t r a f f i c AN UPDATED REVIEW OF ONLINE
B R I E F I N G

August 2017

IVORY TRADE IN JAPANTomomi Kitade

KEY POINTS:• In 2017, TRAFFIC conducted asurvey to update the state ofonline ivory trade in Japan, last
reviewed in 2014. In addition
to online shopping malls andauction sites, emerging online
CtoC (Customer to Customer)
market sites were surveyed.

• 2,447 ivory items2  on average
were auctioned every week
on Yahoo Auction. The tradevalue of ivory over a fourweek monitoring period wasestimated at JPY45.2 million(USD407,000). The majority ofsellers who did not identify
themselves as businesses could
be inferred to be operating assuch.
• Japan’s current legal
framework does not regulate
ivory trade amongst individuals
except when whole tusks
are traded. There is no wayof establishing legality in theactive online trading of otherivory items such as jewellery
and figurines.
• TRAFFIC recommends thegovernment urgently assesses
the feasibility of installingstrict measures to address all
aspects of internal ivory trade,including capturing the identityof, and registering online
businesses with no indication of
their identity as such, as well as
encouraging the e-commerce
sector to implement stricter
measures, including banning
the trade, and awarenessraising for e-commerce users.

BACKGROUND
Japan is home to a long-standing domestic ivory market with a still significant carving
industry and is listed as a country of “importance to watch” under the Elephant Trade
Information System (ETIS) review process3 of the Convention on International Tradein Endangered Species of Wild Fauna and Flora (CITES). Japan has twice been allowed
to be a legal importer of ivory in the context of the two CITES-approved one-off ivory
sales. Aside from the estimated USD19 million annual production by the carving
industry4, a majority of which is based on hanko or name seal sales, there exists a
substantial and largely unregulated domestic market in old ivory products which aretraded amongst dealers and individuals. The wide availability of old ivory products is alegacy of Japan’s former ivory trade boom sustained until the international trade ban ofelephant ivory was introduced under CITES in 1989.
In June 2017, the Japanese government strengthened certain aspects of internal
ivory trade regulations for businesses under the Law for the Conservation of theEndangered Species of Wild Fauna and Flora (LCES). Amendments include updating
the business notification system to a registration system with increased penalties for
non-compliance and mandating ivory businesses to register all whole tusks in theirpossession. While such measures build on the existing controls over businesses, the
LCES regulations leave all other domestic ivory trade with only limited and, in somecases, completely without regulatory control. The proof of legality at the product level
1 The Law for the Conservation of Endangered Species of Wild Fauna and Flora (LCES), reformed in June 2017 for enactment in 2018,
will strengthen ivory business regulations.
2 Excluding whole tusks and semi-processed ivory. Multiple items offered in a single lot were counted separately as individual pieces.
3 Milliken, T. Underwood, F.M., Burn R.W., and Sangalakula, L. (2016). The Elephant Trade Information System (ETIS) and the Illicit
Trade in Ivory: A report to the 17th meeting of the Conference of the Parties. CoP17. Doc. 57.6 (Rev.1). Annex.
4 Kitade, T. and Toko, A (2016). Setting Suns: The Historical Decline of Ivory and Rhino Horn Markets in Japan. TRAFFIC, Tokyo, JapanT RA F FI C BRI EF IN G PAPE R• Emerging online CtoC markets
are being used for trading
personal ivory items, particularly
jewellery. An average of 143
new advertisements2 were
uploaded every week on
Mercari, Japan’s leading online
CtoC market. Advertisementsof "new" ivory jewellery broughtback from Asia and Africa incontravention of CITES werealso found.

©Steve Morello / WWF• Legal ivory sales continue on
online shopping malls andauction sites, though thereis evidence of improved
compliance with Japan’s
domestic law1 owing to
e-commerce companies’
monitoring activities. Overall
trends in online ivory trading
are not possible to gauge
at this point, but collectively
various channels are active.

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is delegated to a voluntary certification scheme for new products, and regulation over trade in any ivory items
other than whole tusks5 is non-existent. These grey areas in Japan’s domestic ivory trade must be addressed
accordingly to eliminate potential loopholes for illegal ivory flows.
Globally, wildlife cybercrime is increasingly recognized as a serious challenge which undermines the efforts
to prevent illegal wildlife trade6, 7. While online ivory sales remain legal in Japan, the sheer scale of the trade
warrants scrutiny to prevent illicit activities. TRAFFIC’s review in 2014 elucidated certain enforcement weak
spots, which led major e-commerce companies to enforce relevant rules for their users through monitoring
activities. While some other unaddressed issues continue to raise concerns, new issues have also arisen
which likely affect the current pattern of online ivory trade, including the growth of the CtoC (Customer toCustomer) sector and increased use of smartphone apps. This study reassessed the pattern of online ivory
trade in Japan and highlighted areas where the lack of regulatory provisions still presents serious challenges.

SURVEY METHODOLOGY
Snapshot analysis

The methodology used by TRAFFIC8 in the 2014 study of online ivory trade on major Japanese e-commerce
platforms was again employed but extended to include several other major platforms in order to capture new
trends in e-commerce. The types of online platforms were categorized into: 1) shopping mall; 2) auction; 3)
CtoC market, with the latter being a new and growing form of online trading.
1) Shopping malls: Rakuten-Ichiba (http://www.rakuten.co.jp/), Yahoo Shopping(http://shopping.Yahoo.co.jp/)
2) Auction: Yahoo Auction (https://auctions.Yahoo.co.jp/)
3) CtoC markets: Mercari (https://www.mercari.com/jp/), Rakuma (https://rakuma.rakuten.co.jp/)
In May 2017, TRAFFIC collected sample webpages using a keyword “hon-zouge 本象牙 (genuine ivory)”
and analysed information on products offered, the status of compliance with the LCES, and the nature ofsellers/businesses. From the search results, every shop was sampled for shopping malls, while the top 100
advertisements were sampled for auction and CtoC market sites. Furthermore, whole ivory tusks weresearched specifically on Yahoo Auction and Mercari sites to check compliance with the LCES. The snapshot
survey was intended as a quick characterization and not as a comprehensive or representative sampling of
total ivory sales. These aspects were supplemented by the monitoring survey. (It should be noted that Rakuten,
Inc. later introduced a ban of ivory sales on Rakuten-Ichiba on 1st July 2017).

T RA F FI C BRI EF IN G PA PER

Monitoring survey

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Ivory trade was monitored on Yahoo Auction and Mercari for four weeks (8th May to 4th June 2017) torecord the types and number of products. For Yahoo Auction, records of successful bidding during this period
were retrieved using a keyword “zouge 象牙 (ivory)” (Yahoo Auction’s search engine allows viewing records
over the previous 120 days). For the CtoC market site, Mercari, new advertisement alerts containing “zouge(ivory)” as a keyword were checked every day using a smartphone app9. Advertisements were checked visuallyto ascertain the authenticity of the ivory, but descriptions by sellers were adopted when it was not clear fromthe photos. Individual items were counted separately when offered in the same lot unless multiple parts
comprised one functional unit (e.g. a pair of chopsticks, a pair of earrings, or a set of bridges for the koto,a traditional Japanese musical instrument). On Yahoo Auction, the total value of ivory trade was compiledusing final bidding price records of ivory items comprising almost exclusively of ivory (90% by appearance,
excluding wrappings, containers or pedestals). The results of sales and final price were not tracked on Mercari
due to the lack of search functions for this purpose. The currency rate of JPY1 = USD0.00900 (at 2nd June2017) was used.
5 Includes carved/uncarved, polished/unpolished tusks retaining the curvature of a tusk
6 CITES Decisions 17.92-17.96
7 Xiao, Y., Jing, G., and Xu, L. (2017). Wildlife Cybercrmie in China: E-commerce and social media monitoring in 2016. TFAFFIC, Briefing Paper
8 Matsumoto, T. (2015). A Review of Online Ivory Trade in Japan. TRAFFIC, Tokyo, Japan.
9 http://furimaalert.webcrow.jp/

RESULTS AND DISCUSSION
Overall results of search trends

The number of shops selling ivory nearly halved in the recent survey compared to 2014 on Rakuten-Ichiba(from 107 to 55 shops), but a similar number of shops were found on Yahoo Shopping (58 shops), which
was not surveyed in 2014. Search results on Yahoo Auction for “hon-zouge” (genuine ivory) increased by
52% compared to 2014 (from 2,737 hits to 4,158 hits). This increase follows a rise in the overall numberof advertisements on Yahoo Auction at a given time, which shifted from roughly 32 million in 2014 to 50
million in 201710. Thus, any increase in the number of hits for “hon-zouge” could simply reflect the generalexpansion of overall activity on this site. Of the two CtoC market sites surveyed for the first time in thepresent study, Mercari is substantially larger and returned numerous advertisements with the keyword,
though the total number of hits could not be determined due to the nature of the technology. Only 45
advertisements were found on Rakuma. It should be emphasized that the keyword “hon-zouge” for genuine
ivory is not designed to be exhaustive and, therefore, the actual number of ivory products on each site ismuch larger. Overall, the increased number of hits in Yahoo Auction may not be a good indicator, but theabundance of advertisements on new sites like Mercari indicates that online ivory trade in Japan is using
diversified channels since 2014, though identifying the definitive characteristics of this result is not possible atthis time.

Pattern of trade across online platforms

The snapshot survey revealed distinct patterns of online trade for shopping malls, auction and CtoC market
sites (Fig. 1). For shopping malls where new products are offered, hanko shops by far constituted the majority,
whereas on the auction site, furnishings such as carvings and netsukes were the largest product type followedby jewellery. These patterns were more or less similar to what was found in the 2014 survey. The third pattern
was found in the CtoC market sites, where ivory jewellery comprised the majority of items offered for sale,followed by carvings and furnishings.
A) ONLINE SHOPPINGC) ONLINE CtoC MARKETS

Figure 1. Types of ivory products advertised on Japanese e-commerce platforms in May 2017 searched using keyword “hon-zouge (genuine ivory)”:A) shopping malls (Rakuten-Ichiba (N=55), Yahoo Shopping (N=58)); B) auction (Yahoo Auction (N=100); and C) CtoC markets (Mercari (N=100),
Rakuma (N=45)). Products were categorized according to the scheme used by METI (Ministry of Economy, Trade, and Industry)11. The examplesof each category are listed in Table 1.
10 https://about.yahoo.co.jp/pr/release/2014/09/01a/ http://topic.auctions.yahoo.co.jp/promo/infographic/#exhibits
11 http://www.meti.go.jp/policy/mono_info_service/mono/paper_consumergoods/20150812tebiki.pdf

T RA F FI C BRI EF IN G PAPE R

B) INTERNET AUCTION

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The extensive availability of old ivory jewellery isa characteristic of Japan’s ivory antiques market
as a result of massive domestic production, as
well as import of such products during the 1970s
and 1980s. The rise of CtoC trading amongst
individuals using smartphones seems to haveprovided a ready channel for re-selling of suchantique items. While close to 70% of ivory
items offered on CtoC market sites were under
JPY10,000 (USD90), there were certain items
offered at a high price range of over JPY100,000(USD900) or even over JPY1 million (USD9,000)(Fig. 2), which were large, elaborate carvings.

ONLINE CtoC MARKET SALES PRICE(%)

Figure 2. Sales price of ivory items in online CtoC market advertisements
surveyed in May 2017 (Mercari (N=100), Rakuma (N=45)).

Trade monitoring

Four-weeks of monitoring revealed an active ivory trade on both Yahoo Auction and Mercari, but the former
dwarfed the latter in scale. A total of 9,788 items (an average of 2,447 per week) were sold on Yahoo Auction,
while 573 new items (an average of 143 per week) were advertised on Mercari. Given that the 9,788 items on
Yahoo Auction are actual transactions that occurred during the four-weeks, this represents a considerable
volume of traffic. Although actual sales on Mercari could not be tracked, 27% of items in the snapshot sample
were marked as “sold”. In Yahoo Auction, jewellery comprised the largest number (5,410 pieces), and a lotof them were offered in bulk. Similarly, there were bulk offerings of up to 70 hanko in a single lot. There
were also certain categories of products that were numerous, with ivory comprising only a small part of theitem in question, namely ivory lids on traditional pottery used in tea ceremonies and ivory weights used
for traditional hanging scrolls. Furthermore, everyday semi-processed ivory was sold on Yahoo Auction,amounting to a total of 59.5 kg of small pieces of various shapes and over 5,000 pieces (mostly beads) of
unknown weight. There were also a few offerings of semi-processed ivory on Mercari, including 1 kg of edge
pieces, 20 edge pieces and one slice of unknown weight. Whole ivory tusks were observed on both sites. A
total of 22 polished and carved tusks were sold on Yahoo Auction, whereas one polished tusk was advertisedon Mercari.
Table 1. Count of ivory containing items on Yahoo Auction (successful bidding records) and Mercari (new advertisements)
over a four-week period between 8th May and 4th June 2017. Multiple items sold in the same lot were counted individually.

Whole tusk

1 polished tusk

Weight known
Weight unknown
Jewellery : necklaces, earrings, brooches, string ties,
ornamental clasps for holding obi
Hanko : new hanko, carved/used hanko
Carvings & furnishings : netsukes, ornamental objects,
incense burners
Stationary : pens, paper knives
Smoking goods : pipes, cigarette holders
Buddhist articles : Buddhist prayer beads
Japanese musical instruments : bachis, shamisen, koto,tuning pegs for shamisen, bridges and plectra of koto
Other musical instruments : guitar saddles
Kitchen utensils : chopsticks, chopstick rests, toothpicks
Tea ceremony utensils : lids, teaspoons, tea canisters
Indoor amusement goods : Mahjong tiles, pool balls, dice
Daily goods : parts for hanging scrolls, shoehorns, fans,ear picks
Other : parts for Japanese swords
Total (excluding whole tusks and semi-processed ivory)

1 kg small pieces
21 small pieces

Yahoo Auction(successful bids)
22 tusks (polished/carved)59.5 kg small pieces
5,262 small pieces

417

5,410

25

1,000

18

974

0
4
1

8
329
18

23

387

2
31
16
10

26
325
394
50

26

845

0
573

22
9,788

Category of ivory containing items

T RA F FI C BRI EF IN G PAPE R

Semi-processed pieces

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Mercari(new advertisements)

Looking at the price range of sales on Yahoo
Auction, 42% were less than JPY5,000 (USD45),
followed by 30% between JPY10,000 to 50,000(USD90 to 450) (Fig. 3). Items sold at the highend of the price ranges were figurines and wholetusks. Finally, the total trade value of ivory items
on Yahoo Auction over the four-weeks amounted
to over JPY45.2 million (USD407,000). Of these,
whole tusks represented only 2% and semiprocessed ivory 6% of the trade by value. The
remaining 92% of the trade comprised otherproducts consisting largely of ivory jewellery,carvings and furnishings. It should be kept inmind that both counts and trade value recorded
here may include some fake ivory as it is
impossible to distinguish genuine products withcertainty through online advertisements. In fact,
offerings of mammoth ivory figurines were also
observed with explicit identification as mammoth
ivory. Furthermore, it is known that netsukes(small Japanese traditional figurines) made of
mammoth ivory as well as other animal tusks,
bones, or antlers are sometimes difficult todistinguish from elephant ivory.

YAHOO AUCTION SALES PRICE

Figure 3. Sales price of ivory items on Yahoo Auction monitored overa four-week period between 8th May and 4th June 2017. Only items
comprising almost exclusively of ivory (90% by appearance, excluding
wrappings, containers or pedestals) were included.

BUSINESS NOTIFICATION NUMBER

Comparison with 2014 data revealed asignificant improvement in the LCES complianceregarding obligatory business notifications12,
with 88% and 85% on Yahoo Auction and
Rakuten-Ichiba, respectively, displaying
notification numbers in 2017 compared to thesmall minority (11% and 22%, respectively) that
did so in 2014 (Fig. 4). While a majority indeed
operated without making notifications in 2014,
all but three shops in Yahoo Shopping who
sold smaller pieces of ivory (e.g. ivory handled
Figure 4. Comparison between May 2014 and May 2017 of thevisibility of notification status on respective websites. Yahoo Shopping
knifes, accessories, shoehorns) were confirmed
was not surveyed in 2014. Numbers indicate the counts of businesses
to have made notifications in 2017. Upon noticeunder each category: Rakuten-Ichiba (N=107, N=55); Yahoo Auction(N=19, N=24); Yahoo Shopping (N=58).
from TRAFFIC, Yahoo notified these three
shops about their state of non-compliance withivory trading regulations and, as of 27th June 2017, one of them had removed all ivory products and anotherdisplayed a newly issued notification number. The actual notification status of the three shops on Yahoo
Auction could not be checked due to lack of business information.
This significant improvement comes as a result of monitoring initiatives taken by e-commerce companies
following the publication of TRAFFIC’s first report in 2014. In addition, regulatory requirements have also
been strengthened by the government to upgrade the notification system into a proper registration system,
making display of a company’s registration number obligatory, and guaranteeing public access to information
12 LCES mandates all businesses that manufacture, trade, or retail in ivory products apart from whole tusks to notify METI. All such businesses receive a sticker showing
a designated operator’s number and are obligated to record all transactions and resulting balances of stockpiles and submit them to METI on a regular basis. The 2017
LCES amendment upgraded this notification scheme to a “registration” scheme with enhanced penalties, which will be enacted sometime in 2018.

T RA F FI C BRI EF IN G PAPE R

2014-2017 comparison oflegality signs

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on registered businesses. These new reforms will beenacted in 2018.

T RA F FI C BRI EF IN G PAPE R

In contrast, usage of the government-issued
voluntary product certification system remained
unchanged from the 2014 survey (Fig. 5). Whilst
the actual use of product certificates could behigher than their visibility on websites, current
evidence suggests that product certification does
not constitute an effective tool for establishing thelegality of worked ivory items marketed throughonline trading. However, the government has not
yet considered reviewing the certification schemeand there are no moves to establish a compulsory
certification system to ensure the legality of worked
ivory products.
The only type of ivory in which trade of individual
items is regulated concerns whole tusks. Of the
27 whole tusks offered at the time of the snapshot
survey on Yahoo Auction, all but four tusks wereaccompanied by the registration cards required
under the LCES, whereas on the Mercari site,
the emerging CtoC market giant, only three outof nine tusks were accompanied by the requisite
registration cards (Fig. 6). The higher rate ofcompliance with the registration card system on
Yahoo reflects the concerted effort by that company
to conduct regular monitoring of whole ivory tusks
to ensure registration. In fact, every whole tusk
found with keyword “hon-zouge (genuine ivory)”in Yahoo Auction’s successful biddings records hada registration card, highlighting the effectiveness of
their monitoring programme. On the other hand,
it remains a possibility that platforms with looser
monitoring and enforcement could provide an
opening for illegal trade. Across both websites, manyof the offers without registration cards were tuskswith extensive curvature, pointing to a possibility
that sellers would not necessarily have recognizedthem as “ivory tusks”. In any case, there remain
enforcement challenges in the trade of whole tusks.

PRODUCT CERTIFICATION

Figure 5. Comparison of voluntary product certification use
between May 2014 and May 2017 for Rakuten-Ichiba (N=107,
N=55). Yahoo Shopping was only surveyed in 2017 (N=57).
Numbers indicate the count of businesses indicating that they
provide product certifications. “Wrong use” was where the imageof a product certification seal was displayed along with businessnotification numbers as though it was a certificate of business
operation.

WHOLE TUSK REGISTRATION

Figure 6. Number of whole tusks offered on Yahoo Auction andMercari at the time of the snapshot survey (using keyword “honzouge (genuine ivory)”) in May 2017 and their accompaniment oflegal documents (registration cards)

Regulatory loopholes

The lack of control over CtoC trading has become
evident in the current study, both on internet auctionand emerging online CtoC markets. While nearly
half (22 out of 47) of the auction sellers on Yahoo
Auction did not identify themselves as businesses,
most of them (18 out of 22) could be inferred to beusing internet auctions for commercial purposes

Figure 7. Identities of sellers offering ivory items on Yahoo Auction
in a snapshot survey in May 2017 (N=47). For sellers appearing as
individuals (no indication of business entities), their list of otheractive auctions was checked to deduce if they were merely selling off
Yahoo
Auctionpersonal items or using
the auction
sitesellers
for business.
Implied business
2%

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OperatingAppears

Of those appearing
as individuals

rather than selling off personal items, based on the list of other auctions they were holding (Fig. 7). Althoughnone of them specialized in ivory, they held at least 25 active auctions simultaneously (up to 1,480 lots) of
mostly antiques and collectables. Two shops had fewer simultaneous active auctions (8 and 16 respectively),
but sold only highly specialized products which were unlikely all to be personal belongings (i.e. parts ofJapanese swords and Japanese musical instruments, respectively); thus, they were grouped with sellers likely
using auction sites for business. Although it cannot be determined from the snapshot survey what proportionof individual sellers trade ivory items regularly, at least four out of 22 sellers “appearing as individuals” offeredmultiple ivory items. Furthermore, the snapshot survey of CtoC markets also revealed a significant proportionof sellers offering multiple ivory items (23% and 25% in Mercari and Rakuma, respectively) and some sellers
are evidently operating businesses on these platforms, even promoting ivory items for their increasing rarity.
These findings highlight the need for the government to scrutinize ivory businesses operating online to ensure
effective enforcement of the strengthened ivory business regulations brought forth through recent LCES
amendments.

Figure 8. Examples of ivory jewellery offered on Mercari with clear statements about their recent origin (from left to right: “bought four years
ago with a necklace in Thailand”, “bought several years ago in Thailand”, “My uncle went to Congo in Africa with work and brought back as asouvenir….received five years ago”).

T RA F FI C BRI EF IN G PAPE R

Furthermore, whether the sellers function as a business or not, the lack of regulation for products other thanwhole tusks was found to present severe challenges in identifying and preventing illegal ivory flows. For
example, surveyors found on Mercari a few advertisements for ivory jewellery recently brought back from
Asia and Africa with explicit statements about their origins (Fig. 8). While these are clear infringements of
CITES regulations, their domestic sales remain legal under the LCES, which allows them to be traded without
any requirement for proof of legality (e.g. CITES import permit or the LCES registration)—unless they arewhole tusks, in which case only registered pre-Convention tusks can be traded legally. Therefore, since bothpre- and post-Convention ivory products can be freely traded without any requirement of proof, it is often
impossible to be sure that a particular ivory item is of bona fide pre-Convention origin, especially for ivory
jewellery as well as certain types of figurines with carving styles different from traditional Japanese motifs.
Although the extent of illegal import seen in the above examples remains unknown, there is a clear and urgent
need for appropriate regulation and awareness-raising amongst Japanese tourists and consumers domestically.

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In sum, the coverage of the current LCES regulation with respect to online ivory trading is patchy at best
as only business operations and trade in whole tusks are subject to the law (Table 2). In terms of sellers,
unidentified businesses and individuals widely trading in auctions and CtoC market sites currently remain
outside the regulatory radar. In terms of products, whole tusks represent a tiny proportion of the tradeoffered on almost all websites, so the large quantities of other products traded by non-business sellers are
therefore completely outside of the LCES control. This situation is of concern given the active online trading
and difficulties in discerning bona fide pre-Convention items. Whilst the current study investigated only
the online aspect of ivory trade on major e-commerce platforms in Japan, the extent of domestic ivory tradefalling outside the current control system is significant when all forms of online ivory trading, such as social
networking sites, and physical trading are taken into account. TRAFFIC intends to conduct further research
into Japan’s domestic ivory market.
Table 2. Summary of applicable LCES regulation on each e-commerce model
Online Shopping Malls
Regulation of sellers

Yes (businesses)

Regulation of tradedproducts

Only whole tusks andlimited use of voluntary
certifications in hanko

Internet Auction
Yes/No (businesses andindividuals mixed)
Only whole tusks, noregulation for otherproducts

Online CtoC Markets
No (individuals)
Only whole tusks, noregulation for otherproducts

RECOMMENDATIONS
In spite of the methodological limitations in establishing the scale of online trade through monitoring surveys,
the apparent significant number of ivory products being offered and traded online in Japan is of concern. The
CITES Parties, in Resolution Conf. 10.10 (Rev. CoP17) on Trade in elephant specimens adopted in October
2016, recommended:… that all Parties and non-Parties in whose jurisdiction there is a legal domestic market for ivory that iscontributing to poaching or illegal trade, take all necessary legislative, regulatory and enforcement measures
to close their domestic markets for commercial trade in raw and worked ivory as a matter of urgency;
RECOGNIZES that narrow exemptions to this closure for some items may be warranted; any exemptions
should not contribute to poaching or illegal trade;
URGES those Parties in whose jurisdiction there is a legal domestic market for ivory that is contributing topoaching or illegal trade and that have not closed their domestic ivory markets for commercial trade in ivory
to implement the above recommendation as a matter of urgency;

T RA F FI C BRI EF IN G PAPE R

FURTHER URGES those Parties in whose jurisdiction there is an ivory carving industry, a legal domestic
trade in ivory, an unregulated market for or illegal trade in ivory, or where ivory stockpiles exist, and Parties
designated as ivory importing countries, to ensure that they have put in place comprehensive internal
legislative, regulatory, enforcement and other measures to:8a) regulate the domestic trade in raw and worked ivory;b) register or license all importers, exporters, manufacturers, wholesalers and retailers dealing in raw or
worked ivory;c) introduce recording and inspection procedures to enable the Management Authority and otherappropriate government agencies to monitor the movement of ivory within the State, particularly bymeans of:i) compulsory trade controls over raw ivory; andii) comprehensive and demonstrably effective stock inventory, reporting, and enforcement systems forworked ivory;

As a CITES Party, Japan has an obligation to fulfill these requirements effectively to ensure that domestic
trade in ivory does not contribute to poaching or to illegal trade. Internet trading channels are creating new
regulatory challenges for Japan and need to be addressed with urgency.

TRAFFIC recommends the following:• The Japanese government should assess the feasibility of installing stricter measures to address all
aspects of its internal ivory trade effectively, including trade in all product types (whole tusks orpieces, and all forms of worked ivory), new and old, and trade by and amongst non-business entities.
• The Japanese government should urgently capture the identities of, and register sellers offering ivory
through online platforms. CITES requirements explicitly call for the registration or licensing of “all… wholesalers and retailers dealing in raw or worked ivory”. Failure to do so would be considered noncompliance with CITES Resolution Conf. 10.10.
• E-commerce companies and relevant ivory industry stakeholders should consider adopting stricter
measures than LCES provides, with an aim to preclude ivory of illegal origin being traded without
legal consequences. To this end, e-commerce platforms should consider banning online ivory trade.
• E-commerce companies and NGOs should assist in awareness-raising amongst users of e-commercesites not only to disseminate CITES and LCES regulations but also to mainstream the issues of illegal
wildlife trade and wildlife cybercrime as a serious crime.

TRAFFIC, the wildlife trade monitoring network, is the leading non-governmental organization working
globally on trade in wild animals and plants in the context of both biodiversity conservation andsustainable development.
For further information contact:
TRAFFICJapan Officec/o WWF
6Fl. 3-1-14 Shiba, Minato-Ku, 105-0014
Tokyo, JAPANT RA F FI C BRI EF IN G P AP ER

Telephone: (81) 3 3769 1716
E-mail: TEASjapan@traffic.org
n-governmentalorganization
working
Website:www.traffic.org(EN)biodiversity conservation
andwww.trafficj.org(JP)
UK Registered Charity No. 1076722,
Registered Limited Company No. 3785518.

is a strategic alliance ofThis project was supported by WWF Japan©1986 Panda symbol WWF ® “WWF” is a WWF Registered Trademark

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