Japan’s Flawed Trade Controls

Japan’s regulatory framework allows the sale of ivory obtained before 1989 as well as ivory purchased in the two CITES-approved sales, but loopholes enable the trade in illegal ivory and facilitate illegal exports. Japan’s ivory trade controls are designed to facilitate trade, not to closely monitor the movement of ivory. The disjointed tracking system cannot ensure traceability of ivory from whole tusk to worked product – there are many loopholes and gaps in the system. 

Only whole tusks are mandated to be registered with the government, and this is the only stage at which ivory’s legal origin and acquisition is validated. Cut pieces of ivory are not registered, so the registration requirement can be easily avoided. Registered business operators must keep records and create “traceability information forms” for a certain size of cut pieces of ivory, but this tracking is separate from the whole tusk system. Additionally, most ivory items in Japan (like hanko) are small and do not meet the requirements for traceability information forms. The reality is that it is impossible to trace a whole tusk through being processed into worked products, and thus there are many opportunities available for illegal ivory to be laundered into the system.

Japan's ivory registration system has documented a large and persistent stockpile of whole tusks over three decades. The records for this stockpile are made available via reports under CITES. Between 1995 and 2025, Japan registered 34,273 whole tusks (392.8 tonnes). The stockpile, calculated by subtracting the consumed tusks from the registered tusks, peaked at 17,080 tusks (180.3 tonnes) in 2019 as a result of the government’s ivory tusk registration campaign, which urged the registration of tusks before new, tougher registration requirements went into effect, and has declined only marginally since.

The whole-tusk data are relatively straightforward, with retained stock representing the difference between registered tusks and tusks for which the registration cards were returned. Once a whole tusk is cut, the registration card is returned and the ivory moves on as cut pieces or finished products, tracked no longer as a single identifiable object but through records of transactions associated with the business. The registration data show that over time, 17,662 (219.3 tonnes) registered tusks were cut and processed into other products, thus leaving the whole tusk registration system. The remaining 16,611 tusks (173.5 tonnes) remain recorded as retained whole-tusk stock available on the market. Nearly half of everything officially registered has never formally left the system.

However, the scale of the accumulated cut-piece stockpile indicates a broader monitoring problem because its changes do not correlate with the weight of the whole tusks for which registration cards were returned. Whether the excess is derived from cutting illegally owned tusks or reflects neglected/delayed declarations, the system cannot account for the difference.          

Anyone who applied for business registration was required to register all whole tusks in their possession in 2018. However, the significant gap between the weight of the whole tusks from 2016-2017, for which registration cards were returned, and the addition of cut pieces during the same period, indicates that some traders evaded this requirement by cutting tusks into pieces.   

Business operators must record and keep inventory data and are required to use “traceability information forms” that include transaction records as of June 2018 for cut pieces of ivory; however, this system is delinked from the whole tusk registration system. Most of the ivory items in Japan, notably hanko, are small and do not meet the requirements (over 1 kg in weight and 20 cm in length) for the “traceability information forms.”

In short, there is no way to reliably track ivory in Japan’s ivory trade control system from its whole tusk origin through being cut and worked into a product for sale on the market. Japan records ivory entering the legal market as if it maintains its whole tusk shape, but what happens afterward is tracked with far less rigor, as ivory changes hands, is cut into pieces, is turned into finished products, and reaches the market. Each step adds distance between the physical ivory and the paperwork meant to account for it. While the realities of the legal system’s structure do not prove that laundering is taking place, these gaps describe a system in which downstream ivory movement becomes increasingly difficult to independently verify.