian crosses
made from ivory.

© TRAFFIC

Specialty Stores
A large variety of ivory items were sold atspecialty stores, from carved or polished tusks,
to figurines with Chinese Gods such as Buddha
or Guanyin, and more functional items such as
chopsticks, hand-held fans and letter openers.
Large quantities of ivory trinkets were also
found. A majority of specialty stores (nineout of 16) also had mammoth ivory displayed
alongside elephant ivory items. Some of thesestores have also branched out into othermaterials in making very similar statuettes,
such as the use of wood and blue stone.

Various ivory trinkets, including bracelets,
necklaces, name seals, dice and small figurines on
display.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 11

5.3. Outlet Types and the Size of Ivory Stocks on Display
The survey team visited a variety of shops with ivory for sale, including 24 antique galleries, 16 ivory
specialty stores, 15 gift shops and 10 name seal stalls. Ivory was also found, although less frequently, at
jewellery stores, hotel souvenir shops and shops that sell mah-jong pieces. The number of some outlet
types identified in the current market survey was similar to those reported in Martin and Vigne’s(2015), namely antique galleries, gift shops and hotel souvenir shops, but differ widely when other
outlet types are considered.

Figure 2: Quantity of ivory items on display

When asked, shopkeepers usually stated that all of their ivory stocks had been deployed for display.
Indeed, they are legally bound to hold all of their ivory stock in the “keeping premises” as outlined in
the Licence to Possess. Not surprisingly, the number of shops displaying fewer than 100 ivory pieces(73%) far outweighed shops that had much larger quantities of ivory on display.

Figure 3: Quantity of ivory items on display by outlet typeOn average, it was ivory specialty shops that had the greatest number of ivory items on display, with
10 out of 16 shops having thousands of items. Two jewellery stores, as well as one name seal stall andone hotel souvenir shop had between 100 and 1,000 ivory items for sale. Gift shops, antique galleries
and mah-jong shops all had fewer than 100 ivory items displayed in store.

12 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong5.4. Licence and Poster Display

Figure 4: Licence and poster display

A condition of the Licence to Possess is that licensees must display their licence in a conspicuous
position on their keeping premises. Of the 74 shops surveyed, only 23 (31%) were found with licences
displayed. The rest did not have licences displayed during the survey, including those that claimed
to possess a licence but did not display them and dealers that were in the process of applying for
a new licence. As previously mentioned in Box 1, many licensees were reluctant to display theirivory licences as their personal/company addresses are shown on them. It is unclear, however, what
constitutes “conspicuous” display of licences and posters, therefore contravention of the licenceconditions is largely ambiguous.

© TRAFFIC

AFCD initiated a new requirement to have posters displayed at licensed premises, starting from
September 2015. These posters were only given out to ivory licensees at the point of licence renewals,
hence only a portion of licensed premises would have received the posters by the December survey.
Indeed, the survey found only a few—five out of 47 shops with ivory—that had posters displayed on
their premises.

Licensed ivory outlet with License to Possess and poster prominently
displayed.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 13

Figure 5: Licence display by outlet type 8

Antiques galleries (11 out of 24 shops) and speciality stores (9 out of 15 shops), i.e. shops that sellelephant ivory or mammoth ivory exclusively, had the greatest proportion of outlets with licences
displayed (see Figure 5). With the highest prices for ivory items observed at antique galleries andspecialty stores, it is perhaps not surprising they were more likely to show their registered credentials.
5.5. Prices of Displayed Ivory
A variety of worked ivory products were available for purchase in Hong Kong, at a wide range ofprices. The most expensive piece found during the current survey was a large statuette at an antiquegallery that was selling for HKD850,000 (USD107,595). At the other end of the price range was anelephant pendant in a tourist gift shop that was selling for just HKD100 (USD13).
Retail prices have been used in the past as an indication of the relative demand for ivory in the market.
Chopsticks are a relatively common and homogenous item for price comparisons between shops. A
pair of ivory chopsticks was found to cost between HKD600 to HKD4,500 (USD77–580) during theAugust and December 2015 surveys. Prices are not dissimilar to the range of chopsticks (pair) prices
in Martin and Vigne (2015), which were reported as USD128 to USD513, nor to 2011 prices thatwere reported as between USD108 and USD538 (Martin and Vigne, 2011). Price differences, even fora relatively homogenous item such as a pair of chopsticks, can depend on the quality and age of theivory, as well as the type of store in which it is being sold.
While price changes for chopsticks might be difficult to track in Hong Kong, they are substantiallydifferent from prices in mainland China, where a pair of chopsticks cost around USD800 in 2015
(TRAFFIC, 2015, unpublished study). It has been suggested that the price difference is due to thehigher cost of rent for licensed premises in mainland China, which tend to be situated in upmarket
malls, as well as the additional cost of certification for individual items on the mainland (Martin andVigne, 2014).

8
The issue of licences, and whether shops visited had licences displayed or not, were condensed into two categories: (1) “Have licences displayed/claimed
to possess” includes shops that had “Licence and Poster”, “Only licence displayed”, “Claimed to possess, not displayed”, and “Applying for new licence”
categories; (2) “No licence/unknown” includes the categories “Only poster displayed”, “No licence or poster found” and “Unknown” (see Figure 5).

14 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong5.6. Willingness to Promote Illegal Behaviour

Figure 6: Response to the question of whether ivory items can be taken to mainland China

The issue of legality was explored by directly asking shopkeepers if the ivory that was displayed could
be taken to mainland China, thereby crossing an international border9 in violation of Cap. 586 and
CITES regulations for the trade of ivory. 42% of the shopkeepers (32 out of 74) were aware of the law
and communicated its requirements accurately to the surveying team, i.e. that ivory cannot be takenback to China, or if they intended to do they must first get a CITES certificate.
Some 27 shopkeepers (36%) stated that ivory could be exported to mainland China. Many shopkeepers
in this category felt that small ivory trinkets for personal use could be taken without any problem
since such items were easy to hide in bags and luggage, which suggests some knowledge of illegality.
Some offered more detailed strategies to conceal purchased ivory, or suggested pretexts if caught at
the border crossing. Two shopkeepers selling name seals recommended carving one’s name on theseal so it could be treated as a pre-owned personal property. Another shopkeeper stated that only areceipt from the shop was needed as legal proof. Yet another offered to post an ivory name seal to an
address in mainland China. Lastly, one shopkeeper offered to deliver the ivory product through to
Shenzhen, which could then be picked up in the mainland for onward travel, for a fee of HKD10,000.
It should also be noted that a further five shopkeepers (7%) claimed not to know if ivory could betaken to mainland China.
It should be noted that at the time the market surveys were conducted, there was already considerable
media attention about Hong Kong’s ivory trade, as well as increasing scrutiny by civil society groups.
This could have led to a more cautious approach by ivory shopkeepers approached in the market
surveys. While the researchers merely asked about the ivory items displayed, it is difficult to assess
how shopkeepers’ willingness to promote illegal behaviour would have changed if the buyer wasserious about purchasing ivory items.

CITES is implemented separately in Hong Kong from mainland China, therefore the border effectively constitutes an “international border” eventhough Hong Kong is a Special Administrative Region of China.

9

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 15

5.7. Licences Displayed and Willingness to Promote Illegal Behaviour

Figure 7: Comparing shopkeeper’s willingness to promote illegal behaviour based on whether licenses weredisplayed on the premises

Figure 7 shows whether adherence to the law in one respect, i.e. displaying licences (or claiming topossess a licence), translates to other law-abiding behaviour, such as communicating correctly about
whether ivory can be taken overseas.
15 out of 29 (59%) of those that had licences displayed, or claimed to possess a licence, correctly statedthat ivory cannot be taken to mainland China, or can only be taken with relevant CITES permits. Of
those premises where no licences were found, only 15 out of 45 (33%) of shopkeepers mentioned thelegal restrictions in taking ivory across the border.
Out of the group with licences displayed (or claimed to possess them), seven out of 29 (24%) asserted
that ivory can be taken to China and overseas. This compares to 20 out of 45 (44%) of those where nolicences could be observed on the premises.
Curiously, five shopkeepers out of the 74 shops with ivory could not give an answer to the question
about taking ivory out of Hong Kong. Adding this to those that promoted taking ivory out of Hong
Kong, a total of 43% of ivory shopkeepers could not, or were not willing to, convey that the exportof ivory was an illegal activity. While it can be counter-intuitive for shopkeepers to hold back frommaking a sale, they hold the responsibility for correctly advising buyers of the law. Further work by
AFCD to inform licensees of the regulations is necessary.

16 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong5.8. Number of Ivory items Displayed and Willingness to Promote Illegal Behaviour

Figure 8: Comparing willingness to promote illegal behaviour based on quantity of ivory displayed

The willingness of ivory shopkeepers to state that ivory can be taken out of Hong Kong, thereby
promoting illegal behaviour, was less evident amongst ivory specialty shops, which typically had over
1,000 ivory items on display. These specialty shops tend to be more cautious, with 20% of them statingthat ivory can be taken out of Hong Kong, while 70% mentioned it could not. In contrast, a larger
proportion of shops (35–45%) that had fewer ivory items displayed (including shops with <10 ivory
items, 10–100 items and 100–1,000 items) stated that ivory items could be taken out of Hong Kong.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 17

6. CHALLENGES IN PHASING OUT HONG KONG’S
IVORY TRADE
By publishing plans to phase out the local ivory trade (Environment Bureau and AFCD, 2016),
the Hong Kong SAR Government has conveyed its commitment to reducing the major threat toconserving the world’s elephants, in line with other domestic and international efforts to restrict ivory
trade. The current phase-out plan follows from Hong Kong’s NIAP commitments, made in 2013
(CITES, 2013), as well as additional law enforcement and control measures outlined in 2015 (see Box
1; AFCD, 2015). Market surveys were conducted as part of TRAFFIC’s research in the second half of2015, at a time when public pressure on the local ivory trade was intensifying.
The research findings provide not only an evaluation of the local ivory market during this critical
period, but also highlight problems with the status quo for trade locally (section 6.1) and internationally(section 6.2). A suggested timeline for the local ivory trade ban has been published in the proposed
phase-out plan (Environment Bureau and AFCD, 2016). Challenges in implementing the proposed
ban both prior to, and after the ban takes effect, are considered and outlined in this section of thereport.
6.1. Local Ivory Trade under the Existing Regulatory System
One of the most revealing findings from market observations was the inconsistency of licensed
dealers in complying with local CITES regulations. The required display of licences, notices andposters has been designed to enable consumers to recognize legitimate selling places and conditions
for purchasing ivory. Yet, after more than two decades of licence implementation, only 31% of shops
visited had noticeable licences displayed.
Having possession licences displayed, which allow dealers to conduct commercial trade in ivory, is
not a guarantee of absolute regulatory compliance. The market survey also found that having licences
displayed did not prevent a small percentage of licensed dealers from suggesting to researchers that
smaller pieces of ivory might go unnoticed by enforcement authorities if taken across Hong Kong’s
borders. Furthermore, this tendency to suggest that ivory items can be smuggled out of Hong Kongcame from a range of shop types, whether it was hotel souvenir shops, stores that specializes only inelephant and mammoth ivory, antique galleries or tourist gift shops. Shops that specialize in nameseals, perhaps because of their small size, had an even greater likelihood of suggesting the concealmentof ivory to take out of Hong Kong.
The willingness of ivory dealers to encourage the smuggling of ivory as personal effects out of Hong
Kong and the limited display of ivory possession licences highlight the shortcomings in the existing
regulatory system in terms of both compliance with existing regulations, as well as current perceptionsof any law enforcement deterrent.
6.2. Recent Escalation of Ivory Trade
The CITES ban on international trade of ivory led to local restrictions being implemented on theimport and (re-)export of ivory in Hong Kong. From 1990 onwards, international trade in ivory was
only allowed if the items were classified as pre-Convention (pre-1976) and with accompanying CITES
permits, in accordance with CITES requirements that were implemented through Hong Kong’s Cap.
586 regulations.
Since 2010, the number of import records of mostly pre-Convention ivory products into Hong
Kong has been increasing (Figures 9, 12 and 13). Much of this increase occurred with imports forcommercial purposes (Figures 10 and 11). This pattern of trade was particularly pronounced between
18 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

2011 and 2014, when Hong Kong imported a total of 6,056 ivory pieces, plus 4,554 kg,10 of worked
and raw pre-Convention ivory (AFCD, pers. comm. 7 April 2017 to TRAFFIC). The majority ofthese imports were sourced from European countries (70% for worked ivory and 98% for raw ivory;
see Figures 14 and 15). In contrast, declared re-exports of pre-Convention ivory from Hong Kong
during the same period (2011–2014) amounts to 323 ivory pieces, plus 3,264 kg, of pre-Convention
ivory11 (AFCD, pers. comm. 7 April 2017 to TRAFFIC). This would suggest a net inflow of ivory into
Hong Kong, but it is unclear whether the imported ivory was retained in Hong Kong for commercial
purposes or as personal items.12
The increased trade activity in pre-Convention ivory during 2010-2014 contrasts with the status of
the local ivory market when market surveys were conducted for this report in 2015. Ivory vendorsinterviewed during this survey were mainly pessimistic about their future ivory trade prospects andarticulated the desire to shift their retail focus towards alternative products, which concurs with
Martin and Vigne’s survey of the Hong Kong ivory market in early 2015. In fact, the vast majorityof ivory retail outlets supplemented their operations by selling a range of other goods, whether it ismammoth ivory, stone and timber carvings, other precious jewellery or antiques.
In November 2016, the researchers revisited some of the same surveyed ivory outlets, roughly a year
after market surveys were conducted for this report. Seven outlets that were revisited appear to haveclosed down for business, and two traders stated that they have since downsized, closing branch storesor converting to wholesale business only. The proposed local ivory ban, which was introduced during
the course of 2016, seems to be having a differentiated effect on ivory outlets in Hong Kong. Smaller
outlets with a few ivory items appear to have less success in liquidating their stock, but specialist ivory
outlets were still making sales, with shoppers still seen at these outlets when the researchers visited.
While a reduction in the licensed trade in ivory will only become evident when the relevant statistics
are published, a consolidation of the market was already evident close to the end of 2016.

© TRAFFIC

For raw ivory, statistics from the CITES trade database show that Hong Kong had imported asignificant quantity of pre-Convention raw ivory during
the period 2011 through 2014, totalling 747 pieces plus
4,298 kg. Almost all of this was sourced from Europe(Figure 15). Raw ivory re-exports from Hong Kong wereconsiderably less than total imports (both raw and worked
ivory) during the same period. This suggests that there issome retention of imported raw ivory in Hong Kong. It is
uncertain, though, how this retained raw ivory has been
used, since there are no ivory carving factories left in thecity (Martin and Vigne, 2015). In addition, according
to the Hong Kong traders surveyed, the few part-time
carvers remaining locally, or those located overseas whomake brief trips to Hong Kong, are largely involved in
Raw and cut ivory pieces.
bespoke work.
Between 2011 and 2014, there were no records of raw ivory being re-exported from Hong Kong tocountries other than mainland China (UNEP-WCMC CITES Trade Database). The fact that during
this period all re-exported raw ivory from Hong Kong was destined for mainland China raises
important questions about the nature of these trade transactions. Whilst ivory processing in China
Trade data are reported in a variety of units. Hence the sum of the quantity reported by number of pieces and quantity reported by weight equals thetotal ivory imports to Hong Kong with CITES permits.

10This figure refers to the import of Elephantidae spp., Elephas maximus (Asian Elephant) and Loxodonta africana (African Elephant). Only the importof elephant ivory is considered, and excludes the import of elephant skins or leather, teeth, skulls and derivatives.

11

It should be noted that re-exports of ivory from Hong Kong could also have been drawn from existing stockpiles, which would suggest that higher
amounts of imported ivory were demanded for local use and/or commercial trade than import and re-export differences alone would indicate.

12

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 19

was certainly ongoing during that time, other studies have suggested that a possible explanation
might be the stockpiling of ivory for investment (Stiles, 2015). Vigne and Martin’s (2014) study ofivory markets in China uncovered a practice of importing expensive ivory items, including raw ivory
tusks, from Hong Kong to mainland China, with investors speculating on tusks becoming rarer in the
future to yield greater profits. Hence investment behaviour could, in part, have propelled the recent
influx of pre-Convention ivory imports into Hong Kong.

Figure 9: Imports of worked and raw ivory for commercial purposes into Hong Kong, 2005–2014.
Source: UNEP-WCMC, CITES trade database.

Figure 10: Declared “purpose” of worked ivory
imports into Hong Kong by number of records,
2005–2014, according to importer data.
Source: UNEP-WCMC, CITES trade database.
“Worked ivory” refers to records reported as“carvings” and “ivory carvings”.

Figure 11: Declared “purpose” of raw ivory imports
into Hong Kong by number of records, 2005–2014,
according to importer data.
Source : UNEP-WCMC, CITES trade database. “Rawivory” refers to records reported as “ivory scraps”,“ivory pieces” and “tusks”.

20 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

11

Prespecimens
Unknown

11

208

190

(blank)Prespecimens

Figure 12: Declared “source” of worked ivory
imports to Hong Kong by number of records,
2005–2014, according to importer data.
Source: UNEP-WCMC, CITES trade database.
“Worked ivory” refers to records reported as“carvings” and “ivory carvings”.

Figure 13: Declared “source” of raw ivory imports
to Hong Kong by number of records, 2005–2014,
according to importer data.
Source: UNEP-WCMC, CITES trade database.
“Raw ivory” refers to records reported as “ivory
scraps”, “ivory pieces” and “tusks”.

Figure 14: Declared source country of worked
ivory imports to Hong Kong, by number ofrecords, 2005–2014, according to importer data.
Source: UNEP-WCMC, CITES trade database.
“Worked ivory” refers to records reported as“carvings” and “ivory carvings”.

Figure 15: Declared source country for raw ivory
imports into Hong Kong, by number of records,
2005–2014, according to importer data.
Source: UNEP-WCMC, CITES trade database.
“Raw ivory” refers to records reported as “ivory
scraps”, “ivory pieces” and “tusks”.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 21

Seizures of illegal ivory in Hong Kong have also been on the rise in recent years. Ivory seizures
occurring between 2010 and 2013 were especially pronounced (Figure 16), reaching an estimatedvalue of HKD84 million in 2013. A large percentage of the total volume of seizures during this period
was due to several large-scale ivory seizures.13 For example, in 2012, three large-scale seizures (56seizure cases in total) contributed to 92% of the total volume of illegal ivory seized in Hong Kong
during that year (4,944 kg out of 5,368 kg; T. Milliken, in litt., 20 February 2017). The large-scale
seizures occurring between 2010 and 2013 were almost entirely made up of raw ivory, but an increasein the number of worked ivory seizure cases can also be observed from 2012 onwards, although
at lower volumes per seizure (T. Milliken, in litt., 20 February 2017). The majority of these recent
worked ivory seizures were transported by smugglers in checked baggage on flights originating fromAfrica (T. Milliken, in litt., 20 February 2017).
Statements of arrested smugglers taken during interrogation do not often reveal very much about
the trade route, nor if there were plans for onward travel from Hong Kong (AFCD, pers. comm., 7
May 2016). Nevertheless, ivory seizure statistics do suggest that Hong Kong is a major gateway forthe global trade in illegal ivory. Some of this may inevitably have ended up in Hong Kong’s local
market, laundered as a legal ivory product. One of the only cases of this was uncovered recently
when ivory was found to be obtained after 1990 through radiocarbon dating, in violation of Cap.
586 (Information Services Department, 2017). Other researchers have suggested that most ivory
shipments confiscated in Hong Kong are destined for mainland China (Martin and Vigne, 2015). As
Hong Kong plays a sizeable intermediary role in the flow of merchandise goods between China andthe rest of the world (12% of mainland China’s exports (US$278 billion) and 13% of imports (US$251
billion) were handled via Hong Kong in 2014; HKTDC, 2016), it is conceivable that a similar dynamic
is at play for the illegal ivory trade. Information, especially from arrested smugglers, would be criticalfor confirming this. However, interrogation and investigation capacity within AFCD needs to be
improved considerably for this to happen if it is hoped to uncover and curtail illegal trade chains. The
use of controlled deliveries may be warranted to examine where such shipments could be heading,
given their frequency.

Figure 16: Ivory seizures in Hong Kong by weight and value, 2005–2015.
Source: Customs and Excise Department (2013a); Legislative Council of Hong Kong (2015).

13
The threshold for large-scale seizures that need to be forensically assessed is any ivory seizure is 500 kg or more, according to CITES Resolution Conf.
10.10 (Rev. CoP16).

22 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong6.3. Challenges to Phasing Out Hong Kong’s Ivory Trade
The proposed ivory phase-out plan (Environment Bureau and AFCD, 2016) represents an important
step in tackling the illegal flow of ivory in Hong Kong. The proposed plan includes halting tradeactivities within the city and of ivory import/exports, which would complement import bans of preConvention ivory that are already in place in a number of other countries. Cessation of the local ivory
trade would also make it more difficult for visiting tourists, purportedly the main consumers of Hong
Kong’s ivory (Martin and Vigne, 2015), to source ivory products in Hong Kong. In addition, further
action should be taken to address the smuggling of ivory out of the city, in order to prevent ivory frombeen traded on the black market. Possible scenarios that might develop before and after the ban, andthat Hong Kong’s enforcement authorities should closely monitor, include:•  Outflow of Ivory to Overseas Markets
Ivory trading activities should be closely monitored by Hong Kong’s law enforcement agencies
even prior to a local trade ban, as signals of an impending ban could prompt a surge in ivory
trade out of Hong Kong as ivory dealers are pressured to liquidate their stocks. Overseas markets
where domestic trade remains open and legal would be obvious targets. Potential and existingivory markets in Cambodia, Lao People’s Democratic Republic, Viet Nam and Myanmar, which
serve both local and Chinese touristic demand for ivory, could become major destinations
for the outward flow of Hong Kong's ivory. China is another obvious market where, despite
forthcoming restrictions on legal sales (State Council, 2016), demand and illegal trade may
persist (Vigne and Martin, 2014).
That a trade ban could trigger high volume movements of ivory stocks to markets abroad hassome precedence—over the six-month reservation period that Hong Kong enjoyed following
enactment of the CITES trade ban in 1990, between 18 January and 7 July 1990, officially a
total of 592 kg of worked ivory and 8,491 kg of raw ivory was legally exported from Hong Kong
(Caldwell and Luxmoore, 1990). In fact, beyond reported exports, Hong Kong’s ivory stockpiles
greatly contracted during this period.
However, an increasing number of countries are implementing more stringent constraints onivory trade. These include import and/or export bans of pre-Convention ivory in China, USA
and the EU, which are major source and destination countries for Hong Kong's trade in preConvention ivory (Figures 14 and 15). Enforcement authorities in Hong Kong will need to be
vigilant of potential smuggling attempts, given that there are fewer opportunities to dispose ofivory stocks legally in traditional markets for Hong Kong's ivory traders, especially in China.
There is also an urgent need for local licensed traders and enforcement authorities to be
informed and kept abreast of policy developments in overseas markets while it is still legal toexport ivory out of Hong Kong, and to distinguish between legal and illegal markets.
•  Antique Ivory
Current plans for a phase out of local ivory trade in Hong Kong excludes the trade in antiqueivory, with the proposed antique ivory cut-off date established as 1 July 1925, 50 years prior to
CITES entering into force (Environment Bureau and AFCD, 2017). Historically, much of theinflux of ivory products into Hong Kong, especially at the height of ivory trade into the cityduring the 1970–80s, dates back to ivory from elephants killed around that time14 (Milliken andMelville, 1989). Therefore, maintaining an antique ivory trade might be seen by the Hong Kong

14
Hong Kong importers, together with European traders, were believed to have monopolized the flow of ivory from Africa during the 1970–80s(Milliken and Melville, 1989).

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 23

SAR Government as sustaining the trade in a relatively small pool of ivory items, while being
consistent with the regulations of other ivory-banning countries.
However, a legal ivory antiques market that fosters a market in ivory, albeit narrowed, could
also have the unintended effect of encouraging consumer demand in ivory. Unlike interest for
antique ivory products in markets such as the UK, where consumers place greater value on the
product's antiquity than the material it is made of (Lau et al. 2016), Chinese consumers find the
opposite appealing, placing greater value on products made of ivory. Therefore, allowing thissubset of Hong Kong's ivory stockpile to be traded commercially could have the inadvertent
outcome of enabling a legal front for the illicit trade of all other ivory products that do not meetthe definition of antiques. This issue will need to be carefully watched going forward.
•  Online Ivory Sales
Online ivory trade on e-commerce websites and social media have also gained popularity overthe past few years, and are often preferred as a less scrutinized space for dealers to trade inillicit ivory (Xiao and Wang, 2015). Although there have been efforts in recent years to remove
and censor ivory selling on e-commerce websites, trade on social media platforms has provenharder to trace. Transactions are often undertaken through private, one-on-one and encrypted
messaging, making it difficult for enforcers to identify and investigate such activities (Xu andGuan, 2015). For Hong Kong’s licensed ivory dealers, selling ivory online is not illegal per se,
but would be illegal if the transaction required the ivory item to be taken out of Hong Kong
without the requisite CITES permit. Monitoring and enforcement of ivory trade on websites
and through social media will require law enforcement agencies to work with the private sector,
especially those that provide servers, to prevent online transactions that are constituted as illegal;
additionally, the logistics and courier sector as transport conduits should become engaged.
Hong Kong authorities will need to be more proactive in engaging private sector companies toprevent illegal trade from occurring on their platforms if, and when, the proposed ban comes
into force.
Further research and investigations are necessary to verify
the flows of ivory in/through Hong Kong, especially ofivory re-exports, and to understand the various avenues forillegal ivory trade. Hong Kong’s law enforcement agencies
should make use of controlled deliveries to understandillegal ivory trade flows, as well as market surveillance andtargeted inspections.

The 10 measures proposed by AFCD to combat smuggling
and strengthen control of local ivory trade (see Box 1)
includes a comprehensive inventory of ivory stocks held
under ivory possession licences, which was initiated in2015 and is due to be completed by the end of 2016 (AFCD,
pers. comm., 26 April 2016). This has been complemented
by surprise inspections that could potentially uncoverirregularities in ivory stock management by licensed
traders. While these measures were critical for ensuring
compliance with the requirements governing possession
licences, they are not necessarily an efficient way foraddressing potential criminality and organized networks

24 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

© TRAFFIC

6.4. Challenges in Tackling Organized Crime

Set of ivory tea utensils

that might be present in Hong Kong. Stocks held on licensed premises are checked, but illegal
stockpiles could easily be held elsewhere. The focus on the retail end of a trade chain ultimately lacks
effectiveness without a complementary effort to investigate and delve into the network of people andorganizations that operate at earlier stages of the supply chain.
The lack of comprehensive investigations is also true of seizures that are made at border control
points, as investigations do not tend to extend beyond seizing the item and arresting individual
smugglers. Operation COBRA III provided evidence that collaborations between law enforcement
at a transnational scale can yield results in terms of uncovering smuggling ringleaders and organizedcrime networks. Stopping the flow of illegal ivory into Hong Kong will therefore require the city’s
enforcement agencies reach out to their overseas counterparts, and dedicate time and budgetary
resources to such collaboration. AFCD’s provision for 2016–2017 of an extra three staff members
to the endangered species team and earmarking of an additional HKD3.7 million to strengthening
controls of the ivory trade (Secretary for the Environment, 2016) is a promising start, as is theestablishment of an interagency unit, the Wildlife Crime Task Force, composed of representatives
from AFCD, Customs and Excise Department and Hong Kong Police Force (Environment Bureau and
AFCD, 2016). Capacity building and joint collaboration with their overseas counterparts on tacklingorganized wildlife crime networks should be made a vital component of the work of the Wildlife
Crime Task Force to halt the illegal trade in ivory. The ability of the Task Force to address wildlife
crime can also be bolstered through high-level participation of the Hong Kong SAR Government’s
Security Bureau.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 25

7. CONCLUSIONS
Hong Kong’s ivory trade has become highly contentious during the recent wave of elephant poachingin Africa for three reasons. Firstly, the local physical market continues to display large quantities
of ivory products openly, indeed more than any other city in the world (Martin and Vigne, 2015).
Despite the dramatic decline in the processing of ivory and the much-diminished retail market fromthe ivory industry’s heyday in the 1970s and 1980s, today’s legacy is still viewed dimly in a world
increasingly connected and driven by social media. Secondly, increasing volumes of pre-Convention
ivory for commercial purposes have been imported into Hong Kong since 2011, outweighing reexports, which is at odds with the notion of a fading local ivory market. These legal imports, muchof them hailing from European countries where stocks of antique ivory still exist, are expected tostop soon, as the EU is considering an export ban and drafting guidelines (European Commission,2016). Ivory re-exports to mainland China, which could previously be re-exported from Hong Kongfor personal use, should also cease with the mainland’s ban on all ivory imports, announced backin March 2016 (State Forestry Administration, 2016). Thirdly, large volumes of illegal ivory fromAfrica have been seized in Hong Kong’s ports of entry, some in transit to Viet Nam, but mostly withthe final destination unknown. The rise in ivory seizures since 2011 in particular links to the global
phenomenon of increased illegal ivory trade flows, making Hong Kong one of several countries/
territories of “primary concern” in the illegal ivory trade, according to analyses of the ETIS datareported to CITES (Milliken et al., 2012; 2016).
These three factors form the backdrop for the proposed plan to phase out local ivory trade that isnow, as of writing, due to be put before Hong Kong’s Legislative Council. If the proposed plan passes,
Hong Kong’s ivory trade policy will be embarking upon new territory, demonstrating a new andunprecedented commitment to combating crimes associated with illegal ivory trade. Full market
closure would be a bold solution, ending an historical legacy, and one that solves the perennial questionof “legality” in the ivory trade for local consumers; that is, removing the local ivory market makes it
clear, once and for all, that commercial trade in ivory is prohibited. Yet questions around sustaining
an antique ivory trade remain, and should be addressed as part of the current legal amendments
proposed.
Much more also needs to be done to tighten up the management of local ivory trade before a local
trade ban comes into place. Research for this report found that 36% of local ivory dealers werewilling to sell ivory products to buyers intending to depart Hong Kong without acquiring any CITES
documentation for their purchases. Further, more than half of the premises sampled did not havethe requisite licences displayed, suggesting that work to monitor compliance and enforce local trade
restrictions remain critical. Part of enforcing local laws should include efforts to increase publicawareness and foster consumer behaviour change, as many of the buyers of Hong Kong’s ivory aremainland Chinese (Martin and Vigne, 2015), who are, knowingly or not, taking ivory illegally acrossthe border. Hence improving knowledge about ivory trade legality, especially at point of purchase, canhelp local laws to be enforced. Improving data transparency could also encourage public surveillanceof possible illegal activities in the market by civil society.
Further research and investigations could help shed more light on the role Hong Kong is playing
with respect to global flows of illegal ivory. Putting in place systems and establishing channels for cooperation with law enforcers in other countries will be key to bolster the combined ability to act onsuch smuggling operations.

26 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong

8. RECOMMENDATIONSAFCD is encouraged to take the following actions immediately, to improve management of the local
ivory trade while working towards a local ivory trade ban:
• Assess the status, use and possible re-exports of pre-Convention ivory that have been legallyimported for commercial purposes into Hong Kong in recent years. Of particular interest is thestatus of imported raw ivory that has been retained in Hong Kong, to assess whether it has been
carved, sold, and/or stockpiled. This could help explain why such imports were occurring at atime when the size of the local market is reportedly depressed and shrinking.
• For public transparency, aggregate figures and trends in Hong Kong’s stockpiles should be
published in the public domain not more than two months after year end, with a high degreeof data resolution that includes quantities of raw/worked ivory (number of pieces and volume
distribution), quantities by weight class, and types of ivory products (tusks, figurines, trinkets,etc.). This will require reporting beyond the level of detail currently requested for ivory possession
licensees, and would in fact provide much more refined data for the validation of stocks. AFCD’s
stocktake of all commercial ivory items should allow this level of data resolution and form the basis
for future stock updates by licensed dealers. More regular reporting of transactions by licensed
dealers (see recommendation 8.1.) would enable ivory sales to be more readily compared with thebaseline. This would allow AFCD to assess the rate of decline of commercial ivory stockpiles atmuch more regular intervals, and to identify and respond to irregularities more rapidly. It would
also ensure that an updated inventory of stocks held in Hong Kong is available should a local
ivory ban be adopted. This baseline will be essential for implementation and enforcement of aban.
• Develop information circulars on recent legislative changes and domestic measures of key trading
markets such as China, Europe and the USA. This would ensure that licensed ivory dealers inHong Kong understand the rapidly evolving changes to international and domestic trademeasures, and are reminded of CITES restrictions for the import/re-export of ivory. Information
on documentation requirements and burden of proof should be included.
• Licensed traders that renewed their licences after September 2015 were required to display a new
notice and poster (see Box 1), both of which are intended to make clear to potential buyers thativory should only be purchased at licensed premises and that a permit is required to take ivory outof Hong Kong. Given the news about Hong Kong’s impending local ivory ban, it is important that
potential consumers have the means to identify allowable practices under the law, particularly at
the point of purchase. Therefore, the requirement to display a notice and poster should extend
to all licensed premises, and a leaflet on the legal ramification of possessing an ivory item forpersonal purposes, which AFCD could produce for ivory dealers to give to customers with every
purchase. This would not entail a huge effort on the part of AFCD, as physical addresses are kept
by the Department, and newly required materials can be sent by post.
• The conditions for selling through online platforms should be clarified for Hong Kong ivory
possession licence holders. At present, it is difficult to assess whether a seller is legally permitted tosell ivory based on posts and advertisements on e-commerce websites and social media platforms.
AFCD should propose an additional administrative measure for Hong Kong licensed holders
to include a photo of their licence and written description about their licensed status. AFCD isfurther encouraged to work with other government agencies with greater investigative powers to
track commercial trade of ivory online by sellers of unclear licence status.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 27

The Hong Kong SAR Government is encouraged to implement the following measures to combat
illegal ivory trade:8.1. Bring Forward Proposed Plans to Ban Local Ivory Trade
The proposed plan to ban local ivory trade would permit local ivory sales to be sustained until 2021,
allowing licensed ivory traders an additional five years to liquidate remaining ivory stocks (75 tonnesof registered ivory remains at the end of 2016; AFCD, 2017). A recent legal analysis by WWF Hong
Kong shows that it is possible for a local ivory ban to be implemented within two years, starting
immediately with the cessation of ivory licence renewals (WWF Hong Kong, 2016). The analysis
suggested granting the Chief Executive the powers to cease issuing and maintaining of commercial
trade licences for certain species, through an amendment of Cap. 586. This would allow a local banon the ivory trade to be carried without a lengthy grace period, if the Chief Executive were to act
immediately to terminate commercial ivory trade once the amended law is enacted.
Given China’s domestic trade ban on all commercial ivory sales by the end of 2017, and the recent
CITES Resolution (10.10. Rev CoP17) urging the closing of domestic ivory markets that contributeto poaching or illegal trade as a matter of urgency, there is now greater justification for a more rapid
implementation of a local ivory ban in Hong Kong. The city could be vulnerable to any unlawfulattempts to leak ivory out of the mainland, given that Hong Kong is one of the closest markets whereivory can still be legally traded (for the time being). Narrowing the allowable trade window in Hong
Kong (i.e. the grace period) could reduce the opportunity for laundering of illegal ivory from othermarkets to Hong Kong, which the city’s phase out plan was designed to accomplish.
Bringing the effective date of a local ivory ban forward would more fruitfully build on the international
momentum to end the illicit ivory trade than the government’s proposed alternative, and demonstrate
Hong Kong’s ability to respond resolutely to the urgent elephant crisis.
8.2. Regular Reporting and Monitoring
There is a greater need to monitor ivory movements within Hong Kong over the next few years,
to understand better the methods that licensees are taking, or intending to take, to liquidate ivory
stocks before the local ivory trade ban is in place. With the risk that existing commercial stocks could
potentially be redirected into trade through black market channels, it is critically important to keep
track of ivory stock movements in Hong Kong, through ongoing physical and online market surveys.
One way in which the tracking of local ivory trade can be improved is to impose a requirement
for more regular reporting of transactions on licensed ivory dealers. Currently, information on
ivory transactions, and therefore changes in overall stockpile levels for individual licensees, are only
gathered every five years, when transaction data are submitted pursuant to the renewal of licences.
Reporting of transactions, set at monthly intervals, would allow AFCD to maintain an actual accountof the level of ivory stocks in the city at any given moment in time. For example, the government ofThailand now requires that retail dealers report ivory sale transactions on a monthly basis (Apinya
Jaitae, Senior Forestry Technical Officer, Department of National Parks, Thailand pers. comm. to Tom
Milliken, TRAFFIC, August 2015). Given the impending ban, these changes should be implemented
as soon as possible.
This should not be too burdensome for licensees since they are already being asked to keep their own
record of transactions within three days of the sale taking place. The format of submission should
not differ greatly from the current format, although AFCD could devise a more efficient mannerof submissions through online tools to minimize the effort required by both licensees and AFCD
personnel.

28 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong8.3. Expand System of Stockpile LabellingWith the introduction of the hologram labelling system in September 2015, a number of ivory itemsin the market now have the new labels attached. However, licensed dealers that renewed their licences
prior to September 2015 do not have the new labels, creating a mishmash of labelled and unlabelled
ivory items for sale in the marketplace. This could create undue confusion about product legality for
consumers.
The hologram labelling system has great value in allowing the enforcement authorities to trace andtrack ivory items, especially during the proposed five-year grace period where local ivory trade isallowed before a ban comes into force. AFCD should propagate this labelling system to all commercial
ivory pieces above 100 g (Box 1) within the next 12 months. This would provide an avenue for existing
licensed dealers to prove the legality of their products and address any biases arising from the poor
timing of the new labelling system. Ensuring more of Hong Kong’s ivory stocks are labelled under the
new system would help to level the playing field amongst all licensed ivory dealers.
8.4. Regulating the Trade in Antique Ivory
The Hong Kong SAR Government has expressed its intention to maintain the trade in antiqueivory, but there are few indications at present concerning the mechanism for proving an ivory item’s
antiquity. The Hong Kong SAR Government is urged to clarify the mechanism of proof as soon as
possible, so that the potential size of the market for antique ivory stocks can be assessed.
It is also currently unclear how the antique ivory trade will be managed and overseen by government
authorities if such trade is allowed. AFCD is currently empowered to impose a licensing system forcommercial trade in scheduled species listed on Cap. 586, including elephants, and at the very least,
such a licensing regime should be enforced on antique ivory traders. It is suggested that a proactive
approach to the management of commercial trade in antique ivory should be introduced, including
a process for AFCD to stocktake, label and record all commercial antique ivory items in Hong Kong.
Such an endeavour may not be as onerous as it sounds, since a similar process had been undertaken
between 2015 and 2016 on the 77 tonnes of commercial pre-Convention and pre-ban ivory for sale
(as at the end of 2015; Legislative Council, 2016), and that the pool of commercial antique ivory
should be considerably smaller. If this process is completed prior to the imposition of the local ivory
trade ban in 2021, enforcement authorities would be well-equipped to monitor future trade in antiqueivory, and potentially limit the potential for illegal laundering of non-antique ivory into the legal
antiques market.
8.5. Review Hong Kong’s stockpile management system for confiscated ivory
In 2014, the Hong Kong Government announced plans to incinerate its ivory stockpiles that had been
confiscated between 2003 and 2014. Since mid-2016, all of the planned 28 tonnes of confiscated ivory
has been completely incinerated (ESAC, 2016). While this effort represented an important policy
shift at the time, it is nevertheless unclear how future confiscated ivory—from border and market
seizures—will be dealt with. Hence, Hong Kong’s policy around ivory stockpile management needs to
be clarified. Furthermore, issues concerning electronic record-keeping of confiscated ivory, their safe
storage and the periodic auditing of such stocks should be reviewed.

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 29

8.6. Tackling Ivory and Other Wildlife Crimes: Enhancing Enforcement
Co-operation between law enforcement agencies on wildlife crimes, both within Hong Kong and with
their overseas counterparts, is critical given the possible transnational nature of such crimes. Hong
Kong’s Customs and Excise Department, for example, have signed Memorandum of Understanding(MoU) agreements with their overseas counterparts on co-operation and mutual assistance.15 These
high-level commitments need to be complemented with communication and information exchanges
between personnel within the various law enforcement agencies. There are successful models of suchco-operation through online sharing platforms that exist globally to foster enforcement co-operation,
ranging from EU-TWIX,16 which allows for real-time alerts between enforcement personnel within
Europe, to NICE-CG and PICE-CG,17 China’s national and provincial platforms, respectively, forcollaborative enforcement effort between China’s various law enforcement agencies. Hong Kong’s
newly established Wildlife Crime Task Force (Environment Bureau and AFCD, 2016) could greatly
benefit from implementing similar communications tools and collaborative methods.
Plans to increase the involvement of the Hong Kong Police Force and the Customs and Excise
Department with AFCD, within the auspice of the Wildlife Crime Task Force (Environment Bureau
and AFCD, 2016), is encouraging. Assistance on investigations, from gathering information andintelligence when taking official statements from arrested smugglers, to examining underlying links
to organized crime, will be greatly enhanced through this proposed interdepartmental collaboration
within the Wildlife Crime Task Force. In this regard, the task force should aim to scale up thegovernment’s oversight of its borders, and improve its tracking and interrogation methods in dealing
with wildlife crimes, extracting lessons from its handling of other serious crimes.
Moreover, as stated in Hong Kong’s NIAP and AFCD’s 10 measures, there is a greater push by AFCD
to make use of forensic technologies to identify the origin of ivory seizures and assess the age, andtherefore legality, of ivory pieces under suspicion. In March 2017, results from forensic tests wasused for the first time in a court of law in Hong Kong, but testing was conducted in an overseas lab
which meant greater costs and time in producing test results (TRAFFIC, 2017). Such technologies
have not been extensively developed locally, but investing in capacity building of local laboratories,
or in-house within AFCD, would help accelerate testing and support more rapid enforcement actions
to combat illegal ivory trade prior to and after a local ivory trade ban. As a wildlife trade hub, Hong
Kong could benefit from much needed forensic examination capacity for other smuggled wildlife
specimens beyond ivory.
8.7. Tackling Ivory and Other Wildlife Crimes: Penalties to Suit a Serious Crime
The element of risk is a prevalent part of the equation for would-be ivory smugglers of organizedcrime networks, but judicial rulings in Hong Kong for wildlife crimes in general are not sufficient
deterrents for such criminals. Sentences that are handed out under Cap. 586 are typically well short ofthe maximum levels,18 and pale in comparison to penalties set by other countries for similar crimes.
When laws reflect wildlife trafficking as a transnational organized crime, it gives recognition of asecurity threat requiring more severe sentencing in criminal prosecutions. It may also lead to the

For example, MoUs with Argentina and Viet Nam Customs signed in 2013 (Customs and Excise Department, 2013b).
EU TWIX is one example of a common platform of law enforcement in Europe to share information and has led to greater intelligence sharing andmore acute assessment of risks amongst enforcement agencies in different European countries (Anon., n.d.).
17
National Inter-agency CITES Enforcement Coordination Group (NICE-CG); Provincial Inter-agency CITES Enforcement Coordination Group(PICE-CG).
18
Offences under Cap. 586 are liable on conviction to a Level 6 fine (HKD100,000) and one year of imprisonment.
15
16

30 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kongengagement of mainstream law enforcement agencies to collaborate to combat wildlife crimes locallyand between countries (Anon, 2016).
As the government seeks to review penalties for wildlife crimes (Environment Bureau and AFCD,
2016), it is important that offences are created to reflect the seriousness of such crimes, and that aprocess should be initiated with the Department of Justice to find suitable amendments to the law toindicate both the “serious” and “organized” nature of wildlife crime.19
8.8. Demand Reduction Strategies
The Hong Kong SAR Government should implement the CITES Resolution on Demand Reduction
strategies to combat illegal trade in CITES-listed species (CITES Resolution Conf. 17.4), which wasagreed in 2016 at the 17th Conference of the Parties. Giving effect to this resolution could lead togreater awareness about the consequence of ivory consumption on remaining elephant populations,research to understand the dynamics of demand, and campaigns to reduce consumption of illegal
wildlife products, targeting specific consumer groups. Existing efforts by AFCD that emphasise thelegal prohibitions on illegal import and export of ivory, through posters displayed in licensed outlets
and border crossings, is a valuable example of this. Following on from those efforts, future campaigns
will probably be necessary if the proposed local ivory trade phase out plan is implemented. Researchon the motivations for procuring illegal ivory, and more targeted campaigns that address the specificdemand of key consumer groups, would be a good approach going forward.

19
The UN Convention on Transnational Organized Crime does not define wildlife crime, but the components of organized and serious crimes in many
instances reflect wildlife trafficking. An organized criminal group involved in a serious crime is defined as three or more persons acting together tocommit a crime punishable by at least four years incarceration to “obtain either directly or indirectly, a financial or other material benefit” (Article 2).

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 31

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34 TRAFFIC report: A rapid survey of UK ivory markets

TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong 35

APRIL 2017

TRAFFIC, the wildlife trade monitoring network,is the leading non-governmental organization
working globally on trade in wild animals andplants in the context of both biodiversity
conservation and sustainable development.
For further informationg contact:
TRAFFIC
Headquarters OfficeDavid Attenborough Building
Pembroke Street
Cambridge CB2 3QZ
UK
Telephone: (44) (0) 1223 277427
Fax: (44) (0) 1223 277237
E-mail: traffic@traffic.org
Website: www.traffic.org

UK Registered Charity No. 1076722,
Registered Limited Company No. 3785518.

This report was made possible through thesupport provided by GIZ on behalf of theGerman Federal Ministry for Economic
Cooperation and Development (BMZ) and theGerman Federal Ministry for Environment,
Nature Conservation, Building and Nuclear
Safety (BMUB).

is a strategic alliance of

36 TRAFFIC report: Closing strategy: Ending ivory trade in Hong Kong