I attended the CITES user group meeting last Thursday in Bristol to press the case on behalf of our industry in relation to the new and looming new restrictions in relation to Rosewoods and Ivory. The meeting included representatives from DEFRA and APHA along with people from the Timber Trade Federation, the numerous Wildlife trade bodies, Auction Houses (including musical instrument ones) right through to the Guild of Taxidermists. The Association of British Orchestras were also there to fly the flag with me for instruments and musicians.
It was very evident that all the government officials are well-intended but totally struggling with the workload and management of the CITES legislation. Lack of staffing was mentioned more than once and the associated worries about processing paperwork and licenses.
Having said that, the case for our industry was well received and I was given a good chance to let them know the problems we are trying to overcome in order to comply with the huge raft of paperwork and on-cost associated with all of this.
I specifically made the point that the new wood restrictions are actually threatening to put some of our small companies out of business where cost compliance is not viable in relation to the selling costs of the instruments. They had no idea how many small luthiers we had in the UK who are faced with enormous cash flow challenges and uncertainty whilst the government and the EU sort out the implementation of the new Rosewood restrictions. On that note, we still do not expect the EU, and therefore the UK, to be ready to issue licenses etc. until “early February” which I made clear was literally putting some of our members in jeopardy!
Anyway, to some specifics:
- Whilst the new CITES rosewood restrictions came into effect on January 2nd, the EU has not yet adopted this.
- Until this is official, border controls are, as we understand it, unable to take action
- We will not get any official “go ahead for now” instructions in light of this but I have confirmed the point above regarding border controls.
- We have a major compounding issue with India and Indonesia both having adopted a “Reservation” policy that means they will not adopt the new Rosewood restrictions until mid-year.
- We all know how much of our wood and guitars come from these territories and we, therefore, now face instruments and wood being sent to the UK without export licenses for this period.
- The Government were made clear that this will not be acceptable to our industry and that we are not in a position to “wait” until mid-year.
- This specific matter has global implications, let alone UK ones.
- One of our major guitar importers is currently exploring if their Indonesian-made guitars could arrive at UK ports with some sort of appropriate paperwork whilst the reservation is in place.
- I made the point that the license charging system will be prohibitive to the smaller businesses in the UK (we quoted Fred Rose Whistles) and pressed for some sort of assistance when the tiny amounts of restricted woods and low product selling price made license compliance untenable.
- We naturally raised second-hand instruments and the total lack of government awareness of the scale of the issue and how to police it. I suggested they go and look at how many used guitars are currently being sold on eBay!!!
- Our friend at the Auction House informed the meeting that many people are currently applying for Article 10 documentation when selling vintage Rosewood guitars. The Article 10 is applied for by saying the guitar contains Brazilian Rosewood even though it doesn’t, because at least there is an existing system for dealing in this highly restricted form of Rosewood!
- We reminded the officials that Hugh Manson of Manson Guitars had written to them inviting all to his place of business in order to see the real effects of the legislation.
- As you may be aware, there is legislation looming that may totally prohibit the selling of Ivory made after 1947
- The Government are yet to work out how to date Ivory.
- Or to be able to assertion if the Ivory if from Asian or African elephants!
- An open consultation will take place on the matter in the next few weeks and final decisions will be made after that.
- I made the case that pianos and violin bows only use Ivory as being incidental to the product.
- In the case of a piano, Ivory would typically be 3% of the total “volume” of materials used in the instrument.
- I told them that we had some second-hand pianos being sold with the Ivory keys being removed and thrown away and replaced with plastic ones…..a ridiculous waste to animals (first) and then humans!
- Together with the ABO, we talked about musicians removing the Ivory tips of their treasured violin bows before travelling abroad for fear of it being confiscated.
- Once again, the government had no idea of the number of post-1947 pianos that exist in the UK that are sold every week either privately, through our shops or via Auction Houses!
- We were informed that the process would initially involve all exiting EU laws being adopted by the UK as a stand-alone Country.
- The UK will then review all the laws and decide which ones to amend or discard
- Apparently this is the easier way to do it……….!!!!
We will continue to work with the Government to make the case for our industry and to work with all our global partners to bring both domestic and global pressure to bear. As a reminder, I will meet with our global partners at the NAMM international coalition meeting next week and there are also some excellent seminaries on CITES being run at the show itself
I will keep you updated as things develop and please keep your comments and input coming!
Paul Mc firstname.lastname@example.org