We write on behalf of the Public Statues and Sculpture Association (pssauk.org), a registered UK charity whose aim is to advance the appreciation of all sculpture.
We understand that the proposed regulations are designed to impede the poaching of elephants, and above all to protect the elephant population from future threats.
We wholeheartedly support the protection of the elephant and would applaud more assistance being given to environmentalists in Africa and Asia in order to encourage and maintain the elephant population.
The trade of any contemporary ivory or unworked ivory tusks should certainly be banned. The current CITES regulations correctly ensure that no such works can be legally traded within the EU.
However, restricting the trade of historic works of art in ivory, be they portrait miniatures, statuettes, portable altarpieces, combs, medallions, devotional reliefs of religious subjects and countless other types of object, will not help in any laudable endeavour to save the elephant.
Antique works of art in ivory (like musical instruments with less than 20% ivory content, which are to be exempted from the regulations) are enormously important cultural objects. They constitute masterpieces in museums, where they are admired and valued by lovers of art, artists and collectors.
The gains to scholarship and culture in this active commerce will continue to bring hitherto unknown works of art into the public realm.
Conversely, banning such trade could lead to illicit underground activity, thus having exactly the opposite effect.
These historic items were made many years ago, often many centuries ago, meaning they not only have no impact on ivory trade today, but are vital artefacts from our past and need to be treasured for posterity.
The PSSA strongly recommends that these important items be exempted from any regulations.
Joanna Barnes and Holly Trusted
Co-chairs, Public Statues and Sculpture Association