John Bennett

International Alliance of Violin and Bow Makers for Endangered Species

December 14, 2022

Events leading to CITES action

• 2017/2018: IBAMA, Federal Police of Brazil and U.S. Fish & Wildlife investigations of illegal exportation of pernambuco wood and bow blanks
• 2021/2022: News stories in Brazil about searches, arrests and confiscations of illegal wood and bow blanks.
• June 2022: Brazil introduces CITES Prop 49 to list Paubrasilia echinate on Appendix I
• 2022-?:  Investigations continue inside and outside Brazil

July – November 2022

• Massive mobilization of trade and musicians organizations
• Presentations and meetings with EU, CITES and national authorities across Europe and North America, environmental organizations (WWF, WRI)
• Strategy meetings among music sector organizations
• Formal information document endorsed by 55 music sector organizations provided to LATAM CITES and all CITES Parties
• Alliance and IPCI developed:

• Submission to TRAFFIC 
• Pernambuco strategy 
• Comprehensive history of 20 years of action in Brazil

• French colleagues launched petition and open letter by musicians 
• Extensive media work, including with newspapers and Yo-Yo Ma video

Music sector representatives at CoP19

• Music sector representatives:
  • John Bennett, Alliance/EILA/IPCI-USA 
• EILA attending CITES meetings since 2013

• Thomas Gerbeth, IPCI-DE
• Heather Noonan, League of American Orchestras
• Fanny Reyre-Menard, CSFI
• Michael Jousserand, CAFIM
• Yuki Hori, Japanese Music Industry Association
• Pierre Guillaume
• Additionally: Professor Daniel Piotto, UFSB (IPCI partner)

Pre-CoP19 positions of CITES & key Parties

• Pre-COP: desire to help Brazil; skepticism towards Prop. 49

• CITES recommendation: REJECT (biological criteria, annotation)
• USA: opposed annotation; supported Appendix II with revised annotation
• Japan/Australia/UK: opposed Prop 49; supportive of music sector
• EU: not stated publicly

• Supportive of Brasil and music sector
• Possible support for Appendix I by some; opposition by others

CoP19 process

• Committee process: two committees (species & process proposals)
• Prop 49 vote in Committee I (species proposals)
• Concerns raised by USA, EU, Australia, Japan, UK
• No consensus – referred to working group
• Working group met twice
• US: supported proposal to revise Annotation #10 to require CITES permits for commercial trade in finished products and exempt noncommercial trade
• EU/UK/Australia/Japan supported EU alternative exempting finished bows from “re-export” permits
• EU argument: No permits for noncommercial trade will be a big loophole
• No Working Group consensus; last minute change in position by Brazil

Music sector position

• Organized side event on Day 1 – attended by EU, US, Japan, UK, Australia, Canada, Brazil
• Made interventions during debate on Prop 49
• Multiple side meetings
• 3 representatives in the Working Group formed to resolve Prop 49
• Raised concerns about:

• Permit burdens for CITES authorities
• No conservation value to impose permits everywhere and forever
• Devastating impacts on musicians and bow-making trade
• Support EU position and add incentives for conservation

CoP19 Decision (Brazil amendment to CoP19 Prop. 49)

• Transfer from Appendix II to Appendix I of Paubrasilia echinata in accordance with Resolution Conf. 9.24 (Rev. CoP17), Annex I, Paragraph A) i) habitat where the species occurs is reducing and v) the species is suffering selective logging and Paragraph B) iii) the species is suffering selective logging and iv) a decrease in the area and quality of habitat and in the number of individuals, and with the following annotation. 

CoP19 Decision, ctd.

“Maintain Paubrasilia echinata in Appendix II with the following annotation which would replace current Annotation #10: 

All parts, derivatives and finished products, except re-export of finished musical instruments, finished musical instrument accessories and finished musical instrument parts.”

Impact:

• CITES permits required when all forms of pernambuco (from wood to finished bows) first leaves Brazil as an “export
• All subsequent cross-border trade requires CITES permits EXCEPT if a finished musical instrument, musical instrument accessory or part

CoP19 Decision – included decisions

Directed to the Secretariat 

19.AA The Secretariat shall: 

a) issue a Notification to the Parties and relevant stakeholders requesting information on 

recent developments, national and international enforcement actions, illegal trade and 

marking of bows regarding Paubrasilia echinata, 

b) subject to external funding, in consultation with the plants committee and in association 

with expert stakeholders, evaluate options for the establishment of a traceability system 

to register the provenance of Paubrasilia echinata (pernambuco) bows produced, 

acquired, or transported by owners, musicians and manufacturers; and 

c) prepare a report on its findings on the implementation of paragraphs a) and b) supra 

and submit any resulting recommendations to the Standing Committee at its meeting. 

Directed to the Plants Committee 

19.BB The Plants Committee shall advise the Secretariat in the implementation of Decision 19.AA paragraph b). 

Directed to Parties, in particular source transit and destination Parties for Paubrasilia echinata 

19.CC Parties, and in particular source, transit and destination Parties for Paubrasilia echinata, are invited to: 

a) continue national enforcement efforts including investigations of illegal trade in Paubrasilia echinata and complement them with joint enforcement actions. 

b) consider the registration of stockpiles of Paubrasilia echinata as appropriate; 

c) offer support in capacity building to Brazil and other Parties as appropriate to improve the implementation of the listing of Paubrasilia echinata; 

d) provide information to the Secretariat, as requested in Decision 19.AA. 

Directed to governmental, inter-governmental and non-governmental organisations and other entities 

19.DD Governmental, intergovernmental, and non-governmental organizations and other entities, are invited to: 

a) support the implementation of the listing of Paubrasilia echinata, inter alia by: 

i) exploring ways to increase the traceability of finished bows, including for 

example, the development and implementation of a system of a unique 

individual marking and by sensitising producers and consumers (in particular 

musicians) of the status of the species, 

ii) work with Brazil to identify existing Paubrasilia echinata plantations within Brazil…to establish a sustainable supply chain; and, 

b) provide information to the Secretariat, as requested in Decision 19.AA.

Directed to the Standing Committee 

19.EE The Standing Committee shall: 

a) consider any report by the Secretariat resulting from the implementation of Decisions 19.AA, as well as any other relevant information brought to its attention regarding the implementation of the listing of Paubrasilia echinata in Appendix II; and, 

b) make recommendations for consideration of the Conference of the Parties at its 20th meeting, including recommendations relating to the development and implementation of a traceability system of Paubrasilia echinata specimens. 

Key conclusions

• Investigations will continue.
• The trade has an opportunity to avoid a new Appendix I proposal at CoP20.
• Actions needed:

• Partner with musicians and other music sector organizations
• Partner with new Brazilian government and local institutions in Brazil
• Educate trade and sector to strengthen legal compliance – as of February, look for CITES permits on Brazil shipments
• Increase support for conservation of pernambuco and science
• Support legalization of plantation stocks
• Begin process to develop consensus in support of a traceability and certification system
• Maintain communications with CITES authorities regarding possible registration of stocks