BLOG: Japan, Ivory, & CITES SC78

• 03/02/2025
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By Amy Zets Croke (EIA Senior Manager, Wildlife Campaigns) and Masayuki Sakamoto (JTEF Executive Director)

Among many other important issues relevant to keeping elephants safe from international commercial trade, domestic ivory markets were on the agenda at the 78th meeting of the CITES Standing Committee (SC78).

To protect elephants, countries endorsed and encouraged the closure of domestic ivory markets to support the international ban on commercial ivory trade in 2016 at the 17th meeting of the Conference of the Parties (CoP17) to CITES. Specifically, Parties agreed by consensus to language in Resolution Conf. 10.10 (Rev. CoP19) paragraph 5 that “urges those Parties in whose jurisdiction there is a legal domestic market for ivory that is contributing to poaching 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.”

The closure of domestic markets has made a difference. In the UNODC’s 2024 World Wildlife Crime Report, it was determined that government policies leading to the closure of key domestic markets have constrained demand and have contributed to the recent shrinking of the ivory market, documented by the collapse in the price of ivory, decreasing seizures of ivory, and decreasing elephant poaching figures.

While most of the Parties previously regarded as major ivory consumers have already taken steps to close their markets for commercial trade in ivory except for narrow exemptions for some items, Japan alone still authorizes a significant legal market for commercial trade in a wide variety of ivory items. Domestic legal markets are vulnerable to the risks associated with illegal international trade in ivory, particularly the illegal export of ivory to other countries.

At SC78, two items related to domestic markets were on the chopping block. The CITES Secretariat suggested deleting decisions agreed to at CoP19 to bolster the implementation of provisions to close domestic ivory markets. Specifically, the Secretariat suggested 1) deleting decisions requiring Parties with legal ivory markets to report on how those markets are not contributing to poaching and illegal trade (Decisions 18.117-119, Rev. CoP19) and 2) deleting decisions compelling the analysis of seizures related to Parties with legal domestic ivory markets (Decisions 19.99-19.101 Rev. CoP19).

EIA and JTEF believe that countries, like Japan, that choose to maintain legal ivory markets in contravention of CITES-endorsed recommendations should be held accountable and obligated to report on truly effective measures they take to control their markets. Illegal exports of ivory from Japan to other jurisdictions with closed markets complicate law enforcement efforts to control the illegal trade, undermine behavior change campaigns that seek to reduce demand for illegal ivory, and ultimately demonstrate the urgent need to close Japan’s market. Due to its large exemptions, Japan’s regulatory framework is in fact designed to facilitate commercial trade in ivory products rather than restrict it. Japan has large stockpiles of raw and worked ivory and thousands of government-authorized ivory traders operating in the country.

From this legal domestic market with limited border enforcement, ivory items have continually flowed illegally to other countries. ​​EIA documented a steady flow of ivory exported from Japan between 2018 and 2020, primarily to China, based on publicly available information. Starting in 2021, public information on ivory seizures made by China Customs became limited. In a 2022 analysis of Chinese court verdicts for ivory trafficking cases involving Japanese ivory, JTEF found that many cases qualified for the designation of serious crime as defined in the United Nations Convention against Transnational Organized Crime (UNTOC) – there are coordinated efforts underway to export ivory from Japan.

The influx of international visitors, particularly to Tokyo as the center of Japan’s ivory trade, also warrants concern. Though the government has an awareness campaign intended to inform tourists that exporting ivory is illegal, that increased awareness does nothing to stop those intent on illegally exporting ivory. In 2020, a study of Chinese travellers to Japan found that 19 percent planned to purchase ivory products and an estimated 12 percent actually did make an ivory purchase and brought that ivory back to China. The annual number of foreign visitors to Japan in 2024 was almost 37 million, setting a new record high, and it is clear that some travellers are intent on bringing ivory back to their home countries.

In addition to supporting the decisions compelling Parties with legal markets to report on their ivory trade control measures, EIA, JTEF, and allies have been advocating for the completion of the analysis of ivory seizures related to legal markets to further bolster the recommendation for Parties with legal ivory markets that contribute to poaching or illegal trade to close them urgently – with a focus on Japan. Understanding the extent and nature of seizures linked to Japan would help inform Parties determine appropriate next steps for evaluating Japan’s implementation of Res. Conf. 10.10 (Rev. CoP19). 

To help Parties determine whether a domestic ivory market is contributing to international ivory trafficking, Parties at CoP19 agreed to conduct an analysis of CITES data on ivory seizures, contained in the Elephant Trade Information System (ETIS), linked to Parties with legal domestic ivory markets, provided that it was feasible. EIA and JTEF had been advocating for this analysis with the goal of making seizure data from the Elephant Trade Information System (ETIS) publicly available at the country level, and thus, in advance of SC78 had recommended that the SC establish a working group to further assess options to pursue the analysis. However, at SC78, Parties decided to forgo the analysis because agreement could not be reached on how to determine which Parties among the many which authorize limited trade in some ivory items should be included in the analysis.

While we believe the analysis was feasible, and that there were viable options for completing it, the outcome is acceptable because a newly launched tool on the ETIS Online platform transparently provides aggregate county-level data to the public. In the case of Japan, the ETIS data clearly demonstrates that it is contributing to illegal international ivory trade. According to the ETIS data, during the 10-year period between 2010 and 2019, before the significant global disruptions of the pandemic in 2020, there were 257 documented seizures connected to Japan.

Regarding the important decisions directing Parties with legal domestic ivory markets to report on measures taken to ensure they are not contributing to poaching or illegal trade, the Standing Committee agreed to renew them. The CITES Secretariat had recommended that the Standing Committee delete these decisions; however, Kenya made a strong case against doing so, underscoring how the implementation of these decisions reinforces the international ban on commercial ivory trade and proposed that the decisions be renewed at CoP20. Kenya’s proposal received strong support on the floor from Senegal, Benin, Niger, Sudan, the United Kingdom, and Israel. We are pleased that the Parties will continue to support the implementation of Res. Conf. 10.10 (CoP19) by continuing the reporting requirement.

Japan voiced the only opposition on the floor, arguing their view that CITES should focus on international trade, despite the clear language contained in the CITES resolution on elephants – which Japan agreed to at CoP17 – calling on Parties to close domestic ivory markets contributing to poaching or illegal trade. Japan also claimed that their stockpiles are old and controlled by strict measures, even though JTEF and EIA have repeatedly pointed out the flaws in their ivory trade controls. While there is currently no evidence in Japan of illegal trade in the form of a large-scale ivory seizure, that evidence is not the only reason to close the market – a market’s significance as a potential source of ivory for illegal export should also be considered.

In today’s global world, all markets are linked, and it is important to limit the risk of ivory being purchased legally in Japan and then exported to other countries, thus fueling the demand for ivory items and undermining others’ demand reduction and enforcement efforts.

Japan has an opportunity right now to turn the tide and take action to close its domestic market for ivory – the government is in the middle of a statutory review of its domestic law, the Law/Act for Conservation of Endangered Species of Wild Fauna and Flora (‘LCES’ or ‘ACES’). We urge the Government of Japan to revise the domestic law to prohibit commercial trade in elephant ivory, effective in 2026, and to announce its intentions at CoP20 later this year to send a strong signal to the international community that Japan’s consumer role in the international ivory trade is over.

Check out www.stopjapanivorytrade.org for more information about Japan’s ivory trade.