October 28th, 2020
Joint Statement on the proposed revision of EU rules on ivory

We are speaking on behalf of musical instruments makers and restorers, orchestras, ensembles, music groups and musicians.

We are well aware of the current poaching crisis and support the initiative of the European Commission to adapt and harmonise EU legislation on ivory, to ban illegal cross-border trade in ivory and protect elephants. We agree with the Commission that this is a sensitive subject that needs to be urgently addressed.

We are grateful for the opportunity to exchange these past months on the issue of ivory.

We also welcome the preferential treatment of musical instruments in the draft EU ivory rules, including intra-Eu trade, as well as the making and restoring of instruments containing small parts of worked ivory. It is of particular interest that antique instruments containing pre-1947 ivory and complying with the “de minimis” rules also fall within the scope of specified rules for instruments. 

As the Commission rightly points out in the summary of the proposal, “there is no evidence or indications that musical instruments represent any significant risk of contributing to poaching or illegal ivory trade.” The amount of ivory used in musical instruments is very small indeed, therefore, additional restrictions would be neither proportionate nor helpful in combatting illegal ivory trade.

In this context, we would like to underline once more that the (very small amounts of) ivory used for musical instruments making and restoring is pre-Convention and that our sector is continuously looking for quality substitutes.

We also fully adhere to the assertion that the intrinsic value of a musical instrument is not related to the ivory that it contains, but to its craftsmanship as well as its artistic and cultural value.

To conclude, the exemptions for musical instruments proposed in the draft guidance of October 2020 – including the possible purchase of Pre-Convention raw ivory for restorations – constitute an adequate response to the concerns of our sector. They will allow musicians, makers and restorers to work in a clear and safe environment, thus contributing to the preservation and transmission of a unique European artistic and cultural heritage.



French Musical Instrument Organisation (La Chambre Syndicale de la Facture Instrumentale, CSFI) 


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The statement was presented at the stakeholder meeting on the newly proposed EU ivory rules, organised on Wednesday 28 October 2020 by the European Commission (DG Environment).


Download the statement

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