DECEMBER 2020

TEETERING ON
THE BRINK
JAPAN’S ONLINE IVORY TRADE
Ryoko NISHINO
Tomomi KITADE

TRAFFIC REPORT: TEETERING ON THE BRINK

01

TRAFFIC REPORTTEETERING ON THE BRINK
TRAFFICisaleading

non-governmentalorganisation working globally on trade in wild
animals and plants in the context of bothbiodiversity

conservation

andsustainable

development.
Reproduction of material appearing in this reportrequires written permission from the publisher.
The designations of geographical entities inthis publication, and the presentation of thematerial, do not imply the expression of any
opinion whatsoever on the part of TRAFFIC or
its supporting organisations concerning the legal

ACKNOWLEDGEMENTS
The completion of this report was only possible with the supportof many individuals from both TRAFFIC and WWF Japan. Firstand foremost, critical inputs from Sabri Zain, Wilson Lau, Lu
Gao, Giavanna Grein, Joyce Wu, Ling Xu, Linda Chou were
essential in refining the manuscript. Special thanks also go to
Yu Xiao, Eleanor Drinkwater, Lauren Brown, Shinichi Kawae, forpractical support, as well as Richard Thomas for finalising thereport. The authors are also grateful for the devoted volunteer
work by Zhang Yujia for taking on background data collection
on illegal trade in Chinese language sources. Last but not least,
the authors express their sincere appreciation that preparationof this report was made possible with funding support fromWWF Japan.

status of any country, territory, or area, or of its
authorities, or concerning the delimitation of its
frontiers or boundaries.
This report was made possible with support fromWWF Japan.

SUGGESTED CITATION
Suggested citation: Nishino, R. and Kitade, T.
(2020). Teetering on the brink: Japan’s online ivory

trade. TRAFFIC, Japan Office, Tokyo, Japan.

GLOSSARYCONTRIBUTING ORGANISATIONSB2C Trade

Trade from Business to Consumer.
Businesses list products in online stores
where consumers purchase them.

C2C Trade

Trade from Consumer to Consumer. This
type of trade is conducted by non-businessindividuals on platforms such as internet
auctions and flea market sites/apps.

Cryptic listings

Listings advertised as not being the product(in this instance ivory) or not explicitly statedas such. Cryptic listings often use codewords, jargon or allusion as to what is reallyfor sale.

hanko

A stamp used as a signature for individuals
and corporations. In Japan, a stamp seal
registered with the local government is used

WWF Japan

ISBN NO. 978-4-915613-38-8
Published by:Japan Office, Tokyo, Japan© TRAFFIC 2020. Copyright of material publishedin this report is vested in TRAFFIC.
UK Registered Charity No. 1076722

LayoutShunji ARAKAWA

TRAFFICREPORT:
ON2020.
THE BRINK
2nd02
edition:revisedon 9thTEETERING
Decemberas an official signature, although increasingly
digitalisation is replacing this tradition.

CONTENTS
KEY POINTS .................................................................................................................................................................... ii
KEY RECOMMENDATIONS .............................................................................................................................. iii
BACKGROUND................................................................................................................................................................ 1
METHODOLOGY............................................................................................................................................................ 4
RESULTS AND DISCUSSION ............................................................................................................................ 7
Online shopping malls (B2C trade) .................................................................................................................... 8
C2C markets..................................................................................................................................................................... 9
Online auction sites................................................................................................................................................... 11
Trade that remains a concern ............................................................................................................................ 12
Concerns regarding the domestic market as a whole still contributing to illegal export.......... 15

CONCLUSION AND RECOMMENDATIONS........................................................................................ 21

TRAFFIC REPORT: TEETERING ON THE BRINKi

KEY POINTSSCOPE OF SURVEY
TRAFFIC conducted online surveys to track changes after voluntary ivory bans were introduced
from November 2019 on Yahoo Shopping and Yahoo Auction, Japan’s largest platforms for online
ivory trade, following similar voluntary bans already implemented by Rakuten-Ichiba, Rakuma andMercari.
The trading practices of a major auction house, Mainchi Auction, and trends in illegal ivory exports
were also examined to understand better the domestic ivory market in Japan. The COVID-19
pandemic has made it difficult to assess physical markets.

RESULTS: Effective measures by companies
The number of shops selling ivory on Yahoo Shopping and Rakuten-Ichiba as B2C (business toconsumer) trade and the volume of ivory trade on Yahoo Auction, a mixture of B2C and C2C(consumer to consumer) trade, have reduced by almost 100% and more than 99%, respectively asa result of the platform-wide voluntary ivory ban.
There was no observable shift in either B2C or C2C trade to other platforms after the introductionof the ivory ban on Yahoo’s platforms.
Monitoring of ivory bans by companies such as Mercari and Rakuma was seen to have beeneffective.

CHALLENGE: Cryptic listings
Cryptic listings with descriptions such as “ivory-like” or “mammoth ivory” but likely
selling genuine elephant ivory occasionally appeared in both B2C and C2C trade,while it was difficult to tell if many other items were genuine because of the qualityof the images depicting them.

CHALLENGE: Lack of legal compliance
Although most of the surveyed platforms had ivory trade bans in place, someinstances of ivory sales were encountered. The level of legal compliance withregistration requirements by businesses overall was found to be very low, with 74%
not displaying registration details and 53% not even being registered businesses.

ii TRAFFIC REPORT: TEETERING ON THE BRINKCHALLENGE: Remaining domestic market
After the ivory ban on Yahoo Auction, there was a slight increase in thenumber of listings and sales on Mainichi Auction, although the value of
total sales remained stable. Active ongoing trade at the major physicalauction house suggests that continued attention to the domestic trade isnecessary.

CHALLENGE: Ongoing illegal export from Japan
Illegal ivory exports from Japan were observed to be ongoing with at least
36 cases of small but noteworthy seizure cases bound for China during
2019.

KEY RECOMMENDATIONSTO THE JAPANESE GOVERNMENTThe Japanese Government should develop an action plan toward closure of ivory
markets (with narrow exemptions) ahead of the Tokyo Olympics/Paralympics.

TO E-COMMERECE COMPANIESJapan-based e-commerce companies who have introduced ivory bans should
ensure policy compliance by users, and platforms that still allow ivory trade should
introduce similar voluntary ivory bans as a matter of urgency.

For a full list of recommendations, see page 23.

TRAFFIC REPORT: TEETERING ON THE BRINK

iii

BACKGROUND
1 TRAFFIC REPORT: TEETERING ON THE BRINKBACKGROUND
Poaching of African Elephants Loxodonta africana
and illegal ivory trade globally has reached criticallevels. In response, the Convention on International
Trade in Endangered Species of Wild Fauna
and Flora (CITES), at the 17th meeting of theConference of the Parties (CoP17) in 2016, called
for ivory market closures with narrow exemptions
by revising Resolution Conf.10.10 (Trade in
Elephant Specimens)1. CITES Parties also called
for strengthening of international trade controls,
together with efforts to ensure domestic ivory
markets do not contribute to poaching or illegal
trade. At the following CoP18 in 2019, it was agreed
that Parties with domestic ivory market deemed tobe contributing to elephant poaching or illegal trade
should take effective countermeasures, and report to
the CITES Secretariat on the measures taken, while
the Standing Committee2 should also assess theirprogress (Decision 18.117-119)3.
Japan has a major ivory market but is not considereda destination for significant illegal ivory flows leaving
Africa4. The government considers that since ivory
currently traded in Japan is from historically legallyimported stockpiles, the domestic ivory market isunrelated to the poaching of African Elephants5
and therefore actions related to this aspect of
CITES Resolution Conf.10.10 (Rev. CoP18) are notnecessary. However, market surveys conducted by

1
2

3
4

5

6

7
8
9
10

TRAFFIC in 20176 and 20187 revealed that ivory has
been illegally exported recently from Japan, mainly
to China, and that domestic trade, including throughonline channels, has contributed to illegal exports.
As Japan has a large and partly undocumented
stockpile of ivory, domestic trade of ivory should
be discontinued where strict controls and reliable
traceability cannot be assured. WWF and TRAFFIC,in accordance with the CITES Resolution, haverecommended that the Japanese Government
should consider instituting an ivory market closure
with narrow exemptions.
The Japanese Government amended the Law for
the Conservation of Endangered Species of Wild
Fauna and Flora (LCES) in 20178, which enteredinto effect on 1st June 2018. In addition to this,the Ministry of the Environment (MOE) introduced
stricter conditions for whole tusk registrations in July
20199. However, these measures only cover ivory
businesses and trade in whole tusks. No measures
were taken to verify the legality and traceability ofprocessed goods and other products, or to determine
the total size of stockpiles. The Tokyo Metropolitan
Government (TMG), recognising its responsibility as
an international city, recently undertook to establish
its own Advisory Council on Regulating Ivory Tradein January 202010 with a scope for potentiallystrengthening regulations. In addition, the Act on

CITES Resolution Conf.10.10 (Rev.CoP18) https://www.cites.org/sites/default/files/document/E-Res-10-10-R18.pdf
The 73rd Standing Committee meeting was originally scheduled for October 2020, but has been delayed due to the COVID-19 pandemic (as of Nobember2020). https://www.cites.org/sites/default/files/notif/E-Notif-2020-051.pdf
CITES Decision 18.117, 118, 119. https://cites.org/eng/taxonomy/term/42050
CITES (2016). CITES CoP17 Doc. 57.6 (Rev. 1), REPORT ON THE ELEPHANT TRADE INFORMATION SYSTEM (ETIS). https://www.cites.org/sites/default/
files/eng/cop/17/WorkingDocs/E-CoP17-57-06-R1.pdf
TRAFFIC (2017). IVORY TOWERS: An Assessment of Japan’s Ivory Trade and Domestic Market. https://www.wwf.or.jp/activities/data/20171220_
wildlife02.pdf
House of Representatives, Japan (2019). Committee on Environment #5 at 198th session of the Diet. http://www.shugiin.go.jp/internet/itdb_kaigiroku.nsf/
html/kaigiroku/001719820190510005.htm
TRAFFIC (2017). IVORY TOWERS: An Assessment of Japan’s Ivory Trade and Domestic Market. https://www.wwf.or.jp/activities/data/20171220_
wildlife02.pdf
TRAFFIC (2018). Slow Progress: A Reassessment of Japan’s Ivory Market in 2018. https://www.wwf.or.jp/activities/data/20180927_wildlife02.pdf
MOE (2018). https://www.env.go.jp/press/105546-print.html
MOE (2019). https://www.env.go.jp/press/106849-print.html
TMG (2020). https://www.metro.tokyo.lg.jp/tosei/hodohappyo/press/2020/01/10/10.html

TRAFFIC REPORT: TEETERING ON THE BRINK

2

the Promotion of Administrative Activities Utilizing
Information and Communications Technology(Digital Procedure Law) was amended11, which
promotes the digitisation and online accessibilityof administrative procedures such as by enabling
corporate registration without a hanko as a company
stamp and signature (around 80% of ivory productionin Japan being comprised of hanko12). Effective asof 16th December 2019, the legal amendment is
expected to promote a shift away from traditional
ivory utilisation in Japanese society.
The anonymity of traders online has encouraged
illegal exports of ivory to proliferate, especiallythrough unregulated C2C trade and internet auctions
that are beyond the control of LCES. TRAFFIC has
previously highlighted this occurrence throughmarket surveys in 201413, 201714 and 201815, andhas recommended the Japanese Government ande-commerce companies should prohibit ivory trade
online. Internationally, global companies such as
Google, eBay and Amazon introduced platform-widebans on ivory listings prior to 2014. In line with this,several Japanese companies have also banned
ivory trade on their platforms, including Rakuten
Inc. (Rakuten) and Mercari Inc. (Mercari) in Julyand November 2017, respectively. Yahoo Japan

11
12

13
14
15

Corporation (Yahoo Japan) also introduced a similar
ban in November 2019, which meant that ivory
products could no longer be listed on Japan’s major
e-commerce platforms, thereby largely restricting
ivory availability online to websites of individual ivory
businesses.
The aim of the current study was to assess how ivory
trade online in Japan has changed following Yahoo
Japan’s ivory trade ban, which was considered amajor turning point, and to evaluate its impact on
the domestic market. The study focused firstly on
the impact of the ivory trade ban on Yahoo Shopping
and Yahoo Auction operated by Yahoo Japan, andsecondly on the effects and challenges for monitoringof their platforms for the companies (Mercari,
Rakuten-Ichiba and Rakuma) who had voluntarily
introduced an ivory ban nearly three years earlier.
While the COVID-19 pandemic has made it impracticalto assess Japan’s physical ivory markets directly, thecurrent study instead examined ivory transactions
at a major auction house, Mainichi Auction (which
conducts both online and physical sales such as inperson auction events), and instances of illegal ivory
export from Japan. Based on these results, TRAFFIC
recommends the Japanese Government installs
effective policies to address its domestic ivory trade.

Cabinet Secretariat (2019). https://www.kantei.go.jp/jp/singi/it2/hourei/digital.html
TRAFFIC (2016). Setting Suns: The Historical Decline of Ivory and Rhino Horn Markets in Japan. https://www.wwf.or.jp/activities/data/16_Setting_Suns.
pdf
TRAFFIC (2015). A REVIEW OF ONLILNE IVORY TRADE IN JAPAN. https://www.traffic.org/site/assets/files/4166/a_review_of_ivory_trade_japan.pdf
TRAFFIC (2017). AN UPDATE REVIEW OF ONLINE IVRY TRADE IN JAPAN. https://www.wwf.or.jp/activities/data/20170808_wildlife02.pdf
TRAFFIC (2018). System Error, Reboot Required: Review of Onlilne Ivory Trade in Japan. https://www.wwf.or.jp/activities/data/20180913_wildlife02.pdf

3 TRAFFIC REPORT: TEETERING ON THE BRINKMETHODOLOGYTRAFFIC REPORT: TEETERING ON THE BRINK

4

METHODOLOGYTARGET PLATFORMS
A survey of various online platforms was conductedfrom June to July 2020. TRAFFIC’s previous methodology
for conducting surveys of online ivory trade in Japan16
was replicated, to enable a comparative analysis withpast results. Three new platforms were added to thesurvey as shown in Table 1.

One of the new platforms, Mainichi Auction, is a major
Japanese auction house with in-person bidding while
also allowing bidding via an online auction system.
Ivory trade at the auction house has been active inthe past, at levels that would make it second only toYahoo Auction, especially for whole tusks. Monitoringof this platform was included in the current survey tohelp assess the impact of the online ivory bans onivory availability elsewhere.

Table 1. Platforms surveyed between June to July 2020
Category

Shopping malls(B2C)

Platforms

Rakuten-Ichiba (https://www.rakuten.co.jp/)✓

Pompare Mall
(https://www.ponparemall.com/)✓

au PAY Market (Wowma) (https://wowma.jp/)

✓
✓
✓
✓
✓
✓
✓
✓
✓
✓

minne (https://minne.com/)
Mercari (https://www.mercari.com/jp/)
Rakuma (https://fril.jp/)
Shoppies* (https://shoppies.jp/)
Jimoty* (https://jmty.jp/)
Yahoo Auction (https://auctions.yahoo.co.jp/)
Mobaoku (https://www.mbok.jp/)
Facebook (https://ja-jp.facebook.com/)
Social Networking
Site (SNS)Twitter (https://twitter.com/?lang=ja)
Instagram (https://www.instagram.com/?hl=ja)

Auction house

Snapshot✓

BASE (https://thebase.in/)

Internet auction
sites

Data collection

Yahoo Shopping(https://shopping.yahoo.co.jp/)

Qoo10 (https://www.qoo10.jp/)

C2C markets

Ivory items
prohibited

Mainichi Auction*(https://www.my-auction.co.jp/)

Monitoring

✓
✓

✓
✓
✓
✓
✓

Assessed for 6 auction
events (2019–2020)* newly added platforms in the 2020 survey
16

TRAFFIC (2018). System Error, Reboot Required: Review of Onlilne Ivory Trade in Japan. https://www.wwf.or.jp/activities/data/20180913_wildlife02.pdf

5 TRAFFIC REPORT: TEETERING ON THE BRINKSEARCH KEYWORDS
As in the previous survey, “elephant ivory”17 inJapanese (象牙) was used as a keyword. However,some possible effects of the ivory ban may be theuse of more cryptic descriptions, possibly to evadedetection, and the appearance of substitutions. We
therefore added “mammoth ivory” (マンモス牙) as asearch keyword (except on social networking sites(SNS) and Mainichi Auction), as a preliminary survey
conducted in early June 2020 had suggested anincrease in such items.

SNAPSHOT ANALYSES
To gain an overview of ivory trade on each platform(Table 1), data were collected on all listings, sellers
or shops found in searches for “elephant ivory”
and “mammoth ivory” in July 2020. The level ofcompliance with LCES provisions18, as indicated bydisplays of ivory business registration details andthe use of a voluntary product certification that
accompanies the product listings, were assessed on
platforms where ivory trade was found. On platforms
where ivory trade is prohibited, the existence of
cryptic listings, the appearance of substitutions, andcontinued business on those platforms by sellers or
shops found in the 2018 survey were assessed.

MONITORING SURVEY
For trade via C2C platforms, auctions, and SNS, newlistings were monitored using the search keyword“elephant ivory” on Mercari, Rakuma, Mobaoku, andSNS. The monitoring period was four weeks, from14th June to 12th July 2020. Due to the ivory ban
introduced on Yahoo Auction from 1st November
2019 (announced in August 2019), monitoring of theplatform was conducted over three four-week periods
to obtain a pre- and post-ban comparison: 1) before

17

18

the ban announcement: 3rd–30th June 2019; 2) one
month after the ban: 3rd–30th December 2019; and3) seven months after the ban: 3rd–30th June 2020.
Actual transaction records during a four-week period
on Yahoo Auction, and all new listings on other sites,
were recorded (checking for new listings once a dayin the case of C2C and auctions, and for public posts
once or twice a week on SNS). Data were collectedon the number of items, product categories, prices
and sellers’ information. We added “mammoth ivory”
as a search keyword (except on SNS) during themonitoring period. When ivory listings were found,they were further tracked in subsequent weeks to
see if the listing was removed by the company. If they
had not been removed, the platforms were notified.
Furthermore, related listings were examined withcare to look for the existence of cryptic listings thatwere advertised as genuine mammoth ivory pieces,
and as alternative materials. On Mobaoku, the only
online auction site which did not ban ivory, the bidding
results for new ivory listings were also tracked andlisting information included in the analysis.

PHYSICAL AUCTION SALESASSESSMENT
Six auction events from Mainichi Auction held
between February 2019 and June 2020 wereidentified to have dealt with ivory items. Relevant data
including the auction results from ivory auction lots
were collected through the open access informationon the auction house’s website, and assessed.
The currency rate of JPY1 = USD0.0093 (at 1st July2020) was used. Information obtained through thesurvey, which pertained to potential non-complianceor illegal activities, was shared with the respective
authorities and companies operating the respective
platforms.

On Yahoo Shopping in 2018, so much ivory was listed that the search keyword “hon-zouge 本象牙 (genuine ivory)” was used to sample listings for realivory products more efficiently.
There is another LCES provision that mandates display of registration cards issued by MOE for any whole tusks advertised. However, no listing of wholetusks was found during snapshot survey.

TRAFFIC REPORT: TEETERING ON THE BRINK

6

RESULTS ANDDISCUSSION
7 TRAFFIC REPORT: TEETERING ON THE BRINKRESULTS AND DISCUSSIONONLINE SHOPPING MALLS (B2C TRADE)
B2C trade drastically reduced as a resultof the ivory trade ban on Yahoo Shopping
and Rakuten-Ichiba
There has been a 100% decrease in the number ofshops selling ivory after Yahoo Shopping, Japan’slargest ivory trading platform, introduced an ivory
trade ban on its platform in November 2019.
A snapshot survey of Yahoo Shopping in June2018 using the search keyword “hon-zouge 本象
牙 (genuine ivory)”19 found at least 54 shops sellingivory. This time, however, there were no hits evenwith the simpler keyword “zouge 象牙 (elephantivory)” (Figure 1). On Rakuten-Ichiba, not a single
shop was found to be selling ivory at the time of the2018 survey, but during the latest survey, one listingfor ivory products was observed on a garden centre’s
page, which is not a typical ivory outlet. The listing
was reported via the website’s reporting system andlater removed. At least 55 shops were observed to behandling ivory on Rakuten-Ichiba in May 2017 before
the ban was introduced (Figure 1), so the ivory ban
by these companies has clearly been effective in
reducing the volume of ivory available for sale.

No. of shops selling ivory

70
60

58

55

54

50
40
30
20
10
0

0

1

2017 2018 2020
Rakuten-Ichiba02017 2018 2020
Yahoo Shopping

Figure 1. Comparison of the number of shops found with ivory listings: Rakuten-Ichiba and Yahoo Shopping(2017–2020)
This figure shows the number of shops where ivory listings were observed in snapshot surveys using keyword searches in
May 2017, June 2018 and July 2020, respectively. In pre-ban surveys (Rakuten-Ichiba in 2017, Yahoo Shopping in 2017 and2018), the keyword used was “hon-zouge (genuine ivory)”, whereas in post-ban surveys, “zouge (ivory)” was used to broaden
the search. It should therefore be noted that the pre-ban shops found with ivory were likely only a portion of the total numberof shops carrying ivory for sale.

19

Before ivory trade bans on Rakuten-Ichiba in 2017 and Yahoo Shopping in 2017 and 2018, the number of ivory listings found with the search keyword“hon-zouge (genuine ivory)” was so high that only the first 100 hits were collected as a sample of the ivory listings on the platforms.

TRAFFIC REPORT: TEETERING ON THE BRINK

8

45

14

42

35
30
25
20
15

16

10

11

10

9

8
6

6

4

3

2

5
0

13

12
No. of shops selling ivory

No. of shops selling ivory

40

132018 2020
Total

0

0

0

2018 20202018 2020
au PAY Market Ponpare Mall

2
1

2018 2020
Qoo10

2018 2020
BASE2018 2020
minne

Figure 2. Comparison of the number of shops with ivory listings: Total across five online shopping malls (left)and each online shopping mall (right).
This figure shows the number of shops where ivory listings were observed in snapshot surveys using the search keyword“zouge (ivory)” in June 2018 and July 2020, respectively.

The number of shops selling ivory on five otherplatforms decreased from a total of 42 in the 2018
survey to 16. BASE, a smartphone application,
experienced a slight increase (from 9 to 13 shopswith ivory) while the other platforms experiencing
a significant decrease (Figure 2). However, those
five platforms introduced policies to prohibit ivory
sales between the last survey in 2018 and the latest
survey in 2020. This means those businesses are notintentionally complying with or unaware of the policyof these platforms. The results were reported to the
Ministry of Economy, Trade and Industry (METI) andrelevant platforms.

Of the 96 shops found with ivory listings in the 2018
survey (across six platforms, excluding RakutenIchiba), four were still in business offering ivory
products. These listings and continuance of a small
number of businesses may indicate the introductionof an ivory ban might not have been effectively
communicated by companies to the sellers on theirplatforms. On the other hand, it shows that thevoluntary bans imposed by major B2C platforms
have led to a drastic reduction in ivory offerings, andthat no shifts in ivory items being offered on other
B2C platforms were apparent. There were also no
cryptic listings found on all seven platforms whichwere surveyed.

C2C MARKETS
Positive effects are due to continued
monitoring by companies, althoughsome issues remain
Mercari and Rakuma, the major C2C platforms inJapan that have implemented an ivory trade ban

No listings were found for ivory products during
snapshot surveys on Mercari and Rakuma.
Meanwhile, the four-week monitoring survey
revealed two listings on Mercari that clearly specified
elephant ivory, with a total of just two items. The
company responded rapidly by removing thesesince 2017, appear to be effectively monitoring andkeeping ivory products away from their platforms.
However, some challenges remain regarding
product identification.

listings one day after it was reported. No relevant
listings were found during monitoring on Rakuma.
These results show that the ivory trade banson Mercari and Rakuma are being implemented

9 TRAFFIC REPORT: TEETERING ON THE BRINK

effectively through consistent monitoring andenforcement action.
Two additional C2C platforms were added to thelatest survey, where listings for ivory items were
found to be limited. No listings were observed on
Shoppies, a previously unsurveyed outlet where ivory
trade has not been banned, and a snapshot surveyof Jimoty found 11 items though the platform hasa policy prohibiting ivory trade. This would suggestthat the ivory trade bans on Japan’s major C2C
platforms, especially from the recent ban on Yahoo
Auction, which had the largest volume of C2C trade(private auctions are considered C2C trade) prior to
the ban, did not drive a dispersal to the other C2C
platforms surveyed.
Cryptic listings that were identified did not giveany clear indication in the listings’ description orcomments that genuine ivory was being offered20,

Examples of cryptic listings on Mercari (left) and Rakuma (right). Detected using the keyword “elephant ivory”, wherethese were described as “ivory-like” but were likely genuine ivory from their visible patterns (Schreger lines).
* Manual/Guide for the ivory identification
Produced by MOE:
https://www.env.go.jp/nature/yasei/manual_idrs/manuals/ebur_mammoth.pdf
Produced by CITES/WWF/TRAFFIC:
https://cites.org/sites/default/files/ID_Manuals/R8_IvoryGuide_07162020_low-res.pdf

20There were several cases that were specified as genuine ivory in the listings’ description or comments at the previous survey in 2018.

TRAFFIC REPORT: TEETERING ON THE BRINK

10

but upon close inspection of the provided images,
four items on Mercari and two items on Rakuma
could be distinguished as genuine ivory via theitems’ Schreger lines.21 These listings were describedas “zouge-hu 象牙風 (Ivory-like)”, “zouge-cho 象牙調 (Ivory-style)”, “zouge-moyou 象牙模様 (Ivorypattern)” and “mammoth ivory”. It could not be
determined whether this was a deceptive tactic
intended to evade surveillance or whether the seller
was unable to recognise the items as elephant ivory.
There were a number of other suspicious listings

with unclear images which prevented definitive
identification; eight such items on Mercari and seven
items on Rakuma were found. Such problems may
persist, given the reliance on images and the lack of
capacity/ability on the part of companies manually
to identify product authenticity. The introduction of
the latest AI technology such as image recognition
system should therefore be considered, along with acomplementary requirement for sellers to post highquality, high resolution images.

ONLINE AUCTION SITES
Ivory trade drastically reduced via theYahoo Auction ban
Similar to Yahoo Shopping amongst online
shopping malls, Yahoo Auction was previously themost active for ivory trade among online auction
sites. Since the ivory trade ban was introduced in
November 2019, the volume of ivory trade has fallen
by more than 99%.
The total value of ivory sales on Yahoo Auction,
based on successful bid prices, during the four-weekmonitoring periods conducted before the ivory ban in
May 2017, June 2018 and June 2019 were JPY45.2
million (USD420,000), JPY37.8 million (USD350,000)
and JPY30.7 million (USD280,000), respectively.
By comparison, surveys on Yahoo Auction in
December 2019 and June 2020, after the ivory
ban had been introduced, found no obvious ivory
listings. However, six cryptic listings and ten cryptic
listings were identified in the December 2019 andJune 2020 surveys, valued at JPY60,000 (USD550)
and JPY80,000 (USD750), respectively. Overall, theban on Yahoo Auction has brought about a drastic
reduction in volume of ivory trade (Figure 3).

four listings were likely elephant genuine ivory from
Schreger lines in the product images provided. There
were an additional 11 listings from the June 2020
survey that were likely elephant ivory from Schregerlines in their images. These listings were describedas “ivory-like” in 11 listings, as “mammoth ivory” in
two listings, and “imitation ivory” in one listing.

Limited shift in trade from Yahoo Auction
to other online auction sites
Among the platforms that have not banned ivory,
only Mobaoku found an increase in the number oflistings, although no actual transactions occurred.
This indicates that the large volume of ivory tradepreviously conducted on Yahoo Auction did not
shift to other online auction sites after its platformwide ivory ban.

Among the cryptic listings found during the December
2019 survey, two listings were found to be genuine

On Mobaoku, a total of 852 ivory items (excluding
duplicates) were observed in the present survey,
compared with four in the 2018 survey. However,when the seller information and actual transaction
results were reviewed, the items listed for sale were
all derived from four sellers, with the same products
being re-listed every 3–7 days. Furthermore, records
indicated there were no actual transactions resulting
from such listings. This indicates a lack of demandivory from their product descriptions, while anotherfrom buyers on Mobaoku, especially when compared21

Arc-shaped curved lines visible in cross-sections of elephant ivory and mammoth ivory. They are named after the man who discovered them, Bernhard
Schreger. The angles of the rhombuses formed by the intersections of Schreger lines differ in elephant ivory and mammoth ivory and can therefore beused to differentiate the two.

11 TRAFFIC REPORT: TEETERING ON THE BRINKTotal value sold (Million JPY)45

JPY45.2(USD420K)
JPY37.8(USD350K)

40
35

Semi-processed pieces
Whole tusks
Other products
JPY30.7(USD280K)

9,788

No. of other products

30
25
20

Total value ofcryptic listings

6,244

10

JPY60,000 JPY80,000(USD550) (USD750)

50
May 2017

June 2018

10,000

8,000

6,000

4,000

4,144

15

12,000No.of products

50

June 201920

23

Dec 2019

June 2020

2,000

0

Figure 3. Trends in total sales and total number of ivory products on Yahoo Auction during four-weekmonitoring periods from 2017 to 2020
The orange line indicates the total number of products sold excluding whole tusks and semi-processed pieces.
Survey periods: 8th May–4th June, 2017; 3rd–30th June, 2018; 3rd–30th June and 3rd–30th December, 2019; 3rd–30th
June, 2020

to the number of items sold on Yahoo Auction prior
to the ban: 6,244 items actually sold over four-weeks
monitoring in 2019. Along with other results in the

C2C market, the ivory trade ban on Yahoo Auction
seems to have led to a drastic reduction in ivory tradeon online auctions.

TRADE THAT REMAINS A CONCERN
Unknown trade via closed groups andprivate posts on SNS
No increase in ivory listings was observed in public
posts on target SNS platforms. The survey could
not evaluate whether trade had shifted to closed
groups or private posts on SNS, which were difficult
to monitor.

the social networking platforms monitored alreadyprohibit advertising and other postings related toendangered animal products including ivory, any
shift in trade to closed groups or private posts on
SNS was not assessed in the latest survey, and is
especially difficult to monitor given their private andinaccessible nature.

On SNS, the number of products found in public
posts considered genuine listings of ivory products
during the 2018 surveys were 24 on Instagram, 8
on Twitter, and none on Facebook, which was not

Additionally, there are reports that SNS are actively
used for ivory trade in China, Indonesia, Thailand andViet Nam22. As these SNS platforms are borderless,there is a legitimate cause for caution about potential
links with the Japanese market. At the same time,a significant change from the 2018 results, with27, 9 and 3 products, respectively. However, while

the differing context of SNS usage in Japan suggests
the need for enhanced language specific monitoring

22

TRAFFIC (2020). TRADING FACES: A Snapshot of the Online Ivory Trade in Indonesia, Thailand and Viet Nam in 2016 with an update in 2019.
https://www.traffic.org/site/assets/files/12981/three-country-ivory-report.pdf

TRAFFIC REPORT: TEETERING ON THE BRINK

12

on global platforms as well as attention to otherplatforms such as LINE which is the most popularmessenger app in Japan.

as 93 listings over a four-week period of monitoring
C2C markets and auction sites were identified. In
particular, many of the items were found on Yahoo
Shopping and Rakuten-Ichiba (during snapshot
surveys, with 129 items and 126 items, respectively)
as well as Mercari (during monitoring surveys, with
101 items) (Figure 4). In listings of mammoth ivory,some items were visually identifiable as elephantivory from their images on BASE, Yahoo Auction
and Mercari. Many other listings and bidding results
could not be determined whether relating to elephantivory due to the poor quality and details in the images
provided. These listings accounted for 40–52%
on Yahoo Shopping, Rakuten-Ichiba and Mercari(Figure 4).

Issues related to mammoth ivory trade,and the need for continued monitoring
The additional search using a new keyword“mammoth ivory” did bring about a number of
positive hits, although it is hard to say whether they
could be substitution or cryptic listings of elephantivory.
Among the “mammoth ivory” hits via a snapshot
survey of six platforms, a total of 63 shops, as well

Yahoo Shopping

0

77

52

Rakuten-Ichiba

0

76

50

Ponpare Mall

02 0

au PAY Market

06 1

Qoo10

0 00

BASE

2 10 3

minne

00 0

Shoppies

00 0

Jimoty

10 0

0

20

Mercari3

Rakuma040

Yahoo Auction
Mobaoku

Difficult to distinguish
Mammoth ivory
Likely elephant ivory

40

60

45

12

12

80

100

120

140

80

100

120

140

53

0

0

0

20

40

60

(Mammoth ivory listings: No.of products)

Figure 4. Number of products and identification results from listings for mammoth ivory found in snapshot
survey (top) and monitorin g survey (bottom)
Survey period; At a certain point on July 2020, monitoring survey; 14th June–12nd July 2020 (Yahoo Auction only: 3rd–30th
June 2020)

13 TRAFFIC REPORT: TEETERING ON THE BRINKAs this is the first time that mammoth ivory listings
were included as a search keyword, it is not possible
to assess any changes in the number of listings.
However, even if all listings described as “mammoth
ivory” were in fact genuine elephant ivory (including
those that could not be distinguished as either
elephant or mammoth ivory), the number of items
offered pales in comparison to listings of elephantivory prior to the ivory trade bans on the platforms.
Nevertheless, the results indicate a need to sustain
monitoring of potential ivory substitutes offered forsale online that may be laundering elephant ivory, as
well as the challenges in identifying ivory from theprovided images.

them, 14 shops (74%) did not display their businessregistration details, while 10 shops (53%) had notactually registered (Figure 5). None of the businesses
were utilising the voluntary product certification
scheme (with a certification sticker attached) toindicate the legality of newly manufactured products.
These results show that there are still instances ofa lack of policy compliance by platforms that haveintroduced an ivory ban, and more importantly, that itis difficult to say if Japanese Government regulations
are working effectively to control trade by theremaining businesses.
This study into online trade proves that bans bycompanies have contributed greatly to the reductionof ivory trade and sales volumes, particularly
the elimination of previously unregulated C2C
trade. It would therefore be advisable to consider
implementing an ivory trade ban on platforms thatstill allow ivory to be traded. Furthermore, to ensure
full legal compliance, the Japanese Government
should take active measures such as guidance
and inspections of ivory businesses, along with
monitoring of online trading platforms. The noncompliance cases identified through the surveys
were reported to METI which is managing the ivory
industry.

Compliance by businesses to legislativechanges remains low
Registration of ivory businesses became mandatory
on 1st June 2018, with an obligation for businesses
to display their registration details with any ivory
listed for sale. However, compliance by businesses
who continue to trade online is low.
Online ivory listings were offered on the surveyed
platforms by a total of 19 shops, even though all
platforms have placed a ban on ivory trade. Among

14

20
No. of shops selling ivory

18
16

5
9

14
12

6
4

6

Business registration
No business registration

6
14
10

Total

9

4
2

2
0

4

10
8

10
8

Business registration
details displayed
No business registration
details displayed

12

0

7
0

0

1

1

RakutenIchiba

0
1

1
0

Qoo10

BASE

1

1

1

1

minne

0
2

1
1

JimotyFigure 5. Legal compliance of shops observed to be selling ivory during the 2020 survey: total across fiveplatforms (left) and individual platforms (right)
Jimoty has positioned itself as a C2C market, but as a platform it allows businesses to list items too. This time, two shops
were found to be listing ivory products as businesses.

TRAFFIC REPORT: TEETERING ON THE BRINK

14

CONCERNS REGARDING THE DOMESTIC MARKET AS A
WHOLE STILL CONTRIBUTING TO ILLEGAL EXPORTSurveys of pre-ban Yahoo Auction andMobaoku indicated a rise in listings forhanko material and semi-processed
piecesSurvey results from Yahoo Auction (from before
the ivory trade ban) and Mobaoku have shown an
increase in trade and listings for hanko material andsemi-processed pieces, a majority of which were byanonymous individuals. The situation calls for strict
domestic controls of ivory trade and stockpiles toprevent leakage into international illegal trade.

Three surveys on Yahoo Auction conducted in 2017–2019 (8th May–4th June 2017, 3rd–30th June 2018,and 3rd–30th June 2019) found a growing trend insales of hanko, with a corresponding decrease in
the sale of other ivory jewellery (Figure 6). Surveys
in 2019, in particular, found a noticeable increase in
the listings of hanko materials for sale, i.e. unfinishedhanko-shaped pieces, as well as some listings forivory cut pieces and other semi-processed pieces. A
survey of Mobaoku conducted in 2020 (14th June–
12th July) also observed that hanko (and hanko
material) accounted for the largest proportion oflisted products not sold (Figure 6).

%
100
24%

25%

20%

80
70

20%
46%

50
55%

16%

Hanko
( Hankomaterials)
Jewelley

22%

20

0

31%

33%

30

10

Others

10%

60

40

30%

21%
10%
1%

2017
Yahoo
Auction

1%

2018
Yahoo
Auction

23%
11%
1%

2019
Yahoo
AuctionFurnishing
Whole tusks

2020
Mobaoku

Weight of semi-processed pieces (kg)

Propotion of product type sold/listed

90

140
119.6

120
100
82.2

80
60

59.5

40
20
0

0
2017
Yahoo
Auction2018
Yahoo
Auction20192020
Yahoo Mobaoku
AuctionFigure 6. Ivory items found at internet auction: proportion for type of ivory products (left), and weight (kg)of semi-processed pieces, sold on Yahoo Auction over four-week periods before the ivory ban (2017–2019),
and listed on Mobaoku in 2020.
Survey periods and number of samples: 8th May–4th June 2017 (N = 9,810, including 22 whole tusks); 3rd–30th June 2018
(N = 4,449, including 35 whole tusks); 3rd–30th June 2019 (N = 6,263, including 19 whole tusks); 14th June–12th July 2020
(N = 852, including one whole tusk)* Yahoo Aucion: number of bidding results, Mobaoku: number of listings** On Mobaoku, the number of products checked during the four-week monitoring period and counted excluding duplicates

15 TRAFFIC REPORT: TEETERING ON THE BRINKIt is not clear why there was such an increase in tradeof hanko material and semi-processed pieces, but it
could suggest ivory manufacturers and wholesalers
selling off their stockpiles online, perhaps as demandin the retail market decline. hanko material and semiprocessed pieces are usually handled by businesses,
but according to Yahoo Auction’s bidding resultsfrom June 2019, C2C trade23 dominated, and only
about 30% of listings were by businesses. The
observed increase of these ivory materials online
followed by the voluntary ban by the platform could
suggest there is a large quantity of such stockpiles
present in the domestic market, which could be
exploited for illegal exports to overseas markets. In

Examples of hanko (and hanko material) listings on Yahoo Auction which stood out in the June 2019 survey.
Characteristically, they were listed in large quantities all at once. On the left are 76 pieces of uncarved hanko material,hanko shaped (and polished). On the right is 1,245 g of square pieces that were simply cut.

Examples of semi-processed pieces listed on Yahoo Auction during the survey in June 2019. The ones on the left
were listed by a business operator. The one on the right was listed as a C2C trade, although the listing details
suggested it could have been listed by a business.

23

Among C2C listings, there are some sellers who appear to be businesses

TRAFFIC REPORT: TEETERING ON THE BRINK

16

fact, there was an incident of attempted illegal exportthat occurred in November 2017 when 605 pieces of
hanko material were seized at the Port of Tokyo24.
The Japanese Government is urged to address theremaining domestic market effectively, including its
stockpiles in Japan.

Shrinking online markets and ongoingillegal exports
The results of the current survey recognise thesuccess of recent voluntary initiatives to eliminatemuch of the unregulated online trade from Japan’smajor platforms, which used to act as sources forillegal exports. However, illegal export from theJapanese market persists.
Data from the Elephant Trade Information System(ETIS)25 previously confirmed that a considerable
proportion (95%) of illegal ivory flowing out of Japanbetween 2011–2016, totalling 2.42 tonnes (t)26, wasbound for China (2.3 t). Furthermore, the Japanese
Government identified that 757 ivory items, weighing
about 131 kg,27 have been intercepted by its customs
authorities as illegal exports from Japan between
2011 and June 2019. While China closed its
domestic ivory market at the end of 2017, illegal ivory
continues to flow to the country. The latest analysis
of ivory seizures linked to China and four selected
Southeast Asian countries conducted by TRAFFIC
identified at least 380 cases during 2019. Of those,the most commonly reported route was Japan to
China with 36 cases, though these seizures often
had low weights (Map)28.
A survey of Chinese tourists reported that Japan
was the second popular destination for tourists
expecting to buy ivory during their travels amongst
Asian counties29. That might become a significant
concern in Japan.

Map: Trade routes identified for elephant products seizures in 2019 linked to the focal locations (China
including Hong Kong SAR, Cambodia, Vietnam, Lao PDR, and Thailand)Line are weighted by the number of cased seized along these routes. Countries which were dark gray without lines showcountries which have been identified as part of the trade chain, but for which there is no additional trade chain information.
24
25
26

27

28

29

Asahi Shimbun (2017). https://www.asahi.com/articles/ASKDL6JQRKDLUTIL06Q.htm
Elephant Trade Information System, a database of global ivory seizure data under CITES. https://www.cites.org/esp/prog/etis
TRAFFIC (2017). IVORY TOWERS: An Assessment of Japan’s Ivory Trade and Domestic Market. https://www.wwf.or.jp/activities/data/20171220_
wildlife02.pdf
House of Representatives, Japan (2019). The response paper for the Re-Interrogatories, No.254 by Yuki WASEDA, on 198th session of the Diet. http://www.
shugiin.go.jp/internet/itdb_shitsumon.nsf/html/shitsumon/b198254.htm
TRAFFIC (2019). USAID WILDLIFE ASIA COUNTER WILDLIFE TRAFFICKING DIGEST: SOUTHEAST ASIA AND CHINA, 2019. https://www.traffic.org/site/
assets/files/13112/uwa-traffic-cwt-2019-digest.pdf
WWF (2020). Beyond the Ivory Ban: Research on Chinese Travelers while Abroad. https://wwfeu.awsassets.panda.org/downloads/traveler___full_report_
final.pdf

17 TRAFFIC REPORT: TEETERING ON THE BRINKIvory items illegally exported from Japan seized by Zhanjiang Customs, Guangdong, China in June 2020 (175.6 gof scroll shaft tips, and a red coral necklace). The right photo shows the preliminary identification using the Raman
instrument. Photo credit: Zhanjiang Customs, Guangdong, China

Beyond China, there is a growing concern that illegal
ivory trade will be diverted to neighbouring Southeast
Asian countries30, especially with the closure of ivory
markets in China. This is supported by a recent case(January 2020) in Japan of a former zookeeperof Laotian nationality who was arrested at Narita
International Airport while trying to smuggle animal
parts, including African Elephant ivory, back to
Laos31. In addition, increasing demand from Chinese
tourists travelling to these neighbouring countries32
is another major focus of concern.
Given these circumstances, there is no reason forcomplacency and a need for increased vigilance
regarding illegal ivory exports from Japan to other
Asian countries. The Japanese Government needs
to recognise the continuing concern over illegal
ivory exports in the context of persistent trade in the
country’s domestic ivory market, and take urgent andeffective measures to stem the illegal trade. On thisnote, more effective implementation of the existing
memorandum of cooperation (MOC)33 signed
between the Japanese Government (METI) andChinese authorities (National Forestry and Grassland

30

31

32

33

Administration) in March 2019 to discuss CITES
issues, including ivory, is strongly recommended. The
Japanese Government is further encouraged actively
to engage in regional law enforcement co-operationin tackling illegal wildlife trade.

Persistent auction trade of ivory products
despite shrinking online markets
Apart from a slight increase in the number of listingsand sales coinciding with the ivory ban on Yahoo
Auction, the trade value at Mainichi Auction overall
remained constant. While there is little evidence fora major shift in ivory trade from online to physicalauction markets, the ongoing level of trade still
illustrates a facet of the domestic market that is
active.
Monitoring of trade at Mainichi Auction was carriedout to examine trends in the domestic market beyond
the online trade. The findings showed an apparent
increase in the number of listings and sales whencompared with the period before the ivory ban was
introduced on Yahoo Auction, with a 180% increase

TRAFFIC (2020). TRADING FACES: A Snapshot of the Online Ivory Trade in Indonesia, Thailand and Viet Nam in 2016 with an update in 2019. https://www.traffic.org/site/assets/files/12981/three-country-ivory-report.pdf
The Japan Times (2020). https://www.japantimes.co.jp/news/2020/01/14/national/crime-legal/laotian-arrested-japan-allegedly-trying-export-ivory-takenzoo/#.Xh5fhcj7QdU%2031
WWF (2020). Beyond the Ivory Ban: Research on Chinese Travelers while Abroad. https://wwfeu.awsassets.panda.org/downloads/traveler___full_report_
final.pdf
METI (2019). https://www.meti.go.jp/press/2018/03/20190320005/20190320005.html

TRAFFIC REPORT: TEETERING ON THE BRINK

18

300

No. of products
listedNo. of products
12.4
sold

(USD115K)

250

No. of products

Of the different types of products sold in recent
listings, many were hankos (or hanko material), as
well as an increasing number of products other thanfurnishings (ornamental objects or netsukes) whichhave been the most common items traded so far.
Trade of whole tusks has also remained constant,
without significant change in the number of sales

14
10.1(USD94K)

12.5(USD116K)

200

16

13.9
(USD129K)

10.7(USD100K)

150

Total value sold

12
10

9.6
(USD89K)

8
6

100

4
50

Total value sold (Milliion JPY)

from an average of 127 to 228 items (Figure 7).
However, the value of total sales remained stable,
and the margin of increase in the number of productlistings and sales were also still minor compared to
the volume that used to be traded on Yahoo Auction(e.g. 6,244 items sold over four weeks in July 2019).

2

0

Feb 2019

May 2019

Aug 2019

Nov 2019

Feb 2020

Jun 2020

0Nov. 2019, ivory trade banned on Yahoo Japan

Figure 7. Trends in total sales and total number of ivory products, including whole tusks, at Mainichi Auction(February 2019 to June 2020)
250
July 2019, registration of whole tusks tightened

No. of products sold200

OthersHanko
150

Jewelley

100
Furnishing50

0

Whole tusks
Feb 2019 May 2019 Aug 2019 Nov 2019 Feb 2020 Jun 2020
Nov. 2019, ivory trade banned on Yahoo Japan

Figure 8. Trends in types of products sold at Mainichi Auction (February 2019 to June 2020)

19 TRAFFIC REPORT: TEETERING ON THE BRINKbeing auctioned (Figure 8). In July 2019 the MOE
made an announcement that the government had“tightened the registration requirements for wholetusks—In principle, domestic trade of whole tusks
is prohibited”34. However, as observed in the current
assessment of Mainichi Auction, this measure has
not led to a substantial reduction in transactionsof whole tusks. This is because the measure
only restricts the new registration of previously
unregistered tusks through an added burden of proofof legal origin, whereas the regulation governing34
35

domestic trade remains unchanged under the law(LCES).
Previous research by TRAFFIC35 identified
widespread leakage of ivory items, including wholetusks, from many of the domestic trade platforms
into smuggling routes to other Asian countries. It is
hard to say that the new set of regulations has led tosuccessfully controlling the domestic market, given
the current situation of continued illegal exports fromJapan.

MOE (2020). http://www.env.go.jp/press/106580.html
TRAFFIC (2017). IVORY TOWERS: An Assessment of Japan’s Ivory Trade and Domestic Market. https://www.wwf.or.jp/activities/data/20171220_
wildlife02.pdf

TRAFFIC REPORT: TEETERING ON THE BRINK

20

CONCLUSIONS andRECOMMENDATIONS
21 TRAFFIC REPORT: TEETERING ON THE BRINKCONCLUSIONS andRECOMMENDATIONS
One adverse consequence of an unregulated market
for ivory products online is the proliferation ofdomestically traded ivory that can enter smuggling
channels to Asian market. However, the current
study does indicate that voluntary approaches bycompanies to ban ivory trade on their platforms havesucceeded in considerably reducing instances of
unregulated ivory trade. This clearly demonstrates
the value of voluntary ivory bans that go further
than legal regulatory requirements—commendable
actions by companies that have implemented sucha ban. As for platforms that still allow ivory trade,following the example set by their peers in instituting
a platform-wide ivory trade ban is encouraged.
The proliferation of illegal ivory trade online isemblematic of wider issues of the broader online
wildlife trade. Internationally, leading companies
from e-commerce, social media and technology
businesses have pledged to reduce illegal wildlife
trade online, collaborating with WWF, TRAFFIC, and
IFAW to launch the Coalition to End Wildlife Trafficking
Online36 in March 2018. As of October 2020, there
were 36 participating companies (Rakuten joined inAugust 2018). They have adopted a common policyof banning trade in wildlife and its products whereinternational trade is prohibited, in line with CITES
designation, including ivory. In view of the expected
increase in the use of online channels in a post-COVID
environment, it is hoped that Japanese companies
play a bigger role in reducing illegal wildlife trade
online, including raising of awareness among theirusers and consumers.

addressed. This includes the ongoing ivory tradeby auction houses, trade within closed groups andprivate posts on SNS, as well as the trade of raw
materials and newly manufactured products at
physical markets, which could not be observed
directly in this survey due to COVID restrictions. In
terms of the physical market, decisions by major retailbusinesses to cease selling ivory are also driving acontraction in ivory availability, especially that of ivory
hanko. AEON Mall Co., Ltd., Japan’s largest retailer,
completely banned ivory product sales by its tenants
at the end of March 2020, while Seven & i Holdings
Co., Ltd., parent company of Ito-Yokado and others,
had done the same around five years ago. In addition,
there are signs that the Japanese custom of using
hanko, for which ivory is valued as the highest-grade
material, is changing, as exemplified by the revisionof the Digital Procedure Law.
In addition to corporate efforts, the TMG establishedits Advisory Council on Regulating Ivory Trade inJanuary 2020, through which the City commits toaddressing the ivory trade as a global issue andits responsibility as an international city. While theCouncil’s activities have been adjusted due to the
COVID-19 pandemic, its focus is to prevent foreign
tourists from taking ivory abroad, especially with the
expected influx of travellers during the Tokyo Olympic
and Paralympic Games. The Advisory Council further
aims to consider whether additional measures forregulating ivory trade are needed in Tokyo.

While the current study has observed a decline in

While companies and local governments have taken
stringent measures within their own jurisdiction thatgo further than national laws and regulations, there

Japan’s ivory trade online, issues remain in otherchannels of domestic trade that market to be

has been a conspicuous delay in the response by thecentral government. Above all, given the continued

36

https://www.endwildlifetraffickingonline.org/about

TRAFFIC REPORT: TEETERING ON THE BRINK

22

illegal export from Japan to China and othercountries, the existing system of regulation appears
vastly inadequate in preventing and controlling thetrafficking of ivory out of Japan. It is clear that specificmeasures are needed urgently, in accordance withthe requirements under CITES Resolution 10.10 (Rev.
CoP18).

In January 201837 and May 201938, WWF and TRAFFIC
requested the Japanese Government urgently toconsider a policy to close the domestic market in
Japan, with narrow exemptions. Reiterating previous
suggestions, TRAFFIC recommends the following for
the Japanese Government:

THE GOVERNMENT OF JAPAN SHOULD:
Develop an action plan toward market closure in Japan with narrow exemptions in time for the
Tokyo Olympics/Paralympics. The action plans should include time-bound, actions involving all
relevant actors and at level that demonstrates a serious national commitment;
Officially declare the above policy move to fulfil its responsibility to the international community,
especially in light of the continued illegal flows from its domestic market.
In addition, the relevant government offices, e-commerce companies and other Internet-related companies
should immediately consider the following specific measures.

THE MINISTRY OF THE ENVIRONMENT (MOE) AND MINISTRY OF
ECONOMY, TRADE AND INDUSTRY (METI) SHOULD:
Immediately start to review the scope of products falling under narrow, tightly-controlled exemptions
that can be legally traded (including phasing out use of ivory hanko);
Establish mandatory and effective mechanisms (e.g. certification and traceability systems for all
products) to ensure legality and traceability before a legal framework is established for the narrow
range of exemptions;
Take more active measures to enhance compliance by businesses, including in online trade;
Help to strengthen the monitoring and implementation efforts of companies such as by promoting
technological innovation, including identification training and financial support;
Co-operate with Japan Customs and law enforcement authorities of other Asian countries (including
through the existing MOC with China) effectively to prevent and bring to justice any offences relating
to illegal export of ivory items from the Japanese domestic market.

RECOMMENDATIONS TO E-COMMERCE COMPANIESCompanies that have introduced a platform-wide ban on ivory trade should ensure policy compliancethrough stricter monitoring and awareness raising to their uses/consumers; online platforms thatstill allow ivory trade should introduce similar voluntary ivory bans as a matter of urgency.

37
38

https://www.wwf.or.jp/activities/activity/152.html
https://www.wwf.or.jp/activities/statement/3954.html

23 TRAFFIC REPORT: TEETERING ON THE BRINKSNS (closed groups and private posts) and other internet platforms, for which the state of ivory
trade remains unknown, should recognise the potential risks and take proactive measures tomonitor and eliminate ivory trade through co-operation with NGOs and enforcement agencies;
E-commerce companies and other Internet-related companies should work together to strengthen
monitoring and enforcement through initiatives such as formulation of industry policies andguidelines for the eradication of illegal wildlife trade and participation in international initiatives(such as the Coalition to End Wildlife Trafficking Online).

IMAGE CREDITS
Page

CreditCover

African Elephant, Moremi Game Reserve, Botswana. ©Martin Harvey/WWFi

African Elephant, South Africa. ©Martin Harvey/WWF

1

African Elephant, South Africa. ©Martin Harvey/WWF

4

Ivory confiscated by Ministry of Forests and Wildlife, Cameroon. ©WWF/Mike Goldwater

7

Elephant ivory bracelets seized by Border Force, Heathrow Airport, UK. ©WWF-UK/James Morgan

21

African Elephant. ©Martin Harvey/WWF

TRAFFIC REPORT: TEETERING ON THE BRINK24

DECEMBER 2020

TRAFFIC is a leading non-governmental organisation
working globally on trade in wild animals and plants
in the context of both biodiversity conservation andsustainable development.
For further information contact:
TRAFFIC
Global OfficeDavid Attenborough Building
Pembroke Street
Cambridge CB2 3QZ
UK+44 (0)1223 277427
traffic@traffic.org
traffic.org
UK Registered Charity No. 1076722,
Registered Limited Company No. 3785518.

TRAFFIC is grateful to the Rufford Foundation for theirfinancial support towards the production of this report

25 TRAFFIC REPORT: TEETERING ON THE BRINK