CITES Annotation #10:  All parts and derivatives, except finished musical instruments, finished musical instrument accessories and finished musical instrument parts for non-commercial trade only for the purpose of paid and unpaid performance, personal use, display, loan, competition, teaching, appraisal, or repair, provided that this does not change the ownership and that such transport is not for sale, transfer or disposal of the specimen outside of the owner’s usual State of residence. Zero quota for wild-harvested specimens (source code W) traded for commercial purposes. 

The amended Annotation #10 entered into force on March 5, 2026. As of that date, all shipments of pernambuco (Paubrasilia echinata), also called Brazilwood or pau-brasil, entering/exiting the United States must comply with the requirements of Annotation #10, even if they were exported or re-exported before that date.

The CITES Parties have agreed that pernambuco from wild sources may not be traded internationally. However, wild- sourced specimens that originated from trees harvested before the date the species was included in the CITES Appendices, September 13, 2007, may be traded internationally. As the sole native range country for the species, Brazil does not allow for the harvest or export of pernambuco from the wild. International trade in pernambuco wood harvested in Brazil since September 13, 2007, the date the species was included in the CITES Appendices, is not allowed. 

No, the CITES requirements apply to international trade.

The United States is actively engaging with other CITES Parties and stakeholders to provide information on the current requirements, including sharing information via a letter to relevant stakeholders and participating in meetings, webinars, and other events hosted by organizations including the International Wood Products Association, the League of American Orchestras, and the National Association of Music Merchants. The U.S. Fish and Wildlife Service welcomes feedback from musicians and the musical instrument sector on other opportunities to share information. Please direct your feedback via email to managementauthority@fws.gov.

Some countries enact stricter domestic measures than those required under CITES.  This may include, for example, the requirement for an import permit for species included in Appendix II, which is not a requirement under CITES. Additionally, each country has its own procedures for verifying documentation upon arrival and departure. We strongly recommend individuals contact the relevant country’s CITES Management Authority to determine their CITES import and export requirements. 

Contact information for Management Authorities can be found on the CITES website.

A CITES re-export certificate authorizes the export of pernambuco wood or wood products when the pernambuco was harvested after its CITES listing date, September 13, 2007, and was last exported using a CITES document. To obtain a re-export certificate, the applicant must provide documentation demonstrating the lawful import of the specimen(s), including the validated foreign CITES export permit or re-export certificate with a USDA/APHIS or CBP declaration stamp. If the individual applying for a re-export certificate was not the importer of record, full chain of custody documentation is also required. To apply for a re-export certificate for pernambuco, use application form 3-200-32. For re-exports of items also containing CITES-listed animal species, use application form 3-200-73.

A CITES pre-Convention certificate authorizes the export of pernambuco wood or wood products made from pernambuco harvested before the species’ original CITES listing date, September 13, 2007, regardless of whether that specimen has been traded internationally since then. If pre-Convention specimens (e.g., wood, bow blanks, etc.) were originally imported under a CITES document, the original certificate number and date is included on the pre-Convention certificate. To apply for a pre-Convention certificate for wood, including finished bows/instruments, harvested before September 13, 2007, use application form 3-200-32. For exports that also include CITES pre-Convention animal species, use application form 3-200-23.

Pre-Convention certificates are one-time use certificates for export of materials harvested prior to the date the species was first included in the CITES Appendices. Pre-Convention certificates are valid for 6 months and are typically used for permanent moves, international commercial sales, etc.

To apply for a pre-Convention certificate for wood species only, use application form 3-200-32. To apply for a pre-Convention certificate for wildlife or wildlife and wood species, use application form 3-200-23.

CITES Musical Instrument Certificates (MICs) are passport-like certificates that may only be issued for pre-Convention materials, or materials made with species that were artificially propagated or bred in captivity. MICs are valid for up to 3 years and are kept with the permittee and validated by each country to which the instrument travels. 

Please note that some CITES Parties do not use or recognize MICs, so it is important to understand the requirements for each country to which you will travel with your instrument containing CITES-listed species.

To apply for an MIC, use application form 3-200-88.

CITES documents are not required for non-commercial international travel with pernambuco musical instruments or finished musical instrument parts and accessories. The CITES Parties have agreed that for the purposes of travel with musical instruments, “non-commercial” includes travel for paid performance or repairs as well as the other purposes outlined in Annotation #10. However, those instruments may not be sold or transferred during travel and must return to the individual’s country of usual residence.

If you plan to donate, gift or otherwise transfer ownership of the instrument while outside your country of usual residence, a CITES permit or certificate is required. For non-commercial travel with pernambuco items that are not finished musical instruments, finished musical instrument accessories, or finished musical instrument parts (e.g., wood, bow blanks, etc.), a CITES permit or certificate is required.

International commercial trade in articles made from pernambuco harvested from the wild, including the sale of pernambuco finished bows, is not permitted except under the following circumstances:

• The wood used in the manufacture of the musical instrument was harvested before September 13, 2007 (the date on which the species was included in the CITES Appendices). In this case, a CITES pre-Convention certificate must be obtained before the instrument is shipped or otherwise taken out of the country.
• The wood was derived from a tree grown in a plantation and is therefore not considered wild sourced. In this case, commercial trade will require a CITES permit or certificate that is issued with a source code that is not “W.”

Pre-Convention certificates and export permits are only valid for a single use. If you have an unused CITES document that you wish to have  re-issued, you must return the original CITES permit or certificate to our office within 6 months of it having been issued. If any changes to your plans for trade or travel have been made, this information must be indicated in the renewal request. As of June 2026, the application processing fee for pre-Convention certificates is $75 each.

Musical Instrument Certificates (MICs) and Traveling Exhibition Certificates are valid for up to 3 years. To re-issue those certificates, the U.S. Fish and Wildlife Service requires the return of the original certificate with all validations confirming return of all items covered under the certificate to the United States. At this time, the application processing fee for MICs is $75.

Master files authorizing the issuance of multiple single use permits for stock material pre-authorized by the Management Authority may be renewed prior to their expiration. Typically, master files are valid from 1 to 3 years. At this time, establishing a master file is $200 and each permit requested from the established master file is $5 each.

If the transaction requires a CITES document, the CITES permit or certificate must be validated by the appropriate authority, often the Customs authority, of the country of export. That permit or certificate must also be presented for inspection and clearance upon entry to the United States to USDA/APHIS or CBP. If the bow also includes wildlife species components, it must be inspected by the U.S. Fish and Wildlife Service’s Office of Law Enforcement, which can inspect the bow for compliance with CITES requirements pertaining to both the plant and wildlife species.

If the person from whom you purchase the bow lives in the country where you purchased it, and you’re bringing it back to the United States in personally accompanying baggage and the bow is intended for personal use, the United States would consider the item exempt under the personal effects exemption and would not require a CITES document. The quantity being brought back under the personal effects exemption must be reasonably necessary or appropriate for the nature of your trip. However, some CITES Parties do not recognize personal effects exemptions at all and others consider any commercial transaction (i.e., sale/purchase) while an individual is outside their country of usual residence to disqualify the individual from the personal effects exemption. The U.S. Fish and Wildlife Service is aware of several countries, including Canada and the United Kingdom, that will require you to obtain a CITES document prior to returning to your country of usual residence with your bow purchased in their country. Please always check with the Management Authority of both the country where you’re purchasing the bow and your home country to confirm the requirements for trade.

As described above, under this scenario, the U.S. Fish and Wildlife Service would consider the international movement exempt from CITES requirements under the personal effects exemption, and the individual would not need to obtain an import/export license from the U.S. Fish and Wildlife Service or a Protected Plant Permit from USDA if the bow is being purchased for personal use. However, as noted above, it is the responsibility of the individual purchasing the bow to determine and comply with the requirements of the country where they are purchasing the bow.

Demonstrating that the travel is for non-commercial purposes will be determined based on any relevant documents or records presented, such as performance booking confirmation, etc., and a transparent and robust conversation between the musician and relevant enforcement personnel.

The CITES Parties have agreed that the acquisition date is the date on which the animal or plant, or in the case of parts or derivatives, the animal or plant from which they were taken, was known to be:

• removed from the wild; or
• born in captivity or artificially propagated in a controlled environment; or 
• if that date is unknown or cannot be proved, the date on which the specimen was acquired is considered the earliest provable date on which it was first possessed by any person.

There is not one type of documentation that an applicant must present to demonstrate pre-Convention status because there is a wide range of information an applicant could use to show that their specimen qualifies as pre-Convention. 

The U.S. Fish and Wildlife Service recognizes that exact purchase or import records may not be available and will accept a wide range of information that documents the pre-Convention status of a specimen. Where applicable, an applicant should state that the specimen is pre-Convention and document the origin to the best of their ability. If receipts or invoices are not available, applicants may provide other documents, such as appraisal documents, serial numbers that correlate with a manufacture or harvest date, photographs, catalogs, advertisements, or inventories that can attest to the origin of the specimen. Additionally, notarized statements may be one of several types of documentation an applicant could present to demonstrate pre-Convention status if no other information is available.

Authorization for international sale of existing stockpiles requires providing documentation that the wood in the stockpile was harvested before September 13, 2007.

Pernambuco wood originating from stockpiles lacking documentation of provenance may not be exported unless there is sufficient evidence that the wood was harvested prior to the CITES listing date.

The requirement for a third-party appraiser to document provenance stems from U.S. Fish and Wildlife Service guidance under Directors Order 210 for antique items under the Endangered Species Act (ESA) and is not a requirement for pre-Convention CITES material. Although obtaining a third-party appraisal of a bow is one option to verify the pre-Convention status of a bow, it is not the only way. The provision of a statement from a third-party qualified expert, such as those in professional trade organizations such as the American Federation of Violin and Bow Makers, could take the place of a more formal appraisal for pernambuco bows. The requirement under our federal regulations is that the applicant must present enough information to support the determination of the materials’ pre-Convention status. The U.S. Fish and Wildlife Service only requires sufficient information for us to determine if this issuance criterion is met.

Currently, registration of bows is not required and thus not a requirement for obtaining a CITES permit or certificate. In order to issue a CITES document for a finished bow made from pre-Convention wood, the U.S. Fish and Wildlife Service requires information on the date of manufacture, provenance (e.g., appraisal documents, catalogues, dated photographs), evidence of lawful acquisition (e.g., bill of sale or signed statement), and evidence of lawful import, when relevant. For the re-export of bows manufactured with wood harvested after the species was included in the CITES Appendices, we require evidence of lawful import (e.g., validated foreign CITES export permit with USDA/APHIS or CBP declaration stamp). Because Brazil has advised that it has not authorized the export of pernambuco from wild sources since the species was included in the CITES Appendices, it would be unlikely that our office could issue a CITES document for a bow manufactured with wood harvested after the species was included in the CITES Appendices, where the source code on the foreign CITES document is “W” (wild source).

While individuals or businesses that own finished bows do not need to prepare a notarized list of their bows, the U.S. Fish and Wildlife Service strongly encourages them to maintain records showing date of purchase, prior ownership, origin of the wood used in the bow, import/export information, etc.

While individuals or businesses consigning finished bows for someone else do not need to prepare a notarized list of their bows, the U.S. Fish and Wildlife Service strongly encourages them to maintain records showing the owner’s date of purchase, prior ownership, origin of the wood used in the bow, import/export information, etc.

Documents used to establish the pre-Convention status of your personal musical instrument(s) or other pernambuco inventory (such as receipts or appraisal documents) do not necessarily need to be renewed so long as there are no changes in the circumstances being attested to in those documents (e.g., the materials have not been modified) or there is no explicit expiration date on those documents.

Although the U.S. Fish and Wildlife Service is aware that some CITES Parties have worked with industry to develop stockpile registration systems, there are currently no mandatory requirements for registering stockpiles of pernambuco.  The U.S. Fish and Wildlife Service will engage with musical instrument makers/manufacturers and other stakeholders as discussions progress and more information becomes available.

This issue is still being discussed, and the U.S. Fish and Wildlife Service will engage with musical instrument makers/manufacturers and other stakeholders as more information becomes available and this work progresses.

The potential development of an internationally harmonized voluntary marking system is still being discussed, and the U.S. Fish and Wildlife Service will engage with musician instrument makers/manufacturers and other stakeholders as discussions progress and more information becomes available.

Stockpile registration is not a requirement of Annotation #10 but CITES Parties are urged to make improvements to stockpile registration and traceability systems in the CITES Decisions adopted at CoP20. The U.S. Fish and Wildlife Service is continuing to discuss internally how best to engage in that work and looks forward to working with other CITES Parties and the musician and musical instrument sectors to determine how best to implement those Decisions.

Currently, there are no mandatory stockpile registration requirements. Nevertheless, as good business practice, it is important to keep track of sales and purchases of wood stockpiles and maintain good records of such wood.