BLOG:Tokyo Continues to Miss the Mark in Addressing Ivory Industry Subsidies

• 11/15/2025
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While pledging to reform Tokyo’s elephant ivory trade, the Tokyo Metropolitan Government (TMG) has also been subsidizing and supporting leading ivory industry stakeholders. Last year, the Environmental Investigation Agency (EIA) and the Japan Tiger and Elephant Fund (JTEF) drew attention to Tokyo’s ivory subsidies. Since then, some changes have been made, but more reforms are needed particularly in the wake of recent fraud perpetrated by Daigo Ivory, a leading industry stakeholder.

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TMG’s Ivory Subsidies and Our Recommendations

When Tokyo’s elephant ivory industry subsidies were first established in 1994, the goal was to stabilize the industry immediately after the international commercial trade in ivory was banned, since traders would no longer have an international supply of ivory. However, even as recently as last year, subsidies provided by TMG were funding efforts to increase the demand for elephant ivory products in Tokyo and work towards opening international trade in ivory. The subsidy program directly contradicts and undermines recent efforts to reform Tokyo’s domestic elephant ivory trade and international recommendations that urge closure of domestic markets for commercial ivory trade.

In June 2024, JTEF and EIA reached out to the Tokyo Metropolitan Government to convey our concerns about the subsidies and provide three main recommendations:

1. Stop any issuance of subsidies for projects aiming to help resume international trade in ivory, increase domestic demand for ivory crafts and products, or facilitate the trade in ivory.

2. Issue a public statement clarifying TMG’s policies on ivory trade and the ivory industry to eliminate mixed-messages and demonstrate clear dedication towards reduction of ivory demand and restriction of legal ivory trade in the jurisdiction of Tokyo.

3. Enact an ordinance adopted by the Tokyo Metropolitan Assembly to close the ivory market in Tokyo with only narrow exemptions.

TMG’s Action to Address Subsidies

In October 2024, apparently in response to our concerns, TMG’s Bureau of Industry and Labor revised the subsidy guidelines to limit the subsidized projects to those that support efforts to stabilize the management of “appropriate trade in ivory” carried out by ivory industry groups. It eliminated subsidies for projects aimed at reopening international trade in ivory and increasing demand for ivory products.

Under the revised guidelines, the subsidies were distributed to cover the cost of the business registration fees exclusively for the members of the Tokyo Ivory Arts and Crafts Association, currently composed of 21 traders. The registration fees are mandated by the Government of Japan for businesses selling ivory to pay every five years to maintain their registration.

Intentional Fraud by Daigo Ivory

In June 2025 executives from Diago Ivory were arrested for ivory trade fraud. The company and the key executive were accused of advertising and selling elephant ivory as mammoth ivory on an internet auction platform that banned elephant ivory sales, and pleaded guilty in August.

EIA and JTEF have had eyes on Daigo Ivory since our initial investigation into Japan’s tusk registration scheme in 2016. In 2022, JTEF released a report that directly drew attention to alleged fraud by Daigo Ivory by providing evidence indicating that Daigo was actively selling elephant ivory on Yahoo! Auctions, even after the e-commerce site banned ivory sales. Ivory from Daigo was even involved in illegal ivory export to China. As revealed in JTEF’s report, some defendants convicted in China for smuggling ivory from Japan had obtained the ivory from Daigo Ivory. 

In the court hearing, it was revealed that Daigo Ivory intentionally circumvented policies to sell ivory in spite of interventions from Yahoo! after JTEF drew attention to likely fraudulent sales.

New Briefing and Recommendations to TMG in Light of Daigo Case

In light of the arrest of Daigo, EIA and JTEF submitted a briefing in July 2025 to TMG with recommendations to manage the revised subsidies as well as other measures to amend the designation of ivory as a traditional craft:

• TMG should completely end the subsidies to the Tokyo Ivory Arts and Crafts Association for any projects to stabilize the management of businesses engaging in appropriate ivory trade. Considering the fraud perpetrated by an Association member and the lack of oversight and guidance by the Association, the recently granted subsidies should be revoked for all members and the payments returned to the Tokyo Metropolitan Government. The Daigo case details make these recommendations even more relevant. Daigo Ivory, as a member of the Tokyo Ivory Association, was certainly not engaging in “appropriate ivory trade” and should not have received government support. Since the beneficiaries were collectively granted the subsidy as Association members, with no further evaluation, the subsidies should be revoked, and payments returned, for all members.In October, the Tokyo Metropolitan Government announced that they would revoke and recall the subsidy for only Daigo Ivory, because it “violated laws and regulations.” Tokyo should go even further and abolish all subsidies to support Tokyo’s ivory industry, or only subsidize initiatives dedicated to ivory alternatives, which would send a clear signal to the national government that Tokyo is eyeing a shift to ending the trade in ivory in Japan in the future.

• TMG should also end the designation of ivory carvings (“edo zoge”) as Traditional Tokyo Crafts. Given historical evidence indicates that the raw materials for traditional crafts typically associated with ivory, including netsuke, have been historically made of a wide variety of raw materials in Japan, such designation of Tokyo Traditional Crafts, with ivory as the only raw material should cease. If related carvings are to be retained as Traditional Tokyo Crafts, a broader, reframed designation, especially on the raw materials, should be considered.

Need for Ivory Market Closure

No progress appears to have been made on the other overarching recommendations shared with TMG in 2024. Regarding the recommendation to issue a public statement clarifying Tokyo’s policies on ivory trade and the ivory industry in Tokyo, TMG representatives provided an explanation of the initiatives that Tokyo is already taking and indicated that TMG would not be issuing a follow up statement.

Regarding the final recommendation, to heed the advice of the Advisory Council including the consideration of legal measures to close Tokyo’s market, TMG representatives noted that Tokyo will promote appropriate ivory trade. There appears to be no plan to consider legal measures, like an ordinance, at this time.

At the national level, the Government of Japan is currently assessing its regulations that govern the trade in elephant ivory as part of an ongoing statutory review of the LCES/ACES. Tokyo Governor Yuriko Koike and the Tokyo Metropolitan Government should fully implement the guidance of the Advisory Council, including urging the national government to make legal efforts towards strict regulations on ivory trade.

Closing the market will support international efforts to protect elephants, streamline and simplify enforcement efforts, and further reduce the demand for ivory within Japan. As the Advisory Council recommended, the Tokyo Metropolitan Government should engage with the relevant ministries of the Government of Japan to support action, including the consideration of market closure, at the national level. Tokyo, as a responsible international leader, Japan’s capital, and a hub for the nation’s ivory sales, must weigh in.