by Deb Shaw with A LOT of contributing authors. Please see the contributors’ list at the end of this article.
I’ll begin with two apologies: the first is for the length of this article. There is a lot of information and misinformation about the disappearance of Kolinsky brushes from art suppliers in the US. It’s a complicated subject, and I’m attempting to gather everything together in one place. The second apology is for the delay in posting this article. Each month I’ve heard rumors that the stockpiles of brushes being held in US Customs were about to be released, and so I’ve erroneously concluded it was a moot point to publish. We’re still waiting, so I’ll dive in.
Background, History, Rumors and Facts
Kolinsky brushes are made with the hair of the Siberian weasel, Mustela sibirica. Some internet information about Kolinsky brushes states that the best brushes are made only with the hairs from the tip of the tales of male weasels, gathered in winter. Some sources claim the hair is gathered from wild populations where the weasels are a pest; some say the hair is a by-product of the fur trade; others state the hair is collected only from humanely and sustainably farmed animals. There is also information that says the animals do not do well in captivity, so it’s impossible to “farm” them. All sources agree that Siberian weasels are not endangered: the International Union for Conservation of Nature (IUCN) classifies these animals as “least concern for extinction.”
Siberian Weasel (Mustela sibirica), Zoo Dresden, Winter 2002/2003, By Altaipanther (Own work) [Public domain], via Wikimedia Commons.
Barry MacKay described them on the GNSI ListServ: “These weasels weigh about 360 to 820 grams, with males, on average, larger than the ladies. That puts them bigger than most animals tagged with the name “weasel”, but smaller than our mink. They are a lovely soft brown in colour, with a blackish face mask and a touch of white near the tip of the muzzle.” In addition to his bird art, Barry works on animal trade issues, and has attended several Conferences of the Parties to CITES. His understanding is that Mustelids do not do well in captivity, due to their high metabolism, activity and home range sizes. Apparently, they have a lot of stress-related illnesses in captivity.
Weasel hair for brush manufacture typically comes from Russia, China, India and Japan. Mustela sibirica populations also are found in Bhutan, Korea, Nepal, Laos, Burma, Taiwan and Thailand. Once gathered, the hair is then made into brushes either in China or the country of origin, or is sent to Europe or the UK to be made into brushes there.
For us to be able to buy Kolinsky sable brushes in the United States, the appropriate paperwork is required for exporting the hair from the country of origin, and then “re-exporting” the brushes from the country of manufacture. The problems with our supplies of Kolinsky brushes started in 2012, when a US Fish and Wildlife Service inspector was requested to research paperwork and permits from Europe for “re-exporting” Kolinsky hair.
Research and interviews about the disappearance of Kolinsky brushes turned up a multitude of reasons, rumors and innuendos. I emailed the US Fish and Wildlife Service directly, and, much to my surprise, on February 14, 2014, received a reply from Craig Hoover, Chief, Wildlife Trade and Conservation Branch, Division of Management Authority. I’ll confess, I’m still impressed to have even received a response. I’ve edited Mr. Hoover’s reply slightly (for example, taking out my complaints about their website not working), but am posting his answers verbatim below:
Dear Ms. Shaw,
…We appreciate your inquiry and the concerns raised by the industry. We’ve had numerous consultations on this issue and are happy to share additional information with you. Please let me know if you have any additional questions.
Kolinsky hair brushes use hairs derived from the Siberian weasel (Mustela sibirica). This species was added to Appendix III of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) in 1989 by India. CITES, as you may know, is a treaty to prevent species from becoming endangered or extinct because of international trade. Under this treaty, countries work together to regulate the international trade of animal and plant species and ensure that this trade is not detrimental to the survival of wild populations. Appendix III includes species for which a particular country has sought help to regulate international trade.
Under the terms of the Treaty, and US regulations implementing CITES, any export of an Appendix-III species from a listing country (in this case, India) requires the issuance of a CITES Export Permit after a determination is made that the specimens in question were legally acquired. Exports from a non-listing country (such as China) require the issuance of a CITES Certificate of Origin essentially indicating that the specimens did not come from the listing country.
Under CITES, member countries have an opportunity to take a reservation to a listing, essentially meaning that the country chooses not to implement the listing. With regard to Mustela sibirica, 22 European countries have taken a reservation to the listing. Neither the United States nor China has taken such a reservation.
Much of the Kolinsky brush hairs are produced in and exported from China to Europe where they are then made into brushes. Because the importing countries in Europe have a reservation to the listing, they do not require a CITES document from China. However, because we require a CITES document for import into the United States, European exporters have obtained CITES re-export documents to send shipments to the United States. However, it came to our attention that the shipments going from China to Europe were not accompanied by CITES documents. We have confirmed with Chinese CITES officials that they require a CITES export document and were not approached to issue one. Therefore, because the shipments were exported from China to Europe in violation of CITES requirements, the subsequent re-export to the United States was also in violation of CITES requirements here.
We have explained this to our European CITES counterparts and advised the industry that specimens that are not lawfully exported from China will not be accepted in the United States. It is incumbent upon Chinese exporters to obtain the necessary CITES Certificate of Origin for export to Europe or directly to the United States.
[In answer to my question as to when or if we can expect the brushes to once again be imported into the United States]:
There is no prohibition on imports to the United States either from Europe or directly from China. However, if the brushes are made with Mustela sibirica hair, then the specimens must comply with all CITES requirements.
[In answer to my question as to whether or not it is legal for an individual artist to receive a gift of Kolinsky sable brushes from a fellow artist in Europe]:
If your question relates to whether someone can receive a gift of such brushes in Europe and then import them to the United States, I would refer you to our CITES regulations for personal and household effects, which are found at 50 CFR 23.15 and are found at:
(d) Personal effects. You do not need a CITES document to import, export, or re-export any legally acquired specimen of a CITES species to or from the United States if all of the following conditions are met:
(1) No live wildlife or plant (including eggs or non-exempt seeds) is included. (2) No specimen from an Appendix-I species is included, except for certain worked African elephant ivory as provided in paragraph (f) of this section. (3) The specimen and quantity of specimens are reasonably necessary or appropriate for the nature of your trip or stay and, if the type of specimen is one listed in paragraph (c)(3) of this section, the quantity does not exceed the quantity given in the table. (4) You own and possess the specimen for personal use, including any specimen intended as a personal gift. (5) You are either wearing the specimen as clothing or an accessory or taking it as part of your personal baggage, which is being carried by you or checked as baggage on the same plane, boat, vehicle, or train as you. (6) The specimen was not mailed or shipped separately.
[In answer to my request for information about whether these animals are farmed, are caught from the wild, and/or are in danger of extinction]: