Wednesday, December 9, 2009

New fish and wildlife/USDA requirements for wood imports.

  The 2008 farm bill amended the nations oldest environmental enforcement bill protecting endangered species. The new amendment now is trying to stop the trade of endangered trees. In doing so they are asking all importers of wooden items to report the genus, species and harvesting locations of every wooden thing imported into the US. They are also making it then a crime to declare falsely the species of wood being imported.
    It is unclear if the intention is to place a large burden on trade or just to add additional crimes to prosecute importers of endangered species. I believe the intention is solely the latter but that they succeed in accomplishing both. They are phasing in different wood products. April 1st 2010 will be the next phase in date that will incorporate many new products. Other products will also be incorporated. Below is the list of goods and their phase in date:

Phase II               April 1st 2009
HTS    Commodity
4401    Fuel Wood
4403    Hoopwood, Pole, Piles and Stakes
4406    Railway or Tramway Sleepers
4407    Wood Sawn or chipped
4408    Sheets for veneer
4409    Wood continuously shaped
4417    Tools, tool handles, broom handles
4418    Builder joinery and carpentry of wood

Phase III                  October 1st 2010
4402    Wood charcoal
4412    Plywood veneered panels (except 44129906 and 44129957)
4414    Wooden frames
4419    Tableware, Kitchenware
4420    Wood marquetry, caskets, statutes .

Phase IV    April 1st 2009
4421    Other articles of wood
6602    Umbrellas, Walking sticks, Riding crops.
8201    Hand tools
9201    Pianos
9202    Stringed instruments
9302    Revolver handles
9305    Pistols parts
940169    Seats, Chairs.
950420    Pool cues, and Billiard accessories.
9703    Wooded art work, and  Wooden sculptures

    We are sending this out now due to the additions coming up in April. Now would be the time to find out from your suppliers the particular species of wood they use and where they get it if from. We foresee this might take some time to find out where actually the wood was harvested from. For finished goods the wood is bought from lumber suppliers, who buy from saw mills, who buy from loggers, plus any number of distributors along the way.
    So we advise importers to begin finding this information out now. We will all have to brush up on our taxonomy. The government requires the scientific name and not familiar name. The USDA states over and over again that they will need both the genus and the species. They are aware that many times it is impossible to know the exact species in a genus. However, they expect importers to state all possible species that the item maybe made from.
    The USDA  states in cases where it is impossible to state the exact species it is not acceptable to state all possible species of the genus. The importer must state each individual species which the wood might possible belong to, based on harvest location, and species in that location. The importer must know and state all the possible species individually. So, the importer must state the genus and if there are multiple species that the wood was derived from each individual species that the wood may belong to.
    The declaration may be made on the forms provided by the USDA. The form is call the PPQ form 505. We are attaching the form for you to look at, or it can be found at the USDA web site: We also can file these forms electronically with the entries. But to file them for you we will need the above information. You may send it to us separately or on the invoices suppled by your supplier.
    Any false declaration will be punishable by criminal statutes and potential fines. The importer is responsible for any information supplied to the broker. There will be more products added to the list mentioned above. The final implantation of the full list is set to take place by August 31st 2010. It is likely that there will be a new list sometime between now and February and we will be keeping an eye out for. The full list of products will likely include as follows:

4405     Wood wool
4410     Particle board
4411     fiberboard
4412      Plywood including 44129906 and 44129957
4413     Densified wood
4415     Packing cases boxes crates and drums
4416     Casks Barrels vats tubs
4701     Mechanical wood pulp
4702    Chemical wood pulp, dissolving
4703    Chemical wood pulp, sulfate
4704     Chemical wood pulp, sulfite
4705    Combination chemical and mechanical wood pulp.
4801    Newsprint
4802    Uncoated writing paper
4803     Toilet or facial tissues
4805    Other uncoated paper
4806    Vegetable parchment
4807    Composite paper and board   
4808    Corrugated paper and board
4809    Carbon paper
4810    Coated paper and paper board
4811    Paper coated
6601        Umbrellas
6603        Umbrella parts
9205         Wind instruments
9401        All seats
990330    Wooden office furniture
940340    Wooden kitchen furniture
940350    Wooden bedroom furniture
940360    Other wooden furniture
940381    Furniture of, cane, osier, bamboo, rattan, or similar materials
9504        Articles for arcade, table, or parlor games. (Parlor???)

    As mentioned before we will can file this electronically, but we will need the information on the invoice or provided for us separately or in the form of the deceleration.  We will monitor the new products and let you know when we find out about them. It is important for imports of the new Phase IV products to begin getting the species, genus and harvest information as soon as possible. Or require your suppliers to begin putting the information on the invoices.