What is Worked Ivory and When is it Importable?

Conservation Force

AH senior member
Jun 23, 2010
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What is Worked Ivory and When is it Importable?

There are two areas of confusion about import of elephant ivory hunting trophies. The first is: What is “worked” ivory? And the second is whether import permits can be obtained. It is extremely complex, but we will present it simply.

When is a tusk considered “worked” by the International Affairs Division of USF&WS? In September 2007, the Division’s narrowed definition of sporthunted trophy went into effect. Since then, trophies have been detained or seized for different reasons in different ports. Some have been detained or seized because they were mounted on decorative stands or there was a skin covering the cracked and chipped base/root area. By filing a claim to transfer to Federal Court, we have just recently obtained the release of tusks that were treated as “worked” because the root area had 6 inches of animal skin covering. That, we hope, is the last of those kinds of misinterpretations. Tusks mounted on bases are now normally being accepted. That includes those with decorative coverings and fastening parts at the root. The stamped numbers (“markings”) must be observable. Some import agents have been alert enough to offer to remove the base covering. Though denied, that offer has helped to ultimately get the tusks released. Of course, if the covering material is elephant skin, it must be separately included on the export permit and entered on the bottom validation section of the export permit.

It does not appear that any amount of painting, scrimshawing (pencil etching) or carving on the surface or deeper will be accepted. Even though the rational for the regulations in the Federal Register suggested that worked items are importable if coded “P” for personal instead of “H” for trophy, that is not true of elephant ivory.

We have processed an import permit application for an elephant tusk taken in Zimbabwe. It was denied. The request for reconsideration was denied, and the Acting Director just refused an opportunity to us to orally argue the merits and denied the final appeal. Permits to import “worked” ivory of elephant on Appendix II (Zimbabwe, Botswana, Republic of South Africa, and Namibia) will not be granted. Ditto Appendix I elephant.

We have two protracted court cases in New York and Atlanta fighting forfeiture of partially scrimshawed tusks of Appendix II elephant from Zimbabwe. The agency’s position is that they have been converted from hunting trophies. Therefore, they are not Appendix II, so an import permit is necessary. Of course, the agency won’t grant import permits. Consequently, wait until your tusks are home to have work done on them. That is permissible.

It is important to note that the agency does not stop there. It claims that the “worked” tusks are no longer considered trophies under the ESA and also the African Elephant Conservation Act (AECA), so once a tusk is “worked” it can never be imported. Both the hunters in the New York and Atlanta cases had the work done before the regulation went into effect, but the agency is unrelenting. I will not confuse you with the defenses we have raised or the fact that only the US takes this position. Just be informed you must have an import permit for “worked” elephant tusks because the agency views all “worked” ivory to be on Appendix I. Second, that the agency will not issue an import permit for “worked” ivory of any elephant. Therefore, “worked” ivory can no longer be imported. We have asked the Law Enforcement Division to publish and explain this plainly because this contradicts the Federal Register Notice. The notice states, “worked” items are importable if coded “P” and an import is allowed when on Appendix I, II or III. To date, we have no response. Take a lesson from hunters that have lost trophies: “worked” ivory is not importable.

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