[NHCOLL-L:5447] Shipping of specimens / updates import requirements for Europe / Germany

Wed May 25 03:30:21 EDT 2011

Morning all,

just to share recent questions regarding CN tariff code / US Fish & 
Wildlife from 3-177:

E-Dec means "Electronic Declaration". This is what you (or the person in 
charge for the shipping at your museum) enters on-line in the system 
(e.g. FedEx) when issuing the bar code label. As in (old style) paper 
waybills, there should be a field in the entry mask where you enter the 
description of goods. This field should include the information "CN 9705 
00 00".

As far as I know the CN tariff is not required for the 3-177 from, but I 
never issued such a form myself, so I am not sure if US Fish & Wildlife 
authorities would need this custom tariff code (but I think not). Also, 
the 3-177 form isn't needed as import document for imports to Europe, so 
no problem if the tariff codes does not appear on the 3-177 from. 
However, it is recommended to have the CN tariff  on your commercial 
invoice / shipping doc which is the relevant document for clearance 
(attached accessible at the _outside_ of your parcel).

In 90 % of cases (except for national postal services which do not offer 
on-line transfer & tracking of data) customs clearance of parcels is 
done based on the electronic data entered in the shipping software of 
the respective carrier prior to the physical departure of the parcels 
from the country. This opens  an approximate 12 h time slot for carriers 
to clarify any discrepancies in advance to allow immediate clearance of 
parcels upon their arrival at the destination air hub in Europe. To 
achieve this, exact & detailed E-Dec information is vital to avoid delays.

If the E-Decs DO NOT hold all relevant information, but only the 
commercial invoice on the parcel, then shipments normally will be 
delayed for one day (to allow physical checks of attached invoices after 
arrival of the consignment). If this data is insufficient, too, carriers 
try to contact the consignee to receive the missing information or hand 
the parcels to directly inspection to keep their scheduled delivery 
promise. This is where the tiresome and many times frustrating part for 
all involved parties starts.

All the best
Dirk

> Morning all,
>
> here is the latest update regarding documentation requirements for 
> specimens on international exchange with special focus on import to 
> Europe / Germany due to new veterinary stipulations effective since 4 
> Mar. 2011. This email summarises results from a workshop on proper 
> shipping of preserved scientific samples held on 5-6 May 2011 at 
> Museum Alexander Koenig, Bonn (Germany), which was attended not only 
> by museum staff, but also from representatives of the various federal 
> German Ministries, veterinarians and FedEx and UPS staff at 
> Cologne/Bonn airport (CGN) to resolve the problems we face with import 
> at CGN (CGN serves as major air hub for UPS & FedEx for international 
> imports to Europe).
>
> Please note that unless otherwise indicated the information provided 
> here basically regulate imports to Germany; regulations in other 
> member states of the EC may differ. The EC legislation should be 
> harmonised within Europe but in fact there are 27 different (national) 
> implementations resulting in a wide variety of licences, permits & 
> other requirements to allow import to single member states. So the 
> information provided here can only be a rough guideline.
>
> _EXCEPTION(S):_
>
> 1. Re-import of loans returned to the respective European Museum do 
> not fall under the strict veterinarian / animal protection legislation 
> restrictions for re-import.
> *Clearly mark these as RETURNED LOANS on all issues invoices / 
> shipping docs AND ESPECIALLY in the E-Decs when returning loans to Europe
> *
> 2. (negotiated only for imports via CGN) *PRESERVED SPECIMENS* 
> *exchanged between international research institutions* will not be 
> subject to chargeable inspections, unless they are clearly identified 
> as such in the invoice / shipping docs and in the E-Decs. This clearly 
> excepts "personal shipments" (see previous posting added below).
>
> However, (current status) shipments will be opened by the vets to 
> check if the description of goods comply with the content of the 
> parcel. We are in negotiations with the vets in CGN that they refrain 
> from this procedure to prevent potential damage of specimens. The 
> representative of the Ministry in charge for air transport / air 
> regulated goods pointed out the parcels containing specimens packed 
> under Special Provision A180 may not be opened unless re-packing can 
> be done by accordingly trained staff (e.g. no such staff at FedEx).
>
>
> _Custom tariff codes: _
>
> For import, all data entered in the shipping docs and especially in 
> the E-Decs are translated in so called (international) harmonised 
> custom tariff codes.
> For import clearance, e.g. UPS/FedEx staff are translating any 
> descriptions into custom codes and enter these in the electronic 
> ATLAS-system for customs and vet clearance. Whatever code seems to 
> match is picked (There are 3 different tariff codes for bird's 
> feathers, all require vet inspection).
>
> *Decision to call parcels inspection (customs / vets) is based on 
> these tariff codes*.
>
> Wrong translations based on insufficient or misleading E-Dec entries 
> or descriptions entered into ATLAS put biological shipments on hold 
> for identification, turning smart parcels to exceptions. UPS & FedEx 
> at CGN would like to avoid any ambiguities, and would highly 
> appreciate E-Decs or shipping docs providing the right tariff code.
>
> *The custom tariff code for collections and collectors' pieces of 
> zoological*, botanical, mineralogical, anatomical, historical, 
> archaeological, palaetological, ethnographic or numismatic *interest* 
> is *CN 9705 00 00*
>
> Please use add this code on all invoices / shipping docs / E-Decs for 
> shipments to Europe (wouldn't surely be wrong for other countries, too)
>
>
> _Fresh samples (blood / tissue):_
>
> Under UN3373 as Biological Substance, category B; use specific UN3373 
> packings. Need vets checks (charged). Avoid Dry Ice (UN1845) shipments 
> (Air Dangerous Good which requires IATA training & certification for 
> packing and shipping). If cooled on ice, mark parcel & docs with "No 
> dry ice included" (note that stryofoam packings are highly prone for 
> dangerous goods checks for hidden dry ice shipments).
>
> Dried blood samples on FTA-Cards are in some countries accepted 
> without inspection (examples are appreciated)
>
> NOTE: processed *DNA/RNA MUST NOT BE SENT under UN3373*
> Processed DNA is NOT infectious and should therefore not be sent as 
> (potentially infectious) Biological Substance, Catergory B, but as 
> normal scientific samples with proper description in the shipping docs.
>
> _
> CITES / Animal protection legislation:
> _
> CITES appendices I, II & III are translated into appendices A, B, C, & 
> D under European Law. Both appendices are NOT CONGRUENT (The European 
> version is stricter, listing many CITES III species in appendix B). To 
> my current knowledge (and based on information of the respective 
> national German authority), current EC animal protection laws DO NOT 
> call for import licences. An exception may be Switzerland, which is 
> not part of the EC. To my knowledge, a copy of the valid import 
> licence (renewed on a yearly basis to Swiss natural history 
> collections) as to be included with the shipping docs.
>
> Species database and additional information is provided here:
> http://www.wisia.de/index.en.html
>
> NOTE: *DNA & tissues of CITES species DO NEED* either *CITES 
> documents* for import, *or* if exchanged between CITES institutes, so 
> called *CITES labels*, as the DNA and all tissues are considered as 
> integral part/sample of the respective specimen!
> Institutional CITES numbers are available at:
> http://www.cites.org/common/reg/e_si.html
>
> E.G. sending tissue / DNA samples of the European Eel (Anguilla 
> anguilla, listed on CITES appendix II) requires either CITES documents 
> or CITES labels (if *both*, *the sending AND the receiving* institute 
> are registered as CITES institutes - in case of only one CITES 
> institute involved, you need CITES documents)
>
>
> More information regarding exception from vets inspections may be 
> hopefully posted soon (we currently still await reply from SANCO 
> regarding our petitions)
>
>
> Best regards
>
> Dirk
>
>
>
> *******************************************
>
>
> The recent weeks I received different emails or telephone calls
> regarding problems which occurred during import of scientific samples to
> Europe / Germany, including both, preserved (formalin) specimens for
> morphological research and tissue samples for DNA extraction. Issues 
> were:
>
> - insufficient / inadequate shipping docs and resulting problems with
> customs clearance
> - charges due to (unnecessary) veterinarian inspection
>
> Most problems with import of specimen into the EU seem to be carrier
> related  (especially with FedEx), caused by inadequate data transfer
> from the export docs is into the (FedEx) E-Doc shipping system (the
> material is often referred to as "biological samples" only - which is
> too unspecific for customs clearance). The information below is
> summarised from an earlier posting on this issue:
>
>
> 1. Make sure that the commercial invoice, the shipping
> documentation and a copy of the loan agreement form are packed *together
> with the airwaybill into one document pouch*. Any additional
> documentation packed in separate pouches attached to the shipment is NOT
> considered to contain relevant import docs, unless the *pouch is clearly
> marked* to contain such documents.
>
> 2. "*country of origin*"; the country of origin is *not
> the country in which the specimens were originally collected* , but that
> country, from which the museums specimens originate and whom they
> legally belong. Re-import of animals / animal parts & samples
> originating *FROM* European collections into the European Community are
> not regulated regarding animal pest inspections and therefore not
> subject to vet inspections.
>
> 3. *shipments containing vertebrates*, need description of original 
> preservation
> method (e.g. 4 % formalin solution at least for three days or warm 
> water maceration)
> and that they do not vector for animal diseases or pests.
>
> 4. Make sure that shipments containing museum specimens on loan are not
> declared as *commercial goods** in the commercial invoice (which is the
> case in most shipments). There should be an explicit statement in your
> commercial invoice and/or your shipping docs, that the material packed
> is *on loan* to or is *returned from a loan* to the respective
> institution / museum. For this purpose, make sure to attach a copy of
> the loan agreement to your commercial invoice/your shipping docs. This
> loan form should include the *inventory numbers*, indicating that the
> material included is *state property* and not of private or commercial
> nature.
>
> 5. The *scientific names* must be included in the loan agreement *AND*
> either in the commercial invoice or in your shipping doc. Descriptions 
> such as
> *dried insects*, *entomological samples* or *DNA samples* are *NOT 
> SUFFICIENT
> *to allow clearance! This is a perpetuating problem of so called 
> "bio-shipments"
> entering the EC.
>
> In the case of *i**ndetermined material* sent for
> identification/determination (to / from European museums), make sure to
> name at least names on family or generic level, e.g. "undetermined
> waterbeeetles, Familiy ABC, Genus XYZ (as detailed as possible for the
> undetermined specimens included).
>
> Once again: the term *dried insects* is *NOT SUFFICIENT FOR
> CLEARANCE*  and may cause damage to specimens included due to untalented
> and unmotivated staff inspecting the shipment for potential CITES
> violations! Note that packages are normally cut from the bottom. So
> sufficient cushioning material in the bottom is essential to protect
> specimens from being cut / damaged if packages are inspected.
>
> 6. Personal shipments:
> In cases that your shipments are packed / processed by
> subcontractors, ****your institutional address** should be clearly 
> displayed
> as original shipper either in the shipping docs, or - even better - on
> the airwaybill (not that of the subcontractor).
>
> *DO NOT NAME THE CONSIGNEE's NAME FIRST*! Naming colleagues/individual 
> persons
> prior to the institute / museum implies (in customs terms) a private and
> therefore commercial nature of your shipment! The first line in the 
> address
> of the consignee must give the name of the institute or museum first !
>
>
> Optimizing your shipping docs means minimising the problems, which has
> already caused damage and loss of material in the past.
> Please help to reduce number of inspections / customs holds and forward
> this information to the relevant people (especially technical museum
> staff in charge for packing and shipping the specimens). Please find
> below a template below which might be useful to adapt for your
> commercial invoice / your shipping documentation.
>
>
>
> Thank you very much for your help,
>
> Kind regards from Munich
> Dirk Neumann
>
>
>
> *************
> TEMPLATE
>
> Format for the address of the Consignee:
>
>
> The Bavarian State Collection of Zoology
> Dirk Neumann, Section Ichthyology / DNA-Lab
> Muenchhausenstr. 21
> 81247 Munich (Germany)
>
>
> Shipping doc:
>
> "This package contains dead preserved ... (freshwater fishes) for
> scientific research, which were originally preserved in 4 % formalin
> solution for at least one week
> and then transferred into 75 % denatured Ethanol for further
> preservation; these specimens are not infectious due to the original
> preservation technique. (= ****Vets statement** )
> The package contains no endangered species (for Latin species names
> please refer to included loan agreement). (0 *Protection status of
> included specimens* )
> The specimens packed are on loan for zoological (morphological) research
> and legally belong to the State of Bavaria (Country of Origin: Germany);
> no commercial value, not for resale. (= ****Customs** )
>
> Commercial value of the used cheesecloth and plastic bags: 5.00 EUR  (=
> commercial value for customs purposes* )
>
> Preserved fishes are single packed with absorbent (Vermiculite (TM)) and
> sealed in PE plastic bags / containers. For transportation specimens are
> wrapped in cloth soaked with 70 % Ethanol;
> amount of free liquid Ethanol per inner packing < 30 ml. Dangerous Goods
> in excepted quantities in compliance with IATA DGR Regulations (50^th
> Ed. / 2009): class 3, ID 3274 / UN 1987, packing group II." (= HAZMAT /
> IATA )
>
>
> -- 
> Dirk Neumann
>
> Tel: 089 / 8107-111
> Fax: 089 / 8107-300
> email: Dirk.Neumann(a)zsm.mwn.de
>
> Postanschrift:
>
> Staatliche Naturwissenschaftliche Sammlungen Bayerns
> Zoologische Staatssammlung München
> Dirk Neumann, Sektion Ichthyologie / DNA-Labor
> Münchhausenstr. 21
> 81247 München
>
> Besuchen Sie unsere Sammlung:
> http://www.zsm.mwn.de/ich/
>
> ---------
>
> Dirk Neumann
>
> Tel: +49-89-8107-111
> Fax: +49-89-8107-300
> email: Dirk.Neumann(a)zsm.mwn.de
>
> postal address:
>
> Bavarian Natural History Collections
> The Bavarian State Collection of Zoology
> Dirk Neumann, Section Ichthyology / DNA-Lab
> Muenchhausenstr. 21
> 81247 Munich (Germany)
>
> Visit our section at:
> http://www.zsm.mwn.de/ich/
>
> -- 
> Dirk Neumann
>   
> Tel: 089 / 8107-111
> Fax: 089 / 8107-300
> email: Dirk.Neumann(a)zsm.mwn.de
>   
> Postanschrift:
>   
> Staatliche Naturwissenschaftliche Sammlungen Bayerns
> Zoologische Staatssammlung München
> Dirk Neumann, Sektion Ichthyologie / DNA-Labor
> Münchhausenstr. 21
> 81247 München
>   
> Besuchen Sie unsere Sammlung:
> http://www.zsm.mwn.de/ich/
>   
> ---------
>   
> Dirk Neumann
>   
> Tel: +49-89-8107-111
> Fax: +49-89-8107-300
> email: Dirk.Neumann(a)zsm.mwn.de
>   
> postal address:
>   
> Bavarian Natural History Collections
> The Bavarian State Collection of Zoology
> Dirk Neumann, Section Ichthyology / DNA-Lab
> Muenchhausenstr. 21
> 81247 Munich (Germany)
>   
> Visit our section at:
> http://www.zsm.mwn.de/ich/  

-- 
Dirk Neumann

Tel: 089 / 8107-111
Fax: 089 / 8107-300
email: Dirk.Neumann(a)zsm.mwn.de

Postanschrift:

Staatliche Naturwissenschaftliche Sammlungen Bayerns
Zoologische Staatssammlung München
Dirk Neumann, Sektion Ichthyologie / DNA-Labor
Münchhausenstr. 21
81247 München

Besuchen Sie unsere Sammlung:
http://www.zsm.mwn.de/ich/

---------

Dirk Neumann

Tel: +49-89-8107-111
Fax: +49-89-8107-300
email: Dirk.Neumann(a)zsm.mwn.de

postal address:

Bavarian Natural History Collections
The Bavarian State Collection of Zoology
Dirk Neumann, Section Ichthyology / DNA-Lab
Muenchhausenstr. 21
81247 Munich (Germany)

Visit our section at:
http://www.zsm.mwn.de/ich/

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