Business Policies - Legal Update - Rules For Florida Residents

Package items for shipment:

It is very important the carving be well protected enroute to me. The carving needs plenty of cushioning to protect it from rough handling. First, using toilet tissue, stuff small wads of tissue into the crevices like areas between legs and under arms. Anywhere there are delicate parts should get support from these wads of tissue. Then the item is wrapped in toilet tissue that you carefully twist to form a tissue rope. When you are done, you should have a tissue bundle that does not look like anything because of the layers of twisted tissue. Then pack that in bubble wrap. Place the bubble wrap package in a box big enough to have a 3 to 6 inch layer of Styrofoam peanuts around it. Seal this box and place it in a larger box also cushioned with Styrofoam peanuts. This sounds like a lot of work but it only takes a few minutes and will protect your carving from additional damage. Sometimes large items cannot be double boxed. Be sure the box is much larger than the item so there is plenty of cushioning. If you ship in a used, flimsy cardboard box, you can expect additional problems. Cardboard boxes from the orient are especially weak and don't hold up. 
UPS, FedEx or priority mail are fine. Insure as you like.   Be sure to include what you want done, what we have discussed, and all contact information including e mail and phone number. I get numerous inquiries about restoration work and don't always retain or remember what was discussed, so a note is always helpful.  When your item arrives, I will contact you to discuss what needs to be done and the cost.

Privacy Policy:

All transactions are confidential. Your personal information is not distributed to any person or business.

Payment:

Payment by Paypal, money order or bank check. Dealers business checks are ok with approval. Sales tax (7%) applies to retail customers in the State of Florida. Dealers must provide certain tax exempt certificates.

Customer pays shipping. All damaged claims are between the shipper and customer.  Repair work and ivory sale and purchase only within the United States.

All items shipped for repair should be sent to :  
    The Japanese Repository
    7705 Northwest 18th Court
    Margate, Florida 33063

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.

  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.