MIRN – Response to Ivory Consultation

MIRN’s response to the UK Government’s consultation on banning the trade in ivory was submitted by email to the given address on 20 December 2017 and an official acknowledgement was received.  The two-page letter addressed several points:

  1. It made clear MIRN’s unequivocal support for any legislation that would be effective in ending the devastating illegal trade in ivory.
  2. It expressed strong support for the Option 2 solution outlined in the Government’s Consultation Document, which would allow an exemption for musical instruments.
  3. It made clear MIRN’s conviction that the continuation of sales of historic musical instruments which include, or in rarer cases are entirely made from, ivory contributes neither directly nor indirectly to ivory poaching today.
  4. It expressed MIRN’s support for a prohibition on the use of elephant ivory in modern instrument making.
  5. It made a case for the exemption for musical instruments to be the defining exemption rather than a restriction which relies on destructive testing or attempts to define complex and subjective qualities such as ‘historic’, ‘antique’ or ‘culturally significant’ by the facile and possibly unreliable assignment of a date.
  6. It requested clarification on what certification (p.15 Consultation document) would consist of for the sale of musical instruments which may contain ivory, such as pianos, violin bows and bagpipes.
  7. It suggested the establishment by Government of a licensed central repository of old and recycled ivory (such as might be obtained from the key coverings of discarded 19th-century pianos, or broken ivory flutes or other discarded non-musical items), where small amounts of ivory could be legally obtained by restorers and museum conservators for strictly prescribed purposes, thus discouraging the creation of a ‘black market’ for ivory.
  8. It asked that the defining qualification for musical instruments should be ‘musical instruments’ and not a ‘de minimis’ exemption, since there is an important minority of musical instruments that are fashioned mostly or wholly of ivory.
  9. MIRN expressed its appreciation for the opportunity to present our views and the Chair offered to meet with any DEFRA/Government representative(s) should they wish to discuss further any points in the letter.
  10. In closing, MIRN stated its concern that any new legislation provide a fair, effective and long-lasting framework that would safeguard both the future of elephants, and the material objects that trace human beings’ ancient relationship with them.

Any MIRN member who wishes to view a copy of the letter should apply to stating that they agree not to circulate it in print or online.