Statement to the European Commission
Stakeholders Meeting on CITES
on behalf of the International Association of Violin of Bow Makers (EILA) 15 July 2022
The International Association of Violin and Bow Makers (EILA) and its members from 25 countries around the world, including throughout Europe, strongly support Brazil’s call for conservation of paubrasilia echinata or pernambuco. We are joined in this statement by our partner organizations : the International Pernambuco Conservation Initiative (IPCI), the International Alliance of Violin and Bow Makers for Endangered Species, the Chambre Syndicale de la Facture Instrumentale (CSFI) – which counts among its members the two French associations of luthiers and bow makers : the Glaaf and the Aladfi -, the Confederation of European Music Industries (CAFIM), the International Federation of Musicians (FIM), and PEARLE* – Live Performance Europe.
Europe is the proud home of modern bow making and of much of the world’s stringed instrument music. Pernambuco bows are crucial to the precision, projection and tone of stringed instrument music. That is why they are used by the greatest living stringed instrument musicians of our day and virtually every professional player.
Our trade has been committed to saving pernambuco, which grows only in Brazil’s Atlantic Rainforest and has been under tremendous pressure from urban and agricultural development for several decades. In 2000, bow makers from France, Germany and the United States formed IPCI. Since that time, IPCI has invested in conserving pernambuco, planting over 250,000 seedlings in partnership with the Brazilian government, cacao farmers and Brazilian environmental NGOS, and supporting the work of leading scientific experts on the country’s national tree.
Bow making uses a relatively small quantity of pernambuco – one tree can provide a lifetime supply for each of the world’s artisanal bow makers. The illegal harvesting and trading of pernambuco, however, cannot ever be tolerated. We were heartbroken to learn of the results of Brazil’s recent investigation. We immediately contacted authorities to understand the nature of the criminal activity and what we, as a trade, can do to better educate our community, improve verification of legality, and contribute to halting illegal activities.
By the Brazilian government’s own implied admission, the efficiency of the legal regime governing conservation and protection of pernambuco remains below expectations. As Brazil’s CITES proposal acknowledges, the extent of natural populations of pernambuco is not understood and the National Program for the Conservation of Brazilwood “has not made significant progress in taking measures to protect the species”. Despite the species being on the national endangered species list for many years, and despite ongoing deforestation and evidence of the illegal trafficking by Brazilian bow makers, Brazil has had no domestic export permit requirement for finished bows. In the absence of strict domestic controls, the export of illegally harvested pernambuco in the form of bows has reached worrying levels. Buyers have been left to rely on paperwork presented by Brazilian traders and good faith representations. We agree that something must change and we are ready to participate in the change.
We have reviewed Brazil’s proposal to list paubrasilia echinata on Appendix I. We are currently seeking to follow up with CITES authorities to make sure we understand Brazil’s intention. At this stage, we believe that stricter domestic control on exports and CITES permit requirements under the existing Appendix II listing would suffice to reach Brazil’s legitimate objectives.
An Appendix I listing, by contrast, would trigger unintended consequences that are not fully acknowledged in Brazil’s proposal.
- Virtually all movement throughout the world of the many tens of thousands of pernambuco bows transported across borders by makers or used for performances by musicians worldwide, including all bows that were made decades if not centuries ago, would become subject to the issuance of permits and the credentialling of those permits by CITES management authorities at ports worldwide. This considerable additional burden on CITES and customs officials would jeopardize their ability to address permit requests and cross-border movements efficiently.
- Permits for commercial trade, essential to supplying musicians and making it possible for them to buy and sell the bows they need, would become virtually impossible to obtain.
- As a result, the entire world of stringed instrument music would be undermined. • In addition, the lifetime savings musicians and makers have invested in their bows would be severely diminished.
We believe a balanced policy solution is obtainable. We welcome dialogue with the European Commission, the Brazilian government, CITES delegations, environmental, cultural and all other stakeholders. It is essential that we address illegal trafficking and ensure the conservation of pernambuco, while also protecting the future of stringed instrument music.
We also fully endorse the statement being made today by our musical community colleagues regarding the importance of streamlining the Musical Instrument Certificate (MIC) process, measures that will be in everyone’s best interest.
This statement was read during the 15 July 2022 stakeholders meeting by Mrs Fanny Reyre Ménard, violin maker in France and member of the CSFI.
Coraline Baroux-Desvignes, déléguée générale Chambre syndicale de la facture instrumentale – CSFI 9, rue Saint-Martin – 75004 Paris
06 16 58 61 51 / firstname.lastname@example.org www.csfi-musique.fr
Signatories as of July 2022
International Association of Violin and Bow Makers. (EILA: Entente Internationale des Luthiers et Archetiers). Founded in 1950 in Europe, the Entente Internationale is an association of violin and bow makers from around the world. The Entente was established with the aim of bringing together master craftsmen on the basis of friendship and exchange and for taking any steps deemed pertinent to defending their working conditions, developing understanding of their art, perfecting teaching methods for their students and combining the strengths and talents of each member in order to promote a revival in the art of violin and bow making. www.eila.org
The International Initiative for the Conservation of Pernambuco (IPCI) is a group of bow makers created in 2000 whose objective is to find solutions to the scarcity of pernambuco wood. IPCI has planted approximately 250,000 pernambuco trees under scientific observation and perfectly adapted in the Brazilian states of Espirito Santo and Pernambuco. www.ipci-usa.org
International Alliance of Violin and Bow Makers for Endangered Species : The seeds of the Alliance go back to 2012 when the Entente and other professional organizations began to collaborate on conservation projects. Recognizing the severity of these challenges, in 2018 the International Alliance of Violin and Bow Makers for Endangered Species was created as an adjunct to the Entente, whose history, reputation, and international nature gave it a unique advantage in this role. Alliance members include instrument and bow making organizations, members of, and suppliers to, the trade, music performance organizations, and individuals. Alliance-USA
French Musical Instrument Organisation. French Musical Instrument Organisation (La Chambre Syndicale de la Facture Instrumentale, CSFI) was founded in 1890 in Paris. It gathers companies and craftsmen who make, distribute and export musical instruments and their accessories. The CSFI also welcomes resellers and other instrument makers associations (violin, guitar, piano). Its main objectives are the protection of its members and of the musical instrument making as a whole and the development of the instrumental practice for everybody. www.csfi-musique.fr
Confederation of European Music Industries. The Confederation of European Music Industries (CAFIM) used to gather European musical instrument manufacturers only. On May 5, 1977, as unification within Europe gradually progressed, the confederation came to cover the entire branch. Today CAFIM represents the music trade in the whole of Europe including wholesalers, retailers and importers. Its general objectives are to promote and safeguard the interests of the European musical instrument industry as well as those of practicing musicians in every conceivable way. www.cafim.org
International Federation of Musicians. The International Federation of Musicians (FIM), founded in 1948, is the only body representing musicians’ unions globally, with members in about 65 countries covering all regions of the world. FIM is recognised as an NGO by diverse international authorities such as WIPO (World Intellectual Property Organisation), UNESCO (United Nations Educational, Scientific and Cultural Organisation), the ILO (International Labour Office), the European Commission, the European Parliament or the Council of Europe. www.fim-musicians.org
PEARLE. Live Performance Europe, is the ‘Performing Arts Employers Associations League Europe’. Pearle* represents through its member associations the interests of more than 10000 organisations in the music, performing arts and live entertainment sector. This includes profit as well as non-profit organisations, ranging from micro-enterprises to organisations with over 250 employees. Pearle* is recognised by the European Commission as a European sectoral social partner, representing the employers in the European sectoral social dialogue committee live performance. www.pearle.ws