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Ivory Ban Consultation: Our Response

Wednesday 10 January 2018

NAVA Propertymark has responded to the Department for Environment, Food and Rural Affairs consultation on Banning UK Sales of Ivory.

In our response, we have outlined that the Government’s focus should be on enforcing current legislation and closing any loopholes that currently allow illegal trade to continue instead of moving forward with a total ban on all ivory sales. With the proper controls in place, increased checks to improve enforcement the illicit trade of ivory would be reduced which in turn would discourage poaching, which continues to decimate elephant populations.

It is clear that more needs to be done to safeguard the elephant population however, we don’t believe that there’s a link between the trade of cultural and historical items made before 1947 and the illegal poaching of elephants for their ivory.

A full ban will affect virtually every field of antique collecting and will deny collectors from preserving our cultural heritage because ivory is a material that has been used for centuries within furniture, silver, pictures and works of art, jewellery and many other items. Therefore, it would reduce the number of items of historical and cultural significance that are in existence.

The full response makes the following points:

  • The sale of musical instruments containing ivory should be exempt for the ban.
  • A de minimis exemption should not be included in the ban; we feel that the current legislation is clearer to understand as there is only a single exemption for items over 70 years old or pre-1947.
  • Items of artistic, cultural or historical value should be exempt from that ban and the exemption should be operated by issuing a lifetime passport that stays with the object even when its ownership changes.
  • Trade with or between museums should be exempt from the ban. Museums in the UK rely on and work with the antique sector to develop their collections and any restrictions could prevent future partnerships.
  • As well as museums regulated auction house and antique trades dealers should also be exempt from the ban.
  • UK Border Force have the professional staff with the specialist detailed knowledge to be able to enforce the ban. We have recently partnered with them on an initiative to remove endangered species items from circulation that lack provenance.

Read the full response

The consultation closed on 29 December 2017. The Government is analysing the feedback provided and aims to publish a summary of responses within 12 weeks.