What's Going On With Kolinsky Brushes?
By Tom Dix, President Global Art Materials
By now, most retailers have heard or become aware that importers and manufacturers are having difficulty importing kolinsky brushes into the U.S. Shipments have been halted and in some cases seized by the U.S. Fish and Wildlife Service. This began at least six months ago and is now causing a serious disruption in the supply of brushes that use pure kolinsky hair. NAMTA members that import these brushes have been working together to try and find a solution, but so far we have been unable to find a permanent fix.
Trade in kolinsky hair is managed by the provisions set out in the Convention on International Trade in Endangered Species (CITES). Kolinsky hair comes from the species called mustela siberica. It is important to know that this is NOT AN ENDANGERED SPECIES, but because of a seldom used provision in CITES, trade in kolinsky hair requires CITES documentation. This includes a country of origin certificate. Most of the kolinsky used by the brush producing countries in Europe originates in China.
The problem is that countries in the EU and the UK require a country of origin certificate for incoming shipments, but do not require that it be on a CITES form. U.S. importers have been using these same forms, provided to us by the European countries, for years and they have always been accepted by Fish and Wildlife. Suddenly and without notice Fish and Wildlife is insisting that the country of origin certificate accompanying U.S. incoming shipments be on a CITES form.
The European CITES authorities insist that the documents they provide conform to the CITES regulations, are complete and valid. Since U.S. authorities now want us to present a different form with the shipments than what is provided to us, they are asking importers to present a document that does not exist. This, of course, has become an impossible task. What was a question about a form has evolved into a policy dispute over the last 6 months between CITES management authorities in the U.S. and Europe, and our industry is caught squarely in the middle.
We have always supported the purpose of the CITES regulations, but do not understand how the position our Fish and Wildlife Service is taking today advances the cause or purpose of the CITES treaty. The rest of the world doesn't understand the position either and continues to freely trade in kolinsky brushes. At this point, it would be fair to say that Fish and Wildlife is not sympathetic to the financial harm to our industry or inconvenience to the artist consumer.
As an organization, NAMTA is working on our behalf to help find a solution and has asked for an urgent appointment with the head of the Fish and Wildlife Service to resolve this issue. We are hopeful that we will get a favorable reply in the next week. If we are unable to get the response we need to begin to fix this problem, the next step would be to come back to the NAMTA membership and ask for your support by contacting your congressmen, senators and members of the congressional subcommittee that has responsibility for oversight of the Fish and Wildlife Service.
This has been an extraordinarily frustrating experience for all of us involved. We appreciate your patience and will keep you informed of any progress we are able to make.
