Runjeet, i agree that the new rules are not quite as bleak as some make out, however i do believe that they are a bit more encompassing then you present.
Firstly, African elephant ivory was freely traded throughout the world and can be found on many ethnographic items from areas well beyond Africa, so this does not just effect collectable items from Africa alone.
As you point out, the new ruling prohibits ALL import of African ivory regardless of the age. Where trading in antique items of ivory is permitted
"The onus will now fall on the importer, exporter, or seller to demonstrate that an item meets these criteria." AFAIK, this is an expensive process. Since you have sought CITES certificates, perhaps you can tell us how much this process cost you for each item? What does CITES require for proof of antiquity?
Regarding inter or intra-state sales, how many American collectors in this room can easily prove that items they own with African ivory parts were imported before 1990 and with Asian ivory, before 1975? Swords and knives picked up at gun shows, antique malls or eBay rarely, if ever, come with acceptable provenance or documentation of antiquity. The "documental evidence" you speak of is generally nonexistent and impossible to obtain at this point in time.
I agree that the government probably does not have the man power to police in country sales at shows and antique malls, but all it takes is for one person to "drop a dime" on a show and i am pretty sure they will show up to prosecute.
