Latest on the CITES Rosewood laws

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RabsRabs Frets: 2648
in Guitar tFB Trader

Heres the whole doc

http://ec.europa.eu/environment/cites/pdf/cop17/implementation_of_cites_cop17_listing_of_rosewood_clean.pdf

Having looked through it and what I can make out heres some more of the relevant info for us (id suggest if this effects you, that you look through the whole thing.

3. Personal and household effect exemption

It should also be noted that the EU Wildlife Trade Regulations contain less strict provisions for trade in specimens that are considered as personal and household effects. The carrying of an item, such as a musical instrument, in personal luggage can in this regard be subject to less strict provisions if it meets the definition of a personal and household effect8.

4. The annotation to the listing of Dalbergia spp., as well as Guibourtia demeusei, Guibourtia pellegriniana or Guibourtia tessmannii, exempts from CITES controls non-commercial trade of a maximum total weight of 10 kg per shipment. a. Does this weight limit of 10 kg apply to the entire shipment, or to the portion of the shipment made of wood of the species concerned?

It is recommended that this 10 kg weight limit is interpreted as referring to the weight of the portion of the shipment made of wood of the species concerned. This means in practice that any shipment weighing more than 10 kg, but which contains an overall weight of wood of the species concerned of less than 10 kg, is exempted from the documentary requirements foreseen under Council Regulation (EC) No 338/97 if it is traded for non-commercial purposes. In other words, the 10 kg limit is to be assessed against the weight of Dalbergia/Guibourtia parts contained in the shipment, rather than against the total weight of the shipment

b. What should be considered as "non-commercial trade" under this annotation? Trade for commercial purposes is taken to include use for commercial gain, acquisition for commercial purposes, purchase, sale, display for commercial purposes, keeping for sale, offering for sale or transport for sale. The interpretation of what constitutes commercial or non-commercial trade should be considered on a case-by-case basis. However, some general guidance can be provided for the following situations: i. The cross-border movement of musical instruments for purposes including, but not limited to, personal use, paid or unpaid performance, display (e.g. on a temporary exhibition) or competition should be considered as non-commercial9; ii. It is furthermore recommended that the international transport or sending10 of an item (to or from a non-EU country), such as a musical instrument, for the purpose of being repaired, is considered as a non-commercial transaction, in view of the fact that the item will remain under the ownership of the same person and that such transport will not lead to the sale of the item. The return to the seller or manufacturer of a product under warranty or after sale service should also be considered as a non-commercial transaction; iii. The loan of specimens for exhibition purposes in museums should also be considered as a non-commercial transaction; iv. The loan of musical instruments for exhibition or competition purposes should also be considered as a non-commercial transaction. The sending of a shipment containing multiple items sent for one of the above purposes (e.g. a shipment of musical instruments being jointly sent for the purpose of being repaired) should be considered as non-commercial, within the terms of annotation 15b) to the relevant wood species, and therefore falling outside the scope of provisions applying to Annex B-listed specimens under Council Regulation (EC) No 338/97, provided that the individual portion of these wood species present in each instrument would, if traveling separately, weight less than 10 kg and therefore qualify for the exemption. The international sending of items (e.g. pieces of musical instrument) for the purpose of being assembled in a third country and then re-exported to the country of initial sending should be considered as a commercial transaction, considering that the assembling of pieces is done in view of the making of an item which will be sold later on, i.e. for commercial purposes.


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Comments

  • guitars4youguitars4you Frets: 15430
    tFB Trader
    thanks for that Rabs

    I'm led to believe that all guitars that contain rosewood that were legally imported into the UK before 2/1/17 are exempt from the new CITES agreement - this effectively includes all used guitars - it is not necessary to apply for a CITES certificate to buy/sell any guitar within the EU - But if you buy outside the EU, be it e-bay or reverb etc you will need a certificate - seller to apply as required - Some sellers will say not worth the hassle - But if you travel back, say from the USA, with that guitar then no CITES required

    The above does not apply to Brazilian rosewood - Brazilian rosewood is in appendix 1 and as such an article 10 certificate will be required for any commercial purpose within the EU - a far tougher set of criteria
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  • guitars4youguitars4you Frets: 15430
    tFB Trader
    I understand that India is fighting this agreement and they are not signed up to CITES based on the fact that they have for a number of years implemented a harvest policy that has created new growth - It is okay for India to adopt this policy but once the wood has left India and is on any/many guitars then CITES authorities will instantly over ride this policy

    I don't think this is the end of it yet as I hear via NAMM and the MIA, plus others that they are seeking some exception based on low volumes of wood used and to allow the used market to be excluded - early stages on this so let's see how it pans out
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  • RabsRabs Frets: 2648
    tFB Trader

    I agree..   They are still in the discussion phases (which really should have been done before the new law came in)...  Its is obvious they never really considered stuff like musical instruments until this point...

    So yeah I reckon we have some more back and fourth to come yet... Really, anyone just carrying a guitar should be let off.. I mean its such an insignificant amount (assuming the whole guitar isn't made of it)....

    We will see..  Im still waiting to hear back from my suppliers about the certificates they are getting from their suppliers...

    Such fun :)

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  • SambostarSambostar Frets: 8745
    edited March 2017
    Dalbergia sissoo is common as muck and easily coppiced and sold as Sheesham furniture products, I think India up up against it as I understand no one is apparently an appropriate authority.  I think they have good reason to be pissed
    Backdoor Children Of The Sock
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  • DanielsguitarsDanielsguitars Frets: 3362
    tFB Trader
    Rabs said:

    I agree..   They are still in the discussion phases (which really should have been done before the new law came in)...  Its is obvious they never really considered stuff like musical instruments until this point...

    So yeah I reckon we have some more back and fourth to come yet... Really, anyone just carrying a guitar should be let off.. I mean its such an insignificant amount (assuming the whole guitar isn't made of it)....

    We will see..  Im still waiting to hear back from my suppliers about the certificates they are getting from their suppliers...

    Such fun :)

    Hi can you let us know where we can buy rosewood fretboards with certification if and when you hear back

    I bought Amazon rosewood in the state's before this came in and they can't supply certificates, none of this has been thought through 
    www.danielsguitars.co.uk
    (formerly customkits)
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  • RabsRabs Frets: 2648
    edited March 2017 tFB Trader
     
    Hi can you let us know where we can buy rosewood fretboards with certification if and when you hear back

    I bought Amazon rosewood in the state's before this came in and they can't supply certificates, none of this has been thought through 

    Sure...   I can tell you right now....

    Ive been getting off this guy almost from the start (he does really nice stuff). He said he is waiting for certificates from Germany

    http://www.ebay.co.uk/sch/bassbar1/m.html?ssPageName=STRK:MEFSXS:MESOI&_trksid=p2053788.m1543.l2654


    And then ive bought a few from this seller who said hes awaiting certification from Korea    

    http://www.ebay.co.uk/itm/131840349585?_trksid=p2060353.m1438.l2649&var=431280591406&ssPageName=STRK:MEBIDX:IT


    Both have said they are coming and I have no reason to doubt them...   Ive left it with them for now as I know that its not really been sorted out yet by the various government agencies that handle this so I guess right now theres no real rush..  Maybe email them about it and see what they say....

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  • DanielsguitarsDanielsguitars Frets: 3362
    tFB Trader
    Rabs said:
     
    Hi can you let us know where we can buy rosewood fretboards with certification if and when you hear back

    I bought Amazon rosewood in the state's before this came in and they can't supply certificates, none of this has been thought through 

    Sure...   I can tell you right now....

    Ive been getting off this guy almost from the start (he does really nice stuff). He said he is waiting for certificates from Germany

    http://www.ebay.co.uk/sch/bassbar1/m.html?ssPageName=STRK:MEFSXS:MESOI&_trksid=p2053788.m1543.l2654


    And then ive bought a few from this seller who said hes awaiting certification from Korea    

    http://www.ebay.co.uk/itm/131840349585?_trksid=p2060353.m1438.l2649&var=431280591406&ssPageName=STRK:MEBIDX:IT


    Both have said they are coming and I have no reason to doubt them...   Ive left it with them for now as I know that its not really been sorted out yet by the various government agencies that handle this so I guess right now theres no real rush..  Maybe email them about it and see what they say....

    Thanks, the whole thing is a joke imo
    www.danielsguitars.co.uk
    (formerly customkits)
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  • gavin_axecastergavin_axecaster Frets: 528
    tFB Trader
    As far as I'm aware the CITES panel only meets every 3 years, so any amendments are a long way off.

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  • gavin_axecastergavin_axecaster Frets: 528
    tFB Trader
    I understand that India is fighting this agreement and they are not signed up to CITES based on the fact that they have for a number of years implemented a harvest policy that has created new growth - It is okay for India to adopt this policy but once the wood has left India and is on any/many guitars then CITES authorities will instantly over ride this policy


    Surely India are on a hiding to nothing - if they don't issue CITES export certificates they will only be able to export to non- CITES countries or countries that effectively ignore trade restrictions, severely limiting the market.
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  • guitars4youguitars4you Frets: 15430
    edited March 2017 tFB Trader
    I understand that India is fighting this agreement and they are not signed up to CITES based on the fact that they have for a number of years implemented a harvest policy that has created new growth - It is okay for India to adopt this policy but once the wood has left India and is on any/many guitars then CITES authorities will instantly over ride this policy


    Surely India are on a hiding to nothing - if they don't issue CITES export certificates they will only be able to export to non- CITES countries or countries that effectively ignore trade restrictions, severely limiting the market.
    sorry - misunderstanding - India has signed up for CITES - did so a while ago - but contesting this effective world wide ban/restriction, that came into place on 2/1/17 as they harvest rosewood and have done so for many years
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  • guitars4youguitars4you Frets: 15430
    tFB Trader
    As far as I'm aware the CITES panel only meets every 3 years, so any amendments are a long way off.

    I think that is with regard to what woods need to go on this list next or adjustments to appendix 1/11/111 - I'm sure other issues are attended to during this within this period 
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  • WezVWezV Frets: 17500
    edited March 2017
    I understand that India is fighting this agreement and they are not signed up to CITES based on the fact that they have for a number of years implemented a harvest policy that has created new growth - It is okay for India to adopt this policy but once the wood has left India and is on any/many guitars then CITES authorities will instantly over ride this policy


    Surely India are on a hiding to nothing - if they don't issue CITES export certificates they will only be able to export to non- CITES countries or countries that effectively ignore trade restrictions, severely limiting the market.
    sorry - misunderstanding - India has signed up for CITES - did so a while ago - but contesting this effective world wide ban/restriction, that came into place on 2/1/17 as they harvest rosewood and have done so for many years


    When I was travelling around India I was kinda shocked to see piles of raw rosewood logs and lorries full of the stuff on a regular basis.   The wood is there, its been harvested  in line with the local regulations and is worth a fair bit of money

    Prior to this new Cities update India's own ruling used to be that rosewood could only be exported in processed form.  The idea being to increase the amount of money Indian's gets for each log, rather than limit its use.  That was still ignored within India and I used to receive regular offers of pallets full of Rosewood direct from India.   About a decade ago the chat of guitar building forums was about the sizes we would be able to get and whether they needed to be fully processed in India.  Would  a fretboard need to be slotted and radiused, would a neck blank count as a finished product?  etc

     Investment in plantation rosewood like Sonokeling should be the long term goal, but even that is hit hard by the uncertainty created by these new rules.  


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  • guitars4youguitars4you Frets: 15430
    tFB Trader
    WezV said:
    I understand that India is fighting this agreement and they are not signed up to CITES based on the fact that they have for a number of years implemented a harvest policy that has created new growth - It is okay for India to adopt this policy but once the wood has left India and is on any/many guitars then CITES authorities will instantly over ride this policy


    Surely India are on a hiding to nothing - if they don't issue CITES export certificates they will only be able to export to non- CITES countries or countries that effectively ignore trade restrictions, severely limiting the market.
    sorry - misunderstanding - India has signed up for CITES - did so a while ago - but contesting this effective world wide ban/restriction, that came into place on 2/1/17 as they harvest rosewood and have done so for many years


    When I was travelling around India I was kinda shocked to see piles of raw rosewood logs and lorries full of the stuff on a regular basis.   The wood is there, its been harvested  in line with the local regulations and is worth a fair bit of money

    Prior to this new Cities update India's own ruling used to be that rosewood could only be exported in processed form.  The idea being to increase the amount of money Indian's gets for each log, rather than limit its use.  That was still ignored within India and I used to receive regular offers of pallets full of Rosewood direct from India.   About a decade ago the chat of guitar building forums was about the sizes we would be able to get and whether they needed to be fully processed in India.  Would  a fretboard need to be slotted and radiused, would a neck blank count as a finished product?  etc

     Investment in plantation rosewood like Sonokeling should be the long term goal, but even that is hit hard by the uncertainty created by these new rules.  


    Did this not have an impact on import tariffs as well - between raw wood of a certain size/weight and finished articles (ie a chess board and pieces)
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