CITES UPDATE: Action on Rosewood has Broad Implications

Action protecting more than 250 species of rosewood (dalbergia) taken at the recent meeting of the Convention on International Trade in Endangered Species (CITES) will have broad implications on the international shipments of musical  instruments containing the wood, including guitars, marimbas and various types of woodwinds.

The CITES delegates at the September 2016 Conference of the Parties in South Africa elected to expand the protection afforded to rosewood by placing some 250 species on Appendix II.  Only Brazilian rosewood, currently protected under a stricter Appendix I listing is excluded.  Although approximately 50 species had previously been listed on Appendix II, the expanded listing comes with an annotation which makes the protection applicable to not only logs and sawn wood, but also what's called "all parts and derivatives," which means finished products like musical instruments.

The expanded listing, which will take effect in early January, 2017 (specific date to be determined), is applicable worldwide and will require all manufacturers and retailers of musical instruments containing one or more rosewood species (excluding Brazilian rosewood) to obtain a permit from the appropriate government regulatory agency (in the United States, it is the Fish and Wildlife Service) if they wish to export one or more instruments outside of the country.  Domestic shipments will not require a permit.

There will undoubtedly be some compliance challenges as the new permit requirement is implemented, particularly with regard to the lead time necessary to obtain a permit prior to an international shipments and the information which must be furnished in the application process.  At the present time, one-time shipping permits carry a $100 fee, although frequent international shippers can obtain a three-year master file permit for $200 and individual shipment permits (valid for six months) at $5 each.

The rosewood listing does include some minor exemptions, including (a) non-commercial shipments (e.g.,, international travel by musicians) with a total weight of 10 kg or less, (b) parts and derivatives of Siamese (aka Thai) rosewood, and (c) all products originating and exported from Mexico.

NAMM plans further activities to keep members informed of the new requirements.  An educational session will be scheduled at the NAMM Show in Anaheim in January, 2017 and, if necessary, an informational webinar will be scheduled before then.  In the meantime, NAMM government affairs representatives will be meeting with FWS officials to determine the most efficient means of compliance.