Still Waiting for Action: Tokyo’s Ivory Trade Assessment

The reality of the scope and impact of COVID-19 hit home for much of the world when the Tokyo 2020 Games were postponed. A year later and looking far different than ever expected or hoped, the Tokyo Olympic and Paralympic Games finally arrived. As the host of the 2020 Games, Tokyo has come under increased scrutiny for its legal market for elephant ivory. Even as the Games were underway, the influential capital city faced mounting international pressure to close its legal ivory market for good. For World Elephant Day 2021, in between the Tokyo 2020 Olympics and Paralympics, we take a look at where Tokyo stands in doing its part to protect the world’s elephants from the threats of ivory trade and poaching.

Simply put, poaching has continued, even in spite of COVID-19. Earlier this year, the IUCN raised the threat level of the savannah elephant from Vulnerable to Endangered and listed forest elephants separately as Critically Endangered, underscoring the need for urgent action to protect elephants from the trade in their ivory. Experts worldwide agree that legal ivory markets provide a cover for illegal ivory trade, stimulate demand and trade, and undermine enforcement and public awareness efforts. For years, the Government of Japan’s domestic ivory market has faced international criticism of its poor regulations and illegal trade and export problem. While many nations and jurisdictions have prohibited most legal trade in ivory, Japan’s ivory market remains open in spite of overwhelming evidence of illegal domestic activity and its contribution to the illegal international trade.

Tokyo’s Ivory Assessment

In a move that suggested a willingness to take stronger action on ivory trade than the national government, in early 2020 the Tokyo Metropolitan Government (TMG) announced the development of an expert panel to explore and discuss measures to prevent illegal ivory trade and export. Tokyo’s Governor Yuriko Koike expressed her commitment to taking meaningful action to address the ivory trade within her jurisdiction and fulfilling Tokyo’s responsibility to the global community as a leading international city. In her opening remarks at the announcement of the assessment, Governor Koike stated that as the host city of the Olympics, Tokyo is responsible for resolving the problem of ivory trade.

The committee’s main tasks were to examine the ivory trade within Tokyo, analyze the existing regulations on domestic trade, and assess and propose measures to be taken by the TMG. Unfortunately, the advisory committee, set to meet several times before releasing policy recommendations in May 2020 before the Games, was put on hold as Tokyo understandably shut down and focused on protecting public health and postponing the world’s most complicated organized event.

Governor Koike highlighted that the advisory committee should guide Tokyo’s actions and policies regarding ivory trade regulation. An initial meeting was held at the end of January 2020 essentially to introduce the panel of experts and clarify the mandate. In October 2020, Governor Koike submitted a petition to key Ministers of the national government requesting the Government of Japan strengthen measures to improve ivory trade regulation; still, the petition does not explicitly refer to the closure of the domestic ivory market. After a long pause, in December 2020 the second and third public meetings of the panel of experts were held. Between the third and fourth meeting, committee members submitted their recommendations to TMG. After being pushed back due to Tokyo’s COVID-19 emergency status, a fourth meeting was held in March 2021. The fifth meeting, which is intended to focus on concrete steps TMG could take to address the ivory trade, was slated for May/June 2021, but it has yet to happen. As far as we know, collective Council recommendations were never submitted to TMG.

Appeals for Market Closure

Numerous stakeholders including non-government organizations, experts in conservation biology and law, and governments, have shared their views throughout Tokyo’s assessment process urging the TMG to close its domestic ivory market and join other nations and jurisdictions in their efforts to protect elephants from the trade in ivory. Many, but not all, have made their appeals public, and we share some of them here.

Leading up to Tokyo’s assessment, in 2019 NYC Mayor de Blasio appealed to Governor Koike to close Tokyo’s ivory market in advance of the Olympics while U.S. Congressional Representatives urged national level action. Governor Koike cited de Blasio’s letter publicly several times at the start of Tokyo’s assessment process.

In March 2020, EIA and 29 other NGOs sent a letter to Governor Koike and the committee members, urging a ban on ivory trade in Tokyo. After a pause in respect of COVID-19 crisis management, in June, EIA, and close allies Japan Tiger and Elephant Fund, a leading Japanese NGO fighting to end ivory trade in Japan, and Humane Society International, issued a statement urging the TMG to resurrect the ivory trade assessment process. Others followed, sending letters appealing for Tokyo to take action to protect elephants by eliminating its ivory trade. Among them were: African Elephant Coalition Council of EldersWildlifeDirectSave the ElephantsThe Association of Zoos and Aquariums, and former CITES Secretary General Peter Sand.

In 2021, 26 NGOs made recommendations to Tokyo for urgent measures to take before the Olympics and before the ivory market could be legally closed. Some African nations also directly appealed to Governor Koike and the TMG, including Niger, Sierra Leone, Burkina Faso, and Liberia. After WildAid and the Japan Tiger and Elephant Fund released a report on Tokyo’s ivory trade in March, Leonardo DiCaprio and Richard Branson publicly called for Japan to cease the sale of ivory. In April, a delegation of Members of the U.S. Congress from Oregon, led by Congressman Earl Blumenauer, appealed to Tokyo’s Governor Yuriko Koike to take steps to close Tokyo’s market for ivory.

Most recently, former Secretaries of State Hillary Clinton and James Baker III published an influential opinion piece in July making a strong case for Japan to finally end the sale of elephant ivory and preserve its reputation as a global leader. Despite these public appeals, and other direct appeals from experts and stakeholders including government officials to Tokyo and Japanese government representatives, little action has been taken by Tokyo or Japan thus far.

Disappointment from Tokyo

EIA and others hoped that the TMG would fulfill its international obligation and heed the advice of some of the experts, taking steps towards closing the market within its jurisdiction. At the very least, announcing the intent to ban ivory sales in the future would have sent a powerful message before the Olympic Games. But our appeals and expectations were met with disappointment. In June 2021, about a month before the start of the Olympics, the Tokyo Metropolitan Government released its plan for short-term measures to prevent illegal exports around the Games. TMG announced that it “decided to implement measures to prevent the illegal transportation of ivory products overseas by cooperating with the national government and taking into consideration the opinions of the expert panel.” This plan essentially replicates an existing and failing national government awareness campaign focused on consumer awareness rather than taking substantive action.

Several panel members strongly recommended going beyond simple awareness measures, so it appears some committee recommendations were selectively disregarded. To put it bluntly, TMG’s plan is a huge disappointment and the business-as-usual approach that it proposes is a bitter pill to swallow after months of consultations and impassioned appeals from African elephant range states and others.

It is not clear what happened and we are left with more questions than answers: Did COVID complications take over with this issue falling through the cracks for now? Or was there never true interest by TMG in addressing the ivory trade problem? Did Tokyo just give up and default to the national government position? What was really the point of this 18+ month process?

National Approach: Inaction

EIA has been urging the Government of Japan to close its domestic ivory market for years. Our investigations and research have consistently exposed the loopholes and problems with Japan’s domestic market and highlight the need for Japan to close its market. The Government of Japan has done little to control the illegal ivory trade, and its legal domestic market serves as a shield for illegal activity, including illegal exports. For example, between January 2018 and December 2020, EIA documented 76 seizures of ivory from Japan made in other countries, with 72 occurring in China, totals which surely are an underestimate.

recent study of Chinese travelers to Japan found that 19% planned to purchase ivory and an estimated 12% actually did make an ivory purchase, with the majority bringing that ivory home to China by plane or through the mail. Investigations by EIA and JTEF in 2020 of Japanese hanko retailers found that many are willing to sell an ivory product knowing that it will be exported internationally despite most being aware that ivory export is illegal. These findings were bolstered by WildAid and JTEF’s report in early 2021, which documents ivory businesses in Tokyo targeting Chinese consumers.

In response to international concerns, the Government of Japan has made only superficial changes to its domestic ivory trade controls, instead choosing to support its ivory industry and traders by upholding its domestic ivory market. Particularly with the European Union’s plans to close the market, Japan’s legal domestic ivory market remains a global outlier.

Moving Forward: Recommendations

EIA and others are continuing to urge the TMG to ban ivory sales within Tokyo’s jurisdiction, which can be achieved through an Ordinance adopted by the Tokyo Metropolitan Assembly. In addition, we are urging the TMG to take steps to discourage ivory sales while the process to ban trade is being implemented and before it could enter into force. We also urge the Governor and Tokyo Metropolitan Government to explicitly recommend to the national Government of Japan to close the domestic ivory market in compliance with CITES Resolution Conf. 10.10 (Rev. CoP18).

It is not enough to make ivory trade “appropriate“; the market must be closed. The Tokyo Metropolitan Government can and should go further, paving the way for Japan to do more to fulfill its international obligation to other nations truly working to protect the world’s iconic elephants from the trade in their ivory.

To learn more about EIA’s Japan ivory campaign, please visit