Check if your item from an endangered species is a worked specimen
Check if your item is a ‘worked specimen’ and does not need an Article 10 certificate for commercial use of endangered species.
Worked specimens of endangered species and antiques pre-dating 1947 do not need an Article 10 certificate for commercial use. This is also known as a commercial use certificate.
Use this guidance to help understand if your item is a worked specimen. If you are still unsure, contact the Animal and Plant Health Agency (APHA) CITES team.
Criteria for worked specimens
An item is a worked specimen if it meets all of the following criteria:
- significantly altered from its natural, raw state
- manufactured or worked (altered) before 3 March 1947
- not reworked to change its purpose since 3 March 1947
- clearly identifiable as jewellery, an adornment, art, utility item or musical instrument
You must:
- be sure your item meets all these criteria and that the Animal and Plant Health Agency (APHA) would agree
- acquire the item in its finished, worked state
You must contact APHA’s CITES team before selling any specimens of rhino, tiger or bear.
What ‘significantly altered’ means
Natural, raw items include teeth, tusks, horns, antlers, skins, hair, feathers and timber.
Significant alterations to a natural, raw item are irreversible changes. Examples include:
- carving, engraving or manufacturing it into another form
- permanently incorporating and fixing it with other material
- crafting it, such as into jewellery
Skins are considered significantly altered if they are either:
- tanned and lined
- tanned with the taxidermy head attached
Examples of items that are not significantly altered
The following items are not significantly altered from their natural state, so do not qualify as worked specimens. You need an Article 10 certificate to use them commercially.
- Animal skulls, skeletons and bones of species listed in Annex A of the Wildlife Trade Regulations (WTR). Cleaning, polishing, priming, mounting or other preparation is not a significant alteration.
- Horns, antlers or skulls of species listed in Annex A of the WTR that are mounted on a wooden plaque. Light carvings, engravings or surface markings that do not change the item’s overall form are not a significant alteration.
- Whole or partial rhino horns with clocks, inkwells, barometers or other items inserted into them. Rhino horn items that are not worked specimens cannot be used commercially. APHA does not issue Article 10 certificates for these specimens.
- Marine turtle shells. This includes whole shells (unless the taxidermy animal is still attached to the shell), lacquered or polished shells, and shells with fixings for wall mounting.
- Sawfish rostrum. A rostrum is the snout of all species in the Pristidae family.
- Bracelets made from tiger claws mounted in silver. This is because the tiger claws could easily be removed from their mounts.
This list is not exhaustive. If you are unsure, contact APHA’s CITES team.
Providing evidence the item was manufactured or worked before 3 March 1947
APHA may ask for evidence that your item was manufactured or worked before 3 March 1947. If you are asked, you must provide proof of the item’s:
- age in a ‘statement of verification’
- provenance (origin)
It is your responsibility to gather evidence before any commercial transaction.
Age verification
An expert can verify the age of your worked specimen. For example, an antiques specialist, museum curator or independent specialist.
The statement of verification should include:
- a detailed description of the specimen
- justification for the original acquisition date (date the specimen was taken from the wild, born in captivity or artificially propagated)
- information about any restoration processes, if relevant
If the original acquisition date is unknown or cannot be proven, you may provide proof of a later date when the item was first owned by someone.
Examples of statements of verification are:
- expert appraisals
- written declarations from manufacturers
- publications of museums or exhibition catalogues
- condition reports
- other written statements from someone with relevant expertise
Provenance
Evidence of provenance should include any known previous ownership or location history. This might provide further evidence of the item’s age and its legal introduction into the UK.
Examples of evidence of provenance are:
- a dated receipt invoice or bill showing when, where and by whom the item was manufactured, sold or repaired
- property titles, including notarised wills or handwritten testaments
- a dated catalogue, newspaper or published articles containing photographs or detailed description of the item concerned
- a date or identification mark on the item
- customs documentation providing evidence of past movements
- transport or insurance documents
- declaration from owners and third parties about the provenance of the item
Items reworked since 3 March 1947
Worked specimens must be in the same condition as they were in 1947. They must not have been altered again (reworked) to change their purpose since 3 March 1947.
Items reworked after 3 March 1947 are not worked specimens. You need an Article 10 certificate to use these items commercially.
Examples of reworked items that are not considered worked specimens are:
- Brazilian rosewood (Dalbergia nigra) items such as floorboards or paneling reworked into guitars
- a fur coat reworked into cushion covers
APHA does not recommend reworking antiques with the intention of selling the reworked item. It may be difficult to prove the item is made from the original worked specimen and your Article 10 certificate application may be refused.
Renovating worked specimens
You can renovate antique worked specimens to restore their condition. But renovation must not change the original purpose of the item it was worked for before 1947 (for example, for utility, art, adornment or jewellery).
Changing the original purpose of the item is considered reworking. Reworked items cannot be sold as worked specimens and need an Article 10 certificate.
If using materials from a species listed in Annex A of the WTR during renovation, they must pre-date that species’ listing in CITES.
Use photographic evidence if you are asked to demonstrate the stages of renovation, where possible.
When you must contact APHA before renovation
You must contact APHA’s CITES team for advice before renovating a worked specimen if:
- you are using material from a species listed in Annex A of the WTR
- you are renovating a taxidermy animal
- the renovation process will compromise the ability to verify the item’s age or eligibility to qualify as a worked specimen
Contact APHA’s ivory team at ivoryact@apha.gov.uk if you are planning any renovations using ivory.
Examples of commonly repaired, renovated or reworked items
Reworked animal skin rugs
Animal skin rugs may be classified as worked specimens if:
- they are tanned and lined
- they are not lined but have the taxidermy head attached
- you can demonstrate evidence of an original lining
You may need evidence or expert advice to determine the item’s age if the original lining has worn away or been replaced.
An antique full-body tiger mount that has been reworked after 1947 into a tiger skin rug is not considered a worked specimen.
Renovated taxidermy animals
Taxidermy animals are significantly altered from their natural state, so can qualify as worked specimens.
Renovated tea caddies
Some tea caddies produced before 1947 are made from marine turtle tortoiseshell. They may include Brazilian rosewood or ivory inlay.
You can take tortoiseshell from another item to renovate a tea caddy produced before 1947. A renovated tea caddy would be considered a worked specimen.
Categorising items as jewellery, an adornment, art, utility item or a musical instrument
The following items are usually considered worked specimens if they were manufactured or worked before March 1947.
Jewellery and adornments
- Jewellery carved from rhinoceros horn or tortoiseshell, such as prayer beads.
- Otter paw brooches mounted in wooden shields or silver-plated mounts.
Art
- Libation cups carved from rhino horn.
- Ceremonial spoons carved from rhino horn.
These items usually have detailed carvings that experts can use to determine their age. Items made from rhino horn or ivory can also be dated using scientific means.
Utility items
- Crocodile skin shoes.
- Clothing.
- Furniture made from rosewood or including ivory inlay.
- Handbags, shoes, wallets or watchstraps made from crocodile skin or snakeskin.
- Walking sticks, canes and knobkerries (clubs) made from rhino horn.
You may be able to determine the age of an item of clothing by:
- an accompanying receipt
- the label
- company records
- consulting fashion experts
Musical instruments
Many types of musical instruments contain items listed in Annex A of the WTR. Examples that are usually considered worked specimens include:
- woodwind instruments such as bagpipes or clarinets with ivory ferrules or banding
- pianos with ivory keys or inlay, or rosewood marquetry
- stringed instruments such as guitars with ivory bridges, fret boards or tuning keys, or with bodywork made from Brazilian rosewood
If the instrument contains ivory, the ivory must make up less than 20% of its total volume. You will not need an Article 10 certificate for commercial use in Great Britain, but you must still register the item under a standard exemption in accordance with the Ivory Act 2018.
Many rosewood guitars were made after 1947. It is important to establish an accurate manufacturing date to determine if the item is a worked specimen.
Import and export of worked specimens
You need a CITES permit to import, export or re-export worked specimens.
APHA may grant CITES permits for worked specimens for commercial purposes if there are no other conservation issues for that species.
Other rules for ivory, tigers, bears and rhinos
Read additional guidance about selling items made of or containing ivory.
You need an Article 10 certificate to sell elephant ivory items pre-dating 1947 in Northern Ireland.
Specimens of some species are subject to stricter controls. These are:
- tigers (Panthera tigris) and any parts or derivatives
- bear (Ursidae) – bile, paws and gall bladders
- rhino (Rhinocerotidae) and rhino horn
If you intend to trade or move specimens from any of these species, you must email APHA before you apply at wildlife.licensing@apha.gov.uk.
Get help
For advice on if your item is a worked specimen, contact APHA’s CITES team.
You must provide APHA with enough evidence, such as photos, expert opinions and provenance. APHA will provide an opinion on whether the specimen:
- qualifies as a worked specimen
- can be renovated and sold without an Article 10 certificate
- needs to be accepted as ‘worked’ before renovation
- needs further certification for commercial use
Keep a copy of APHA’s response for future reference.