I was told on Monday that tomorrow the new modifications of CITES come into effect.  Cocobolo, Mad Rose and madagascan ebony are going in to appendix II.  While I think this is a good idea, I am not particularily happy with the implementation.  The CITES people in Granada want to see invoices for every piece that we have in order to be sure that we didn’t import it illegally.  Of course we didn’t import it illegally!  Someone else imported it and then we bought it legally (before we knew the situation in Madagascar).   So now if we don’t have the invoices they won’t register it and we won’t be able to use it on guitars that we plan to export.  I have never bought rosewood from Madagascar but I know that others have and may or may not have the invoice for it.  Spanish law says that you have to keep your tax returns and invoices for 5 years, even the new EUTR wood regulation says the same; now suddenly the CITES folk says we need to keep them forever.

I understand that legalizing elephant tusk or Brazillian Rosewood today would cause more people to go out and get these products illegally and then try to certify them but I do not see the same logic as applicable to new entries to CITES.  If we have the stuff today and it was not illegal when we bought it how can we have it illegally?  If we declare it before the cutoff date then we should be able to get it registered.  Once the ban comes into effect any new legalizations would be heavily scrutinized as they could conceivably encourage illegal imports.