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PostPosted: Sat Dec 17, 2016 5:22 pm 
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Mahogany
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J De Rocher wrote:
Elman Concepcion wrote:
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 :-(


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?


Yes.



These users thanked the author Elman Concepcion for the post: J De Rocher (Sat Dec 17, 2016 5:24 pm)
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PostPosted: Wed Dec 21, 2016 2:08 pm 
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Mahogany
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I did some research on the topic this week and wrote a blog article about what I came up with... I hope this helps. Let me know if I really missed the mark on anything. I'm doing the best I can. Thanks!

http://www.ericschaeferguitars.com/34-rosewood-cites-means-luthiers-travelling-musicians/

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PostPosted: Wed Dec 21, 2016 4:36 pm 
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Thanks for posting this write up. It's nicely organized and clearly written.

For people taking guitars across a border to display at a guitar show, would they also need a second export permit from the country where the show was to get the guitar back into their home country?

"As this rolls out, the wood you order post January 2017, should come with documentation… I’d imagine."

This is something I'm really curious about how it will work in practice. Taking the case of Brazilian rosewood as an example, PRS guitars has publicly stated that they are under no obligation to provide documentation to their customers who buy PRS guitars containing Brazilian rosewood, therefore they don't. Even though the wood they use is pre-convention. http://www.prsguitars.com/brazilian/ See fine print at the bottom. They are taking this position even though the amount of BRW they handle must be tiny (and should be manageable) compared to the amount of Indian rosewood that is used by guitar manufacturers in general. I also wonder how this documentation will work for builders who buy Appendix II wood after January.

"It does not matter if it’s Appendix I or Appendix II, CITES only affects border crossings."
Is this the case for Appendix I wood? The FWS document "§ 23.55 How may I use a CITES specimen after import into the United States?" appears to say that without proof of a pre-convention certificate, BRW can only be used for non-commercial purposes. https://www.gpo.gov/fdsys/pkg/CFR-2014-title50-vol9/pdf/CFR-2014-title50-vol9-sec23-55.pdf
I have tried to dig up a clear answer to this without success. There is a constant supply of BRW available from ebay and from non-ebay sources and I expect that very little of it comes with documentation. Are people getting away with violating the rules because of no enforcement, or is it actually ok to use undocumented BRW in a guitar that you sell in your own country? I have some BRW bridge blanks I would like to use.

There are two web presentations from earlier this month that weren't on your list, so in case you haven't seen them:

International Wood Products Association - new rules on importing and exporting Appendix II woods and products: https://attendee.gotowebinar.com/rec...25012870722049

League of American Orchestras and NAMM - effects of the new rules on traveling musicians: https://1sourceevents.adobeconnect.c...&pbMode=normal

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PostPosted: Wed Dec 21, 2016 8:18 pm 
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Eric - two OLFers who are Canadian posted on another thread that Canada is requiring them to document their pre-2017 Appendix II wood with the Canadian regulatory agency by the end of this month if they want to be able to use it in guitars that would be shipped across a border for sale in the future. I haven't read or heard anything like a year-end drop dead date like that in the U.S. for existing stocks of Appendix II wood. Have you?

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PostPosted: Wed Dec 21, 2016 9:44 pm 
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US Fish and Wildlife Service posted this nice FAQ/Q&A today. Spells out things pretty well from different perspectives I think but I still have a few questions:

https://www.fws.gov/international/pdf/q ... r-2016.pdf



These users thanked the author James Ringelspaugh for the post: J De Rocher (Wed Dec 21, 2016 10:50 pm)
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PostPosted: Wed Dec 21, 2016 11:18 pm 
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Seems so burdensome.

Seems there could be trouble acquiring new woods to build with. For instance, unless the supply houses in Canada are scrambling to get preconvention certification for their existing stock, if I wanted to buy a set of rosewood from say Bow River, I would not be able to ship a guitar built with it into the US as I would not be able to provide the proper docs.


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PostPosted: Thu Dec 22, 2016 12:38 am 
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It is going to be burdensome for anyone who does business across borders, but what really amplifies the burden is the very short time between adoption of the new rules and their implementation. It's not realistic to expect that three months is enough get the various regulatory agencies up to speed on the practical implications of the new rules let alone ramping up their capacity to process a large number of a new class of permit applications that have to accommodate a bunch of different scenarios from applicants. It was clear from the two web presentations I listened to from earlier this month that FSW was still trying to get their head around the consequences of the new rules and how they would meet demand with less than a month to go. And then there is the problem of how either CITES or the agencies designated to enforce the rules can effectively communicate the new rules to all the business people who will be impacted in time for them to make adjustments and adopt new procedures. It seems like a messy transition is coming up.

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PostPosted: Fri Dec 23, 2016 9:01 am 
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Brazilian Rosewood
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Where is "repeal and replace" when you need it! gaah


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PostPosted: Fri Dec 23, 2016 10:28 am 
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Mahogany
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J De Rocher wrote:
Thanks for posting this write up. It's nicely organized and clearly written.

For people taking guitars across a border to display at a guitar show, would they also need a second export permit from the country where the show was to get the guitar back into their home country?

"As this rolls out, the wood you order post January 2017, should come with documentation… I’d imagine."

This is something I'm really curious about how it will work in practice. Taking the case of Brazilian rosewood as an example, PRS guitars has publicly stated that they are under no obligation to provide documentation to their customers who buy PRS guitars containing Brazilian rosewood, therefore they don't. Even though the wood they use is pre-convention. http://www.prsguitars.com/brazilian/ See fine print at the bottom. They are taking this position even though the amount of BRW they handle must be tiny (and should be manageable) compared to the amount of Indian rosewood that is used by guitar manufacturers in general. I also wonder how this documentation will work for builders who buy Appendix II wood after January.

"It does not matter if it’s Appendix I or Appendix II, CITES only affects border crossings."
Is this the case for Appendix I wood? The FWS document "§ 23.55 How may I use a CITES specimen after import into the United States?" appears to say that without proof of a pre-convention certificate, BRW can only be used for non-commercial purposes. https://www.gpo.gov/fdsys/pkg/CFR-2014-title50-vol9/pdf/CFR-2014-title50-vol9-sec23-55.pdf
I have tried to dig up a clear answer to this without success. There is a constant supply of BRW available from ebay and from non-ebay sources and I expect that very little of it comes with documentation. Are people getting away with violating the rules because of no enforcement, or is it actually ok to use undocumented BRW in a guitar that you sell in your own country? I have some BRW bridge blanks I would like to use.

There are two web presentations from earlier this month that weren't on your list, so in case you haven't seen them:

International Wood Products Association - new rules on importing and exporting Appendix II woods and products: https://attendee.gotowebinar.com/rec...25012870722049

League of American Orchestras and NAMM - effects of the new rules on traveling musicians: https://1sourceevents.adobeconnect.c...&pbMode=normal


Yes, I believe it works like this. For appendix II, anytime you leave a country (export) you need a permit. So, say you leave the usa, enter the uk, leave the uk, re-enter the usa. In that series of steps, you would need 2 permits: one for leaving the usa, one for leaving the uk.
For brazilian rosewood, or any appendix I, that same series of steps would necessitate 4 permits, to cover both import and export.

"Is this the case for Appendix I wood? The FWS document "§ 23.55 How may I use a CITES specimen after import into the United States?" appears to say that without proof of a pre-convention certificate, BRW can only be used for non-commercial purposes. https://www.gpo.gov/fdsys/pkg/CFR-2014-title50-vol9/pdf/CFR-2014-title50-vol9-sec23-55.pdf"

Thanks for bringing this up. You're right about appendix I. I was under the assumption that regulations were limited to borders and what happened within the borders were within that particular countries own discretion. But that was more of a pre-conceived assumption rather than a result of my research.
In fact, looking over that document it's hard to tell what you're supposed to assume for Appendix II even.

"(b) Appendix II with an annotation for noncommercial purposes
where other specimens of that species are treated as if listed
in Appendix I.
(c) Appendix II without an annotation for noncommercial purposes,
or Appendix III, and threatened under the ESA, except
as provided in a special rule in §§ 17.40 through 17.48
or under a permit granted under §§ 17.32 or 17.52"

This lists both "Appendix II with an annotation for noncommercial purposes" and "Appendix II without an annotation for noncommercial purposes"

It makes you wonder why there even is an annotation for noncommercial purposes if this document seems to imply that either way it is limited to "The specimen may be used only for noncommercial purposes"

I need to do more research. I'll work this into my second follow up article on this. ...But for now, my head hurts, just looking at it! Lol

"Are people getting away with violating the rules because of no enforcement, or is it actually ok to use undocumented BRW in a guitar that you sell in your own country?"

That is an interesting question, which I plan on also bringing up in the followup. As I understand this whole mess with all rosewoods being put under CITES, is a consequence of the lack of enforcement, or more accurately, the lack of ability to enforce. Unless ALL rosewoods are under scrutiny, it's hard for anyone to pick out the ones that the enforcers are actually interested in. I think up to this point, they've been relying on the threat of punishment, but now they are actually going to more or less bring the boot down, so to speak. Just my opinion. I'm wondering if they will be using some discretion with the rosewoods that they aren't interested in, or if all offenders will be treated the same...
As with anything related to government and law, this stuff isn't intended to be intelligible to the public. So on some level, we have to just wait and see what this whole thing is going to look like.

I'll check out those 2 links. Thanks for bringing them up.

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These users thanked the author ericschaeferguitars for the post: J De Rocher (Fri Dec 23, 2016 11:27 am)
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PostPosted: Fri Dec 23, 2016 10:32 am 
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Mahogany
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First name: Eric
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Country: US
Focus: Build
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J De Rocher wrote:
Eric - two OLFers who are Canadian posted on another thread that Canada is requiring them to document their pre-2017 Appendix II wood with the Canadian regulatory agency by the end of this month if they want to be able to use it in guitars that would be shipped across a border for sale in the future. I haven't read or heard anything like a year-end drop dead date like that in the U.S. for existing stocks of Appendix II wood. Have you?


That is news to me. I wonder if anybody else has a take on that?

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These users thanked the author ericschaeferguitars for the post: J De Rocher (Fri Dec 23, 2016 11:27 am)
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