Comment from George Gruhn

My greatest concern regarding proposed Lacey Act regulations is that all items imported into the USA must have written declaration of every plant and animal species, including the country of origin, Latin name of the species, and verification that it was not improperly harvested. It's tough enough to comply with the CITES regulations, but the proposed Lacey Act regulations are virtually impossible. I cannot look at a piece of lacquered wood or a piece of pearl inlay in a fingerboard and know the country of origin and Latin name of each species. Various species of mahogany and some other types of wood look virtually the same and pearl inlay in a fingerboard, especially white pearl, looks the same from one species to another if it is cut as inlay. I certainly can't tell the country of origin nor can I certify that was harvested properly on vintage and used items. I think the new regulations are virtually impossible to comply with even on new instruments. Musical instrument manufacturers buy wood and pearl from wholesale suppliers who do not always specify where the materials came from or the Latin name. While I support conservation efforts, it certainly seems that it is a misguided waste of effort to use the Lacey Act in this manner. It seems that the Lacey Act now is cropping up everywhere ranging from regulation of pets to musical instruments to furniture and absolutely any product that has plant or animal material, which means virtually anything that is not totally synthetic material would require Lacey Act declarations. Aside from the fact that it's virtually impossible to comply with these regulations, I can't imagine that the US government has enough staff to enforce this, nor would it make sense to try. I strongly support efforts to preserve living plants and animals which are endangered, but restrictions on vintage and used items create a bureaucratic nightmare for enforcement agencies while doing nothing to protect living species. George Gruhn Gruhn Guitars