CITES Considers Revising Rosewood Rules
...that were hastily implemented in January of this year. Approximately 25 instrument makers, including representatives from Martin and Taylor Guitars, and Madinter, a leading supplier of tonewoods, were present. Scott Paul, director of natural resource sustainability at Taylor Guitars, said the committee was surprised by the unusually large turnout and “gave us a very sympathetic hearing.”
The CITES regulations in question placed all 200-plus species of Dalbergia, commonly known as rosewood, on “Appendix II” status, requiring manufacturers to secure import and export licenses for all products containing rosewood. For guitar and wind instrument makers, the new rules effectively brought trade to a halt as countries around the world scrambled to develop the appropriate forms and procedures for complying with the new rules. As a result, in the first quarter of 2017, U.S. electric guitar imports plummeted by 25% and acoustic guitar imports were off 31%.
The CITES Plant Committee cannot alter the text of the rosewood regulations. That can only be done by the CITES Committee of Parties (COP) which will next meet in 2019. What the Plant Committee can do is suggest alternative interpretations of the text. Given that even the Committee conceded that the rules were poorly written and full of ambiguous language, “alternative interpretations” hold the promise of easing some of the compliance burdens.
The good news emerging from the meeting was that the 500 scientists, environmental organization representatives, and interested observers in attendance seemed to agree that there were opportunities to scale back some of the burdensome reporting requirements on manufacturers that use rosewood, including guitar and wind instrument companies, without sacrificing the goal of preserving the world’s rosewood forests. The bad news was that the Plant Committee can only make recommendations; any actual changes to the CITES rules have to wait for the full meeting of the “Conference of Parties,” set for sometime in 2019 in Sri Lanka.
The original regulations permitted “non-commercial exports of a maximum weight of 10 kilograms (22 lbs.) per shipment” to pass borders without import/export licenses. The Committee suggested interpreting the weight requirement to apply only to the rosewood content of the shipment, not the total weight. In the case of consolidated shipments, such as when orchestras tour and consolidate all their instruments into a single container, the 10 kg threshold is applied to each instrument, not the entire shipment. The Committee is also recommending that shipments for warranty and repair be free from licensing requirements.
The CITES rosewood regulations mandated that manufacturers fully document the chain of custody of a piece of rosewood from the time it was cut until it lands at the loading dock, and to secure licenses to verify the legality of the rosewood used in each finished product slated for export. The music industry has requested to have the finished goods licensing requirement eliminated, arguing that in addition to requiring time-consuming paperwork, it is unnecessary. If the legality of the rosewood entering a factory is verified, why does the process have to be repeated for thousands of individual finished goods? This proposal was initially dismissed but has since gained support and will be presented at the upcoming Conference of Parties gathering. The Plant Committee also discussed the possibility of removing Indian rosewood from the reporting requirements, because it is widely cultivated at tea plantations to provide shade for the tea plants, and cutting is strictly regulated. As one participant noted, “Rosewood in India doesn’t even come close to needing Appendix II protection.”
The CITES rosewood regulations were drafted to slow the trade in rosewood furniture, primarily for the Chinese market, that was leading to indiscriminate logging of rosewood forests. The authors of the regulations acknowledge that they never even considered the impact the rules would have on the musical instrument industry, and according to Paul, “seem open to our suggestions.” However, he cautions that given the politics of the organization and the nuance of drafting rules, “positive changes are not guaranteed.”
Environmental enforcement agencies around the world, like the U.S. Fish and Wildlife Service, are emerging as an unlikely ally in rewriting the rosewood rules. Several agency representatives at the meeting complained that generating export licenses for musical instruments was consuming a disproportionate amount of time, diverting personnel from far more pressing issues.
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