GHY Tradelines

(STR Trade Report)

With just a few more legislative days before lawmakers break to focus on their campaigns, there is little expectation that any trade-related measures will be taken up until after the November elections. Unless Congress approves the following bills during such a “lame duck” session, efforts to enact them will have to begin again next January.

PNTR for Russia

Repealing the Jackson-Vanik Amendment and extending permanent normal trade relations status to Russia is necessary to allow U.S. businesses to take advantage of the trade liberalization measures associated with Russia’s accession to the World Trade Organization, which became official Aug. 22. PNTR legislation was approved by the Senate Finance Committee July 18 and by the House Ways and Means Committee July 26, but despite widespread support from both lawmakers and the Obama administration neither chamber seems likely to vote on a PNTR bill before the upcoming recess.

Lacey Act

The Retailers and Entertainers Lacey Implementation and Enforcement Fairness (RELIEF) Act (H.R. 3210) was reported by the House Natural Resources Committee and placed on the House calendar. This bill would exempt any plant product imported or manufactured before May 22, 2008, from the requirements of the Lacey Act amendments and limit the import declaration requirement to solid wood and items imported only for commerce. It would also clarify that the Lacey Act only prohibits the importation of wood products harvested in violation of foreign laws that pertain to plants.
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(David Fogarty — Reuters)

Call it CSI: Singapore.

But unlike the Crime Scene Investigators from the popular TV series, these detectives are hired to look for evidence of rogue wood from stores increasingly worried about being duped by a global trade in illegal timber now worth billions.

They take wood samples into their lab and put them through DNA tests that can pinpoint the species and origin of a piece of timber. They also track timber and timber products from forest to shop to ensure clients’ shipments are legal.[...]

Every two seconds, an area of forest the size of a football field is clear-cut by illegal loggers, the World Bank says in a recent study. Annually, such illegally cleared land is equivalent to the size of Ireland. Read more here.
 

(AFP)

Guitar-maker Gibson has agreed to pay $350,000 to avoid US prosecution over allegations it illegally imported endangered wood from India and Madagascar, according to US officials.

“Gibson has acknowledged that it failed to act on information that the Madagascar ebony it was purchasing may have violated laws intended to limit over-harvesting and conserve valuable wood species,” Assistant Attorney General Ignacia Moreno said in a statement, released on Monday.

The company also imported rosewood and ebony from India in a potential violation of the US Lacey Act, which protects endangered foreign wood species, the statement from the Justice Department alleged. Read more here.
 

(STR Trade Report)

The Department of Agriculture’s Animal and Plant Health Inspection Service is soliciting comments through Aug. 6 on the proposed three-year extension of the import declaration required for certain plants and plant products under the Lacey Act. This declaration must contain, among other things, the scientific name of the plant, the value of the importation, the quantity of the plant, and the name of the country from which the plant was harvested. For paper and paperboard products with recycled plant content, the importer is not required to specify the species or country of harvest with respect to the recycled plant product component but will be required to provide the average percentage of recycled content. If the product also contains non-recycled plant materials the basic declaration requirements still apply to that component of the product imported.

Comments should focus on (a) whether this declaration is necessary for the proper performance of APHIS’ functions, including whether the information has practical utility; (b) how to enhance the quality, utility and clarity of the information collected; (c) the accuracy of APHIS’ estimate of the burden of this declaration, including the validity of the methodology and assumptions used; and (d) ways to minimize that burden through the use of automated, electronic, mechanical and other collection technologies (e.g., permitting electronic submission of responses).

Industry sources believe Congress may act soon on legislation that would make various changes to the Lacey Act amendments of 2008, including the import declaration requirement. The Retailers and Entertainers Lacey Implementation and Enforcement Fairness (RELIEF) Act (H.R. 3210) would exempt any plant product imported or manufactured before May 22, 2008, from the requirements of the Lacey Act amendments and limit the import declaration requirement to solid wood and items imported only for commerce. Witnesses at recent congressional hearings have testified of the difficulty of providing the information required on the import declaration, and key lawmakers have said they are interested in advancing reforms this year. Others, however, have expressed opposition to what they see as an effort to water down the 2008 amendments.
 

(Randy Boswell – Postmedia News)

A U.S. senator has made it his mission to save country music in Canada this summer from nitpicking, guitar-snatching U.S. government agents who might try to enforce a “confusing” American law that targets products made of wood from endangered tree species around the world.

Republican Sen. Lamar Alexander is the senior federal lawmaker from Tennessee – its capital, Nashville, far better known as Music City and for its Grand Ole Opry than for being home to the state legislature. […]

“I don’t want the musicians from Nashville who are flying to Canada to perform this summer to worry about the government seizing their guitars,” Alexander said in a statement issued Friday, adding that he is working with Democratic Sen. Ron Wyden of Oregon to address the “unintended” consequences of new U.S. legislation the two of them co-sponsored in 2008. Read more here.
 

(STR Trade Report)

Legislative initiatives affecting international trade are picking up a bit of steam, and with nearly three months before Congress takes its annual month-long summer recess a number of them could see further progress. The process of assembling a miscellaneous trade bill will continue to move quietly forward, and in the meantime debate over fiscal year 2013 funding for federal trade agencies is heating up. Lawmakers have also recently held hearings on possible reforms concerning imported wood and wood products. Read more here.
 

(National Retail Federation)

The National Retail Federation today urged Congress to review and revise controversial rules on the importation of wood products and plant material that retailers fear could lead to unfair government seizure of merchandise ranging from furniture to musical instruments. “Retailers recognize the need for environmental conservation but the current law leaves them guessing on which products are legal and which aren’t,” NRF President and CEO Matthew Shay said. “Congress needs to carefully review the Lacey Act to ensure that the goal of eliminating illegal logging is its primary objective, not penalizing businesses that are doing their best to comply with an unworkable law.”

Shay commented as a subcommittee of the House Natural Resources Committee prepares to hold a hearing this afternoon on legislation that would reform portions of the law. Laurie Everill, regional customs compliance and operations manager for NRF member IKEA-North America, is scheduled to testify to the Subcommittee on Fisheries, Wildlife, Oceans and Insular Affairs on the challenges facing companies seeking to comply with the law, and changes sought by NRF to address those challenges, improve enforcement and compliance with the law, and support its goal to end illegal logging. Read more here.
 

(Video: Gibson Guitar • Story: Tennessean.com)

Seizure of imported hardwood draws attention of lawmakers

U.S. Justice Department officials have requested a meeting with Gibson Guitar owners next week, while in Congress lawmakers continue to ask why the factories and offices of the longtime manufacturer of prized guitars were raided on Aug. 24.

Gibson CEO Henry Juszkiewicz said he will meet with federal officials in Nashville on Wednesday to discuss the raids. Juszkiewicz said he is unsure where the conversation will lead.

In Congress, U.S. Fish & Wildlife officials have agreed to brief lawmakers on the House Energy and Commerce Committee in the next two weeks on the issue, U.S. Rep. Marsha Blackburn, R-Brentwood, said Wednesday.

The agency oversaw the Gibson raids, with agents confiscating computer hard drives, and pallets of wood and guitars suspected of being imported illegally in violation of the U.S. Lacey Act, which bans the importing of environmentally threatened plants and animals. Read more here.

Video: Henry Juszkiewicz, Chairman and CEO of Gibson Guitar Corp., has responded to the August 24 raid of Gibson facilities in Nashville and Memphis by the Federal Government. In a press release, Juszkiewicz said: “Gibson is innocent and will fight to protect its rights. Gibson has complied with foreign laws and believes it is innocent of ANY wrong doing. We will fight aggressively to prove our innocence.”
 

(CME – Steve Coleman)

Exporters sending goods across the U.S. border may have to do even more homework under changes to the Food, Conservation and Energy Act.

A U.S. government decision to amend the Lacey Act, could mean exporters will have to spell out where everything that went into the finished product came from if they want their goods to cross the international border.

“It could lead to new, onerous requirements for documentation,” said Paul Clipsham, CME’s Director of Commercial and Consumer Policy. “It could be another non-tariff barrier to entry…We’d like businesses to look into (possible side effects) themselves.”

U.S. Congress passed changes to the act in 2008 aimed at preventing illegal logging practices around the globe to save rain forests and other environmentally-sensitive areas. Anything done that doesn’t conform to American law means the product won’t cross the border.

Provisions in the law mean the act could apply to other industry sectors.
 

(World Trade Interactive)

The Department of Agriculture’s Animal and Plant Health Inspection Service is inviting public comments by Aug. 29 on regulatory options that could address certain issues that have arisen with the implementation of the declaration required for imports of certain plants and plant products under the Lacey Act amendments of 2008.

This declaration must contain the scientific name of the plant, the value of the importation, the quantity of the plant and the name of the country from which the plant was harvested.  Read more here.
 

(World Trade Interactive)

The Department of Agriculture’s Animal and Plant Health Inspection Service recently issued a notice concerning the use of special use codes on the import declaration for plants and plant products (form PPQ 505) required under the Lacey Act amendments. APHIS states that comments received from the public have raised issues regarding the efficient and accurate completion of this form that fall into three categories: the possible use of shorthand for common trade groupings of species; the possible difficulties involved in identifying composite, recycled, reused or reclaimed materials to the genus and/or species level; and the difficulty in identifying the genus and species for certain articles manufactured prior to the passage of the Lacey Act amendments.

APHIS has established a number of special codes to address these situations, as detailed below. Provided that these codes are properly (truthfully, accurately, completely and appropriately, pursuant to this guidance) used in an import declaration that is otherwise in compliance with the requirements of the Lacey Act, APHIS will not refer for prosecution or take any other enforcement action as to such a declaration filed while this guidance is in effect based on any failure to provide genus, species or country of harvest information. Read more here.

(World Trade Interactive)

The Department of Agriculture’s Animal and Plant Health Inspection Service is conducting a required review of the implementation of the import declaration requirement for certain plants and plant products contained in the Lacey Act amendments made by the 2008 Farm Bill. Public comments on this issue are due no later than April 14.

Under the Lacey Act amendments, imports of certain plants and plant products must be accompanied by an import declaration that contains, among other things, the scientific name of the plant, the value of the importation, the quantity of the plant and the name of the country from which the plant was harvested. APHIS started phasing in this requirement as of Dec. 15, 2008, and it currently applies to items classified under HTSUS headings 4402 (wood charcoal); 4412 (plywood, veneered panels), except 4412.99.06 and 4412.99.57; 4414 (wooden frames); 4419 (tableware and kitchenware); 4420 (wood marquetry, caskets, statuettes); 4421 (other articles of wood); 6602 (walking sticks, whips, crops); 8201 (hand tools); 9201 (pianos); 9202 (other stringed instruments); 9302 (revolvers and pistols); 9305.10.20 (parts and accessories for revolvers and pistols); 9401.69 (seats with wood frames); 9504.20 (articles and accessories for billiards); and 9703 (sculptures). Additional products could be added in the future, but APHIS has said it plans to provide at least six months’ notice before any such action is taken.

The amendments also require APHIS to review the implementation of the declaration requirements, including the effect of certain exclusions, and to submit to Congress a report detailing the results of that review. This report must include an evaluation of the effectiveness of each type of required information in assisting enforcement, the potential for harmonization with other applicable import regulations and an analysis of the new law’s effects on the cost of legal plant imports and the extent and methodology of illegal logging practices and trafficking. APHIS must also provide recommendations for appropriate legislation to assist in the identification of violative plant imports. APHIS is therefore soliciting from the public information on these topics as well as other issues pertinent to the implementation and enforcement of the 2008 Lacey Act amendments.

The U.S. Animal and Plant Health Inspection Service (APHIS) is reopening the comment period for its proposed rule that would establish definitions for the terms “common cultivar” and “common food crop”. This action will allow interested persons additional time to prepare and submit comments.

APHIS will consider all comments received on this Docket No. APHIS-2009-0018 on or before November 29, 2010. For a copy of the proposed rule with the definitions, as well as the regulatory impact analysis, please refer to the  Federal Register and APHIS supporting materials.To submit comments directly go here.

pspan style=”FONT-FAMILY: ‘Verdana’, ‘sans-serif’; COLOR: black; FONT-SIZE: 8pt; mso-bidi-font-family: Arial”(Lexology – Karen Lobdell, Drinker Biddle amp; Reath LLP)/spanspan style=”FONT-FAMILY: ‘Verdana’, ‘sans-serif’; COLOR: black; FONT-SIZE: 10pt; mso-bidi-font-family: Arial”?xml:namespace prefix = o ns = “urn:schemas-microsoft-com:office:office” /o:p/o:p/span/pp style=”MARGIN-BOTTOM: 12pt”span style=”FONT-FAMILY: ‘Verdana’, ‘sans-serif’; COLOR: black; FONT-SIZE: 10pt; mso-bidi-font-family: Arial”The Animal and Plant Health Inspection Service (APHIS) published the long-awaited Proposed Rule August 4, 2010, providing the definitions for Exempt and Regulated Articles under the Lacey Act. [...]o:p/o:p/span/ppspan style=”FONT-FAMILY: ‘Verdana’, ‘sans-serif’; COLOR: black; FONT-SIZE: 10pt; mso-bidi-font-family: Arial”APHIS plans to supplement these definitions by providing guidance in the form of a list of examples of plant taxa or commodities that qualify for exemption. The United States Department of Agriculture and Department of Interior will develop and maintain this list on a website, updating it as necessary. Updates will also be noted on the APHIS website. The list will not be exhaustive, and will also provide an email address to which the public can send inquiries regarding specific taxa or commodities, and request additional taxa and commodities be added to the list.br /br /Comments on this Proposed Rule are being accepted on or before October 4, 2010, and may be submitted on the a href=”http://www.regulations.gov/fdmspublic/%20component/main?main=DocketDetailamp;d=APHIS-2009-0018″ target=”_blank”span style=”color:#0000ff;”Federal eRulemaking Portal/span/a.br /br /Finally, we note that on August 4, 2010, CBP advised the Commercial Operations Advisory Committee (COAC) at its quarterly meeting that there are currently no plans for additional phases to be implemented to the Lacey Act to include more HTSUS Headings. This had been a concern for the trade since the previous FR Notice had indicated that there was a possibility of additional phases being implemented after September 1, 2010. Read more a href=”http://www.drinkerbiddle.com/files/Publication/0b91f100-e055-4b85-86a7-a59af42dcfc6/Presentation/PublicationAttachment/d5d1289d-9ff4-465a-98f5-aed5a3adcf7c/Lacey_Act_Update.pdf”span style=”color:#0000ff;”here/span/a.strongspan style=”FONT-FAMILY: ‘Verdana’, ‘sans-serif’; FONT-WEIGHT: normal; mso-bidi-font-family: Arial”o:p/o:p/span/strong/span/p

strongUnits of Measure Must Now be Metric/strongbr /br /Clients are reminded that as per U.S. Animal and Plant Health Inspection Service (APHIS) all plant material quantities be reported on the Lacey Act declaration should now be using standardized metric units (such as kg, m, m2, m3).br /br /The values are to reflect the actual plant content in the product and not necessarily the product as a whole.br /br /APHIS is no longer accepting other counts of items (e.g., PCS – pieces, No – number, boxes, etc) as valid units of measure.br /br /APHIS notes that counts of items do not adequately address the “quantity of the plant material” required by the Act.(3372.f.1.A.ii) Counts do not allow for differences in size or weight between items, nor do they accurately reflect the actual plant content in a shipment.

span style=”font-size:85%;”(World Trade Interactive)/spanbr /br /The Lacey Act amendments of 2008 require the Department of Agriculture’s Animal and Plant Health Inspection Service to collect information on the importation of plant material using a Plant and Plant Product Declaration (form PPQ-505). This information must include the quantity and unit of measure of the imported plant material.br /br /In an effort to create a uniform dataset, APHIS is requiring that plant material quantities be reported on the declaration using standardized metric units (kilograms, meters, square meters, etc.). These values should reflect the actual plant content in the product and not necessarily the product as a whole. While this requirement took effect May 1, APHIS is allowing a two-month grace period (ending July 1) to allow industry to make the needed changes to declaration procedures.br /br /As a result of this change, APHIS will no longer accept counts of items (pieces, boxes, etc.) as valid units of measure on the declaration. APHIS states that item counts do not allow for differences in size or weight between items and do not accurately reflect the actual plant content in a shipment.

span style=”font-size:85%;”(CIFFA eBulletin)/spanbr /br /The Lacey Act Amendments of 2008 require APHIS to collect information on the importation of plant material, using a Plant and Plant Product Declaration (known as the PPQ505). The quantity and unit of measure of the imported plant material must be declared. In an effort to create a uniform dataset, APHIS will no longer accept counts of items (PCS – pieces, No – number, Boxes, etc) as valid units of measure. Counts of items do not adequately address the “quantity of the plant material” required by the Act.(3372.f.1.A.ii) Counts do not allow for differences in size or weight between items, nor do they accurately reflect the actual plant content in a shipment.br /br /Beginning May 1, 2010, APHIS is requiring that plant material quantities be reported on the declaration using standardized metric units (kg, m, m2, m3). The values should reflect the actual plant content in the product and not necessarily the product as a whole. For an example a href=”http://www.aphis.usda.gov/plant_health/lacey_act/downloads/ClarificationQuantityandUnitofMeasure.pdf” target=”_blank”click here/a.

span style=”font-size:85%;”(World Trade Interactive)br //spanbr /The next phase of enforcement of the import declaration requirement under the Lacey Act is slated to begin April 1.br /br /Under the amendments to the Lacey Act that included in the 2008 Farm Bill, imports of certain plants and plant products must be accompanied by an import declaration that contains, among other things, the scientific name of the plant, the value of the importation, the quantity of the plant and the name of the country from where the plant was harvested. For paper and paperboard products containing recycled content, the declaration also must include the average percent of recycled content without regard for species or country of harvest.br /br /The import declaration requirement currently applies to items classified under HTSUS headings 4402 (wood charcoal); 4412 (plywood, veneered panels), except 4412.99.06 and 4412.99.57; 4414 (wooden frames); 4419 (tableware and kitchenware); and 4420 (wood marquetry, caskets, statuettes).br /br /Beginning April 1, this requirement will be expanded to include items classified under the following HTSUS headings.br /br /• 4421 (other articles of wood)br /• 6602 (walking sticks, whips, crops)br /• 8201 (hand tools)br /• 9201 (pianos)br /• 9202 (other stringed instruments)br /• 9302 (revolvers and pistols)br /• 9305.10.20 (parts and accessories for revolvers and pistols)br /• 9401.69 (seats with wood frames)br /• 9504.20 (articles and accessories for billiards)br /• 9703 (sculptures)br /br /USDA has previously stated that for any future enforcement phases it intends to provide at least six months’ notice to affected persons and industries to facilitate compliance. Last fall USDA indicated that the next phase would begin no earlier than Sept. 1.

span style=”font-size:85%;”(IE Canada)/spanbr /span style=”font-size:85%;”/spanbr /Today is the last day to provide input to the survey established by I.E.Canada and the Canadian Manufacturers and Exporters regarding implementation of amendments to the Lacey Act. The overall results of this survey will assist with advocacy efforts in the U.S., and be shared with the Canadian Embassy in Washington.br /br /The survey, which covers issues such as requests for compliance certificates from U.S. customers and import declarations under the Lacey Act, is available on Survey Monkey a href=”https://www.surveymonkey.com/s.aspx?sm=oJMT_2f884GBaE2R4QJoMc1w_3d_3d” target=”_blank”here/a.br /br /Questions about the survey should be directed to Carol Osmond at a href=”mailto:cosmond@iecanada.com”cosmond@iecanada.com/a.

span style=”font-size:85%;”(USDA/APHIS via World Trade Interactive)br //spanbr /bDeclaration Enforcement Postponed for Numerous Products/bbr /br /The U.S. Department of Agriculture, Animal and Plant Health Inspection Service, has issued a notice modifying the schedule of enforcement of the import declaration requirement under the Lacey Act amendments. This modification postpones enforcement for numerous products. Comments on this action are due by Nov. 2 (refer to a href=”http://www.aphis.usda.gov/plant_health/lacey_act/downloads/2008-0119.pdf”APHIS-2008-0119/a for contact details).br /br /Under the Lacey Act amendments included in the 2008 Farm Bill, imports of certain plants and plant products must be accompanied by an import declaration that contains, among other things, the scientific name of the plant, the value of the importation, the quantity of the plant and the name of the country from where the plant was harvested. For paper and paperboard products containing recycled content, the declaration also must include the average percent of recycled content without regard for species or country of harvest. USDA began phasing in its enforcement of this requirement in December 2008.br /br /After a review of comments received, further internal consideration and experience with implementation of the first phase of enforcement of the declaration requirement, the USDA has revised the phase-in schedule as follows. USDA emphasizes, however, that Lacey Act amendment provisions other than the import declaration are already effective and that actions to enforce those provisions may be taken at any time.br /br /strongRevised List for Phase III/strongbr /br /Phase III, which is scheduled to begin Oct. 1, now covers only items classified in the following HTSUS headings.br /br /• 4402 (wood charcoal)br /• 4412 (plywood, veneered panels), except 4412.99.06 and 4412.99.57br /• 4414 (wooden frames)br /• 4419 (tableware and kitchenware)br /• 4420 (wood marquetry, caskets, statuettes)br /br /strongRevised List for Phase IV/strongbr /br /Phase IV, scheduled to begin April 1, 2010, has been substantially revised and now covers the following HTSUS headings.br /br /• 4421 (other articles of wood)br /• 6602 (walking sticks, whips, crops)br /• 8201 (hand tools)br /• 9201 (pianos)br /• 9202 (other stringed instruments)br /• 9302 (revolvers and pistols)br /• 9305.10.20 (parts and accessories for revolvers and pistols)br /• 9401.69 (seats with wood frames)br /• 9504.20 (articles and accessories for billiards)br /• 9703 (sculptures)br /br /strongFuture Changes/strongbr /br /USDA states that there will be no further additions to phases III or IV and that it intends to provide at least six months’ notice to persons and industries affected by any future changes to facilitate compliance with the new requirements.br /br /In addition, USDA is seeking comments on the following HTSUS headings currently under consideration for subsequent enforcement phases that would be scheduled to begin on or after Sept. 1, 2010.br /br /• 4405 (wood wool [excelsior])br /• 4410 (particle board)br /• 4411 (fiberboard of wood)br /• 4412 (plywood, including 4412.99.06 and 4412.99.57)br /• 4413 (densified wood)br /• 4415 (packing cases, boxes, crates, drums)br /• 4416 (casks, barrels, vats, tubs)br /• 4701 (mechanical wood pulp)br /• 4702 (chemical wood pulp, dissolving)br /• 4703 (chemical wood pulp, sulfate)br /• 4704 (chemical wood pulp, sulfite)br /• 4705 (combination mechanical and chemical)br /• 4801 (newsprint)br /• 4802 (uncoated writing paper)br /• 4803 (toilet or facial tissue stock)br /• 4804 (uncoated kraft paper)br /• 4805 (other uncoated paper and board)br /• 4806 (vegetable parchment, etc.)br /• 4807 (composite paper and board)br /• 4808 (corrugated paper and board)br /• 4809 (carbon paper)br /• 4810 (coated paper and board)br /• 4811 (paper coated, etc.)br /• 6601 (umbrellas)br /• 6603 (umbrella parts)br /• 9205 (wind musical instruments)br /• 9401 (seats)br /• 9403.30 (wooden office furniture)br /• 9403.40 (wooden kitchen furniture)br /• 9403.50 (wooden bedroom furniture)br /• 9403.60 (other wooden furniture)br /• 9403.81 (furniture of cane, osier, bamboo, rattan or similar materials)br /• 9504 (articles for arcade, table or parlor games)br /br /br /Finally, USDA continues to consider the applicability of the import declaration requirement to other products not included in the revised phase-in schedule or listed above and seeks comment on how this requirement should be enforced as to additional goods classified under the following HTSUS chapters.br /br /• chapter 48 (paper and articles of)br /• chapter 82 (tools, implements)br /• chapter 89 (ships, boats and floating structures)br /• chapter 93 (arms and ammunition)br /• chapter 94 (furniture, etc.)br /• chapter 95 (toys, games and sporting equipment)br /• chapter 96 (brooms, pencils, buttons)br /br /strongEnforcement Delayed for Composite, Recycled, Reused Materialsbr //strongbr /Several commenters contended that identifying composite and recycled or reused materials (e.g., medium density fiberboard, particleboard and scrap wood) to the genus and/or species level would be difficult and in some cases impossible. In response to those comments, USDA has decided to further delay enforcement of the declaration requirement for these products so that it would begin no earlier than Sept. 1, 2010.br /br /strongUse of Spp. to Identify Species of Imported Plants/strongbr /br /Several commenters proposed that USDA allow for importers to provide only the genus name in circumstances where the individual species would be difficult to identify. USDA has responded by stating that in circumstances where the list of possible species in a particular product includes ball species in a genus/b, it is acceptable to use “spp.” following the genus name on the import declaration form. However, when reference to all possible species in a genus is not accurate (based on geographical or other factors), importers are expected to provide either the single genus and species or a specific list on the import declaration form of all possible species that may have been used to produce the plant product.br /br /strongFederal Register Reference:/strong Implementation of Revised Lacey Act Provisions, September 2, 2009 available a href=”http://www.aphis.usda.gov/plant_health/lacey_act/downloads/2008-0119.pdf”here/a (PDF).