Online elephant ivory market surveys in the European Union

October 2020

Louisa Musing and Shaliza Malik

A TRAFFIC Report prepared for the European Commission

Contract No. ENV.F.3/SER/2019/0020

Online elephant ivory market surveys in the European Union

Report prepared by TRAFFIC for the European

Commission under Contract No.

ENV.F.3/SER/2019/0020

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Suggested citation:

Musing, L. and Malik, S. (2020). Online elephant

ivory market surveys in the European Union. A

TRAFFIC report prepared for the European

Commission.

ISBN: 978-1-911646-28-0

Online elephant ivory market surveys in the European Union

TABLE OF CONTENTS

1. BACKGROUND .................................................................................................................................... 4

2. METHODOLOGY .................................................................................................................................. 5

2.1 Online surveys .............................................................................................................................. 5

2.1.1 Online sales platforms .......................................................................................................... 5

2.2.2 Survey effort .......................................................................................................................... 6

2.2.3 Considerations and potential biases .................................................................................... 9

3. RESULTS ............................................................................................................................................ 10

3.1 Number of ivory items offered for sale online .......................................................................... 10

3.2 Product types.............................................................................................................................. 11

3.3 Provenance ................................................................................................................................. 14

3.4 Percentage of ivory .................................................................................................................... 14

3.5 Weight of ivory items ................................................................................................................. 16

3.6 Age of ivory items ...................................................................................................................... 19

3.6 Price of ivory items - summary .................................................................................................. 21

3.6.1 Fixed/retail price ................................................................................................................. 24

3.6.2 Auctioneer’s estimate ......................................................................................................... 26

3.6.3 Bids and reserve prices ....................................................................................................... 27

4. DISCUSSION ...................................................................................................................................... 29

5. CONCLUSIONS .................................................................................................................................. 32

6. ANNEX 1 – METHODOLOGY – FURTHER DETAILS ............................................................................ 33

6.1 Sampling the Member State markets to survey ....................................................................... 33

6.1.1 Overview of stratified random sampling ........................................................................... 33

6.1.2 Analysis for stratified random sampling ............................................................................ 33

6.1.3 Results from stratified random sampling ........................................................................... 42

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1. BACKGROUND

In the context of the ongoing discussions on possible further restrictions to the European Union’s (EU)

elephant ivory (hereafter “ivory”) trade, a desk-based online EU ivory market survey was endorsed by

the European Commission and the EU Member States1 at the 16th Meeting of the Group of Experts of

the competent CITES Management Authorities (ExGr16) in December 2019. Due to the lack of ex-ante

control by authorities on commercial intra-EU trade for pre-1947 worked ivory items, it is difficult to

obtain reliable information and data on different product types and value of objects in intra-EU trade.

The aim of conducting these online market surveys was therefore to gather representative

information on the characteristics of the current intra-EU ivory market to understand better:

the proportion of different product types, including pre-1947 “antiques”, available on the

market;

the ivory items that could qualify as “de-minimis”2, depending on whether a weight or volume-

based qualification would be implemented and therefore be exempt from requiring an intra-

EU trade certificate;

price (EUR) of ivory items available for sale in the EU market and the proportion of “cheaper”

ivory items, i.e. those of smaller historic, artistic, or cultural value, which would likely not

continue to be traded due to the additional burden on traders/dealers to apply for permits.

This study did not aim to quantify the scale of the EU internal market but further details on the

elements listed above will inform the proposals to further regulate EU ivory trade.

Following the 88th meeting of the Committee on Trade in Wild Fauna and Flora and ExGr17, an informal

meeting of CITES experts was organised by the European Commission for the EU Member States on 5

March 2020. At this meeting, a set of changes to the existing EU ivory trade rules were proposed by

the European Commission for consideration by the Member States, including the requirement for a

certificate to be issued for all worked specimens (regardless whether it is pre-1947 or not) in

commercial intra-EU trade, except for “de-minimis” items. These de minimis items would be traded

without a certificate if they were pre-1947 antiques or pre-Convention. The exact definition of the

“de-minimis” items still needs to be established, based on input from Member States as well as

relevant stakeholders, however as a starting point a volume based (less than 20%) qualification for

specimens with ivory content would first be considered. The proposal is also considering whether

subsequently to include an additional weight-based qualification3 for those items with more than 20%

ivory. The proposal also seeks to restrict re-export of worked specimens to commercial trade in

musical instruments that are used as part of the livelihood of an individual, and pre-1975 worked

specimens where the item is a recognised piece of art. For these objects, the CITES Management

Authority would have to be satisfied that the value is significantly higher than that of the ivory it

contains, due to its craftsmanship, rarity, and/or artistic and cultural value4.

1 As of 31 January 2020, the United Kingdom withdrew from the European Union and is no longer an EU Member State. The project was designed prior to the UK’s exit from the EU. 2 Those items that contain a small quantity of ivory. 3 Note: This would mean that the percentage is looked at first. If the ivory content is less than 20%, the item is exempted and can be traded

without a certificate. If the ivory content is higher than 20% (including items made 100% of ivory) then the weight of the ivory is looked at

and if it is lower than certain weight threshold the item can also be traded without a certificate. 4 Language still to be refined.

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Examining the proportion of more high-end, expensive artistic pre-1947 “antiques” and pre-

Convention items, that would potentially be re-exported from the EU under the proposed changes,

was not the aim of the study. While craftmanship, rarity and/or artistic and cultural value cannot be

ascertained simply from the monetary value of an item, relevant information on the proportion of

more expensive items on the intra-EU market was examined where possible. The aim was to provide

insight into the proportion of “expensive” worked ivory items currently available on the EU market

that traders would likely apply for authorisation to re-export commercially if further regulatory

measures were put in place.

2. METHODOLOGY

A rapid online assessment of a sample of the EU’s internal ivory market was conducted between

March and May 2020. This rapid assessment involved surveys of offers of ivory for sale on online sales

platforms, such as antiques and auction websites, in selected EU Member States.

The domestic ivory markets in each of the EU Member States vary considerably, with some having

historical trade links with African/Asian countries and an “ivory culture” which has over the years

resulted in individuals and traders accumulating significant ivory collections. Therefore, to survey a

representative sample of the EU’s internal ivory market, stratified random sampling5 was used (see

Annex 16). Following this categorisation, two Member States from each of the groups (Group One,

Group Two and Group Three) were randomly selected using an online random selection tool7. The

random selection was conducted on 20 March 2020 and the following six Member States were

selected:

Group One (small): Czech Republic and Luxembourg

Group Two (medium): Austria and Belgium

Group Three (large): Germany and Italy

2.1 Online surveys8

2.1.1 Online sales platforms9

For each of the six Member States selected to survey, up to five different online sales platforms per

Member State were surveyed. The purpose of the study was to survey ivory items found offered for

sale across a representative sample of the EU market (see above), therefore online sales platforms

known to sell ivory items at the national level were selected. The online sales platforms for each of

the six Member States were identified in two ways: by directly consulting the CITES Management

Authorities of the six Member States on known antiques auction websites and online marketplaces

that sell ivory at the national level (including national or regional e-commerce sites known to sell

5 Stratified random sampling is a method of sampling that involves the division of a population or dataset into smaller sub-groups known as strata. In stratified random sampling or stratification, the strata are formed based on members' shared attributes or characteristics such as income or educational attainment. See: Levy, P.S and Lemeshow, S. (2008). Sampling of Populations: Methods and Applications. Fourth Edition. John Wiley & Sons, Inc; https://www.investopedia.com/terms/stratified_random_sampling.asp 6 This document contains restricted EU-TWIX data and should not be shared publicly without consent from the EU Member States 7 https://wheelofnames.com/ 8 On 19 March 2020, a pilot survey was conducted to test the methodology outlined. 9 A platform accessed via a web address including, but not limited to, the following: social media websites, e-commerce websites and online forums.

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ivory), and through additional research on several online search engines. Those websites with the

largest collections of ivory items at the national level were surveyed. The types of websites surveyed

were as follows:

Antiques auction consolidation websites, where auction “lots” from different auction houses

can be viewed in one place. These sites allow products to be advertised for customers to place

bids on and purchase as a type of online auction;

Online auction houses or antiques websites. On these retail sites, items were typically

advertised at a fixed price, sometimes with an opportunity for the customer to negotiate; and

General e-commerce sites known to sell ivory at the national level10 (mainly identified by the

CITES Management Authorities).

The purpose of this study was to understand the characteristics of the current intra-EU ivory market,

therefore the analysis focuses on the EU market as a whole and does not provide extensive analytical

detail of the characteristics of the ivory markets for each of the six countries.

2.2.2 Survey effort

The online sales platforms selected for each of the six Member States were surveyed twice at different

periods of time to try and avoid duplication and too narrow sampling across the markets:

Survey One was conducted for 6 days starting in March (30 March – 4 April); and

Survey Two was conducted for 6 days one month later (27 April – 2 May)

For each of the online sales platforms, up to the first 50 items of ivory were surveyed and recorded. A

maximum of one day (approx. 8 hours) was spent on each of the six Member States per survey. For

each online sales platform across the six Member States, the search term “ivory” was entered in the

national language11 to yield results12. Items of ivory colour were excluded from the results, as were

other ivory items, such as that derived from whale teeth, and walrus, hippo, and mammoth tusks as

far as possible.

For each elephant ivory item listed for sale, the following information was recorded, if available:

product type,

estimated percentage of ivory in the item,

price,

age,

weight,

10 Where relevant, the results from the e-commerce sites were filtered to yield country level results. The international e-commerce site e-Bay was not included as the focus of these surveys were online sales platforms selling ivory at the national level and the challenges with delineating geographic scope of the site. 11 The CITES Management Authorities of the six Member States confirmed the correct and/or most relevant search term for “ivory” in the national language, where relevant. 12 The only exception was for Belgium’s results on the Salesroom where the English search term “ivory” was used. This was because more listings were found using this search term than for the national languages. Note: all listings were filtered at the country level to ensure only those results in Belgium were identified.

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dimensions,

provenance,

additional materials on the ivory items that may affect their value,

images were also downloaded.

Product types were categorised into groups of ivory items (for example, figurines/sculptures, ivory

jewellery, furniture, pipe, container/vessel, knife, etc.) and in accordance with four CITES description

codes (IVC – ivory carvings, IVJ – ivory jewellery, WPR – wood products; PKY – piano keys) for analytical

purposes only (Table 1). An item was classified as a “wood product containing ivory” when the items’

structure was a wood-based product e.g. a wooden box or piece of wooden furniture with ivory inlay

or ivory as adornment. An ivory item containing wood was classified as an “ivory carving” when the

wood was not the main part of the items’ integrity but an additional material e.g. a base or mount for

an ivory item.

Table 1. Classification of the different types of ivory products found offered for sale

CITES description code Item types Examples(s) if relevant

Ivory carvings Ashtray

Book cover Prayer book with ivory cover

Brush Hairbrush

Candle holder

Carved panel

Carved tusk Worked ivory tusk

Chess set

Cigarette holder

Container/vessel Bowl, box, chalice, cup, jug, tea set, vase

Crucifix

Cutlery Spoon, cutlery with ivory handle, cutlery set

Fan

Figurine/sculpture Netsuke, okimono, statue, decorative figure

Flute

Frame Picture frame

Furniture Furniture item made entirely of ivory

Ivory painting Miniature painting

Knife Ivory handle on knife

Mirror

Other Child’s rattle, candle holder, ivory billiard balls, decorative carving, paperweight, dominos, bookmark, ivory holder with pin cushion

Pipe Smoking pipe

Pistol handle

Rosary

Stationary Letter opener, ruler, seal, stamp, pen

Sword Ivory handle on sword

Thermometer

Walking stick Handle of walking stick

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Ivory jewellery Jewellery Bangle, bracelet, brooch, necklace, pendant, jewellery set

Piano keys Piano Keys Ivory piano keys

Wood products Carved Panel

Clock

Compass

Container/vessel Jewellry box with ivory inlay

Crucifix Wooden crucifix with ivory inlay

Figurine/sculpture Combination figure with wood and ivory

Furniture Piece of furniture with ivory inlay

Other Wooden panel with ivory inlay

Pipe

The percentage of ivory in each item was recorded using a grid overlay system on the downloaded

image to determine the quantity of ivory. The most complete image of the item facing forwards was

downloaded, then a grid overlay was placed over the image to quantify the total number of squares

that the item covers (see Figure 1). The number of squares that contain ivory (Figure 2) were calculated

and transformed into a percentage. Figure 1 indicates a total of 85 squares covering the whole item.

Figure 2 indicates a total of 58 of the squares contain elephant ivory. This equates to ca. 68% of the

item containing elephant ivory. All percentages were only approximate calculations (see section 2.3

for issues to consider when examining the percentage of ivory in an item). For those items that the

percentage of ivory could not be measured (for example if there is no complete image available), then

these were excluded from the results.

Sets of ivory items (for example a tea set, a set of cutleries or a pair of figures) were included in the

results. However, online sales listings which included multiple items that were not a set, or a pair,

were excluded as collecting accurate information on the price of these items would not have been

possible.

Figure 1. A grid overlay covering the image of an

antique ivory item. The white lines indicate squares

covering the whole item.

Figure 2. A grid overlay covering the image of an

antique ivory item. The orange lines indicate squares

covering ivory in the item.

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2.2.3 Considerations and potential biases

When conducting any online or physical market survey, it is highly unlikely to avoid and eliminate all

potential bias that may impact the results of the survey. Below is an outline of the various issues that

need to be taken into consideration when examining the results of the online EU ivory market surveys.

Narrow sampling

Only conducting online surveys does not account for the full range of ivory items available for

sale on the physical EU market, potentially excluding both less sought-after common items

and very high value art pieces more likely to be sold by physical auction houses..

Only six Member States were surveyed over a total of 12 days. This is a relatively small sample

size and a short period of time to gather a comprehensive picture of the EU’s domestic ivory

market. Therefore, the results from these surveys should only be considered as a snapshot of

the ivory items available on the EU market.

Surveying online sales platforms

Due to the nature of online sales platforms, it is difficult to confirm whether the items listed

for sale were indeed physically in that country.

It was challenging to identify the five different online sales platforms for each of the Member

States selected, to give a fair representation of the market (e.g. both high end items and

smaller “cheaper” items).

Online sales platforms always have some bias towards items that are likely to fetch the highest

prices and so underrepresent “cheaper” ivory items while one of the aims of this survey was

to understand how many “cheaper” items there are in the domestic ivory market that traders

may not apply permits for (if the exemption in Article 62(3) were lifted).

Auction houses/antiques dealers will likely have to pay a premium to advertise on these online

platforms which may exclude some of the smaller auction houses/antiques dealers.

The information on the online sales listings e.g. the age of the item, were taken at “face value”

and could not be independently verified.

Duplicates

Avoiding duplication of ivory items listed on different platforms for sale is challenging. For

example, several companies/traders use more than one of the online marketplaces to offer

their ivory items for sale. Duplicates from these sites were identified and removed, as far as

possible.

Percentage of ivory

Accurately calculating the percentage of ivory in an item when it cannot physically be

seen/inspected poses several challenges, for example, the method used in this survey does

not account for the ivory in an item that cannot be seen in the downloaded image. Therefore,

all percentages listed are approximate calculations only.

Price

For some listings, the price of the item may be fixed (e.g. an item listed for sale on an antiques

website). However, for those items listed on auction sites, the price may vary from the

opening price for the item, the auctioneers estimate, live bids or the “hammer price” (the final

price the item was sold for). For the purposes of this survey, all prices were recorded to gather

as much information as possible.

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COVID-19

The outbreak of COVID-19 may have impacted people’s spending and buying habits across the

EU as well as the ability of auction houses and online marketplaces to sell items. During the

pilot survey (19 March 2020), it was noted that the pandemic seemed to be affecting some

online auction houses with some sites reporting to have ceased trading for the time being

during the health crisis. Nevertheless, many websites continued to trade with numerous

active listings, therefore it was deemed prudent to continue with the surveys.

3. RESULTS

Surveys of the online EU ivory market focused on two types of websites: antiques auction

consolidation websites and online auction houses or antiques websites. The online auction

consolidation site, The Salesroom13, was surveyed for three of the six EU Member States (Austria,

Belgium, and Germany)14. It is important to note that Survey Two was impacted by COVID-19, as fewer

items were listed for sale compared with Survey One. In the case of Luxembourg, some of the auction

websites were postponed due to COVID-19, therefore the second survey of the selected online sales

platforms was not repeated as only duplicates from Survey One were found in that country.

3.1 Number of ivory items offered for sale online

Over both surveys, 16 different online sales platforms were surveyed. A total of 490 elephant ivory

items were listed for sale over 12 days of surveys between March and May. The quantity of ivory items

found offered for sale across the different market sizes in Europe did not vary considerably, however

this was expected due to the thresholds placed on the number of online sales platforms and ivory

items surveyed per Member State across the two surveys (see section 2.2.2). Most ivory items were

found offered for sale in the large and medium markets (approximately 38% and 39%, respectively)

followed closely by small markets (23%). Despite the Czech Republic being classified as a small ivory

market for the purposes of this study, it accounted for the third highest number of ivory items found

offered for sale. Of the six countries surveyed, the highest quantity of ivory items found offered for

sale were in Belgium (Table 2). As previously mentioned, the low number of ivory items found available

for purchase in Luxembourg was attributed to the impact of COVID-19.

Table 2. Number of ivory items found per ivory market across Survey One and Two

Ivory markets surveyed Number of items Percentage (%)

Large ivory market 186 38.0

Germany 97 19.8

Italy 89 18.2

Medium Ivory Market 192 39.2

Austria 89 18.2

Belgium 103 21.0

Small Ivory Market 112 22.9

Czech Republic 94 19.2

Luxembourg 18 3.7

Grand Total 490 100.0

13 https://www.the-saleroom.com/ 14 Live auctions on the Salesroom were not running during the survey period for the remaining three countries

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3.2 Product types

Of the 490 ivory items, ivory carvings were the most frequent item found offered for sale (400 items,

ca. 82%), followed by ivory jewellery (63 items, ca. 13%), wood products containing ivory (21 items,

ca. 4%) and pianos with ivory piano keys (6 pianos, ca. 1%). The only type of musical instrument found

offered for sale was one flute15. Figurines/sculptures were the most frequently observed single type

of item, accounting for 40% of all ivory products found offered for sale on the EU market, followed by

containers/vessels (ca. 10%) (mostly ivory boxes) and ivory jewellery (ca. 13%) (Table 3).

Table 3. Number of the different ivory product types classified as ivory carvings found across the EU market Ivory item Type of product Number of items Percentage (%)

Ivory carvings Ashtray 2 0.4%

Book cover 5 1.0%

Brush 1 0.2%

Candle holder 4 0.8%

Carved Panel 8 1.6%

Carved Tusk 22 4.5%

Chess Set 1 0.2%

Cigarette holder 2 0.4%

Container/vessel 46 9.4%

Crucifix 7 1.4%

Cutlery 7 1.4%

Fan 5 1.0%

Figurine/sculpture 196 40.0%

Flute 1 0.2%

Frame 2 0.4%

Furniture 1 0.2%

Ivory Painting 37 7.6%

Knife 10 2.0%

Mirror 3 0.6%

Other 15 3.1%

Pipe 1 0.2%

Pistol handle 1 0.2%

Rosary 2 0.4%

Stationary 6 1.2%

Sword 11 2.2%

Thermometer 1 0.2%

Walking stick 3 0.6%

Total (IVC) 400 81.6%

Ivory jewellery Jewellery 63 12.9%

Total (IVJ) 63 12.9%

Pianos with ivory piano keys Piano Keys 6 1.2%

Total (PKY) 6 1.2%

Wood products containing ivory

Carved Panel 1 0.2%

Clock 2 0.4%

Compass 1 0.2%

Container/vessel 5 1.0%

Crucifix 1 0.2%

Figurine/sculpture 2 0.4%

Furniture 5 1.0%

Other 2 0.4%

Pipe 2 0.4%

Total (WPR) 21 4.3%

Grand Total 490 100.0%

15 Categorised as an “ivory carving” for the purpose of this analysis.

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Figure 3. Examples of types of ivory carvings and ivory jewellery found offered for sale in the EU

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Figure 4. Examples of types of wood products containing ivory found offered for sale in the EU

Of all the different types of products found, a total of 50 items contained other materials including:

gold, silver, tropical hardwoods (such as ebony, mahogany and rosewood), marble, leather, bronze,

snake skin, porcelain, tortoiseshell, mother of pearl, coral, and precious stones (such as turquoise,

amethyst and quartz). The prices of these items ranged from EUR40 to EUR11 500, with most items

with a fixed, estimate or minimum bid price set at more than a few hundred euros. Most of the items

found offered for sale were containers/vessels (such as a silver tea pot with ivory embedded into the

handle), figurines/sculptures, weaponry (such as swords and pistols with ivory inlay), walking sticks

and paintings with small quantities of ivory. Nearly 50% (21 items) of products made with ivory and

other materials contained less than 20% ivory, with a further nine items (18%) containing between

20–39% ivory.

Within the category ivory carvings, figurine/sculptures were the most frequently observed items

found across the EU market totalling 196 items (ca. 49%). Of these figurines/sculptures, 153 items (ca.

78%) were ivory statues, with other items including ivory busts, okimonos, and netsukes each

accounting for less than ca. 8% each. Container/vessels, miniature ivory paintings, carved ivory tusks,

swords and knives with ivory handles were also frequently observed items offered for sale. Less than

10 items were found for each of the other ivory products on the EU market, such as fans, candle

holders, hairbrushes and walking sticks with ivory handles (Table 3). Examples of the types of items

incorporated in the category “other” include billiard balls, paperweights, dominoes, and children’s

rattles. A total of 52 ivory carvings contained other materials including silver, ebony, precious stones,

yellow and rose gold, marble, tortoiseshell, tropical woods, mother of pearl and leather.

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Ivory jewellery was also frequently observed for sale in the EU (63 items). Under this category, the

types of items ranged from necklaces (ca. 49%), brooches (ca. 14%), bracelets (ca. 13%), jewellery sets

(ca. 9%), pendants (ca. 8%) and ivory bangles (ca. 6%). Seven ivory jewellery items contained additional

materials including gold, precious coral, pearl, turquoise and mahogany, and were typically priced

above EUR100 per item. Wood products containing ivory or ivory inlay accounted for 21 ivory items

found offered for sale in the EU. Most products were containers/vessels (ca. 24%) (e.g. tropical

hardwood boxes with ivory inlay or jewellery boxes with ivory inlay), followed by pieces of furniture

with ivory inlay (ca. 24%), clocks with ivory inlay (ca. 9%), figurines/sculptures (ca. 9%) (e.g.

combination of wood and ivory statues), pipes (ca. 9%) and other items (ca. 9%) such as panels of

wood with ivory inlay. Wooden crucifixes, carved panels, and compasses each accounted for less than

5%. Only six of the wood products containing ivory also contained other commodities including

mother of pearl, tortoiseshell, gold, marble, gemstones, bone, and silver, and were typically priced

above EUR500 per item.

3.3 Provenance

Available information on provenance of the ivory items offered for sale was patchy. More than 290

items noted some detail on the origin of the item, however it was unclear for several of these listing

whether the origin described was where the item had been crafted or where the item was held in

collection for auction. Overall, 180 items provided information on provenance that was deemed

reliable16; 118 described as originating from European countries, 48 items from Asia and 14 items from

Africa. Most items that had reliable available information on provenance were ivory carvings (161

items) originating from Europe (110 ivory items).

Of the 118 items that were described as originating from within Europe, the majority were from France

and Germany (35 items and 30 items, respectively). Other European countries included Austria, Italy,

the UK, Turkey, and Greece. Of those ivory items with provenance from Asia, most originated from

China (20 items), followed by Japan (16 items) and India (seven items). Other countries/territories

included Iran, Syria, Hong Kong SAR, Viet Nam, and Indonesia. The ivory items with provenance from

Africa were from countries such as Congo, Somalia, Democratic Republic of the Congo, and Namibia.

3.4 Percentage of ivory

The percentage of ivory within the items found offered for sale was recorded for all 490 items and

categorised into the following groups: 0–19%, 20–39%, 40–59%, 60–79% and 80–100% for analytical

purposes. More than 50% of items found offered for sale contained between 80–100% ivory (Table 4)

and within this category, 197 (ca. 73%) items were made entirely of ivory. More than ca. 88% of items

found offered for sale in the EU market contained more than 20% ivory. Of the items containing the

lowest quantity of ivory (less than 20%), 23 items contained less than 10% ivory, while 34 items

contained between 10–20% ivory.

Table 4. Percentage of ivory in items found offered for sale.

Percentage of ivory category Number of items Percentage (%)

0–19 57 11.6%

20–39 54 11.0%

40–59 39 8.0%

60–79 69 14.1%

80–100 271 55.3%

Total 490 100.0%

16 Information on the provenance of an ivory item was deemed reliable only when the listing explicitly stated where the item originated from.

15

The types of products containing the highest quantity of ivory (between 80–100%) were ivory carvings,

such as figurines/sculptures (e.g. ivory statues, okimonos, and netsukes), containers/vessels (e.g. ivory

boxes, jugs, bowls, vases and chalices) and carved ivory tusks. Other items that contained a high

percentage of ivory included miniature ivory paintings, billiard balls, stationary items (such as letter

openers and rulers), thermometers, candle holders, ivory fans, and crucifixes. Ivory jewellery, such as

ivory necklaces, brooches, bracelets, and pendants, also frequently contained more than 80% ivory.

Table 5. Types of ivory items containing ivory only

Ivory carvings, such as containers/vessels (e.g. tea sets), ivory statues, swords with ivory handles,

knives with ivory handles and book covers, were also the items that frequently contained the lowest

quantity of ivory (between 0–19%). Wood products containing ivory, such as pieces of furniture with

ivory inlay and tropical hardwood boxes with ivory inlay, and pianos with ivory piano keys also

contained lower quantities of ivory. One piano with ivory piano keys was recorded to contain between

20–39% ivory. It is highly likely that this calculation was due to the angle of the 2D photograph

whereby the piano keys were the focal point of the image and the whole piano could not be seen,

therefore the true percentage of ivory could not be calculated using the grid overlay system (see

section 2.2.3 for further information).

Table 6. Types of ivory items containing between 10-20% ivory and less than 10% ivory

Examples products containing between 10–20% ivory

Examples products containing less than 10% ivory

Swords with ivory handles, statues containing ivory and other previous materials, tea sets, miniature ivory paintings, pieces of furniture with ivory inlay, bowl with ivory inlay, crucifixes, walking sticks, knives with ivory handles, pianos with ivory piano keys and boxes with ivory inlay.

Statues containing ivory and other previous materials, tea sets, boxes with ivory inlay, pieces of furniture (e.g. chest of drawers) with ivory inlay, book cover and pots with ivory inlay,

Box 1: An example of the number of items containing more than 20% ivory with a value of more than EUR100.

Examples of types of products containing ivory only

Statue, carved ivory tusk, ivory necklace, okimono, netsuke, box, bust, jug, carved panel, bracelet, brooch, cutlery, fan, crucifix, carved ivory portrait, pendant, ruler, letter opener, thermometer, ashtray and chalice.

Figurines/sculptures were the most frequently observed item on the EU market, with 198 items

found offered for sale. A total of 15 (ca.8%) of these were recorded to contain less than 20%

ivory. Of the 183 items which contained more than 20% ivory, 85 items (~47%) either had a fixed

price, estimate or minimum bid price of EUR500 or more, of which 79 were declared as pre-1947

items. A total of 81% (148 items) were priced at more than EUR100. Of these 148 items, 112 ivory

products were declared as pre-1947 antiques and 31 items provided no details on age. The

remaining five ivory products were declared post-1947 items.

16

3.5 Weight of ivory items

Available information on weight of items found offered for sale was sporadic, and even those items

with some details provided, the accuracy and reliability of this information is unknown as the items

could not physically be inspected. Numerous items provided details on the total weight of the item,

and not just the weight of the ivory, therefore only those items with specific information on the weight

of the ivory were analysed.

A total of 60 items provided details on the weight of the ivory, all of which were converted to grams

(g). Weight of the ivory was mainly provided for ivory carvings (57 items), with only two ivory jewellery

items and one wood product providing such information (Table 7). A total of 44 of the items provided

some information on age, 43 of which were declared as pre-1947 items. The remaining item was

declared as pre-Convention. The range in weight of ivory varied from 14.5 g to 15.8 kg, with only 13

items containing ivory that weighed 50 g or less. Only 10 items contained more than 1 kg of ivory: the

two heaviest items were a pre-1947 carved ivory tusk weighing 15.8 kg and a pre-1947 antique ivory

vase (weighing 2.8 kg). Only one of these items contained less than 20% ivory, with 90% of the

remaining 59 items all containing more than 80% ivory.

Table 7. Approximate weight (g) of ivory items found offered for sale on the EU market

Weight (g)

Number of items

Percentage (%)

Ivory carving

Ivory jewellery

Wood products Total

0-30 6 1 0 7 11.7%

31-50 4 1 1 6 10.0%

51-100 4 0 0 4 6.7%

101-200 9 0 0 9 15.0%

201-300 7 0 0 7 11.7%

301-400 5 0 0 5 8.3%

401-500 3 0 0 3 5.0%

501-1000 9 0 0 9 15.0%

>1001 10 0 0 10 16.7%

Total 57 2 1 60 100.0%

Nearly 70% of items contained 500g or less of ivory, with 55% containing 300g or less of ivory and ca.

43% containing 200g or less (Table 7). The items with the lowest content of ivory in terms of weight

were figurines/sculptures (36 items), all of which were ivory statues (24 items), okimonos (8 items),

and netsukes (4 items) (Table 8). All the okimonos and netsukes were made entirely of ivory weighing

less than ca. 200g. Of the 24 ivory statues, 17 of these were made entirely of ivory, with the remaining

items all containing more than 50% ivory in terms of volume. Just under half of the 24 ivory statues

(ca. 42%) contained less than 300g ivory, with a further ca. 25% containing between 301g and 500g.

The items with the highest content of ivory were carved tusks which contained between 900g and

15.8 kg of ivory, and containers/vessels, such as boxes, tea sets, chalices, vases, and jugs. All these

containers/vessels were made of between 80-100% ivory in terms of volume, with all but one item

containing more than ca. 400g of ivory (Table 8). All remaining items contained less than 150g of ivory

and were made entirely of ivory. The only exceptions were one carved panel containing 100% ivory

weighing 410g, and one pipe containing ca. 14% ivory weighing 40g.

17

Table 8. Number of different ivory product and the approximate range of ivory content reported in weight (g)

CITES code Type of ivory item

Number of items

Approximate weight (g) range

Approximate price (EUR) range

Ivory carving Candle holder 1 120 200

Carved panel 3 74-410 1000-1200

Carved tusk 5 900-15 800 120-1100

Container/vessel 8 40-2800 200-11 000

Cutlery 2 80-142 25-500

Figurine/sculpture 36 15-2568 86-8000

Stationary 2 20-90 300-500

Ivory jewellery Jewellery 2 30-40 100

Wood products Pipe 1 40 300

Total 60

Price information, in the form of fixed, estimate, minimum bid or reserve price (see section 3.6 for

further details), was available for 58 of the 60 items with details on the weight of the ivory content,

of which the majority were more high value items, with 48 items set with a fixed, estimate, minimum

bid or reserve price of between EUR100-2000 (Figure 5 and 6). Only two items were priced below

EUR100: one netsuke weighing 22g and one decorative piece of ivory cutlery weighing 142g.

Figure 5. The weight (g) and fixed, estimate, minimum bid or reserve price (EUR) of ivory items found offered for sale in the

EU market.

0

2000

4000

6000

8000

10000

12000

0 500 1000 1500 2000 2500 3000

Pri

ce (

EUR

)

Weight (g) of ivory

18

Figure 6. The weight (g) of ivory in an item with a fixed, estimate, minimum bid or reserve price (EUR) of less than EUR2000.

Note: This figure uses the same dataset as Figure 5 but focuses on those ivory items priced less than EUR2000.

Box 2. An example of the number of pre-1947 and pre-Convention items with ivory weighing 500g or less and containing

more than a 20% volume of ivory.

0

200

400

600

800

1000

1200

1400

1600

0 500 1000 1500 2000 2500 3000

Pri

ce (

EUR

)

Weight (g) of ivory

Of the 59 items found offered for sale on the EU market with information on the weight (g) that

contained more than 20% ivory in terms of volume, ca. 68% contained ivory weighing 500g or

less: ca. 54% contained 300g ivory or less, ca. 43% contained 200g or less, and ca. 14% contained

between 301-500g ivory. A total of 43 of these items provided details on the age, with 98%

declared as pre-1947 (with the remaining items declared as pre-Convention items). Under the

proposed changes, an additional weight-based qualification for those items with more than 20%

ivory in terms of volume would be applicable, therefore not requiring an intra-EU trade certificate

for commercial purposes. If the weight-based qualification were set at 300g or less, this would

result in over half (ca. 51%, 22 of the 43 items) of the items declared as pre-1947 and pre-

Convention falling under the “de-minimis” qualification and therefore not requiring an intra-EU

trade certificate. If the weight-based qualification were set at 200g or less, 16 of the 43 items (ca.

37%) would not require such a certificate based on the available information (which is however

limited).

19

Box 3. An example of the value of the pre-1947 and pre-Convention items with ivory weighing more than 300g and containing

more than a 20% volume.

Information on the dimensions of the items was also sporadic and variable, with most dimensions

given for the entire item and not just the ivory content, therefore it was not possible accurately to

analyse these details.

3.6 Age of ivory items

The age of ivory items found offered for sale was identified for 342 items (ca. 70%). The level of detail

given ranged from a general description such as “18th Century” or “turn of the Century”, to more

specific dates, such as “1910s–1920s”, “1950s”, “1839” or “1929”. Of the 342 items found offered for

sale on the EU market with some information on age, ca. 93% were declared to be pre-1947 antique

ivory items (319 items). A total of 23 items (ca. 7%) offered for sale indicated that the items were post-

1947 items. Most of these products were declared as pre-Convention items (items with ivory acquired

in the EU between 1947 and 1975), with only two items possibly dating to the 1980s and 1990 (Table

9).

Table 9. Number of ivory items found offered for sale that were declared as post-1947 items.

Current EU trade regulations Date Number of items Example(s) of types of products

Worked ivory: Items with ivory acquired in the EU between 1947 and 1975 – “pre-Convention”

1950s 2 Figurines/sculptures, jewellery –pendant

Before 1960 1 Ivory sceptre

1960 2 Figurines/sculptures, knife with ivory handle

1960s 2 Jewellery - necklace

Pre1970 1 Jewellery – necklace

1971 2 Jewellery – necklace

1973 2 Jewellery and piano keys

Pre-Convention 4 Figurines/sculpture

Total pre-Convention 16

Worked ivory: “pre-Convention” or “pre-Appendix I”

1960s-70s 1 Jewellery – brooch

1970s 2 Jewellery – necklace, knife with ivory handle

Mid-20th Century 1 Piece of furniture with ivory inlay

Second half 20th Century 1 Piece of furniture with ivory inlay

Total pre-Convention/pre-Appendix I 5

Worked ivory: Items with for African elephant ivory imported or acquired in the EU between 1975 and 1990 – "pre-Appendix I"

1880-1990 1 Carved ivory tusk

1980s 1 Figurines/Sculptures

Total pre-Appendix I 2

Of the 21 pre-1947 antiques and pre-Convention items containing ivory weighing more than

300g, all were priced above EUR120. Most items (ca. 72%) were reportedly of high value with a

fixed, estimate, minimum bid or reserve price of EUR500 or more. Given the high monetary value

of these items, it is likely that traders would apply for an intra-EU trade certificate for commercial

purposes under the proposed new trade rules. Of the 27 pre-1947 antiques and pre-Convention

items containing ivory weighing more than 200g, all were items priced above EUR120, with the

majority (ca. 70%) with a fixed, estimate, minimum bid or reserve price of EUR500 or more.

20

The main types of pre-Convention items found offered for sale were jewellery items (9 items) and

figurines/sculptures (6 items), with the majority (ca.74%) containing between 80–100% ivory and

priced above EUR100 per item. Other items included an antique rocking chair containing walnut

veneer, tropical hardwoods, mother of pearl and ivory embedded into the frame from the second half

of the 20th Century, and a mid-20th Century game table made with various tropical woods, mother of

pearl and ivory inlay. Only two items contained less than 20% ivory, including a piece of furniture with

ivory inlay and a piano with ivory piano keys. One piano with piano ivory keys was declared as dating

to 1973, however, it should be noted that this may be the age of manufacture and the ivory used for

the piano keys could have been made using ivory imported into the EU before 1947.

Most pre-1947 ivory items available for sale on the EU market were ivory carvings (ca. 90%), including

ivory figures and statues, miniature ivory paintings, containers/vessels, and swords with ivory handles.

Fewer pre-1947 ivory jewellery items, wood products containing ivory and pianos with ivory piano

keys were found offered for sale: ca. 5%, ca. 4% and ca. 1%, respectively. Of the 319 pre-1947 items

found offered for sale in the EU, most items (ca. 88%) contained more than 20% ivory (Table 10, Box

4). Of those items containing more than 20% ivory, more than 50% of items had a fixed, estimate or

minimum bid price of EUR100 or more (Box 5).

Table 10. Number of pre-1947 items and the percentage of ivory the items contains.

Percentage of ivory (%) Number of items

0–19 40

20–39 36

40–59 26

60–79 52

80–100 165

Grand Total 319

Box 4. An example of the number of items containing more than 20% ivory declared as pre-1947 items

Box 5: An example of the number of pre-1947 items containing more than 20% ivory with a value of more than EUR100

Of the 319 pre-1947 ivory items found offered for sale on the EU market, a total of 279 items

contained more than 20% ivory. Of those items, 225 ivory products (ca. 81%) had a fixed, estimate

or a minimum bid price of EUR100 or more, while 50% (140 items) were priced at more than

EUR500. Most of these items were ivory figurines/statues (a total of 112 ivory items). When

considering the proposed changes whereby pre-1947 items containing more than 20% ivory

would require an intra-EU trade certificate for commercial purposes, and considering those

“cheaper” items that traders would not likely apply for a certificate for, this would result in ca.

81% of the items likely requiring such a certificate. However, this does not consider the additional

weight-based threshold for items containing more than 20% ivory in terms of volume that would

likely significantly reduce the number of items requiring such a certificate.

Of the 433 items containing more than 20% ivory, the declared age of the product was provided

for 300 ivory items, with 279 items reported as pre-1947 antiques. When considering the

proposed new ivory trade rules whereby pre-1947 items containing more than 20% ivory would

require an intra-EU trade certificate for commercial purposes, this would result in 279 items

requiring such as certificate (ca. 93%), however this does not take into account the additional

weight-based threshold for items containing more than 20% ivory in terms of volume that would

likely significantly reduce the number of items requiring such a certificate.

21

3.6 Price of ivory items - summary

Information on price was recorded for a total of 459 items. For the 31 items where no price

information was given, the potential buyer was required to message the seller privately and then start

the buying/bidding process. Prices from online sales platforms in Austria, Belgium, Germany, Italy, and

Luxembourg were available in Euros (EUR), while online sales platforms in the Czech Republic provided

information in Czech Koruna (CZK). All price information in CZK was converted to EUR on the day the

item was surveyed17. While the price information recorded as “fixed/retail price” and “winning bid”

provide a relatively accurate representation of value of the ivory item that is offered for sale, other

price categories including “auctioneer’s estimate”, “current bid”, “reserve price” and “starting bid”

are less reliable as the final price could be much higher than recorded. For example, an auctioneer’s

estimate provides a price, or a range of prices given to an auction lot by auction house experts which

reflects the amount the lot might sell for at auction. Auctioneers may sometimes give artificially low

estimates to encourage bidding, however there are no guarantees that the lot will achieve the

estimate. Furthermore, a reserve price is a minimum price that the consignor is willing to accept and

is an amount agreed upon between the consignor and the auction house/seller. Reserves are typically

set at or below the low estimate of a lot. If bidding does not reach the reserve, the item will not be

sold18. While collecting these data does not guarantee the price reflects the true value of the ivory

item, it does provide insight to the lowest value the item might sell for. Additional materials that may

be contained in the item may also inflate the price and should be considered when examining the

results. Most items listed for sale included either an auctioneer’s estimate on price or fixed/retail price

(ca. 31% and 30%, respectively) (Table 10). Price information for piano keys was only provided as a

fixed/retail price. For all other types of ivory products, a variety of price information was given. All

prices were provided in specific figures aside from those ivory items with an auctioneer’s estimate;

these items were typically provided with a price range, for example ‘EUR1000-2000’.

Table 10. The number of items offered for sale with the various price information given.

Type of price information Number of items Percentage (%)

Auctioneer's estimate 154 31.4%

Current bid 31 6.3%

Fixed/retail price 148 30.2%

No price given 31 6.3%

Reserve price 13 2.7%

Starting bid 111 22.7%

Winning bid 2 0.4%

Grand Total 490 100.0%

The majority of ivory items found offered for sale on the EU market were set with a fixed/retail,

estimate, minimum bid or reserve price of between EUR100–EUR499 per item, with fewer items

priced below EUR100 (ca. 23%) and above EUR1000 (ca. 22%) (Table 11). A total of 48 items were

priced less than EUR50 for one single item with a further 58 items priced between EUR50 and EUR99.

While prices ranged from as little as EUR5 to EUR89 000 for one single item (Table 12), most ivory

products were priced below EUR2000 (Figure 7). Only 14 ivory items were priced above EUR 6000,

with only one item priced above EUR15 000: one Steinway grand piano with ivory piano keys

manufactured in 1973 (Figure 7). Figurines/sculptures, crucifixes, candle holders, carved tusks,

stationary and other items had the largest range in prices (Table 12).

17 https://www1.oanda.com/currency/converter/ 18 https://www.invaluable.com/blog/invaluable-auction-glossary/

22

Table 11. Price ranges (EUR) (either fixed, estimate or minimum bid price) and number of different ivory products. Note: if

the price was given in a range for the auctioneer’s estimate, the minimum estimate was used to categorise the price range

e.g. if a price of EUR400–600 was given, it was categorised in the EUR100–499 range.

Price (EUR)

Number of items Total

Percentage (%) Ivory

carvings Ivory jewellery

Wood products

Piano keys

0-99 65 37 3 0 105 22.9

100-499 145 15 6 1 167 36.4

500-999 82 1 4 0 87 19.0

≥1000 89 1 6 4 100 21.8

Total 381 54 19 5 459 100.0

Table 12. Price range of ivory items with a fixed, estimate or minimum bid price given by the online sales platforms.

CITES code Type of ivory product Number of items Approx. price range (EUR)

Ivory carving Ashtray 2 20-40

Book cover 5 15-150

Candle holder 4 30-1500

Carved Panel 8 200-4500

Carved Tusk 19 33-3000

Chess Set 1 3200

Cigarette holder 2 10-50

Container/vessel 45 8-12 000

Crucifix 7 15-15 000

Cutlery 6 10-500

Fan 5 30-300

Figurine/sculpture 189 7-10 000

Flute 1 275

Frame 2 275-450

Furniture 1 750

Ivory Painting 36 30-150

Knife 9 17-650

Mirror 3 120-1100

Other 12 50-3000

Pipe 1 55

Pistol handle 1 1000

Rosary 2 50-320

Stationary 5 270-2100

Sword 11 140-600

Thermometer 1 550

Walking stick 3 180-450

Ivory Jewellery Jewellery 54 5-1200

Piano keys Piano Keys 5 255-89 000

Wood products Carved Panel 1 500

Clock 1 5000

Compass 1 275

Container/vessel 4 70-3500

Crucifix 1 500

Figurine/sculpture 2 500-1200

Furniture 5 240-4000

Other 2 140-350

Pipe 2 55-300

Total

459

23

Figure 7. The percentage (%) and price (EUR) of ivory items found offered for sale in the EU market. Note: One outlier was

removed from the figure: one piano containing ca. 9.5% with a fixed priced of EUR 89 000.

Figure 8. The percentage (%) of ivory in an item with a fixed, estimate of minimum starting price (EUR)at EUR2000 or less.

Note: This figure uses the same dataset as Figure 7 but focuses on those ivory items priced EUR2000 or less.

0

2000

4000

6000

8000

10000

12000

14000

16000

0 10 20 30 40 50 60 70 80 90 100

Pri

ce (

EUR

)

Percentage of ivory (%)

0

200

400

600

800

1000

1200

1400

1600

1800

2000

0 10 20 30 40 50 60 70 80 90 100

Pri

ce (

EUR

)

Percentage of ivory (%)

24

As noted above, the price information recorded as “fixed/retail price” and “winning bid” provide an

accurate representation of value of the ivory item, however those prices provided as “auctioneer’s

estimate”, “current bid”, “reserve price” and “starting bid” are less reliable as the final price could be

much higher than recorded. Nevertheless, based on the available information, most ivory products

were high value items priced between EUR100-2000 and typically contained a high content of ivory

(above 20%). The proportion of “cheaper” ivory products (with a fixed, estimate, minimum bid or

reserve price below EUR100) available for purchase accounted for a small proportion of the EU

market, with the vast majority of these cheaper items containing more than 20% ivory (Figure 8).

3.6.1 Fixed/retail price

Prices recorded as a fixed/retail price ranged from ca. EUR5 to EUR89 000, with the majority of items

priced above EUR100 (Table 13, Table 14). Only nine ivory items (three ivory carvings including a small

ivory figurine, a crucifix, and a cigarette holder) and six ivory jewellery items, including necklaces and

pendants, were priced less than EUR15 each. All these items were made entirely of ivory aside from

one necklace which contained between 20–39% ivory. Only one item was priced at EUR89 000: one

Steinway grand piano with ivory piano keys manufactured in 1973. Excluding this grand piano, the

prices ranged from ca. EUR5 to ca. EUR2500. Pianos with ivory piano keys were the most expensive

items found offered for sale on the EU market and typically contained less than 20% ivory (see section

3.4).

Table 13. Price ranges (EUR) and number of items of ivory carvings, ivory jewellery and wood products containing ivory with

a fixed/retail price (EUR) given by the online sales platforms.

Price (EUR)

Number of items

Ivory carvings Ivory jewellery Wood products Piano keys Totals

0–49 19 17 0 0 36

50–99 15 18 3 0 36

100–499 40 12 4 1 57

500–999 13 1 0 0 14

>1000 1 0 0 4 5

Total 88 48 7 5 148

Table 14. Price range and average price of ivory items with a fixed price/retail price given by the online sales platform.

CITES code Type of ivory product Number of items Approx. price range (EUR)

Average price (EUR)

Additional materials

Ivory carvings Ashtray 2 20–40 30.9

Book cover 4 15–150 84.8

Candle holder 2 200–300 250.0

Carved Tusk 6 30–440 180.7

Cigarette holder 2 10–50 29.1

Container/vessel including boxes and pots

5 20–740 216.0

Crucifix 3 15–400 221.6

Cutlery 3 25–500 261.7

Fan 2 30–85 56.8

Figurine/sculpture including busts, netsukes, and statues

36 7–1350 305.2 Ebony; bronze

Flute 1 275 275.0

Frame 1 274.5 274.5 Tortoiseshell; ebony

Furniture 1 750 750.0

25

Ivory Painting 6 30–800 278.4

Knife 5 20–540 209.2

Other (dominoes) 1 74 73.8 Ebony

Pipe 1 55 55.0 Silver

Rosary 2 50–320 185.0

Sword 1 555 555.0 Thermometer 1 550 548.1 Walking stick 3 180–450 282.9 Rosewood

Ivory jewellery Jewellery items including brooches, necklaces, pendants, bangles, bracelets, and jewellery sets 48 5–800 102.5

Gold, mother of pearl, coral, turquoise and

mahogany

Wood products Compass 1 275 275.0 Container/vessel

3 70–165 101.2 Mother of pearl,

mammal bone

Other 2 140–350 245.0 Pipe 1 55 54.8

Figure 9. Items with a fixed/retail price of ≤ EUR99 and above ≥ EUR100 and the quantity of ivory contained in the items.

Overall, there was a near equal split between those ivory items containing more than 20% ivory that

were set with a fixed/retail price of less than EUR100 or EUR100 or more per item (Figure 9). Ivory

carvings were the items with the greatest range in price, from ca. EUR7 to EUR1350 (Table 14), with

44% of items priced between EUR100 and EUR499 (Table 13). The cheapest items available for sale on

the EU market with a fixed price under EUR50 included:

smaller ivory figurines/sculptures, specifically ivory statues made with 100% ivory;

ashtrays made with 100% and between 20–39% ivory;

prayer book covers made with less than 20% ivory;

cigarette holders made with between 80–100% ivory,

a small ivory box made with between 60–79% ivory;

decorative fork and spoon made with 100% ivory;

a small knife with ivory embedded into the handle (containing between 20–39% ivory); and

miniature ivory paintings made with a range of quantities of ivory.

0

5

10

15

20

25

30

35

40

45

50

0-19 20-39 40-59 60-79 80-100

Nu

mb

er o

f it

ems

Percentage of ivory (%)

≤ EUR 99 ≥ EUR 100

26

The most expensive ivory carvings available on the EU market priced over EUR500 included

figurines/sculptures, swords, ivory paintings, knives, thermometers, cutlery sets, container/vessels

and furniture typically containing more than 50% ivory, for example:

an ivory statue from Japan’s Meji period (second half of 19th century) made entirely of ivory;

an antique thermometer made with 100% ivory;

a side table made entirely of ivory; and

an ivory miniature painting made with between 40–59% ivory.

Other expensive items that contained less than 20% ivory included a pre-1947 sterling silver jar with

an ivory handle and an antique Ottoman sword with a handle that was originally made with walrus

ivory but replaced with elephant ivory. Another item with a lower ivory content was an ancient

Arabian dagger with an ivory handle (approx. 30%).

The seven wood products containing ivory were all priced above EUR50 (Table 13, Table 14). These

items typically contained a lower percentage of ivory in the item, however only one item contained

less than 20% ivory. Ivory jewellery items were the cheapest types of products available for sale on

the EU market with a fixed price, with 75% of items selling for less than EUR100 each, with some items

priced less EUR20 (mainly necklaces and pendants) (Table 14). Only five ivory jewellery items were

priced higher than EUR200, with the two highest items sold for EUR490 and EUR800 however both

these items contained additional materials that may have elevated the price: one bracelet containing

ca. 4% ivory as well as gold and coral, and one ivory bracelet with gold clasps containing ca. 93% ivory,

respectively.

3.6.2 Auctioneer’s estimate

Of the 154 items with prices recorded as auctioneer’s estimates, ca. 87% of prices were given as a

range, for example ‘EUR600–800’. Auctioneer’s estimates ranged from EUR10–20 to EUR15 000–

20 000, with most items (35%) priced over EUR1000 (Table 15). Less than 10% of the ivory items were

given an auctioneer’s of less than EUR100 per item, with the remaining 132 items priced higher than

EUR100. The lowest estimated prices were given to three items all made entirely of ivory: one ivory

necklace from the 1930s, and two cutlery sets from the 1930s. The highest estimated price of

EUR15 000–20 000 was given to an antique Corpus Christi Crucifix from the 17th century containing

80–100% ivory. All but one item was declared as a pre-1947 antiques: a sceptre made entirely of ivory

declared as a pre-1960 item.

Table 15. Price ranges (EUR) and number of items of ivory carvings, ivory jewellery and wood products containing ivory with

an auctioneer’s estimate price (EUR) given by the online sales platforms. Note: if the price was given in a range, the minimum

estimate was used to categorise the price range e.g. if a price of EUR400–600 was given, it was categorised in the EUR100–

499 range.

Price (EUR)

Number of items Total Total (%)

Ivory carvings Ivory jewellery Wood products

0–99 14 1 0 15 9.7

100–499 25 0 1 26 16.9

500–999 39 0 3 42 27.3

1000–4999 51 1 2 54 35.1

> 5000 17 0 0 17 11.0

Total 146 2 6 154 100.0

27

Approximately 90% (143 items) of these items contained more than 20% ivory. The only items with an

estimated price over EUR5000 were ivory carvings (typically ivory figurines/sculptures and

containers/vessels) of which all but two items contained more than 60% ivory. Some of the more

expensive ivory carvings available on the EU market (typically with an estimated price of more than

EUR1000 per item) also contained other materials of value including gold, marble, mother of pearl,

tropical wood, quartz, silver, precious stones, and tortoiseshell which may have elevated the price.

3.6.3 Bids and reserve prices

Three different types of bidding information were provided for a total of 144 items: starting bid,

current bid, and winning bid. All bidding information was given in specific figures e.g. EUR1050. The

age of the item was provided for 105 of these items, all but two of which were declared as pre-1947

antiques.

The starting bid price was provided for 111 items and included ivory carvings (104 items), wood

products containing ivory (6 items) and ivory jewellery (1 item) with prices ranging from EUR10 to

EUR12 000 (Table 16).

Table 16. Price ranges (EUR) and number of items of ivory carvings, ivory jewellery and wood products containing ivory with

a starting bid price (EUR) given by the online sales platforms.

Price (EUR)

Number of items Total

Ivory carvings Ivory jewellery Wood products

0–99 6 0 0 6

100–499 61 1 1 63

500–999 22 0 1 23

>1000 15 0 4 19

Total 104 1 6 111

Only six items were priced with a starting bid of less than EUR100 (Table 16). These types of products

included: a small ivory sewing box, a child’s rattle, and a small candle holder, with the majority

containing more than 40% ivory in the product. The items with the highest starting bid (above EUR500

and up to EUR12 000) typically contained the highest quantity of ivory; ca. 57% of items contained

more than 60% ivory. These items included products such as carved ivory tusks, containers/vessels

(such as a Chinese carved sewing ivory box from ca. 1850 and a Japanese ivory vase from the late 18th

century), figurines/sculptures (such as netsukes, okimonos, and carved ivory statues from the late 19th

Century), miniature ivory paintings, stationery, and fans.

28

Figure 10. Items with a starting bid of ≤ EUR99 and above ≥ EUR100 and the quantity of ivory contained in the items.

Of the 21 items containing less than 20% ivory (Figure 10), only two items (one silver tea set with ivory

embedded into the handles and one ivory figure on a marble base with gilded bronze) were set with

a starting bid of more than EUR1000; EUR1200 and EUR1300, respectively. Of the remaining 19 items,

13 ivory products were priced with a starting bid of less than EUR500 and the remaining six between

EUR600 and EUR950. The types of products included: antique knives and swords with ivory handles,

pieces of furniture with ivory inlay (such as an antique rocking chair containing walnut veneer, tropical

hardwoods, mother of pearl and ivory embedded into the frame from the second half of the 20th

century [post-1947]), figurines/sculptures (such as a small ivory bust approximately 7 cm in size and a

small figurine with ivory hands) and containers/vessels.

Information on the current bid price was collected for 31 items (Table 19), most of which were

figurines/sculptures (ca. 60%), with prices ranging from ca. EUR8 to EUR2500. It should be noted that

23 of these items were priced at less than EUR450 each and only two items had a current bid of more

than EUR700. At the time of the survey, most of the lots had more than 7 days left on auction indicating

that the final price could be much higher than the current bid. More than 80% of the items contained

a high ivory content (more than 60%), with only three items containing less than 20%. The winning bid

price was only recorded for two ivory items. Both items were pre-1947 ivory carvings containing 100%

ivory; one okimono sold for EUR390, and one paperweight sold for EUR72.

A total of 13 items provided price information in the form of a reserve price (Table 17), most of which

were figurines/sculptures and miniature ivory paintings. Prices ranged from EUR30 to EUR4800, with

10 of these ivory products set with a reserve price of less than EUR1000. The least expensive products,

accounting for ca. 26% (reserve price less than EUR100), were ivory jewellery items (such as an ivory

bangle made entirely of ivory), book covers with ivory inlay and miniature ivory paintings made with

20–39% ivory. The items with the highest reserve price were figurines/sculptures (six items in total)

and one ivory fan, ranging in price from EUR200 to EUR4800. Most of these items contained less than

20% ivory, however the two most expensive items with a reserve price of over EUR2500 both

contained more than 60%.

0

10

20

30

40

50

60

0-19 20-39 40-59 60-79 80-100

Nu

mb

er o

f it

ems

Percentage of ivory (%)

≤ EUR 99 ≥ EUR 100

29

Table 17. Price ranges (EUR) and number of items of different ivory products with a current bid, reserve price or winning bid

(EUR) given by the online sales platforms.

Price (EUR) Current bid Reserve price Winning bid

Total Total (%)

Ivory carving

Ivory jewellery

Ivory carving

Ivory jewellery

Ivory carving

0–99 8 0 2 1 1 12 26.1

100–499 13 2 5 0 1 21 45.7

500–999 6 0 2 0 0 8 17.4

>1000 2 0 3 0 0 5 10.9

Total 29 2 12 1 2 46 100.0

4. DISCUSSION

The online EU ivory market surveys conducted over a period of two months in 2020 provide an insight

to the characteristics of the intra-EU ivory market as a whole. While the study does not quantify the

scale of the market, the information gathered provides some detail on the proportion of different

types of products, particularly the pre-1947 antique items available for purchase in the EU. The results

also provide an understanding of the proportion of pre-1947 items that may qualify as “de-minimis”

(based on a volume-based qualification of less than 20% ivory content, and a weight-based

qualification) and therefore be exempt from requiring an intra-EU trade certificate under the

proposed changes. Details on the value of items offered for sale were also collected to, inter alia, try

and understand the proportion of “cheaper items” with smaller historical, artistic or cultural value

which would likely not continue to be traded if certain restrictions were in place due to the additional

burden on traders/dealers to apply for permits. Examining the proportion of more high-end, expensive

artistic items that would potentially be re-exported from the EU under the proposed changes was not

the aim of the study, however, some information has been highlighted throughout the study to

provide insight of the proportion of worked ivory items currently available on the EU market that may

be commercially re-exported.

A range of different ivory product types were found offered for sale across the EU. Items categorised

as ivory carvings were the main type of product, accounting for ca. 82%. Ivory figurines and

sculptures (such as ivory statues, netsukes, and okimonos) were the most frequently observed single

type of item on the market. Items classified as containers/vessels, such as boxes made entirely of ivory

and pieces of ivory jewellery such as necklaces, brooches, and pendants, were also frequent items

available for purchase. The types of ivory products seen less frequently varied from compasses, pieces

of furniture made entirely of ivory, hairbrushes, chess sets, pipes, children’s rattles, cigarette holders

and ivory billiard balls. Wood products containing ivory, such as boxes made from tropical hardwoods

and ivory inlay, pieces of furniture and crucifixes, as well as musical instruments, were also less

available on the EU market. Only seven musical instruments were found available for purchase on the

EU market: six pianos with ivory piano keys and one flute with an ivory handle.

Based on the available information, the EU market is predominantly made up of items that contain a

high percentage of ivory in terms of volume, with only 57 items (ca. 12%, out of 490) containing less

than 20% ivory. For those items where information on the weight of the ivory in the product was

30

available (ca. 12%, 60 of 490 items), the data suggest that ivory products available for purchase on the

EU market typically contain a low quantity of ivory in terms of weight, with more than half of these

items (55%, 33 of 60 items) containing 300g ivory or less, ca. 43% (26 items) containing 200g ivory or

less and a further ca. 13% containing 301-500g of ivory.

Under the new proposal, commercial intra-EU trade of pre-1947 (and pre-Convention) worked ivory

items would require a certificate, and case-by-case authorisations would need to be given by the

relevant CITES Management Authority for musical instruments and recognised pieces of art for

commercial re-export. The application for an intra-EU trade certificate for pre-1947 (and pre-

Convention items), that would not qualify as “de-minimis”, would likely need to be accompanied by a

small fee set by the relevant CITES Management Authority. The financial (fee) and the administrative

implications (application procedure) would likely result in the eventual decrease of the availability of

smaller ivory items from the market (and/or non-compliance with the new regulations). Furthermore,

while craftmanship, rarity and/or artistic and cultural value cannot be ascertained simply from the

monetary value of an item, price provides some insight of the proportion of worked ivory items

currently available on the EU market that would likely continue to be commercially re-exported if the

currently proposed further regulations were implemented.

Information on price was available for most of the ivory products found offered for sale on the EU

market, provided in either a fixed, estimate, minimum bid or reserve price. Overall, most ivory items

found offered for sale on the EU market were priced between EUR100–EUR499 per item, accounting

for ca. 36%, however as these data include prices set with a minimum bid or reserve price, it is likely

that some of the final prices would be much higher than recorded. Typically, ivory items were not

priced above EUR2000 for one single item, with only 14 ivory items priced above EUR 6000. The

“cheapest” ivory products available for purchase accounted for ca. 23% of the market, with a fixed,

estimate, minimum bid or reserve price set below EUR100. A few items were priced as low as ca.

EUR7. The different product types typically of low value ranged from small ivory carvings (specifically

small figures/statues, cigarette holders, single items of cutlery, ashtrays, and miniature ivory

paintings) to ivory jewellery items (specifically necklaces and pendants) which typically had a higher

content of ivory. Conducting online surveys of a representative sample of the EU market does not

account for the full range of ivory items offered for sale on the EU market (including the physical

market), potentially excluding the less sought-after, ‘cheaper’ more common ivory items available

for purchase. Online sales platforms also tend to have some bias towards selling items that are likely

to fetch the highest prices and therefore are likely to underrepresent ‘cheaper’ ivory items.

Therefore, the share of ‘cheaper’ items available on the market as a whole is likely to be an

underestimate. Furthermore, online surveys also do not likely consider the very high value art pieces

more likely to be sold by physical auction houses as these items are more likely to be sold at

specialised venues and not online, again resulting in these items likely being underrepresented in

the survey.

Wood products containing ivory were generally priced above EUR100 per item, with only seven

products set with a fixed/retail prices no higher than EUR500. The remaining price information for

wood products were in the form of bids and auctioneer’s estimates and were generally set between

EUR500 and EUR1000. Due to the nature of estimated prices and the bidding process, the potential

for an elevated winning bid for all these items is expected. Ivory carvings were the types of items with

31

the widest range in price, from as little as EUR7 for a rosary made of ivory, to a 17th century Corpus

Christi with an auctioneer’s estimate of EUR15 000 – 20 000. The most expensive ivory carvings

available for purchase included figurines/sculptures, pieces of furniture made entirely of ivory and

containers/vessels, which typically contained a higher ivory content (above 50%). Pianos with ivory

piano keys were the most expensive ivory items found offered for sale on the EU market, ranging from

EUR250 to the highest item set with a fixed/retail price of EUR89 000.

Several items found offered for sale were declared as containing other materials that may have

elevated the price of the item and possibly attribute further historical, artistic, or cultural value to the

item. The types of other materials found included gold, silver, tropical hardwoods (such as ebony,

mahogany and rosewood), marble, snake skin, porcelain, tortoiseshell, mother of pearl, coral, and

precious stones (such as turquoise, amethyst and quartz). A variety of different product types were

found to include these other materials, such as silver tea pots and jars with ivory embedded into the

handle, antique weaponry such as swords and pistols with ivory inlay and walking sticks and paintings

with small quantities of ivory as adornment. The content of ivory in these items varied, with a near

50% split between those that would qualify as “de-minimis” and those that would not. Most of these

products were attributed a higher monetary value, with items typically with a fixed, estimate or

minimum bid price of between a few hundred and a few thousand Euros for one single item. While a

reliable artistic, cultural, or historical value cannot be attributed to an item without the expertise of a

professional, it is likely that traders could seek authorisation to commercially re-export these items

containing valuable materials, including ivory.

Details on the approximate age of items were available for more than 70% of ivory products offered

for sale on the EU market, with nearly all items declared as pre-1947 antiques (319 items, ca. 93%).

The vast majority of these pre-1947 antiques contained more than 20% ivory (279 items, ca. 88%),

and half of these priced EUR500 or more (either as a fixed, estimate or minimum bid price). Box 1

provides an example of the proportion of items on the market that may be considered of high value

based on its monetary value (above EUR500). For example, figurines/sculptures were the most

frequent single item found offered for sale, with just under half the items declared as pre-1947

antiques containing more than 20% ivory. As previously mentioned, craftmanship, rarity and/or

artistic and cultural value cannot be ascertained simply from the monetary value of an item, however

these data provide some insight of the proportion of ‘high-end’ antiques currently available on the EU

market that would likely continue to be commercially re-exported if the currently proposed further

regulations were implemented. Overall, 279 pre-1947 ivory items found offered for sale on the EU

market that contained more than 20% ivory, of which only ca. 19% would likely be considered less

valuable (priced at less EUR100 per item). Under the proposed changes, whereby pre-1947 items

containing more than 20% ivory would require an intra-EU trade certificate for commercial purposes

within the EU, and considering those ‘cheaper’ items that traders would not likely apply for a

certificate, this would result in ca. 81% (225 items out of 279) of items not falling under the volume-

based “de-minimis” qualification. However, this calculation does not consider the additional weight-

based qualification for those items containing more than 20% ivory that would also qualify as “de-

minimis” under the new proposal. Box 2 provides an example of the proportion of pre-1947 and pre-

Convention items with more than 20% ivory in terms of volume that would qualify as “de-minimis” if

a weight-based qualification were set. This would result in over half (ca. 51%) of the pre-1947 and

pre-Convention falling under the “de-minimis” qualification and therefore not requiring an intra-EU

32

trade certificate if weight-based qualification were set at 300g or less, or 37% if it would be set at

200g or less. While the ivory items with available information on weight and declared age are small,

they indicate that a large share of the ivory items on the market contain a low quantity of ivory in

terms of weight and thus would likely not require an intra-EU trade certificate under the new proposal

depending on the threshold set.

5. CONCLUSIONS

Increased tightening of domestic ivory trade rules has been seen across the world in recent years and

the EU is currently considering various options to regulate further the intra-EU trade and re-export of

worked specimens for commercial purposes. This study aimed to provide some indication of the

characteristics of the internal market by conducting a rapid assessment of online offers for sale of

ivory on online sales platforms in six EU Member States. Conducting online surveys of a representative

sample of the EU market does not account for the full range of ivory items offered for sale on the

online EU market and those available for purchase on the physical market. This potentially excludes

many items, including the less sought-after, ‘cheaper’ and more common ivory items and very high

value art pieces more likely to be sold by physical auction houses. Other considerations include that

due to online sales platforms prioritising listings of ivory items likely to fetch the highest prices the

‘cheaper’ ivory items available on the market are likely to be underrepresented in the survey results.

Nevertheless, the data provides some insight into the proportion of different product types on the

market, quantities of ivory contained within the item and attributed monetary value.

Based on the available information, it appears that the EU market is predominantly made up of pre-

1947 antique ivory carvings, some of which contain additional materials such as gold, silver, and

tropical hardwoods. These items are typically of high value e.g. priced above EUR500 for one single

item, and frequently contain more than 20% ivory. The online surveys confirm that the share of ivory

items on the EU market that would likely qualify as “de-minimis” under a volume-based qualification

of less than 20% ivory content is small, however the proportion of items that would qualify as “de-

minimis” under the additional weight-based qualification is high. The proportion of ‘cheaper’ items

(less than EUR100 per item) offered for sale on the EU market that would not likely go through any

new permitting procedures, are also relatively low in numbers, however due to several considerations

outlined above, this is likely an underestimate of this share of the market. Finally, the online surveys

also confirm the proportion of items with a high monetary value, providing insight to those ‘high-end’

antiques that may be commercially re-exported under the proposed changes.

It is not advisable to directly extrapolate these results to the number of antique ivory items that would

for the first time require an intra-EU trade certificate under the proposed changes, due to the

considerations outlined above. However, the online survey results indicate the share of the market

that would likely qualify as “de-minimis” under a volume based qualification (ca. 12%), therefore

excluded from requiring an intra-EU trade certificate, and the proportion of ‘cheaper items’ (ca. 23%)

available for purchase that would likely be withdrawn from the internal EU trade due to their low

value. While, it is expected that compliance checks and national enforcement efforts would increase

for a period after the proposed changes were implemented, a minimum of ca. 30% of the current

market would not require regulating, therefore reducing the administrative burden for authorities.

However, this is likely an underestimate due to the additional weight-based “de-minimis” qualification

33

that would exclude several items from requiring intra-EU trade certificates and several other

considerations outlined throughout the report.

6. ANNEX 1 – METHODOLOGY – FURTHER DETAILS

6.1 Sampling the Member State markets to survey

6.1.1 Overview of stratified random sampling

The Member States were first categorised into strata. Due to the exemption in Article 62(3) of

Commission Regulation (EC) No 865/200619 (which exempts pre-1947 worked items from the

requirement to hold valid certificates for intra-EU trade), there is limited information available on the

size of the domestic ivory markets in each of the Member States that can be used to classify them into

strata for the online surveys. Therefore, a wide range of information sources were used to estimate

better the scale of each of the markets and categorise the Member States into one of the following

groups:

“small” ivory markets (Group One),

“medium” ivory markets (Group Two),

“large” ivory markets (Group Three).

It should be noted that the current information available is very incomplete and by no means a true

representation of what the domestic markets may in fact look like. The only purpose of this exercise

was to enable the selection of six Member States to survey that would largely represent the EU market

in these online surveys. To categorise the size of the ivory market for each of the Member States,

information and data were extracted from the following sources:

Legal trade data from the CITES trade database20 for the period 2013–201821;

Illegal trade data from the EU Member States CITES Annual Illegal Trade Reports submitted to

EU-TWIX22 for the years 2017 and 201823;

Elephant Trade Information System (ETIS) cluster analyses from the CoP17 (data analysed for

the period 2012-2014) and CoP18 (data analysed for the period 2015-2017) ETIS reports24;

Data on intra-EU trade in pre-1947 ivory antiques and pre-Convention worked ivory for the

period 2012-201625.

6.1.2 Analysis for stratified random sampling The methodologies that were followed to classify each of the Member States per source of data are

explained below.

19 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32006R0865 20 https://trade.cites.org/ 21 Data extracted from the CITES Trade Database on 10 February 2020. 22 https://www.eu-twix.org/ 23 EU-TWIX data were downloaded by EU-TWIX staff on 29 January 2020 24 https://cites.org/sites/default/files/eng/cop/17/WorkingDocs/E-CoP17-57-06-R1.pdf and

https://cites.org/sites/default/files/eng/cop/18/doc/E-CoP18-069-03-R1.pdf 25 https://ec.europa.eu/environment/cites/pdf/reports/EU%20ivory%20trade%20background%20report%20TRAFFIC%20Jan.%202019.pdf.

34

CITES TRADE DATA

Data with the following parameters were analysed:

Trade in worked26 ivory reported at Elephantidae spp. (including lower taxonomic categories,

Elephas spp. and Loxodonta spp.)

Years 2013-2018

EU imports and EU exports

Importer and exported reported quantities

Commercial (T) and personal (P) purposes

All source codes excluding ‘I’

Number of specimens and additional number of specimens recorded by weight (kg)

Methodology to categorise EU imports and EU exports separately:

Number of specimens and weight (kg) were categorised based on the total reported quantities

for all commodity groups for the period 2013-2018, not by individual year (Table 20).

Table 20. The total reported quantities of number of specimens and weight (kg) per Member State for each of the

categories (small, medium or large).

The highest number of specimens and weight provided in either the importer or exported

reported quantity were selected for categorisation.

When most of the items reported in legal trade were piano keys, the number or weight of

ivory carvings was looked at instead to categorise the Member States. This was to avoid bias

based on information on reporting inconsistencies in the CITES trade database27.

Methodology to categorise Member States’ legal trade (EU imports and EU exports combined):

The most frequent category was selected for each of the Member States.

If there was an equal split, then the average category was chosen e.g. two small and two large,

then a “MEDIUM” category was selected. If, for example, there were two medium or two

large, then the higher category was selected.

EU-TWIX SEIZURE DATA

Data with the following parameters were analysed:

All seizures reported as worked ivory28 in the 2017 and 2018 EU seizures analyses reported at

Elephantidae spp. (including lower taxonomic categories, Elephas spp. and Loxodonta spp.);

Years 2017 and 2018;

Number of records, number of specimens and additional reported in weight (kg);

All trade directions.

26 CAR - carvings; JWL - jewellery; IJW – ivory jewellery; IVC – ivory carvings; KEY - keys; PKY – piano keys 27 https://ec.europa.eu/environment/cites/pdf/reports/EU%20ivory%20trade%20background%20report%20TRAFFIC%20Jan.%202019.pdf 28 BOC – bone carvings; CAR - carving; HOC – horn carvings; IJW – ivory jewellery; IVC – ivory carvings

Category Worked Items Weight (kg)

Small ≤ 50 ≤ 50

Medium 51–500 51–500

Large ≥ 501 ≥ 501

35

Methodology to categorise the markets:

Number of records, specimens, and additional weight (kg) were categorised based on total

quantities per year (Table 21): Table 21. The total reported quantities of number of records, number of specimens and additional weight (kg) per

Member State for each of the categories (small, medium or large).

When most records, specimens and additional weight recorded were piano keys, the number

of ivory carvings was examined to categorise the Member States.

ETIS REPORTS

Methods:

If a Member State was identified in the cluster analysis, then at a minimum it was classified as either ‘MEDIUM’ or ‘LARGE’

Member States were classified as ‘MEDIUM’ or ‘LARGE’ based on the relevant information in the cluster analysis e.g. relating to the frequency of seizures, purpose of commodities in trade, weight of ivory seized, links to Organised Criminal Groups and information on rule of law and law enforcement ratio and any other information;

Main text for consideration is highlighted in bold.

Category No. of

records No. of

specimens Weight (kg)

Small ≤ 10 ≤ 20 ≤ 10

Medium 11 - 49 21 - 100 11 - 100

Large ≥ 50 ≥ 101 ≥ 101

36

CoP17 REPORT

Table 22. ETIS cluster analysis for CoP17 (data analysed for the period 2012-2014)

MEMBER STATE RELEVANT INFORMATION FROM CLUSTER ANALYSIS Market size

AT (other Parties include South Korea (KR), Lao PDR (LA), Turkey (TR), Rwanda (RW), Macau SAR (MO), Philippines (PH), Saudi Arabia (SA))

Group 9 - …In terms of frequency, this group almost never made and reported seizures, and was rarely otherwise involved in the trade chains of seizures reported by other countries. Thus, this group has the lowest mean number of seizures, however, interdictions typically involve the large ivory weight class. The governance indicator for rule of law is relatively high, but there is considerable variability within the group, with most entities providing positive scores (including Austria). On the other hand, the law enforcement ratio is second poorest score overall in this analysis which is probably why these countries are chosen as pathways for large-scale movements of ivory that are orchestrated by organised crime syndicates; indeed, almost all of the weight of ivory seized represented shipments of 800 kg or more.

MEDIUM

BE (other parties include Australia

(AU), United States (US), Germany (DE))

Group 10 - The frequency and scale measures point to a large number of mostly low weight seizures, indicating the persistent interdiction of worked ivory ‘personal effects’ products from returning tourists and other similar seizures. This group collectively displays commendable governance values with the highest scores for rule of law and the second highest law enforcement ratio. The cluster is also not implicated in any large-scale ivory seizures indicating a general absence of higher level organised criminal activity. The domestic ivory market score is in the lower middle range, reflecting the situation in the United States and Germany where active domestic ivory trade in mostly pre-Convention and antique items occurs.

LARGE

DE (other parties include Australia (AU), United States (US), Belgium (BE)

Group 10 - The frequency and scale measures point to a large number of mostly low weight seizures, indicating the persistent interdiction of worked ivory ‘personal effects’ products from returning tourists and other similar seizures. This group collectively displays commendable governance values with the highest scores for rule of law and the second highest law enforcement ratio. The cluster is also not implicated in any large-scale ivory seizures indicating a general absence of higher level organised criminal activity. The domestic ivory market score is in the lower middle range, reflecting the situation in the United States and Germany where active domestic ivory trade in mostly pre-Convention and antique items occurs.

LARGE

37

MEMBER STATE RELEVANT INFORMATION FROM CLUSTER ANALYSIS Market size

ES (other Parties include United Arab Emirates (AE), Angola (AO), Japan (JP), Mozambique (MZ), United Kingdom (GB))

Group 13 - This cluster comprises a residual grouping of countries that play markedly differing roles in the ivory trade…whilst the contemporary ivory trades to the United Kingdom and Spain typically involve non-commercial seizures from tourists. With the exception of the United Kingdom, all of these countries are far more likely to be implicated in seizures that are made elsewhere. For this cluster, both the mean number of seizures and the mean weight of ivory seized fall right in the mid-range of this analysis. Worryingly, this cluster has the third highest value for the proportion of seizures that involved 800 kg of ivory or more, the indicator that signals the involvement of organised crime in the trade. This latter result is primarily due to the fact that, in 2012, the second largest ivory seizure ever recorded in ETIS was shipped from Lome, Togo to Algeciras, Spain for transhipment on to Malaysia. Overall, the governance indicator for rule of law is extremely positive, however, the contribution of individual countries is highly variable for such an eclectic group. Rule of law scores are very positive for the United Arab Emirates, Japan, Spain and the United Kingdom, but very negative for Angola and Mozambique. This group ranks the third lowest in terms of law enforcement ratio and only the United Kingdom seems to contribute decidedly positive values to the collective score. This group also has the second highest domestic ivory market score as all countries except the United Arab Emirates and Spain have significant markets.

MEDIUM

FR (other Parties include Sudan (SD), India (IN), Zambia (ZM))

Group 6 - Falling in the middle in terms of the mean number of seizures, and showing a low mean weight value, this grouping is not particularly noteworthy. Further, none of the seizures have involved large ivory consignments of 800 kg or more so there is little to suggest active organised criminal activity. Assessing governance, the mean rule of law measure shows a negative value which could signal corruption problems, but the very high law enforcement effort ratio seems to indicate generally good performance where ivory trade is concerned. Finally, with a very low market score, this group of countries does not appear to play an obvious problematic role at the retail level.

MEDIUM

IT (other Parties include Switzerland

(CH), Egypt (EG), Netherlands (NL))

Group 11 - This group of European nations and Egypt has a very modest mean number of seizures and the mean weight value is the lowest in this assessment. The governance indicators are mid-range with the rule of law score barely positive but a more robust law enforcement ratio, although the latter score is somewhat compromised by the fact that Italy has not reported any ivory seizures to ETIS in over six years. Since 2012, there is no evidence of involvement in large-scale flows of ivory. The domestic ivory market score is the third lowest in this analysis with a general absence of trade activity in the three European countries.

MEDIUM

38

MEMBER STATE RELEVANT INFORMATION FROM CLUSTER ANALYSIS Market size

NL (other Parties include Switzerland

(CH), Italy (IT), Egypt (EG))

Group 11 - This group of European nations and Egypt has a very modest mean number of seizures and the mean weight value is the lowest in this assessment. The governance indicators are mid-range with the rule of law score barely positive but a more robust law enforcement ratio, although the latter score is somewhat compromised by the fact that Italy has not reported any ivory seizures to ETIS in over six years. Since 2012, there is no evidence of involvement in large-scale flows of ivory. The domestic ivory market score is the third lowest in this analysis with a general absence of trade activity in the three European countries

MEDIUM

CoP18 REPORT

Table 23. ETIS cluster analysis for CoP18 (data analysed for the period 2014-2017)

MEMBER STATE RELEVANT INFORMATION FROM CLUSTER ANALYSIS Market size

AT (other Parties include Australia (AU), Canada (CA), Switzerland (CH), Spain (ES), New Zealand (NZ)

Cluster 12 – This cluster of relatively wealthy nations in Europe, Oceania and North America generally exhibits good values across the entire spectrum and are not generally involved in significant illegal ivory trade in the period examined. The measure for frequency falls at the lower end of the scale, whilst the weight value is the third lowest in this analysis, indicating that most seizures involve worked ivory products in trade as personal effects. None of this trade links with large-scale movements of ivory that could be linked with higher-level organised crime and the high LE Ratio means that 70% of the transactions in which these countries are involved are made by one of countries in the group. Finally, the domestic ivory market score is in the fifth lowest position indicating some presence of mostly ‘background’ antique or pre-Convention ivory.

MEDIUM

BE (other Parties include Central African Republic (CF), Côte d’Ivoire (CI), Germany (DE), Guinea (GN), Netherlands (NL), Sudan (SD)

Cluster 11 - …the group falls right in the middle in terms of the mean number of seizures, but, in fact, the three European nations account for over 90% of the seizures made by these countries. Equally, the mean weight value is at the lower end of the scale measure, but the three European countries again account for over 90% of the weight, with about one-third representing large-scale ivory seizures which probably link to organised crime. The LE Ratio (60%) is high, again owing to the performance of Germany and the Netherlands…. The domestic ivory market score is tied with two other clusters in the fifth position…

MEDIUM

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MEMBER STATE RELEVANT INFORMATION FROM CLUSTER ANALYSIS Market size

CZ (other Parties include Botswana (BW), Egypt (EG), Italy (IT), Sri Lanka (LK), Togo (TG).

Cluster 10 - Small number of mostly medium weight seizures, with no involvement in the large-scale ivory movements which are the hallmark of organised crime. At 82%, four out of five seizures in which these countries are implicated are made by the nations in this group themselves, thus overall the high LE Ratio shows generally good law enforcement.

MEDIUM

DE (other Parties include Belgium (BE), Central African Republic (CF), Côte d’Ivoire (CI), Guinea (GN), Netherlands (NL), Sudan (SD)

Cluster 11 - …the group falls right in the middle in terms of the mean number of seizures, but, in fact, the three European nations account for over 90% of the seizures made by these countries. Equally, the mean weight value is at the lower end of the scale measure, but the three European countries again account for over 90% of the weight, with about one-third representing large-scale ivory seizures which probably link to organised crime. The LE Ratio (60%) is high, again owing to the performance of Germany and the Netherlands….The domestic ivory market score is tied with two other clusters in the fifth position with Germany, Côte d’Ivoire and the Sudan having national market scores above the group’s average.

MEDIUM

FR (other Parties include United Arab Emirates (AE), Angola (AO), Ethiopia (ET), United Kingdom of Great Britain and Northern Ireland (GB), United States of America (US)

Cluster 7 - … and two European and one North American destination countries or sources of mostly old ‘legacy’ ivory. This cluster is collectively making lots of seizures, holding the second highest value in this analysis. The very high frequency, however, translates into a mid-range weight value and none of the weight value derives from large-scale movements of ivory, suggesting no evidence of organised crime as it relates to moving large consignments of ivory….At 69%, the LE Ratio indicates that more than two-thirds of the total number of seizures that these countries are implicated in are being seized by these countries and not elsewhere... The domestic market score for this group is in the mid-range.

LARGE

NL (other Parties include Belgium (BE), Central African Republic (CF), Côte d’Ivoire (CI), Germany (DE), Guinea (GN), Sudan (SD)

Cluster 11 - the group falls right in the middle in terms of the mean number of seizures, but, in fact, the three European nations account for over 90% of the seizures made by these countries. Equally, the mean weight value is at the lower end of the scale measure, but the three European countries again account for over 90% of the weight, with about one-third representing large-scale ivory seizures which probably link to organised crime. The LE Ratio (60%) is high, again owing to the performance of Germany and the Netherlands. The domestic ivory market score is tied with two other clusters in the fifth position.

MEDIUM

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INTRA-EU TRADE

Pre-1947 items

Methodology:

Data collected for the period 2012-2016

Data and information extracted from: https://ec.europa.eu/environment/cites/pdf/reports/EU%20ivory%20trade%20background%20report%20TRAFFIC%20Jan.%202019.pdf

Some Member States provided total quantities for the period 2012-2016, while others only

recorded quantities per year. As a result, total number of specimens and/or weight were

used to categorise the Member States (using the categories in Table 20).

Results:

Six Member States (Cyprus, Estonia, Ireland, Latvia, Slovenia and Slovakia) reported no intra-EU antique trade. (SMALL)

Greece reported one comb from 5th–6th century in 2012. (SMALL)

Italy reported 13 specimens between 2012 and 2016, ten of which were traded in 2016. Piano keys, carvings, swords and rifles were the main product types. Italy also reported an increase in 2016, which was reportedly thought to be due to private individuals selling their specimens in an economic crisis or no longer wanting to own ivory. (SMALL)

Hungary require a “verification of origin” document for trading antique ivory. The documents are required for antique and pre-Convention ivory items. A total of 13 owners have been registered for antique and pre-Convention specimens and 48 transactions were reported in 2016 which involved mainly figures and carvings for commercial trade. (SMALL)

France provided estimates of an average of 25 000 antiques sold per year by auction houses in Auvergne-Rhone-Alps area and at least 60 000 per year in Paris area and believed part of these were for subsequent re-export to Asia. (LARGE)

Netherlands reported receiving applications for an EU certificate for 58 specimens containing a mixture of jewellery, art and household goods (e.g. boxes, piano keys) between 2012 and 2016, with a peak of 34 in 2013. These applications were all rejected as no EU certificate is required for such trade. (MEDIUM)

Spain reported no information on the quantity but suggested that most antiques in trade are figures, household goods and personal items. An increase in trade has been observed, which is believed to be due to private individuals selling their specimens in the economic crisis (NO INFO).

Sweden stated they believed the number of piano keys involved was increasing but otherwise there was no real change as auction houses are not very keen on selling ivory due to the difficulty of providing proof of legal origin (NO INFO).

For the remaining 14 Member States (AT, BE, BG, CZ, DE, DK, FI, HR, LT, LU, MT, PL, PT, RO) no information was provided on intra-EU trade of pre-1947 antiques and therefore no category was given (NO INFO).

Pre-Convention worked ivory Methodology:

Data collected between 2012 and 2016;

Data and information extracted from: https://ec.europa.eu/environment/cites/pdf/reports/EU%20ivory%20trade%20background%20report%20TRAFFIC%20Jan.%202019.pdf and the original datasets;

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Some Member States provided total quantities for the period 2012-2016, while others only

recorded quantities per year. As a result, total number of specimens and/or weight were used

to categorise the Member States (using the categories in Table 20).

Results:

Four Member States (Bulgaria, Estonia, Latvia and Slovakia) reported no intra-EU trade in pre-Convention ivory. (SMALL)

Eleven Member States reported trade in post 1947 worked ivory carvings between 2012-2016 (Table 24).

Table 24. Total reported quantities of intra-EU trade in pre-Convention worked ivory data between 2012 and 2016, as provided by eleven EU Member States

Member States Mass (kg)29 (Additional) no. of specimens

Category

AT 0 4 SMALL

BE 290 237 MEDIUM

CY 11 2 SMALL

CZ 2 0 SMALL

DK 55 241 MEDIUM

ES 8523 530 LARGE

FR 1698 6 LARGE

IT 6 2717 LARGE

NL 5 19 SMALL

PL 0 1 SMALL

SI 0 1 SMALL

TOTAL 10 590 3758

Spain and France were the main countries involved in intra-EU trade of both pre-Convention raw and worked ivory between 2012 and 2016, reporting ca. 97% of trade in worked specimens (based on mass [kg]) (Table 25) (LARGE). Table 25. Total reported weight of pre-Convention ivory traded in Spain and France between 2012 and 2016.

For worked specimens, the intra-EU trade from Italy was significantly higher than any other EU Member State, accounting for ca. 72% of all trade. However, over the years, trade levels have gradually decreased, from 898 specimens in 2012 to 188 specimens in 2016, respectively. (LARGE)

29 Rounded up to the nearest kilogram.

Year

Worked items (weight)

Spain France

2012 5729.683 402.6

2013 177.795 379.0

2014 461.657 515.1

2015 1666.221 292.4

2016 487.145 108.9

Total 8522.501 1698.0

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6.1.3 Results from stratified random sampling

Tables 26 and 27 indicate the final categories for the Member States. The final category for each

Member State was selected by choosing the most frequent category that appeared across the

different sources of data and information. For example, the results for Belgium all indicated the

categories ‘MEDIUM’, therefore the final category ‘MEDIUM’ was selected. If there was no overall

majority, then the average was taken, e.g. the results for Poland indicated two ‘SMALL’ categories and

one ‘LARGE’ category. Therefore, the final category of ‘MEDIUM’ was selected. Where there is an

asterisk next to the Member State, this indicates a country with historical links to Africa/Asia and an

“ivory culture” which has over the years resulted in individuals and traders accumulating significant

ivory collections. If there was an equal split across the different categories for those Member States

with historical links to Africa, then the higher category was selected. For example, the results for

Portugal indicated one ‘SMALL’ category and one ‘MEDIUM’ category. As Portugal has historical links

with Africa, the final category of ‘MEDIUM’ was selected.

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Table 26. Overview of EU Member State categorisation for each source of data

EU Member State

CITES Trade data (2013-2018)

Seizures data (2017, 2018)

ETIS Reports30 Intra-EU trade31 (2012-2016)

FINAL CATEGORY

CoP17 cluster analysis (2012-2014)

CoP18 cluster analysis (2015-2017)

Pre-1947 antiques

Pre-convention worked ivory

AT Medium Small Medium Medium No info Small MEDIUM

BE* Medium Medium Large Medium No info Medium MEDIUM

BG Small Small N/A N/A No info Small SMALL

CY Small Small N/A N/A Small Small SMALL

CZ Small Small N/A Medium No info Small SMALL

DE* Large Small Large Medium No info No info LARGE

DK Small Small N/A N/A No info Medium SMALL

EE Small Small N/A N/A Small Small SMALL

ES* Medium Large Medium N/A No info Large LARGE

FI Small Small N/A N/A No info No info SMALL

FR* Large Large Medium Large Large Large LARGE

GR Small Small N/A N/A Small No info SMALL

HR Small Small N/A N/A No info No info SMALL

HU Small Medium N/A N/A Medium No info MEDIUM

IE Small Small N/A N/A Small No info SMALL

IT* Large Medium Medium N/A Small Large LARGE

LT Small Small N/A N/A No info No info SMALL

LU Small Small N/A N/A No info No info SMALL

LV Small Small N/A N/A Small Small SMALL

MT Small Small N/A N/A No info No info SMALL

NL* Medium Medium Medium Medium Medium Small MEDIUM

PL Large Small N/A N/A No info Small MEDIUM

PT* Medium Small N/A N/A No info No info MEDIUM

RO Small Small N/A N/A No info No info SMALL

SE Small Small N/A N/A No info No info SMALL

SI Small Small N/A N/A Small Small SMALL

SK Small Small N/A N/A Small Small SMALL

Note: * Those EU Member States with historic colonial links to Africa

30 ‘N/A’ represents those Member States that were not included in the ETIS analyses for CoP17 and CoP18. 31 ‘No info’ represents those Member States that did not provide any data or information on intra-EU trade between 2012 and 2016.

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Table 27. Final categorisation of each EU Member State

SMALL MEDIUM LARGE

Bulgaria Austria France

Croatia Belgium Germany

Cyprus Hungary Italy

Czech Republic Netherlands Spain

Denmark Poland

Estonia Portugal

Finland

Greece

Ireland

Lithuania

Luxembourg

Latvia

Malta

Romania

Sweden

Slovenia

Slovakia