Import/Export Regulations to Take Effect January 2, 2017

September 2017: The music industry and those that supply wood product inputs to music instrument manufacturers strongly support efforts to conserve rosewood and bubinga as well as further study of their biology, conservation, and trade. 

Statement of Principles: Musical Instruments and Appendix II Annotation 15

Annotation #15 pertaining to Dalbergia spp., Guibourtia demeusei, Guibourtia pellegriniana, and Guibourtia tessmannii (bubinga) provides that the rosewood and bubinga Appendix II listings cover:

All parts and derivatives are included, except:
a) Leaves, flowers, pollen, fruits, and seeds;
b) Non-commercial exports of a maximum total weight of 10 kg per shipment;
c) Parts and derivatives of Dalbergia cochinchinensis, which are covered by Annotation #4; and d) Parts and derivatives of Dalbergia spp. originating and exported from Mexico, which are covered by Annotation #6.

Musical Instruments, Rosewoods and Bubinga

The music industry and those that supply wood product inputs to music instrument manufacturers strongly support efforts to conserve rosewood and bubinga as well as further study of their biology, conservation, and trade. Protecting these trees is a priority.

The making of musical instruments requires very limited quantities of rosewood and bubinga. For example, guitars, violins, violas, double basses, clarinets, piccolos, oboes, flutes, xylophones, and pianos that contain rosewood or bubinga typically contain less than 10kg of the material. Marimbas and a small minority of pianos may contain larger quantities of the wood, but will usually not exceed 30kg per instrument. Instrument makers, retailers, and musicians rely on the trade in instruments for their livelihoods and to produce art that uplifts the human experience. In aggregate, these instruments represent an extremely small proportion of the worldwide trade in rosewoods and bubinga.

Increases in the cost of materials can greatly erode marginal profitability and threaten the livelihoods of instrument makers and related businesses (e.g., violin peg makers). For traveling musicians, and particularly for orchestras and ensembles, the non-commercial exemption in Annotation 15 is incomplete and unclear.

The absence of a clear and complete exemption for the movement of musical instruments as finished products presents a significant impact on the trade, hinders international cultural activity, and unnecessarily burdens CITES management authorities. If the Parties do not replace or correct the Annotation 15, the world of music and culture will lose certain instruments that produce the highest quality tones, with no corresponding conservation benefit.

Essential Elements of any Annotation for Rosewoods and Bubinga

1. Whether or not the annotation specifies musical instruments, in effect all trade in musical instruments should be exempted from CITES permitting requirements. This should include:

• Commercial shipments of finished musical instruments or instrument parts that will be incorporated into instruments without substantial modification
• Non-commercial transportation of finished musical instruments
• Musical instruments carried as personal effects and shipped as cargo

2. To the extent the existing Annotation 15 remains:

• Delete the term “non-commercial”
• Clarify its other terms of reference related to non-commercial activity, consolidated shipments, weight limits, and identification and marking requirements, as discussed at the 23rd meeting of the Plants Committee.
• Accommodate all musical instruments

3. Ensure consistency with current practices in customs, shipping, documentation, and declarations procedures.