Nightmare on Spanish Cedar (cedrela odinata)
 

I have run into CITES problems with Spanish cedar (Cedrela ordinata). According to the CITES manual Spanish cedar is on appendix III and applies to logs, lumber, and veneer, Table 2-3 of the manual, says that articles are exempt. The new interpretation I am facing and trying to fight is that guitar is made of veneer, and so requires CITES. I have a shipment in LAX, that may be returned to Spain, because it lack CITES permits, which up till now were not required under my interpretation of articles being exempt.

Well at one point in time all the Spanish Cedar was made out of logs so there is no exceptions. Talk about stupidity.

My understanding is that a guitar is a finished product. Last time I talked with a rep, they defined a veneer as thin lumber under a certain thickness.

A guitar is not veneer regardless if veneer is used in its construction. It should not fall under Appendix 3 unless it’s just veneer being shipped.

Are you trying to import a finished guitar, or wood to make a guitar with?

Nightmare at LAX
 

I am importing finished guitars. I have spent the days looking at the regs, so under appendix II and III unless otherwise noted a species parts and the derivatives require cites, so under this interpretation rosewood species require CITES (and there is an annotation that says as much in Appendix II. Appendix III where Spanish cedar (cedrela odorata) is listed, annotation #5 reads this applies to logs, lumber, and veneer. Up till now the standard understanding is that as is shown in USDA manual on CITES table 2-3, page 35, if it is not a log, lumber, or veneer (categories of raw woods) then goods manufactured with it do not require CITES. At LAX, at least there interpretation is that guitars fall under the category of veneer, this is a novel, new interpretation, one that is not shared in the industry at least.

I can not find any language that defines places guitars under "veneers." My best guess is that they are generalizing this from the treatment of rosewoods, dalbergia species, where the annotation clearly includes guitars.

If I can't get a favorable interpretation of this, then my shipment will be returned to the maker. He will not be able to get CITES for them because he needs to present the raw wood first. Worse, I have guitars on order with several other makers who I must inform that they will need CITES in order to export their guitars.

NIGHTMARE: DHL's rep referred me to USFW who apparently they got this from, the person I spoke with in USFW LAX station seemed to know nothing about this, and be concerned only if the shipment contains mother of pearl, and they referred me to USDA at LAX who seemed to agree that CITES was required, but their expert biologist won't be back till Monday.

I desperately need help. If anyone knows who I can all at USDA or USFW and get a definitive opinion I would be greatly appreciative of your help, and I am only the first in a long line of importers who would be grateful.

James