Official Luthiers Forum!

So, I posed the question to environment Canada as to how to inventory and document my existing rosewood, bubinga, and ovangkol in order to be able to ship completed instruments once the wood has been built into a guitar.

I am posting the response here with permission, in an effort to do a sort of step by step walk through for folks to see, as we'll all need to do it if we want to use our existing stock for export in completed guitars, and maybe this will help ease the burden of those poor folks at EC about to be buried under mountains of extra paperwork.

Here is the response from EC. The actual inventory documentation will need to wait a few days, as I need to get some guitars shipped ASAP, however I'll get to it as soon as I can, and I'm sure most questions will be answered along the way, as I am in a highly typical scenario shared by many of us this side of the border. So this will be an ongoing process until everything I need to know is known, hopefully.

Ed,

The registration/documentation 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 

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.

Any wood that you get after January 1st will be a bit tricky, since you will need to track whether it was imported into Canada (and you have the CITES documents for that) or you obtained for someone else, who will have to certify when and how the wood got into Canada. We can cross that bridge when you get there.

Cheers,


Lise Jubinville

Chef d’unité, Politique et opérations des permis CITES / CITES Canada - Organe de gestion
Gestion de la faune et affaires réglementaires / Service canadien de la faune
Environnement and Climate Change Canada / Gouvernement du Canada
ec.cites.ec@canada.ca /Tel 1 855 869 8670

Head, CITES Permit Policy and Operations Unit / CITES Canada - Management Authority
Wildlife Management and Regulatory Affairs / Canadian Wildlife Service
Environment et Changements climatiques Canada / Government of Canada
ec.cites.ec@canada.ca /Tél 1 855 869 8670




-----Original Message-----
From: halcyonguitars@gmail.com [mailto:halcyonguitars@gmail.com]
Sent: December 21, 2016 3:12 PM
To: Cites (EC)
Subject: Pre-Convention Compliance...

Greetings,

I would like instructions as to how to properly go about documenting the rosewood pieces currently in my inventory, as well as rosewood guitars currently in production, to be sure that I will be able to ship these instruments properly when the time comes.

Thanks,

Ed

So, is it the case as stated in the other thread on this topic that you have to have the inventory filed with EC by the end of this month if you want "to be able to export the instruments legally in the future"? Or is it that the sooner you get your inventory submitted, the sooner you can get a permit?

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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

I interpret as needing to be done before Jan 2, 2017.

Well, that pretty much sucks then.

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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

Well, how much inventory do most of us have?

I have combined maybe 20 sets, a partway done guitar, and a few fingerboards, so no big deal.

Here's what I submitted to EC...

Hi Lise,

My company currently builds aprroximately 50 guitars per year, the vast majority of which are sold in the USA.

I build two different brands.

Tinker is the deluxe line, expensive with gloss coat, 3k$CAN upwards.

Halcyon is our more approachable line, where most guitars are less than 2k$CAN, and is the majority of the work.



Here is our current inventory of woods about to go Appendix 2 as of January 2, 2017.

8 sets (from which we derive the back and sides, bindings, headstock veneer, and bridge plate) of Guibourtia demeusei, aka Bubinga

4 sets (from which we derive the back and sides, bindings, headstock veneer, and bridge plate)
of Dalbergia latifolia, aka East Indian Rosewood

As well, we have

23 rosewood fingerboard blanks
13 rosewood bridge blanks
5 rosewood headstock veneers

6 bubinga headstock veneers

7 unmatched bubinga back sets (complete backs with no matching sides)
2 unmatched bubinga side sets (complete sides with no matching backs)

Here are our two brands/logos

image1.JPG
Please let me know one way or the other as to whether this is sufficient information or not.

Thanks,

Ed Bond

And the image...

I sent my inventory details today. Not that bad, around 20 B+S sets of Dalbergia and a bunch of blocks I use for bridges. I do know a bunch of luthiers who have over a hundred sets... I do pity them!

The real question is: are they going to really cross-check every request for export (probably in the hundreds every month)?

Pau Ferro is looking better every day as far as I am concerned

Cheers, and good luck to my friends with big stacks of Rosewood...

Not that bad at all. Even if you have 100+ sets. Hi. My name is tom and I have 101 sets.

"Hi. My name is tom and I have 101 sets."
Cracks me up Ed. Never mind Tom. What about Lise? He's going to have to deal
with all of this, come the new year.
Btw, I threw my little stash on the pile as well.
Ken

Yes, a whole lot of folks are going to have mounds of extra work to do, no doubt they will be expected to simply absorb it without extra staffing. Cause that's how it works.

Actually, I suspect that the time it takes to hire extra staff (I know the paperwork it involves to hire someone as a former government employee) is going to slow everything down significantly. I would not be surprised if export requests take months instead of weeks to go though. I will probably use non Dalbergia woods for exports until a clear picture emerges.

Mine was a bit bigger the 100+ EIR sets and 50 or so Bubinga sets weren't that bad but pulling out the finerboards and bridges out from the mix with ebony was a bit of a pain as I have a 150 so FB and 100 bridges in each species and the piles kept falling over....Done now. I had an automatic email return from the agency but otherwise no acknowledgements. I will see what transpires next week. I am also certain that there is a bit more Dalbergia wood buried in my piles....just too much work to pull it out!

Happy New Year all, may 2017 leave a few musicians alive by it's end!

Shane

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Canada