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Anti Vivisection Action Network



A letter to demand the refusal of permission of the import of Borneo elephants.

October 6th , 2003

Minister of the Economy, Trade and Industry
Mr.Shoichi Nakagawa

Minister of the Environment
Mrs. Yuriko Koike

We have been informed from an international NGO, which is working on protecting the wild Asian elephants captured in Sabah, Borneo (Malaysia) and are intended for export to Japanese zoos.

We have serious concerns that the intended ex/import may not be in compliance with CITES provisions. We would therefore like to request the Japanese government not to permit the importation until after investigating this case.

1. The import of these elephants will threaten the survival of the species.

Asian elephants are listed on Appendix I of CITES and may only be im/exported under strict conditions. According to Article III, paragraph 2a, an export permit should only be granted if the export is not detrimental to the survival of the species.

Borneo elephants have only recently been found to be genetically distinct from other Asian elephants subspecies, which have followed an independent evolutionary path in an isolated environment.(See attached article)

Genetic research has found that contrary to the former belief that elephants were introduced to Borneo in the 18th century it has now been found that elephants are indigenous to Borneo, and have experienced an independent evolutionary development for at least 18,000 years.

The population number of Borneo elephants is estimated to be very low, between 1,000 to 2,500 animals in total. Their distribution is very limited, fragmented and restricted to 5% of the northeast of Borneo only. Moreover, genetic diversity is extremely low, making Borneo elephants even more vulnerable. The habitat and range of Borneo elephants is rapidly decreasing due to logging operations and conversion of forests for plantations. Killing of elephants and the capture of live animals are additional threats.

Therefore we fear that exporting the elephants would be detrimental to the survival of this isolated species.

2. There is no proper facilities in Japan to keep elephants.

According to Article III, paragraph 3b,the Managing Authority of importing country should consider if the facility is suitable for keeping and caring about animals. However, there are neither laws for zoos nor the public organizations which guide and supervise zoos.

On the other hand JAZA (Japan Aquarium and Zoo Association) insists that it is a social gathering of the zoo industry and clarifies that it dose not work on advising and supervising zoos.

That is why even facilities where it is impossible to keep animals for scientific purposes because of their poor condition, can call themselves "zoos". Some of them have even been involved in illegal importation.

Because there is no obligation to follow the standard for facility, it is not too much to say that there are only a few zoos where they care about animal's biological and habitat needs.

ALIVE has been working on zoo checks for a long time. As a result we have found that most elephants display repetitive behavior because of mental and physical stress.(See attached video film) it is obvious that Japan's zoos do not offer a proper environment for elephants whose life span is between 70 years and 80 years. In fact many elephants die earlier than expected.

3.A false definition: "non-commercial purpose"

According to Article III, paragraph 3c) an import permit must only be granted for Appendix I specimens if these are not to be used for primarily commercial purposes.

In Japan animals that are listed to CITES I are allowed under a breeding program, purportedly a scientific research by zoos. At this time animals are also allowed to be imported for scientific purposes. However, the Managing Authority should check if the purpose of this importation can be justified.

While about 70 Asian elephants are kept in Japan's zoos, no Asian elephants have been bred. Because elephants are highly socialized animals, which live in a maternal family, simple keeping of male and female animals does not cause breeding.

Moreover, male elephants are rarely kept in captivity because it is hard and dangerous to control them in the breeding season. Based on the actual situation in Japan, there will never be proper conditions where Asian elephants can be bred. Therefore it is a falsehood that they apply for the import under a scientific (breeding)purpose.

4. No relation to the conservation of the species

According to CITES Resolution Conf.5.10 Annex, paragraph e) , "any importation for captive breeding purposes must be aimed as a priority at the long term protection of the affected species as required in Res. Conf.2.12".

However, there is only 1 female elephant, which is a presumed "Borneo elephant".(born in 1998,probably) It means that it will be more than 10 years until she can breed. Before her breeding season she will be exhibited. As a result the main purpose of this import is to keep them for commercial purposes. This point also violates CITES.

Basically the conservation of Asian elephants should be done in their own habitat. Bringing one or two elephants, one of whom will not be mature to breed for over ten years, has no relation to the preservation of the species. And if successful breeding does occur in captivity, one young elephant, separated from his/her local population, will not help in the conservation of the species.

Wildlife researchers insist that Borneo elephants should be conserved in their habitat. And with regard to the Borneo elephant's genetic distinctiveness they should be carefully managed separately from other Asian elephants.

For the above reasons ALIVE would like to demand that the Japanese government not permit this import.


Fusako Nogami
Director of ALIVE
All Life In a Viable Environment