Comment from George Gruhn

We are aware that the comment period for new Lacey Act regulations ends Nov. 1, so time is of the essence. We urge you to exclude musical instruments from the Lacey Act for the following reasons: Compliance is impossible: When dealing used and antique musical instruments, furniture, and artifacts it is virtually impossible to determine the exact Latin name of each species or the country of harvest. For example, while we know which are the most commonly used species of pearl or mahogany for guitars, there is truly no way to look at a piece of pearl inlay or lacquered mahogany-like wood and to identify the exact species. Consequently, it is impossible to comply with new APHIS regulations that require a detailed declaration of materials. Not relevant to Lacey Act: While we strongly support wildlife preservation and the intent of the Lacey Act, we can not retroactively change the material content of used musical instruments, furniture and many other collectible items, which can last 200 years or more. The importation/exportation of these items carries no threat to wildlife and is thus not relevant to the intent of the Lacey Act. George Gruhn, proprietor Gruhn Guitars (dealing used and vintage guitars since 1970) Nashville, Tennessee