If you think of CITES woods, you probably first think of figured rosewood inlays in a guitar or a perhaps an ebony piano key. But do you often associate it with your flooring?
Certainly the musical instrument world is filled with CITES listed woods, but not many people in the regular timber trade have dealt with CITES-governed trade. Although some major commercial woods have been CITES listed in the past (Russian Oak springs to mind, as does Brazilian Mahogany and Spanish Cedar), very few listings have significantly impacted the flooring trade. That may change with the proposed new listing for Ipé.
Ipé, a South American hardwood, has long been a favorite flooring wood and a hugely popular decking wood. Prized for it’s durability and fire ratings both, Ipé was used for the original Coney Island boardwalk and still performs at Las Vegas’s Treasure Island and many other locations.
As a review CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) is an international treaty governing trade in endangered or potentially endangered plants and animals. Roughly 35,000 species of plants and animals are listed in one of three “Appendices.”
As buyers of wood products, the simple way to look at the Appendices is as three levels of risk and the corresponding control, and to remember that CITES is often both country and product specific.
- Appendix I is for species that are threatened with extinction. Generally no commercial trade is allowed for these listings.
- Appendix II covers species are species that are not necessarily threatened with extinction, but may become so unless trade is subject to strict regulation. Trade is strictly controlled with additional permitting that requires what is referred to as a Non-Detriment Finding.
- Appendix III are species that, while not necessarily threatened with extinction globally, are listed after one member country has asked for help in controlling trade. Trade in these species is only permitted with an appropriate export permit and a certificate of origin from the state of the member country who has listed the species.
As noted, CITES is often a country-specific listing. This can be a challenge for some species, like genuine mahogany, that grow in multiple countries. Always make sure you know the actual origin (required under Lacey, too, of course!) for your material.
CITES can also be a product-specific listing, so as an example, a listing might cover logs, but not flooring. In the case of Ipé, they are proposing the inclusion of Handroanthus spp., Tabebuia spp. and Roseodendron spp. (ie Ipé in commercial use) in Appendix II with Annotation #6 (logs, sawn wood, veneer sheets and plywood.)
There is currently debate as to whether “sawn wood” in this listing would include decking as CITES uses agreed upon definitions rather than specifying HTS codes. If decking is included, the impact on the market would be huge. Most decking companies aren’t set up to handle the increased administrative burden of CITES trade. However some trade in completed flooring is likely to continue.
More information on CITES generally can be found here:
- Info from the U.S. Fish & Wildlife Service on Traveling Across Borders with Musical Instruments
- Info from the U.S. Fish & Wildlife Service on Import and Export Permits
- Info from U.S. Customs & Border Patrol on Endangered species, CITES, endangered wildlife, plants, exotic skins and animals
And we’ll likely learn in June about the future of Ipé. Stay tuned. If you handle a lot of Ipé, you may wish to join the IWPA for information on the CITES process and an opportunity to have your thoughts heard on the issue.
Elizabeth Baldwin is Environmental Compliance Officer for Metropolitan Hardwood Floors. In her 25 plus year career in the wood industry has visited over 70 countries and hundreds of facilities of all sizes and types. She describes herself as a “jack of all wood trades.” Familiar with jungles of all sorts–having camped out along the Amazon and walked the halls of Congress–she blogs for the NWFA on both environmental and regulatory issues for educational and informational purposes only. Her blog is not intended and should not be construed as legal advice. Persons seeking legal advice on compliance with CARB, TSCA, the U.S. Lacey Act or any other law, regulation, or compliance requirement/claim should consult with the regulatory agency directly and/or a qualified legal professional.