18th December 2025
IBAMA have just published their interpretation of the COP20 decision on Paubrasilia echinata. The Google-translated version of the article says: It is worth remembering that materials legally acquired before September 13, 2007 are considered pre-convention and, therefore, are not under the control of CITES. For these cases, commercialization will be permitted provided it is accompanied by the pre-convention license issued by the administrative authority of each country.
It’s clear from other parts of the article that Brazil doesn’t fully understand how the CoP20 decision will be implemented – for instance, travelling musicians will not, in fact, have to show their bows at customs posts unless asked to do so. However, their statement about pre-convention bows confirms what we’ve been saying all along to the UK CITES Management Authority (and to anyone else who would listen) – Brazil is not interested in pre-convention bows and does not want to restrict their movement, use or sale. Brazil’s concern is about any wood which may have been illegally exported after 2007 when Paubrasilia echinata was first listed by CITES, and any bows which may have been made from that wood. Brazil first enacted domestic legislation on the harvest of native trees in 1992, but it is the 2007 date which is used by CITES.
Here’s hoping that CITES Management Authorities will start issuing Pre-Convention Certificates for use when a bow is moved across international borders for commercial purposes. These certificates document an item’s exemption from the need for Re-export or Import permits. They last for three years, can be used for multiple journeys, and do not have to be stamped at international borders (which is critical for the UK, as there is no facility to stamp permits when travelling on Eurostar). We have produced a briefing note for DEFRA outlining simplified procedures which could be used for issuing Pre-Convention Certificates for pernambuco bows.
Issuing Pre-Convention Certificates for qualifying bows would be a sensible and proportionate way forward, particularly for the UK, given the potential permitting burden of the large number of low-risk pre-convention bows which are sold every year by UK auction houses, shops and independent dealers.