February 9th, 2021
Pearle* together with FIM and CSFI welcome proposed exemptions for musical instruments in draft EU ivory rules
Joint contribution to the public consultation on the draft revised guidance document on the EU regime governing trade in ivory, interpreting Commission regulation (EC) No 338/97 and Commission Regulation (EC) No 865/2006

9 Feb. 2021

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

We 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.

CSFI, FIM and Pearle are pleased to be given the opportunity to contribute to the consultation on the draft revised EU regime governing trade in ivory, which outlines exemptions for musical instruments containing small parts of ivory. We take this opportunity to recall that the sector is continuously looking for quality substitutes to ivory for instrument making and restoring.

We welcome the Commission’s decision regarding the preferential treatment of antique musical instruments as well as instruments containing legally acquired ivory in the draft EU ivory rules, which also includes the making and restoring of instruments containing small parts of worked ivory.

An exemption for the movement of musical instruments, covering both commercial and non-commercial travelling, is essential for musicians, orchestras and music groups, as it allows them to continue to use their instruments and accessories lawfully for live performances, displays and recordings.

As the Commission rightly points out in the text, “the value for any musical instrument is intrinsic and the fact that it contains ivory is secondary when determining the value. Additionally, trade in musical instruments has never been reported as contributing to current poaching or illegal trade in ivory.” We 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.

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.

To conclude, we believe that the exemptions for musical instruments proposed in the guidance document published on 28 January 2021 constitute an adequate response to the concerns of our sector. They will allow musicians, orchestras, ensembles and music groups, makers and restorers to work in a clear and lawful environment, thus contributing to the preservation and transmission of the European artistic and cultural heritage.

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Pearle* together with FIM and CSFI welcome proposed exemptions for musical instruments in draft EU ivory rules
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