Antique Ivory
Mar 12 2019 | CINOA

CINOA EU Ivory trade submission 2019.02.06 as follow up to the EU stakeholders meeting on 2019.01.28

**Summary & document submitted to the EU**
EU stakeholder meeting on ivory trade — Brussels, 28 January 2019
6 February 2019
As follow up to our email on 21 January, the January 28 2019 EU Stakeholders meeting on the ivory trade was organised by the Commission to help them to evaluate whether it is deemed necessary to tighten the rules and streamline current regulations. The majority of participants were from wildlife conservation groups, but there were art market trade representatives from Spain, Belgium, France, UK, Germany & CINOA, as well as a handful of individuals representing owners of musical instruments who put forward their arguments.
The Commission floated the idea of tightening up on the proof needed for pre-1947 worked ivory, although the wildlife conservation groups called for more stringent rules and some promoted the idea of a total ban immediately. CINOA and the other art market representatives, as well as the musical instruments representatives, made clear that a total ban would be disproportionate and any tightening of rules should focus on high risk areas.
Although CINOA does not see a connection between the appalling acts of poaching and old pre-1947 ivory, we underscored the trade’s willingness to work with the authorities. The representatives of the trade re-offered to provide, if necessary, an ivory certification service that could be performed by specialist dealers or trade associations. We stressed that an evaluation of the age of ivory does not always require invasive and expensive scientific testing, although we do recognize that in some specific cases, scientific testing might be necessary. If the rules governing checking were to be tighten, they would have to be workable. Implicit in targeting the higher risk objects would be the need to define then in terms of the amount or proportion of ivory they contain.
Regarding the timeline, the Commission cannot go any further without discussions with Member States’ representatives.  Any changes to the rules would follow the normal EU processes, depending on the nature of the change.
Please find the link to the document CINOA EU Ivory trade submission 2019.02.06 as follow up to the EU stakeholders meeting on 2019.01.28 that was submitted today to the European Commission on behalf of CINOA following their request for input before 6 February 2019. The attached document, which is meant to provide the broad lines of the concept of trade certification, was drafted with input from those that attended the EU Stakeholders meeting on 28 January, the CINOA Round Table meeting on 31 January as well as several other dealer experts in Ivory.
In addition, two other documents were submitted: 1) a BADA & CINOA joint document which comments on the *non-paper* that was issued by the EU to generate discussions at the stakeholders meeting 2) Anthony Meyer, on behalf of the groups he represents, submitted a paper that is in line with the CINOA submission. (available on request).

For more information, contact Erika Bochereau at