Statement to the European Commission
cites collage

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. 

Thank you. 

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 / 

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. 

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. 

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.

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. 

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. 

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.