Moving a piano with ivory keys (US law)
December 20, 2021 1:39 PM Subscribe
I have an old piano with ivory keys. It needs some repair, but I'm planning to move across the country and that's looking complicated, so I don't know how much money I should put into it. Help me understand the laws and possible issues with hiring movers.
I don't have the receipt for the piano. I bought it in the 1980s, and the serial number puts its manufacture in the 1940s. I like this piano and would like to keep it, but I don't think I like it enough to have all the keys replaced.
The US Fish and Wildlife Service site refers to exemptions for moving ivory as part of a household move, but it keeps referring to "specific conditions" without spelling out what those are. I did not read the entire 33-page document - I searched "household." It does talk about demonstrating that the ivory was removed from the wild before 1976. Maybe that's the condition. Is the serial number enough to demonstrate that?
This blog writer reports that one moving company told her they will not ship pianos with ivory keys at all because of the hassle with inspections and liability. Obviously, it would be bad to find this out at the last minute.
Another piano website I can't find now said it's not legal to ship ivory across state lines at all, but maybe that person just misunderstood the law?
I don't have the receipt for the piano. I bought it in the 1980s, and the serial number puts its manufacture in the 1940s. I like this piano and would like to keep it, but I don't think I like it enough to have all the keys replaced.
The US Fish and Wildlife Service site refers to exemptions for moving ivory as part of a household move, but it keeps referring to "specific conditions" without spelling out what those are. I did not read the entire 33-page document - I searched "household." It does talk about demonstrating that the ivory was removed from the wild before 1976. Maybe that's the condition. Is the serial number enough to demonstrate that?
This blog writer reports that one moving company told her they will not ship pianos with ivory keys at all because of the hassle with inspections and liability. Obviously, it would be bad to find this out at the last minute.
Another piano website I can't find now said it's not legal to ship ivory across state lines at all, but maybe that person just misunderstood the law?
Best answer: Further down that USF&WS they state that 'Noncommercial use, including interstate and intrastate movement within the United States, of legally acquired ivory is allowed.'
This post from the Piano Technicians Guild has clarifications directly from USFG about moving and repairing ivory key pianos. They specifically detail out the exemptions as well:
"US Fish and Wildlife Service De Minimis Exception Requirements
To qualify for the de minimis exception, manufactured or handcrafted items must meet all of the following criteria:
If the item is located within the United States, the ivory was imported into the United States prior to January 18, 1990, or was imported into the United States under a Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) pre-Convention certificate with no limitation on its commercial use;
If the item is located outside the United States, the ivory was removed from the wild prior to February 26, 1976;
The ivory is a fixed or integral component or components of a larger manufactured or handcrafted item and is not in its current form the primary source of the value of the item, that is, the ivory does not account for more than 50 percent of the value of the item;
The ivory is not raw;
The manufactured or handcrafted item is not made wholly or primarily of ivory, that is, the ivory component or components do not account for more than 50 percent of the item by volume;
The total weight of the ivory component or components is less than 200 grams; and
The item was manufactured or handcrafted before the effective date of this rule.
Goldberg made the point that the USFW based the 200-gram figure on the approximate weight of a set of piano keytops. Throughout the ruling, the USFW goes to great lengths to point out that they don’t believe musical instruments are contributing to the poaching of elephants or the ivory trade."
posted by ApathyGirl at 2:02 PM on December 20, 2021 [7 favorites]
This post from the Piano Technicians Guild has clarifications directly from USFG about moving and repairing ivory key pianos. They specifically detail out the exemptions as well:
"US Fish and Wildlife Service De Minimis Exception Requirements
To qualify for the de minimis exception, manufactured or handcrafted items must meet all of the following criteria:
If the item is located within the United States, the ivory was imported into the United States prior to January 18, 1990, or was imported into the United States under a Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) pre-Convention certificate with no limitation on its commercial use;
If the item is located outside the United States, the ivory was removed from the wild prior to February 26, 1976;
The ivory is a fixed or integral component or components of a larger manufactured or handcrafted item and is not in its current form the primary source of the value of the item, that is, the ivory does not account for more than 50 percent of the value of the item;
The ivory is not raw;
The manufactured or handcrafted item is not made wholly or primarily of ivory, that is, the ivory component or components do not account for more than 50 percent of the item by volume;
The total weight of the ivory component or components is less than 200 grams; and
The item was manufactured or handcrafted before the effective date of this rule.
Goldberg made the point that the USFW based the 200-gram figure on the approximate weight of a set of piano keytops. Throughout the ruling, the USFW goes to great lengths to point out that they don’t believe musical instruments are contributing to the poaching of elephants or the ivory trade."
posted by ApathyGirl at 2:02 PM on December 20, 2021 [7 favorites]
Also, even though you do not have a purchase receipt, the piano can be dated by serial number, which would be applicable towards provenance as detailed here (on the PTG page above):
"In addition, the USFW also laid out some general principles for establishing provenance and meeting de minimis requirements saying, "Forensic testing is not necessarily required and provenance may be determined through a detailed history of the item, including a qualified appraisal or another method, including using information in catalogs, price lists, and other similar materials that document the age by establishing the origin of the item, can be used."
posted by ApathyGirl at 2:05 PM on December 20, 2021 [1 favorite]
"In addition, the USFW also laid out some general principles for establishing provenance and meeting de minimis requirements saying, "Forensic testing is not necessarily required and provenance may be determined through a detailed history of the item, including a qualified appraisal or another method, including using information in catalogs, price lists, and other similar materials that document the age by establishing the origin of the item, can be used."
posted by ApathyGirl at 2:05 PM on December 20, 2021 [1 favorite]
Best answer: Here are two articles discussing issues when the recent changes to ivory rules were proposed: #1. #2. She also links to the same q&a the Fish & Wildlife service does, which defines terms like "de minimus".
Also de minimus is defined here. Note that this applies only to interstate sale, import, and export of ivory, however. There is no restriction on simply owning ivory.
Finally, here is the Piano Technicians Guild summary of the issue.
There is nothing there that prohibits you from owning your own piano that includes ivory, or transporting it across state lines, or even selling it within a single state.
In fact you can sell a piano like yours across state lines - you can document the age of the ivory via the piano's serial number, and the 200-gram weight limit is specifically designed to accommodate the weight of ivory on the white keys of a regular 88-key piano. That qualifies it for an exemption.
There are two potential problems areas I can see coming up:
#1. Article #1 mentions "One piano-moving company has already told me that, to avoid the hassle of paperwork and inspections and the associated liability, it will no longer ship ivory-keyed pianos, even for private customers moving their household goods."
So the only way to know about this for sure is to mention your ivory-keyed piano to the company that is moving your items and see what they say.
#2. A few states have specific ivory laws and perhaps they will cause trouble.
It looks like New Jersey has a ban on sale of ivory within the state with few/no exceptions. But that still does not affect you owning a piano with ivory or moving your own piano. Other than that, states to look out for include New York, Washington, California, Oregon, and Hawaii. But as far as I can tell, none of those prohibit OWNING a piano with ivory keys. And for sales, they have exceptions for musical instruments.
TL;DR: Check with your moving company to be sure they are fine with it. Otherwise you are good to go.
Future sale and export are the main possible sticking points, with a minor possible sticking point being repair to the piano or particularly, to the ivory keytops, if you use an out-of-state repair service. For those eventualities, it is smart to be able to document the age of manufacture of your piano. Do something like print out manufacturer serial numbers corresponding to date of manufacture and keep that with the piano. Another way would be to get an appraisal of the piano and have the appraiser document/note the year of manufacture as part of the appraisal.
posted by flug at 2:38 PM on December 20, 2021 [2 favorites]
Also de minimus is defined here. Note that this applies only to interstate sale, import, and export of ivory, however. There is no restriction on simply owning ivory.
Finally, here is the Piano Technicians Guild summary of the issue.
There is nothing there that prohibits you from owning your own piano that includes ivory, or transporting it across state lines, or even selling it within a single state.
In fact you can sell a piano like yours across state lines - you can document the age of the ivory via the piano's serial number, and the 200-gram weight limit is specifically designed to accommodate the weight of ivory on the white keys of a regular 88-key piano. That qualifies it for an exemption.
There are two potential problems areas I can see coming up:
#1. Article #1 mentions "One piano-moving company has already told me that, to avoid the hassle of paperwork and inspections and the associated liability, it will no longer ship ivory-keyed pianos, even for private customers moving their household goods."
So the only way to know about this for sure is to mention your ivory-keyed piano to the company that is moving your items and see what they say.
#2. A few states have specific ivory laws and perhaps they will cause trouble.
It looks like New Jersey has a ban on sale of ivory within the state with few/no exceptions. But that still does not affect you owning a piano with ivory or moving your own piano. Other than that, states to look out for include New York, Washington, California, Oregon, and Hawaii. But as far as I can tell, none of those prohibit OWNING a piano with ivory keys. And for sales, they have exceptions for musical instruments.
TL;DR: Check with your moving company to be sure they are fine with it. Otherwise you are good to go.
Future sale and export are the main possible sticking points, with a minor possible sticking point being repair to the piano or particularly, to the ivory keytops, if you use an out-of-state repair service. For those eventualities, it is smart to be able to document the age of manufacture of your piano. Do something like print out manufacturer serial numbers corresponding to date of manufacture and keep that with the piano. Another way would be to get an appraisal of the piano and have the appraiser document/note the year of manufacture as part of the appraisal.
posted by flug at 2:38 PM on December 20, 2021 [2 favorites]
We have moved our 100+ year-old piano several times. Before I came along my wife's family moved it a bunch or times between at least four states. Nobody has ever inquired about the keys.
posted by bondcliff at 3:13 PM on December 20, 2021 [3 favorites]
posted by bondcliff at 3:13 PM on December 20, 2021 [3 favorites]
Last spring I hired a professional piano moving company to move our family's piano (built around 1864) from California to Oregon. No one at the piano moving company mentioned anything about restrictions on moving my piano across state lines due to the ivory veneers on the keys. They were much more concerned about the piano dimensions, the logistics of getting a concert grand in/out of the residences, and that I had proper insurance in case of a catastrophe in transit. It was incredibly expensive, by far the single biggest expense of any move I have ever done, but worth it given the condition of this particular piano and its unique history. I would not have gone to the trouble or expense if it had been my grandma's old upright. If you haven't yet gotten quotes from a few piano moving companies, that might be a good place to start so you can weigh the practicalities of bringing your piano along with you in the move.
posted by Lady Sugar Maple at 3:37 PM on December 20, 2021 [2 favorites]
posted by Lady Sugar Maple at 3:37 PM on December 20, 2021 [2 favorites]
I moved a 100+ year old Steinway Model M with ivory keys from Houston to the Steinway facility in Astoria for a refresh and thence to my Manhattan apartment. Never once did ivory even enter the conversation.
Most important advice: Don't talk to a regular moving company about this. You want specialist piano movers for this. They will take care of everything.
posted by slkinsey at 8:08 AM on December 21, 2021 [2 favorites]
Most important advice: Don't talk to a regular moving company about this. You want specialist piano movers for this. They will take care of everything.
posted by slkinsey at 8:08 AM on December 21, 2021 [2 favorites]
This thread is closed to new comments.
Is it legal for me to keep my elephant ivory?
Yes. Federal wildlife laws and regulations such as CITES, the ESA, and the AfECA do not prohibit possessing or display of ivory, provided it was lawfully acquired. There is no certification requirement or process to register ivory items and you do not need a permit from the Service to possess or display ivory for noncommercial purposes. We recommend that you maintain any records or documentation you have that demonstrates the origin and chain of ownership of the item. We recommend that you provide all documentation to any future recipient of your elephant ivory item. Check to make sure that you are also in compliance with local and state laws. Contact the state to check on their requirements.
posted by scolbath at 1:59 PM on December 20, 2021 [6 favorites]