Input paper on document 65.4 for the CITES SC78 meeting

Date: January 21, 2025
Subject: DOCUMENT 65.4 FOR THE UPCOMING CITES SC78
Response: Exercise Caution Against Biased Interpretation of Ivory Market Analysis

The summary of responses in the document 65.4 highlights the complexity and varying interpretations surrounding the purpose of analyzing domestic ivory markets under Decision 19.99. While it is valuable to explore the dynamics between legal domestic ivory markets and illegal activities, it is crucial to avoid over-interpreting or selectively using information to justify biased decisions, particularly when there is no conclusive evidence linking legal ivory markets to illegal sales or poaching.
Key points of caution include:
1. Scope and Intent of Analysis: The broad range of objectives outlined—ranging from addressing poaching concerns to providing technical advice—shows that Parties have different expectations of the analysis. Without a clear and unified purpose, conclusions may reflect pre-existing biases rather than objective insights.
2. Inconsistent Data and Low Response Rates: The Secretariat’s acknowledgment of low response rates to Notifications and the inconsistent quality of data provided underscores the limitations of the analysis. Drawing definitive conclusions from incomplete or unevenly distributed data risks
undermining the credibility of decisions.
3. Diverse Domestic Market Regulations: Parties with regulated markets, prohibitions with exemptions, or total prohibitions vary widely in their approaches. Simplistic comparisons between these groups may overlook contextual nuances, such as the nature of exemptions or the regulatory capacity of individual Parties, leading to misleading conclusions.
4. No Proven Causal Link: Current evidence does not support a causal relationship between legal domestic ivory markets and increased poaching or illegal trade. Misinterpreting correlations as causations can lead to unfair restrictions on regulated markets without addressing the underlying drivers of poaching, such as weak enforcement or poverty in source regions.
5. Potential Bias in Decision-Making: Using limited or selectively interpreted data to push for domestic market closures or stricter regulations risks marginalizing Parties with well-regulated markets. Instead, decisions should be grounded in robust evidence that accounts for regional differences and the actual effectiveness of various regulatory frameworks.
Recommendation:
• Ensure the analysis considers diverse regulatory frameworks and their enforcement capacity rather than drawing blanket conclusions.
• Avoid using partial or incomplete data as a basis for sweeping policy changes, as this could lead to ineffective or inequitable outcomes.
• Encourage Parties to provide more comprehensive and transparent data to improve future analyses and align policy decisions with evidence-based insights.
By maintaining objectivity and resisting biased interpretations, Parties can foster balanced, informed decision-making that genuinely addresses illicit financial activities while respecting the diversity of domestic markets.