African Elephant Hunting Trophy Import

Page Updated: Feb 2020

This is a closer look at the current state of play regarding legal African elephant hunting and the importation of trophies into the USA, European Union and Australia.

2020 CITES & AFRICAN ELEPHANTS

Currently (26/11/2019) only elephant populations of Botswana, RSA, Namibia and Zimbabwe are classified as CITES Appendix II for the purpose of trade in hunting trophies for non-commercial purposes (amongst other purposes). All other elephant populations are CITES Appendix I.

However CITES Species + can be seen listing elephant populations in Botswana, DRC, Eswatini (Swaziland), Namibia, South Africa, Tanzania, Zambia and Zimbabwe as all being CITES II with Reservation. What does this mean?

This Reservation applies only to the CoP18 update of the references to the Resolutions mentioned in annotation 2 relating to the populations of Loxodonta africana in Botswana, Namibia, South Africa and Zimbabwe (CITES Notif. No. 2019/077). So following the CITES trail further...

CITES Notif. No. 2019/077 reflects that Botswana, DRC, Eswatini (Swaziland), Namibia, South Africa, Tanzania, Zambia and Zimbabwe have communicated their reservation with respect to "the update of the references to the Resolutions mentioned in annotation 2 relating to the populations of Loxodonta africana in Botswana, Namibia, South Africa and Zimbabwe". Meaning what exactly?

Botswana, DRC, Eswatini(Swaziland), Namibia, Tanzania and South Africa all declared not to be in a position to implement Resolution Conf. 11.20 (Rev. CoP18) for trade in live elephants and southern white rhino.

Zimbabwe also communicated that it reserved its right not to be bound by the same Resolution Conf. 11.20 (Rev. CoP18) on Definition of the term 'appropriate and acceptable destinations' with regard to trade in live elephants. (Probably after China's 2016 - 2019 self-suspension of import of tusks, they decided to import whole live elephants. (100 odd live wild elephants sent from Zimbabwe to Chinese 'zoos' (CITES Trade Database 2014 - 2017).

So hunters may ignore the Species + icon, CITES II with Reservation, as it only applies to trade in live African elephants not hunting trophies. Botswana, RSA, Namibia and Zimbabwe remain the only CITES II African elephant countries for hunting trophies.

CITES CoP18 Outcome For The African Elephant

  • Transfer the elephant populations of Botswana, Namibia, South Africa and Zimbabwe from Appendix II to Appendix I - REJECTED
  • Proposal for transfer of the elephant populations of Zambia from Appendix I to Appendix II including 'trade in hunting trophies for non-commercial purposes' - REJECTED
  • Amendment of annotation 2 for elephant populations of Botswana, Namibia and Zimbabwe - REJECTED
  • By the way, woolly mammoths will not be classified as Appendix II after all.

2020 CITES Declared Export Quota Of Ivory Hunting Trophies

2020 CITES National Export Quotas

  • Benin - 0
  • Botswana - 800 from 400 elephants
  • Burkina Faso - 0
  • Cameroon - 0
  • CAR - 0
  • Ethiopia - 0
  • Mozambique - 0
  • Namibia - 180 from 90 elephants
  • South Africa - 300 from 150 elephants
  • Tanzania - 100 from 50 elephants
  • Uganda - 0
  • Zambia - 0
  • Zimbabwe - 1000 from 500 elephants

USA Flag 2020 USA & AFRICAN ELEPHANTS


The US Endangered Species Act classifies all African elephants as 'Threatened' across the whole continent of Africa. Notice there is not even any differential between quite independent elephant populations across Africa.

The circumstances (environmental pressures) applying to each population are distinctly different. This means their conservation requirements are different. Conservation applications that are good, relevant and desirable for one population, therefore, could be very detrimental to another. Ipso facto, each population has management needs that are unique to itself. No single management solution fixes them all – which is what the animal rightists want to impose on Africa.
In effect, this scientific fact makes the endangered species concept – so beloved by the US Fish and Wildlife Service – a fallacy. It has no place whatsoever in the scientific practice of wildlife management. Read more on The True Green Alliance

All the CITES regulations regarding international trade in African elephant hunting trophies for non-commercial purposes have become, to all intents and purposes, completely irrelevent now many CITES signatory countries like the US and others, succumb to populist 'animal rights' pressure to effectively ban the import of legally obtained African elephant hunting trophy products. How do they do this?

US ESA & CITES

Under the Endangered Species Act (ESA) of 1973, the US Fish & Wildlife Service has been designated to carry out the provisions of CITES through the Division of Management Authority and the Division of Scientific Authority. CITES requires each Party to regularly submit reports on how they are implementing the Convention. These reports may contain information on legislative and regulatory changes, as well as law enforcement, permitting, communications and administrative matters.

The Endangered Species Act (ESA) is a key legislation for both domestic and international conservation. The act aims to provide a framework to conserve and protect endangered and threatened species and their habitats.

  • The term 'endangered species' means any species which is in danger of extinction throughout all or a significant portion of its range ...
  • The term ‘threatened species’ means any species which is likely to become an 'endangered' species within the foreseeable future throughout all or a significant portion of its range.
  • The determination of whether any species is an 'endangered' species or a 'threatened' species because of any of the following factors...
  • The present or threatened destruction, modification, or curtailment of its habitat or range.
  • Over-utilization for commercial, recreational, scientific or educational purposes.
  • Disease or predation.
  • The inadequacy of existing regulatory mechanisms.
  • Other natural or manmade factors affecting its continued existence.
  • Basis for determinations of a species inclusion — "The Secretary shall make determinations solely on the basis of the best scientific and commercial data available to him after conducting a review of the status of the species and after taking into account those efforts, if any, being made by any State or foreign nation, or any political subdivision of a State or foreign nation, to protect such species, whether by predator control, protection of habitat and food supply, or other conservation practices, within any area under its jurisdiction, or on the high seas".
  • The United States has pledged itself as a sovereign state in the international community to conserve to the extent practicable the various species of fish or wildlife and plants facing extinction
  • Foreign Species and the US Endangered Species Act

Endangered Species Act (ESA) Special Rule for the African Elephant

If a species is listed as 'threatened', the Service can establish 'special rules' designating unique situations where otherwise prohibited activities could be allowed. Some species covered by special rules include beluga sturgeon, African elephant and leopard.

This special rule for African elephants is 4(d) of the ESA [50 CFR 17.40 (e)], 2016. With regard to elephant sport-hunted trophies, non-commercial importation is still allowed. The only changes are...

  • Limited import of sport-hunted trophies to two per hunter per year. It is not clear if '2 trophies' = 1 pair of tusks and/or other trophy items from 1 elephant. Before there was no limit.
  • Requires issuance of a threatened species permit under 50 CFR 17.32 for import of all African elephant sport-hunted trophies. Before it required issuance of a threatened species permit under 50 CFR 17.32 for import of African elephant sport-hunted trophies from Appendix I populations.

USF&W On Trophy Hunting

"We continue to believe that well-managed trophy hunting can benefit conservation..."
"Trophy hunting can generate funds to be used for conservation, including for habitat protection, population monitoring, wildlife management programs, and law enforcement efforts".
USF&W also endorses the IUCN principles on trophy hunting...
The IUCN Guiding Principles on Trophy Hunting as a Tool for Creating Conservation Incentives 2012 state that well-managed trophy hunting can "assist in furthering conservation objectives by creating the revenue and economic incentives for the management and conservation of the target species and its habitat, as well as supporting local livelihoods" and, further, that well-managed trophy hunting is "often a higher value, lower impact land use than alternatives such as agriculture or tourism." When a trophy hunting program incorporates the following Guiding Principles, IUCN considers that trophy hunting can serve as a conservation tool: Biological sustainability; net conservation benefit; socio-economic-cultural benefit; adaptive management—planning, monitoring, and reporting; and accountable and effective governance".
Source: Endangered and Threatened Wildlife and Plants; Revision of the Section 4(d) Rule for the African Elephant (Loxodonta africana)

USF&W On African Elephant Sport-Hunting

2014 - 2017: The following African elephant parts were imported into the USA from Tanzania as hunting trophies or personal imports...
  • 4 tusks
  • 3 ears
  • 4 feet
  • 1 skin pieces
  • 1 skins
  • 12 'trophies' unspecified
Source: CITES Trade database
2014 - 2018: The following African elephant parts were exported from Zimbabwe into the USA as hunting trophies or personal imports...
  • 177 tusks
  • 4075 kg tusks
  • 536 ears
  • 176 feet
  • 5213 skin pieces
  • 11 skins
  • 20 hair items
  • 45 bones
  • 8 teeth
  • 7 trunks
  • 114 'trophies' unspecified
Source: CITES Trade database
  • 2018 - USF&W withdrew all previous ESA negative enhancement findings for African elephant trophies taken in Zimbabwe.
  • 2018 - USF&W withdrew all previous ESA negative enhancement findings for African elephant trophies taken in Tanzania.
  • 2018 - USF&W withdrew all previous ESA negative enhancement findings for African elephant trophies taken in Zambia.
  • 2018 - USF&W withdrew all very old ESA enhancement findings for South Africa, Namibia and Botswana.

This USF&W clean-out of ESA enhancement findings and non-detriment determinations for African elephants does not necessarily mean import permits for elephant trophies will be issued.

USF&W intends to use the information cited in these findings and contained in its files as appropriate, in addition to the information it receives and has available when it receives each application, to evaluate individual permit applications.

The Service is continuing to monitor the status and management of these species in their range countries. At this time, when the Service processes these permit applications, the Service intends to do so on an individual basis, including making ESA enhancement determinations, and CITES non-detriment determinations when required, for each application. The Service intends to grant or deny permits to import a sport-hunted trophy on a case-by-case basis pursuant to its authorities under the ESA and CITES. As part of the permitting process, the Service reviews each application received for import of such trophies and evaluates the information provided in the application as well as other information available to the Service as to the status of and management program for the species or population to ensure that the program is promoting the conservation of the species. Each application must also meet all other applicable permitting requirements before it may be authorized.

US Hunters Are Legally Allowed To Import African Elephant Trophies

African elephant sport-hunted trophies may be imported into the United States provided:

  • The trophy was legally taken in an African elephant range country that declared an ivory export quota to the CITES Secretariat for the year in which the trophy animal was killed.
  • A determination is made that the killing of the trophy animal will enhance the survival of the species and the trophy is accompanied by a threatened species permit issued under § 17.32
  • The trophy is legibly marked in accordance with 50 CFR part 23. See below...
  • The requirements in 50 CFR parts 13: General Permit Procedures, 14: Importation, Exportation, And Transportation of Wildlife, and 23: CITES Regulations have been met.
  • No more than two African elephant sport-hunted trophies are imported by any hunter in a calendar year.

50 CFR part 23 Ivory Marking: The trophy ivory must be legibly marked by means of punch-dies, indelible ink, or other form of permanent marking, under a marking and registration system established by the country of origin, with the following formula: The country of origin represented by the corresponding two-letter ISO country code; the last two digits of the year in which the elephant was harvested for export; the serial number for the year in question; and the weight of the ivory in kilograms. The mark must be highlighted with a flash of color and placed on the lip mark area. The lip mark area is the area of a whole African elephant tusk where the tusk emerges from the skull and which is usually denoted by a prominent ring of staining on the tusk in its natural state.

USA Flag Applying For An African Elephant Trophy Import Permit

  • A reminder...the US Endangered Species Act classifies all African elephants as 'Threatened' across the whole continent of Africa. Botswana, RSA, Namibia and Zimbabwe are classified as CITES Appendix II.
  • US hunters may NOT import any elephant trophies from any country except Namibia, South Africa, Zimbabwe and now Botswana (having lifted it's own elephant hunting moratorium). No other country has a CITES export quota for African elephant sport-hunted trophies.
  • You must use Application Form 3-200-20 'IMPORT OF SPORT-HUNTED TROPHIES under Appendix I of the Convention on International Trade in Endangered Species (CITES) and/or U.S. Endangered Species Act (ESA)'. (Form 3-200-19 is only for leopard & rhino).
  • Note there is a form expiry date at the top right. This is the date of expiry of the form print run.
  • What does this mean? 3-200-20: Note 3: Applications for species listed as endangered under the U.S. Endangered Species Act are published in the Federal Register for a 30-day public comment period.

ESA Section 10(c) NOTICE AND REVIEW—The Secretary shall publish notice in the Federal Register of each application for an exemption or permit which is made under this section. Each notice shall invite the submission from interested parties, within thirty days after the date of the notice, of written data, views, or arguments with respect to the application. However, we may be assured...

While section 10(c) of the ESA requires that we publish notice in the Federal Register of each application involving an exemption or permit made under section 10, this is not the case for applications involving threatened species, which are not subject to the section 9 prohibitions and thus, the notice and comment requirements in section 10(c). Source: Endangered and Threatened Wildlife and Plants; Revision of the Section 4(d) Rule for the African Elephant (Loxodonta africana in 'Comment 10 Response'.

  • Section 9 of 3-200-20 might be tricky for some hunters as you are asked to provide information to support a USF&W finding that your activities will enhance or benefit wild populations of the species involved, population status or trend, how trophy or licence fees are used by either the landowner, local community or government and other funding activities that are being carried out, by the safari outfitter, professional hunter, concession holder or landowner that provide a conservation benefit to the species being hunted.

As the hunting client, you might not know much about the local conservation measures taken in the area you are going to hunt. Rather than leaving this section blank, it is advisable to find out as much as possible from your outfitter/PH/landowner.

Also for more help with an elephant permit application, you may contact Joe Jackson of Conservation Force who offers free assistance in building a compelling case for your application.

  • USF&W has revised its procedure for assessing applications to import elephant hunting trophies. They intend to make findings for elephant trophy imports on an application-by-application basis.
  • Once you have filed your application and paid your non-refundable fee, the assessment process is said to take about 90 days.
BUT

Despite lifting their illegal ESA enhancement findings for African elephant in 2018, the USF&W Service still has the authority to behave in an arbitrary manner, to the detriment of international conservation efforts. Their insistence on American hunters providing proof that the relevant African nations' hunting programs enhance the survival of elephants completely undermines the CITES process.

Essentially, in addition to the (Bots, SA, Nam, Zim) elephant CITES II export permits, USF&W is demanding, what can only be termed as extra 'enhancement permits', bestowed at their discretion in an excessively slow process resulting in very limited issue of elephant import permits.

As, by far, the largest number of paying hunting clients in Africa are American, this USF&W policy is drastically cutting the revenue for elephant, other wildlife species and habitat conservation, anti-poaching programs and human employment & livlihoods in Africa while also denying African countries their sovereign right to manage their own wildlife.

US Imports Of Elephant Trophies Since 2018

The CITES Trade Database is somewhat unreliable with the 'trade terms' describing the various animal products being basically left to the imagination of the filing person/country. The 'purpose' though can only be classed as a 'Hunting Trophy' or 'Personal'.

Data from 2019 & 2020 is still unavailable.

Ignoring the various other bits of an elephant (ears, feet, skin,etc) that can be imported and may belong to a single animal, it looks like some US hunters have received some import permits in 2018...

South Africa to USA
  • 6 Tusks
  • 22 'Trophies' unspecified
Namibia to USA
  • 1 Tusk
  • 18 'Trophies' unspecified
Zimbabwe to USA
  • 4 Tusks
  • 49 Kg Tusks
  • 1 'Trophy' unspecified
Zambia to USA
  • 2 'Trophies' unspecified

EU Flag 2020 EU & AFRICAN ELEPHANTS

Like the US, the EU implements CITES trade regulations in all the member states through what is known as the EU Wildlife Trade Regulations. Currently these are Council Regulation (EC) No 338/97 on the protection of species of wild fauna and flora by regulating trade therein.

The CITES regulation is stated that only elephant populations of Botswana, RSA, Namibia and Zimbabwe are classified as CITES Appendix II for the purpose of trade in hunting trophies for non-commercial purposes (amongst other purposes). All other elephant populations are CITES Appendix I.

The EU lays down the provisions for import, export and re-export as well as internal EU trade in of species listed in its four Annexes which contain some non-CITES species. It provides for procedures and documents required for such trade (import and export permits, re-export certificates, import notifications and internal trade certificates) and it regulates the movement of live specimens.

EU Wildlife Trade Regulations Go Beyond CITES...

  • For species in Annexes A and B import conditions are stricter for the EU than under CITES.
  • The EU may unilaterally establish import restrictions with regard to certain species/countries.
  • The EU Suspension Regulation: An EU 'Scientific Authority' may advise the 'Management Authority' not to issue an import permit because it is of the opinion import conditions are not met. Member States can immediately suspend the issue of import permits the issue is resolved or not.
  • If a non-detriment finding is made and the EU Scientific Review Group forms a 'Positive Opinion', imports can be resumed.
  • If the Scientific Review Group forms a 'Negative Opinion' the EU will reject all permit applications for the species/countries in question.
  • An import permit is required for both Annex A and Annex B species, (CITES I & II equivalent) to be applied for at the competent authorities in the Member State. This undermines the CITES II species only requiring an export permit.
  • An import notification is required for Annex C and D species. An import notification is a declaration filled in by the importer and to be submitted, where appropriate together with CITES Appendix III documents from the exporting country, to the Customs office of introduction into the Community.
  • Annex D contains species listed in CITES Appendix III for which one or more EU Member States have entered a reservation as well as species for which EU imports warrant monitoring.

EU Wildlife Trade Regulations & The African Elephant

  • The African elephant, Loxodonta africana, populations of Botswana, Namibia, South Africa and Zimbabwe are included in Annex B
  • All other African elephant populations are included in Annex A for trade in hunting trophies for non-commercial purposes.
  • Annex A elephant hunting trophies from specific ecosystems of Tanzania only, may be imported - these are Serengeti (15), Tarangire-Manyara (10), Katavi-Rukwa (13) and Selous-Mikumi (36). As long as the quotas allocated at ecosystem level do not exceed >0.3% of managed population. The trophy animals must be male with tusks more than 20kg or 160cm in length. The quota must be reviewed annually and adjusted, as necessary, to take into account most recent population data. Source: 79th SRG 2017
  • Annex A elephant hunting trophies from Zambia may be imported into the EU. Source: 73rd SRG 2015

EU Elephant Hunting Trophy Import Permit Regulations

  • The import will not be harmful to the conservation of the species.
  • The imported trophies were legally obtained in the country of origin.
  • The EU has not published an import restriction.
  • The Scientific Review Group or the Scientific Authority of an EU Member States has not formulated a negative opinion on the species you intend to import from a specific country.
  • There are no other conservation factors that would prevent the permit being issued.
  • The trophy must not be used for commercial purposes.

Importing African Elephant Trophies Into The EU

  • The import into the EU of hunting trophies from all African elephant populations, whether listed in Annex A or Annex B of the EU Wildlife Trade Regulations, will require both an import permit and an export permit. Stricter controls were introduced for certain Annex B species/populations, including the African elephant, in January 2015
  • Hunting trophies that are imported into the EU for non-commercial purposes can be considered 'personal or household effects' under the EU Wildlife Trade Regulations.
  • It is worth checking, before hunting an Annex A & B species, that the EU Scientific Review Group has not imposed any sudden import suspensions.
  • Application forms for import or export permits, re-export certificates and import notifications should be obtained from the Management Authority of the importing destination Member State.
  • Before hunting a CITES Appendix I animal you must ask the Management Authority of the importing Member State to provide you with a copy of the import permit for the exporting country or a written statement that an import permit will be issued. This document can be used to obtain the export permit from the exporting country.
  • After the hunt you should be sent a copy of the CITES export permit from the hunting country. You should then attach this to your import application to the CITES Management Authority of your Member State country.
  • When the import permit is issued it must be sent to the exporter.
  • Both import and export permits must accompany the shipment and presented to Customs at any necessary border point before entering the EU.

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