CITES Compliance: Answering Common Questions for Sellers

Update: On Wednesday 08/28/19, the CITES convention in Geneva, Switzerland decided to exempt finished musical instruments, parts, and accessories from CITES restrictions on all rosewood species except Brazilian rosewood (whose protections predate the other rosewood species and remain in place).

According to NAMM, the exemption for musical instruments will take effect in late November 2019. Until that time, all restrictions remain. Read "CITES Restrictions on Musical Instruments Are Coming to an End" for more info and check back soon for more details.

CITES is the Convention on International Trade in Endangered Species of Wild Fauna and Flora. It is legislation meant to protect endangered species of wildlife, forests and fisheries. With new CITES requirements surrounding the international shipment of instruments containing rosewood, we are trying to make it as easy as possible for sellers to comply. Be sure to read our other articles about dealing with CITES, The (Relatively) Painless Way to Deal with CITES" and "How to Apply for an Individual CITES Permit." Please note that domestic sales and personal instruments carried across borders do not have these same restrictions. In this article, we will attempt to provide some clarity on this issue, but nothing contained herein should be construed, or relied upon, as legal advice. Instead, we are simply passing on some best practices that have worked for Reverb users in the past.

New regulation surrounding the international shipment of instruments containing rosewood has caused a host of questions and some confusion. In reality, complying with CITES just means taking measured, but uncomplicated, steps to ensure compliance. In this article we will attempt to answer the most common and pertinent questions that sellers may have about CITES and obtaining permits.

What is all this talk about rosewood and CITES?

Most developed countries work together to restrict trade in endangered species (think ivory or tortoise shell). This partnership is called CITES. Representatives meet every 3 years to determine which species should be included. During the most recent CITES meeting, the Dalbergia species, which include all rosewood trees, was added to the list of woods that require additional documentation in order to be sent outside of the country. Previously just Brazilian rosewood was considered a restricted material. Now all rosewood is treated the same.

What does that mean?

The new rosewood restrictions went into place on January 2, 2017. Instruments made before January 2, 2017 (called “pre–convention”) can be sent outside the country, but require a permit from the US Fish and Wildlife Agency. If the instrument you’re selling was made before 2017 and contains rosewood, you should file for a permit before sending it out of the country. If you’re buying an instrument that contains rosewood from outside the country, you should make sure the seller has secured an export certificate from their country’s respective agency.

How do I get a permit?

You can receive a one-time export certificate by filling out this form. Detailed instructions can be found here. Please note these instructions are for “pre–convention” instruments, meaning instruments made before 2017. Once you know where the instrument is going, you can begin the application process. The cost is $75 and can take 30 to 60 days to be completed. You’ll need to provide some evidence that the instrument was made before 2017 — an original bill of sale or a reference to the date based on the serial number should work.

If you think you’ll be sending multiple rosewood instruments outside the US, you can apply for a Master File. With a Master File, you do not need to know in advance which instrument you will be exporting or where it will be going. When you apply for the Master File, you can request “partially completed certificates”. These certificates are good for up to 6 months. You simply add information about the individual instrument and where it is going after you make a sale. This alleviates the 30 to 60 day waiting period by allowing you to have a stock of permits on hand and ready to go.

A Master File application costs $200 and each partially completed certificate costs $5. The one downside of this process is instruments have to be shipped via an approved port where the instrument may need to be inspected and authorized. FedEx/UPS/DHL should be able to route your shipment to an appropriate port for inspection, but it would not hurt to speak to your carrier about these issues when shipping to ensure compliance.

What happens if I don’t have a permit?

While many people have continued to ship instruments internationally with no issues, the law requires that you have an export certificate. If you do not the instrument may be refused entry into the destination country and could potentially be seized.

Lead photo by Buffalo Music and Guitars

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