Rosewood CITIES question

Hello again John,

Yes it's confusing, and I guess things have changed to a certain extent. The reference to "CITES form" may in fact be a new document. It's something we used to refer to simply as "Export Documents". It's not something you fill out, however. It's something you may be issued after completing the Wildlife & Fisheries form (instructions linked above). If you're a U.S. resident selling a "pre-convention" (not restricted before this January) Appendix II wood to a buyer out of the country, for example, the fee is $75.00 to submit the application.

You have to submit proof (bill of sale will do) for the pre-convention export documents, but your application can still be rejected, and here is where I see a potential problem.

This is new enough to where I can't say this positively, but it certainly appears to me that even the simplified pre-convention process is still going to require that you also submit your own list of all plant and animal (shell) material by scientific name in your instrument along with the weight of each. First, it's very unlikely anyone but the manufacturer could give you scientific names for things like shell species or brace material for example, but trying to put the tiny weights on these single instrument quantities for entry data designed for container shipments is really challenging as well.

We stopped dealing with any restricted woods years ago, but in bringing up our pieces from Central America we still have to do Lacey Act paperwork which also has this requirement (Lacey is an additional requirement for folks bringing instruments into the U.S.) We, of course knew what woods we used for all our parts, but never actually weighed them. At the time, the GAL (Guild of American Luthiers) put out a sample sheet with typical weights for all the parts of a typical classical/acoustic guitar. We simply used a fraction of those weights based on the total weight of our instruments versus the total typical guitar weight. We never had a problem; I don't think W&F wants to get that picky on a single instrument shipment.

I would post that page, but unfortunately they appear to have taken it down. Here's what they say about the situation now (again this is in reference to Lacey, but the requirement appears to be the same):

Since May 1, 2010, when filling out import forms and documents APHIS has been requiring that exact quantities for each species of material in a shipment must be tallied and listed separately using only standardized metric units: kg, m, m2, m3. For a guitar, this means calculating exactly how much mahogany is in the neck and kerfing; how much ebony in the fingerboard, bridge, and heelcap; how much rosewood in back, sides, and peghead veneer; how much maple in the bindings; how much of each species of shell used in the inlays. The actual cost for each material must also be declared. Several luthiers have now figured out typical quantities for each model of guitar they make and use these saved files for completing their border clearance documents. Sure it’s a hassle, but it’ll help keep trouble from knocking on your door!

So I guess what I'm saying is that since all this is so new (again), I'm not sure how particular they'll be on this data. Obviously if you can list all species and weights, you should do it. It will be interesting to see what will happen if you can't. They have said they are under a much greater caseload now (six weeks to process your application), but they also say they can reject your application. I have a feeling that means coming back with more complete data would also mean coming back with another $75.00.

As far as the question about packaging, that one's a lot easier. You should make three copies. Keep one, attach another to the outside of the box in a clear plastic envelope, and put the third inside the box in case the outside copies were to get torn off.

(Whew, makes me tired even writing all this!)

Good Luck!
 
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Dirk,

Thanks again for your effort in providing this information. I imagine it is only surpassed by actually going through the CITES process.

John
 
It appears exceptions and/or permits can vary from country to country. I very recently attempted to order a ukulele from a musical vendor in Japan. The vendor stated that ".......because of new regulations they could not sell or ship items with rosewood outside of Japan." The uke in question has a rosewood bridge and fret board.
 
I'm still trying to understand the difference of shipping as an individual or shipping as a commercial endeavor. If for example I sell ukulele that has some Rosewood on it and send it to a buyer in Europe as a "gift" since I am not a dealer and can accept Paypal friends and family payment. Would that ukulele be seized at customs? Is it illegal to send a gift of One ukulele? Or if someone was moving overseas and they needed to ship their belongings which included a ukulele that had a Rosewood fretboard?

A rose is a rose is a rose. A rosewood by any other name would smell as illegal. Is that the word in a nutshell?
 
I'm still trying to understand the difference of shipping as an individual or shipping as a commercial endeavor. If for example I sell ukulele that has some Rosewood on it and send it to a buyer in Europe as a "gift" since I am not a dealer and can accept Paypal friends and family payment. Would that ukulele be seized at customs? Is it illegal to send a gift of One ukulele? Or if someone was moving overseas and they needed to ship their belongings which included a ukulele that had a Rosewood fretboard?

A rose is a rose is a rose. A rosewood by any other name would smell as illegal. Is that the word in a nutshell?

If you internationally ship a uke with rosewood and it is inspected and discovered to have rosewood, it will be seized.
 
... and send it to a buyer in Europe as a "gift" since I am not a dealer and can accept Paypal friends and family payment.

As far as import regulations into the EU are concerned, gifts don't exist. This is also why the European receiver of a gifted uke will pay import tax and VAT for it.
 
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