No CITES permits needed for some Dalbergia rosewoods weighing 10 kg or less

I am pleased to report that CITES rules have be partially relaxed for all the Dalbergia species except Dalbergia nigra, because the CITES annotation, #15, has been changed.  “Finished products to a maximum weight of wood of the listed species of up to 10 kg per shipment” do not now require a CITES re-export or import permit.

The official notice says the following about the 10kg shipment limit:

"10 kg per shipment", the 10 kg limit should be interpreted as referring to the weight of the individual portions of each item in the shipment made of wood of the species concerned. In other words, the 10 kg limit is to be assessed against the weight of the individual portions of wood of Dalbergia/Guibourtia species contained in each item of the shipment, rather than against the total weight of the shipment.

This will have benefits for any members who wish to import or export items made from, or containing inlay or veneers made from, the following woods:

African blackwood

Blackwood

Bois de violette

Bombay blackwood

Cocobolo

Hongmu

Huanghuali

Kingwood

Princes wood

Rosetta wood

Tulipwood

and the species Guibourtia demeusei, Guibourtia pellegriniana, Guibourtia tessmannii. (i.e. bubinga wood). 

The change does not reflect a general exemption for other restricted species, but only applies to those woods.  Finished products to a maximum weight of wood of the listed species of up to 10 kg per shipment are exempted from the need to obtain a CITES permit.

As furniture-dealing members will know, some of these woods were used historically in the form of veneers.  The surface area of veneer that would weigh 10kg can amount to several square metres, often considerably more, and consequently many items of veneered kingwood or tulipwood furniture, as well as small objects made from these woods, will no longer require CITES certification.  However, items comprising more than 10kg of these woods will still need to obtain the appropriate CITES certificates for import and export purposes.

BADA has been attempting to get Defra to agree to an acceptable methodology whereby dealers in such items can calculate the weight of veneer, but Defra does not feel qualified to approve a means of calculating the weight.

In view of this BADA has prepared the table below as a guide to the weight of different thicknesses of veneer for some of the above woods. It must be emphasised that this is a guide only and members would need to perform their own computations and take their own measurements in relation to their items.

 

 

 

 

Veneer thickness:
0.6 mm

Veneer thickness:
0.8 mm

Veneer thickness:
1.0 mm

Common name

Scientific name

Density

Maximum weight allowed

Max surface area

Example dimensions

Max surface area

Example dimensions

Max surface area

Example dimensions

 

 

kg/m3

kg

m2

cm x cm

m2

cm x cm

m2

cm x cm

Bois de Rose

Dalbergia maritima

930

10.00

17.9

423

x

423

13.4

367

x

367

10.8

328

x

328

Cocobolo

Dalbergia
retusa

1,095

10.00

15.2

390

x

390

11.4

338

x

338

9.1

302

x

302

Kingwood

Dalbergia cearensis

1,200

10.00

13.9

373

x

373

10.4

323

x

323

8.3

289

x

289

Tulipwood

Dalbergia decipularis

970

10.00

17.2

415

x

415

12.9

359

x

359

10.3

321

x

321


To avoid problems in customs, members wishing to import or export items that incorporate such woods should ensure that items are accompanied by details of the weight of the wooden Dalbergia element.  In cases involving veneers of the above woods members would be advised to also explain their calculation of the estimated weight by providing a figure for the surface area that is covered by the veneer, as well as its thickness.  For example, a 0.8 mm kingwood veneer covering 9 square metres of the surface of a bureau would fall below the 10.4 square metre maximum in the table above. Such a veneer would weigh 9/10.4 x 10 kg = 8.6 kg. 

Each member with an object to be shipped will need to assess the object themselves and consider whether it will meet the new criteria for exemption. BADA cannot be held responsible for any reliance placed by members on the density figures used in the table, nor for any errors in the figures that have been calculated.  Importers or exporters are also strongly advised that they should check that the exporting or destination country’s CITES management authority understands that annotation #15 means that CITES paperwork may not be required for some shipments of Dalbergia.

If you or your shipper has any questions about this please do not hesitate to contact me.

A more formal summary of the CITES changes is shown below.  


Mark Dodgson

August 2020

 

Summary of Dalbergia CITES changes

This summary was compiled by cross-referencing EU regulation 2019/2117 with information contained in the reference book, Woods in British Furniture-Making 1400-1900 by Adam Bowett.

This summary should be treated as guidance only.  Members unsure whether a particular wood is covered by CITES and EU restrictions are advised to make their own enquiries before offering an object for sale or importing or exporting it.

Species (scientific name) Common name Density
(per wood-database.com)		 Annex Trade within UK & EU Import and re-export
           
NO CHANGE TO RULES FOR:          
Dalbergia nigra  Brasilian rosewood   Annex A Commercially allowed without a certificate provided item was made prior to 3 March 1947 ("worked antique exemption").
 
If worked after 3 March 1947 an Article 10 certificate is required.		 CITES permit required for imports and re-exports.
Pterocarpus erinaceus African rosewood,
Senegalese rosewood,
kosso		   Annex B Commercial sale is unrestricted for annex B species
(no need to to use "worked antique exemption").		 CITES permit required for imports and re-exports (regardless of weight and worked/unworked status)
           
CHANGES TO RULES FOR:          
All species of the family name Dalbergia spp with the exception of Dalbergia nigra (which is already restricted - see above). 
This therefore includes the following woods that are used in antique furniture:		     Annex B Commercial sale is unrestricted for annex B species
(no need to to use "worked antique exemption").		 CITES permit no longer required for imports and re-exports of finished products containing up to 10kg of the annex B species.

CITES permit still required for all other forms of the species, and for finished products in which the species weighs more than 10kg.
Dalbergia cearensis Kingwood,
princes wood,
bois de violette		 1,200 kg/m3
Dalbergia cultrata Blackwood 1,060kg/m3
Dalbergia cochinchinensis Siamese rosewood, Thai rosewood, Vietnamese rosewood, hongmu 1,035kg/m3
Dalbergia decipularis Tulipwood 970kg/m3
Dalbergia latifolia Blackwood,
black rosewood,
Indian rosewood,
Bombay blackwood,
rosewood,
rosetta wood,
sonokeling rosewood		 830kg/m3
Dalbergia maritima Bois de rose 930kg/m3
Dalbergia melanoxylon African blackwood 1,270kg/m3
Dalbergia odorifera Huanghuali 960kg/m3*
Dalbergia retusa Cocobolo 1,095kg/m3
Dalbergia sissoo Indian rosewood,
East Indian rosewood,
sonosissoo		 770kg/m3
Dalbergia spruceana Brazilian rosewood 1,085kg/m3
Dalbergia stevensonii Honduras rosewood,
kingwood?		 1,025kg/m3

*density taken as average from Institute of Physics article: Wei Liu et al 2019 IOP Conf. Ser.: Mater. Sci. Eng. 490 022005