The (Relatively) Painless Way to Deal with CITES

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, "CITES Compliance: Answering Common Questions for Sellers" 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.

Instrument retailers are confused and frustrated by the new requirements surrounding international sales of rosewood instruments. Their frustration is understandable given that there is no clear direction on how to best comply with CITES regulations.

In short, if a US seller is looking to ship an instrument containing rosewood outside the US they should have a permit from the U.S. Fish and Wildlife Service. Theoretically, this should be done every time the user wants to sell a guitar. Unfortunately, the permits cost $75 each, take up to 8 weeks to process, and can only be filed for after you’ve sold the instrument. It’s simply not realistic for most businesses.

There may be a better way to deal with this permit process: The Master File. With a Master File, you fill out your application once, and with it request as many export certificates as you like. You don’t need to know which instruments they will be used for, or where they will be going at that time. You can simply have a stack of certificates ready to be slipped into a case as soon as you make an overseas sale. Certificates only cost $5 and are good for up to 6 months (there is, however, a one-time $200 cost for the Master File).

As a business, you may want to consider creating a Master File for two reasons: first, it’s the law. Knowingly violating trade restrictions can have serious penalties; and second, there’s an opportunity. Because of the confusion around CITES permits, many sellers stopped selling internationally. Global demand for vintage American guitars has not decreased, but supply has. Those able to sell outside the US can capture more sales, at higher prices, to eager international buyers.


How to File for CITES Permits for Used and Vintage Guitars and Other Instruments

Here’s what it takes to deal with CITES:

The new CITES restrictions went into place on January 2, 2017. New instruments manufactured after January 2 can no longer be shipped across borders unless it can be proven that the wood was legally harvested before 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.

For our purposes, we’re focused only on the export of used instruments made before January 2, 2017. Also note, Brazilian rosewood is treated slightly differently. With the Master File process explained below you can also send instruments containing Brazilian rosewood provided they were manufactured prior to June 11, 1992.

  • Step 1: Download and print this form. Complete sections A (or B), C and D on page 1.

  • Step 2: Fill out page 3 as we’ve shown below. Ignore section 3, as that is not for people requesting a Master File.

  • Step 3: Complete Part III on Page 7 regarding where and how to send the permits. Note that despite what some applications indicate, the Fish and Wildlife Agency is no longer accepting credit card payments.

  • Step 4: Include a letter to the Fish and Wildlife Agency indicating that you are requesting a Master File for the export of pre-convention instruments containing rosewood. This cover letter should make it clear that you have sufficient knowledge about these products you wish to export. A template is below, but don't hesitate to customize the letter to provide more details.

  • Step 5: Print and sign the letter. Include pages 1, 3, 6, and 7 of your signed application as well as a check made out to the US FISH AND WILDLIFE SERVICE for $200 plus $5 for each certificate (so if you wanted 10 certificates, the check would be for $250). Mail your application to:

U.S. Fish and Wildlife Services
Division of Management Authority
Branch of Permits, MS:IA
5275 Leesburg Pike
Falls Church, VA 22041-3803

That’s it. If there are any problems or questions, the agency will contact you. Otherwise, you should have your Master File and certificates in 4 to 6 weeks.

Once you have the Master File, include a certificate along with some documentation that shows the instrument was made prior to 2017 in your customs paperwork when shipping the guitar. An original bill of sale or a reference to the date based on the serial number should work for dating purposes. Also note that 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.

Lead photo by Buffalo Music and Guitars

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