TRAFFIC System Error, Reboot Required:B R I E F I N GTomomi Kitade and Yui Naruse©GREG ARMIFIELD / WWF-UK

SEPTEMBER 2018

Review of Online Ivory Trade in JapanKEY POINTS:••

In June and July 2018, TRAFFIC
conducted an extended survey of
online elephant ivory trade in Japan to
track changes in trade and compliancepatterns since 2017, particularly inresponse to: 1) voluntary ivory banson major platforms, Rakuten-Ichiba,
Rakuma and Mercari in 2017; and 2)
new domestic regulations introduced inJune 2018.
Yahoo Japan now remains the single
most important provider of online
platforms for both BtoC (Business to
Customer) sales (Yahoo Shopping) andauction trade (Yahoo Auction), which
includes CtoC (Customer to Customer)
trade. The scale of ivory sales on Yahoo
Shopping appeared to be similar tothat found in 2017. The total estimatedvalue of ivory transactions on Yahoo
Auction over a four-week period was
JPY37.8 million (USD340,626), 16%less than estimated in 2017 over asimilar time period.
Shops selling ivory were no longer
identified on Rakuten-Ichiba. The ivory
ban on Mecari and Rakuma has alsosignificantly reduced the number of

easily identifiable CtoC advertisements(e.g. 98% reduction on Mercari).
However, cryptic advertisements, use ofcode words, and rapid turnover in ivory
products were detected, indicating
persistent trade amongst anonymous
CtoC users.
•

A small number of shops/users sellingivory products were also identified
on other online shopping malls, anauction site, and public spaces ofmajor social networking sites (SNS)(Facebook, Twitter, and Instagram
where advertising ivory is supposed to
be prohibited internationally).

•

Compliance with the new domestic
regulations by ivory businesses varied
across platforms and independentwebsites. The proportion of
unregistered businesses ranged from0% on independent hanko shop
websites and Yahoo Shopping to 26%
for businesses advertising to purchaseivory online. Non-compliance withthe requirement to display businessregistration was relatively highoverall, ranging from 22% to 52%.
Furthermore, discerning whether thelegal requirement applies to the many
anonymous sellers on auction, CtoC
and SNS platforms presented a serious
challenge.
•

The widespread lack of proof of legal
origin persists due to the absence ofregulations for products except wholetusks (e.g. on Yahoo Auction just 35
tusks were traded over four weeks as
opposed to 4,414 worked products),
and illegal trade in tusks without
registration cards was still observed on
Yahoo Auction (2 out of 35 tusks, 6%).
Use of voluntary product certification
was sparse amongst online retailers andnearly non-existent on other platforms.

•

TRAFFIC recommends the government
urgently introduce measures that
effectively ban unregulated CtoC trade
online; that e-commerce companies,
especially those hosting unregulated
CtoC trade such as Yahoo Auction,
introduce a voluntary ban on ivory
products and collaborate with industry
and NGO partners in the Global
Coalition to End Wildlife Trafficking
Online.

TR AF FI C BRI EF I N G P AP ER•

1BACKGROUND
The alarming levels of poaching of African Elephants over the past decade, combined with the heightened
illegal ivory trade globally, has led some of the world’s governments with major domestic ivory markets tointroduce strict regulations to prevent commercial ivory trade at the national level. As the primary demand
centre for illegal ivory, China’s market closure at the end of 2017 has provided the impetus for eradicatingillegal ivory trade 1. In East Asia, where traditional ivory carving has existed for centuries, mainland China’s
policy shift was soon followed by policies in Hong Kong and Taiwan to end both manufacturing and internal
trade by 2021 and 2020, respectively 2.

TR AF FI C BRI EF I N G P AP ER

In contrast, Japan remains a stronghold for the ivory industry and markets. While the government
strengthened regulations governing ivory businesses under the Law for the Conservation of Endangered
Species of Wild Fauna and Flora (LCES) that entered into effect on 1st June 2018 3, it has no intention toconsider reviewing its policy or regulations further. The current state of Japan’s domestic ivory market,
however, has been depicted as of concern in recent years: firstly, because of the substantial illegal export ofivory to China identified in ETIS 4 and TRAFFIC’s market survey conducted between May and September
in 2017 5; and secondly, due to persisting regulatory loopholes that remain unaddressed despite theaforementioned regulatory reform, including the lack of compulsory proof of legality requirements for
trade in anything other than whole tusks. Considering the urgent call by the Convention on International
Trade in Endangered Species of Wild Fauna and Flora (CITES) to take every measure to ensure domestic
ivory markets do not contribute to poaching or illegal trade 6, Japan is in need of policy reform to eliminate
unregulated ivory trade effectively from its domestic market.

2

Online trade of ivory in Japan has been surveyed by TRAFFIC in 2014 7 and 2017 8. It essentially mirrors
the overall state of Japan’s domestic market, characterised by ongoing production and sales of newly
manufactured ivory items represented by ivory hanko as well as active antiques and secondhand markets forthe vast number of ivory items either manufactured in or imported to Japan in the past. The antiques andsecondhand markets appeared to be revitalised by the advent of e-commerce platforms, first with auction
sites and more recently with dedicated CtoC (Customer to Customer) market sites. However, TRAFFIC
flagged the lack of effective regulation over such trade as a serious loophole in 2017, especially since evidenceof “legal” domestic sales in what appeared to be illegally imported items from places such as Thailand andCentral Africa was encountered. Rakuten, Inc. (Rakuten, hereafter) and Mercari, Inc (Mercari, hereafter)
subsequently banned ivory sales from their platforms in July and November 2017, respectively. Ivory trade,however, still continues on many Japanese platforms including Yahoo Auction, while their footprint oninternational illegal trade was substantiated by recent seizure incidents in China where Japanese e-commercesites were found to be repeatedly used by organised crime to procure large quantities of ivory items to
smuggle to China. One such seizure made in August 2016 by the Shijiazhuang Customs involved some 1,639
items weighing 101.4 kg 9. A covert interview of an antiques seller in July 2018 suggested exploitation ofJapanese online auction sites for illegal export was ongoing (R. Nishino, pers. comm. July 2018).

1.	State Council Office (2016). http://www.gov.cn/zhengce/content/2016-12/30/content_5155017.htm. 30th December 2016.
2. TRAFFIC (2018). https://www.traffic.org/news/taiwan-announces-move-to-close-its-domestic-ivory-market-by-2020/. 4th April 2018.
TRAFFIC (2018). https://www.traffic.org/news/hong-kong-votes-to-impose-domestic-ivory-ban-by-2021/. 31st January 2018.
3. CITES No.2018/61 “Japan: tightened regulations on ivory transactions” issued on 13th June 2018.
4. Elephant Trade Information System, a database of global ivory seizure data under CITES.
5.	Kitade, T. and Nishino, R. (2017). Ivory Towers: An Assessment of Japan’s Ivory Trade and Domestic Market. TRAFFIC, Tokyo, Japan.
https://www.traffic.org/publications/reports/ivory-towers-japans-ivory-trade/.
6. CITES Resolution Conf. 10.10 (Rev. CoP17).
7.	Matsumoto, T. (2015). A Review of Online Ivory Trade in Japan. TRAFFIC, Tokyo Japan.
https://www.traffic.org/publications/reports/a-review-of-online-ivory-trade-in-japan/.
8.	Kitade, T. (2017). An Updated Review of Online Ivory Trade in Japan. TRAFFIC, Tokyo, Japan.
https://www.traffic.org/publications/reports/traffic-surveys-find-thousands-of-ivory-items-sold-weekly-online-in-japan/.
9. Changcheng Web (2016). http://report.hebei.com.cn/system/2016/08/15/017192677.shtml. Changcheng Web, 15th August 2016.

©SHIJIAZHUANG CUSTOMS

The present study reviewed the dynamics of online ivory trade in Japan by extending the survey conducted
in 2017. The two specific reference points looked at were: 1) the impact of the new ivory ban on major
platforms, namely Rakuten-Ichiba, Rakuma, and Mercari; and 2) the new LCES regulations for ivory
businesses that entered into force on 1st June 2018. Under the new regulations, all businesses dealing inivory are required to register with the government (previously only required to “notify” the government)
whereby stricter obligations and penalties are applied 10. A list of all registered businesses is now disclosed
online 11, and businesses are required to display the registration details to operate legally, even online. As
with previous surveys, this study carefully evaluated ongoing and emerging issues beyond mere compliancewith existing regulations to underscore the risks of continued trade in the absence of sufficient regulatory
safeguards. Recommendations were made for regulatory improvements and best practices for voluntarymeasures by e-commerce companies.

TR AF FI C BRI EF I N G P AP ER

Ivory items illegally exported from Japan seized by Shijiazhuang Customs in August 2016. The items were allegedly purchased from Japanese
e-commmerce sites.

10.	K itade, T. and Nishino, R. (2017). Ivory Towers: An Assessment of Japan’s Ivory Trade and Domestic Market. TRAFFIC, Tokyo, Japan.
https://www.traffic.org/publications/reports/ivory-towers-japans-ivory-trade/.
11. http://www.meti.go.jp/policy/mono_info_service/mono/seikatsuseihin/zougebekkou/downloadfiles/tourokubo.pdf.

3METHODOLOGY
Target platforms and websites
The methodology used in TRAFFIC’s 2017 online survey 12 was adopted with extended coverage of online
platforms and websites as shown in Table 1. Major social networking sites (SNS) were surveyed for the firsttime, although access was restricted to open public posts due to methodological and resource limitations.
Samples of independent business websites, specifically those of: 1) hanko sellers and 2) dealers advertisingivory purchasing, were also surveyed to check compliance level with LCES. Posting of ivory advertisements
was prohibited on all of the surveyed CtoC markets and SNS as well as Rakuten-Ichiba, one of the major
online shopping malls (Table 1). Depending on the category of sites, either snapshot and monitoring data or
both were collected following the 2017 methodology (Table 1).
Table 1. Online platforms and websites surveyed
Category

Shoppingmalls

Auction sites
CtoC markets
SNS
Independentwebsites

Platforms/websites

Yahoo Shopping* (https://shopping.yahoo.co.jp/)
Rakuten-Ichiba* (https://www.rakuten.co.jp/)
Pompare Mall (https://www.ponparemall.com/)
Wowma (https://wowma.jp/)
Qoo10 (https://www.qoo10.jp/)
BASE (https://thebase.in/)minne (https://minne.com/)
Yahoo Auction* (https://auctions.yahoo.co.jp/)
Mobaoku (https://www.mbok.jp/)
Mercari* (https://www.mercari.com/jp/)
Rakuma* (https://fril.jp/)
Facebook (https://ja-jp.facebook.com/) in Japanese
Twitter (https://twitter.com/?lang=ja) in JapaneseInstagram (https://www.instagram.com/?hl=ja) in Japanese
50 hanko retailers
50 businesses advertising ivory purchasing

Ivory items
prohibited

Data collection
methods
Snapshot

Monitoring

○
○

○
○

○

○

○

○

○

○

○
○
○

*platforms also surveyed in 2017

TR AF FI C BRI EF I N G P AP ER

Snapshot analyses

4

A snapshot analysis was conducted for each of the targetted online shopping malls, auction sites and CtoC
market sites in June 2018 to collect and analyse information about types of products offered for sale, price,
sellers’ identities and compliance with LCES provisions such as display of ivory business registration
numbers and use of product certification. A keyword “hon-zouge 本象牙 (genuine ivory)” was used forYahoo Shopping and Yahoo Auction to sample real ivory items efficiently from a large number of hits (only
the top 100 auction advertisements were sampled in Yahoo Auction). A simple keyword of “zouge 象牙(ivory)” was adopted for all other sites where ivory advertisements were sufficiently scarce for exhaustive
sampling. Snapshot analyses of independent websites were also conducted to assess the LCES compliancelevels. The top 50 websites identified by Google search using the following keywords respectively were
sampled: “zouge inkan 象牙 印鑑 (ivory hanko)”and “zouge kaitori 象牙 買取 (ivory purchase)”. Only thecompliance related information was sought from these websites.

12. Kitade, T. (2017). An Updated Review of Online Ivory Trade in Japan. TRAFFIC, Tokyo, Japan.

Monitoring survey
Four-week monitoring was conducted to check for new ivory advertisements on auction sites, CtoC sites andSNS platforms. Monitoring was either done using a smartphone alert app 13 or by checking the sites with the
keyword “zouge (ivory)” every day for the period between 11th June and 8th July 2018. An exception wasYahoo Auction where its search engine allows retrieval of actual transaction records for the previous 120
days. Here, Yahoo Auction’s actual transaction records during a four-week period between 3rd and 30th
June 2018 were compiled in detail. As per the methodology used in the 2017 survey, the number of ivory
items by type were recorded for each site. In the case of Yahoo Auction, the total value of the ivory trade
was calculated using final bidding price records for items comprising almost exclusively of ivory (90% byappearance, excluding wrappings, containers or pedestals). The new advertisements were searched more
stringently on Mercari and Rakuma where the ban was in place and were further tracked to see if they
were being removed by each company’s monitoring efforts. Monitoring of public SNS posts was difficult,but any post which was considered functionally an advertisement was recorded. The currency rate of JPY1
= USD0.0090 (at 2nd July 2018) was used. Information obtained through the survey which pertained topotential non-compliance or illegal activities was shared with the respective authorities and companies
operating the respective platforms.

RESULTS
Overall result across platforms
Online shopping malls

The five other newly surveyed online shopping malls only housed a limited number of shops selling ivory,
ranging from three to 13 (Fig. 1 right). Here, shops selling ivory hanko were again the most common, except
for Minne, which is a market place for handcraft artists, representing sellers of hand-made ivory jewellery
and netsuke straps. Other types of products advertised on Pompare Mall and mobile-based BASE included
jewellery, Buddhist articles, tea ceremony utensils, and daily goods (parts for bags). There was one shop
specialising in ivory on BASE, selling semi-processed ivory materials (offcuts of raw ivory) in addition tofinished products. At least 11 shops selling ivory were found to be present on more than two platforms.

13. http://furimaalert.webcrow.jp/.

TR AF FI C BRI EF I N G P AP ER

The total disappearance of shops from Rakuten-Ichiba, compared to 55 shops observed in June 2017,
represented a major shift in the pattern of sales across online shopping malls. Yahoo Shopping subsequently
became the single largest platform for ivory sold online, where the number of shops identified by the
keyword “hon-zouge (genuine ivory)” was 54, roughly the same as the 58 shops observed in 2017. The
category of ivory items sold by shops on Yahoo Shopping also remained nearly unchanged with shops selling
hanko dominating (70%) (Fig. 1 left). However, eight out of the 54 sampled shops (15%) were different shops
from those found in 2017. Whether this is due to a sampling error or an indication of new stores opening on
Yahoo Shopping is unknown.

5

Yahoo Shopping
Kitchen utensils 4%
Japanese musicalinstruments 4%

Number of shops selling Ivory items

Other
4%

0

Hanko
70%

Qoo10

3

BASE

3

minne

15
3

6

Wowma
Jewellery 9%

1010Pompare Mall

Tea ceremonyutensils 4%
Buddhist
articles 5%

5

Hanko
Others6
11

Figure 1. Types of ivory products advertised by shops on Japanese online shopping malls in June 2018 characterised by a Snapshot survey using
keyword searches. LEFT) A sample of shops found on Yahoo Shopping using the keyword “hon-zouge (genuine ivory)” (N=54); RIGHT) the
total number of shops found to be selling ivory on other shopping mall sites (exhaustively searched using keword “zouge (ivory)” ).

Auctions

TR AF FI C BRI EF I N G P AP ER(Million JPY)

Yahoo Auction remains the largest andTotal JPY 45.2M
Total JPY 37.8M
most vibrant platform for ivory trade(USD 407K)(USD 341K)(Fig. 2). There were, however, a few
50
6%differences compared with the 20172%4%40
results. Firstly, the total value of ivory
12%
items sold on Yahoo Auction during
30
Semi-processed
the monitoring period was estimated to
92%
84%
20
Whole tusks
have declined by 16% compared to 2017,from JPY45.2 million (USD407,000)
Other products
10
to JPY37.8 million (USD340,626) in02018 (Fig. 2). The total count of ivory2017
2018
containing products sold declined
Figure 2. Sales value of ivory items on Yahoo Auction monitored over afurther by 55% from 9,788 to 4,414
four-week period in 2017 (8th May to 4th June 207) and 2018 (3rd June toitems, which was largely accounted for30th June 2018). Only items comprising almost exclusively of ivory (90% byappearance, excluding wrappings, containers or pedestals) were included.
by the decline in the observed numberof ivory jewellery items sold in bulk
(Table 2). On the other hand, there
was an increase in the number of whole ivory tusks sold from 22 to 35 tusks, which translated into morethan a five-fold increase in the combined value of the tusks from JPY871,000 (USD7,840) to JPY4.45 million(USD40,066) (the exchange rates were the same at JPY1 = USD0.0090). Active sales of semi-processedmaterials including over 1 kg of cut pieces were also observed, sometimes by anonymous sellers who were
not registered businesses. Search results of “zogue (ivory)” on Mobaoku, the other auction site surveyed forthe first time, revealed only four items, rendering it negligible in comparison to Yahoo Auction.

6

Table 2. Count of ivory containing items sold on Yahoo Auction over a four-week period in 2017 (8th May to 4th June2017) and 2018 (3rd June to 30th June 2018). Multiple items sold in the same lot were counted individually.

Semi-processed pieces

2017

2018

22 tusks

35 tusks

Weight known

59.5 kg small
pieces82.2 kg(including cut pieces)

Weight unknown

5,262 small
pieces3 small pieces

5,410

1,368

1,000

823

974

892

Jewellery : necklaces, earrings, brooches, string ties, ornamental
clasps for holding obi
Hanko : new hanko, carved/used hanko
Carvings & furnishings : netsukes, ornamental objects, incenseburners
Stationary : pens, paper knives

848

Smoking goods : pipes, cigarette holders

329

160

Buddhist articles : Buddhist prayer beads
Japanese musical instruments : bachis, shamisen, koto,

18

7

387

296

tuning pegs for shamisen, bridges and plectra of koto
Other musical instruments : guitar saddles

26

27

Kitchen utensils : chopsticks, chopstick rests, toothpicks

325

91

Tea ceremony utensils : lids, teaspoons, tea canisters

394

307

Indoor amusement goods : Mahjong tiles, pool balls, dice50

46

Daily goods : parts for hanging scrolls, shoehorns, fans, ear picks

845

329

Other : parts for Japanese swords
Total (excluding whole tusks and semi-processed ivory)

22

20

9,788

4,414

Screenshots of ivory cut pieces sold on Yahoo Auction (left: 1,221 g; right: 706.5 g). At least 13 such items weighing from 500 g to over 1 kg
were sold over a four-week period by four sellers, three of which were registered businesses. Proof of legality is not compulsory under theJapanese law for trade in raw ivory unless it is retaining the shape of a whole tusk.

TR AF FI C BRI EF I N G P AP ER

Category of ivory containing items
Whole tusk

7

CtoC sites

TR AF FI C BRI EF I N G P AP ER

Snapshot sampling using the keyword “honMercarizouge (genuine ivory)” on Mercari and Rakuma
573
600
returned few relevant advertisements, whichsignifies a drastic reduction in ivory sales
500
compared to before the ban when well over400
100 and 45 advertisements, respectively, were300
encountered using the same method in June 2017.
200
Similarly, a four-week monitoring of Mercari
marked a significant reduction in the number
100
14of new advertisements easily detectable with the0
keyword “zouge (ivory)”, going from some 573
2017
2018
products along with a polished tusk and various
Figure 3. The number of ivory products newly advertised andsemi-processed pieces counted in 2017 to only
were easily detectible with keyword “zouge (ivory)” on Mercari
over a four-week period in 2017 (8th May to 4th June) before
about 14 products with no tusk or semi-processed
the ivory ban was introduced and after the ban in 2018 (11thpieces, representing a nearly 98% reduction inJune to 8th July 2018).
the number of products (Fig. 3). These resultspresumably reflect the effect of the companies’
policies banning ivory trade. However, close
inspection of relevant advertisements flaggedcertain items that still appeared to be ivory but were not easily detectable. These advertisements wereusually not directly titled “ivory” but instead labelled with a code word “zouge-hu 象牙風 (ivory-like/ivorystyle)”, likely in attempts to evade monitoring. Scrutinising product descriptions also showed that in many
advertisements sellers revealed they were made of authentic ivory.

8

Screenshots of ivory items advertised with cryptic titles on CtoC sites where companies introduced a ban on ivory in 2017. LEFT) an
example from Mercari where the title states “zouge-hu (Ivory-like)” but a tag shown in the image clearly says “hon-zouge (genuine ivory)”.
RIGHT) an example from Rakuma where the title includes the equivalent of the term “ivory-colour” as well as “zouge-hu (ivory-like)” butvisual inspection of the image as well as the price (JPY20,000 or USD180) indicate the product is likely to be ivory.

Given such observations, more stringent monitoring of Mercari and Rakuma were conducted in thepresent survey by casting a wide net for relevant advertisements and scrutinising the contents to identify
cryptic advertisements. This led to detection of at least 52 and 11 advertisements on Mercari and Rakuma,
respectively, posted over a four-week period where the sellers either stated or indicated products were indeed
made of ivory (Fig. 4 left). These included sellers overtly referring to the platform’s policy banning ivory
trade as the reason why they had to use the code word “zouge-hu (ivory-like/ivory-style)”. Another code
word encountered on Mercari, especially on open messaging boards for interested buyers to ask questions or
negotiate price with sellers was “zou-san ゾウさん(elephant/Mr. Elephant)”. Furthermore, at least 32 and two
additional advertisements, respectively on Mercari and Rakuma, were identified as having high likelihoodsof being ivory based on visual inspection and price (Fig.4 left), while there were many more that appeared
possibly ivory but this could not be ascertained.
Tracking of these new advertisements encountered during monitoring showed that some were being detected
and deleted by the companies’ monitoring diligence (Fig.4 right). However, a large proportion was either
already sold or still available for purchase after one week (Fig. 4 right). These are likely manifestationsof challenges posed by cryptic descriptions as well as sales taking place so rapidly, especially on Mercari
where 50% (42 out of 84 items) were sold within one week (Fig. 4 right). The rapid sales likely indicate that
there is still demand for ivory items despite the ban, possibly from buyers who search amongst cryptic
advertisements for genuine ivory. These fast-selling ivory items were mostly ivory jewellery such as necklaces,
bracelets and bangles.

Number of new advertisements
100

Number of new advertisements
100

80

Sellers revealingivory is genuine

8060

Sellers not revealingivory is genuine
but identified likely
by visual inspection

60

52

40
20
0

32

Mercali

11
2

RakumaAfter One Week
Sold
Still Advertised

42

Deleted

40
20
0

35
7

Mercali

5
62

RakumaTR AF FI C BRI EF I N G P AP ER

Figure 4. LEFT) The number of new ivory advertisements including those inconspicuous ones only identified upon scrutiny of descriptions
and imanges on Mercari and Rakuma during four-weeks monitoring (11th June to 8th July 2018); RIGHT) Tracking result of such ivory
advertisements after one week as either sold, still being advertised or deleted.

9

SNS
Quantitative characterisation of ivory trade over SNS was not possible due to methodological and resource
limitations (i.e. searching and viewing public posts). However, four-week monitoring using the Japanese
keyword “zouge (ivory)” revealed some advertisements for ivory items being posted on Twitter andInstagram, as well as Facebook to a lesser extent (Table 3) which appeared to be against these platforms’
policies regarding products from endangered animal, including ivory. These public posts were largely posted
by Japanese businesses advertising new products such as jewellery, with a handful of such sellers identified
on both Twitter and Instagram (Table 3). While some invited interested buyers to contact them directly overSNS, most sellers provided links to separate product pages under companies’ homepages or other online
shopping sites such as BASE and minne. There are likely more public sellers than encountered during thismonitoring since further inspection of previous Instagram posts (going back to February 2018), for example,
revealed 11 more unique sellers.
Table 3. Public posts on SNS observed during the four-week monitoring survey (11th June to 8th July 2018).
No. ofpublic posts
advertising ivory
items

Total no. of
products
advertised

Facebook

2

3

Twitter

26

Instagram

7

Total no. ofsellers

No. of sellers
that arebusinesses

Jewellery

2

2

27

Jewellery, Japanesemusical instruments, partsfor handbag

5

5

9

Jewellery, netsukes

7

7

Types of products

TR AF FI C BRI EF I N G P AP ER

It was clear from the scarcity of open advertisements by non-business sellers that SNS are unlikely to beserving as active open platforms for CtoC trade of ivory in Japan. However, several of the sellers were foundto have posted 10 or more ivory items in the recent past, indicating that SNS are being used by some BtoC
sellers for advertising ivory items openly. Importantly, however, such observations from public posts could
be just one aspect of trade on major SNS in Japan (or in the Japanese language), and the situation in closed
groups and private posts remain unknown.

10

Screenshots of ivory advertisements by Japanese antiques business dealers identified on Instagram.

Compliance with LCES regulations
Business registration
The visibility of a business registration number, a new legal requirement from 1st June 2018, varied acrossshopping malls with an overall rate of non-display at 28% (27 out of 96, including shop duplications on
multiple platforms 14) (Fig. 5 left). Notably, Pompare Mall, Qoo10, and minne had many shops without therequired display, while the non-display level on Yahoo Shopping was low considering the number of shops
it housed (4% or two out of 54). Only Wowma had every shop displaying the registration number as legallyrequired. The non-display level across independent websites was 22% (11 out of 50) for the sample of hankoselling shops and reached 52% (26 out of 50) for the sample of shops advertising ivory purchase (Fig. 5 right).
Checking of the actual business registration status with the register showed that unregistered businesses
were found on 12% of online shopping malls (10 out of 82, excluding shop duplications on multiple
platforms), while none were found on Yahoo Shopping, Wowma, or Qoo10 (Fig. 6 left). Similarly all of the
independent hanko shops sampled were registered. In contrast, the proportion of unregistered businesses
reached 26% (13 out of 50) across sampled websites advertising to purchase ivory products (Fig. 6 right).

Business registration: Display
0

10

20

Yahoo
Shopping

Number of Shops
30

40

50

52

2

Pompare Mall 2

11

7

BASE
minne 2

10

20

30

40

39

Shops advertisingivory purchase

3

Qoo10

0
Hanko shops

6

Wowma

Number of Shops

60

50
11

24

26

2
9

Displayed

Not Displayed

Figure 5. Display of ivory business registration numbers on websites: LEFT) online shopping malls; RIGHT) independent websites of shops
advertising sales of ivory hanko and purchase of privately owned ivory products. Websites were surveyed in June 2018 using keyword“hon-zouge (genuine ivory)” for searching Yahoo Shopping, “zouge (ivory)” for searching other online shopping malls, and “zouge inkan(ivory hanko)” for seaching invididual shops using Google Search.

0

10

Yahoo
Shopping
Wowma

6
11

2

3
8

BASE
minne

30
54

Pompare Mall
Qoo10

Number of Shops

20

4

40

50

Number of Shops

60

0

10

20

Hanko shops

Shops advertisingivory purchase

30

40

50

50

37

13

1
7

Found in registry

Not FoundFigure 6. Actual registration status of businesses advertising ivory sales/purchase online: LEFT) online shopping malls; RIGHT) independentwebsites of shops advertising sales of ivory hanko and purchase of privately owned ivory products. Registration status was cross-checked withthe public register of ivory bussinesses disclosed by the Japanese government using registration number and company inforamtion.

14.	Including duplication of 14 shops present on multiple online shopping malls (representing 11 independent businesses) as their display status
sometimes varied on different platforms.

TR AF FI C BRI EF I N G P AP ER

Business registration: Actual11Delineation of business sellers from non-business sellers on online auction (mixed BtoC/CtoC), CtoC and
SNS platforms presented a challenge. In the snapshot sample of Yahoo Auction, the top 100 advertisements
were found to be put up by 45 unique sellers, of which 22 were registered businesses (Fig. 7 left). A number ofregistered businesses were also identified amongst the sellers found on Facebook (2 sellers), Twitter (5 sellers)and Instagram (4 sellers) (Fig. 7 right), of which only one seller on Instagram displayed its registration
number on its accounts page. The biggest issue is the identity and legality of other sellers found on theseplatforms which is unclear despite their significant presence (e.g. accounting for over half the sellers on
Yahoo Auction and all sellers on Mercari and Rakuma) (Fig. 7). For example, at least one seller on Mercari
and three on Instagram were definitively businesses, based on descriptions such as company information
and/or an antiques dealer’s licence number found on their webpages, but were found to be unregistered.
Furthermore, two sellers on Yahoo Auction displayed registration numbers that did not match any entries
in the register. There were other anonymous sellers who could reasonably be assumed to be using online
sites for business purposes based on the types and number of products they were advertising. However,ascertaining the legal obligation of each of these sellers (i.e. whether or not they were subject to LCES
regulations as businesses dealing in ivory) was deemed practically impossible.

Sellers on online auction
0
Yahoo Auction

10
22

20

30

Sellers on CtoC sites and SNS
40

0

50

23

10

20

30

40

50

60

70

66

Mercari
13

RakumaFacebook 2

Mobaoku 2

Twitter
Registered businesses
Other Sellers

5

Instagram 4 3

Registered businesses
Other Sellers

12©GREG ARMIFIELD _ WWF-UK

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Figure 7. Sellers on online auction, CtoC market sites, and SNS: LEFT) sellers on online auction sites, Yahoo Auction (N=45) and Mobaoku(N=2), identified in the snapshot sample obtained using keyword search “hon-zouge (genuine ivory)” in June 2018; RIGHT) sellers on Mercari(N=66), Rakuma (N=13), Facebook (N=2), Twitter (N=5), and Instagram (N=7) identified as posting new advertisements during the four-weekmonitoring period (11th June to 8th July 2018). Whether the sellers were registered businesses were checked against the public register using
company information.

Whole tusk registration
Trade or advertisements
Yahoo Auction
for whole tusks wereobserved only on Yahoo
Not Displayed
Auction where 35 tusks
2 tusks (6%)
were sold over the fourweek monitoring period.
All but two tusks (94%)
were traded legally with
Displayed
33 tusks (94%)
their registration cards
displayed and/or numbers
indicated (Fig. 8). Those
Figure 8. Display of registration
A screenshot of African style ivory tusks
auctioned illegally withoutcards/numbers for whole ivory tusks
sold without indication of government
sold on Yahoo Auction during theregistrations on Yahoo Auction in June 2018.
displaying their registration
four-week monitroing period between
3rd and 30th June 2018 (N=35).
cards were a pair of African
style carvings (right photo).
This evidence of illegal
trade in such items with
their unproven legal-origin is a particular concern, notwithstanding the high level of compliance overall.
The information was conveyed to the Ministry of the Environment (MOE), the Police and Yahoo Japan for
appropriate enforcement actions.
Product certification
The use of voluntary product certification to indicate legality of newly manufactured products was low at
20% (26 out of 132) across all online shopping malls and independent websites advertising ivory hanko(Fig. 9). Only ten shops (19%) on Yahoo Shopping indicated the use of product certification whereas none
were found on other online shopping malls. Nine out of the ten shops on Yahoo Shopping used certification
for ivory hanko whereas the remaining shop offered it with ivory chopsticks. The visible usage amongst
independent websites selling ivory hanko was 32%, while an additional 12% incorrectly displayed the productcertification as though it was a certificate of business operation (Fig. 9 right). Product certification was neverencountered on online auction, CtoC or SNS platforms, except for a single instance on Mercari where a sellerof hanko mentioned it.

0

10
10

Yahoo Shopping
Wowma

30

Number of shops
40
50
60

Hanko Shops

13
3

BASE

9

minne

11

0

10

20

Number of shops
30
40
50

44

6

Pompare Mall
Qoo10

20

16

28

6

Used

Used

Not usedNot usedWrong useWrong use

Figure 9. Use of voluntary product certification by shops advertising ivory products in online shopping malls (Yahoo Shopping: N=54;
Wowma: N=6; Pompare Mall: N=13; Qoo10: N=3; BASE: N=9; minne: N=11) or through individual websites (N=50). Websites were surveyed
in June 2018 using the keyword “hon-zouge (genuine ivory)” for searching Yahoo Shopping, “zouge (ivory)” for searching other online
shopping malls and “zouge inkan (ivory hanko)” for seaching invididual shops using Google Search. “Wrong use” means a product certifciaton
seal image was displayed along with business registration numbers as though it was a certificate of business operations.

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Product certification on website

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DISCUSSION
Persisting issues of regulatory loopholes
The strengthened regulations introduced in June 2018 for ivory businesses has had very limited impact
in terms of verifying the legality and traceability of online ivory trade in Japan. Most importantly, theregulations contained no provisions to address the lack of proof of legality for products traded in the market.
This undoubtedly continues to be the biggest loophole especially for online trade where active CtoC tradeoccurs completely outside the existing government oversight. In this sense, the voluntary moves by Rakuten,
Inc. and Mercari, Inc. to ban ivory sales on their CtoC sites were considered to be of paramount importanceas a step toward curtailing substantial parts of such unregulated online trade. In contrast, Yahoo Auction
continues to allow this type of trade in a significant volume. For example, the proportion of trade in which
the proof of legality at the product level were not established (i.e. anything but whole tusks) accounted for
88% of the JPY37.8 million (USD340,626) worth of ivory products sold on Yahoo Auction over the fourweek monitoring period. Furthermore, the new regulations did not include any provisions to ameliorate
the voluntary certification scheme for newly manufactured products despite its effectiveness repeatedly
being questioned since its establishment in 1995. The level of usage observed online was just as low as in2017, visibly used in 19% of shops on Yahoo Shopping and 32% of independent websites of hanko retailers,
indicating the scheme continues to be ineffective in ensuring the legality of new products in the market.
The new LCES regulations for ivory businesses also apply only to some sellers online, and with the exceptionof online shopping malls, which by design host only BtoC sellers, it was found difficult to distinguishanonymous one-off sellers from those who were regularly trading ivory products commercially. This issue
was evident on platforms where CtoC trade occurs. For example, the situation on Yahoo Auction was
virtually unchanged from 2017 where only about half of sampled sellers were obvious business sellers.
Although the company’s efforts to encourage sellers to comply with the law seemed to have resulted in nearly
all sellers that appeared clearly as business operations to register and display their registration informationas legally required, uncertainties in the trading practices of the rest of the anonymous sellers remainunresolved, and the existing regulations provide no instrument to address this matter further.
In summary, ivory trade in Japan’s online space consists of largely unregulated CtoC and BtoC trade thatis mostly lacking in proof-of-legality checks at the product level. This loophole remains regardless of key
advancements made in the LCES regulations concerning stricter oversight of ivory businesses, and urgently
needs to be addressed through further legal and regulatory improvements.

TR AF FI C BRI EF I N G P AP ERBest practices of e-commerce companies

14

The present survey evaluated the change in the status of online ivory trade in Japan under different voluntarypolicies imposed by online platforms. In fact, many platforms worldwide have taken stricter policies than theminimum required by their respective domestic regulations. This in part stems from companies’ recognitionof the international nature of illegal wildlife trade as well as that of their roles and responsibilities therein.
eBay, Google, and Amazon are such examples and had already banned ivory sales in Japan before TRAFFIC
conducted its first survey in 2014. Rakuten and Mercari, two Japanese companies, followed suit in July andNovember 2017, respectively. These moves were welcomed as TRAFFIC’s 2017 survey warned against therisk of unregulated CtoC trade, recommending a voluntary ban as best corporate practice. The present
study showed that new policies have effectively reduced the amount of such trade, for example by some 98%
estimated reduction on Mercari. Challenges in enforcing the ban, however, were identified; certain cryptic
advertisements and code words were detected along with rapid sales in such products, indicating persistent
demand for ivory products through CtoC trade. Mercari is further investing in more stringent monitoring toprevent such trade.

The present study did not detect any obvious spillover of CtoC trade from Mercari and Rakuma to otherplatforms. One exception might be the apparent increase in the trade of whole tusks on Yahoo Auction
compared to 2017 as Mercari was previously used for trading whole tusks, although to a much lesser degree
than Yahoo Auction. Nevertheless, causality in such an observation cannot be inferred. It should also be
noted that private SNS platforms could not be surveyed in the present study, limiting the insights into thepotential significance and dynamics of such trade. Notwithstanding this incomplete knowledge, the scaleof ongoing trade on Yahoo Auction continues to dwarf that observed on any other platforms including theresidual CtoC trade remaining on Mercari and Rakuma. At the moment, it appears unlikely that there would
be much new incentive for sellers of ivory products, including those with ivory with potentially dubious
origins, to shy away from the remaining open platforms, as long as the trade in Japan remains legal andlargely unregulated as it is now. However, diligence is needed to better monitor SNS and other emerging
platforms such as international e-commerce sites that may facilitate more direct international connections
and trade.

In March 2018, 21 of the world’s leading e-commerce, social media and technology companies with
operations in North America, Europe, Asia, and Africa came together with TRAFFIC, WWF, and IFAW
to launch the Global Coalition to End Wildlife Trafficking Online 19. One Japanese company has joined the
Coalition (Rakuten in August 2018). But others are encouraged to engage with the Coalition and continue tobuild on their own ongoing efforts in collaboration with industry and NGO partners globally. In so doing,
companies can play a wider role for civil society that goes much beyond simply enforcing regulations within
platforms’ boundaries to deterring illegal trade globally and educating users in wildlife protection.

15.	Yahoo Japan Corporation is a separate legal entity from all other Yahoo operations globally, including Yahoo! in the United States. Its policies
and procedures are unique to the Japanese company.
16. Ministry of the Economy, Trade and Industry (2016). http://www.meti.go.jp/english/press/2016/0916_01.html. 16th September 2016.
17.	K itade, T. and Nishino, R. (2017). Ivory Towers: An Assessment of Japan’s Ivory Trade and Domestic Market. TRAFFIC, Tokyo, Japan.
https://www.traffic.org/publications/reports/ivory-towers-japans-ivory-trade/.
18.	People’s Court Daily (2013). http://rmfyb.chinacourt.org/paper/html/2013-10/24/content_71951.htm. 24th October 2013.
19. TRAFFIC (2018). http://www.traffic.org/home/2018/3/7/leading-tech-companies-unite-to-stop-wildlife-traffickers.html.

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Yahoo Japan Corporation 15 (hereafter, Yahoo Japan) is still considered to be of central importance given its
sheer scale in Japan’s online ivory trade, and therefore its policies have implications beyond Japan’s borders.
At present, the company does invest in maximising the compliance of its users with existing regulations
as evidenced by its public commitments to ensuring appropriate trade practices and participation as acore member in the government-led “Public Private Council for the Promotion of Appropriate Ivory Trade
Measures” 16. The present survey also showed a relatively high level of compliance with business registration
requirements as well as legal trade in whole tusks. However, even within the narrow frame of existing
regulations, there were incidents of illegal trade in whole tusks, highlighting enforcement challenges whenthe volume of trade is so high. Despite all of these efforts, the biggest shortfall in Yahoo Japan’s voluntarypolicy is in not going beyond what is minimally required by domestic regulations, thereby allowing a large
volume of unregulated trade without proof of legality. The actual footprint of such practices on international
illegal trade remains unknown for incoming trade (illegal imports) due to a lack of seizures, but has been
established for outgoing trade (illegal exports) as implicated by significant seizures made in China wherelarge quantities of products were allegedly sourced from e-commerce sites in Japan 17. In one instance, aChinese Court revealed that criminals convicted for smuggling a total of over 3.2 tonnes of raw and worked
ivory from Japan between November 2010 and April 2012 confessed to using Yahoo Auction for procuring
the ivory 18.

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RECOMMENDATIONS
The online ivory trade in Japan has been identified as a source of international illegal ivory trade, particularly
as illegal exports to China, and is still insufficiently regulated with a critical loophole that essentially allows
unregulated trade of ivory products without proof of legality. This state of affairs falls short of the emphatic
measures called for countries with legal domestic markets by CITES Resolution Conf. 10.10 (Rev. CoP17) toensure their domestic markets do not contribute to poaching or illegal trade. Japan appears to be out of stepwith the other key ivory markets in Asia that are taking significant strides to resolve their domestic ivory
markets. TRAFFIC recommends the following to address the persisting issues of online ivory trade in Japanas a matter of urgency:• The Ministry of the Environment (MOE) and the Ministry of Economy, Trade and Industry (METI)
should urgently consider introducing enforceable proof-of-legality requirements for trade in all worked
ivory products and also substantially narrow the range of items that can be traded legally in Japan (e.g.
bona fide antiques with certain cut-off dates or products with legality guaranteed by the government).
• The MOE and METI should, until the abovementioned regulatory framework for a narrow line of legal
domestic trade is established, introduce measures that effectively ban unregulated CtoC trade online, andfor new products at least upgrade the existing voluntary product certification scheme to a mandatory andeffective mechanism for ensuring legality and traceability.
• E-commerce platforms such as Yahoo Auction that are characterised by a high proportion of unregulatedtrade (CtoC) as well as a high risk of serving as an intermediary for international illegal trade shouldurgently introduce a voluntary ban on ivory trade, until at least sufficient regulatory and enforcement
safeguards are in place.
• Providers of online shopping malls (BtoC sites) should enforce business registration requirements and,along with online retailers, should work to ensure the legality of all new products by mandating the usageof product certification.

TR AF FI C BRI EF I N G P AP ER• E-commerce and other online companies are further encouraged to work with industry partners andNGOs at both national and international levels, especially as part of the Global Coalition to End Wildlife
Trafficking Online, by adopting global best practices, and collectively fortifying their monitoring andenforcement efforts and conducting effective awareness-raising amongst users.

16

ACKNOWLEDGEMENTS
The authors thank colleagues from TRAFFIC and WWF Japan for their strong support and guidance towards the completion ofthis report: in particular, Crawford Allan, Richard Thomas, James Compton, Tom Milliken, Ryuji Tsutsui, Tobai Sadayoshi, Wilson
Lau, Giavanna Grein, and Xiao Yu for their critical reviews and invaluable inputs to the draft. The authors also send special thanks
to Ryoko Nishino, Junkichi Mima, Richard Thomas and others from TRAFFIC and WWF for their dedicated support towards therelease of the report.

©GREG ARMIFIELD _ WWF-UK

TRAFFIC, the wildlife trade monitoring network, is a leading non-governmental organization working globally on tradein wild animals and plants in the context of both biodiversity conservation and sustainable development.
For further information contact:

TR AF FI C BRI EF I N G P AP ER

TRAFFICJapan Officec/o WWF Japan 3F. 1-4-28 Mita, Minato-ku, Tokyo
108-0073 Japan
Telephone: (81) 3 3769 1716
E-mail: TEASjapan@traffic.org
Website: www.traffic.org (EN)www.trafficj.org (JP)UK Registered Charity No. 1076722,
Registered Limited Company No. 3785518.

This Project was supported by WWF Japan©1966 Panda symbol WWF @“WWF” is a WWF Registered Trademark

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