This is a reference containing the current Annotation #10, some explanation of its meaning, and previous versions. The current version, based on a decision at CoP20 and taking effect on 5th March 2026, is:
Annotation #10
All parts and derivatives, except finished musical instruments, finished musical instrument
accessories and finished musical instrument parts for non-commercial trade only for the
purpose of paid and unpaid performance, personal use, display, loan, competition, teaching,
appraisal, or repair, provided that this does not change the ownership and that such
transport is not for sale, transfer or disposal of the specimen outside of the owner’s usual
State of residence. Zero quota for wild-harvested specimens (source code W) traded for
commercial purposes.
Source: E-CoP20-Com-I-04
Unpacking Annotation #10
Annotation #10
An Annotation is a clause adding detail to a CITES Appendix II listing, which provides some flexibility in writing different rules that should apply to particular species. There is a different annotation (#15) for Rosewood species, for example.
All parts and derivatives, except…
The Appendix II listing and associated rules apply to all forms of this tree species, the language of ‘parts and derivatives’ is consistent with other CITES listings.
…except finished musical instruments, finished musical instrument
accessories and finished musical instrument parts for non-commercial trade….
The exemption from permit requirements applies to these specific products. Note the word ‘finished’, meaning raw wood is not included (and would require permits for movement across borders). In the case of Paubrasilia echinata, the relevant part is musical instrument accessories. The language here is used in other CITES Annotations to clarify that instruments, accessories and parts, so long as they are ‘finished’ products, are included.
…only for the purpose of paid and unpaid performance, personal use, display, loan, competition, teaching, appraisal, or repair, provided that this does not change the ownership
This is the list of permitted reasons for taking a product (a bow containing this species) across a border under the exemption from permit requirements outlined in this Annotation.
and that such transport is not for sale, transfer or disposal of the specimen outside of the owner’s usual State of residence.
This is new and explicitly states that movement across borders for the purpose of sale, transfer or disposal is not an purpose that is exempt from permit requirements.
Zero quota for wild-harvested specimens…traded for commercial purposes.
This is also new and explicitly states that absolutely no wild-harvested Paubrasilia echinata should be traded. The timing of harvesting is relevant, there is still wood available that was harvested before the species was listed (2007) and the zero quota is not referring to that wood, although a pre-CITES certificate would be required to move that wood across a border.
(source code W)
This small details leaves open the possibility of Paubrasilia echinata from plantation sources being traded, because that wood may have a different source code (such as A or Y).
Clarification (Canadian intervention)
During the final proceedings at CoP20, Canada as chair of the working group provided this clarification of the meaning of the new Annotation #10, as follows:
The last sentence in the annotation includes a zero-export quota for all trade in wild-
sourced specimens for commercial use.
This includes re-export, and applies to any specimens and stockpiles harvested after
February 2007 – when the species was first listed.
Stockpiles harvested after 2007 can still be traded and used domestically, and turned
into finished products, which can be transported internationally if they meet the
exemption requirements.
If it can be proven that this material is pre-convention (source code O), then both
commercial and non-commercial international trade is allowed with appropriate
permits.
Previous versions of Annotation #10
Prior to CoP19, Annotation #10 read:
Logs, sawn wood, veneer sheets, including unfinished wood articles used for the fabrication of bows for stringed musical instruments.
This effectively only regulated raw or semi-processed wood.
After CoP19, until the most recent change at CoP20, Annotation #10 read:
All parts, derivatives and finished products, except re-export of finished musical instruments, finished musical instrument accessories and finished musical instrument parts.
This expanded the scope to include finished products (bows) but maintained a full re-export exemption, re-export covering the vast majority of trade in bows.
