Latest on the new CITES Rosewood laws

[Rabs]

http://www.mia.org.uk/2017/01/cites-update-from-the-namm-show/

 

I attended 3 separate meetings whilst at the NAMM Show. One was with all the trade bodies from around the world (i.e. MIA-equivalents) and two were with NAMM, the League of American Orchestras and the US Fish and Wildlife Service (like our DEFRA). Many thanks to NAMM for organising all the meetings.

 

As before, I will try and summarise in bullet points:

 

Overview

1.It is very evident that MI companies across the globe are all struggling with the same compliance problems relating to the new rosewood restrictions.

2.It was also evident that a number of companies have already decided on alternate woods for future production.

3.We naturally wait to see how consumers will react to non-rosewood guitars!

4.The US Fish and Wildlife Agency were open and honest about the massive workload they are trying to manage (7 staff for 700 applications at the moment!).

5.It emerged that CITES chose to restrict ALL rosewoods because of the difficulty in distinguishing between different varieties (go figure!).

6.The scale of rosewood use was totally underestimated in relation to managing the new restrictions. Forget instruments for one moment, nobody even thought of amount used in cars for dashboards etc.!

7.East Indian rosewood is a large part of the restriction that affects our industry.

8.The new restrictions was the first time that finished instruments were included (as opposed to raw materials).

9.There was a general feeling (naturally not official) that the authorities were generally seeking and checking (at this stage) compliance from companies, rather than individuals with individual instruments.

10.Germany has emerged as a Country that appears to have especially taken the whole matter very seriously including bespoke rules and regulations!

11.We gathered that a shipment of new rosewood acoustic guitars bound for Australia had been “held up” at a Japanese port.

12.We spoke with representatives from Indian MI and they seemed confident that they would achieve “some sort of exemption” for rosewood. We really can’t see how this could be allowed by CITES!

13.In the meantime, Indian and Indonesian authorities are being urgently asked to create some sort of “Compromise Documentation” (in light of the Reservation Policy they have both adopted (see previous newsletter on MIA website).

 

Other

1.Ebony may not be far away in future restrictions (next CITES meeting is 2019).

2.New USA formaldehyde restrictions came into play in December 2017 with new standards relating to emissions…be aware!

3.The USA-led Music Instrument Passport (for musicians) does not appear to have been widely adopted around the world (a 3 year passport costs $100 instead of $75 per visit).

4.A Global Timber Forum is planned to be set up in UK and we are liaising with it.

5.The US authorities have started to create “Master Files” to help frequent user US companies with applications that involve both finished and unfinished products.

6.Sorry to say that there were no “glimmers of hope” to help companies using tiny amounts of rosewood in instruments (we will keep trying).

 

Summary

 

Nothing especially new emerged apart from the hope that India and Indonesia will swiftly find a resolution to their reservation stance.

 

It was marginally consoling to speak to so many MI colleagues from around the world and to know that we are all facing the same issues!

 

We will continue to work with you and the authorities to find a way through the issues so many of you are facing.

[deeman]

Not to get too political or anything, but I think this may be a little over-reaching by our collective governments.

 

Lumber (tone woods included) is a very lucrative business. Most companies (in the developed world anyways) know now that reforestation is key to their continued success and profits.

 

I can understand some regulation with the logging companies and importers of such wood, but to then extend the regulation to the people that buy from the regulated distributers and loggers is asinine.

 

Best of luck Rabs in keeping all of this sorted.

[Big Bill]

The FBI just raided my house and took all the rosewood off of all my guitars!

 

 

 

[rct]

 

rct

[Hall]

Heck. They just came and took my sandlewood incense left over from 1966 also!

[Rabs]

Not to get too political or anything, but I think this may be a little over-reaching by our collective governments.

 

Lumber (tone woods included) is a very lucrative business. Most companies (in the developed world anyways) know now that reforestation is key to their continued success and profits.

 

I can understand some regulation with the logging companies and importers of such wood, but to then extend the regulation to the people that buy from the regulated distributers and loggers is asinine.

 

Best of luck Rabs in keeping all of this sorted.

Cheers man...

 

Yeah its all a bit of a pain if I want to sell anything outside the UK (not that im in that position at the moment).. Mostly because they just hadn't considered our industry so its all a bit in the air at the moment.. Im sure it will get sorted out at some point...

 

My small worries for the average person is.. What happens if you get some overzealous or just plain stupid customs officer who doesn't actually know what they are talking about, they just know Rosewood is on the list.. So id just say if you are traveling with a RW equipped guitar, make sure you take your receipt as proof just in case... Better safe than sorry when it comes to these things. (even though I reckon theres only a small chance of that actually happening).

[Drog]

Not to get too political or anything, but I think this may be a little over-reaching by our collective governments.

 

Lumber (tone woods included) is a very lucrative business. Most companies (in the developed world anyways) know now that reforestation is key to their continued success and profits.

 

I can understand some regulation with the logging companies and importers of such wood, but to then extend the regulation to the people that buy from the regulated distributers and loggers is asinine.

 

Best of luck Rabs in keeping all of this sorted.

 

Problem is, the woods in question come from countries that do not replenish their woods as we do here in North America. Or the trees are really slow growth. Also the land areas for certain species have been destroyed.

 

We might be responsible here but what about China? Best to blanket everything from the source than try to police it after the fact.

 

Easy to understand now the reason Gibson has been pushing richlite. Maybe some more maple necked Gibsons with Cherry wood in the future?

[Rabs]

Easy to understand now the reason Gibson has been pushing richlite. Maybe some more maple necked Gibsons with Cherry wood in the future?

Id be happy with baked maple....

[pippy]

5.It emerged that CITES chose to restrict ALL rosewoods because of the difficulty in distinguishing between different varieties...

This is going to be well-nigh impossible to put into practice with any semblance of accuracy.

 

Anyone who made the epic journey through the thread arguing about the exact definition of what is - and what is not - a species/sub-species of "Rosewood" will remember that it is almost impossible to tell, without testing a sample of the wood, whether one specific piece of wood is actually a 'true' member of the rosewood genus.

 

Briefly; ALL true Rosewoods belong to the genus Dalbergia but, and this is where it gets tricky, not all species of Dalbergia are Rosewoods. Similarly, many other species are so similar to "true" Rosewoods that they are both called and sold as Rosewoods even although they are not from the Dalbergia genus.

 

This is just a little quote from the wiki definition of "other" (i.e. not "true") rosewoods;

 

"The timber trade will sell many timbers under the name rosewood (usually with an adjective) due to some (outward) similarities. A fair number of these timbers come from other legume genera; one such species that is often mentioned is Bolivian Machaerium Scleroxylon sold as Bolivian rosewood. Another that may be found in market from Southeast Asia is Pterocarpus Indicus, sold as New Guinea rosewood (and related species)...

 

Would YOU trust a Customs Officer to know that the Cocobolo (Dalbergia Retusa) fingerboard of your guitar is not classified as a true Rosewood?

When it gets to the Granadilla - used very recently by Gibson - it becomes even more complicated. Granadilla is another timber from the Dalbergia genus (D. Melanoxylon) but until recently was actually more often classified as being a sub-species of Ebony (which is, obviously, a protected species). Will the 2017 CITES changes affect these timbers?

 

There is going to be an awful lot of confusion in the near future.

 

Pip.

 

EDIT : I just did some checking and to answer some of my own questions it isn't just the 'true' rosewoods which have been added to the list but the entire Dalbergia genus. This further complicates things!

 

My small worries for the average person is.. What happens if you get some overzealous or just plain stupid customs officer who doesn't actually know what they are talking about, they just know Rosewood is on the list.. So id just say if you are traveling with a RW equipped guitar, make sure you take your receipt as proof just in case... Better safe than sorry when it comes to these things. (even though I reckon theres only a small chance of that actually happening).

Hmmm.....

I'm not so sure the chance will be that small, Rabs, and, on the contrary, were a customs officer to seize such a guitar they would be correct to do so.

 

This is a quote from the Restricted and Endangered Wood Species section of 'The Wood Database' website;

 

"If you believe that the wood or finished wood product was harvested/made before the date of the CITES listing, you still cannot legally travel with or export the wood unless you have written proof or other evidence that it was obtained before the listing date. If you have the required evidence, and are willing to pay a processing fee and wait 2-3 months for processing, then you may be eligible for a Pre-Convention Certificate."

 

EDIT Pt. 2 : As far as Machaerium Scleroxylon (aka 'Bolivian Rosewood' as mentioned above) goes, here is what the same website says about it;

 

"...because the wood is so similar in appearance and working properties to rosewood it is also sometimes referred to as Bolivian or Santos Rosewood. The wood has been used in various capacities as a substitute for the endangered Brazillian Rosewood. Although the wood is not technically in the Dalbergia genus, it’s in a closely-related genus (Machaerium), and contains the same sensitizing compounds found in rosewoods—about as close to a true rosewood as a wood can get without actually being a Dalbergia species."

 

Furthermore;

 

"This wood species is not listed in the CITES Appendices, and many of the species within the Machaerium genus are reported by the IUCN as being of least concern.".

 

If I were in control of timber supplies at Gibson I think I might be making enquiries along this route...

[merciful-evans]

Id be happy with baked maple....

 

I'd much prefer it.

 

Rosewood is wonderful for acoustic back & sides, but I dont much like it on my fretboards.

[Rabs]

 

Hmmm.....

I'm not so sure the chance will be that small, Rabs, and, on the contrary, were a customs officer to seize such a guitar they would be correct to do so.

 

This is a quote from the Restricted and Endangered Wood Species section of 'The Wood Database' website;

 

"If you believe that the wood or finished wood product was harvested/made before the date of the CITES listing, you still cannot legally travel with or export the wood unless you have written proof or other evidence that it was obtained before the listing date. If you have the required evidence, and are willing to pay a processing fee and wait 2-3 months for processing, then you may be eligible for a Pre-Convention Certificate."

 

EDIT Pt. 2 : As far as Machaerium Scleroxylon (aka 'Bolivian Rosewood' as mentioned above) goes, here is what the same website says about it;

 

"...because the wood is so similar in appearance and working properties to rosewood it is also sometimes referred to as Bolivian or Santos Rosewood. The wood has been used in various capacities as a substitute for the endangered Brazillian Rosewood. Although the wood is not technically in the Dalbergia genus, it’s in a closely-related genus (Machaerium), and contains the same sensitizing compounds found in rosewoods—about as close to a true rosewood as a wood can get without actually being a Dalbergia species."

 

Furthermore;

 

"This wood species is not listed in the CITES Appendices, and many of the species within the Machaerium genus are reported by the IUCN as being of least concern.".

 

If I were in control of timber supplies at Gibson I think I might be making enquiries along this route...

Well I say that because they have been making clear the whole way along that personal travel with a guitar is fine.. They aren't going after individuals (I seem to remember its for 22lbs worth and over)... The rule is only for people carrying for commercial use.... OR if you want to buy or sell a guitar internationally.. So really they should leave anyone with just one guitar alone but as I say, you just need to get that one idiot or over zealous customs twit...

 

I have bought my Rosewood from two different sources.. I contacted both of them and neither of them knew anything about it. The first guy said ohh what a pain I wont be buying any more and then a few days later he sent me another message saying he contacted his supplier (in Korea :unsure: ) and will be getting certification. And the other guy said he had also contacted his German supplier and they also have stuff in the works... So it is being sorted, just rather slowly.. And as of yet im still not sure what will happen with the guitars I have already built.. (assuming anyone actually buys one )

 

The thing is that if you have to prove its older than 2017... Easy enough for most guitars that have a made on date on them. What about the ones that don't or arnt obvious.... What about all the 2017 Gibsons that were built in 2016???

 

But I really don't think it will effect anyone just traveling with a single guitar (unless you are on a tour maybe?)

 

We will have to wait a bit and see how they decide to actually enforce all of this.

[pippy]

Well I say that because they have been making clear the whole way along that personal travel with a guitar is fine...They aren't going after individuals...

We will have to wait a bit and see how they decide to actually enforce all of this.

I hope you are correct.

 

Who, exactly, was making it clear that personal travel/individuals would not be affected/pursued? If it was a representative of any of the the enforcing agencies, or, better still, CITES themselves, is there anywhere that this stance is written down officially?

 

On another tack; have you, yourself, thought about using the 'Bolivian Rosewood' mentioned earlier? From what is written on 'The Wood Database' it sounds an ideal substitute for (Braz!) rosewood.

 

Pip.

[rct]

I hope you are correct.

Who, exactly, was making it clear that personal travel/individuals would not be affected/pursued?

 

Somewhere in here I linked to a summary of the thing. It's pretty clear, unless you are expressly leaving your country to sell the guitar you are carrying, they have no interest it what wood it is made of. And it is doubtful they will even remember to ask you if you are selling this guitar. And they themselves know that everyone with a tenth of a brain cell will just say no anyway.

 

There is also the amount of rosewood, more than 11 kilos. I'll leave the math to your agile Euro brain, as I only know 11 kilos as a metric crapload of weed, not the actual pounds avoirdupwah.

 

rct

[Rabs]

I hope you are correct.

 

Who, exactly, was making it clear that personal travel/individuals would not be affected/pursued? If it was a representative of any of the the enforcing agencies, or, better still, CITES themselves, is there anywhere that this stance is written down officially?

 

On another tack; have you, yourself, thought about using the 'Bolivian Rosewood' mentioned earlier? From what is written on 'The Wood Database' it sounds an ideal substitute for (Braz!) rosewood.

 

Pip.

Well this was the original article... While its not an official article I think they probably know what they are talking about

https://reverb.com/uk/news/new-cites-regulations-for-all-rosewood-species

 

heres an article from the Guardian https://www.theguardian.com/environment/2016/sep/29/wildlife-summit-cracks-down-on-illegal-rosewood-trade

 

And then the Musical Industries Association (which is where ive been getting a lot of this from) http://www.mia.org.uk/2017/01/cites-update-from-the-namm-show/

 

Since then everything else I have seen matches what this says...

 

I will try and find the official pages for it.. But its not easy to read through all that legal speak...

[pippy]

Thanks for the reassurances, rct and Rabs.

 

 

Pip.

[fortyearspickn]

My own two cents:

My greatest take-away from the Reverb CITES article is that the great majority of the rosewood being harvested is going to a booming high end furniture market in China.

I have bbq grill tools with rosewood handles. Guess where they were made?

Brazil and Madagascar, among others, have already 'harvested' most of their hardwood.

They not only destroy the forest - they destroy the wildlife. Tiger populations in Indonesia have been decimated in the past 50 years as the demand for Palm Oil led to burn and slash.

Four years ago, the US destroyed SIX TONS of ivory from years of confiscations of illegal shipments.

Fish & Fowl are the ones who raided Gibson's inventory, seized a bunch, then just sat on it until Gibson settled out of court so they could move on. The Feds still have the wood.

The US Federal Government Agencies can certainly NOT be relied upon to correctly determine the species or the date harvested. They will seize what they feel like.

The article also notes UN reported 'rosewood' seized internationally represents the highest 'value' of any other 'wildlife' seizures.

Similar confusion existed for decades, probably still does on 'genuine tortoise shell'. It use to be the most common material for ladies combs, compacts, etc. Also used for guitar picks.

Now, even the smallest amounts are 'regulated.

States like California are attempting to prohibit the transfer of FIREARMS as part of the estate of a decedent. So, pro-regulatory politicians want to seize the firearm collection of a man who intended to pass it down to his sons. This would establish a precedent for anything else they don't like. Including 'rosewood' instruments.

And, finally, if these same bureaucrats change the 'weight limit' from 'above 22 lbs' to 'above 2 lbs' , how are the Fish N Fowl guys going to measure the back and sides as they are integral to a 5 pound guitar?

Be afraid Be Very Afraid.

Sorry for the rant.

But to paraphrase ..... " They can pry my guitar from my cold, dead hands. "

[pippy]

Fish & Fowl...raided Gibson's inventory, seized a bunch (of wood), then just sat on it until Gibson settled out of court so they could move on. The Feds still have the wood...

Not wishing to start a bunfight, fortyearspickn, but for the sake of accuracy I'd just like to point out that the wood was returned in the winter of 2013/14. Gibson brought out the first of the 'Government Series' guitars - Les Paul, Explorer, SG,V, ES-335 - which were crafted from this very timber starting in Feb 2014.

 

Pip.

[badbluesplayer]

I spent my career getting federal environmental permits for construction. This stuff is nothing. This is like in the bottom 0th percentile of how complicated regulations can be. And the implementation seems to be going silky smooth despite some confusion in the trenches. Now you know. No charge for the first consultation. Not that I the ESP to predict that - Gibson would be signing some kind of consent decree agreeing not to use ebony for like 5 years or so - or anything like that. And how long has it been and now they're using some? Five years? No, really?!

[fortyearspickn]

I hope you are correct.

 

Who, exactly, was making it clear that personal travel/individuals would not be affected/pursued? If it was a representative of any of the the enforcing agencies, or, better still, CITES themselves, is there anywhere that this stance is written down officially?

 

On another tack; have you, yourself, thought about using the 'Bolivian Rosewood' mentioned earlier? From what is written on 'The Wood Database' it sounds an ideal substitute for (Braz!) rosewood.

 

Pip.

 

 

Thanks for the info. Last info I had is apparently outdated.