CITES 2002 www.panda.org/species/cites WWF POSITION STATEMENT 12th Meeting of the Conference of the Parties to CITES, Santiago, 3-15 November 2002 African elephants Props. 6, 7, 8, 9, 10, 11 Botswana, Namibia, South Africa, and Zimbabwe propose a range of amendments to the annotations to the listing in Appendix II of their African elephant populations. These amendments would allow trade in an expanded range of elephant products, including hunting trophies, live animals, hides, leather goods, raw ivory and worked ivory. All proposals seek to establish initial and subsequent annual quotas for trade in raw ivory. All specify that trade in raw ivory from these populations not take place until 18 months after such amendment. The proposal from South Africa further specifies that ivory exports would be limited to existing stocks of tusks or ivory pieces of more than 20 cm in length and one kilogram in weight originating from Kruger National Park. Zambia has proposed the transfer of its elephant population from Appendix I to Appendix II, with an annotation to allow trade in live animals and trade in raw ivory. Kenya and India have proposed the transfer of all African elephant populations currently listed in Appendix II to Appendix I. See following page for full summary of proposals BIG LEAF MAHOGANY, A BARTSCHI, WWF-CANON SIBERIAN TIGER, KLEIN/HUBERT, STILL PICTURES ASIAN ELEPHANT, A COMPOST, STILL PICTURES
Summary table of CoP 12 elephant proposals (adapted from the TRAFFIC Recommendations on Proposals to amend the Appendices at CoP 12) Substantive proposed amendments to the Appendices are indicated in bold. Proposal Proponent Current Annotation Proposed Annotation/Transfer Prop. 6 Botswana Export of hunting trophies Trade in hunting trophies; Export of live animals. Trade in raw ivory under an initial quota of not more than 20,000kg and an annual quota of not more than 4,000kg; Trade in hides; Trade in leather goods; and Trade in ivory carvings. Prop. 7 Namibia Export of hunting Trade in hunting trophies; trophies; and Export of live animals. Trade in raw ivory under an initial quota of not more than 10,000 kg and an annual quota of not more than 2,000 kg; Trade in hides; Trade in leather goods; and Trade in ivory carvings. Prop. 8 South Africa Trade in hunting trophies; Trade in hunting trophies; Trade in hides; and Trade in raw ivory under an Trade in leather goods. initial quota of 30,000 kg and an annual quota of not more than 2,000 kg; Trade in hides; and Trade in leather goods. Prop. 9 Zambia [Appendix I] To Appendix II to allow: and Trade in raw ivory under an initial quota of 17,000 kg. Prop. 10 Zimbabwe Export of hunting trophies; Trade in hunting trophies; Export of live animals; Export of hides; Trade in raw ivory under an initial Export of leather goods; quota of not more than 10,000 kg and Export of ivory and an annual quota of not carvings. more than 5,000 kg; Trade in hides; Trade in leather goods; and Trade in ivory carvings. Prop. 11 Kenya [Populations in All populations currently in and India Appendix II] Appendix II to Appendix I.
1. General background WWF has a significant long-term commitment to elephant conservation in both Africa and Asia, with active field elephant conservation programmes in numerous countries in both regions. In these conservation programmes, as well as in our participation at CITES, we are guided by a single objective: ensuring the longterm future of African and Asian elephants in the wild. WWF supported the inclusion of the African elephant in Appendix I of CITES at CoP 7 in 1989, in order to combat a massive illegal trade in ivory causing dramatic declines in elephant populations throughout most of Africa in the 1970s and 1980s. The evidence indicates that the 1989 Appendix I listing was successful in eliminating some major ivory markets, leading to reduced poaching in many countries and allowing populations to recover. Since that time, international commercial trade in raw ivory has been banned, apart from a single shipment of ivory from southern African nations to Japan, in 1999. This was made possible by the transfer from Appendix I to Appendix II of the African elephant populations of Zimbabwe, Namibia and Botswana in 1997 and of South Africa in 2000. Throughout this entire period, and despite the relative success of the 1989 ban, illegal killing for illegal trade in ivory has remained a complex and ongoing problem. i. CITES and international monitoring of illegal elephant killing and trade The overriding concern of the CITES Parties must be to ensure that their decisions on elephant trade effectively combat illegal killing and trade of elephants and their products, while allowing, where relevant, trade-related conservation benefits to be realised. This concern goes to the heart of the credibility of CITES as an international institution. In 1997, in Res. Conf 10.10, CITES Parties mandated the development and implementation of two major tools to achieve this goal: MIKE (Monitoring the Illegal Killing of Elephants) and ETIS (Elephant Trade Information System). ETIS, established and maintained by TRAFFIC-the wildlife monitoring network (a joint programme of WWF and IUCN), in cooperation with the CITES Secretariat, comprises elephant product seizure records going back to 1989, which are used as a basis to assess trends in illegal trade. It allows assessment of the impact of several vital factors on levels of illegal trade in elephant products, including domestic ivory market scale and regulation, levels of corruption, law enforcement effort, underlying economic trends and, indirectly, ivory trade decisions of the CITES Parties. TRAFFIC will present at CoP 12 an analysis of this data, indicating, among other insights, the primary importance of large, poorly regulated domestic ivory markets in driving patterns of illegal trade. WWF is currently supporting training and capacity building for effective ETIS implementation in Africa. MIKE is an international site-based system to monitor illegal killing of elephants in their range states in Africa and Asia, currently in the process of implementation. WWF is working co-operatively with the MIKE team to determine how it may support MIKE implementation in Africa. ii. Illegal ivory trade in Africa and Asia Recent TRAFFIC reports on the ivory market in a number of Asian countries have revealed a persistent demand for ivory products, continuing illegal trade, and weaknesses in legislation and enforcement. In China, despite the decline of the state-run ivory carving industry since the international ban, illicit ivory remains much in demand, with the ivory carving industry now believed to be run mainly by private, and illegal, family operations. The increasing power of Chinese consumers and weak enforcement of ivory trade regulation add further concerns to the future development of China as a major ivory consumer. In Taiwan, domestic sale of ivory is permitted under strict regulations but smuggling and illegal trade activities still persist. In Vietnam, open markets for elephant products, mostly curios, continue to serve both the domestic market as well as tourists from other parts of Asia. Most of these markets remain poorly regulated and, to a large extent, rely upon illegal sources of ivory. In Myanmar, legislation allows trade of products derived from domesticated
elephants, creating a large potential loophole in which wild-caught elephants and elephant parts from other countries could be 'laundered'. Domestic trade is also a growing concern in Africa. According to an analysis by TRAFFIC of the ivory seizure data in ETIS, illegal ivory trade in Africa is most strongly correlated with the presence or absence of unregulated domestic ivory markets. A number of countries in Africa have active ivory carving industries that are not yet structured, organised or controlled. Ivory products are openly sold in tourist curio markets, hotels and other retail outlets, completely disregarding CITES recommendations and with little government interference. In one known case, ivory products were even available for sale in the departure lounge of an international airport in flagrant violation of CITES. Comprehensive legislative, regulatory and enforcement measures need to be adopted in these countries that will address issues such as registration or licensing all importers, manufacturers, wholesalers and retailers dealing in ivory products. Even where legislation is in force, legal loopholes in some countries currently allow unregulated, unreported and illegal trade in ivory. Domestic trade controls also need to be implemented to document and monitor the flow of ivory. iii. Conservation of African and Asian elephants International and domestic trade control is only one component of a much larger elephant conservation agenda. Elephants face a range of serious threats across their range, including increasing human-elephant conflict, diminishing range due to the spread of agriculture and other intensive uses, and declining budgets for protected area management and law enforcement. As crucial as domestic and international trade controls are measures for strengthening the infrastructure of parks and protected areas, integrating elephant and human needs outside protected areas and developing methods to mitigate conflict, developing conservation programmes that provide benefits and conservation incentives for local people, expanding appropriate ecotourism opportunities, conducting applied scientific research, including effective habitat and population monitoring, and training and equipping park managers, anti-poaching units and other law enforcement agents. WWF is actively engaged with these efforts, in both Asia and Africa. Elephant conservation and management needs vary greatly from country to country and region to region, due in part to differences in elephant population numbers, vegetation and human densities. In southern Africa, for example, where some of the largest elephant populations remain, elephant management approaches employed by range states in savanna and miombo differ greatly from those used by West African and Asian states with threatened and fragmented forest elephant populations. In Central Africa, poorly known elephant populations inhabit dense rain forest, greatly hampering effective management. The contrast in population numbers between states is immense: Botswana, for instance, may have over 100,000 elephants, while no range state in West Africa has a population above 4,000. As the responsibility for conserving elephants lies ultimately with the range States of both Africa and Asia, it is vital that they build consensus and mutual understanding of their individual concerns. The ongoing African elephant range states Dialogue process has been crucial in this regard, and a range States Dialogue involving Asian range states could prove equally valuable. The international community, international donor institutions, and CITES Parties with greater financial resources should stand ready to assist range States on request.
2. Trade in raw ivory Proposed amendments 6(c), 7(e), 8(d), 9(a), 10(a) Proponents: Botswana, Namibia, South Africa, Zambia, Zimbabwe WWF position: Oppose WWF recognises and applauds the success of many Southern African elephant range states in conserving and managing their elephant populations. WWF has active field programmes which contribute to elephant conservation in Namibia, Zambia, Zimbabwe, and South Africa. WWF recognises that elephant conservation and management work requires large revenues. While different countries employ different models to secure sustainable funding sources for this vital work, including eco-tourism and trophy hunting, we recognise that income from trade in elephant products can, and has, provided revenue for elephant conservation. In many countries, including Southern Africa, the large majority of elephants live outside of protected areas, and large and often growing populations can cause severe impacts on local people, typically the rural poor. WWF recognises that ensuring long-term effective conservation in much of the region requires working closely with local communities, and ensuring that they have incentives to maintain elephant populations, rather than destroying them or converting land to agriculture and other intensive uses. Community based conservation programmes in Southern Africa highlight the successes that can be gained with such an approach. We recognise further the role that revenues from trade in elephant products can play in providing these incentives, although different approaches are certainly possible. However, the prospect of trade in ivory from southern African elephant populations raises serious concerns regarding the potential for such trade to lead to increased illegal killing of both African and Asian elephants. Recent decades have seen a distressing decline in West, East and potentially Central African, and Asian elephant populations. While these populations are impacted by widespread loss of habitat and conflicts with humans, illegal killing for both ivory and, increasingly (in Africa), elephant meat, remains a key threat. The status of the Asian elephant is of particular concern. The population of Asian elephants stands at only around one-tenth of that of African elephants, and poaching may already have caused disruption to sex ratios in these populations due to ivory being carried only by males. Our understanding of factors influencing illegal killing and trade in ivory remains limited, although we look to the ETIS report presented at CoP 12 for further understanding. Approval of further legal international ivory trade may risk sending the message to poachers, "middlemen" and governments that ivory trade is legal or may become so, potentially encouraging increased killing and/or stockpiling of ivory. It is essential to ensure that potential conservation benefits to the elephant populations of proponent range States do not lead to negative impacts on elephant populations in other range States in Africa or Asia. This has been one of the strongest and most consistent messages from both the CITES Conference of the Parties and the African elephant range States Dialogue over the last several years. We therefore believe that the following conditions must be satisfied before the CoP considers proposals for re-opening trade in ivory: a) comprehensive enforcement controls are in place in both exporting and importing countries that effectively minimise the risk of illegal ivory infiltrating any further legal trade; b) mechanisms are in place in the proponent country or countries that will ensure that the conservation status of the elephant population(s) concerned and their environment will be enhanced directly as a result of any revenues raised;
c) mechanisms are in place whereby independent monitoring of the sourcing, marking, packing, export and import of ivory can be carried out under the auspices of CITES; d) MIKE (Monitoring the Illegal Killing of Elephants) has established a base line, and sustained data collection at site level is ongoing and sufficient to produce analytical reports in the future as required. We note that ETIS is already operational, and forms the basis of a full analytical report at CoP 12. WWF draws the attention of the CITES Parties in particular to the importance of the international monitoring systems on illegal killing and trade (condition (d)). MIKE and ETIS were mandated at CoP 10 in 1997 in both Decision 10.1 and Res. Conf. 10.10. ETIS is operational and returning reliable data for analysis. However, while important progress has been made in the development and implementation of MIKE, this system is currently inadequately developed to provide substantive information to assist the CITES Parties in decision making. We note in this respect that MIKE will be submitting only an implementation progress report at CoP12, and will not be delivering a substantive report until CoP13. We thus believe resumption of international trade in ivory is premature. Although these Parties deserve support and credit for their success in conserving and managing their elephant populations, WWF urges Botswana, Namibia, South Africa, Zambia, and Zimbabwe to withdraw their proposals regarding amendments to the Appendices to allow such trade. 3. Trade in elephant products other than raw ivory i. Hunting trophies, hides and leather Proposed amendments: 6 (d),(e); 7 (c),(d) Proponents: Botswana, Namibia WWF position: Support The elephant populations of Botswana and Namibia are included in CITES Appendix II, with certain annotations. WWF believes that these populations are appropriately listed in the CITES Appendices. WWF supports amending the associated annotations to these listings to allow for the proposed trade in nonivory products, including hunting trophies (already permitted under current annotations), hides, and leather goods, provided that the Conference of the Parties is satisfied that effective enforcement controls for such commodities are in place in proponent countries. ii. Ivory carvings Proposed amendments: 6 (f); 7 (d) Proponents: Botswana, Namibia WWF position: Oppose With respect to trade in ivory carvings, WWF has serious concerns regarding effective domestic regulation of ivory markets. Poor regulation of domestic ivory markets has emerged as a key factor in the existence of illegal ivory trade, in the TRAFFIC analysis of ETIS seizure data presented at CoP 12. A number of measures to control domestic ivory markets have been set out in Res. Conf. 10.10. It is imperative that a mechanism is established to ensure effective regulation and control of these markets before a legal domestic ivory carving industry is considered.
iii. Live animals Proposed amendments: 9 (a) Proponent: Zambia WWF position: Oppose WWF does not object in principle to the current annotation allowing trade in live elephants from South Africa. This annotation is conservation-based, and allows only for trade in live animals for re-introduction purposes into protected areas formally proclaimed in the legislation of the importing country. It is hoped that this measure might reduce South Africa s current need to cull elephants due to lack of adequate range. However, WWF is concerned about the lack of detail specifying the conditions of export of live elephants from other states. WWF only endorses removal from the wild and export of live elephants for legitimate reintroduction, translocation, or other conservation purposes that are designed to enhance the conservation of the species in the wild, and only as a strategy of last resort. In this regard we look forward to the issuing of guidelines on translocations, currently under discussion by the IUCN African Elephant Specialist Group. 4. Transfer of the Zambian population of African elephants from Appendix I to Appendix II Prop. 9 Proponent: Zambia WWF position: awaiting report of panel of experts Zambia has proposed to transfer its population of elephants from Appendix I to Appendix II, with an annotation to allow trade of 17 tonnes of raw ivory obtained from management operations, and live sales under special circumstances. In 1997 the CITES Parties agreed a process for the transfer of populations of African elephants from Appendix I to Appendix II, in Res. Conf. 10.9. Proposals to transfer these populations undergo a review process by a Panel of Experts nominated by UNEP, IUCN and TRAFFIC International. This panel assess scientific evidence available regarding numbers and trends of the indicated population, the conservation and management of these populations, and threats to their status, and the adequacy of controls on trade in ivory and other parts and derivatives. WWF awaits the findings of this Panel of Experts in order to formulate recommendations on this proposal. However, for reasons given above, we believe any such downlisting should not be accompanied by an annotation allowing trade in raw ivory, and our concerns, expressed above, regarding trade in live animals remain applicable. 5. Proposal to transfer all african elephant populations currently listed in Appendix II to Appendix I Prop. 11 Proponents: Kenya/India WWF position: Oppose Kenya and India have proposed the transfer of the African elephant populations of Zimbabwe, South Africa, Botswana and Namibia from Appendix II to Appendix I. The criteria for listing on Appendix I are established by the Convention in Article II, and elaborated in Res. Conf. 9.24. The biological criteria which must be fulfilled for species to be listed on Appendix I are set out in Annex I of Res. Conf. 9.24, and may be met if the
population under consideration is (or is likely to be in five years) either small, or with a restricted area of distribution, or subject to declining numbers. The southern African elephant populations currently listed in Appendix II show every evidence of being large, extensively distributed and in all four countries show evidence of ongoing healthy growth. WWF considers that these populations clearly do not meet the criteria for Appendix I. We thus urge Kenya and India to withdraw this proposal. 6. WWF summary recommendations for CITES CoP 12 Recommendations on elephant trade proposals Proposal Proponent(s) Proposed Amendment Recommendation 6(c), 7(e), Botswana, Namibia, Raw ivory Oppose 8(d), South Africa, Zambia, 9(a),10(a) Zimbabwe 6(d),(e), Botswana, Namibia Hunting trophies, hides and leather Support 7(c),(d) 6(f), 7(d) Botswana, Namibia Ivory carvings Oppose 7(a) Zambia Live animals Oppose 9 Zambia Transfer Zambian population Await panel of to Appendix II experts report 11 Kenya/India Transfer all populations on Oppose Appendix II to Appendix I
Further recommendations 1. WWF urges decisive action by the Conference of the Parties to address the issue of unregulated domestic markets for ivory in Africa and Asia. These have emerged as major drivers for large scale patterns of illegal ivory trade, with consequent impacts on elephant poaching and population decline. Required actions include commitments to support capacity building and training, implementation of increased trade controls and enforcement efforts, and legislative and regulatory reform. 2. WWF urges increased debate and understanding among CITES Parties and the NGO community, in both Africa and Asia, of the operation, capabilities and limitations of MIKE. 3. WWF urges the Conference of the Parties to support the effective operation of MIKE and ETIS, to allow increased understanding of the patterns and scale of illegal killing and trade in elephants and their products. 4. WWF urges the Conference of the Parties to consider decisions and actions to address the current status of the Asian elephant, in particular combating widespread poaching for domestic and international trade. 5. WWF encourages the Conference of the Parties to recognise and address the illegal elephant killing of elephants for meat, including for international markets, in addition to killing for trade in ivory. WWF s mission is to stop the degradation of the planet s natural environment and to build a future in which humans live in harmony with nature, by: conserving the world s biological diversity ensuring that the use of renewable resources is sustainable promoting the reduction of pollution and wasteful consumption. WWF International Species Programme Panda House, Weyside Park Godalming, Surrey GU7 1XR United Kingdom E-mail: information@wwf-species.org www.panda.org/species Panda symbol 1986 WWF WWF registered trademark Printed on recycled paper made from 100 per cent post consumer waste Project number 1506/September 2002