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4. Hong Kong have also provided suggestions as to why CITES documents might become separated from their ivory and these reasons

appear to have more force;

liquidation/disillusion of intermediate traders rendering

tracing impossible;

lack of formal education in a very traditional (carving) trade is likely to result in an uneducated attitude towards the generation of paper work in the past;

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- it is common for carvers to buy small quantities from traders/shops, carve them and then re-sell them to original vendors without bothering with documentation. Some vendors,

with the introduction of restrictions and reduced markets, have

refused to re-purchase, leaving a large number of carvers each

holding small quantities

ties/no documentation.

5. I think we can make use of the above points as to why CITES documentation may have become detatched. It is certainly valid to say that carving is a very old and traditional occupation and that those involved in it are likely to be, and certainly to have been,

rather uneducated. The suggestion that some traders have not re-purchased their ivory from carvers also holds water.

5. Hong Kong have taken the line that unless there is evidence that the stocks have been imported illegally it would be quite wrong to assume that they are illegal. I think this is right. Hong Kong

have also said that if they are presented with information that any such stocks are not what the trader concerned claims, then they will

investigate cases "vigorously". I think that this line can be used

in our letters.

7. In their telno 1199, Hong Kong have again made the point that Hong Kong is the only CITES party which "dares and cares" to compose a statutory requirement or a licence to possess ivory and is the only country to find out exactly what the existing stock levels are. They make the point that, based on international ivory trade statistics, there must be thousands of tonnes of ivory in

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