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D'oh, I just realized of course that my plan will only work for commissioned pieces where I know the buyer's address well ahead of time. It also occurs to me that, while I have to fill out an export form, will the buyer also have to fill out a corresponding import form on their end? I don't know. However, I did get word of an online seminar about the topic, so hopefully I'll get some hard answers. You can register for it here: http://216.34.99.192/votingmodule/VOTING2/f/1087545/10f2/?msig=63ab3800702bce2e0ddab857f261bcc5

Well...what the heck is an online seminar? How does it work?

Don't know-never done it. I'm guessing it's just a live webcast, but you have to register to watch. I think this one is not Canada-specific, so hopefully it will be useful to everyone.

US Fish and Wildlife sent me a link to a couple of webinars to discuss the new rules:

The first webinar, hosted by the International Wood Products Association, will take place on Tuesday, December 6, from 2:00 PM - 3:00 PM EST. This webinar will emphasize guidance on commercial imports and exports of timber and timber products.

https://attendee.gotowebinar.com/regist ... 3574145538

The second webinar, hosted by the League of American Orchestras, will take place on Wednesday, December 7, from 12:00 noon to 1:00 PM EST. This webinar will emphasize guidance on international travel with musical instruments.

http://216.34.99.192/votingmodule/VOTIN ... 57f261bcc5

Both parties need to get the appropriate import/export permits.

Michael N wrote:
"Necks are a little more problematic but I haven't really tried to address that, partly because I had such a stash of honduran and cedrela."

Here in the US we can get butternut wood pretty easily at the moment. It's a relative of walnut, and similarly stable, but much less dense. It works pretty much like cedrela. The problem is that it's disappearing due to an imported blight. Too bad: I used to love the nuts. Anyway, there's a lot of salvage logging going on, so it's fairly easy to get, for now.

How would basswood serve? I've heard of using willow, too, but I'm not sure how stable that would be. Then again, maybe the European stuff is better than the weeping willow we get around here. Willow does make very good block and liner stock, though. After all, that's what Strad used....

What happens if there are no import and export concerns? In other words, if one has undocumented Appendix I or II wood in the US, will it still be legal to build and sell an instrument made from that wood as long as the buyer is in the US?

Domestic shipping is fine for a2...

For undocumented Appendix I wood, is it actually still legal? According to the US Fish and Wildlife Service, an Appendix I wood without a "Pre-Convention certificate" can only be used for noncommercial purposes in the US.

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Once in a while you get shown the light in the strangest of places if you look at it right - Robert Hunter

In the past couple of days I’ve had a chance to speak with the head of the Canadian CITES permit office as well as take part in a seminar from the US Fish and Wildlife Agency, to lean more about how the new regulations affect us. Keep in mind that in this context I am speaking from a Canadian point of view, and referring only to Appendix II-listed species, meaning all dalbergia rosewoods and all guibourtia bubingas. Brazilian rosewood and other Appendix I species are a separate issue with much stricter controls.

The new regulations aren’t terriblly onerous. For musicians, if you own a guitar and are travelling with it, you don’t even need a permit. Even if you are a professional, performing musician, you’re fine. Up to 10kg of rosewood or bubinga per non-commercial shipment (performance doesn’t count as a commercial activity) is exempt, which is easily enough to cover a couple of guitars. As well, only the parts actually made of CITES-listed species count towards that 10kgs. Just make sure that you don’t sell them when you’re out of the country.

There is one exception to this rule; Siamese rosewood, aka Vietnamese rosewood, dalbergia cochinchinensis, requires a CITES permit in all cases. If you know that any of your guitars are made with it, you or your clients will need to get a permit even for personal travel with that guitar. I believe that a “travel certificate” with three-year validity will be available in these cases through the Canadian CITES permit offices.

To bring an instrument to a guitar show is trickier; you probably already need an ATA Carnet to cross customs smoothly, and now you might also need a CITES document. Americans can get a “travelling exhibition certificate”, but I’m not aware of a canadian equivalent. Probably one will have to contact the permit office directly and see if they can issue a special document for the situation. If not, the individual travel certificate will probably be sufficient, as long as you don’t sell the guitars in the foreign country.

If you want to sell a guitar internationally though, if it contains any rosewood or bubinga you will need to apply for an export permit (one permit per shipment) here http://www.ec.gc.ca/CITES/default.asp?lang=En&n=BA634294-1. This applies if you’re an individual or a luthier or a manufacturer. It’s free, which is good, but it will likely take several weeks to process. You’ll need to fill in the names and addresses of both the sender and recipient, and list all parts and quantities of rosewoods or bubingas, among other things. The Canadian office has been very helpful, and is going to try to make it as easy and painless as possible for us. For example, if you have an instrument that you want to sell, but don’t have a buyer yet, you can ask them to prepare a permit and hold it; once you have the name or address, they can complete the form and send it within a few days. Export permits are valid for six months from the date they are issued, and can be extended for another six months as often as required.

Another thing that we can do to help make the permit applications go as quickly as possible will be to make a “pre-convention declaration” and send it to the CITES permit office. This would be a document that indicates all the quantities of rosewood and bubinga that you have in your possession prior to Jan 2nd 2017. List everything you’ve got, including latin names and quantities (volume, dimensions, or weight) of each, with pictures, and corresponding invoices if you’ve got them. Also document every finished guitar you’ve got in stock that includes rosewood or bubinga. This is the part that I think is the biggest hassle, but better to do it once and avoid potential future pain.

I have a fair bit of rosewood that was either mislabelled on the invoices, or sold under a common name that appears to have no corresponding latin name, or doesn’t have any paper trail at all. In these cases, the permit office suggested that if there was a piece of wood whose species I was unsure of, to label it as dalbergia spp. Same for bubinga: list it as guibourtia spp. They all have the same status, so it won’t really matter.

Importing these species isn’t supposed be a problem… but I’m sure it will be. It is the responsibility of the exporter to provide the CITES export permits, and the importer doesn’t have to do anything. While export permits are free for Canadians, it will not necessarily be the same in other countries. For example, I believe that american companies will be charged 100USD per export permit; I suspect that no-one is going to want to bother going through the process, which means that Canadians are effectively going to be shut out from buying rosewood and bubinga from American suppliers. Hopefully some Canadian wood suppliers will continue to import these woods in quantities that make it worth the added expense, but we’ll almost certainly end up having to pay more. On the other hand, it means that American guitars will also become more expensive (they’ll need export permits too), thus giving a small domestic competitive advantage to home-grown luthiers. At least, that’s my theory.

Hopefully this clarifies more than it obfuscates.

Thanks for writing up this summary. It's very helpful.

I listened to the webinar this morning that was focused on the effects of the new rules on musicians. One comment I would add regarding the 10 kg exemption for personal (noncommercial) transport across borders is that, from the US regulators' point of view, they said they are interpreting the 10 kg amount as per instrument as opposed to per shipment, and the 10 kg applies to the total amount of the Appendix II wood in that instrument as opposed to the total weight of the instrument. So for guitars, no problem (even electric guitars) for noncommercial transport.

Another take away from the webinar for me is that it's VERY important to remember that the rules and the interpretation of rules may differ on opposite sides of a border. So when considering transporting across international borders, it's important to do your homework ahead of time.

The administrator representing the US agency that issues permits said they expect to be "slammed" in the near term so if you think you'll have a use for a permit, getting in the queue sooner than later would probably be best.

Ed asked above if the bubinga we use is one of the bubingas that's covered. As far as I can tell, there are 16 to 20 species of bubinga worldwide, 12 or 13 of which are from west Africa. The three species that will be listed under Appendix II (Guibourtia demeusei, Guibourtia pellegriniana, and Guibourtia tessmannii) appear to be the most commonly available and Guibourtia demeusei and Guibourtia tessmannii are commonly exported from Africa. So I'm guessing the answer will be yes in most cases.

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Once in a while you get shown the light in the strangest of places if you look at it right - Robert Hunter

Thanks for that Mike.

I wonder where sending an unfinished guitar into the US for finishing would fall?

That's similar to the question about sending a guitar across a border for repair. It comes down to whether or not it's considered to be a commercial activity. The repair question came up in the webinar yesterday and the US position is that if the repair has no fee associated with it, then it is considered noncommercial activity. If there is a fee associated with the repair, CITES paperwork will be required. Based on that, it seems that they could consider finishing for a fee to be a commercial activity. You should be able to find out by asking here: managementauthority@fws.gov

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Once in a while you get shown the light in the strangest of places if you look at it right - Robert Hunter

With non-Brazilian RW, I presume? The webinar made this quite clear. If there is a financial transaction you involved, I.e., you're paying someone in the US for a service, then the movement is commercial and a Canadian CITES export permit is required, and a US export permit to return it, regardless of how little rosewood is in the instrument.


Sent from my iPad using Tapatalk

Thanks.

For anyone who's interested, you can see/hear the webinar presentation on the effects of the rules on musicians here: https://1sourceevents.adobeconnect.com/ ... ode=normal

Ed - the part of the question & answer section that comes closest to answering your question starts at 36:10.

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Once in a while you get shown the light in the strangest of places if you look at it right - Robert Hunter

Even after reading a number of articles and listening to a podcast on the Fretboard Journal website and both the webinars, there a number of practical consequences of the new rules for builders who sell their guitars that I don't understand. I get that for the Appendix II rosewoods and bubingas, a CITES permit will be required to send a guitar across a border for the purpose of a sale. That's simple enough.

A CITES export permit will require "evidence of legal acquisition" and "evidence of lawful import". For wood bought before January 2017, that's presumably easy if you have a sales invoice with a purchase date. How is this going to work for wood bought in 2017? If I buy a cocobolo back and sides set next April, build a guitar, and want to sell it to someone in Vancouver, B.C., how would I document legal acquisition and import of the wood for an export permit application? Are wood sellers now going to be providing documentation with Appendix II wood sales after January 1?

A longer term question is what happens if I sell that cocobolo guitar to someone here in the Seattle area and they decide two years later to sell it to a buddy in Vancouver, B.C.? They would be faced with the same problem of documentation for an export permit. As a practical matter, are builders going to be needing to be able to provide their customers with documentation down the road?

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Once in a while you get shown the light in the strangest of places if you look at it right - Robert Hunter

For me all this hassle is enough to not sell rosewood/bubinga instruments cross border. It's a shame but it isn't just a case of adding the cost of a permit to the price of an instrument - a UK CITES permit is £60 plus the time it takes to fill in the forms and deal with any issues, lets call it £150. Like many makers, I price according to supply and demand and what the market will bear. If slapping on another £150 was fine, I already would have!

It's a real shame as I invested a lot of money in some highly figured bubinga, specifically to avoid any possible future CITES complications with rosewoods, now bubinga has gone straight in to Appendix II. I'm offloading a lot of old decent ebony I have for the same reason - I don't want to be stuck with it like I am with the 75 sets of BRW I have in storage in the UK. We can certainly expect to see ebony added in the next round, in three years time, and how about wenge or saplele?

If you make for fun or just your domestic market then these new additions to CITES don't make a great deal of difference, but if ike me, your small business is truly international, this is going to be a real pain. I guess the purpose of CITES is to discourage us from using these materials, and so it can be said that they work. I am seriously looking at engineered timbers now like rocklite - there are many versions out there, all more expensive than regular wood but they come with a advantage of not being prone to falling foul of any future CITES changes.

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nigel

http://www.theluthierblog.com

If I'm understanding this thread correctly, there isn't a great need to rush out and buy all the rosewood you can between now and January as long as what you buy comes from an in country supplier and your product isn't sold outside of the country. Is that correct? I would love an excuse to stock up, but I don't know if this is the right excuse.

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Insta - https://www.instagram.com/cbcguitars/
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The key point there is not selling your product containing rosewood outside your country. If you don't do that, the new rules don't affect your commercial activities and there's no need (excuse) to stock up as far as I can tell.

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Once in a while you get shown the light in the strangest of places if you look at it right - Robert Hunter

Correct, but you need to confirm that your in country supplier will still be able to supply rosewood. Should not be a problem in the USA because LMI intends to continue importing Indian rosewood, but other countries could be an issue. One Australian supplier has told me they intend to continue importing Indian rosewood, but that is not confirmed, so I am using that as an excuse to stock up. I won't be selling anything containing rosewood outside of Australia, but that is not likely to affect me much at all since the Lacey Act changes caused all my US sales to tank.

Here is a podcast from FBJ with John Thomas. An interesting and informative listen.

https://www.fretboardjournal.com/podcas ... hn-thomas/

I scanned the thread before posting. My apologies if it's already been posted.

M

I'm in the US.
So is the consensus that we need to take pictures of all our Rosewoods between now and January 1, 2017 ???
What a pain in the a$$.
There goes my Holidays

Only if you plan to export said wood in either raw or finished format.

I'm wondering why you would want to photograph them before Jan 1. Are these rosewoods that don't have purchase receipts/invoices and you would want to have date-stamped photos to document them?

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Once in a while you get shown the light in the strangest of places if you look at it right - Robert Hunter