The Ivory Page

These notes are for information and guidance only.  I have done my best to be accurate, but I cannot accept responsibilty: I am not qualified to give official advice.

UK Ivory Sales Act and Article 10

The position for the UK is quite clear.  The law states:

"From 6th June 2022 you will not able to deal in items containing or made from elephant ivory under the Ivory Act 2018 as exempt or certified exempt."

We were able to obtain an exemption for pre-1975 musical instruments containing less than 20% ivory (which covers practically everything except ivory flutes).  It is necessary to register them before offering for sale, selling, or buying.  The link to the registration process is below:

https://apply-deal-ivory.service.gov.uk/

The fee is £20, and registration is instant by return email. 

A recent conversation with APHA, who are responsible for registrations, confirms that the previously existing requirement for a CITES  Article 10 certification for post-1947 ivory keyboards remains in place, in addition to the requirement for registration. 

Application for CITES, including Article 10, is now on-line: 

https://www.gov.uk/guidance/apply-for-a-cites-permit

The cost of an Article 10 certificate is currently £31.

Sales through this website

All instruments from UK with ivory keys offered for sale on this website must be  registered in accordance with the Ivory Act, and I will ask for the registration code.

The exceptions to this are cases where we can be certain that the keys are not ivory, or instruments which are genuinely offered 'Free to Good Home' - the act applies to sales, not gifts.  

Please note that instruments with ivory keys (even if recycled) made in 1975 or later cannot be registered and therefore cannot be sold.  We must be able to prove that they were made before this.

In summary:  

Pre-1947 instruments: simple and quick.

1947 - 1974: more complicated, takes longer, more expensive.

1975 and later: sale illegal.

International Sales - A Guide to CITES 

Sales to any country outside Great Britain, and between any other countries (the EC is regarded as a common area) do of course require CITES Export/Import certificates for pianos with ivory keys. 

There is a fee - currently £37 in the UK.  Application is now on-line:

https://www.gov.uk/guidance/apply-for-a-cites-permit

Full guidance notes from APHA may be seen by clicking HERE

APHA aim to give clearance within 15 working days of receipt of the application.  

Please note that from a UK perspective, CITES approval is needed for transfer to the Jersey, Guernsey, and the Isle of Man - these are Crown Dependencies and not part of the United Kingdom nor of the European Community.  Also, by an anomaly, CITES is required for transfers between Great Britain and Northern Ireland - but not between Northern Ireland and The Republic.

I hope these notes are of some use, but please let me know if I can offer any more help.

*****************************

Ivory Sales in the European Union

 New Developments 2024 

This is now getting complicated, and I am sorry to say that I no longer feel able to offer any advice.  The background to the current situation is that the European Commission issued a Directive in 2021 (see below) the provisions of which are required to be enacted into law by all 27 member states. As of late 2024, it does seem that national authorites are taking action.

It seems that no changes have been made to the 2021 European Commission Directive, which may be seen below:

I hesitate to offer clarification, but I think it is fair to offer the following extracts:

We note two points in the second paragraph.  Firstly, authorities in at least three EU countries are requiring proof of the age.  For a dated piano, or a numbered one where reliable records exist this might be straightforward, but officials may not be familiar with square pianos, and there might be some 'discussion'.  Secondly, authorities in one case recorded so far have required proof of identity and competence of the 'performing artist'.  

The last box in the last column is significant, as it closes off the option of importing a restoration project simply as a pre-1947 antique - this option is available only for sales to museums.  

We are starting to hear of specific cases, including one where an instrument with Elforyn keys was challenged, so do please let me know of your own experiences, so that we can build up a picture of the situation.  It's getting difficult!