Owner Ron Fromkin
ivoryrepair@yahoo.com

April 2017 UPDATE

FOR FLORIDA RESIDENTS ONLY

I have begun to make ivory parts for bonafide Florida residents. This will include blanks and parts for cue stick makers, knife makers and gun grip makers.  All items will be cut oversize and clear coated. All items will be made from documented pre-1990 African elephant ivory. It is legal for me to sell these items to Florida residents. I have a substantial supply of seasoned ivory that is available. I have some Pre-1990 legal elephant tusks available for Florida residents. I will have the best prices on the ferrules, joints and butts for cue stick makers and blanks for knife and gun grip makers, and  have a small amount of scrap available to crafts persons. Please contact me by e mail for more information.

 

No ivory can be sold to persons who are not a legal resident of Florida. We will strictly adhere to the requirements of the Federal  regulations allowing these sales to Florida residents.  A visit to Florida by an out of State resident does not constitute residency.  Selling to a Florida resident and then  that person sending the items out of State is called a “straw man sale” and is illegal.

Legal Update

Now that Director's Order 210 is in effect, there were some areas that were not crystal clear to me as an ivory restorer and occasional seller in Florida. Areas of concern to me were not discussed in any of the information I had seen. I contacted Rob Mitchell on some of this and he suggested I contact Craig Hoover of the Fish and Wildlife Service. He is the Chief of the Division of Management Authority, International Affairs.

Mr. Hoover was very helpful with my questions. The following are the questions and answers I received.
Rules concerning repairs sent from outside Florida.
  1. Can I repair or clean an elephant ivory carving sent to me from other States as long as I do no repairs with added elephant ivory?
The answer was yes, for either African or Asian ivory. If the item is an antique under the Endangered Species Act (ESA) my repair would only impact the status of that item if I repair it with an ESA species component. The antique status is a separate issue not addressed here.
So if you are in a State other than Florida, and have a carving in need of a restoration, I can do that work but cannot add any elephant ivory to the item, regardless of age. Examples would include an item needing cleaning, a dropped carving that needs reassembly, removal of old glue.
  1. Can I repair an elephant ivory carving sent from other States and use hippo, bone or man made materials for repairs that require additional material?
The answer was yes. If a elephant ivory carving was sent for repair was missing a hand, for example, I could carve a new hand out of hippo. Any elephant ivory removed from a carving (for example trimming a part for a better fit with replacement hippo ivory) cannot be used for any purpose. This basically addresses small slivers and scrap removed from a carving. I have no use for it anyway.

Rules for Florida residents
  1. Can I sell an elephant ivory object to a bonafide Florida resident if I have documentation showing the object was in the USA prior to 1990 ?
Answer was that it depends if it is African or Asian elephant ivory. Asian ivory must have been in the USA prior to July 1, 1975. I do not see much Asian ivory.
African ivory must have been in the USA prior to January 18th, 1990. There must be documentation to support this.
The documentation could include CITES documents, dated photos, a dated letter or other evidence. It was suggested that a seller provide copies to a buyer of such documentation.
  1. I have some African elephant tusks purchased by me in 2013. They were sold in the USA in 1980-81. I have original records and invoices. Can I take one of these tusks and create a chess piece for example for a bonafide Florida resident ? It is understood the item fabricated from a tusk would not be an antique.
Answer- Yes, this is consistent with Federal law. There is no Florida law prohibiting this. So for a Florida resident, I can make parts for a carving with pre-1990 elephant ivory. I can also use hippo, bone or man made material if the customer desires that. If you are not a bonafide Florida resident, I cannot repair anything with elephant ivory.
Mr. Hoover suggested I keep track of any tusk cut up for repairs for Florida residents and keep the material separate from other material. As many of you know, often repairs are the size of a grain of rice, so it may be difficult to keep really accurate records down to milligrams, especially considering waste material from sanding or lathe turning.
If you have any questions, please contact me at ivoryrepair@yahoo.com. Additional information is available at https://www.fws.gov/international/travel-and-trade/ivory-ban-questions-and-answers.html

For more information on this issue contact Godfrey Harris at the Ivory Education Institute or Rob Mitchell at the Elephant Protective Association.

   OR 

The Japanese Repository has been established since 1991 and specializes in ivory repair and restoration work to the trade and private parties, using genuine ivory materials. Missing or broken parts are hand carved in ivory and securely attached to the object. Whenever possible, repairs are made with ivory matching the original in color and density and finish. I also work in bone, wood, antler and horn. I have extensive experience in restoration and repairs to the following items:
Netsuke- ivory, wood, antler.
Japanese Okimono.

Chinese ivories of all types, including polychrome stain and painted surfaces.
Indian and Goa style carving.
European Ivory pieces.
Ivory tankards.
Chess sets, repair and fabrication, ivory, bone, wood, turned and figural.
Napoleonic Prisoner of war bone carvings.
Canes and walking sticks.
Small inlay work- bone, wood, ivory and other natural materials.
Wood carving- small items only, missing parts, cracks, damage, inlay.
Lathe turning in bone, ivory and wood for chess pieces, knobs, Finials, and bun feet for boxes and tea caddies.

Snuff bottle repairs- Tops in ivory and other materials, cork stoppers and spoons in bone and ivory.

If you have any questions about a repair please e-mail me at ivoryrepair@yahoo.com