The Illusion of Control: Hong Kong's 'Legal' Ivory Trade

For more than a century, Hong Kong has been a hub for the global ivory trade. Due to the region’s high overall trade volumes, easy access to mainland China, and lax regulation and supervision, this role continues, despite the 1989 international commercial ivory trade ban. Hong Kong has been the gateway through which the tusks of hundreds of thousands of poached elephants have been laundered—first en route to Japan, and more recently, to China. Officials claiming to regulate the trade provide a façade of legitimacy while making no physical link between the ivory itself and the paper trail with which they legitimize it. In short, Hong Kong has been the ivory poacher’s and smuggler’s laundry.

At the time of the 1989 ban, Hong Kong held 670 tonnes of ivory, much of it highly dubious in origin and laundered through the discredited quota system under the UN Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). Rather than set a deadline for selling off this stock and closely monitoring its disbursement, Hong Kong’s Agriculture, Fisheries and Conservation Department (AFCD), the government agency charged with implementing CITES, has continued to allow unregulated sales for 26 years, making no meaningful checks to ensure the ivory is from the original stock and not from recently poached elephants. Traders admit they routinely replenish stocks with newly poached ivory, as there is no system to connect any individual tusk or ivory product to required documentation. Essentially, the AFCD has provided unlimited license to launder poached ivory. Nearly all of Hong Kong’s ivory vendors flout even the most basic regulation: the requirement that vendors clearly display licenses in their stores.

In international meetings, AFCD officials have defended—and even promoted—continued domestic trade, insisting that its system is airtight, when in fact nothing could be further from the truth.

It’s clear that the AFCD lacks the resources, capability and desire to monitor the ivory trade, even superficially. Though long-term sales trends indicate that Hong Kong’s stockpile should have been exhausted around 2004, 111.3 tonnes remain unsold, a figure that has barely changed in recent years, when demand for ivory has been the highest-ever, fueled by mainland China’s economic growth. A recent study indicated that over 90% of the ivory sold in Hong Kong is purchased by tourists from the mainland (47 million visited in 2014), with unscrupulous vendors coaching them on how to successfully evade detection when smuggling it back to China.

According to the latest figures, up to 33,000 elephants are poached each year for their ivory. In a recent poll, 75% of the Hong Kong public interviewed supported a ban on ivory sales. China and the United States recently announced a joint commitment to ending all commercial ivory sales—a move that is undermined by Hong Kong’s ongoing laundering and illegal exports.

WildAid and African Wildlife Foundation recommend that the Hong Kong government take the following immediate actions:

  1. Join China and the United States in announcing a ban on all domestic ivory trade.
  2. Establish a full-time investigative wildlife crime unit.
  3. Allocate more resources to combating wildlife crime.
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