In Japan, the control of internal ivory trade is managed by the “Law for Conservation of Endangered Species of Wild Fauna and Flora” (LCES) and the by-laws thereof

1) Whole tusk registration system
The legislation prohibits any transaction and display for sale of whole tusks without registration under certain conditions with the registered organization to the Government.

It’s not mandatory to register whole tusks in private possession if there is no intention to trade them. As a result there is a huge amount of unregistered whole tusks in stock within the country, and this basically spoils the effectiveness and practicality of the system.
Moreover, examination of registration applications is watertight. For instance, statement of a third person that the ivory at issue has been in possession of the applicant since 1990, is accepted as a proof to the legitimacy. Once when a Member of parliament questioned the credibility of the examination in an interpellation session at the National Diet, he was amused to hear the Ministry of the Environment’s reply as, “We co-relate the submitted proof with the dates of newspapers wrappings in the ivory” (Proceedings of the Environment Committee, House of Representatives, dated 12th June 2003, during the 156th Session of the National Diet).

2) Ivory business registration system
The legislation obliges those engaged in transaction of ivory to register their business with the Government. The registered dealer should record the names and addresses of those from whom the dealer obtained cut pieces or worked ivory; ask his/her business counterpart from where they got the ivory products; and confirm and keep the record of such information in a ledger.

This system is only to track down transactions of ivory cut pieces between registered dealers, and it does not cover the movement of ivory from the processing stage onwards ? i.e. from cut pieces to finished products, and then to retail markets.
Moreover, it also does not prohibit registered dealers to obtain cut pieces or ivory products of which the legitimacy of import is not established. With such loopholes, it is meaningless to manage the movements of initially registered stock of cut pieces alone.

The obligations laid out in the ivory business registration system are far from being fulfilled by ivory dealers. According to the survey conducted by JWCS, before COP12, as many as 86.7% (189/218) of hanko retailers selling ivory hankos in Tokyo had not registered their businesses with the government. Another survey carried out after COP12 (October 2003) revealed that, as many as 91.4% (96/105) of ivory hanko retailers in Osaka remained unregistered.
Despite this extremely low level compliance, the relevant authorities have never bothered to exercise its authority to take punitive measures such as ordering business suspension or raising criminal charges against negligent dealers.