Covid-19 and New Zealand’s Role in the Global Illegal Wildlife Trade

Covid19 and NZ illegal wildlife trade

By Fiona Gordon – Environmental Policy Analyst & Ambassador to the Jane Goodall Institute New Zealand

The pandemic which has sent countries into lock down and wiped billions from economies has refocused attention on the illicit trade of wild animals.  From pangolin scales to primate skulls, elephant ivory and tiger bone the wildlife products arriving at New Zealand’s border provide an insight into the truly global extent of the illegal trade in wildlife.

Scientists say the coronavirus (SARS CoV-2) that causes Covid-19 most likely originated in bat populations.  Somewhere along its evolutionary path it probably jumped to an intermediary host animal before acquiring its ability to infect humans. As it forges a path of misery around the globe it is exposing our inadequacies – those of national health systems, international agreements, and ultimately our conservation efforts.

Wild animals can naturally carry potentially harmful bacteria, parasites, fungi and viruses including coronaviruses. It is when these jump to humans—called a spillover event—that they can cause illnesses, known as zoonotic diseases.

Fortunately for us, intact and healthy ecosystems tend to provide a kind of natural firewall between humans and zoonotic diseases.

There are literally hundreds of coronaviruses circulating among animals such as pigs, camels, bats and cats. Of the seven coronaviruses known to affect people, three have emerged from their animal reservoirs to cause serious and widespread human illness and death in just the last two decades: Severe Acute Respiratory Syndrome (SARS) in 2003, Middle East Respiratory Syndrome (MERS) in 2012 and now Covid-19.

Humankind has now poked so many holes in nature’s firewalls that coronaviruses can now just walk right on through. From the destruction of forests to our relentless encroachment into pristine habitats – in our failure to conserve the natural world, we have failed ourselves as well.

The stand-out failure though has to be our ongoing inability to halt the illegal wildlife trade. By default and by association, we’ve also failed to control the legal international wildlife trade effectively.  Concerns are now being raised that the shortcomings of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) which regulates international wildlife trade could even expose us to the next pandemic.

At a recent IUCN Commission on Environmental Law webinar event, John Scanlon AO, former Secretary-General to CITES, explained that “CITES does not regulate the way the wildlife is harvested, handled, or stored in the source state, or how it’s handled, stored, sold or consumed in the destination state.” He said that, “captive breeding facilities, which now account for close to 60% of trade in animals, are not assessed by CITES on public health grounds. Yet all of these activities can pose a risk factor for the emergence of zoonotic diseases.”

Despite aiming to regulate international trade, as Scanlon points out, CITES does not create enforcement authorities or require illegal trade to be criminalized, and it is not a natural forum for police and other enforcement officials.

Such shortcomings are perhaps best illustrated by CITES’ inability to end wildlife crime, which is estimated to be the world’s fourth biggest illegal trade. A pertinent example is that of the pangolin, which has been suggested as a potential intermediary host of Covid-19, although research is so far inconclusive.  Despite being afforded the highest-level of protection under CITES, the illegal trade in these scaly anteaters is at a record high, according to Scanlon.

With the unenviable reputation of being the most heavily trafficked wild mammal in the world it should be no surprise that pangolin body parts arrive in New Zealand too.

Between 2017 and 2018 official data show 12 occurrences of seizure or surrender (seizure records) of items consisting of pangolin body parts – a total of about 152 individual items including sachets of whole and powdered scales, bags of raw ingredients, tea bags and soup, a medicine ball, packets of tablets and pills, and a necklace containing a pangolin claw/foot. Most of the items arrived from China.

These products represent only a minute portion of the more than 18,000 seizure records of CITES listed wildlife over the same two year period.  About 65% of the seizure records are for corals and shells, another 8% are for the roots of plants, and a further 11% are for meat – typically crocodile and alligator meat, but also featuring minke whale, dolphin meat, bear, turtle and python meat.

Table 1:

*Seizure Records include records of seizure and records of surrender.

Data Source: New Zealand CITES Illegal Trade Report 2017 and 2018, provided by Department of Conservation, New Zealand. Graph Source:  Data analysis, summary and graph produced by Gordon Consulting, New Zealand.

Medicines make up a further 7% of the seizure records, over half of which are for Saussurea Costus, an endangered flowering thistle.  Other have been made from the body parts of animals such as Saiga Antelope, Musk Deer, leopard, tiger, bears (including bear bile), primates, turtles, pangolin and snakes. Other products include leather products, elephant ivory and feet, and the skulls, teeth and claws of leopard, bears, and lynx.

It makes for a gruesome shopping list and it is worthwhile recalling that each seizure record can and often does consist of multiple individual items – sometimes hundreds and even thousands of items.  About 5% of the seizure records represent more than 69,000 individual items made from wildlife considered to be threatened with extinction. Listed on CITES Appendix I, these are the most endangered species of all those listed under CITES and international trade is prohibited, except for exceptional cases.  The remaining seizure records are almost entirely for species listed on Appendix II.  These are species not necessarily now threatened with extinction, but they could become so if trade is not closely controlled.  This is not a mere numbers game.

So, how do all these wildlife products get to New Zealand?  By far the majority of seizure records are related to airports, in particular Auckland Airport situated within the country’s largest city. Data further indicate that 64% of the seizure records are associated with New Zealand citizens and 32% are associated with visitors.

Table 2:

*Seizure Records include records of seizure and records of surrender.

Data Source: New Zealand CITES Illegal Trade Report 2017 and 2018, provided by Department of Conservation, New Zealand. Graph Source:  Data analysis, summary and graph produced by Gordon Consulting, New Zealand.

Table 3:

*Seizure Records include records of seizure and records of surrender.

Data Source: New Zealand CITES Illegal Trade Report 2017 and 2018, provided by Department of Conservation, New Zealand..Graph Source:  Data analysis, summary and graph produced by Gordon Consulting, New Zealand.

It is a depressing picture and one that exemplifies the truly global extent of the illegal wildlife trade.  On a positive note, New Zealand has introduced an instant infringement fine system for offences relating to the international wildlife trade, which is a useful enforcement tool in addition to prosecution options.  The Government is also due to announce the results of the 2019 review of the Trade in Endangered Species Act, the key national piece of legislation relating to the international trade in endangered species, which included an option to ban New Zealand’s domestic trade in elephant ivory.

Along with regulation and law enforcement, demand reduction strategies form part of the package needed to combat wildlife crime effectively. With such a rich database at its fingertips, the New Zealand Government is well positioned to develop targeted strategies which aim to shift purchasing preference and buyer behaviour away from illegal wildlife products.  Former Prime Minister Helen Clark says, “It is vital that New Zealand strengthens its vigilance against this vile illicit trade, and not become a weak link in the chain of global efforts aimed at stopping it.”

Scanlon urges that we all “finally grasp the nettle with wildlife crime” and recognise the massive impacts wildlife crime has on economies, ecosystems, public and animal health, security, and people.

“The risks of future wildlife-related pandemics are real, and the stakes are high,” he says, “preventing them requires bold reforms to wildlife crime and trade laws. Making these reforms rests with countries. Now is the time to present them with viable options and a broad alliance of organisations has come together to do just that under the banner Global Initiative to End Wildlife Crime.

“I am delighted to Chair the Initiative,” says Scanlon, “which is advocating for and offering technical support to create a new international agreement on wildlife crime and to amend existing international wildlife trade laws to include public health and animal health into decision making.”

The risks of future wildlife-related pandemics can come from unregulated, regulated, and illegal wildlife trade. This is a matter for every nation to be far more cognisant of in the wake of Covid-19.

Published: Journal of African Elephants 

New Zealand Government Assessing Need for Ivory Trade Regulations

By Fiona Gordon – Director of Gordon Consulting and an Ambassador to the Jane Goodall Institute New Zealand.

Five fishermen casting their rods, two hauling in their nets, six seated buddhas, intricate pagodas and an army of miniature immortals. There’s perhaps one hundred of them in total.  Each a lifeless creamy white, sitting silently on their un-unique wooden bases.  Some look remarkably similar, almost identical.  Some appear just like the ones at another antique shop a few hundred kilometres away.  So similar in fact that one could be forgiven for thinking they might be from the same artist or manufacturer.

Only one of them is noted as ‘antique’.  There’s no reference to age whatsoever for the rest. They don’t sit for long inside their glass display cabinets. The ivory at one New Zealand auction alone soon disappears out the door for around NZD $10,000 (USD $6,600).

It is a matter of opinion as to whether the purchase price is extortionate or not, but these little ivory trinkets were undoubtedly obtained through lethal extortion.  Whether 100 years ago or yesterday, the African elephant brutally slaughtered for her ivory tusks would not have been compliant, she would not have willingly given her life. Nor that of her baby’s, killed for her tiny tusks or to draw in the rest of the herd or left to die of stress and starvation.

The African elephant was listed on the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) in 1976 after it was observed that the international trade in ivory was drastically reducing their population. Even with international regulation on trade, elephant populations continued to crash. The situation was so dire that in 1989 CITES put in place a total ban on the international commercial trade in ivory.

Since the 1989 ban thousands of elephant ivory carvings, ivory pieces and tusks have been legally imported into New Zealand for non-commercial purposes.  Surprisingly, CITES data shows that over 60 per cent of these imported ivory items are not noted as pre-1976 (pre-Convention), instead noted as being sourced from the ‘wild’ or of ‘unknown’ source.  Most of this ivory arrives from South Africa, Zimbabwe, Botswana, and some from Mozambique or it is re-exported from Great Britain, Australia.

While clearly imported specifically for non-commercial purposes, according to New Zealand’s Department of Conservation, any ivory legally imported after the 1989 ban can legitimately be sold on New Zealand’s domestic market.   This is irrespective of the purpose listed on the import permit, as that purpose relates to the reason for the item entering New Zealand at the time of import. The Department confirms that no restriction is placed on the future sale of the specimen.

This would seem to fly in the face of the 1989 international trade ban and an unsuspecting New Zealand public would likely be horrified to learn that their domestic market could well include ivory from recently killed elephants.

According to the Chief Executive Officer of the African Wildlife Foundation(AWF), Kaddu Sebunya, “Africa has only about 460,000 elephants left. The ivory trade is fuelled by demand in countries such as New Zealand and it is deeply disappointing that the market for ivory is thriving. It’s time that the New Zealand government outlawed the sale of all ivory and gave African elephants a chance.”

These matters fall on the deaf ears of New Zealand auction houses who cleanse their conscience by protesting that they deal in ‘old’ ivory and are operating within the law.  They explain that they can tell the age of an ivory item due to their years of experience. They explain that the ivory they sell is collected from various sources including estate sales and second hand shops within New Zealand.  They explain that artist signatures on ivory items indicate a ‘finer example’ and will typically command a higher price, but are not necessarily related to a particular period or date. They comment that they rarely undertake research into such matters.

With such confidence it is surprising then that New Zealand auction houses rarely provide any statement, let alone any verifiable evidence, as to the age or source of the ivory they sell or note the name or history of the artist that produced the so-called ‘beautiful pieces of art’.  With or without such statements, auction houses command between 15% – 35% plus tax on the hammer price of every lot sold via vendor commission and buyer premiums.

In any case, should an auction house choose to make a statement as to the age or source of the ivory for sale,  their policies ensure that neither they nor the seller are responsible for the correctness of any statement as to the authorship, origin, date, age or provenance of any lot.  Any statements they provide are ‘statements of opinion’ and are ‘not to be relied upon as statements of representations of fact’.  Potential buyers are required to ‘satisfy themselves by inspection or otherwise’ as to such matters.

Any inquiry by Department Officers will likely go around in circles.  Without domestic ivory trade regulations, officers must first hold reasonable grounds to believe an item has been illegally imported before being able to investigate, request documentation or other evidence relating to the trade.

With little more than a photo in a catalogue to base any judgement on and where ivory appears to be of ‘a type commonly traded and imported’, there can be little to suggest an item has been illegally imported.  Where inquiries are made and should it transpire that the ivory was purchased locally prior to being listed for sale at the auction house, the Department will likely be satisfied that the items were ‘legally obtained’.

According to Sebunya, “New Zealand is a classic example of how legitimizing some aspects of ivory trade opens doors for illegal trade as well. We will continue to lose African elephants unless governments get serious about completely outlawing ivory trade thus crushing demand.”

Indeed it is not just plausible but fact that thousands of dollars-worth of illegally imported ivory has already slipped through New Zealand’s border, some of which was sold on the domestic market under the guise of legality.

New Zealander and Past Chair of African Wildlife Foundation, David Thomson, says,“New Zealand has the reputation as a world leader in conservation of its land, forests, bird life and oceans and our conservationists are respected worldwide.”  Thomson considers that, “as an international participant in conservation and a respected signatory of CITES we should be monitoring the trade in all wildlife products, especially ivory and rhino horn.”  He adds, “it should not be difficult to add clarity to our regulations about the import and trade of ivory and it should be an obligation of our justices to prosecute the trade of illegal wildlife parts. We are stringent in applying the law if a native species is abused and we need to join hands with our international community to do likewise.”

In a positive move, the New Zealand delegation to the 2018 London Conference on Illegal Wildlife Trade made a formal commitment to “assess the need for regulation of New Zealand’s domestic ivory trade”.

For a country renowned for its conservation acumen, thousands of people are saying it is way past time for New Zealand to sharpen up its act.  Every domestic ivory market only serves to fuel demand and undermines the considerable resources being invested on the ground in Africa to protect her elephants from slaughter.

They stand there quietly, perhaps 30 of them.  Each stunningly unique, with their individual personalities, memories, histories and family bonds.  Intelligently caring for each other, sharing knowledge of waterholes and feeding grounds with their dependent young.  Some will move along ancient corridors only at night now, afraid to travel during the day, least the poachers see their tusks. They are Africa’s elephants. They are priceless.  They are worth protecting.

About the Author:

Fiona Gordon is a New Zealand based environmental policy analyst and an Ambassador to the Jane Goodall Institute New Zealand.  She has undertaken research into the international and domestic ivory trade since 2014. Fiona was principal researcher and co-author of the 2016 report by the International Fund for Animal Welfare (IFAW) “Under the Hammer” which provided the results of the first ever investigation into the nature of the auction house trade in elephant ivory and rhino horn in Australia and New Zealand.

ORIGINALLY PUBLISHED: Journal Of African Elephants 2nd May 2019

Australia and New Zealand – Letting Elephant and Rhino Down


With a lack of appropriate enforcement tools at the border and unregulated domestic markets, if you manage to get your ivory or rhino horn into New Zealand or Australia, you are home and hosed to make a killing.

Screen Shot 2017-11-23 at 11.41.30 am.png

“Let’s get serious about wildlife crime.” “The future of Elephants is in our hands.” “Listen to the Young Voices.” These annual World Wildlife Day messages were brought home with the conclusion of the inaugural United Nations Office on Drugs and Crime (UNDOC) 2016 World Wildlife Crime Report that all regions of the world play a role as a source, transit or destination for contraband wildlife.

The Report called for the introduction of national legislation to regulate the possession, use and sale of the most threatened wildlife products from other parts of the world. It offered potential solutions, including providing customs agents with the right tools to conduct international wildlife crime enforcement. Measures required as part of the multi-faceted strategy to combat wildlife crime, world wide.

Elephants and rhinoceros are our global flag ship species in the fight against international wildlife crime. The Great Elephant Census revealed an alarming 30% decline in Africa’s savanna elephant population over 7 years. Save The Rhino reported best estimates of only 30,000 rhinos survive in the wild at the end of 2015 and that nearly three rhinos were killed every day in South Africa in 2016 alone.

Media reports on ivory and rhino horn seizures and law enforcement focus on key source, transit and consumer nations, and righty so. However other countries are also harbouring the illegal trade.

Notably, the Pacific is increasingly becoming a source and transit region for illegal wildlife trafficking, where trade is “well organized by opportunistic criminal networks and unscrupulous traders”. In the heart of this region, New Zealand and Australia have more recently been implicated in the illegal trade of ivory and rhinoceros horn.

Wildlife seizures at the New Zealand border have more than doubled from 2,268 in 2011 to 5,809 in 2015. From a total of 19,221 seizures, eight prosecutions were brought under New Zealand’s Trade in Endangered Species Act (TIES Act). Two of these prosecutions were for the illegal importation of elephant ivory. No infringement fines were issued.

Australian Customs and Border Protection Services reportedly seize 7,000 wildlife items each year, mostly in the post and passenger environment. Hundreds of seizures of suspected elephant ivory and rhino horn products were made between 2010 and 2016. No infringement fines or prosecutions have been reported for wildlife offences under the Environment Protection and Biodiversity Conservation Act.

Despite the high seizure rates New Zealand and Australia have no infringement fine mechanisms for offences related to the international movement of wildlife specimens. Commendably, in February this year, New Zealand introduced the Conservation (Infringement System) Bill, which will provide for infringement systems to be placed in the Trade in Endangered Species Act.

Border control is clearly the first line of defense. However, as seizures are only ever indicative of the real scale of an illegal trade, domestic regulations must provide the second – to effectively deal with the illegal trade of wildlife items that do slip through. And they do slip through.

A New Zealand man managed to illegally import some 20 ivory items, worth about USD$12,614, before being caught out when an African elephant tusk was detected at the international mail centre. Some of the illegally imported ivory had already been sold on the domestic market.

Australian police seized an estimated USD $63,000 worth of ivory on the domestic market in 2014 and Customs seized 100kg of ivory at Perth airport the following year. No fines or prosecutions in relation to either of these seizures have been reported to date.

The incentives for criminals seeking to launder illegally imported items are obvious. Thousands of ivory products are sold each year in Australia and New Zealand on domestic markets that remain completely unregulated. Ivory can fetch as much as USD $23,600 for a pair of tusks and USD $53,000 for a pair of rhino horns. With no legal requirements for sellers to provide any proof of the origin or age of these products, the vast majority of them are offered for sale without provenance information.

These gaps, in border enforcement and lack of domestic regulations, are precisely the gaps identified in the UNODC Report. In Australia and New Zealand, if you manage to get your ivory or rhino horn into the country, you are home and hosed to make a killing on the domestic market.

For the elephant and rhino, there is no room or time left for any gaps and “we are just a drop in the bucket” inertia. Last year the Convention on International Trade in Endangered Species of Wild Flora and Fauna (CITES) asked all nations with unregulated domestic markets in ivory and rhino horn to close or regulate their markets. A truly global response is being called for. As the two largest parties to CITES in the region, Australia and New Zealand have a clear mandate for action and an obvious opportunity to lead the way on this front.

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