Howdy Folks,
I have sorted out what is required for us here in the US as far as CITES Permits, etc. for sending our instruments made from CITES II protected species out of the country.
For exports of instruments containing African Blackwood or other CITES II species:
Go to https://www.fws.gov/forms/3-200-32.pdf and request a “Master File” plus the Single Use Permits. The Master File is $200 and the Single Use Permits are $5 each. The Single use permits are essentially clones of the master permit.
I think one actually waits for the Master File to be granted before one pays for each of the Single Use Permits - according to the FWS agent I spoke with. However, they will want to know how many approximately one will need and these are good for 6 months. Additional ones can be ordered per the directions on that form. I’ll see if I can get this clarified.
In terms of documents etc. for the wood which for most of us will be pre-CITES II dated receipts from suppliers dated before 2017 including ones in the US, photos of the wood, etc. are all requested and depending upon the volume, the degree of data resolution required will be decided on a case by case basis. This only pertains to the wood that one intends to use in instruments intended for export. There is no requirement to document wood intended for sales within in the US. Thus one might consider allocating the wood into such categories as domestic use only and exportable instead of the entire woodpile!
One also needs to go to https://www.aphis.usda.gov/plant_health/permits/downloads/forms/ppqform621.pdf and submit that application plus its $70 fee. They requested this be done and paid for electronically.
Once the permits are in hand, the $5 single use CITES permit and a copy of the USDA permit accompanies the instrument being shipped. The Single Use Permit and a copy of the USDA 621 permit is then included in the same slip envelope on the outside of the package as the Form 2976-A Customs forms required for any export (these can be found at the Post Office and related online postage sites such as Endicia, which generates them automatically).
These exports are inspected and sent off via a USDA approved shipping facility. Usually when one mails a package overseas from one’s local post office, it is routed through one of these approved facilities (almost everything I send overseas from here in Seattle is routed through San Francisco). The USDA agent I spoke with this morning will confirm that this is truly the case, and that the documents go on the outside of the package. He wasn’t 100% sure, and will confirm this in a few business days.
….
One way around all of this nonsense is to simply stop exporting instruments made from CITES II protected wood. Sales of instruments to clients in the US can continue and no permit or reporting is required. For us woodwind makers there are alternatives to African Blackwood that are not under CITES protection. Mopane for instance. Or (heaven forbid) Delrin. Octopus Wood in Turkey has fantastic boxwood and Muzaffer Yeltekin is great to do business with. I get the older and dryer blue stained wood for my flutes (I sort of started the stampede for this - it was nicely dried down to 5%! He may be out of this wood - at least the really dry stuff.)
There might be issues when a client wants to sell an instrument made from African Blackwood to someone out of the country. As long as the instrument contains less than 10 kg of blackwood (22 pounds!) there is no restriction or permit required for them to take any instrument with CITES II wood across an international border as a personal item. However, in the case where they’re mailing it as an eBay sale or mailed gift, a permit is required and they have to apply for a $75 single use permit using the same https://www.fws.gov/forms/3-200-32.pdf permit form that we use to get the master permit.
They would have to provide proof that the instrument is pre-CITES or made from CITES approved sources. We makers may get besieged by our former clients for requests of documentation. However, I personally have made over 3000 blackwood flutes over the last 35 years and it will be up to my clients to come up with a bill of sale or some sort of other evidence that they have held these instrumets pre-CITES. Its not up to me to help them sell the instruments they purchased from me or from my resellers, especially if they didn’t keep any sort of documentation themselves such as a cancelled check or other evdence! I don’t keep such documentation beyond the required 7 years and its sometimes impossible and a hassle to find such info.
The permits are required if the maker takes an instrument he or she made to another country with the intention of selling it, however.
I simply plan to estimate and register a portion of my blackwood and mark it all “For Export” rather than register the entire lot. This simplifies things and I might simply only include the wood that I purchased in 2016, which is on the surface of the pile with receipts readily available.
I asked the FWS agent about wood that I might purchase in the future from my wood supplier, mentioning that all of his inventory is pre-CITES but that his documentation may be lacking thanks to his recent paperwork surge. They asked me to include a cover letter describing this with information. I will also be asking my wood supplier for copies of his CITES permits (assuming that he gets these) that could be included with mine, for future updates or the current application. The FWS will want updates on wood inventories as these change - the frequency depending upon how often and how much. I suspect for a large firm such as Martin Guitars etc. they will want more frequent updates whereas for us individual makers they may simply want this info when we renew our permits, so that they aren’t swamped with unnecessary paperwork. Again that will be determined on a case by case basis. I mentioned to the FWS agent that all of the Blackwood that I am using will be pre-CITES for the rest of my career. Its best if the Blackwood ages about 20 years and all of the wood I am getting from my wood supplier is stuff the Clarinet Industry rejected and sold him via Scott Nagel about 20 or more years ago. The clarinet bodies that I am repurposing into Folk Flute bodies were all turned to that form in 1999 from wood harvested in 1979 and earlier!
The makers in other countries especially the EU have more stringent permitting and documentation requirements. For us in the US things are relatively simple. I hope you find this info useful. Please share it with other makers. And if you have information that otherwise is different than what I have been told, please let me know and I will send out an updated info sheet.
Cheers!
Casey
PS: Its been really cold here and my radiant floor just doesn’t heat the house enough. So I have been having a lovely fire every morning using 1 to 2 gallons of cut off ends, reject pieces and rejected flute parts made primarily from African Blackwood. The stuff burns like coal in my old Oak potbelly stove!