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I haven't been frequenting this forum for a bit ... apologies if this has already been covered exhaustively already. I knew of course of the CITES addition of all rosewoods this past September, but was made aware yesterday that a complete inventory of all rosewood parts and guitars (both in-progress and completed) have to be submitted to CITES by the end of this month, to be able to export the instruments legally in the future.

Here's an excerpt from an email from the head of CITES permit policy and operations, to Guillaume Rancourt of Rancourt Guitars (thanks to Guillaume and to Linda Manzer for forwarding it to me)

"The first thing we need to do is get an inventory of any guitar with rosewood or rosewood pieces that you have in your possession. You need to create a detailed list of what you have - # of guitars (finished or unfinished), # of pieces of rosewood that are shaped (and what shapes those are) and # of pieces of rosewood. If you have different types of Dalbergia spp (the scientific name for the entire family which will be under CITES protection), then this inventory needs to distinguish the quantities of each species. We need to get this list in our office (via email is ok), by end of 2016. This will serve to “certify” that your stock of rosewood is pre-convention (i.e. before the CITES changes occurred). We would also like to get a short summary of what your business is about – how you operate, how you track your guitars and stockpiles of wood and volume of exports per year. We need to get a sense of what we will have to manage for your business and ensure that we setup the right process for your business model.

When you ship a guitar after January 2nd 2017, you will need to obtain a CITES permit from our office. I have attached the application form. You will need to refer to the associated line item from the wood inventory that we have received and recorded in our files at the Canadian CITES office. NOTE: I have attached 2 versions of our permit application form – one is editable on the computer (no handwriting is required, but might not be compatible with your computer) and the other one is printable (handwriting is required).

If you receive new rosewood after January 2nd, 2017, this wood will have to enter Canada with a CITES export document issued by the exporting country. Please keep a record of that CITES document and send us a copy. We will have to update your wood inventory to account for that “new” wood."

I've also just talked to Michael Greenfield who confirmed that Canadian luthiers exporting guitars with rosewood components to the U.S. will need to submit CITES export documentation that will refer to this inventory list (apparently will take around 20 business days). He also confirmed that the recipient will not (thank goodness) have to submit CITES import papers too.

Yikes. Thanks for this, David.

What's the email address that we're supposed to send this list/info to?

SteveG

I'm thinking you email Lise Jubinville (head of CITES permit policy) at the address below

ec.cites.ec@canada.ca

Thanks David.

This is for export only purposes, David? What about guitars staying within the country?

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CITES A2 applies only to wood crossing borders for commercial purposes. If it stays in Canada, its unaffected. If it stays in the US it's unaffected. Shipped in either direction, affected.

This can be read two ways.

You have to have your pre-2017 wood documented by the end of the month to be able to use it at all in the future for export.
Or
If you want to export an instrument right away in 2017, you need to have the inventory submitted before the end of the month so that permits can be issued ASAP.

I suspect that the intended meaning of the email is the second one, which is a hassle but a lot less Draconian. I realize you are talking about the Canadian regulators, but I've listened to two presentations involving representatives of US Fish and Wildlife Service and they made no mention of any deadline. Only that you need to document wood to get a permit for export.

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Any idea how this may affect people traveling with guitars over a border?


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"There's really no wrong way, as long as the results are what's desired." Charles Fox

"We have to constantly remind ourselves what we're doing....No Luthier is putting a man on the moon!" Harry Fleishman

"Generosity is always different in the eye of the person who didn't receive anything, but who wanted some." Waddy Thomson

Depends on the purpose. If you're just taking a guitar on a road trip, no problem. If you're taking it down to sell, or display at a show, it's commercial purposes and therefore, permit required.

Us Canadians need to document our rosewood inventory by the end of the year, if we which to be able to get CITES permits to ship guitars using wood for said inventory in the future.

It seems to me that most Canadian builders currently source their IRW from US suppliers. As a Canadian who started my building in New Zealand, I've developed good business relationships with Indian suppliers and now back in Canada I continue to buy my rosewood direct. It hasn't always been easy to ensure that the quality is what I want, but the understanding has developed and I now have reliable access to top-quality material.

I'm wondering if I should be getting into the business of importing rosewood for sale to other Canadian builders. I can ensure that the paperwork is in order and that Canadian buyers get what they need to demonstrate the legitimacy of their material for future export as finished products.

Personally, I'd like to continue to use rosewood, as I love working with it and feel it represents incredible value as a first-class tonewood. Maybe other builders will decide to abandon it, because of the hassle, but I'm interested to know if there are some who simply want an easy supply from a Canadian source. If so, I may bite the bullet to work with my Indian partner to ensure that there is inventory readily available to Canadian builders.

Please let me know your feelings.

Hey Rod ... from what I've read, a musician crossing the border qualifies under a personal instrument exemption (in most countries).

Thanks David.

Tim, I think it would be amazing for you to start importing EIR or other Rosewoods which are documented... Having an in-country supplier would be very good indeed. Either that or check in with Bow River or Dave Myers at BC tonewoods, they might be interested in being a certified supplier of rosewood.

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"We have to constantly remind ourselves what we're doing....No Luthier is putting a man on the moon!" Harry Fleishman

"Generosity is always different in the eye of the person who didn't receive anything, but who wanted some." Waddy Thomson

Bow River is in the process of listing their inventory for pre-convention certification of the affected woods they have. When you buy a set of rosewood, it will come with the needed export papers, or maybe you'll need to ask or something, but they're on it.

Any wood purchased by them or anyone else importing it will come with the export certificate from the origin country which will serve as the papers needed to get an export permit.

That's my understanding.

I am sorting my wood collection and was wondering if we should list the back and side sets as a set or a total list by sides, backs and other size pieces. What I don't get is if they are not asking for photos how will they know what set of wood we are building an instrument from and exporting.

I always enjoy rooting through my wood pile so this is not as bad a job as it could be though a bit of a time waste. While at it I will photograph some of the sets I lack pictures of.

Fred

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I hear ya -- that's also what I'm up to this afternoon.

On the subject of photos, they likely wouldn't prove very much, except to show you actually had "x" pieces in the photo. I think the folks in Ottawa are being pragmatic in their documentation request. You document a December inventory of "y" pieces. As you apply for export of those, in raw or finished form, they'll get struck off your documented pre-listing inventory. Once they're all on permits, you'll have to document new wood to export more.

What is less clear to me is what paperwork we can offer a Canadian buyer of an instrument built in 2017 that will allow him/her to apply for an export permit, should he/she wish to sell across the border at a later date.




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That's a good question.

Perhaps apply for an export permit for all the guitars you build using wood in your preconvention stash and provide it with the guitar even if they are in Canada?

Kinda what I was thinking. You'd want to do the same for all post-listing wood as well. The export permit is free, at least in Canada, but I'm not sure how long it's good for. Something we need to sort out with our sunny-ways crowd in Ottawa.


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Here's an email that I got from Exotic Woods in Burlington, Ont. It reiterates what has already been posted. It looks like they will continue to stock and sell rosewoods and bubinga in the future. Good news for Southern Ontarians!

Hello Friends…we have received some news regarding the upcoming amendments to the CITES agreements….all of the world’s rosewoods
(except Brazilian…already Appendix 1) and the Bubinga species are being added to CITES Appendix II as of January 2, 2017. In order to gain a better understanding of what that will mean for all of us we have been in contact with the CITES Permit Policy and Operations Unit of CITES Canada - Management Authority / Wildlife Management and Regulatory Affairs / Canadian Wildlife Service. This is their recommendation:

We have been asking our guitar, bagpipe, furniture and other wood friends to create an inventory of the Dalbergias (all true rosewoods) and Giubourtias (bubinga) that are presently in their facilities in Canada. All this wood will be considered pre-convention for CITES. These will be treated differently from a permitting perspective. Anyone who buys some of this wood from you could need to have some type of certification that they are getting pre-convention wood versus “new” wood that enters Canada after Jan 2, 2017 with CITES permits.

All we are looking for is a list of the species and quantities of that species. The quantities can be in number of boards of x size or total volume or whatever method works for you. This does not have to be a super precise number….we need to at least get a rough guesstimate of what you have. Pictures are always nice to show us what this looks like.

If this information is in our email box on January 1st, we would deem the wood inventory to be pre-convention. First thing is to get the inventory to us so we get your snapshot in time.

That is what we have been doing all day….cataloguing all of our back and side sets and fingerboards and bridge blanks and head plates and rough stock and caps…..the list seems pretty daunting. In reality, the count wasn’t that bad. We are recommending that you all do the same primarily to save yourself major headaches if you sell to out of country clients.

This is advice from the head of the department to builders:

The registration means that you need to send us an inventory of the rosewood you have presently in your facility. A spreadsheet works nicely if you have multiple types of rosewood and multiple formats of rosewood (i.e. planks, fret boards, fingerboards, partially completed instrument, complete instrument, etc.). Provide a list of the type of wood, quantity of that wood in each of the formats you may have and approximately when you obtained the wood (does not have to be super precise). As well, please provide us with a short overview of your business, so that we can understand your operating model. As well, please provide a photo or copy of a label you affix to your finished guitars as a reference for us. Photos are always good to help us visualize what you are talking about J

If we have that list of wood, when you do require a CITES permit to export a finished guitar, you can request the permit and indicate that the source of the wood used for making the guitar is listed in the inventory provided to CITES Canada in December 2016, from the line item #x of the spreadsheet or list.

Basically, this is a precautionary measure for people who may be sending instruments or parts to clients outside of Canada in the future

Rest assured, there will be rosewood available in the future, it’s just going to be slower in coming and more paperwork on our end.

On a happier note, Merry Christmas. Please drive safe and sober this season.


Best regards,
Chris

EXOTIC WOODS INC.
5229 Harvester Rd.
Burlington, ON
L7L-5L4 905-335-8066
chris.marshall@exotic-woods.com

Alex

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In fact, I've been in contact with folks in India, and this CITES export permit requirement has caught them unprepared. Things will be shaky until they get things sorted.
Bulk importation and subsequent sale of material in Canada shouldn't pose much of a problem. My main concern for Canadian builders is that, along with the material, they get what they and their clients need to permit trade of individual instruments in the future. Hopefully the folks in Ottawa will help us and wood dealers will cooperate.

David Wren wrote:

"When you ship a guitar after January 2nd 2017, you will need to obtain a CITES permit from our office. I have attached the application form."

Where can we get this form?

Cheers,

[url]ec.gc.ca[/url] and search for "CITES forms". But the CITES permit area has been down the last few days. The office reopens tomorrow.



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What does this mean for buying/selling used or vintage guitars made previous to Jan 2 2017? I'm in Canada, say I see a used rosewood board Tele I like on ebay in the US, do I have to get permits for it if I buy it?

Sort of ... the eBay seller will need to apply for and purchase a CITES export permit to sell across the border. Importer has no paperwork, but it is not allowed entry to Canada without the US CITES export document. To get the export permit, the US authorities need proof that wood is legal -- proving date of manufacture would be the usual approach.


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