In March, USFWS issued import permits for bracelets made of the sole of elephant feet/skin of a sport hunted elephant taken in Tanzania (Appendix I of CITES). This is an important breakthrough for hunters taking elephant in Tanzania or any other country where elephant remain on Appendix I, such as Zambia, when and if Zambia reopens.
It should be understood that the Division of Management Authority (DMA) issued a CITES import permit. The DMA did not say an import permit was not necessary. Instead, DMA required a separate import application and fee than that for the ivory and other unworked parts being imported as hunting trophies. The bracelets are not treated as trophies because they are “worked” or “crafted,” so USFWS requires separate import permit applications.
USFWS has published a proposed regulation to treat such crafted parts as trophies, but it has not been finalized. We were concerned that crafted parts of an Appendix I species would not be permitted since applications for import of scrimshawed/crafted elephant tusks have been denied in the past, though we don’t know how such an application would be treated today. It should be pointed out that elephant bracelets from Republic of South Africa, Namibia, Botswana and Zimbabwe, where elephant are on Appendix II, also require an import permit for the “worked” bracelet, even though an import permit is not appropriate for the unworked parts that are considered “trophy” parts. The downlisting of those elephant to Appendix II is only as trophies, which USFWS maintains excludes crafted parts. If the part is not a “trophy” because it has been crafted, then that part remains on Appendix I, thus an import permit is necessary just like in Tanzania and Zambia where even trophies are on Appendix I (not downlisted with an annotation).
We presume that bracelets of elephant hair will be treated the same as those approved skin bracelets from the soles of elephant feet. The same is true of elephant feet and bones made into useful or decorative items.