USF&WS Proposed Ivory Trade Rules as of July 29, 2015

Click here for a link to the regulation

Click above link to see the entire proposed ivory trade rules .

It appears the most important aspects of these proposed rules for antique cane collectors are the de Minimis concept and identifying the object as an antique. In the de Minimus rule[ page 45162] it states  that the sale of an item[cane?] would be acceptable if the fixed ivory component[handle] of an item of < 200grams[ their definition of de Minimus] and is not the primary source of the value of the item. The proposal goes on to say they would consider the value added by the craftsmanship [carving?] that went into the ivory component , not just the value of the ivory itself. So, just maybe that carved ivory horse head [weighing 150 grams] attached to a wood cane shaft would qualify as okay to sell within the USA[strictly my own personal interpretation]. The document does include ivory knife handles as an example of an acceptable de Minimus and what we need to have included besides knife handles in this rule are “cane handles”[ page 45163 ].

It would appear easier to have the sale of antique canes under the “qualified antique exception”to be the best route , except for [d] of the requirements to be classified as an antique under ESA [ page 4517 2nd column ] Which states” entered at a port designated for ESA antiques” . I do not know how this could be certified? The document has several more paragraphs devoted to the “antique question” which I find very confusing and difficult to interpret . If anyone else clearly understands this, please let is know.

I also encourage you to send comments to the Council at the address  in the above link. Let them know that cane handles should be included along side  knife handles a examples as falling under the “de Minimus” rule. Also we need some help and clarity on the definition of a qualified antique. Please write to them! that are encouraging us to do that.

Peter Robinson, Senior Director



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