US law exempts worked-ivory items under 200 grams and made before July 6, 2016 from its domestic ivory-sale ban (the de minimis exception)

Alongside the near-total US ban on commercial trade in African elephant ivory, US Fish & Wildlife Service guidance carves out a "de minimis" exception: an item may qualify for domestic sale when it contains a small, incidental amount of worked ivory — "less than 200 grams" — and was "manufactured or handcrafted before July 6, 2016." The exception turns on both a mass threshold and a manufacture-date cutoff; an item must clear both, not either. (Necessary, not sufficient: the same guidance further requires that the ivory be worked rather than raw, comprise less than 50% of the item by both value and volume, and fall inside an import/removal window — imported before January 18, 1990, or removed from the wild before February 26, 1976.)

The 200-gram figure is what makes the exception matter for musical instruments rather than for ivory as a decorative material: the ivory content of a typical instrument is a trace inlay or fitting, not a solid mass. A violin bow tip-plate, for example, averages on the order of a quarter of a gram — hundreds of times below the ceiling. So most instruments carrying incidental ivory fall inside the de minimis window by weight, with the pre-2016 manufacture date doing the real gatekeeping work.

This is the domestic sale counterpart to the international travel rule captured in the CITES musical-instrument certificate: the certificate governs crossing borders; the de minimis exception governs whether an item can be sold at home. The two run on different dates (border travel keys on pre-February-26-1976 acquisition; domestic sale keys on pre-July-6-2016 manufacture), a distinction easy to blur and worth keeping separate.

The threshold and both dates are Tier-1, quoted directly from fws.gov; the ~0.25 g bow-tip figure is a Tier-3 illustration, not load-bearing. This note is seedling pending an independent re-read of the fws.gov guidance (blocked at promotion time). Update 2026-07-10 (audit): the independent re-read landed — both quoted thresholds confirmed verbatim against fws.gov.