[Nhcoll-l] ACE entry & APHIS core

Tue Aug 16 15:20:36 EDT 2016

Hi Ellen,

thanks a lot for all this valuable information you provided and all you 
efforts & discussions with regulators and authorities.

As an "outsider" and being not that familiar with the US imports 
regulations I had a look on the customs declaration form you linked in 
your second post (form 19 CFR 122 27).

To me, this seems to be the standard questionnaire passengers arriving 
from abroad have to file in many countries. It applies for all _fresh, 
unpreserved_ materials. The reasoning behind is protection against bird 
flue strains or phytopathogenes that could be carried in the hand or 
checked luggage.

But for our preserved stuff, as well as for hunting trophies, there are 
specific harmonised regulations between North America which help to ease 
import when the material either originated from a safe sourcing country 
(i.e. a country with proper reliable veterinarian check), or underwent a 
so called safe treatment (i.e. boiling/maceration, formalin fixation, 
ethanol preservation, complete cell lysis). Do you know if there is any 
reference inside the US laws which reflect this concept ? Is the concept 
of safe sourcing/safe treatment applicable for US imports?

Further, you mentioned normal shipments send by courier companies such 
as FedEx (which is a complete separate string compared to the checked 
luggage ACE declarations); all shipments we sent the last few weeks with 
FedEX (with reference the the respective EU animal-by-product laws / 
safe treatment) arrived without any hassles or delay at the museum of 
destination.

Our material travels under custom tariff code 9705.00  - which serves as 
indirect hint that it is somehow treated but not fresh. So far, I had 
the impression that this combination was working well - at least for the 
preserved stuff that travels inside regular postal networks ...

Curious to hear your thoughts,
all the best from the old world / late side of our globus

Dirk

Am 15.08.2016 um 23:29 schrieb Ellen Paul:
>
> 1. I want to clarify something first. If you use FedEx, then the FedEx 
> in-house customs broker (FedEx Trade Network) will be handling this 
> for you. I do not yet know what they will be charging. I am awaiting a 
> reply from the FTN contacts I've reached out to. Last I heard, they 
> were charging $35 for a USFWS e-dec so I'm guessing that they will 
> charge at least that much for the ACE component and the APHIS 
> component. I will keep you posted as I learn more.
>
> I admit that I worry about FTN understanding the nature of your 
> shipments and entering the right data, but I've offered to be a 
> resource for them.
>
> 2. The need for a customs broker is greatest for hand-carry. If you 
> are shipping and using FedEx, there is already a broker involved - the 
> FedEx Trade Network. So you don't need a customs broker if using 
> FedEx. For hand-carry, though, you really will need a broker to handle 
> the ACE entry and APHIS core (and, when USFWS comes into the "single 
> window" system, then for USFWS as well). There is, per CBP, no way for 
> individuals to gain access to the ACE system. And frankly, based on 
> what I've seen just of the APHIS core, you wouldn't want to. It is 
> incredibly complex.
>
> So for hand-carry, you will need a broker.
>
> Apart from the need for a broker who has or will develop the 
> expertise, which is why I've asked two companies to give us proposals, 
> I'm also hoping that working with a single broker might help with the 
> CITES validation problem. I won't go into detail here, but the short 
> version is that if we have a single broker who really "gets it" there 
> is at least a chance that they can work closely with their 
> corresponding broker at the shipping end to be sure that the 
> validation is done and done properly.
>
> 3. During this transitional phase, some airports are allowing you to 
> come through in the traditional way. Problem is that you can't count 
> on it. So unless you are prepared to get the OK from the CBP Field 
> Operations Office and the CBP Agricultural Quarantine Inspection 
> office at the arrival airport in advance, you are taking a chance.
>
> The ports and all the phone numbers are here: 
> https://urldefense.proofpoint.com/v2/url?u=https-3A__www.cbp.gov_contact_ports&d=CwID-g&c=-dg2m7zWuuDZ0MUcV7Sdqw&r=CLFZJ3fvGSmDp7xK1dNZfh6uGV_h-8NVlo3fXNoRNzI&m=huw0h3atcW0MY2mtFR2Nm3ASP070WJi1RBureWKv52I&s=wm0Z18Yp1I-JQ8D4Ze_8oYtXBWWCz79vNe6hCacNHd4&e= 
>
> I am still working on getting the paper form "translated" for you.
>
> I've been asked if this applies to exports. The answer is that I think 
> so but I'm not sure. I'm working on it.
>
> Ellen
>
> -- 
> Ellen Paul
>
> Ellen Paul
>
> Executive Director
>
> Ornithological Council 
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