TRAFFIC A RAPID SURVEY OF UK IVORYr e p o r t

AUGUST 2016

MARKETSLau, W., Crook, V., Musing, L., Guan, J. and Xu, L.

TRAFFIC REPORTTRAFFIC, the wildlife trade monitoring
network, is the leading non-governmentalorganization working globally on trade inwild animals and plants in the context of bothbiodiversity conservation and sustainable
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Suggested citation:Lau, W., Crook, V., Musing, L., Guan, J. and
Xu, L. (2016) A rapid survey of UK ivory
markets. TRAFFIC, Cambridge, UK.
This is the original English version of A
rapid survey of UK ivory markets. A Chinesetranslation is also available.
Design:ADB Design Studio, Beijing
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Front cover photograph and credit:
Ivory items for sale in London antiquesmarkets ©TRAFFICA RAPID SURVEY OF UK
IVORY MARKETS© TRAFFIC

Lau, W., Crook, V., Musing, L., Guan, J. and Xu, L.

TA B L E O F C ON T E N T S

Acknowledgementsvi

Executive summaryvii

Introduction

1

Legislation controlling commercial ivory trade in the EU and UK

4

Methods

6

Physical market surveys

6

Online surveys

10

CITES trade data

11

Seizure data

12

Results

14

Physical market survey results

14

Individual market/area results

14

Product types and prices

17

Additional information on the UK ivory market collectedfrom traders

18

Online survey findings

20

Number of ivory items for sale online

20

Product types

21

Prices21
TRAFFIC report: A rapid survey of UK ivory markets iii

Declarations concerning age, provenance and legality
CITES trade in ivory: re-exports and imports

22
24

Re-export of ivory from the UK

24

Import of ivory into the UK

25

EU and UK re-exports and imports of ivory

26

Discrepancies in UK trade according to importer andexporter data27

UK ivory seizures

29

Discussion and conclusions

31

Recommendations

34

References

35

Appendix 1. Number of outlets and ivory items per outlet

37

Appendix 2. Quantities and prices by type of ivory items

39

Appendix 3. Survey results of antique auctions websites

41

Appendix 4. Survey results of online antique marketplaces

42

iv TRAFFIC report: A rapid survey of UK ivory markets

ABBREVIATIONS AND ACRONYMS
CITESConvention on International Trade in Endangered Speciesof Wild Fauna and Flora

COTES

Control of Trade in Endangered Species (Enforcement)
Regulations

Defra

Department for Environment, Food and Rural Affairs

ETIS

Elephant Trade Information System

EU

European Union

EU-TWIX

European Union – Trade in Wildlife Information eXchange

GBP

British PoundRIE

Raw Ivory Equivalents

UK

United Kingdom

UK CITES MA

CITES Management Authority of the United Kingdom

USA

United States of America

TRAFFIC report: A rapid survey of UK ivory markets v

ACKNOWLEDGEMENTS
The authors thank TRAFFIC colleagues, especially Katalin Kecse-Nagy, Sabri Zain, Stephanie Pendry,
Rachel Kramer, Tom Milliken, Yannick Kuehl, Steven Broad, Richard Thomas and Julie Gray for theongoing support provided and for their reviews. The authors also thank Wang Haibin and Shi Kunfor external expert reviews and several staff from the UK CITES Management and Enforcement
authorities for information provided on legislation, online surveys of wildlife trade and current
enforcement measures in place.
China CITES Management Authority is gratefully thanked for financial support of this study andthe Rufford Foundation is gratefully acknowledged for its contribution towards the final stages of
production of this report.

vi TRAFFIC report: A rapid survey of UK ivory markets

EXECUTIVE SUMMARY
The African Elephant Loxodonta africana and Asian Elephant Elephas maximus have been listed in the
Appendices of the Convention on International Trade in Endangered Species of Wild Fauna and Flora(CITES) since 1976 and 1975, respectively. Commercial international trade in ivory is generally not
permitted, however in accordance with CITES and European Union (EU) regulations, commercial
trade of antique ivory (“worked ” specimens acquired before 3rd March 1947) and “raw ” or “worked”
pre-Convention ivory is possible under certain prescribed conditions.
1

2

3

Despite international control measures, legal trade in (antique) ivory, as well as elephant poaching andillegal ivory trade, have been rising in the past decade, with the most significant increases observed
from 2007 onwards. This has led to calls for countries to implement stricter domestic measures going
beyond the requirements of CITES, and to take additional deterrent actions to address illegal ivory
trade. Much of the focus around recent elephant poaching and illegal ivory trade has been on African
range States and Asian consumer markets, however, there have been indications that changes are also
occurring in European markets. In 2014, a study on ivory trade in the EU found that legal commercial
re-exports of pre-Convention ivory products, and re-exports of both worked and raw ivory from theEU, have increased in recent years, particularly since 2007.
Historically, the United Kingdom (UK) had one of the largest ivory markets in the world. The
popularity of ivory products peaked in the 19th and early 20th century, with annual ivory imports
of up to 500 tonnes between 1910 and 1914. Much of the imported ivory was made into decorative
items and household and personal objects. These ivory items are now considered antiques, and in
2004, when the UK ivory market was last surveyed by Martin and Stiles (2005), large quantities ofivory antiques were being offered for sale. Despite evidence confirming the considerable availabilityof ivory in the UK market in 2004, there is a lack of information regarding the current status of themarket and therefore the potential link with the surge in both legal and illegal global ivory trade inrecent years.
This report presents a rapid assessment of the current commercial UK ivory market, with a focus
on the antiques sector. Using the survey by Martin and Stiles as a comparative baseline, physicalmarkets and selected shops in London where ivory was found in 2004 were revisited and surveyed.
Online offers for sale on UK-based antique and auction websites were also researched, to complement
the physical market survey results. In addition, CITES trade data on import and re-export of ivory
from the UK/EU during 2005 and 2014, and reports of ivory seizures involving the UK from the
Elephant Trade Information System (ETIS) and EU-TWIX were briefly analysed to provide context
with regards to the UK’s current role in international ivory trade. Furthermore, available literatureand guidance on relevant legislation, together with information collected from consultation with UK
CITES authorities, was reviewed.
4

Physical and online market surveys in April 2016 confirmed the ongoing availability of antique ivory
in the UK market. No new or raw (“unworked”) ivory was seen in any of the physical market outlets
or online platforms—only one ivory item seen for sale was reportedly from after the legal cut-off(1947) for antique ivory being sold without CITES documentation within the EU. Antique ivory
items were available across all 13 antiques markets and in the two areas of antiques shops surveyed. A
wide range of ivory items were being offered for sale including figures (56%), household goods (27%),
jewellery (9%) and personal items (8%); similar ivory items were found for sale/auction online.

“Worked ivory” includes items defined as carvings in the CITES Trade Database.
“Raw ivory” includes items defined as tusks, ivory pieces and ivory scraps in the CITES Trade Database.
3
Items acquired before the date on which CITES or the EU Wildlife Trade Regulations became applicable to them in the country in which they were acquired.
4
European Union – Trade in Wildlife Information eXchange—the system includes a database of CITES seizures in the EU (http://eu-twix.org/)
1
2

TRAFFIC report: A rapid survey of UK ivory markets vii

Compared to 2004, fewer individual market stalls in London were offering ivory for sale in 2016,
declining, from ~640 stalls in 2004 to 200 in 2016. The total number of ivory items for sale had
also declined, from ~6,000 items in 2004 to 3,200 in 2016. It is important to note that the surveys
conducted in 2004 and 2016 were not identical due to various unavoidable factors, and comparisonsmust be made with caution. Although the reasons behind the apparent decline in the number of ivory
items being offered for sale in London’s physical antiques markets between the 2004 and 2016 surveys
are unknown, possibilities could include the emergence of online sales and/or stricter legislation
which, according to traders, has led to reduced prices and demand for ivory items.
In 2004, buyers of ivory antiques at London’s physical markets were dominated by American andEuropean tourists, but in 2016 traders reported that travellers/citizens from East Asian countries/
territories (including mainland China, Japan and Hong Kong) are increasingly purchasing ivory in
the UK. According to ivory dealers, the craftsmanship, style of carving and the era and/or provenanceof antiquity were considered the primary indicators of quality and value in the UK’s antiques products,
rather than the material the item was composed of. Correspondingly, there was little difference inprice between products made with ivory or other materials.
Traders had a variable understanding of what constitutes legal sale and trade of ivory, howeverawareness of a specific cut-off date for the legal commercial use of antique ivory in the UK/EU was
unanimous. Many traders were aware of the existence of trade controls in other countries, such as
stricter rules in the United States of America (USA) and mainland China for importing ivory. Highend dealers were generally very knowledgeable regarding the national and international legislationand specific requirements for trade pertaining to ivory, however casual/opportunistic traders were lessknowledgeable and took a more fluid stance on the need for documentation. Several dealers suggested
transporting ivory items in personal luggage or sending them by post, without any documentation.
Few dealers were able to provide proof of age or documentation to prove legal acquisition, althoughsome of the antiques websites surveyed require the approximate date of manufacture to be provided
for each ivory product advertised.
According to CITES exporter data, the UK was a net (re-)exporter of ivory for commercial purposesover the last decade: 990 kg and ~54,000 specimens of ivory were re-exported for commercial purposes
between 2005 and 2014. In total, the UK’s re-exports of commercial ivory made up 31% of the total
EU re-exports during this period. The majority of commercial trade reported by the UK for 2005–2014 was in worked ivory (carvings), with only 2% involving raw ivory. However, importers reported
a much higher number of raw ivory items in trade from the UK (for example, 109 tusks reported byimporters versus 17 tusks reported by the UK); according to stricter UK domestic measures, only
worked specimens (antique or pre-Convention) can be legally re-exported for commercial purposes,
and therefore it would be essential to clarify the reasons for these discrepancies.
Seizure data also show that the UK plays a role in illegal ivory trade, at both import and re-export,
but in particular as a transit country, with ivory seizures reported by the UK having increased inrecent years. Although the physical and online market surveys carried out for this study did not
find any new ivory for sale or clear indications of illegal activity, a number of traders and buyers
indicated their knowledge/intention of taking antique ivory items out of the EU without the necessary
documentation, and hence illegally. Lack of awareness and/or clarity over the UK’s and destination
countries’ regulations on ivory trade and the specifics surrounding the antiques (pre-1947) derogation
under the EU Wildlife Trade Regulations, appear to play a major role in this.

viii TRAFFIC report: A rapid survey of UK ivory markets

The report concludes with a number of recommendations:
The UK CITES Management and Enforcement authorities are encouraged to:• Compile simple information/guidance on the current and planned/upcoming legislation anddocumentation requirements, definitions/examples of “worked” antique specimens, burden of
proof and best practice related to commercial antique ivory use and trade in the UK, and specificdomestic measures in important previous/current destinations for antique ivory sourced in theUK, such as the USA and China• Share this information/guidance via the UK CITES MA website in addition to information sources
regularly used by antique dealers and auction houses, such as the Antiques Trade Gazette• Raise awareness of tourists, in collaboration with CITES authorities in destination countries/
territories, regarding rules for purchasing ivory in the UK and its transportation across borders,through tour operators and airlines and targeted signage in relevant airport terminals• Explore the possibility of making declarations regarding the age and acquisition of all ivory items,
both on websites and in physical stalls/shops, mandatory in the UK• Continue to target ivory-related Customs inspections on shipments in postal and courier services
destined for East Asia and luggage of those travelling to the region, and consider extending thistargeting to other previously important destinations for ivory sourced in the UK, such as the USA• Research and clarify the discrepancies between importer/exporter-reported CITES trade of ivory(raw ivory in particular) from the UK over the last decade

The UK CITES Management and Enforcement authorities, in collaboration with authorities
in other EU Member States and other experts such as university researchers and nongovernmental organizations, are encouraged to:• Fund and plan regular, systematic and comprehensive market monitoring of all types of ivory on
offer for sale, including antique, pre-Convention and new, both in the UK and other EU Member
States• Continue to monitor online sales of ivory in the UK and carry out an assessment of the ivory tradeon social media platforms in the UK and the EU to determine if trade in ivory is prevalent on theseplatforms• Strengthen co-operation with e-commerce companies to research and develop innovative ways toprevent illegal online trade in ivory and other endangered species in the future.

TRAFFIC report: A rapid survey of UK ivory markets ix

INTRODUCTION
Wildlife crime has become one of the largest and most profitable transnational organizedcriminal activities in recent years, and represents a significant threat to the Earth’s biodiversity(Milliken et al., 2012; European Commission, 2016a). National and international awareness of
the widespread impacts of wildlife crime have evolved rapidly over recent years, in particularfor iconic and keystone species such as elephants (Sollund and Maher, 2015; European
Commission, 2016a). Both the African Elephant Loxodonta africana and the Asian Elephant
Elephas maximus have been subject to poaching for their ivory to meet demand for national
and international trade causing major population declines across their ranges (Blanc, 2008;
Choudhury et al. 2008; CITES, 2015). Poaching and illicit trade in elephant ivory havereached their highest levels since the mid-1990s, with particular increases seen since 2007,
which have generally been attributed to growing demand in Asian markets (Milliken et al.,2012; UNEP et al., 2013).
5

The African Elephant has been listed in Appendix II of the Convention on International
Trade in Endangered Species of Wild Fauna and Flora (CITES) since 1977. The species wastransferred from Appendix II to Appendix I in 1989, however, some populations were downlisted to Appendix II, under a set of conditions, in 1997 (Botswana, Namibia and Zimbabwe)and 2000 (South Africa) (UNEP et al., 2013). The Asian Elephant has been listed in CITES
Appendix I since 1976. This means that, in general, commercial international trade in ivory
is not possible. In line with CITES, trade in ivory is strictly regulated within the single marketof the European Union (EU) through provisions of the EU Wildlife Trade Regulations which
are directly applicable to trade to, from and within all EU Member States, including theUnited Kingdom (UK) . According to the relevant EU regulations, commercial trade in ivory
is permitted under prescribed conditions for antique ivory (“worked ” specimens acquired
before 3rd March 1947) and pre-Convention ivory (“raw ” or “worked” items acquired before
the date on which CITES or the EU Wildlife Trade Regulations became applicable in the
country in which they were acquired).
6

7

8

9

In response to a recent surge in illegal ivory trade, several countries have implemented
stricter domestic measures, going further than the requirements of CITES. For example, on
26th February 2015, China imposed a one year ban on the import of African Elephant ivory
carvings (not including pre-Convention items) and on 15th October another one year ban
on the import of African Elephant tusk hunting trophies. Even stricter controls were brought
in on 20th March 2016 (State Forestry Administration Bulletin No. 3, 2016), when China
suspended the import of elephant tusks and ivory carvings (including pre-Convention tusks
and other ivory products, and tusks obtained in Africa as hunting trophies) from 20th March
2016 to 31st December 2019 (CITES, 2016). On 2nd June 2016, the United States of America(USA) adopted new regulations on domestic trade in ivory under which commercial exports
and sales of ivory between US States are only allowed for proven antiques more than 100
All references to the term “ivory” in this report refer to elephant ivory, unless otherwise specified.
At the time of conducting the survey, the UK was a member of the EU and all research was conducted before the 23rd June 2016 referendum on EU
membership in the UK. The fact that the UK voted to leave the EU could have implications on the current legislation controlling trade in ivory andfuture ivory markets, however this was not considered in more detail here due to the many unknowns at present.
7“Worked ivory” includes items defined as carvings in the CITES Trade Database, see legislation section for full definition.
8
Items acquired before the date on which CITES or the EU Wildlife Trade Regulations became applicable to them in the country in which they wereacquired.
9“Raw ivory” includes items defined as tusks, ivory pieces and ivory scraps in the CITES Trade Database.
5
6

TRAFFIC report: A rapid survey of UK ivory markets 1

years old (USFWS, 2016). US regulations preventing commercial imports of ivory and tradein raw ivory were already in place (USFWS, 2016). In June 2016, the Hong Kong Government
proposed plans to phase out domestic ivory trade within a five-year period, as well as bans on
the import and re-export of pre-Convention ivory into the territory (Environment Bureau/
AFCD, 2016).
Several EU Member States including France and Germany have adopted stricter measuresin relation to ivory trade and no longer issue re-export certificates for pre-Convention raw
ivory. In February 2016, the EU published the EU Action Plan against Wildlife Trafficking,which provides a comprehensive framework for joined-up efforts to fight wildlife crime
inside the EU, and for strengthening the EU’s role in the global fight against illegal wildlife
trade (European Commission, 2016b). Action 2 of the EU Action Plan “Further limit tradein ivory within and from the EU” aims to ensure that “Member States do not issue export
and re-export documents for raw pre-Convention ivory” (European Commission, 2016b) by
the end of 2016 through the issuance of Commission guidelines. The guidelines also aim toprovide well defined criteria to regulate intra-EU trade in antique ivory further.
Research on and discussions around recent elephant poaching and illegal ivory trade havefocused mainly on African range States and Asian consumer markets, with little attention paid
to European countries. However, there have been indications that changes are also occurringin European markets. Legal commercial exports of pre-Convention ivory products from theEU have shown an increase in recent years, especially since 2007, based on numbers of traderecords in the CITES trade database during the period 2003 to 2012 (Mundy, 2014). Increases
in re-exports of both worked ivory (carvings) and raw ivory (tusks, ivory pieces, ivory scraps)
from the EU have been observed, with re-exports of tusks showing a particularly pronounced
upward trend after 2007 (Mundy, 2014). Of note is the fact that mainland China and Hong
Kong were reported as the main destinations of pre-Convention/antique ivory in recent years
since 2007 (Mundy, 2014).
The Elephant Trade Information System (ETIS) analyses carried out for CITES Conferenceof the Parties (CoP) include a “cluster analysis” which identifies those countries or territories
most prominently implicated in illegal trade in ivory. In the cluster analysis, data are prescreened to separate out those countries only marginally implicated in ivory seizures, whileother countries or territories which show similar patterns in terms of their seizure data aregrouped together. The characteristics of these groupings are then described to understandunderlying trade dynamics and factors, including effective law enforcement. The UK hasfeatured in six successive cluster analyses since the first such analysis was carried out in 2002,
suggesting that the UK has consistently played a role in illegal ivory trade globally (CITES
Secretariat, 2013).
10

The UK historically had one of the largest elephant ivory markets in the world. Ivory carving
in the UK commenced in the 10th century (Woodhouse, 1976) and ivory was in widespreaduse in religious and decorative art from the 11th century onwards (Williamson, 2011). The

10

ETIS is one of the two formal monitoring systems for elephants under CITES; ETIS, which is managed by TRAFFIC, is a comprehensive information
system to track illegal trade in ivory and other elephant products (https://cites.org/eng/prog/etis/index.php)

2 TRAFFIC report: A rapid survey of UK ivory markets

production and use of ivory in the UK reached a peak between 1800 and 1914 (after which
there has been a steady ongoing decline), with ivory imports into the UK quadrupling froman average of 112 tonnes a year from 1814 to 1820 to 496 tonnes annually from 1910 to 1914
(Martin, 2001). During this period, in addition to more traditional decorative uses, ivory
was increasingly chosen as a medium for utilitarian household and personal objects such asbrush, cutlery and walking stick handles, tea caddies, paper knives, rulers, boxes, piano keys
and jewellery (Martin and Stiles, 2005).
In 2004, Martin and Stiles (2005) carried out a comprehensive market survey of European
ivory markets, including the UK. This was the fourth in a series of surveys depicting thestatus of and trends within elephant ivory markets in different regions of the world: Africa(Martin and Stiles, 2000), South and Southeast Asia (Martin and Stiles, 2002) and East Asia
(Martin and Stiles, 2003). Martin and Stiles (2005) noted their surprise at the large scale ofboth the German and UK ivory markets in 2004, and that these exceeded/were close to thoseof many Asian and African countries, such as China, Japan, South African, Cameroon and
Nigeria: in 2004, the UK had the greatest number of outlets openly selling ivory productsin the world, and ranked ninth in the number of items available. However, it was also notedthat the primary difference between the European and Asian/African markets was that thegreat proportion of the European ivory could be considered antique (pre-1947) or had been
crafted from registered raw ivory stocks acquired prior to 1989, and therefore, in principle
were legal (though many items may have lacked the required documentation). Much of theivory found openly for sale in Asian and African countries, on the other hand, had beenacquired and crafted more recently and was potentially illegal (Martin and Stiles, 2005).
Despite evidence confirming the considerable availability of ivory in the UK market in 2004,
there is a lack of information regarding the current status of the market and therefore thepotential link between the surge in both legal and illegal global ivory trade and the UK ivory
market in recent years. Using the survey undertaken in 2004 as a comparative baseline, this
rapid assessment aimed to examine the size and composition of the current commercial UK
ivory market for domestic and international use. It focused on the antiques sector, which
was identified by Martin and Stiles (2005) as the main source of ivory for sale in the UK, andspecifically sought to address the following:1) The current size and market for ivory in the UK (based on surveys of the principal
antiques markets identified by Martin and Stiles, 2005);
2) The awareness and compliance of UK traders with current CITES and EU Wildlife
Trade Regulations;3) The principal buyers/destinations for antique ivory purchased in the UK; and
4) Changes in the UK ivory market since 2004.

TRAFFIC report: A rapid survey of UK ivory markets 3

LEGISLATION CONTROLLING COMMERCIAL IVORY
TRADE IN THE EU AND UK
The information presented in this section is based on various sources, including the text of the EU
Wildlife Trade Regulations, TRAFFIC’s insights and European Union (EU)/European Commission
guidance on interpretation of these regulations (including the Reference Guide ), a legal analysis
carried out by DLA Piper UK LLP (2016) and consultation with UK CITES authorities. It is important
to note that at the time of writing this report a referendum on EU membership was held (on 23rd June2016) and the UK voted to leave the EU. This could result in future changes to the current legislation
controlling trade in ivory.
11

Trade in elephant ivory is strictly regulated in the EU through the provisions of the EU Wildlife Trade
Regulations (which implement CITES in the EU), and specifically Council Regulation (EC) No. 338/97
and Commission Regulation 865/2006 . As a general rule, ivory cannot be traded within, to or fromthe EU for commercial purposes. However, intra-EU trade, and re-export of ivory for commercial
purposes are permitted under prescribed conditions. Under EU Regulations, the following exceptions
and cut-off dates would be applicable to the UK:1213• intra-EU trade is authorized for antique ivory (“worked” specimens acquired before 3rd March
1947) and pre-Convention ivory (items imported into the EU before elephant species were listed
in Appendix I of CITES (18th January 1990 for African Elephant and 1st July 1975 for Asian
Elephants)); pursuant to Article 8(3)(a) of Council Regulation (EC) No. 338/97• Re-export is authorized for antique ivory (“worked” specimens acquired before 3rd March 1947)and pre-Convention ivory (specimens acquired before the date on which CITES became applicableto them, i.e. 26th February 1976 for African Elephants and 1st July 1975 for Asian Elephants );pursuant to Article 5(6)(ii) of Council Regulation (EC) No. 338/97.
14

As per the exceptions described above, intra-EU commercial trade in antique ivory (officiallydescribed as “worked specimens” and falling under the “antiques derogation” in Article 62(3) of
Commission Regulation 865/2006) can occur without internal EU trade certificates (often referred toas Article 10 certificates) being issued by the CITES Management Authority (MA). Traders offering
an antique ivory specimen for sale should, however, be able to justify/have some form of proof (which
can include expert opinion) that the specimen falls under the derogation and may be required toprovide this proof when requested by authorities.
Re-exports of antiques from the EU, or intra-EU trade and re-exports of pre-Convention ivory, mustbe accompanied by the relevant certificates/permits issued by CITES MAs. In the case of intra-EU
trade, the responsibility for acquiring an Article 10 certificate falls to the seller, prior to offering an
item for sale. Both a re-export certificate and an import permit (from the country of destination) areneeded for re-exports from the EU. The responsibility for acquiring certificates/permits is a) with thebuyer if they are purchasing the item in-country and taking it to their country of residence or b) withthe seller if they are shipping this abroad as part of the sale.
Worked specimens are defined in Article 2w of Council Regulation (EC) No. 338/97 as specimensthat were removed from the wild and significantly altered from their natural raw state for jewellery,adornment, art, utility or musical instruments, more than 50 years before the entry into force of theEuropean Commission and TRAFFIC (2015). Reference Guide to the European Union Wildlife Trade Regulations. Brussels, Belgium.
Council Regulation (EC) No 338/97 on the protection of species of wild fauna and flora by regulating trade therein – the “Basic Regulation”.
13
Commission Regulation (EC) No 865/2006 (as amended by Commission Regulation (EC) No 100/2008, Commission Regulation (EU) No 791/2012
and Commission Implementing Regulation (EU) No 792/2012) laying down detailed rules concerning the implementation of Council Regulation(EC) No 338/97 – the“Implementing Regulation”.
14
The CITES Convention applied from 26th February 1976 to African Elephants with the listing of the species in Appendix III by Ghana; Asian
Elephants were listed in CITES Appendix I on 1st July 1975.
11

12

4 TRAFFIC report: A rapid survey of UK ivory markets

Regulation, i.e. before 3rd March 1947. Such specimens are considered worked only if they fall clearly
into one of the aforementioned categories and require no further carving, crafting or manufacture
to affect their purpose. Antiques acquired before 1947, but that remain substantially unaltered fromtheir natural state (i.e. whole uncarved tusks), do not qualify.
There have been a number of complications with applying this definition in practice, and consequently
the EU developed internal guidance on this topic. This is based on the collective interpretation acrossall Member States on what may or may not qualify as “worked specimens” and when the generalderogation from the need to get a certificate for commercial use for intra-EU trade applies. There
are plans to release a public version of this guidance in the near future to facilitate appropriate use of
the derogation by traders. This will cover aspects such as acceptable proof that the item was acquired
prior to 3rd March 1947; typical examples of items falling under the definition “significantly alteredfrom their natural raw state” and the categories of “jewellery”, “adornment” etc.; and the renovation
and “re-working” of specimens.
Pre-Convention ivory is generally divided into two different types: “worked” and “raw” (or unworked).
In this case the term “worked” is being used to describe specimens that have been modified to convert
them into an item of jewellery, musical instrument etc., however this may have occurred after 1947,
and therefore these specimens would not fall under the antiques derogation. Raw or unworked
specimens are those that are not considered significantly altered from their natural state, such as
whole uncarved ivory tusks, or small uncarved ivory pieces.
In the UK, the Control of Trade in Endangered Species (Enforcement) Regulations (COTES) enables
the EU Wildlife Trade Regulations to be enforced within the UK. In addition to these regulations,the UK has stricter domestic measures regarding trade in certain species. The UK only allows thecommercial use of “worked” ivory specimens (either antiques or pre-Convention items). In somecircumstances the UK Management Authority (MA) may also allow non-commercial use of unworked pre-Convention items (including ivory pieces or tusks), such as for cultural exchange between
museums.
15

Authorized/unauthorized commercial use/offers for sale of ivory in the UK, and any consequent
movement to/use in another EU Member State, is summarized below. In all cases, any movement ofivory (whether considered antique or not) out of the EU must be accompanied by CITES re-export
certificates and import permits.
Authorized:• Pre-1947 worked ivory specimens with some form of proof that this item fulfils the antiques
derogation, but without an Article 10 certificate• Worked African Elephant ivory specimens acquired prior to 1990 and worked Asian Elephantivory specimens acquired prior to 1975 with an Article 10 certificate
Unauthorized:• Pre-1947 worked ivory specimens without any form of proof that this item fulfils the derogation• Worked African Elephant ivory specimens acquired prior to 1990 and worked Asian Elephantivory specimens acquired prior to 1975 without an Article 10 certificate• Post-1975 worked Asian Elephant ivory specimens and post-1990 worked African Elephantivory specimens, and all un-worked ivory specimens, under any circumstances
15

COTES Regulations came into effect in 1997, and have been amended in 2005, 2007 and 2009 and are currently under review.

TRAFFIC report: A rapid survey of UK ivory markets 5

METHODS
A rapid assessment of the UK’s domestic ivory market carried out in April 2016 involved surveys of:• Physical antique markets/shops in London, revisiting most of the markets surveyed in 2004 by
Martin and Stiles (2005), and• Online offers for sale on UK-based antiques and auction websites, to complement the results
obtained during the physical market survey.
In addition, the UK’s current role in international trade in ivory, and the legal basis for UK ivory
trade, was briefly reviewed through:• Analysis of CITES trade data on import and re-export of ivory from the UK during 2005–2014;16• Reports of ivory seizures involving the UK, based on ETIS and EU-TWIX data records;• Available literature/guidance on relevant legislation and contact with UK CITES authorities for
additional information and verification.
The use of the word “ivory” in this report refers to elephant ivory, unless otherwise specified.
Throughout the report, the term “outlet” refers to all types of stalls, shops and online sites offeringivory items for sale. Markets are areas/buildings with either temporary or permanent stalls where anumber of individual store-holders offer their items for sale. Shops are generally considered to refer
to more permanent premises, with a single store holder (individual or group of traders) offering items
for sale (see Table 1). The term antique/s is used in this report to refer to “worked” pre-1947 ivory
falling under the worked specimen derogation of the EU Wildlife Trade Regulations (see legislation
above), unless otherwise specified. It is important to note that an ivory item such as a tusk on a mount
may be considered an antique by the antique sector due to its age, but if not sufficiently modified fromraw state, it would not fall under the worked specimen derogation and therefore not be considered an
antique under the EU Wildlife Trade Regulations.
Physical market surveys
A full replication of the Martin and Stiles (2005) study was not possible due to funding and time
limitations; the key UK markets for domestic ivory trade identified by Martin and Stiles were therefore
prioritized for the 2016 survey. These involved all major antiques markets in London and a smaller
number of antiques shops. Online surveys (see below) were further reaching, covering many otherantiques shops and locations in the UK, complementing the results from the physical market surveys
in London. The current survey was conducted in April 2016, 12 years on from the Martin and Stiles(2005) study in April and May 2004.
As per the key markets identified by Martin and Stiles (2005), the focus of this survey was on theantiques sector—target products, however, were not only antiques; all ivory items being offered
for sale in antiques markets/shops were recorded, and observations and questions concerning theavailability of new ivory in the UK were made (see below for further questions/topics discussed withtraders). Furthermore, it is important to note that ivory is also used for musical instruments and/or
could be sold in other business channels (such as non-antiques markets, car boot sales, other online

16

European Union – Trade in Wildlife Information eXchange – the system includes a database of CITES seizures in the EU (http://eu-twix.org/)

6 TRAFFIC report: A rapid survey of UK ivory markets© TRAFFIC

London antiques market

marketplaces and/or social media)—music shops and other business channels were not surveyed andtherefore this aspect of the UK’s ivory market was not assessed.
All London antiques markets visited by Martin and Stiles (2005) were re-surveyed in 2016 (see Table1), with the exception of Antiquarius, KM Antiques Fair, Fleurdelys, Bond Street Antiques Centre
and St James Church Antiques Market, which were either no longer operational or were open on
a day of the week that coincided with another market’s opening hours. In the case of the latter, themarket that was reported in Martin and Stiles (2005) as having a greater number of ivory items wasprioritized. In addition, Harrods (the only department store found to be selling ivory items in 2004)
and London’s Chinatown in Soho were revisited.
The survey team spent as long as was required (ranging from a few hours to two working days) ateach of the antiques markets to record the number and types of ivory items being offered for sale. The
total number of stalls in each market and the number of stalls with ivory items on display were also
recorded. For the larger markets, the total number of stalls were approximated. Many of the same
traders were present at various markets. When the survey team were certain they had seen the traderin a previous market and with the same items for sale, this information was not recorded, to avoid
duplication wherever possible. As a result, the total number of traders and items for sale at certain
markets that were visited towards the end of the survey period (e.g. Spitalfields Market) were lower
than might be expected.
Where stalls were closed, if possible they were revisited once on the same day or the following opening
day/week. However, in many cases they were still not open and if items were not clearly on display, it
was not possible to estimate the types and number of items for sale—these stalls were consequently
not included in the counts of total number of stalls.
In the case of antiques shops, the survey focused on two main areas with a high concentration of
antiques shops, namely Kensington Church Street, and the Mayfair area of Piccadilly, New/Old Bond
Streets. When shops were closed (as was the case for many in the Mayfair area, which generally
required an appointment), estimates were made from information on their websites or by looking
through shop windows. It is important to note that many of the antiques markets have permanent
antiques shops along the street associated with them (e.g. in Portobello and Camden Passage) or arepermanent stalls/shops open every day within a large building (e.g. Alfies and Grays), and therefore

TRAFFIC report: A rapid survey of UK ivory markets 7

surveys of these shops were included in the market surveys (as done by Martin and Stiles, 2005).
For both the markets and shops, each ivory item on display was counted where possible, but where
there were more than 10 of the same type of item per stall/shop, counts were made by +10 increments,
or +50 if there were over 50 items on display. Only items that were on display were counted. A size
category was assigned to each item and where possible the type of product, approximate age, priceand any other details such as origin were recorded—either when this information was displayed,when it was possible to question the trader or based on the researchers’ experience.
While Martin and Stiles (2005) provided size ranges by product type, the current study used anumerical system to categorize the different sizes of items found so that they could be swiftly recorded.
The categories were as follows:• Size 1: Very small – Jewellery, such as rings or earrings (one pair counted as one item);• Size 2: Small – 1–10 cm in length/height;• Size 3: Medium – 10–20 cm length/height;• Size 4: Large – larger than 20 cm, including whole tusks;• Size 5: A set – usually for a set of tableware (knife, fork, spoons) or vanity sets.
These categories and the guide ranges were used to allocate an approximate size to the items—where
possible, the researchers also took other factors into consideration, such as width and density. If only
part of an item was made of ivory, e.g. the handle of a walking stick or inlay in furniture, the size
category selected was based on the amount of ivory within the item. It is important to note that there
was a large variation in the size of the large category in particular. For example, there were hollow
boats over 50 cm in length made up of hundreds of small thin pieces of ivory and whole carved tusksof variable sizes, including vases made of whole tusks reaching heights of 60 cm.
This survey recorded the specific product type for sale, where possible. In the case of figures, thesewere recorded as specific types (such as netsukes or Cantonese magic balls) where this was stated by
the trader/clear to the researcher, however in other cases figures were simply recorded as “Figures”
with their associated size category. For analysis, items were grouped into four main commodity types:
jewellery, figures, household goods and personal items.
Where possible additional information was obtained from traders in order to gauge their knowledge/
perception/awareness of the status of the UK ivory market, the buyer demographic and regulations
concerning cross-border trade in ivory. Questions/topics of discussion included, but were not limitedto:• Most popular/common items for sale;• Where/how the items were acquired;• Awareness of each item’s origin and/or age, including ability to identify elephant ivory andassess actual age of the item;• The availability of new ivory on the market;

8 TRAFFIC report: A rapid survey of UK ivory markets

• Level of demand, including typical buyers and for what purpose, e.g. collectors;• Awareness of current national regulations and CITES, including whether ivory items can betaken to other countries and any documentation needed;• Concerns over possible new regulations or tighter controls, e.g. related to the new EU Action
Plan or stricter measures in the USA;• Suspicious activities including requests for new ivory or illicit transportation methods.
A survey method similar to that used by TRAFFIC in other ivory markets around the world was
replicated here – the surveying team posed as potential and interested buyers, notes being takenusing a mobile phone or Dictaphone, and photos taken wherever possible. No ivory was purchased aspart of the survey. This covert survey method, however, limits the number and range of questions thesurvey team is able to ask and any information collated from traders during the current survey was
opportunistic. Due to funding and time restraints, the current survey did not involve further in depth
investigation/research into traders or items for sale. Ongoing research by Portsmouth University aims
to gain a more comprehensive understanding of the supply and demand of ivory in the UK and of
trader compliance/understanding of legislation, through questionnaires and interviews with antiquesdealers, trade associations and auction houses, complementing the results of this survey (Arkell, 2015;
C. Cox, University of Portsmouth, pers. comm. to TRAFFIC, 2016).
The survey team was composed of Chinese, European and North American nationals experienced inivory identification. In cases where an item was identified by the survey team as ivory, but the trader
was unclear whether it was in fact ivory, then the item was recorded as ivory. However, if the trader
said an item was ivory when the survey team knew it was not, the item was not recorded. Certain
items were impossible to identify/verify as ivory such as “miniatures”, which are small paintings on
various media, including ivory. When the trader stated with certainty that these were painted on ivory
these were recorded, otherwise miniatures were not included (and therefore the number of ivory
miniatures seen is likely to be an underestimate of the actual total on the market). The focus of thesurvey was elephant ivory, but information on other kinds of “ivory”, such as that derived from whale
teeth or walrus, hippo or mammoth tusks, was noted if deemed to be of interest, e.g. when the trader
had mistaken it for elephant ivory.
Where possible, similar methods were used for both the 2004 and 2016 surveys, to facilitate somecomparison between results. The key markets for domestic ivory trade identified by Martin and Stiles(2005) were re-visited in 2016, and the number of outlets, the number of ivory items on offer for saleand their prices were also recorded. Furthermore, ivory not displayed openly was not counted, unlessthe trader brought it out to show.
However, it is important to note that there were a number of differences/uncertainties in relation to
the methods used in 2004. For example, in the 2016 surveys, a covert survey method was utilized,
duplication of counts was avoided if individual traders were recognized at different antique markets,and due to time and funding constraints the survey team were unable to revisit a number of outlets
that were closed on the initial visit. As it is unclear whether Martin and Stiles employed these survey
techniques, a direct and precise comparison and analysis of changes over time is not possible.

TRAFFIC report: A rapid survey of UK ivory markets 9

Online surveys© TRAFFIC

The survey team conducted a survey of offers for sale on various antiques and auction websites over
two weeks in April 2016, obtaining a snapshot of online advertisements for ivory products in the
UK. This was not intended to be an exhaustive survey of online ivory sales, but to complement thefindings from the physical market survey, specifically looking at the types of antique ivory items thatare available online and how they compare with ivory available at physical markets. Online surveys
also allowed the survey team to collate more information on prices and ivory antiques offered for saleor auction by traders beyond London; combined with physical market surveys exclusive to London,
this has enabled a more comprehensive picture to be built up of ivory availability across the UK.
There are a number of past and ongoing initiatives monitoring online sales of wildlife, and ivory inparticular, on online auction websites (such as eBay) and classified advertisement sites in Europe andthe UK (IFAW, 2014; A. Roberts, NWCU, pers. comm. to TRAFFIC, 2016), and therefore this study
did not go into this aspect in further detail.

Ivory figure for sale on UK-based online antiques marketplace

Two types of websites were included in the search:• Antiques auction consolidation websites, where lots from many different auction houses can beviewed in one place.
• Online antiques marketplaces, which connect small and large traders with potential buyers;
In each case only a select number of sites were searched—the first few pages/principal results using a
number of search engines were used to prioritize sites for further research. Two auction consolidationsites were sampled: Barnebys and The Saleroom, both of which are used by a range of UK auction
houses such as Christie’s, Dreweatts, Sotheby’s and Woolley & Wallis (see Appendix 3) and six online
antiques marketplaces were surveyed (see Appendix 4).

10 TRAFFIC report: A rapid survey of UK ivory markets

Web scraping software was used to extract data from ivory advertisements from a range of UK
websites that specialize in the selling of antiques, using “ivory” as the search item. A number ofdata points were recorded for each advertisement, including the product description, condition anddimension, list price, sales status, trader/contact information and provenance details. However, notevery advertisement had information on every data point. The results were then manually checked toensure only those advertisements with seemingly genuine ivory were included.
17

Several companies/shops used more than one of the online marketplaces to offer their items for sale,and a number of auction houses used both consolidation sites—duplicates from these sites wereidentified and removed from total counts, where possible. In the case of the auction consolidation
websites, The Saleroom was used as the principal source of information as auction house names were
provided in all cases; additional information from named auction houses with lots on Barnebys, andnot advertised on the Saleroom, were then added to the totals.
The number of items/lots on auction or for sale on each online antiques shop/auction house site wasthen counted. Counts per outlet included items that were on sale or up for auction at the time of thesurvey, as well as items that had been sold and auctioned in the past, but were still appearing on thewebsite. Other ivory, such as that derived from whale teeth, and walrus, hippo and mammoth tusks,
were sometimes included in the results from the searches “ivory” — these were excluded from thetotal ivory counts.
CITES trade data
Trade data for Elephantidae were extracted on 18th May 2016 from the CITES trade databasemanaged by UNEP-WCMC for the period 2005–2014. At the time of writing, the most recent annual
data available were for 2014, however these are likely to be incomplete as not all CITES Parties had
submitted their 2014 reports by this time (CITES, last updated 4th May 2016 ). The UK submitted allof its reports for 2005–2014, and therefore this analysis focuses on data reported by the UK, unlessotherwise specified, i.e. when focusing on re-exports from the UK, exporter data (reported by theUK) have been used instead of importer data (from various countries), and vice versa for UK imports.
Differences between reported importer and exporter data were analysed/highlighted when of interest.
18

19

20

Non-ivory elephant products (such as elephant teeth, bone, elephant leather products) were removed
from the analysis and ivory terms were classified under the following categories to facilitate analysis:• Raw ivory: tusks, ivory pieces and ivory scraps (there being no data for the latter)• Worked ivory: ivory carvings and carvings
The analysis focused on the number of records and the quantities of raw and worked ivory traded,using comparative tabulations to assess the import into and re-export out of the UK. Comparison
between UK and EU trade in ivory was also made—trade of antique ivory within the EU is permitted
without CITES documentation and hence would not be recorded in the trade database; therefore, EU
trade in ivory as a whole must be considered even when focusing on the UK market.
Trade records were typically reported as number of pieces or by weight, making it difficult to compare
and to measure the total volumes in any given year. This is particularly the case for “ivory pieces”,
http://www.locoy.com/
This includes trade reported as Elephantidae spp., Elephas spp. (Asian Elephant) Loxodonta spp. (African Elephant), Elephas maximus and Loxodonta
africana.
19
United Nations Environment Programme-World Conservation Monitoring Centre.
20
Annual Reports of CITES Parties: https://cites.org/sites/default/files/annual_reports.pdf (accessed 18th May 2016).
17
18

TRAFFIC report: A rapid survey of UK ivory markets 11

“ivory carvings” and “carvings”, where the number of pieces given could refer to different sizes andweights (UNEP-WCMC, 2013). Where the number of tusks were reported, however, it was possible toconvert this to an approximate number of elephants in trade (two whole tusks per elephant).
When examining the purpose of trade, this analysis focused on commercial (code: T, or blank),
and also items traded for personal use (code: P) where relevant, with records for other purposessuch as scientific (code: S) being minimal in comparison. The analysis also focused on specimens
derived from wild-caught specimens. The following source codes were considered “wild sourced” andincluded in the analysis: specimens taken from the wild (code: W), confiscated or seized specimens(code: I), source unknown (code: U or blank) and pre-Convention specimens (code: O).
Seizure data
A summary of ivory seizure data for 2005–2014 was sourced from ETIS, and details about specificseizure cases were supplemented with data from EU-TWIX (following permission granted by thereporting EU countries) and information published in the media.
Since seizures can be reported as either number of pieces or total weights, ETIS has developed
regression models on the ratio of ivory pieces and weights, based on previous data, to assign anestimated weight for all seizure cases. The weights of worked ivory seizures are also recalibrated toaccount for loss during the carving process, which inflates the weight by about 30%, resulting in raw
ivory equivalent (RIE) weights. It also makes worked ivory seizures comparable by weight to raw
ivory.
A summary (total number of annual seizures and estimated annual weight) of two types of seizure
data were analysed: ivory seizures that were made in the UK and reported by the UK, and ivory
seizures that involved the UK as either the country of origin, export/re-export, transit or destination.
The latter was based on seizure data reported by countries other than the UK.

12 TRAFFIC report: A rapid survey of UK ivory markets

Table1. Antiques markets/shops surveyed in April 2016 in London, UK. *Opening times are approximate—in many cases,
especially for markets, stalls can be set up earlier or later in the day, and also close earlier.

TRAFFIC report: A rapid survey of UK ivory markets 13

08.00 - 17.00
10.00 - 17.00

Wednesday andSaturdayMonday to Sunday

Monday to Sunday
SaturdayMonday to Sunday

HampsteadKensington

Notting Hill

Notting Hill

Hampstead Antique
Emporium

Kensington Antiques
CentrePortobello Road Antiques
MarketKensington

Mayfair

Kensington Church Street

Mayfair area

Monday to Sunday

Monday to Sunday

Monday to Sunday

Liverpool
StreetSpitalfields Market

Other areas with antiques
shops

SundayVictoria

Royal Horticultural Hall
(Adams Antique Fair)

Tuesday to Sunday

Mayfair

Grays Antique Centre
and Mews

10.00 - 17.00

10.00 - 17.00

10.00 - 17.00

10.00 - 16.30

09.00 - 17.00

08.00 - 17.00

09.00 - 18.00

10.00 - 18.00

10.00 - 18.00

Islington

Camden Passage Antiques Market

10.00 - 18.00

Monday to Saturday

Monday to Saturday

Chelsea

Bourbon Hanby

06.00 - 14.00

Friday10.00 - 18.00

Opening times*

09.00 - 20.00

Bermondsey

Bermondsey AntiqueMarketTuesday to Saturday

Opening days

Covent Garden Monday to Sunday

Marylebone

Alfies Antique Market

Covent Garden

Location (inLondon)Antiques markets
http://www.alfiesantiques.com/

Permanent indoor market withstalls/shops
Open air weekly market withstallsPermanent indoor market withstalls/shops

Street with high concentration of
antique shops
Area with high concentration of
antique shops

Indoor weekly market with stalls

Monthly indoor market withstallsPermanent shops

http://www.antiques-london.com/

http://www.oldspitalfieldsmarket.com/

http://www.adamsantiquesfairs.com/

http://www.portobelloroad.co.uk/themarket/

http://www.antiques-london.com/

Permanent indoor market withstalls/shops
Open air weekly market withstalls/shops

http://www.hampsteadantiqueemporium.
com

Permanent indoor market withstallsPermanent shops
Permanent indoor market withhttps://www.coventgarden.london/markets
stallsPermanent indoor market with
http://www.graysantiques.com/
stalls/shops

Open air bi-weekly market with
http://www.camdenpassageislington.co.uk
stallshttp://www.bourbonhanby.com/

http://bermondseysquare.net/bermondsey-antiques-market/

URL

Type(s) of outlet

RESULTS
Physical market survey results
Thirteen antiques markets and two areas with a high concentration of antiques shops in London weresurveyed for ivory items in April 2016—all markets and areas had ivory items for sale. Of the ~1,200
stalls and shops selling antiques surveyed in the 13market areas, 15% (~200) were offering ivory forsale. A total of ~3,200 ivory items were counted, of which ~56% belonged to size 2 (between 1cm and10cm) and ~35% belonged to size 3 (between 10cm and 20cm). In total, 73 of the 87 product types
found during the 2016 survey were of sizes 2 and 3. A total of ~7% belonged to size 4 (larger than
20cm, including whole tusks) with size 5 (a set of items) and size 1 (very small items such as jewellery)each making up ~1% of the ivory items found. Of the 30 antiques shops found along Kensington
Church Street, nine had a total of ~250 ivory items for sale and four shops in the Mayfair area had~40 ivory items for sale.
When comparing these results with those from 2004 (for the same 13 market areas only), there appears
to have been a significant reduction in the total number of stalls in London markets selling ivory(from 641 in 2004, 35% of the total, to 193 in 2016) and the total number of ivory items for sale (from~6,000 items in 2004 to ~3,200 in 2016) over the last decade. However, it is important to note thatthe total number of stalls in a number of markets varied significantly between 2004 and 2016, being
much higher in 2004 in a number of locations such as Bermondsey, Camden Passage and Portobello.
This may be due to an actual reduction in traders over the last decade , or the fact that the numberof traders can vary significantly between market days due to factors such as weather and number ofcustomers . Furthermore, in 2016 only those shops/stalls actually selling antiques and either open forbusiness or with articles on display that could be viewed from the window were counted, and the total
numbers for large markets were approximated.
21

22

In both 2004 and 2016, six markets were responsible for offering more than 90% of ivory items. The
average number of ivory items displayed per market stall/shop appears to have in creased, from 10
items in 2004 to 16 items in 2016, suggesting that while fewer traders may be offering ivory, they eachhave on average a larger stock.
Individual market/area results
Portobello Road Antiques Market
Portobello Road Antiques Market is considered one of the world’s largest antiques markets, offering
antiques for sale every Saturday throughout the year. Traders have stalls in over 15 arcades/galleries(and also on the street) along Portobello Road and adjoining roads, in addition to a number ofpermanent antiques shops open throughout the week (which were also included in this market
survey). Approximately 500 stalls/shops were found to be selling antiques during the April 2016
survey and 81 stalls were offering antique ivory items for sale. The type and number of ivory items
varied considerably between traders—the majority (63%) were selling 10 ivory items or fewer, with
only eight stalls apparently specializing in ivory, together offering over 50% of all ivory items available
for sale at Portobello market.

Based on information published in the Guide to the Antique Dealers of Great Britain (no longer available) and BADA (the British Antique Dealers’
Association) and LAPADA (the Association of Art and Antiques Dealers) membership, it is estimated that the number of antique dealers in the UK
has declined by at least 20% over the last decade (M. Dodgson, BADA, in litt. to TRAFFIC, August 2016).
22
In Portobello market for example, many traders closed their stalls earlier when visited during the first week of the survey, as they were frustrated withthe lack of customers.
21

14 TRAFFIC report: A rapid survey of UK ivory markets

In total over 1,400 different ivory items were seen for sale in the Portobello area—this is less than half
the number of items that were recorded in 2004. Together with the fact that there appears to have beena drop in the number/proportion of traders offering ivory (35% of stalls in 2004 compared to only
16% in 2016), this suggests there has been a decline in the availability of antique ivory at Portobello
over the last decade. However, Portobello market was still the principal market area in London for
antique ivory, offering for sale nearly 45% of all ivory items seen during the April 2016 market survey.
Royal Horticultural Hall (Adams Antiques Fair)
Adams Antiques Fair is a monthly Sunday fair located at the Royal Horticultural Hall, and offers highend antiques in an indoor market environment. In April 2016, 42 of a total of 150 stalls were offering
antique ivory items for sale. The number of ivory items found at each stall varied between one and 25
items, with two-thirds of the stalls offering five ivory items or fewer for sale. ~217 ivory items werecounted in the Royal Horticultural Hall in April 2016, which amounted to less than a third of thenumber counted there in 2004 (739). A decline in the proportion of traders with ivory items available(68% in 2004 compared to only 28% in 2016) suggests, as for Portobello market, a reduced demand
and/or availability for antique ivory at the Adams Antiques Fairs.
Camden Passage Antiques Market
Camden Passage Antiques Market is an outdoor market open twice a week; there are also several
permanent antiques shops along Camden Passage and on adjoining streets. Of the 25 stalls and shops
found to be selling antiques in April 2016, 13 were offering ivory items for sale. The number of ivory
items found at each stall/shop ranged from one to ~500 items—the latter was in an antiques shop
specializing in ivory, with an extensive range of items for sale, both by size and origin. In total, ~650
ivory items were counted along Camden Passage (making this market area the second most importantfor ivory, after Portobello), which is the same as in 2004 (653 items). However, as noted above, ~500 ofthese were held in one shop alone, and of the remaining 150 items, the average number of items perstall in the rest of the market was similar in 2016 (13) to that in 2004 (10.5).
Grays Antiques Market and Grays Mews Market
Grays Antiques and Mews Markets are located inside two heritage buildings in London’s West End,
offering antiques for sale six days a week. Of the total of 110 stalls counted in the Grays Antiques andMews Markets (60 and 50 stalls respectively) in April 2016, 21 (11 and 10 respectively) were seen
offering ivory items for sale. Stalls had a wide range in number of ivory items for sale, from three
to over 150 items. Around 200 ivory items were seen at Grays Antiques Market, and 279 at Grays
Mews Market. Combined, the two Grays markets had the third most numerous ivory items amongst
London’s antiques markets surveyed. The total number of ivory items was similar between 2004 (456)
and 2016 (483), however there was an increase in the number specifically available in the Grays Mews
Market. This was largely due to one stall that held an estimated 155 ivory items (predominantly small
netsukes) in 2016, more than half of the total found at Grays Mews Market.
Bourbon-Hanby Antiques Centre
Bourbon-Hanby Antiques Centre is an indoor arcade with stalls/shops that specialize in high-end
antiques and collectables, open six days of the week. Of the seven antiques shops in the arcade, fivewere offering ivory items for sale in April 2016, making this the market with the highest proportion ofstalls/shops offering ivory (70%). Number of items per shop ranged between four ivory items to ~95
items, with a total of 146 ivory items counted, an increase from 115 items in 2004. Despite its small
size, Bourbon Hanby had the sixth highest number of ivory items for sale across the 13 markets.

TRAFFIC report: A rapid survey of UK ivory markets 15

Covent Garden Markets
Both Jubilee Market Hall and Apple Market in Covent Garden have antiques for sale—Jubilee Market
hosts an antique market with around 100 stalls once a week and ~50 stalls at Apple Market sell avariety of arts and crafts, clothing, food and gifts items, including antiques, every day of the week.
Only six stalls were seen selling antique ivory items (between three and 22 ivory items per trader) at
Jubilee Market in April 2016, while none of the stalls at Apple Market had ivory items for sale. A totalof 43 ivory items were counted, which was slightly fewer than the 56 antique ivory items found across
18 stalls at both Jubilee and Apple markets in 2004.
Alfies Antique Market
Alfies Antique Market has a mix of antiques, vintage and retro furniture, fashion and household items
for sale, and is open five days a week. A total of 67 stalls were open when visited in April 2016, with
six stalls offering a total of 48 antique ivory items for sale. These stalls had between one and 22 antiqueivory items on offer. The amount of ivory recorded in Alfies market in 2016 is considerably less thanthe 263 ivory items found in 2004. Back then, 16 stalls were offering ivory for sale, out of a total of 118
stalls at the market.
Bermondsey Antiques Market
Bermondsey Antiques Market runs once a week and is primarily an open-air antiques market, witha small number of stalls located indoors. Of the 60 stalls that were set up at Bermondsey Market in
April 2016, nine were selling a total of 40 items of antique ivory. Few ivory items were sold at eachstall, ranging from one to nine items. In 2004, the total number of stalls (223), those selling ivory (60)and the total number of ivory items for sale (552) were all considerably higher than in 2016.
Hampstead Antique & Craft Emporium
Hampstead Antique and Craft Emporium is a small indoor antiques and craft market in London open
six days of the week, with 25 traders selling a variety of vintage and antique items. Three stalls wereseen selling a total of 26 antique ivory items in April 2016; this is a slight reduction from the 38 ivory
items recorded in 2004.
Old Spitalfields Market
Old Spitalfields Market holds different types of markets during the week, with one day set aside for
antiques. Of the ~150 stalls set up in April 2016, only six were offering antique ivory items for sale.
However, three of these were traders seen at other markets and their ivory items were not included in
the totals. A total of only nine antique ivory items were counted which is very low in comparison to
the 144 ivory items found in 2004.
Kensington Church Street and Antiques Centre
There is a large concentration of high-end antiques shops (~30 in total) along Kensington Church
Street in London, including the Kensington Antiques Centre, which has eight antiques stalls inside. In
April 2016, nine of the shops along the street were offering a total of 249 ivory items for sale, and fiveof the stalls in the Kensington Antiques Centre were offering a total of 61 items. The number of ivory
items varied considerably between traders, from one to 90 items—one shop specializing in walking
sticks stocked an estimated 50 items with ivory handles. Both the number of shops and number ofivory items found in this area appeared to have declined since 2004, when 16 shops/stalls were sellingaround 800 ivory items.

16 TRAFFIC report: A rapid survey of UK ivory markets

Mayfair area (Piccadilly, New/Old Bond Streets)
Mayfair is an exclusive area in West London and many of the antique shops offering high-end itemsin this area can only be viewed “by appointment only”. Due to the limited timeframe available for the2016 survey, this restricted the number of shops visited/items counted and the physical market results
for this area were supplemented by viewing results online from their dedicated websites. In April
2016, four shops were offering antique ivory for sale (~40 items in total), with the number of ivory
items on offer ranging from three to 25 items per shop. Together these shops had some of the highest
priced antique ivory found during the 2016 survey such as an ivory cabinet costing over GBP30,000.
Finally, in April 2016 no ivory items were found openly for sale in London’s Chinatown (the same
result as for 2004) or in Harrods, a high-end department store in Knightsbridge. When researchers
questioned shop assistants in Harrods, they were told that Harrods no longer has an antiques
department and consequently has no ivory items for sale.
Product Types and Prices© TRAFFICIn the current study, a wide range of ivory items were found on offer for sale including figures (56%),
household goods (27%), jewellery (9%) and personal items (8%) (see Appendix 2). Of the figures
on offer for sale, nearly half were medium sized (between 10cm to 20cm, size 3), followed closely bysmall figures (between 1cm and 10cm, size 2) and netsukes. Household goods were mainly made upof magnifying glasses followed by small sized cutlery (both with handles made of ivory). Jewellery
items on offer for sale were predominantly small-sized brooches, bangles/bracelets and pendants.
The commodity group for which the lowest number of ivory items was found were personal items,of which the majority were walking canes with ivory handles and medium sized fans. Of note is that
Martin and Stiles (2005) similarly found that the majority of items on offer for sale in 2004 included
figures, netsukes, magnifying glasses, cutlery, brooches, bangles, pendants and walking canes. Martin
and Stiles (2005) also found that the majority of ivory items were of sizes equivalent to the current
size categories 2 and 3.

Ivory figures for sale in London antiques market

TRAFFIC report: A rapid survey of UK ivory markets 17

Prices were only obtained during the 2016 surveys where marked or stated by the trader and therefore
a comprehensive comparison with prices recorded in 2004 is not possible. Online sales offers may
however give a better indication of current prices for certain ivory items and may facilitate a moreaccurate temporal comparison (see online survey findings). Overall, prices in 2016 ranged enormously
from ~GBP10 to more than GBP35,000 per item (see Appendix 2). Figures and household goods
were the items that varied the most in price; figures ranged from ~GBP15 to GBP18,000 per item,
while household goods ranged from ~GBP10 to more than GBP35,000 per item. Personal items
fluctuated less in price, ranging from GBP10 to GBP12,000 per item, and jewellery ranged from
GBP10 to GBP350 per item. Overall, high market prices were attributed to large ivory items on offer
for sale and were predominantly found in shops rather than stalls, for example a veneered piece offurniture made of >90% ivory was priced at GBP34,500, and large cutlery sets priced up to GBP8,000.
Comparatively, smaller items fetched lower prices and were mainly sold in stalls, for example knives
were priced at ~GBP10 per item and shoe horns between GBP50 and GBP100 per item.
23

Additional information on the UK ivory market collected from traders
Overall, market and shop traders offering ivory items for sale were moderately knowledgeable about
individual pieces, their age and provenance and legislation; however, there was a large variation in
knowledge in particular between high-end antiques traders (generally very knowledgeable) andopportunistic traders. Traders were generally approachable and forthcoming with information when
asked and it appeared that traders were acquiring much of their knowledge/information on UK
legislation, changes to other national legislation affecting international trade and views on any suchchanges from articles published in the Antiques Trade Gazette . These articles were referred to by
many traders, suggesting this would be a very important medium for any future awareness raisingamongst this group of stakeholders.
24

Identification and pricing of elephant ivory items versus other materials
On a number of occasions, the survey teamdiscovered that other materials such as bone,horn, resin, ivorine or other plastics were being
misidentified as elephant ivory, and vice versa. Of
note, however, is that traders were generally moreconcerned with craftsmanship, style of carving
and the era and/or provenance of antiquity as
indicators of quality and value rather than thematerial the item was composed of. In manycases there was little difference in the price of
items composed of ivory and similar materials.
For example, one trader was offering for sale acutlery set (composed of four pieces) made withivory handles for GBP29, and a similar set made ofivorine (six pieces) for GBP25. Similarly, anothertrader was offering two magnifying glasses, onewith an ivory handle and the other with a plastic
handle, for GBP12 and GBP10, respectively.

The survey team were informed by traders that they had several ivory items priced at ~GBP50,000 per item, however in these cases the traders did not
specify which these were so they were not attributed to a specific ivory item.
24
https://www.antiquestradegazette.com/
23

18 TRAFFIC report: A rapid survey of UK ivory markets

When asked how traders distinguished between elephant ivory and similar materials (including otheranimal ivories such as mammoth), some explained that it was colour, brightness, or the sense of touchthat helped them differentiate it. Some relegated it to expertise and/or experience, and only one trader
mentioned the importance in the grain of the ivory, however the crossed pattern/Schreger lines foundin elephant ivory was not described.
Awareness of age and origin
The majority of the traders were able to provide an approximate manufacturing age for ivory items
on display, by century, a few decades or specifically referring to them being prior to the 1920s or 1947
(the latter the legal “antique” classification cut-off for ivory). The oldest item on offer for sale wasdated as 1740. Only one product was confirmed to have been made after 1947, allegedly produced
in 1969. When asked how traders established the age of an item, most referred to their expertiseand specific knowledge of era/type of the antique. Traders in high end shops tended to be more
precise/knowledgeable about age and origin and noted they were able to provide confirmation ofthis through past sales information or expert opinion. With regards to new ivory, certain traders
explained it had little value to their business given that the raison d’être of the antiques industry ispreserving pre-modern objects as works of art, suggesting that freshly poached ivory was of little
value in the antiques market.
The majority of the traders were also able to provide information on the origin of ivory items withthe majority of products claimed to be from China, Japan and India. Other areas of origin included
Europe (mainly Germany and France) and Africa. With regards to acquiring ivory items, traders
claimed to source products from other markets across the UK, house clearances and auction houses.
Nationality of buyers
According to traders, the principal buyers of ivory antiques in recent years are East Asian citizens,from mainland China, Japan and Hong Kong, as well as European citizens, such as Germans, Austrianand Portuguese. One trader explained that she had learnt the Chinese (Mandarin) word for ivory toaccommodate the high number of potential Chinese buyers. Furthermore, during the surveys, two
Chinese speaking “scouts”were observed taking pictures of antiques, including ivory items, on theirmobile phones, uploading images with descriptive text, and calling contacts (speaking in both English
and Chinese language). No purchases were specifically observed, however one trader confirmed that
one of the scouts had purchased many ivory items in the past.
In comparison to Martin and Stiles’ findings, there appears to have been a change in buyer demographic
over the last decade. In 2004, it was reported that the majority of buyers were from the USA, followedby the UK and other European countries. Furthermore, in 2004 it was noted that high-end shops
were apparently selling 75% of ivory antiques to US citizens, however in 2016 many traders noted adramatic decline in buyers from the USA.
Awareness of UK, other national and international legislation
Generally, traders had a mixed understanding of what constitutes legal international trade in ivory,
although their awareness of the existence of a specific cut-off date for legal trade in antique ivory was
unanimous. Whilst some traders could accurately pinpoint the correct year in which an ivory item
is considered “antique” by law (ivory acquired and modified before 1947) and permitted in internal
EU trade without CITES documentation, others stated various dates between the 1920s and 1960s.
Most high-end traders were very knowledgeable regarding the national and international legislationand specific requirements for trade pertaining to ivory. Those that were aware of the legal restrictions

TRAFFIC report: A rapid survey of UK ivory markets 19

in ivory trade also understood the evidence needed for their customers to take ivory pieces out of theEU, such as the provision of an invoice and verification of age from the trader. Many stated that thecustomer would then be responsible for acquiring an export permit. However, some traders offeredto carry out this service on a buyer’s behalf.
A number of traders were forthcoming with information regarding changes in legislation highlighting
their apprehension in selling ivory items to certain members of the survey team (which included
Chinese and US nationals), due to stricter domestic legislation in their national countries. Many
traders appeared to know the specifics of US legislation, including the differences between State laws.
However comparatively, traders were generally less aware of the legality in exporting to China; somethought it was illegal, while others were unaware of any legislative changes in China but insisted thatthe customer should be responsible to check themselves as to the rules in the intended destination
country. Exporting to China was considered a risk by several traders and one specifically mentioned
the need to check personal identification upon purchase as they refused to sell ivory to Chinese
nationals due to regulatory changes. It is important to note that a few traders, although aware of
regulatory changes in China, suggested that purchasing small ivory items was not an issue and thatthe buyer would be able to transport these items in their personal luggage without detection. Some
traders were also aware that worked ivory can be taken to other EU countries, but unworked tusks are
not permitted in trade. One trader stated that unworked ivory was a lot more common 10 to 15 years
ago; she believed this was due to some legislative changes.
Other traders took a more fluid stance on the documentation required for trade and international
legislation with regards to exporting ivory to countries outside the EU, particularly China. Several
traders suggested that transporting ivory items to China was not a problem at all. A member ofthe survey team came across a Chinese citizen who declared she had successfully transported manyivory items by post. Other methods/techniques suggested by traders to facilitate the export of ivory
items included declaring the items as personal/household items that the buyer is travelling with, using
women to take items as they were less likely to be checked by the authorities, that a receipt was
adequate proof of age, and that the trader could state on the receipt the item was made of animal bonerather than ivory.

Online Survey Findings
Surveys of the online antiques ivory market in the UK focused on two types of websites: antiques
auction consolidation websites and online antiques marketplaces. Lots from over ~70 different UK
based auction houses could be searched on the auction consolidation websites. Several auction
houses were using both sites—therefore the Saleroom, which provided more specific details of theactual auction houses involved was taken as the main source of information, and items from any
additional auction houses found on Barnebys were added to these results (see Appendix 3).Barnebys
results on the other hand included more guide price information, and therefore these were used forprice analyses. Several traders used multiple online marketplaces to offer their items for sale. Total
and unique results for each market place are presented in Appendix 4.
Number of ivory items for sale online
Antiques auction consolidation websites
When surveyed in April 2016, the Saleroom was being used by 65 auction houses with a total of 578
lots containing ivory. Barnebys had an additional 10 auction houses (not using the Saleroom) offering

20 TRAFFIC report: A rapid survey of UK ivory markets

117 lots of ivory , totalling 695 items across all antique auction consolidation houses. The auction
houses with the most number of ivory items being auctioned were Woolley & Wallis (54 items, 8% of
the total number of items across all auction houses), Bamford Auctioneers & Valuers (49 items, 7%),
Canterbury Auction Galleries (47 items, 7%) and Dreweatts (43 items, 6%) (see Appendix 3). Twentytwo auction houses were together offering nearly 75% of the total number of ivory items (10 items ormore each), with another 53 auction houses each offering between one and nine items.
25

Online antique marketplaces
Six online antique marketplaces were sampled in the survey, yielding a total of 2,008 ivory items forsale during the survey period. However, a number of sellers were using multiple marketplaces to offer
their items for sale – when clear duplicates were removed the total number of unique items for salewas 1,710 ivory items. Platforms such as Antique Atlas, Online Galleries and British Antique Dealers
Association (BADA) offered a large number of ivory items for sale, with 734 items, 606 items and 336
items advertised respectively on a specific date in April (731, 454 and 265 unique items, respectively).
These three platforms together made up 85% of the unique ivory items found in the survey of online
antiques marketplaces. Selling Antiques also had a large number of ivory items advertised (163 uniqueitems, 10% of total) (see Appendix 4).
Product types
Similar items observed in the physical markets were also found online. The majority of ivory items
found online fitted into an existing category of products sold in the physical markets. A few very
unique items, such as an Indian ivory/tortoiseshell desk blotter on offer through Burstow and Hewitt,
and a cricket cage up for auction through Christie’s for an estimated GBP15,000–GBP25,000 were also
found.
All the items observed online may be considered “antique” under the UK’s definition of antique ivory,
with the most recent item reportedly manufactured (carved) in the 1920s. Items were dated as early as
the 17th century, with many from the turn of the 20th century. Products were from a broad range ofcountries and styles, with the most prominent being Japanese carvings (figures and netsukes), French
and English household items and miniatures (paintings), German, French and Spanish jewellery; andvarious other decorative items such as panels and vases from China, Japan, Africa and India.
PricesAntique auction consolidation websites
Guide price data were more frequently provided on Barnebys (96% of lots had guide prices) comparedwith The Saleroom (6% of lots). Therefore,guide price information from the Barnebys website wereused to assess product prices.
Forty-two per cent of items being offered for sale through the antiques auction consolidation website
Barnebys had guide prices of under GBP500. A large number of ivory items (37% of the total advertisedon Barnebys) had guide prices between GBP1,000 and GBP5,000. Items below GBP500 included chess
sets, gambling chips, cutlery, fans and a wide range of figures. The item with highest guide price wasan ebony table cabinet from circa 1650 made of a mix of materials such as ivory, tortoiseshell andcedar wood being auctioned at Christie’s (GBP20,000–GBP40,000).
25

The web scraping software found an additional 301 items on Barnebys that were not ascribed to a specific auction house. Manual checks of these items
confirmed that most were also being sold on the Saleroom. Therefore, these additional items were not included in the total count of ivory items in
auctions.

TRAFFIC report: A rapid survey of UK ivory markets 21

Online antiques market places
The price range of ivory products was the lowest for the website Antique Atlas—with 60% of ivory
items priced under GBP500. Items under GBP100 were typically household goods (including needle
cases, scissors, letter openers, page turners), smaller figures and jewellery pieces(including brooches,bangles and earrings).Items between GBP100 and GBP500 included carved Japanese-style figures,
Chinese fans, portrait miniatures, jewellery boxes, magnifying glass, opera glasses and small to
medium sized figures. The most expensive ivory item found on Antique Atlas in April 2016 was a pairof Japanese carved vases costing GBP7,500.
Figure 1 compares the range of prices for ivory items on one of the online marketplaces with thegreatest number of items for sale (Antique Atlas) and one of the antiques auction consolidation
websites (Barnebys). Based on price information from these websites alone, antiques auction websites
had a greater proportion of higher-priced ivory items for sale (based on guide prices provided)
compared to items found on online marketplaces. 41% of ivory items on Barnebys had a guide priceof GBP1,000 or more, while only 10% of ivory items on Antique Atlas were priced at GBP1,000 or
more. The majority of ivory items were under GBP500 on both types of antique ivory websites, with
42% of items on Barnebys and 60% on Antique Atlas within this price range.

Figure 1: Price ranges of antique ivory items offered for sale on UK online antiques marketplace

Antique Atlas and auction consolidation site Barnebys in April 2016. Notes: Number of items fallingwithin the respective price range is indicated within each colour bar. Where a price range was given
for an ivory item, the uppermost price was used in the analysis, e.g. for a product with a guide price of
GBP20– 400, GBP400 was used in the calculation.
Declarations concerning age, provenance and legality
The various auction consolidation sites (and corresponding individual auction houses) and online
marketplaces surveyed appeared to be using different methods for providing information on the age
and legality of the ivory being offered. Selling Antiques requires antique dealers to include a formal
declaration that states the date of manufacture, and the date is shown on the product detail page. Both
Online Galleries and the BADA websites have the date of manufacture included in brackets after thetitle, however it is unclear if this is a requirement. Further, BADA specifies the need to obtain a CITES
certificate when exporting an item outside the EU, with the following paragraph found at the bottomof an ivory product advertisement’s webpage:

22 TRAFFIC report: A rapid survey of UK ivory markets© TRAFFIC

Note related to CITES regulations included with advertisement for ivory item on
UK-based online marketplace“If you are purchasing tortoiseshell or ivory pieces and are outside the EU you must have a CITES
certificate in order to import the item into your country. We can obtain these on your behalf at a
cost of GBP50 and these can take up to 14 working days to arrive at our office. Due to the strict
exporting rules of these pieces, they may also come with further shipping costs. Please ensure youcontact us prior to purchase for a quote.”
Christie’s auction house also has a special notice about international trade on its website, stating that:“Several countries prohibit the importation of property containing materials from endangered
species, including but not limited to coral, ivory and tortoiseshell; prospective buyers shouldfamiliarise themselves with relevant customs regulations prior to bidding if they intend to importthis lot into another country”.
Other auction houses such as Sworders, Dreweatts and Woolley & Wallis have similar wording intheir terms of reference, stating that “buyers intending to export goods should ascertain (a) whether an
export licence is required and (b) whether there is any specific prohibition on importing goods of thatcharacter because, e.g. they may contain prohibited materials such as ivory.”
These terms place the onus on the buyers and focus on items being (re-)exported from the EU, as inmost cases these auction houses are selling antiques which fall under the worked specimen derogation(see section above on legislation), and therefore no documentation under the EU Wildlife Trade
Regulations is required for commercial use within the EU. However, sellers offeringworked antiqueivory for sale should be able to justify have some form of proof that the specimen falls under the
derogation and may be required to provide this proof when requested by authorities. Furthermore,
not all antique items fall under the worked specimen derogation (i.e. if they are have not been
sufficiently modified) and in these cases EU Wildlife Trade Regulation documentation is required forcommercial use, even within the EU. There have been reported cases of auction houses putting ivory
items up for auction without the appropriate documentation, e.g. in 2015 a silver mounted elephanttusk was put up for auction by Christie’s. Under the EU Wildlife Trade Regulations this is considereda raw unmodified tusk and therefore requires documentation prior to offering for sale; in May 2016,
Christie’s auction house was fined GBP 3250 for this infringement (Anon, 2016).
TRAFFIC report: A rapid survey of UK ivory markets 23

CITES TRADE IN IVORY: RE-EXPORTS AND IMPORTS
Trade data records from UNEP-WCMC’s CITES trade database that pertain to the UK’s and theEU’s re-export and import of ivory were analysed. The analysis focused on trade in reportedly wildsourced ivory (which includes the source codes I, O, U, W and blank) for commercial purposes (T andblanks); comparison with trade for personal purposes (P) was also made. The number of transaction
records is used as the main basis of comparison, as many records involve the number of pieces ofivory (not weight), however the size of these pieces is generally unknown. The exception to this is thecase of whole tusks, when the number of pieces can be used to provide an estimated weight range.
Where provided, trade quantities reported by weight were also compared.
Re-export of ivory from the UK
According to exporter data in the CITES trade database, there were a total of 567 records of re-exportsof wild-sourced ivory for commercial purposes from the UK between 2005 and 2014. These records
were composed of ~990 kg and ~54,000 specimens of ivory.
Re-exports for personal and commercial purposes together accounted for the majority of the ivory
trade from of the UK (>84% in all years, according to (UK) exporter data). Trade for commercial
purposes dominated ivory re-exports, totalling over 65% of re-export records from the UK between
2005 and 2014; while trade for personal purposes made up 25% of the trade during the same period.
The remainder were mainly re-exported from the UK for exhibition purposes, and nominal re-export
trade in ivory for education, scientific and hunting trophy purposes was also reported.
During 2005–2014, out of a total of 567 records of re-export of commercial wild-sourced ivory fromthe UK, 98% (557 records) involved worked ivory, and 2% (10 records) involved raw ivory (see Figure2). The raw ivory records included 17 whole tusks (source declared as pre-Convention or unknown),
equivalent to 59.5–127.5 kg by weight . Analysis of the number of records suggests there has been a
gradual increase in re-exports of both worked and raw ivory from the UK over the last decade (253/3
records for worked/raw ivory for 2005–2009, compared to 304/7 for 2010–2014).
26

Figure 2: Number of records of re-export of wild-sourced worked and raw ivory for commercial purposes from theUK, 2005–2014, according to exporter data. Source: UNEP-WCMC CITES trade database. Wild-sourced
ivory included that reported under source codes I, O, U, W and blank.
26

Calculated using an estimate weight ranging between 3.5 kg/tusk and 7.5 kg/tusk (Mundy, 2014).

24 TRAFFIC report: A rapid survey of UK ivory markets

Wild-sourced ivory from the UK was re-exported for commercial and personal purposes to a large
number of different countries in Asia, North America, Europe and the Middle East. According to
number of records, overall, the USA was the top importer of UK ivory during the period 2005–2014 (22% of all records), with China (15%), Australia (14%), Switzerland (12%) and Canada (9%)
also in the top five. When comparing the destinations of re-exports of worked specimens over thelast decade, the number of actual specimens reportedly re-exported to the USA has declined from
~19,000 in 2005–2009 to ~11,000 in 2010–2014, and the number re-exported to mainland China has
increased from ~2,000 to ~11,000.
Import of ivory into the UK
There were a total of 214 records in the CITES trade database of imports of wild-sourced ivory forcommercial purposes into the UK between 2005 and 2014 (made up of ~10 kg and 6,500 specimens),
which represents 52% of the total number of records of ivory imports. A large proportion of ivory
import transactions to the UK were for exhibition and personal purposes (22% and 15% of total ivory
imports, respectively). The remainder were composed of imports as hunting trophies, for educationand scientific purposes. As for re-exports, the large proportion of UK’s ivory import records involved
worked ivory. Records of raw ivory imports included 16 tusks (source declared as pre-Convention or
seized) equivalent to 56–120 kg by weight . The number of records of import of worked/raw ivory
appear to have declined slightly over the years, with 112/6 records for 2005–2009, compared to 94/2
records during 2010–2014 (see Figure 3).
27

Between 2005 and 2014, the UK imported ivory from many countries across the world, including
North America, Africa, Europe, the Middle East and Asia Pacific. According to the number of records,
several of the main destinations for re-exports were also the principal source countries/territories forcommercial ivory imports into the UK, with the USA, Switzerland, Jersey , Australia and Canada
making up over 55% of all import records.
27

Figure 3: Number of records of import of wild-sourced worked and raw ivory for commercial purposes into UK,
2005–2014, according to importer data. Source: UNEP-WCMC CITES trade database. Wild-sourced ivory
included that reported under source codes I, O, U, W and blank.

27

One of the Channel Islands, Crown dependency of the United Kingdom.

TRAFFIC report: A rapid survey of UK ivory markets 25

EU and UK re-exports and imports of ivory
When comparing number of records, in the CITES trade database, both the UK and the EU reported
a greater number of re-exports of commercial wild-sourced ivory than imports in 2005–2014. The EU
as a whole reported 1,808 re-export records, composed of ~7,600 kg and ~64,000 specimens of ivory,and 566 import records, composed of ~500 kg and ~11,500 specimens of ivory.
During 2005–2014, re-export records in the CITES trade database of wild-sourced ivory from the UK
for commercial purposes made up 31% of the total re-export records for the EU as a whole (see Figure4), and UK import records 38% of the EU total. The increase of re-exports over the last decade is more
pronounced for the EU as a whole (than for the UK alone), increasing gradually from 132 records in
2005, to 192 records in 2010, and 266 records in 2014, according to the EU’s exporter data (see Figure4). This equates to a 55% increase in re-export records from the periods 2005–2009 to 2010–2014,
compared to only a 21% increase for the UK. The small decline in ivory import records for the EU asa whole (12% difference between the two five year periods) was slightly less than the decline noted
above for the UK (19%).

Figure 4: Number of records/proportions of wild-sourced ivory re-exports for commercial purposes from the
UK and the rest of the EU, 2005–2014. Source: UNEP-WCMC CITES trade database. Wild-sourced ivory
included that reported under source codes I, O, U, W and blank.

Eighty-two percent of the EU’s ivory re-export records and 91% of the EU’s ivory import records
involved worked ivory specimens—18% and 9% of records therefore being for raw ivory respectively.
The EU reportedly re-exported ~1,300 tusks (equivalent to 4,500 kg–9,800 kg ) and imported 56
tusks (equivalent to 200 kg–420 kg ) between 2005 and 2014. These are much higher numbers andproportions of raw ivory records/specimens than those recorded for the UK alone.
22

22

It is important to note that the rate of increase (between 2005–2009 and 2010–2014) in the numberof re-export records from the EU, as well as for the UK specifically, were much greater for raw ivory(266% for EU; 133% for UK) than for worked ivory (33% for EU; 20% for UK). Of note is that the

26 TRAFFIC report: A rapid survey of UK ivory markets

number of EU re-export records of raw whole tusks increased steadily during 2005–2009, but thensignificantly increased between 2010 and 2014, from 14 records in 2010 to 81 records in 2014 (seeFigure 5). Both the EU and the UK’s worked ivory imports declined by 16%, while for raw ivory, theEU actually increased its imports by 38%, while the UK decreased imports by 67% from the period
2005–2009 to 2010–2014.
The UK and EU reported re-exporting and importing ivory to/from a similar set of countries/
territories in 2005–2014. The top countries importing ivory from the EU included the USA (whichsourced 34% of its total EU ivory from the UK), as well as Australia (55% of EU ivory from UK) andCanada (41% of EU ivory from UK).

Figure 5: Number of records of wild-sourced worked and raw ivory re-exports for commercial purposes from the EU,
2005–2014. Source: UNEP-WCMC CITES trade database. Wild-sourced ivory included that reported undersource codes I, O, U, W and blank.

Discrepancies in UK trade according to importer and exporter data
The CITES trade database includes the trade records from importer and exporter countries/
territories—these can highlight discrepancies in the number of transactions reported by trading
countries. The total number of ivory re-export records reported by the UK for commercial purposes
were almost double the number of records and specimens reported by importers during 2005–2014;
567 records in exporter data, composed of ~990 kg and ~ 54,000 specimens, compared to 274 recordsof importer data, composed of ~20 kg and ~26,500 specimens. This differenceis mainly attributed torecords of worked ivory, where exporter data had more than double the number of records every year
compared to importer data, between 2005 and 2014 (except for in 2006).
In contrast, the UK reported fewer records of raw ivory re-exports than importing countries, with10 records (composed of 49 specimens) and 58 records (composed of 585 specimens) during 2005–
2014, based on exporter and importer data, respectively. For example, there were almost no reported
TRAFFIC report: A rapid survey of UK ivory markets 27

UK records of trade in “ivory pieces”, but there were 39 records of imports of ivory pieces from theUK according to importer data during the 2005–2014 period. The same discrepancy (number ofrecords/total number of tusks according to importer data being greater than according to exporterdata) is evident for the re-export of tusks (See Figure 6). The UK reported the re-export of 17 tusks
for commercial purposes, compared to 109 tusks reported by importers. Specifically, importer datasuggest that 38 tusks were re-exported from the UK to Macau and 11 from the UK to Hong Kong in
2012, and 28 tusks from the UK to Hong Kong in 2013, none of which were reported by the UK. It
would be important to verify the reasons for these large differences. A number of records of trade intusks from the UK to Switzerland(12), Jersey(2) and Australia(2) reported by importers in 2005–2014
were also not reflected in the UK’s exporter records.

Figure 6: Number of wild-sourced tusks re-exported for commercial purposes from the UK, 2005–2014, according toimporter and exporter data. Source: UNEP-WCMC CITES trade database. Wild-sourced ivory included thatreported under source codes I, O, U, W and blank.

There are also differences in the reported number of wild-sourced tusks imported into the UK forcommercial purposes, when comparing importer and exporter data: the UK reported the import of
16 tusks, whereas (re-)exports of 45 tusks to the UK are reported in exporter data during the 2005–2014 period. This difference can mainly be explained by the one record of re-export of 31 tusks by
Canada in 2013, not reported by the UK.
Records of certain trading countries/territories have particularly large discrepancies with UK records.
Hong Kong consistently reports more wild-sourced ivory commercial trade records than the UK,
whether for re-exports or imports. Conversely, the UK tends to report more wild-sourced ivory
commercial trade records than mainland China for both re-exports and imports. Australia reports
considerably more commercial ivory imports from the UK, and much less in re-exports to the UK.
Overall data discrepancies are more prevalent in relation to UK re-exports, and countries that report
substantially less equivalent ivory imports include Qatar, Singapore and Russia (all of which have

28 TRAFFIC report: A rapid survey of UK ivory markets

submitted their CITES annual reports for these years). Reasons for such discrepancies could include
exporters/importers reporting the same transactions using different trade terms (possibly “carving” or“ivory carving” being used by the UK, given the much greater number of records for these terms inexporter than importer data) or importers reporting based on permits issued, but not used. It would
be important to clarify the reasons behind these discrepancies, in particular those related to raw ivory.

UK IVORY SEIZURES
Between 2010 and 2014, some 154 seizure records (on average 30.8 seizures per year) were reported by
the UK to ETIS, representing a total of 345.5 kg in raw ivory equivalent (RIE) weight. For comparative
purposes, Germany reported 236 seizures (753.03 kg RIE), and France 268 seizures (1,561.38 kg RIE)
during the same period, according to ETIS data. The number of UK seizures between 2010 and 2014
increased considerably when compared to seizures from the previous five-year period, when 75
seizure records, totalling 134 kg RIE, were reported by the UK (an average of 15 seizures per year).
2012 was a record year for ivory seizures reported by the UK to ETIS, with the highest number ofivory seizure cases and equivalent weight compared to all other years during the period 2005 to 2014(see Figures 6 and 7). Forty-five seizure cases occurred in that year alone, representing 84 kg RIE ofivory. Part of the seized ivory was a 15 kg consignment that was sent by freight in 2012, containing
hundreds of carved items that included bangles, pendants, beads and name seals. The consignment
was smuggled out of Nigeria, and was heading to Hong Kong and Guangzhou in China (Border
Force, 2012).
However, seizures that have been reported to ETIS so far were dwarfed by the UK’s largest seizure ofillegal ivory in 2015. In October 2015, a total of 110kg of ivory, including tusks, carved bangles andbeads, was found in abandoned baggage in transit from Angola and seized at Heathrow Airport (BBC,2015). This seizure was reportedly destined for Germany and differed from other previous seizuresin the EU (with the EU as a destination), which are typically small amounts of ivory smuggled for
personal use (Mundy, 2014). This single seizure had more ivory, in terms of total volume, than theannual seizure totals in the previous 10 years.
In both these examples, the UK was a transit country for consignmen tsen route from Africa (Nigeria
and Angola) to Asia or Europe (China and Germany). Seizures of this scale involving the UK are nottypical. According to ETIS data, the majority of seizure cases over the last decade with the UK as thepresumed final destination, involved the smuggling of 1–2 pieces of ivory (over 80% of seizure cases).
This is in line with a broader assessment of the EU, which appears to play a relatively small role inlarge-scale illegal transactions of ivory compared to other regions (Underwood et al., 2013; Mundy,2014).
In 2015, the UK Border Force (UKBF) ran an operation specifically targeting postal parcels enrouteto China in search of ivory items. During this operation, the UK reported over 150 seizure records
of ivory items (mostly antiques) being shipped to China in postal parcels, with one parcel containing
22 kg ivory carvings. While this has been described as a new phenomenon compared to 2014, it isimportant to note that this may have been occurring for many years but was discovered as a result ofproactive action from the UKBF (TRAFFIC, 2016).
Figures 7 and 8 show not only seizures that were made in the UK, but also those made in othercountries that involved the UK either as a country of export/re-export, transit, or destination. Between
2010 and 2014, there was a slightly higher number of seizure cases reported by the UK (154 cases)
compared to seizures reported by other countries and involving the UK (151 cases). However, total
volumes of seizures made by other countries (but involving the UK) in 2010–2014 were higher (412

TRAFFIC report: A rapid survey of UK ivory markets 29

kg RIE) compared with seizures made by the UK (346 kg RIE). Seizures that were made by othercountries butinvolving the UK included shipments that could have potentially been seized in the UK
during transit or in export—greater international co-operation and information exchange ensuresthat countries involved, in this case the UK, are informed of such seizures and associated information
can help inform national enforcement efforts through risk assessments and profiling.

Figure 7: Number of seizures made in the UK and number of seizures involving the UK, but made in other countries/
territories, 2005–2014. Source: ETIS data.

Figure 8: Estimated weight of seizures made in the UK and seizures involving the UK, but made in other countries,
calculated in raw ivory equivalent (RIE), kg, 2005–2014. Source: ETIS data.

30 TRAFFIC report: A rapid survey of UK ivory markets

28

DISCUSSION and CONCLUSIONSThe 2016 physical and online market surveys in London confirmed the ongoing availability of ivory
in the UK market. Antique (reported as pre-1947) ivory items were on offer for sale across all 13
antiques markets and two areas of antiques shops surveyed. No evidently new or raw (“unworked”)
ivory was seen in any of the physical markets or antiques shops, or in the online antiques shops,
marketplaces or auctions—only one ivory item seen in the physical markets was reportedly produced
post-1947 (in 1969).
When comparing the results with those found in 2004, there appears to have been a significant
reduction in the total number of stalls in London markets offering ivory items for sale, from ~640
in 2004 to 200 in 2016. Declines in the number of ivory items for sale in physical markets are also
evident, reducing by nearly 50%, from ~6,000 items in 2004 to 3,200 in 2016, however the average
number of ivory items displayed per outlet appears to have increased by 60%, from 10 ivory items in2004 to 16 ivory items in 2016. It is important to note that the surveys of London’s physical markets
conducted in 2004 and 2016 were not exact replicates, and any comparison needs to be assessed withsome caution. Generally, the majority of traders displayed only a few ivory items for sale, however
there were a number of ivory specialists, stocking between 100 and 500 distinct pieces.
The range of product types seen in 2016 were similar to those in 2004 with figures (including
netsukes), household goods (specifically magnifying glasses, cutlery, and walking canes) and itemsof jewellery (specifically brooches, bangles and pendants) the most popular items offered for sale in2004 and 2016. Traders generally had at least some knowledge about individual pieces, their age andprovenance, and were generally more concerned with craftsmanship, style of carving and the era and/or provenance of antiquity as indicators of quality and value rather than the material the item wascomposed of. In many cases there was little difference in the price of items composed of ivory andother similar materials.
The snapshot survey of the online antiques ivory market confirmed the variety of ivory items available
in the UK, with ~700 lots of ivory items and ~1,700 ivory items being offered for sale on two auction
consolidation sites and six online antiques marketplaces at one point in time in April 2016. Declines
in the number of physical stalls displaying and offering ivory items for sale might be explained in partby the high number of online sales (not an option in 2004) that facilitate direct trade with certain
overseas markets, combined with an overall reduction in the number of antique dealers in the UK
over the last decade. Traders at physical markets also noted that ivory items were being offered at
reduced prices due to the imposition of stricter legislation, which had subsequently reduced demand.
Based on the information collected during the 2016 surveys, all dealers were aware that trade of
antique ivory items was permitted, however the level of knowledge and compliance with current
legislation varied significantly. In general, casual and/or opportunistic dealers were limited intheir understanding of current legislation, yet high end dealers/auction house sappeared more
knowledgeable and compliant, in particular with the need for permits to export ivory from the EU
and the fact that individuals were not permitted to take ivory to the USA or mainland China due tostricter domestic legislation there.
Other dealers were moderately knowledgeable regarding the trade of pre-1947 ivory items, yet several
declared that anyone was able to purchase ivory items with no need for documentation to export

28

At the time of writing this report a referendum on EU membership was held (on 23rd June 2016) and the UK voted to leave the EU. This could have
implications on the current legislation controlling trade in ivory and the UK ivory market in the future, however this was not considered in moredetail here due to the many unknowns at present.

TRAFFIC report: A rapid survey of UK ivory markets 31

the pieces. Many were also aware of the existence of some trade controls/restrictions, yet suggested
smuggling the items in personal luggage or sending them by post. Of note is that very few dealers
were able to provide proof of age or documentation to prove legal acquisition. A simple mandatorydeclaration system (as currently used by one online marketplace Selling Antiques) requiring a formal
declaration of the approximate date of manufacture could potentially help to solve this issue for thesector as a whole. Many antiques dealers appeared to source much of their legal information/generalawareness over changes in legislation from the Antiques Trade Gazette.
According to Martin and Stiles (2005), buyers in UK physical markets were once dominated byAmerican and European tourists. In 2016 many traders reported that it is increasingly travellers/
citizens from East Asian countries/territories, including mainland China, Japan and Hong Kong,purchasing ivory items. Furthermore, researchers spoke to a number of Chinese buyers who claimed
to come to the UK regularly to purchase ivory and other antique items and take them back to China.
Two Chinese speaking “scouts” were seen recording information on antiques, including ivory items,
for sale at Portobello Market and sending this on to prospective buyers. Information collected fromboth traders and buyers from East Asia suggested that people are taking antique ivory out of the EU
without the required documentation, in their personal luggage (hand or check in) or alternatively
sending items in postal parcels.
Analysis of CITES trade data for elephant ivory showed that over the last decade the UK has been a
net exporter of wild-sourced ivory for commercial purposes. According to UK export data, between
2005 and 2014, ~990kg and ~54,000 specimens of ivory were re-exported for commercial purposes
from the UK. The majority of trade was in worked ivory (carvings and ivory carvings), with only 2%
involving raw ivory. Raw ivory re-exports included 17 whole tusks (source declared as pre-Convention
or unknown) for commercial purposes. Of note is that importer data show far higher numbersof whole ivory tusks re-exported from the UK between 2005 and 2014 (109 tusks). According tostricter UK domestic measures, only worked specimens (antique or pre-Convention) can be legally
re-exported for commercial purposes, and therefore it would be essential to clarify the reasons for/discrepancy between records of UK raw ivory re-exports held in the CITES trade database.
Re-export records of ivory for commercial purposes from the UK made up 31% of the total for the EU.
Although also predominantly composed of worked specimens, 18% of the EU’s reported re-export
records involved raw ivory (~1,300 tusks) between 2005 and 2014. These are much higher numbers
and proportions of raw ivory records/specimens than those recorded for the UK alone. Analysis of
the number of records suggests there has been a gradual increase in re-exports of both worked and
raw ivory from both the UK and the EU over the last decade—the rate of increase was greatest for raw
ivory (266% for the EU as a whole between 2005 and 2014).
The principal destinations for ivory re-exported from the UK over the last decade were the USA,
mainland China, Australia, Switzerland and Canada. However, the number of actual specimens
reportedly re-exported to the USA has nearly halved between 2005–2009 and 2010–2014 (from~19,000 to ~11,000) and the number re-exported to mainland China increased from ~2,000
to ~11,000. Information collected from traders in the 2016 survey support this shift in principal
destinations for antique ivory items.
Seizure data show that the UK is also an import, re-export and/or transit country for illegal ivory
trade, with an increase in ivory seizure records reported by the UK in recent years (an average of 15
annual seizure records, totalling 134 kg raw ivory equivalent reported for 2010–2014). There havebeen a number of seizures of new and/or antique carved items—in 2015, the UKBF recorded over
150 seizures of ivory carvings in postal parcels en route to China, through targeted inspections andsearches.

32 TRAFFIC report: A rapid survey of UK ivory markets

Although the physical and online market surveys carried out for this study did not find any new ivory
for sale or clear indications of illegal activity, a number of traders and buyers indicated their knowledge/
intention of taking antique ivory items out of the EU without the necessary documentation, andhence illegally. Lack of awareness and/or clarity over the UK’s and destination regulations on ivory
trade and the specifics surrounding the antiques (pre-1947) derogation under the EU Wildlife Trade
Regulations, appear to play a major role in this.

TRAFFIC report: A rapid survey of UK ivory markets 33

RECOMMENDATIONSThe UK CITES Management and Enforcement authorities are encouraged to:• Compile simple information/guidance on the current and planned/upcoming legislation anddocumentation requirements, definitions/examples of “worked” antique specimens, burdenof proof and best practice related to commercial antique ivory use and trade in the UK, andspecific domestic measures in important previous/current destinations for antique ivory
sourced in the UK, such as the USA and China• Share this information/guidance via the UK CITES MA website in addition to information
sources regularly used by antique dealers and auction houses, such as the Antiques Trade
Gazette• Raise awareness of tourists, in collaboration with CITES authorities in destination countries/
territories, regarding rules for purchasing ivory in the UK and its transportation across borders,through tour operators and airlines and targeted signage in relevant airport terminals• Explore the possibility of making declarations regarding the age and acquisition of all ivory
items, both on websites and in physical stalls/shops, mandatory in the UK• Continue to target ivory-related Customs inspections on shipments in postal and courier
services destined for East Asia and luggage of those travelling to the region, and consider
extending this targeting to other previously important destinations for ivory sourced in theUK, such as the USA• Research and clarify the discrepancies between importer/exporter-reported CITES trade ofivory (raw ivory in particular) from the UK over the last decade

The UK CITES Management and Enforcement authorities, in collaboration with authorities
in other EU Member States and other experts such as university researchers and nongovernmental organizations, are encouraged to:• Fund and plan regular, systematic and comprehensive market monitoring of all types of ivory
on offer for sale, including antique, pre-Convention and new, both in the UK and other EU
Member States• Continue to monitor online sales of ivory in the UK and carry out an assessment of the ivory
trade on social media platforms in the UK and the EU to determine if trade in ivory is prevalenton these platforms• Strengthen co-operation with e-commerce companies to research and develop innovative ways
to prevent illegal online trade in ivory and other endangered species in the future.

34 TRAFFIC report: A rapid survey of UK ivory markets

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Arkell, R. (2015). Research project begins into effect of total ivory ban in the UK. Antiques Trade Gazette.https://www.antiquestradegazette.com/news/2015/research-project-begins-into-effect-of-total-ivory-ban-in-the-uk/
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news/uk-england-london-34905000.
Blanc, J. (2008). Loxodonta africana. The IUCN Red List of Threatened Species 2008: e.T12392A3339343. http://dx.doi.org/10.2305/IUCN.UK.2008.RLTS.T12392A3339343.en. Downloaded on 17th June 2016
Border Force (2012). Border Force seizes illegal ivory. Available at: https://www.gov.uk/government/news/
border-force-seizes-illegal-ivory. Downloaded on 17th June 2016.
Choudhury, A., Lahiri Choudhury, D.K., Desai, A., Duckworth, J.W., Easa, P.S., Johnsingh, A.J.T., Fernando,
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T7140A12828813.en. Downloaded on 17th June 2016.
CITES (2015). Elephant Poaching Rates Virtually Unchanged in 2014 [press release]. 23rd March. https://cites.
org/eng/mike_figures2014 (accessed 22nd June 2016).
CITES (2016). China: provisional measures on the suspension of import of tusks and ivory carvings ofelephants. Notification to the Parties No. 2016/034. 1st April 2016. https://cites.org/sites/default/files/notif/ENotif-2016-034.pdf (accessed 22nd June 2016).
CITES Secretariat (2013). Monitoring of Illegal Trade in Ivory and Other Elephant Specimens, CITES Sixteenth
Meeting of the Conference of the Parties, Bangkok, Thailand, March 3-14, 2013. CoP16 Doc. 53.2.2. https://cites.org/sites/default/files/eng/cop/16/doc/E-CoP16-53-02-02.pdf (accessed 22nd June 2016).
DL Piper UK LLP (2016). Illegal wildlife trade UK ivory laws. A report prepared by DLA Piper UK LLP for The
Royal Foundation and United for Wildlife.
Environment Bureau/Agriculture, Fisheries and Conservation Department (AFCD, 2016). Proposed Plan for
Phasing Out the Local Trade in Elephant Ivory. Legislative Council Panel on Environmental Affairs. 27th June
2016.
European Commission and TRAFFIC(2015). Reference Guide to the European Union Wildlife Trade Regulations.
Brussels, Belgium.
European Commission (2016a). Commission Staff Working Document: Analysis and Evidence in support of
the EU Action Plan against Wildlife Trafficking. SWD(2016) 38 final.
European Commission (2016b). EU Action Plan against Wildlife Trafficking. COM(2016) 87 final. https://
ec.europa.eu/transparency/regdoc/rep/1/2016/EN/1-2016-87-EN-F1-1.PDF (accessed 25th May 2016).

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International Fund for Animal Welfare (IFAW, 2014). Wanted – Dead or Alive: exposing online wildlife trade.
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Martin, E. and Stiles, D. (2000). The Ivory Markets of Africa. Save the Elephants, Nairobi and London.
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Martin, E. and Stiles, D. (2003). The Ivory Markets of East Asia. Save the Elephants, Nairobi and London.
Martin, E. and Stiles, D. (2005). The Ivory Markets of Europe. Care for the Wild International: West Sussex; Save
the Elephants: London.
Milliken, T., Burn, R.W., Underwood, F.M. and Sangalakula, L. (2012). The Elephant Trade Information System(ETIS) and the Illicit Trade in Ivory: A report to the 16th meeting of the Conference of the Parties to CITES. CoP16
Doc. 53.2 (Rev. 2). CITES, Geneva, Switzerland.
Mundy, V. (2014). The Re-export of pre-Convention/antique ivory from the European Union. Report prepared for
the European Commission.
TRAFFIC (2016). Overview of important international seizures in the European Union, January to December
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Seizures Data. PLoS ONE 8(10): e76539. doi:10.1371/journal.pone.0076539.
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Assessment. United Nations Environment Programme, GRID-Arendal. www.grida.no
US Fish & Wildlife Service (USFWS, 2016). Administration Takes Bold Step for African Elephant Conservation:completes near-total elephant ivory ban to cut off opportunities for traffickers [press release]. 2 June. https://www.
fws.gov/news/ShowNews.cfm?ref=administration-takes-bold-step-for-african-elephant-conservation:-&_ID=35686 (accessed 22nd June 2016).
Williamson, P. (2011). Ivory Carvings in England from Before the Norman Conquest. Last updated: 17th
February 2011. http://www.bbc.co.uk/history/british/normans/ivory_01.shtml (accessed 23rd May 2016).
Woodhouse, C. (1976). Ivories: A History and Guide. David & Charles, London.

36 TRAFFIC report: A rapid survey of UK ivory markets

17

13

118

The
Kensington
Antiques
CentreAlfiesAntiques
Market139

Royal
Horticultural
Hall Antiques
Fair

BourbonHanby
Antiques
Centre61

Grays Mews
Market80

136

CamdenPassage
Antiques
MarketGrays
Antiques
Market832

No. of outlets

Portobello
Road Antiques
MarketMarket/area

16

3

3

20

94

12

62

328

14%

23%

18%

25%

68%

20%

46%

39%

No. of outlets % of outlets
with ivory
with ivory

263

12

115

367

739

89

653

2,973

No. of ivory
items

Martin & Stiles (2005)

4%

0%

2%

6%

12%

1%

11%

50%

67

8

7

60

150

50

25

500

6

5

5

11

42

10

13

81

9%

63%

71%

18%

28%

20%

52%

16%

% of market
No. of outlets % of outlets
No. of outlets
totalwith ivory
with ivory

48

61

146

204

217

279

654

1,414

No. of ivory
items

Current Study (2016)

2%

2%

5%

6%

7%

9%

21%

45%

% of market
total

Appendix 1

Number of Outlets and Ivory Items per Outlet

TRAFFIC report: A rapid survey of UK ivory markets 37

38 TRAFFIC report: A rapid survey of UK ivory markets

19

62

1,855

TOTAL

16

12

669

Kensington
Church St.

Mayfair area
(Piccadilly,
New/Old
Bond Streets.)

Grand
TOTAL

641

6

18

60

3

44

223

15

31%

33%

27%

12%

No. of outlets % of outlets
with ivory
with ivory

112

No. of outlets

Hampstead
Antique& Craft
Emporium
Spitalfields
MarketBermondsey
Antiques
MarketCoventGardenMarket Jubilee Market
Hall
CoventGardenMarket Apple Market

Market/area

6,926

133

792

6,001

144

38

552

56

No. of ivory
items

Martin & Stiles (2005)

14%

86%

2%

1%

9%

0%

1%

30

1,252

150

25

60

50

100

206

4

9

193

3

3

9

0

5

30%

4%

12%

15%

0%

6%

% of market
No. of outlets % of outlets
No. of outlets
totalwith ivory
with ivory

3,432

42

249

3,141

9

26

40

0

43

No. of ivory
items

Current Study (2016)

14%

86%

0%

1%

1%

0%

1%

% of market
totalAppendix 2
Quantities and Prices by Type of Ivory Items
Item

Size category

Quantity

JEWELLERY% of total

Price range in GBP

9.5

Brooch2

88

2.6

14–350

Bangle/Bracelet

2

80

2.3

25–250Pendant

2

78

2.3

25–170

Necklace – medium

3

36

1.0

25–160Earrings (pair)

1

26

0.8

10–25

Necklace–small

2

12

0.3

25–75

Cross–medium

3

4

0.1

Cross–small

2

2

0.1

FIGURES

56

Figure – medium

3

785

22.9

15–3,850

Figure – small

2

513

14.9

35–15,000

Netsuke

2

422

12.3

89–350Figure – large

4

187

5.4

1,200–18,000

Carved tusk

4

13

0.4

1800

Cantonese magic ball

3

3

0.1

140–800

HOUSEHOLD GOODS

26.8

Magnifying glass (handle)

2

247

7.2

15–200

Cutlery – small (handle)

2

143

4.2

9

Box – small

2

73

2.1

35–2,500

Paper knife/letter opener

3

52

1.5

15–135

Box – medium

3

40

1.2

48–22,000

Vase – large

4

40

1.2

2,800–3,000

Page turner

3

36

1.0

85–550

Cutlery – medium (handle)

3

35

1.0

10–195

Cutlery set (handles)

5

34

1.0

24–8,000

Vase – medium

3

30

0.9

Pen knife (handle)

2

21

0.6

Furniture with inlay (medium)

3

16

0.5

9,500

Picture/mirror frame

3

16

0.5

40–100

Sewing accessories

2

15

0.4

Stamp

2

10

0.3

Napkin ring

2

9

0.3

Ruler – medium

3

9

0.3

170

Chess set

5

9

0.3

80–2,200

Sewing bobbins

1

8

0.2

Furniture (veneered >90% by ivory)

4

6

0.2

12,000–34,500
12–375

Knife (handle)

2

6

0.2

Mirror

4

6

0.2

125

TRAFFIC report: A rapid survey of UK ivory markets 39

Item
HOUSEHOLD GOODS cont.
Tray
Furniture with inlay (small)
Candle snuffer
Tea caddy
Tea/chocolate pot (handle)
Snooker ball
Candlestick (pair)Ruler – small
Shoe horn
Bowl (handles)
Salt and Pepper set
Alphabet set
Dice cup/set
Panel
Sail Creaser
Thermometer
Box – large
Candlestick (pair)
Chopsticks (pair)
Clock
Cutlery – other
Fly whisk
CalendarCounter set
Toy setPERSONAL ITEMS
Walking cane (handle)
Fan – medium
Aide memoire/card case
Fan – small
Sword (handle)
Hunting knife (handle)
Clothes brush
Hairbrush
Miniature painting
Glove stretcher
Pipe
Baby rattles/dummy (ring)
WhistleVanity set (complete)
Cigarette holder
Umbrella (handle)
Binoculars
Parasol (handle)
PistolGavil
Bible
Perfume bottle
Purse
Conductor baton
Mask
Notebook

Size category

Quantity% of total

Price range in GBP

3
2
3
3
2
2
3
2
2
2
2
3
2
2
3
2
4
4
2
3
3
2
3
5
5

6
5
4
4
4
4
3
3
3
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1

0.2
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0

460
12,000

2
3
2
2
3
3
3
3
2
3
2
2
2
5
2
2
2
3
2
2
3
3
2
3
3
2

86
43
18
14
11
10
10
10
8
7
6
5
5
5
4
4
3
3
3
2
1
1
1
1
1
1

7.7
2.5
1.3
0.5
0.4
0.3
0.3
0.3
0.3
0.2
0.2
0.2
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.1
0.0
0.0
0.0
0.0
0.0
0.0

3432

100

TOTAL
40 TRAFFIC report: A rapid survey of UK ivory markets

8,500–10,000
110–250
9,000
28–69
50–100

150–225
1,200

500
16,000
3,200
7,000
950

250–1,400
600–1,500
70–245
650
950
10
15
850–1,200
12.50–15

500–800
225
50
170
150
140–395
12,000

4,000
140
1,000
40

Appendix 3
Survey Results of Antique Auctions Websites

ANTIQUE AUCTIONS(via The Saleroom and Barnebys)

WebsitePrice ranges(GBP)

Woolley & Wallis

Saleroom(http://www.the-saleroom.com/en-gb)

Bamfords Auctioneers & Valuers

Saleroom

49

Canterbury Auction Galleries

Saleroom

47

Dreweatts

Barnebys(https://www.barnebys.co.uk/)

43

Lawrences Auctioneers of Crewkerne

Saleroom

41

Reeman Dansie

Saleroom

27

Bearnes Hampton & Littlewood

Saleroom

25

Lindsay Burns & Company

Saleroom

25

Christie’s

Barnebys

23

Tooveys

Barnebys

22

Tennants Auctioneers

Saleroom

20

Christie's South Kensington

Saleroom

18

Lukehoney

Barnebys

17

Lyon & Turnbull

Saleroom

16

Island Auction Rooms

Saleroom

15

Mendip Auction Rooms

Saleroom

13

Special Auction Services

Saleroom

12

Burstow & Hewett

Saleroom

11

Semley Auctioneers

Saleroom

11

Bishop & Miller Auctioneers Ltd

Saleroom

10

Warren & Wignall Ltd.

Saleroom

10

Nigel Ward & Company

Saleroom

10

Others (53 auction houses)

Saleroom or Barnebys

176

Sub-totals

Saleroom578

30–8,000

Barnebys

117

40–40,000

TOTAL for Auction Houses

29

Total no. ofivory items
54

29

695

This number excludes duplicated ivory lots (301 in total) that were also found on The Saleroom.

TRAFFIC report: A rapid survey of UK ivory markets 41

Appendix 4
Survey Results of Online Antique Marketplaces

WebsiteTotal no. of
antique dealers(unique dealers)

Total no. ofivory items(unique ivory
items)

Price Range(GBP)

Antique Atlas

http://www.antiques-atlas.com/

100 (94)734 (731)

20–7,500

Online Galleries

http://www.onlinegalleries.com/

66 (46)606 (454)

95–75,000

British Antiques
Dealers Association(BADA)

http://www.bada.org/

39 (24)336 (265)

175–35,000

Selling Antiques

http://www.sellingantiques.co.uk/

67 (51)231 (163)

100–34,500

Antiques.co.uk

https://www.antiques.co.uk/

12 (11)98 (94)

25–1,695

The Hoarde

http://www.thehoarde.com/

1(1)

3 (3)

38–130285 (227)

2008 (1,710)

ONLINE ANTIQUE
MARKETPLACETOTAL

42 TRAFFIC report: A rapid survey of UK ivory markets

TRAFFIC report: A rapid survey of UK ivory markets 43

AUGUST 2016

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

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This document was publishedwith the kind support ofis a strategic alliance of

44 TRAFFIC report: A rapid survey of UK ivory markets