BLOG: Release of report from the evaluation committee on the “Endangered Species Conservation Act”: The Japanese government is in turmoil over the closure of the domestic ivory market
https://www.jtef.jp/en/wp-content/uploads/2025/07/250716-象牙在庫-1024x1014.jpg 1024 1014 Japan Tiger Elephant Organization Japan Tiger Elephant Organization https://www.jtef.jp/en/wp-content/uploads/2025/07/250716-象牙在庫-1024x1014.jpgMasayuki Sakamoto, Executive Director of Japan Tiger and Elephant Fund
It has been nine years since the 17th Conference of the Parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) (CoP17) revised its resolution to recommend the closure of domestic ivory markets in 2016. For the Ministry of Economy, Trade and Industry METI), which protects the ivory industry, and the Ministry of the Environment, which follows suit, the coming months will be a crucial time as they decide whether to move forward with closing Japan’s ivory market.
Events in the 2025 Regular Diet Session
Lawmakers have become to give an eye on the situation of Japan’s ivory market and reviewing the regulations. During the 2025 regular Diet session, Komeito Party lawmaker Miyazaki Masaru said at the House of Councillors Budget Committee on March 28, “The time has come for METI to show the public its direction, including the market closure, while also strengthening regulations, taking into account the situation of the ivory industry.” He added, “There is also the issue of timing,” and pointed out, “Currently, a review of the Species Conservation Law is being considered, and if we miss this opportunity, the next opportunity to revise the law may be nearly ten years away.”[1] This questioning apparently drew criticism from hanko (name seal) manufacturers, but when Miyazaki asked the question again at the House of Councillors Audit Committee on May 26, he emphasized that “taking into account the international situation, etc., we have reached a time when we need a national debate on whether we should actually close the market.”[2] Also, at the House of Representatives Environment Committee on June 3, Matsuki Kenko, a member of the Constitutional Democratic Party of Japan, called on the Ministry of the Environment (MoE) to “think in the direction of eliminating (the domestic ivory trade),” and called for the law to be amended “as soon as possible.”[3]
The species conservation law referred to here is the “Act for the Conservation of Endangered Species of Wild Fauna and Flora (ACES),” which regulates domestic trade of designated wildlife species including their parts and products made from them. “Closing the domestic ivory market” roughly means banning the domestic trade of ivory, so the best way to achieve this would be to amend the ACES. MoE is the competent authority for the ACES, but ivory trade regulations are jointly administered by METI. As the authority that protects and supervises the ivory industry, METI has the power to decide whether to allow trade regulations that affect the industry to be implemented.
Review of Ivory Trade Regulations Postponed to New Committee; Amendment to ACES Also Postponed for One Year
The 2017 amendment to the ACES stipulated that the law be reviewed approximately five years after its implementation. In response to this, MoE established the “Committee to Evaluate the Implementation of the Act on Conservation of Endangered Species of Wild Fauna and Flora” in March 2024,[4] and has been carrying out an evaluation. The final report was finally published on June 27, 2025.[5]
The report[6] also has a section on ivory trade regulations, and states the following about its “implementation evaluation” on this point:
While closely monitoring the status of crackdowns on smuggling and illegal trade, we will work with the Ministry of Economy, Trade and Industry and other relevant ministries and agencies to eradicate them, and in order to clarify issues for further improvement of domestic ivory trade regulations, we will analyze the actual state of distribution based on examination of the effectiveness and operation of the 2017 amendments to ACES (business registration system, etc.), and take appropriate measures depending on the results of the analysis. We will also hold dialogues with stakeholders through the Public-Private Councils on the Promotion of Appropriate Ivory Trade and other forums, and will continue preparations for CITES CoP20. (Emphasis added by the author)
In a press release announcing the report, MoE stated that the Implementation Evaluation Committee “has examined and evaluated the amendments made in 2017 and identifying issues.”[7] However, as mentioned above, ivory trade regulations have been treated differently and identification, analysis, and evaluation of the issues left to the future.[8]
Even more noteworthy is the fact that, in the “future outlook” for the overall review of the ACES, it is stated that “based on the issues outlined in this report, a review committee will be established and the laws, regulations and implementation will be considered from FY2025 to FY2026.”[9] In other words, an ACES amendment bill will be prepared after fiscal year 2026 and submitted to the Diet in 2027 at the earliest. As it was originally stated that “in the event that system reforms are required, the Central Environmental Council (Wildlife Subcommittee) will be consulted as necessary from fiscal year 2025 onwards,”[10] it was basically expected that the amendment bill would be submitted to the Diet in 2026. There appears to have been a change in plan to postpone submission of ACES amendment bill to the Diet by one year.
How should we think about the one-year delay?
It is unclear whether there is a direct relationship between the postponement of identification, analysis, and evaluation of issues related to ivory trade regulations to the review committee that will follow the Evaluation Committee and the postponement of the submission of the ACES amendment bill to the Diet by one year. However, there is room to see that the METI and the MoE, which have so far firmly denied the closure of the domestic ivory market, have taken into consideration domestic and international new developments and have changed their stance to leave room for policy changes on the occasion of the revision of ACES. The developments that influenced both ministries include, firstly, the official publication of data on the world’s illegal ivory seizures, as identified through the official CITES program, by country involved in the illegal trade[11]; secondly, the fact that this was covered by NHK,[12] and furthermore, that this issue was raised in questioning by both the opposition and ruling parties in the 217th Diet session, leading to calls for consideration of closing the market.
It is nothing short of regrettable that the submission of the amendment to ACES has been postponed for a year. 2027 will be a full 10 years since the last amendment. There is no way to make up for the significant delay compared to other countries. However, if this one year is used effectively to realize in both name and reality the closure of domestic ivory markets as required by the CITES resolution, then it can be seen as having a positive significance. In practically implementing the market closure, it is necessary to consider a soft landing measure, such as “narrow exemptions for some items” permitted by CITES resolution, so as not to “unfairly” infringe on the interests of related businesses and users of ivory that are recognized as having cultural importance. On the other hand, simply “buying time” is by no means acceptable.
Headwinds Against Maintaining the Ivory market Continue
Since then, incidents have continued to call into question Japan’s policy of maintaining the ivory market. At the end of May 2025, a “Petition to close the domestic ivory market” was accepted (pending review), and the petition was introduced by the leading opposition party member Matsuki and the mid-ranking Liberal Democratic Party member Iwata Kazuchika. [13] On June 4, it was reported that the Tokyo Metropolitan Police Department had arrested individuals involved in Daigo Ivory company, a leading manufacturer of ivory hanko. This incident exposed the fact that the members of the Tokyo Ivory Arts and Crafts Cooperative Association, who was supposed to have been promoting “appropriate ivory trade” through joint public-private efforts with MoE and METI,[14] had been grossly neglecting the regulations under ACES.
Amid this, a working document on the closure of domestic ivory markets has been submitted ahead of the CITES CoP20 (Samarkand, Uzbekistan), which will open on November 24, 2025. The submission was made by Burkina Faso, Ethiopia, Niger, and Senegal.[15] The document includes a proposed decision for Japan. As MoE states in the aforementioned report of the Implementation Evaluation Committee that it will “conduct dialogue with stakeholders through the Public-Private Council for Promoting Appropriate Ivory Trade and advance preparations for CITES CoP20”, the Ministries is likely to take a strong stance against market closure during deliberations at CoP20 in principle. However, what will happen if the majority of the Parties is outnumbered? The outcome of the deliberations will likely have a major impact on the policy of METI and MoE regarding whether to close the domestic ivory market through the amendment of ACES in 2027.
[1] Minutes of the 217th Diet Session, House of Councillors, Budget Committee, No. 14 (March 28, 2025)
https://www.sangiin.go.jp/japanese/joho1/kaigirok/kaigirok.htm
[2] 217th Diet Video Library, House of Representatives Committee on Environment (May 26, 2025)
https://www.webtv.sangiin.go.jp/webtv/index.php
[3] 217th Diet Video Library, House of Representatives Committee on Environment (June 3, 2025)
https://www.shugiintv.go.jp/jp/index.php?ex=VL&deli_id=55838&media_type=
[4] https://www.env.go.jp/nature/kisho/kagaku/01306.html
[5] https://www.env.go.jp/press/press_00038.html
[6] https://www.env.go.jp/content/000324539.pdf
[7] See Note 4.
[8] The evaluation of ivory trade regulations that should have been conducted by the Implementation Evaluation Committee will likely be prepared by MoE and METI as part of the process of compiling materials to be submitted to the ACES evaluation committee (to be established under the Central Environment Council (Wildlife Subcommittee)), which will be described later.
[9] See Note 4.
[10] FY2023 Implementation Evaluation Committee for the Act on the Conservation of Endangered Species of Wild Fauna and Flora (1st Meeting) Document 1-2 “Proceeding with the consideration of measures to be taken for the conservation of endangered species of wild fauna and flora”
https://www.env.go.jp/content/000209896.pdf
[11] https://etisonline.org/data-aggregates
[12] https://www3.nhk.or.jp/news/html/20250215/k10014723191000.html
[13] https://www.shugiin.go.jp/internet/itdb_seigan.nsf/html/seigan/2171780.htm
[14] Document 4: 1st Meeting of the Public-Private Council for Promoting Appropriate Ivory Trade
[15] https://cites.org/sites/default/files/documents/COP/20/agenda/E-CoP20-076-02.pdf
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