System Abuse

Ivory purchased legally in Japan is being illegally exported, undermining ivory market closures and the enforcement efforts of other jurisdictions. With abundant loopholes in the domestic trade controls, and limited border enforcement, the regulations are being circumvented and abused by criminals seeking to take advantage of Japan’s readily available legal supply of ivory – likely with the intent to supply the demand in other countries.

In 2022, JTEF analyzed court decisions from cases of ivory smuggled from Japan to China, including incidents from 45 identified cases spanned from 2010 to 2019. Fifteen cases were from 2018 and 2019, after China’s ivory market closure was implemented. The details of these cases indicate a significant level of organized crime in the majority of illegal exports from Japan to customers in China. Learn more in Smugglers’ Source and Ripe for Abuse. 

Other studies have highlighted that Japan’s legal ivory market is appealing to international travelers on the hunt for ivory trinkets. A 2020 study of Chinese travelers to Japan found that 19 percent planned to purchase ivory products and an estimated 12 percent actually did make an ivory purchase. The surveyed travelers who made purchases illegally exported the ivory to China either by plane or through the mail – results which align with the analysis of the Chinese court cases.

International seizure data aggregates from the CITES Elephant Trade Information System (ETIS) show that there were 321 ivory seizures (3.6 tonnes) connected to Japan between 2008 and 2025. Of those seizures, 267 out of 321 seizures (83%) and 3,022 out of 3,634kg (83%) were reportedly made outside of Japan. In a 2025 report for the 20th Conference of the Parties to CITES, Japan was linked to an estimated 10% of China’s worked ivory seizures, and China appeared along the global trade chain in 56% of worked ivory seizures. International seizures of legally purchased ivory in Japan make it clear that Japan’s domestic ivory market poses a threat to international efforts to combat poaching and the illegal ivory trade, particularly as others close their own domestic trades and markets shift. 

In early 2026, the Tokyo Metropolitan Police Department arrested individuals for violating the Act on Conservation of Endangered Species of Wild Fauna and Flora (ACES), by advertising and selling unregistered whole ivory tusks, with one suspect intent to illegally export the tusk to Thailand. In 2023, a sea freight shipment reportedly destined for Thailand contained 710 worked pieces of ivory from Japan that were seized.

These select cases highlight that more attention is needed to deter and prevent ivory from being illegally exported. If the government really wants to maintain the legal market, the Act on Conservation of Endangered Species of Wild Fauna and Flora (ACES) and its enforcement must be significantly strengthened, including with revised domestic trade regulations and special measures to prevent illegal export, and with more diligent monitoring of business transactions and records.

Japan must recognize that any open ivory market contributes to illegal trade and poaching and do its part to protect elephants.