Duke of Pearl - Posted - 08/29/2011:  13:18:42

Gibson’s prior Madagascar ebony and rosewood issue of the November, 2009 raid is one thing, but this new problem (August 24, 2011 raids on 4 locations) with Indian rosewood and ebony fingerboard blanks is another.  It seems that India has regulations banning wood exports of anything over 6mm thickness unless it’s been worked beyond simply “sawn wood” inside their country.  But it’s not possible to have India process fingerboard blanks any further into a slotted, shaped, inlaid and bound form, and the Indian Ministry of Trade is O.K. with that since the fingerboards aren’t raw lumber and actually have been worked on as far as reasonable.  But the U.S. government is insisting that not going all the way makes the blanks “sawn wood” and thus illegal to export according to Indian law even though Indian authorities are fine with fingerboard blanks!  Additionally, there’s been some understandable confusion with appropriate tariff code numbers; and also with having the boards drop-shipped from India to a broker and then a storage facility while being invoiced by LMII, especially since Gibson and not LMII are taking ultimate delivery.  It’s bureaucratic harassment and abusive enforcement by agencies with almost total power and less than total understanding of their own regs.

LMII has done everything possible to establish conformance with the law and provide all documents, paper trails, chain of custody evidence, etc.  But now they’re justifiably worried that big white trucks and heavily armed agents will show up unannounced at their address, a scenario they might not be able to survive.  Even though the U.S. instrument industry accounts for but 1% of wood use here, they seem to be getting disproportionately targeted no matter how much such harassment might endanger the industry’s survival or how many jobs could be lost.

If these charges hold up, then virtually all Indian ebony and rosewood fingerboard blanks used in the entire industry are illegal, and everyone’s wood inventories and instruments would be liable to seizure and harsh penalties.  In fact, the same would apply to all guitar woods over 6mm thick originating in India.  So, I’d imagine that all the big dogs are watching this very closely – as goes Gibson, so goes the whole industry.  The U.S. government is quickly making it increasingly difficult for small as well as large businesses to survive rampant over-regulation.

(Private message me your email address and will send attachments of the full search warrant affidavit and Gibson’s official press release response.)

What can we do to revise badly written and unworkable regulations, and stop increasingly abusive enforcement?  Let upcoming electoral candidates know there’s a very serious problem that’s quickly endangering a lot of domestic businesses and killing formerly healthy small international sales, as well as negatively impacting all musicians who travel out of the country.  If this could become a campaign issue which highlights some of the deeply flawed and over-regulated current federal policies and could gain public support, it’s possible to change things.

Much of the problem has nothing at all to do with material from protected plant and animal species, but more to do with bureaucratic and regulatory demands involving non-listed species and costs that are impossibly complicated and unnecessary.  In the case of genuine vintage and antique instruments (and many other non-instrument products) current enforcement practices are really nothing more than permission for federal agencies to vandalize and destroy priceless and irreplaceable objects, harass legitimate businesses, musicians, and collectors, and block many traditional exchanges between cultures.

To address a few points which seem to be causing confusion:

1) The issue isn’t at all about “sawed Indian ebony logs with paperwork identified as finger boards”.  It’s about fingerboard blanks, and whether or not they can be considered a product involving enough native labor to satisfy the export laws of India.  It’s also about a wrong (but closely related) tariff code being entered on only SOME of the paperwork.

2) What’s an acceptable product?  As the agent himself pointed out in Gibson’s search warrant affidavit, there’s a distinction between a “fingerboard” (an unfretted wood blank of rough size) and a “fretboard” (which is slotted and contains fret wire).  If so, then those are two different products, and as such it’s possible to have a fingerboard blank as distinguished from simply “sawn wood” – adding slots, wires, inlays, shaping and binding would make that blank into a related but different product.  In the same way, we offer flat shell blanks, veneers, Abalam® sheets, and strips made to specifications according to what their intended use is: as materials which may or may not be remanufactured/incorporated into other types of finished products such as inlays, guitars, jewelry, furniture, fishing lures, and so on.  Similarly, plywood is imported as a product unto itself without it needing to be in another and more final form such as furniture, boxes, or whatever.

To insist, as the U.S. agencies seem to be doing, that materials from India must be in their ultimate retail form is insane, especially in light of the Indian government not interpreting their own regs that way or insisting on such nonsense. 

3) Compelling U.S. citizens to obey foreign laws also isn’t the issue.  The Lacey Act assumes that other entities (both foreign and domestic) know best how to manage their respective plant and animal resources, and it attempts to honor those regulations whether they be tribal, regional, state, federal, or foreign.  Gibson’s ebony from India is being challenged on the basis of how our agencies interpret the laws of India, regardless of how India herself interprets them.

4) In applying for and accepting most federal permits (such as the USFWS Import/Export Permit), the document specifically states that by signing you have agreed to have authorities examine at any time they wish your premises, paperwork, and inventory.  So it’s not an issue of unreasonable search and seizure.

What's confusing is that in the search warrant affidavit Agent Rayfield goes to some length in distinguishing an unslotted "fretboard" from a slotted and fretted "fingerboard" (Para. 13) as found on a finished instrument, and later (para. 22) distinguishes HS 9209.92.00 as "finished parts of musical instruments".

He also mentions (Para. 13) that "importers and exporters have sometimes referred to the sawn pieces of wood intended to be manufactured into fretboards as 'fingerboards' or 'fingerboard blanks'".  But he contends that even though these may be informally referred to as "fingerboards" they're actually no more than "sawn wood" and being over 6mm in thickness are "sawn logs" (Para. 19 and 25) and thus a prohibited HS 4407 item (Para. 12).

So at issue is whether or not "fingerboards" exceeding 6mm are "finished parts for musical instruments" as would be allowed under HS 9209.92.00.  If not, the argument is that they're "sawn logs" and illegal. 

mtnpckr - Posted - 08/29/2011:  13:53:15

I wish I could comment on this, but certain moderators would just deem it political and hide my comment anyway.

gansen - Posted - 08/29/2011:  14:03:47

Facts have been long and hard coming in the happening. And I say "happening" as I don't think any charges have been pressed, to make it a case. In 2009 it may have been different but no charges resulted either. So in part this is an issue over "seizure", as in if you take something that belongs to someone else it is "seizure". No wait that is theft.
Perhaps if Gibson imported firearms made of Indian rosewood and then refurbished the stocks as fretboards there would be less of an issue. Or maybe we all need to be sitting on the lawn of the white house singing Woody G songs. Or if this is an issue over imports and taxes well are fore fathers taught us how to deal with that. It started with the Boston tea party and ended in a Revolution.

gansen - Posted - 08/29/2011:  14:17:16

Sorry, I guess this whole subject is "polictical".

peewee - Posted - 08/29/2011:  14:42:06

Well I personally don't understand why we on this forum cannot discuss issues like this without being Moderated.  I am not sure this subject is Political anyway.  As I see it we on this forum should be able to discuss Political / Legal issues that effect the banjo community.. Now discussing who's gonna be president or some such does not belong here in my opinion.

Roll Player - Posted - 08/29/2011:  14:57:43

Chuck, thanks for the excellent detailed factual presentation. It's clear that these regulations need some work, and it certainly looks like there's been some seriously over-zealous enforcement going on. I would think that a "sawn log" would be a lot less specific in its dimensions as compared to a fingerboard blank (or bridge blank, etc.) The distinction doesn't seem all that subtle to me, but then I'm not a Fish & Wildlife agent.

Roll Player - Posted - 08/29/2011:  15:15:19

quote:

---

Originally posted by MitchellB

This kind of puts a political slant on it.    ​I have deleted the link to a political site.   ​Jazzylynne 

---

Yeah, that sure does... and I think it's inappropriate here. I'm glad Chuck presented the details and let us draw our own conclusions. The fact that a regulation is inappropriately enforced is no more or less politically relevant than the failure to have or enforce regulations causing a banking collapse.

Moderator alert: this may be political content, and if so, feel free to remove it... I'm all for a democratic government creating and enforcing regulations for the good of all if they are clear, consistently enforced, and effective. This case shows just how difficult that can become, particularly if a few over-zealous bureaucrats lose sight of the purpose of the regulation. It also shows why we all need to pay attention to what government and all other powerful institutions are doing. If you think this is the only abuse of power going on (or that government is the only source of abuse of power) you are sadly mistaken.

Edited by - Lynne on 08/29/2011 16:40:13

rommy - Posted - 08/29/2011:  15:42:19

"This case shows just how difficult that can become, particularly if a few over-zealous bureaucrats lose sight of the purpose of the regulation. It also shows why we all need to pay attention to what government and all other powerful institutions are doing. If you think this is the only abuse of power going on (or that government is the only source of abuse of power) you are sadly mistaken"

Roll Player - I couldn't agree more.

Warren Yates - Posted - 08/29/2011:  15:52:57

Wow! That is a lot to take in all at one time. The storm can surly get a lot worst before it gets better. LMII like the rest of us will be working to find a way around the Laws of India. Frankly I am tired of India getting our phone jobs. There are woods that work well that are not from India that will work find. I am in the frame of mind that even our wood needs to be grown in the US. Walnut makes great instruments and who knows, dogwood might sound just as good as ebony for bridge tops. Personally I like Cocobolo for fingerboards. OK I have done started thinking now! Watch out!

Warren

Earls 5 - Posted - 08/29/2011:  16:44:01

Cocobolo is a naturally oily wood perfect for fingerboards, but routing the inlay cavities IS a little trickier.

uncle.fogey - Posted - 08/29/2011:  16:56:09

I'm reading this, I'm seeing a collective consciousness, and it makes me sad.

First thing I get is that is that there's a knee-jerk reaction to assume that any regulation hampering the trade of exotic hardwood  is being caused by the Obama adminstration in some attempt to hurt the musical instrument business. (?)

It's complicated - We should NOT ALLOW the decimation and extinction of various trees that have been historically been used for making musical instruments so that some guys down in Brazil and in India can get rich while they cut down the last tree.

You can (not so) easily pass a law that says you shouldn't kill elephants in order to get their tusks, but someone has to enforce it.  Ditto, rhinoceros horns, which are supposed to promote virility (do the Chinese need more people?) Ditto many other things. 

Just look at the deer hunting laws here in PA - they are written the way they are written because some AH is always going to try to get around them;  ranger - "you' don't have a hunting license".  AH -  "I'm not hunting"   Ranger  "then why are you out in the woods with a rifle?"  AH  - "I'm allowed to have a rifle - I'm just out walking with my rifle". so they write the regulations in such a way that if you are walking in the woods with a rifle during hunting season "you are hunting".  It's no wonder the laws are written so ridiculously - it's not the fault of the law, it's the fault of the people who will creatively disobey them - no matter what the regulation, someone will try to circumvent it.  My understanding of what goes on with poachers in places like Africa and India, makes our AH seem like a boy scout.  There's a lot of money to be made and these guys don't give a crap what they're doing and they are about as interested in assuring that pernambuco wood or elephants will endure into the future as the man in the moon.

Ask yourself what would happen if we could no longer get endangered woods to make banjos from?  Nothing - ABSOLUTELY NOTHING.  There are a bazillion kinds of legally obtainable woods out there that can be used to make a banjo fingerboard or a guitar back.

Get a life and learn how to make a banjo without enlisting the help of people who would kill you if they saw you out in the woods.

What's so bad about American wood?  This country is a virtual garden of Eden when it comes to lumber.

And stop blaming it on Obama . You ain't seen nothing yet.

Wing It - Posted - 08/29/2011:  17:05:59

I find it interesting that Martin Guitars gets it's wood from exactly the same sources as Gibson, yet, they have never been raided, however they did donate heavily to .....

Roll Player - Posted - 08/29/2011:  17:47:05

Good post Ken. Effective, intelligent regulation is hard. It may take a few tries to get it right, and it's not Obama's fault if a Fish & Wildlife agent gets a wild hair. Maybe the regulations about ebony and rosewood need work, but the answer is not doing away with regulations. Remember the banking crisis, everyone? Or you could read your history books and look at what led to the Great Depression of the 30's.

RBuddy - Posted - 08/29/2011:  17:49:55

The problem as I see it isn't necessarily political at all and probably shouldn't be addressed as such. I want the "good wood" to be sustainable as much as anybody, possibly much more than most, just cause I love nice wood. And that goes to pearl or abalone or whatever else. The serious problem seems to be having appropriate documentation for both new and vintage instruments - which can be a real big problem. Also, what are builders to do with their favorite wood stash that they may have spent a lifetime accumulating prior to regulations? I doubt most anyone can come up with a documented wood chain of custody. I hope they don't have to throw it in the wood stove to avoid prosecution. Sometimes poorly written regulations have the opposite effect as that desired.

haildixon - Posted - 08/29/2011:  18:26:29

WHACKAMOLE!

OK-4 - Posted - 08/29/2011:  18:30:25

In simple laymen's terms it is called "smuggling." We have had laws and regulations to prevent smuggling since the days of our founding fathers, who wrote the Constitution (among other reasons) to provide for a Federal Government that could regulate imports.

Back to banjos: Imports of banjos have been regulated forever. You need to pay customs duties on banjos, and shipments of banjos have always been subject to inspection (by customs officials, or "bureaucrats") and possible punitive action. There is nothing new about regulating trade.

Earls 5 - Posted - 08/29/2011:  19:05:01

Poor OR mis- management swings both ways it appears.Too much or too little - each has a draw back on ecology. Lines must be drawn wisely.
I once had a bumper sticker that read - " if you dont' like logging, try plastic toilet paper !" Certain woods just simply make better -
instrument fingerboards, but yes there are other choices. There is middle ground, where resources can be used without Raping the
land. Another bumper sticker reads - " Trees grow jobs". There is a season - turn,turn,turn.....

Julio B - Posted - 08/29/2011:  19:54:17

An excellent and informative post!  Thank you!

~Julio B

gansen - Posted - 08/29/2011:  20:10:54

First they outlaw moonshine, then marrying your cousin, and now banjo's, some call this progress. Just trying to lighten things up. Glad I've found a group who are pretty like minded as myself.

Duke of Pearl - Posted - 08/29/2011:  20:16:04

The wood in question is from sustainable sources which are tightly regulated by the Indian government, and not from endangered or protected forests. And it's not just governmental permission that's involved but approval from deep-ecology non-governmental organizations (NGO's) that have done intensive on-site investigations from the trees to the mills right on through the entire custodial chain of those who have anything to do with handling the woods. For instance, certification by the Forest Stewardship Council (FSC, at fsc.org), or the Environmental Investigation Agency (EIA, at eia-global.org and forestlegality.org). These various watch-dog groups are working tightly with the guitar industry (among others) to provide trustworthy documentation for legally and responsibly harvested materials, while making it as hard as possible for suspect suppliers to survive.

Sure, there are a lot of woods native to the U.S. (and Australia, and other places) from which instruments can be built, but they're not at all equivalent in terms of stability, gluability, workability, finishability, durability, or acoustics. And there's no good reason to work with either acoustically or esthetically inferior materials as long as environmentally friendly sources remain available and support needed jobs in suffering economies.

And regardless of what anyone may think about the current or past administrations, or any political party, these people and parties have almost nothing to do with most of these laws which have been around for decades or longer, and which suffer from being overly vague or self conflicting; or with government agencies which refuse to communicate with each other, or lack familiarity with their own regulations; or with individual agents who are eager to build a reputation; or with the psychology of people who hold tremendous power.

It's interesting that in the search warrant affidavit, the agent quotes India's regulations as requiring "finished" instrument parts even though those regs nowhere use the word "finished".

sideways - Posted - 08/29/2011:  20:58:03

So who said "sic 'em"?

mtnpckr - Posted - 08/29/2011:  21:18:42

Not to stir anything up, Uncle.fogey, but yours is the only reference to Obama or any other politician.

Don't confuse bureaucrats with politicians. Bureaucrats are not elected, they get their job and immediately start to build their empire so they can justify their existance and clamor for more and larger budgets, so they can continue to build their empire and on and on.

Yes, we need to protect certain species, be it plant, animal or whatever, but this is far beyond enforcing any law.

Roll Player - Posted - 08/29/2011:  22:13:26

Originally posted by MitchellB



....This kind of puts a political slant on it. ​  I have deleted the link to a political site. ​  Jazzylynne

Mtnpckr, the deleted link was what brought Obama into it. That's what Ken (uncle.fogey) was responding to. He didn't bring it up.

Bill Rogers - Posted - 08/29/2011:  23:43:39

Governmental bureaucracies, as any poly sci major can tell  you, are notoriously unresponsive to directions from their supposed (elected) bosses.  That's the nature of the beast and has been for centuries in this country and most others.  Because of that I doubt that there's any political direction going on here.

rexhunt - Posted - 08/30/2011:  04:27:07

quote:

---

Originally posted by Bill Rogers

Governmental bureaucracies, as any poly sci major can tell  you, are notoriously unresponsive to directions from their supposed (elected) bosses.  That's the nature of the beast and has been for centuries in this country and most others.  Because of that I doubt that there's any political direction going on here.

---

Bingo!!  It seems like a bunch of bureaucrats are simply trying to justify their existence which is what a good many bureaucrats do.  Once this gets to the courts and the higher level bureaucrats who are answerable to the pols all this nonsense will end.

Rex

Paul R - Posted - 08/30/2011:  05:14:49

quote:

---

Originally posted by Bill Rogers

Governmental bureaucracies, as any poly sci major can tell  you, are notoriously unresponsive to directions from their supposed (elected) bosses.  That's the nature of the beast and has been for centuries in this country and most others.

---

 And the British made a comedy series out of it.

Big Joe - Posted - 08/30/2011:  05:52:29

My wife has worked in International trade for 30 years and I have done a bunch of international shipping and sales as well. Over the years the regulations and way in which shipments are handled and documented has changed substantially. NAFTA certainly has not been any help in this process either. The government gives you certain codes that are supposed to be used for importing or exporting different goods, but it is not that easy to determine which code or category any particular item may go. If you use the wrong number you can create a real mess and that is extremely easy to do. It is not a matter of intent, but a matter of little clarity in what these codes are or which one is to be used for a particular item.

In addition, each item shipped has to be listed as to country of origin. It is a bit unclear if that is to each part or the entire finished product. Does one have to list each segment separately or ??? and getting help or direction from the government or shippers is nearly impossible. Fortunately, I have my wife to call on when needed, but these things change from time to time so what I may do today may not apply tomorrow.

Is the issue the woods, Indian law, governmental oversight, or the unclear rules and codes and ineffective application? Maybe a bit of each, but as has been noted, the application of these rules has been very short sighted and not equally applied to all in the industry. While it is not a political issue directly, the administration of these agencies is a result of the atmosphere politically for that agency. The unfortunate part is that the consumer will eventually pay for the legal costs involved to fight or clarify these issues for the instrument makers. The cost of banjos and guitars and mandolins will likely rise from the cost of defending and clarifying these issues and the instruments may suffer as alternatives may be sought. Some of those alternatives may be quite good, others maybe not so good.

These are difficult issues to grasp and the unequal application is certainly frustrating. I guess you kick the biggest kid on the block if you want to get noticed. The sad part is these raids, which have not produced any illegality to date as shown by the courts, have certainly frightened the entire industry and the police agencies certainly got a LOT more publicity than they would had they raided the supplier or a small builder. When the publicity settles, the lawyers will battle this and lots of money wasted. My prediction is that it will ultimately return to the way things have been with Indian wood imports. Maybe the paperwork will get a bit clearer and easier to understand. I hope so. I certainly have no idea what it all means when I have to fill it out, and neither do the agencies involved. That I know from experience.

Bart Veerman - Posted - 08/30/2011:  06:10:37

Hmmm, when I mail one of my bridges to someone in the U.S. from Canada, do I have to fill out this paperwork because there's a tiny piece of ebony on top the bridge?

lazyarcher - Posted - 08/30/2011:  06:20:41

quote:

---

Originally posted by Bart Veerman

Hmmm, when I mail one of my bridges to someone in the U.S. from Canada, do I have to fill out this paperwork because there's a tiny piece of ebony on top the bridge?

---

Bad Bart.

lazyarcher - Posted - 08/30/2011:  06:28:35

Forget India. I have access to 20 5' Rosewood logs that were used as ballast a ship on Lake Erie in the 30s. If you want fingerboards, theres enough rosewood there for about a bazillion, or about 1000 guitar backs and sides. You just have to smuggle them across the border. I just stick them down my pants.

Edited by - lazyarcher on 08/30/2011 06:30:31

Nymphadora - Posted - 08/30/2011:  07:50:46

   Obviously, we can use different woods but we don't want to, especially me. I had been using quite a bit of ebony and even more Macasser ebony. I also have, surprisingly, a small collection of a creamy white substance that smells like teeth when you cut it. It came from a very very very large mammal, went through the jewelery trade, was confiscated by men in black, and then bought by me in a government auction. Go figure.....  But I don't feel good about restoring 100 year olde instruments with plastic or countertop scraps.

   Can we not grow rosewood and ebony here in the U.S. somewhere? Or Puerto Rico or Hawaii? Granted, it would take a while until we could use but it is time to look towards the future if raids are going to be happening.

   In the Pacific Northwest is the yew tree.....great if you shoot longbows like I do, because Pacific Yew makes sweet bows. It's expensive and difficult to just wander in and cut it down, I've been told. The drug companies make cancer drugs from the bark. I don't know what they do with the rest of the tree that bowyers build bows with, but they certainly don't give it to me. Perhaps it's time for companies to begin planting yew, mahogany, rosewood, and ebony somewhere in the U.S. and its territories so they can use the wood locally, or close to local, pay taxes instead of multiple tariffs and hoops to jump through. Climate has to be right somewhere here to grow these exotic woods, I should think.  Hugs.....  

Duke of Pearl - Posted - 08/30/2011:  08:10:40

"Hmmm, when I mail one of my bridges to someone in the U.S. from Canada, do I have to fill out this paperwork because there's a tiny piece of ebony on top the bridge? """"    "

Whether or not meant to be, that's actually a valid question.  Yes, it does need to be declared -- there's no "de minimis" exception, meaning it doesn't matter how large or small the shipment or value is, it needs to be declared.  A shipment which contains wildlife material or requires any type of species-specific permitting must go through a “formal clearance” procedure, regardless of its size or value (Q&A no. 9):

9. Is there a de minimis exception?  The statute does not provide for any de minimis exceptions, either to the substantive prohibitions or to the declaration requirement. 

Additionally, there is no “innocent owner exception” for border crossings that, however unintentionally, violate declaration requirements.  Full details about the procedures, definitions, restrictions, and allowances for importing and re-exporting woods can be found in the USDA/APHIS Cites I-II-III Timber Species Manual.  Section 1 is the Introduction, 2 is Importation, and 3 is Re-exportation. 

See 50 CFR part 23.13(d), part 23.15(d)(7) which explains the CITES requirements for traveling internationally with your personal or household effects that include CITES material.  These say that import/export documents aren’t needed unless an item or shipment contains CITES Appendix I materials; a guitar containing CITES I materials like Brazilian rosewood, tortoiseshell, or ivory must be accompanied by a species-specific export permit, such as a preconvention certificate 3-200-32 – but this only applies to the U.S. and doesn’t necessarily protect the owner in other countries.  For CITES II materials no permit is needed as long as all other personal exemption requirements are met (such as not involving any type of commercial activity). 

An excellent and recently updated piece by John Thomas regarding the impact of CITES on traveling musicians is in the online version of the Fall, 2008 Fretboard Journal. 

What must ALWAYS be avoided is getting involved with wildlife material which comes from endangered (“listed”) plants and animals and lacks a paper trail.  Genuine antiques might be O.K.; but materials or products of recent or undocumented origins, having falsified paperwork, or coming from unscrupulous dealers will eventually put both you others at risk.  It also defeats the original and legitimate purpose of these wildlife laws: to protect species which are dangerously close to extinction.  Establish a high ethic for your activities and then stick with it, and above all make sure you “know your dealer”! 

gansen - Posted - 08/30/2011:  08:11:22

I'm still a little confused. Is Indian rosewood a rare wood? I thought it boiled down to labor not material. I do however love the idea of reusing old timbers.

Duke of Pearl - Posted - 08/30/2011:  08:42:26

"But I don't feel good about restoring 100 year olde instruments with plastic or countertop scraps."

O.K., this introduces another legal issue which should really get everyone ticked off.  For materials and products made from antique or pre-Convention ESA-listed species, as soon as one of these items is substantially modified or used to make a new product, its exempt status instantly disappears. Unfortunately, even with legitimate documentation the age of the original item does not automatically carry over to the use of its material in another one.  Instead, the new article assumes the date of its recent remanufacture, thus now making it post-ban and illegal to sell or to import or export.  In fact, if an antique were to only be restored using either old or new patches of the same ESA-listed species, its legal age will be moved forward to the date of the new repair, with the same insane results.

This is the regulatory restriction which prevents guitar picks or pickguards being made from recycled antique tortoiseshell bracelets, combs, and boxes, no matter how old they might be.  The situation is entirely different for antique or pre-Convention Brazilian rosewood.  BW is listed in CITES Appendix I; but since it isn’t listed by ESA, pre-Convention items and materials can be freely modified, reworked, repaired, and repurposed without losing their antique or pre-ban status.

Here are the regulations establishing the above restrictions in using or remanufacturing older ESA-listed plant or animal materials (bold italics supplied):

Title 19 CFR 10.53 -- Antiques 

(e) Antique articles otherwise prohibited entry by the Endangered Species Act of 1973 (16 U.S.C. 1521, et seq.) may be entered if: (1) The article is composed in whole or in part of any endangered or threatened species listed in 50CFR 17.11 [animals] or 17.12 [plants], (2) the article is not less than 100 years of age, (3) The article has not been repaired or modified with any part of any such endangered or threatened species, on or after December 28, 1973, (4) The article is entered at a port designated in 12.26 of this chapter, (5) A Declaration for Importation or Exportation of Fish or Wildlife (ASFWS Form 3177) is filed at the time of entry with the port director who will forward the form to the U.S. Fish and Wildlife Service, and (6) The importer meets the requirements of paragraph (a) of this section.

Title 50, CFR 14.22 Certain antique articles.

Any person may import at any Customs Service port designated for such purpose, any article (other than scrimshaw, defined in 16 U.S.C 1539(f)(1)(B) and 50 CFR 217.12 as any art form that involves the etching or engraving of designs upon, or the carving of figures, patterns, or designs from, any bone or tooth of any marine mammal of the order Cetacea) that is at least 100 years old, is composed in whole or in part of any endangered or threatened species listed under §17.11 or §17.12 of this subchapter, and has not been repaired or modified with any part of any endangered or threatened species on or after December 28, 1973. 

minstrelmike - Posted - 08/30/2011:  08:53:25

the slashdot link to the article is titled:

first they came for the mandolins and I said nothing.

Frisco Fred - Posted - 08/30/2011:  10:14:04

Copied from a knife enthusiast forum.  Knife Rights

m

coelhoe - Posted - 08/30/2011:  10:39:08

I don't know why American builders don't use persimmon instead of ebony. It is essentially the same tree, just as hard but lighter in color, which can solved by using a dye.

Duke of Pearl - Posted - 08/30/2011:  11:07:54

persimmon: see ebony.

persimmon



Either of two trees of the genus Diospyros in the ebony family, and their globular, edible fruits. The native American persimmon (D.

..... Click the link for more informationAlthough American Persimmon is taxonomically a close cousin to true ebonies (all in the Ebenaceae family) , its typical weight  of 53 pounds per cubic foot  makes it about  makes it about  makes makes it about 16-17% less dense than ebony at 64 pounds, a not insignificant difference when attempting to control all the variables in an instrument.  As mentioned, its much paler color could be darkened by staining, but many modern luthiers are averse to using dyes on top-end guitars (for a number of reasons which are not just marketing concerns).  There's also no reason to switch from established and well liked traditional materials as long as legitimately managed and sustainable sources remain available.

Bart Veerman - Posted - 08/30/2011:  13:51:23

Thanks for all the info Ken, greatly appreciated.

JohnTheWhite - Posted - 08/30/2011:  15:58:44

In high-level trade negotiations, the Indians would like to be able to say, "We aren't enforcing copyright on music CD(s), because you are using Ebony fingerboards thicker than 6mm". This is why "our" government's reading of another country's regulations is often more strict than the regulations were originally stated.

Closer to home and in my opinion, the only Ebony worth having is Gabon African ebony as found in Egyptian tombs and prewar D-18(s). If someone is putting Indian Ebony on an instrument it's because of cost. Last I looked, Gabon ebony suitable for finger boards was about $75 per board foot; Indian Macassar, $52.00. In addition, Ebony does not contribute to a string instrument being exceptionally good-sounding. It looks good and feels good, but Rosewood sounds better. Gibson banjos have rosewood fingerboards, no apologies required, and Gretsch guitars have rosewood fingerboards that have been ebonized - dyed black - even Chet's.

Some people think they can tell the difference, (sounds better), between a Brazilian rosewood fingerboard and some other species that looks the same, (straight grained), in that application. It doesn't matter to me if it does. If it's an old guitar with Brazilian great; if it's a new instrument, I don't want to have anything to do with it. The species is becoming extinct, so I don't want it. The same goes for Ivory, Rhino horn, and parrot tongues.

Polle Flaunoe - Posted - 08/31/2011:  00:50:12

JohnTheWhite,

"Ebony does not contribute to a string instrument being exceptionally good-sounding"

Says who?

Here´s a quote from an article by George Gruhn:

"The late 1920s Ne Plus Ultra Silver Bell #6 is a fine example of Bacon's best work. In Latin "ne plus ultra" means "the ultimate." The Bacon & Day Ne Plus Ultra line offered some of the highest quality, as well as the most heavily ornamented banjos, ever produced by any maker. The banjo was noted for its especially great volume, as well as for its unusual depth of tone and its beautiful "singing" quality. The style 6 featured heavily engraved, gold-plated metal parts, elephant ivory inlay with extensive engraving, and carving on the back of the headstock. It also featured a Iion's-head carving at the heel of the neck.

The Ne Plus Ultra styles 6, 8, and 9 featured a neck, resonator, and shell made from ebony (Gaboon), instead of maple or holly. This produced a different sound, even though the metal parts on these banjos were of the same construction as those on the standard Silver Bell models."

Polle

Edited by - Polle Flaunoe on 08/31/2011 00:51:06

MrNatch3L - Posted - 08/31/2011:  01:10:39

OK, so if I were to buy this ca. 1926 Gibson Ball Bearing Mastertone Granada Pot With Repro. Neck from Zepp, and bring it over to Europe for a while, then come back to the U.S. with it sometime, what kind of **** would I be in for on account of "flamed maple neck has a "hearts and flowers" inlay pattern in its Brazilian rosewood fingerboard" ?  

If I understand all this stuff correctly, I would be required to declare to U.S. Customs that I am brining in the Brazilian rosewood, and I would have to have federally compliant documentation on the origin and source of Brazilian rosewood proving that it is of legal age and origin, and if I fail to declare, or I don't have the documentation in perfect order, the feds could confiscate the entire banjo and I'd be out over $5K USD.

(Of course, obtaining such documentation is virtually, if not totally impossible on such an instrument, isn't it? Catch-22. Caveat emptor. )

Or am I missing something? 

tonehead - Posted - 08/31/2011:  03:24:25

Does anyone know what is done with the confiscated wood?  

JohnTheWhite - Posted - 08/31/2011:  07:02:28

Polle wrote:
"JohnTheWhite [wrote] Ebony does not contribute to a string instrument being exceptionally good-sounding"

Says who?

Here´s a quote from an article by George Gruhn:
[... good stuff about Ne Plus deleted ...]
The Ne Plus Ultra styles 6, 8, and 9 featured a neck, resonator, and shell made from ebony (Gaboon), instead of maple or holly. This produced a different sound, even though the metal parts on these banjos were of the same construction as those on the standard Silver Bell models."
[...end of Pole quote...]

I agree that if an instrument's neck is made from Ebony the best sounding fingerboard would be Ebony. The problem in most applications is that the velocity of sound is so different between Ebony and Mahogany, for instance, that the interface causes reflections. Also, the sound that traveled in the fret board will arrive slightly later than that which traveled through the neck. This is called dispersion.

The following is a quote from Dana Bourgeois, (pantheonguitars.com/tonewoods.htm):
"Ebony, the traditional fingerboard material found on violins, classical guitars, and high-end steel strings, has the lowest velocity of sound of all the woods commonly used in lutherie and has definite damping characteristics. This may not prove to be much of a problem for large-bodied guitars made out of red spruce or Brazilian rosewood, but it may be something to consider when designing smaller guitars, particularly those using some of the less resonant woods for tops and backs."

Hotrodtruck - Posted - 08/31/2011:  07:32:09

Your papers please. Ve must check your papers!

Nymphadora - Posted - 08/31/2011:  08:32:01

What do they do with the confiscated wood..? Probably auction it off with the rest of the confiscated stuff like cars and airplanes and boats....and ivory..... I bought mine at a Fed auction in '75 or so. I've used it all up so maybe they have some more..... I would certainly like one of the ES-335's shown in the raid photo. I think I'll try inlaying with a superglue/heroin mix.... the penalties are only a slap on the wrist compared to pearl, rosewood and ebony. I'm afraid to do anything now. Oh, well.... at least here in Arizona our borders are now safe....  Hugs.....     

Duke of Pearl - Posted - 08/31/2011:  09:52:42

"...what kind of **** would I be in for on account of "flamed maple neck has a "hearts and flowers 'inlay pattern in its Brazilian rosewood fingerboard' ?"

That’s a deceptively simple question that has an unfortunately complicated answer!

To start with, whether traveling with or shipping any items (such as raw materials, parts, musical instruments, or antiques) which contain animal species listed in CITES Appendices I, II, or III, not just any U.S. border port can be used.  The ONLY ports of entry (POE’s) allowed to deal with wildlife shipments (of any sort, not just CITES related) that are commercial or require a species-specific permit are these 18: Anchorage, Atlanta, Baltimore, Boston, Chicago, Dallas-Fort Worth, Honolulu, Houston, Los Angeles, Louisville, Memphis, Miami, New Orleans, New York, Newark, Portland, San Francisco and Seattle.  You may need to change travel plans in order to clear through one of these ports.  If it can be shown that using an approved port would create a serious financial hardship, exception permits for using a non-approved port can be applied for (which can take substantial time to receive permission).  A FWS Q&A on this subject can be found here.

Non-commercial personal wildlife items or baggage and household effects which do not require permitting may be cleared at any port of entry.

An instrument containing CITES I materials like Brazilian rosewood, tortoiseshell, or ivory must be accompanied by a species-specific export permit, such as a preconvention certificate 3-200-32 – but this only applies to the U.S. and doesn’t necessarily protect the owner in other countries.  For CITES II materials no permit is needed as long as all other personal exemption requirements are met (such as not involving any type of commercial activity).

Now let’s deal with the banjo question, but we’ll set up a few different situations:

If it didn't have the shell inlay (a wildlife material) or the Brazilian rosewood (or any other CITES listed woods) you could simply clear it through customs as a "personal effect".  Even then, it would be wise to have with you a list of all the wood materials including the common and Latin (scientific) species names and their countries of origin.  Never volunteer the list but only whip it out if you get challenged about any of the woods.

If it didn't have the shell inlay, and since the instrument has a serial number that can be referenced against rough manufacturing dates which are pre-ban (June 11, 1992), the rosewood would require an FWS Form 3-200-32 which can be filed to get a Pre-Convention Certificate/species-specific permit.  The cost is $50.00-200.00 (depending on whether applying for a single shipment, personal property, or for setting up a “Master File” for multiple items).  Currently the approval process can take 3-6 months.  A recently published factsheet by the USFWS regarding musical instrument issues can be seen here. 

If it has the shell inlay but no Brazilian rosewood or other CITES listed wood, use USFWS Form 3-177.  Box 6 of this form requires a unique 3 character (alphabetic, numeric, or alphanumeric) Entry Filer Code as assigned by CBP to all licensed brokers or importers/exporters.  This code is then always used as the first three characters of a special 11 digit number which must be computed according to an extremely complex formula for each shipment.  CBP will assign this Entry Filer Code to professional brokers and large volume importers, but unfortunately for anyone else the “large volume” threshold is defined as at least 15 shipments per month with a minimum annual value of $1,000,000.00!  The only exception for smaller entities is if they already own a special Automated Broker Interface (ABI) software program used in electronic (internet) filings, one not available directly from Customs but through independent vendors and at a cost of approximately $50,000.00.  So, in order to be strictly legal and avoid possible confiscation and fines, a customs broker must be hired to complete the paperwork – including the mandatory $91.00 “Inspection Fee” this is going to cost about $200.00 each time the instrument leaves or reenters the country.

Additionally, when importing or exporting any wildlife materials (or products containing them) even in the tiniest amounts, it will be necessary to apply for an FWS permit (Form 3-200-3) or license in order to fill out the 3-177 form.  This will cost $100.00/year, even if you only need to use it once.

If it has both the shell inlay and the rosewood or other CITES listed wood, both the 3-200-32 and 3-177 forms will be necessary, as well as the 3-200-3 permit.

If it has even the tiniest bit of ivory such as a string/5thstring nut or bridge saddle, you’ll need the 3-200-3 USFWS Import/Export Permit and also a USFWS permit as below:

African elephant ivory removed from the wild after February 4, 1977, is not considered to be Pre-Convention (CITES); and worked African elephant ivory may only be re-exported for non-commercial purposes.  To re-export such items, submit USFWS Form 3-200-73.  You must state that it was acquired (removed from the wild or held in captivity or a controlled environment) before the date CITES applied to it.  Other listing dates can be found at the CITES website.  The cost is $75.00.  Raw ivory tusks may not be re-exported.  Mammoth and mastodon ivories can be freely traded without any permits.

Fines and penalties for non-compliance can be extremely severe ($100,000-500,000 and 1-5 years in jail) especially if it’s determined that violations were done “knowingly” and without exercising “due care” in researching applicable laws; punishment is reduced to forfeiture of goods and perhaps several hundred dollars in fines if it can be shown illegal activity was “unknowing” and that “due care” was reasonably attempted.  Lacey Act provisions and a flow chart of penalties and fines for non-compliance on plant products are summed up in an Environmental Investigation Agency document, The U.S. Lacey Act.  Penalties are the same for both animal and plant violations.

For full details on all these laws and how to deal with them, go to this recently posted article at the Guild of American Luthiers (GAL) site: luth.org/cites.htm.

“Flying under the radar” may have worked for decades, but with intensified governmental focus on stringed instruments, doing things the old way involves risks that can easily result in both the loss of an instrument, a business, and personal bankruptcy.  How lucky do you feel?  Welcome to the world of Big Government – if you don’t take a liking to it, think hard about who you’ll be voting for.

MrNatch3L - Posted - 08/31/2011:  10:31:30

quote:

---

Originally posted by Duke of Pearl

"...what kind of **** would I be in for on account of "flamed maple neck has a "hearts and flowers 'inlay pattern in its Brazilian rosewood fingerboard' ?"

 

That’s a deceptively simple question that has an unfortunately complicated answer!

To start with, whether traveling with or shipping any items (such as raw materials, parts, musical instruments, or antiques) which contain animal species listed in CITES Appendices I, II, or III, not just any U.S. border port can be used.  The ONLY ports of entry (POE’s) allowed to deal with wildlife shipments (of any sort, not just CITES related) that are commercial or require a species-specific permit are these 18: Anchorage, Atlanta, Baltimore, Boston, Chicago, Dallas-Fort Worth, Honolulu, Houston, Los Angeles, Louisville, Memphis, Miami, New Orleans, New York, Newark, Portland, San Francisco and Seattle.  You may need to change travel plans in order to clear through one of these ports.  If it can be shown that using an approved port would create a serious financial hardship, exception permits for using a non-approved port can be applied for (which can take substantial time to receive permission).  A FWS Q&A on this subject can be found here.

Non-commercial personal wildlife items or baggage and household effects which do not require permitting may be cleared at any port of entry.

An instrument containing CITES I materials like Brazilian rosewood, tortoiseshell, or ivory must be accompanied by a species-specific export permit, such as a preconvention certificate 3-200-32 – but this only applies to the U.S. and doesn’t necessarily protect the owner in other countries.  For CITES II materials no permit is needed as long as all other personal exemption requirements are met (such as not involving any type of commercial activity).

Now let’s deal with the banjo question, but we’ll set up a few different situations:

If it didn't have the shell inlay (a wildlife material) or the Brazilian rosewood (or any other CITES listed woods) you could simply clear it through customs as a "personal effect".  Even then, it would be wise to have with you a list of all the wood materials including the common and Latin (scientific) species names and their countries of origin.  Never volunteer the list but only whip it out if you get challenged about any of the woods.

If it didn't have the shell inlay, and since the instrument has a serial number that can be referenced against rough manufacturing dates which are pre-ban (June 11, 1992), the rosewood would require an FWS Form 3-200-32 which can be filed to get a Pre-Convention Certificate/species-specific permit.  The cost is $50.00-200.00 (depending on whether applying for a single shipment, personal property, or for setting up a “Master File” for multiple items).  Currently the approval process can take 3-6 months.  A recently published factsheet by the USFWS regarding musical instrument issues can be seen here. 

If it has the shell inlay but no Brazilian rosewood or other CITES listed wood, use USFWS Form 3-177.  Box 6 of this form requires a unique 3 character (alphabetic, numeric, or alphanumeric) Entry Filer Code as assigned by CBP to all licensed brokers or importers/exporters.  This code is then always used as the first three characters of a special 11 digit number which must be computed according to an extremely complex formula for each shipment.  CBP will assign this Entry Filer Code to professional brokers and large volume importers, but unfortunately for anyone else the “large volume” threshold is defined as at least 15 shipments per month with a minimum annual value of $1,000,000.00!  The only exception for smaller entities is if they already own a special Automated Broker Interface (ABI) software program used in electronic (internet) filings, one not available directly from Customs but through independent vendors and at a cost of approximately $50,000.00.  So, in order to be strictly legal and avoid possible confiscation and fines, a customs broker must be hired to complete the paperwork – including the mandatory $91.00 “Inspection Fee” this is going to cost about $200.00 each time the instrument leaves or reenters the country.

Additionally, when importing or exporting any wildlife materials (or products containing them) even in the tiniest amounts, it will be necessary to apply for an FWS permit (Form 3-200-3) or license in order to fill out the 3-177 form.  This will cost $100.00/year, even if you only need to use it once.

If it has both the shell inlay and the rosewood or other CITES listed wood, both the 3-200-32 and 3-177 forms will be necessary, as well as the 3-200-3 permit.

If it has even the tiniest bit of ivory such as a string/5thstring nut or bridge saddle, you’ll need the 3-200-3 USFWS Import/Export Permit and also a USFWS permit as below:

African elephant ivory removed from the wild after February 4, 1977, is not considered to be Pre-Convention (CITES); and worked African elephant ivory may only be re-exported for non-commercial purposes.  To re-export such items, submit USFWS Form 3-200-73.  You must state that it was acquired (removed from the wild or held in captivity or a controlled environment) before the date CITES applied to it.  Other listing dates can be found at the CITES website.  The cost is $75.00.  Raw ivory tusks may not be re-exported.  Mammoth and mastodon ivories can be freely traded without any permits.

Fines and penalties for non-compliance can be extremely severe ($100,000-500,000 and 1-5 years in jail) especially if it’s determined that violations were done “knowingly” and without exercising “due care” in researching applicable laws; punishment is reduced to forfeiture of goods and perhaps several hundred dollars in fines if it can be shown illegal activity was “unknowing” and that “due care” was reasonably attempted.  Lacey Act provisions and a flow chart of penalties and fines for non-compliance on plant products are summed up in an Environmental Investigation Agency document, The U.S. Lacey Act.  Penalties are the same for both animal and plant violations.

For full details on all these laws and how to deal with them, go to this recently posted article at the Guild of American Luthiers (GAL) site: luth.org/cites.htm.

“Flying under the radar” may have worked for decades, but with intensified governmental focus on stringed instruments, doing things the old way involves risks that can easily result in both the loss of an instrument, a business, and personal bankruptcy.  How lucky do you feel?  Welcome to the world of Big Government – if you don’t take a liking to it, think hard about who you’ll be voting for.

 

 

 

---

Either that's completely insane or I am. Bring on the straightjacket. Due to the level of restraint exercised to keep from going on and blasting the forum rules to smithereens and getting this topic or myself locked, I shall now proceed to knock back a stiff vodka. But thank you for taking your time to spell all this out. I appreciate your efforts and ability to deal with excruciating detail.

mtnpckr - Posted - 08/31/2011:  16:36:38

quote:

---

Originally posted by MrNatch3L

quote:

---

Originally posted by Duke of Pearl

"...what kind of **** would I be in for on account of "flamed maple neck has a "hearts and flowers 'inlay pattern in its Brazilian rosewood fingerboard' ?"

 

That’s a deceptively simple question that has an unfortunately complicated answer!

To start with, whether traveling with or shipping any items (such as raw materials, parts, musical instruments, or antiques) which contain animal species listed in CITES Appendices I, II, or III, not just any U.S. border port can be used.  The ONLY ports of entry (POE’s) allowed to deal with wildlife shipments (of any sort, not just CITES related) that are commercial or require a species-specific permit are these 18: Anchorage, Atlanta, Baltimore, Boston, Chicago, Dallas-Fort Worth, Honolulu, Houston, Los Angeles, Louisville, Memphis, Miami, New Orleans, New York, Newark, Portland, San Francisco and Seattle.  You may need to change travel plans in order to clear through one of these ports.  If it can be shown that using an approved port would create a serious financial hardship, exception permits for using a non-approved port can be applied for (which can take substantial time to receive permission).  A FWS Q&A on this subject can be found here.

Non-commercial personal wildlife items or baggage and household effects which do not require permitting may be cleared at any port of entry.

An instrument containing CITES I materials like Brazilian rosewood, tortoiseshell, or ivory must be accompanied by a species-specific export permit, such as a preconvention certificate 3-200-32 – but this only applies to the U.S. and doesn’t necessarily protect the owner in other countries.  For CITES II materials no permit is needed as long as all other personal exemption requirements are met (such as not involving any type of commercial activity).

Now let’s deal with the banjo question, but we’ll set up a few different situations:

If it didn't have the shell inlay (a wildlife material) or the Brazilian rosewood (or any other CITES listed woods) you could simply clear it through customs as a "personal effect".  Even then, it would be wise to have with you a list of all the wood materials including the common and Latin (scientific) species names and their countries of origin.  Never volunteer the list but only whip it out if you get challenged about any of the woods.

If it didn't have the shell inlay, and since the instrument has a serial number that can be referenced against rough manufacturing dates which are pre-ban (June 11, 1992), the rosewood would require an FWS Form 3-200-32 which can be filed to get a Pre-Convention Certificate/species-specific permit.  The cost is $50.00-200.00 (depending on whether applying for a single shipment, personal property, or for setting up a “Master File” for multiple items).  Currently the approval process can take 3-6 months.  A recently published factsheet by the USFWS regarding musical instrument issues can be seen here. 

If it has the shell inlay but no Brazilian rosewood or other CITES listed wood, use USFWS Form 3-177.  Box 6 of this form requires a unique 3 character (alphabetic, numeric, or alphanumeric) Entry Filer Code as assigned by CBP to all licensed brokers or importers/exporters.  This code is then always used as the first three characters of a special 11 digit number which must be computed according to an extremely complex formula for each shipment.  CBP will assign this Entry Filer Code to professional brokers and large volume importers, but unfortunately for anyone else the “large volume” threshold is defined as at least 15 shipments per month with a minimum annual value of $1,000,000.00!  The only exception for smaller entities is if they already own a special Automated Broker Interface (ABI) software program used in electronic (internet) filings, one not available directly from Customs but through independent vendors and at a cost of approximately $50,000.00.  So, in order to be strictly legal and avoid possible confiscation and fines, a customs broker must be hired to complete the paperwork – including the mandatory $91.00 “Inspection Fee” this is going to cost about $200.00 each time the instrument leaves or reenters the country.

Additionally, when importing or exporting any wildlife materials (or products containing them) even in the tiniest amounts, it will be necessary to apply for an FWS permit (Form 3-200-3) or license in order to fill out the 3-177 form.  This will cost $100.00/year, even if you only need to use it once.

If it has both the shell inlay and the rosewood or other CITES listed wood, both the 3-200-32 and 3-177 forms will be necessary, as well as the 3-200-3 permit.

If it has even the tiniest bit of ivory such as a string/5thstring nut or bridge saddle, you’ll need the 3-200-3 USFWS Import/Export Permit and also a USFWS permit as below:

African elephant ivory removed from the wild after February 4, 1977, is not considered to be Pre-Convention (CITES); and worked African elephant ivory may only be re-exported for non-commercial purposes.  To re-export such items, submit USFWS Form 3-200-73.  You must state that it was acquired (removed from the wild or held in captivity or a controlled environment) before the date CITES applied to it.  Other listing dates can be found at the CITES website.  The cost is $75.00.  Raw ivory tusks may not be re-exported.  Mammoth and mastodon ivories can be freely traded without any permits.

Fines and penalties for non-compliance can be extremely severe ($100,000-500,000 and 1-5 years in jail) especially if it’s determined that violations were done “knowingly” and without exercising “due care” in researching applicable laws; punishment is reduced to forfeiture of goods and perhaps several hundred dollars in fines if it can be shown illegal activity was “unknowing” and that “due care” was reasonably attempted.  Lacey Act provisions and a flow chart of penalties and fines for non-compliance on plant products are summed up in an Environmental Investigation Agency document, The U.S. Lacey Act.  Penalties are the same for both animal and plant violations.

For full details on all these laws and how to deal with them, go to this recently posted article at the Guild of American Luthiers (GAL) site: luth.org/cites.htm.

“Flying under the radar” may have worked for decades, but with intensified governmental focus on stringed instruments, doing things the old way involves risks that can easily result in both the loss of an instrument, a business, and personal bankruptcy.  How lucky do you feel?  Welcome to the world of Big Government – if you don’t take a liking to it, think hard about who you’ll be voting for.

 

 

 

---

Either that's completely insane or I am. Bring on the straightjacket. Due to the level of restraint exercised to keep from going on and blasting the forum rules to smithereens and getting this topic or myself locked, I shall now proceed to knock back a stiff vodka. But thank you for taking your time to spell all this out. I appreciate your efforts and ability to deal with excruciating detail.

---

 NOT an imported brand , I  hope!