Rosewood Restrictions

sequoia

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LMI sent me an email that if I wished they would send me a detailed explanation on the coming restrictions on east Indian rosewood. I replied that I would like to see an explanation of the coming restriction because I don't really get it. Please clarify.

Well I still don't really get it. I concede that my brain doesn't really work in these legal, lawerly ways. I mean what the hell is an annotation? Notice that all rosewoods or all Dalbergia is being lumped. This is kind of nuts and doesn't make sense. Do these people know wood or am I missing something?

Below is the email I got:

The New CITES Ruling

Some Explanations.
CITES is an international organization that regulates the import and export of plant and animal
species and materials in order to protect endangered species. Their rulings are legally binding in all of
the 182 countries who participate. It is CITES, for example, that strictly prohibits the import and export
of elephant ivory. There are three “Appendices” with Appendix I being used for the most stringent
protections (Ivory, Brazilian Rosewood) and Appendices II and III being less stringent.
During their recent congress, the CITES body moved all Dalbergia species (Rosewoods of every kind)
to Appendix II unless the specie was already on Appendix I. Other guitar woods are already at
Appendix II, the most common one being Honduran (or “genuine”) Mahogany.
All woods listed on CITES Appendices require CITES import / export permits and related fees and
forms in order to get the wood over any international border. This is why LMI does not sell Mahogany
blanks internationally. However, with Mahogany and some other CITES listed materials, there is an
‘annotation’ on the ruling which allows for exceptions and exclusions to the import/export
restrictions. For this reason, we are able to sell a pre-carved Mahogany neck to an international
customer, but not a rectangular neck blank. We can sell mahogany kerfing, but not an electric guitar
body blank or bracewood blank.
The new ruling for Rosewood is different as there are no similar annotations. So unfortunately,
when the new CITES ruling took effect on 1/4/2017 we and other wood sellers were no longer able
to feasibly retail any Rosewood part internationally, worked or un-worked unless annotations are
added to the listing. This includes Indian Rosewood, which unlike most of the other Rosewood species,
has been harvested and exported with great care and oversight by the Indian government and in many
cases, by third-party certifiers like FSC (Forest Stewardship Council).
Why include Indian Rosewood along with other Rosewoods (which are threatened)? By lumping all the
Rosewoods together it removes the responsibility of customs officials from having to distinguish
between the different species of Rosewood, which can often be very difficult. Misrepresenting
Rosewood species (calling Cocobolo ‘Indian Rosewood’ for example) has been a common method of
smuggling.
 
Am I to understand then, that LMI and other importer/retailers can still sell Indian Rosewood, Cocobolo or other woods that they legally import with the required documents and fees, to luthiers in the U.S? And if that is so, will they provide the necessary documents so that we can pass them on to the customers of our finished instruments so they can transport them across borders?
I support the idea of protecting these marvelous woods, but life is sure getting complicated.
 
I hear you and I don't understand either. This all sounds like gafflebab to me. From what I can tell is that nobody can clearly state what the hell is going on. ... I suppose it will be sorted out in the end.
 
It's a real nuisance. Stewmac and lmi no longer sell these internationally.
 
I mean what the hell is an annotation?
... basically, in this context, it's an amendment covering a specific circumstance.

The new regulations have been introduced as a cover-all, simply put, "Don't do it"

Eventually, given sufficiently valid argument, specific exclusions may be annotated (added) to cover that circumstance.

It's a lot easier and quicker to say "don't do it at all" and get that enshrined in law. The if's, but's and maybe's can be argued about later, in the meantime the species is being protected :)
 
This should be treated as a wonderful challenge to find and use other woods. The world won't end if Ukuleles or guitars are not made of Mahogany or Rosewood. There are hundreds of other specie to experiment with.
 
Bazmaz's latest review is of a KoAloha Opio spruce-topped tenor that uses a mahogany fretboard ...
 
What does this mean for all the guitars and ukuleles that have rosewood fretboards and bridges? Can they be confiscated by customs agents now?
 
What does this mean for all the guitars and ukuleles that have rosewood fretboards and bridges? Can they be confiscated by customs agents now?

Potentially, yes!

If you've got something valuable you want to import/export, get clarification, in writing, from each and every set of officials you're likely to encounter, before you get there!

Even then, there's no guarantee that the officers you meet on the day won't have a different opinion and decide to impound your whatever until they've double-checked.

Customs officials can, literally, be a law unto themselves. It pays to keep on the right side of them!
 
Elderly is not shipping many items internationally now and is in the process of trying to sort through all the paper work with the US and other governments. They told me it would be months at least to get through the process. Americans still have access to the very large American market but as a Canadian looking to upgrade my uke, my options are more limited.
 
It means that exporting is now such a complicated and awkward business that we are all going to be forced to prefer 'local' - a good thing in my eyes. Builders like Chuck saw the writing on the wall some time ago and pulled up the draw bridge - the sad thing about this is there is no-one in the UK of the stature of Chuck regarding inlay work to fill the void caused by this ridiculously draconian international legislation. At least the US was ahead of the wave - we are so behind here in the UK - our Customs and Excise hadn't even any documentation in place when I started looking in December last year... And yes, it is a great and much welsome 'forced opportunity' for builders to start looking for real alternatives though I suspect the days of exporting fine instruments made from lovely wood are definitely numbered.
 
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New CITES rules are a business killer. I spoke with someone at HMS last night. Anything with rosewood cannot be shipped for export without a $93 permit fee. If the instrument has abalone also, that requires another permit. There is a hefty fine for non compliance.

Fees apply to imports also. Offshore companies like Pono, Kala, Kiwaya, etc. are stuck with stock that require expensive permits plus the wait to go through the process.

Here's the kicker, it may take months for each permit to process!

What I am not clear on is whether CITES forms are required every time an instrument with rosewood crosses a border, when ukes are imported to the US dealers and then exported elsewhere.
 
I've been using walnut and maple for many years now. So called 'alternative' woods have a long history in musical instrument making, so I haven't the slightest fear of using them. I've also become somewhat sensitised to ebony dust and therefore I use bog oak as an alternative. It's a great alternative at that. It's been almost a year since I last used rosewood and I've been slowly reducing my use of it for a decade.
Having said all that rosewood will not disappear and luthiers will continue to export instruments with it. I see no difference to the use of the restricted Cedrela. Makers didn't stop using cedrela, nor have they stopped exporting instruments that contain cedrela. There's more paperwork, more cost but it's not illegal. Not even close.
 
... And yes, it is a great and much welcome 'forced opportunity' for builders to start looking for real alternatives though I suspect the days of exporting fine instruments made from lovely wood are definitely numbered.

I'm not a luthier by profession, but I built some instruments back in early nineties (90's) just for fun just before the Brazilian rosewood strictures set in I could see even then that that the end was coming. It was inevitable and obvious to me way back when that this couldn't last... Yes, there are certainly lovely replacement woods but gosh darnit, I do like rosewood and I'm gonna miss it. Deeply. So it isn't like this is some sort of surprise to luthiers. The writing has been on the wall for decades. Plus look on the positive side, the stuff is definitely toxic and oily and nasty. The thing I'm going to miss is that it looks and sounds great and I love it. Onward and upwards! Evolve change or die.... Now I hear this ovangkol stuff is great and just the cats meow. Sorry. Nothing will replace that beautiful Dalbergia sp. There is just something about it. Sorry, it just isn't really replaceable.
 
Can any maker or dealer share their experiences with this new regulation so far? Has any shipment of wood or finished instruments been stopped, or even confiscated? Can papers be acquired for any instrument, even the ones that are already in stock? With Rosewood being used for fretboards and bridges on a wide range of ukes, from cheap Chinese imports up to the Hawaiian K brands, is it impossible now to have such an instrument shipped across international borders? Can dealers in Canada or Europe still import brands like Kala, Pono, or Kanilea, or are their businesses doomed (or forced to restrict themselves to instruments without Rosewood)? Are companies changing their models to other woods like Ebony (which may end up on that same list even faster with this measure)?
 
In the UK I could have registered what stocks of rosewood I have. I still have the receipts (for tax purposes) even though the wood was bought years ago. I didn't bother because I have so little of it left, 5 or 6 sets. That can still be used for instruments within the UK (or the EU, for next 2 years). If I registered the wood I could have used it and exported.
You can still cross borders with your rosewood instruments, part of your personal allowance, which I believe has a 10 Kg upper limit.
Don't be confused. This is not an outright ban, it's a control. Providing makers have the required documentation there is nothing to stop them exporting across international borders. It is true that it will cost more because you will need to pay for the CITES certification. If you are selling within the US or within your own borders (or within the EU) it won't cost anything. It won't affect the US or the EU as much as it will some other countries. They both have relatively large indigenous markets. The death of rosewood and it's use in musical instruments is nonsense. It will be continually used for most of our lifetimes and beyond. This is not the same situation as Brazilian rosewood restriction.
 
The death of rosewood and it's use in musical instruments is nonsense. It will be continually used for most of our lifetimes and beyond. This is not the same situation as Brazilian rosewood restriction.

I think you are maybe right Michael. This is not about restricting Brazilian rosewood (Dalbergia nigra) which was and still is over exploited and has been on the highest CITES restricted list for decades and that is a good thing. I don't ever expect to buy or work with Dalbergia nigra ever again and I'm ok with that. I think the fear and confusion comes from the idea that there is blanket restriction on all Dalbergia sp. including the main stay East Indian rosewood which is a mainstay of the industry. The problem as I see it is that if East India rosewood (Dalbergia Latifolia) comes under these new restrictions, it isn't so much the export of the wood as a finished product but the import of the wood as raw material that becomes a problem. True, I'll bet there are stocks of imported D. latifolia already in stock that will last us many, many years so maybe this whole thing is much ado about nothing?
 
Nothing to stop you or anyone else importing rosewood. Fact. You do need the certificate for the wood that you are buying though. Indian Rosewood has been controlled by the Indian government for years. It will continue to be readily available for decades. It may cost more but it's still relatively cheap.
AFAIK the blanket restriction was imposed because the customs authorities were having difficulties differentiating between rosewoods. I suspect that they are more interested in much larger shipments, trying to ensure it is legal and that it has the correct certification. Very small importation of a few dozen sets of Indian rosewood has just been caught up in the cross fire.
 
Answering the last part of my own question above, I think there are some companies changing their models in order to replace the Rosewood parts: I know Pono is switching to Ebony fretboards and bridges on all models, and Kanile'a is now presenting their models with Ebony fretboards (and beach sand inlay instead of Abalone position markers).
 
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