[NHCOLL-L:4669] Again: Shipping scientific samples to Europe

Thu Jan 14 04:24:02 EST 2010

This morning I received an email from colleagues from Austria dealing 
with unjustified vet inspections and incurred charges of 150,- EUR (=217 
U$) per inspection. Samples entered Austria apparently as freight 
shipment arriving at Vienna airport, originating from University of 
Ontario, Canada, however this seems to be a common problem with 
scientific shipments to Austria.

As outlined in previous postings on this issue, "insect larvae" have 
been identified as potential carriers for animal pests. Therefore, all 
shipments containing "insects" must be inspected.

However, these new European legislations (EdK 2007/275/EG, 91/496/EWG 
and 97/78/EG) fails to determine what exactly the veterinarians should 
inspect, which results in quite different handling of shipments in 
different European countries (see unsatisfactory situation in Italy).

Please make sure, that your shipping docs includes a statement regarding 
the preservation of the dried insects, e.g. that specimens were 
originally fixed with ethyl acetate and/or preserved in ethanol (> 96 %) 
to avoid future costs and damage or loss of material because of 
unjustified inspections.

Please make sure also, that material which is returned from loan from a 
European Museum is clearly marked as such (including a copy of the 
original loan form), as animals (or animal parts) originating from 
Europe underlie no vet inspections for re-entry into the EU.

Avoid the unspecific (and insufficient) term "insects" or "dried 
insects" in your shipping docs.

For Details of a previous posting on this issue see below.

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. Most shipments are advised electronically based on the data retrieved
from the commercial invoice prior to the actual import / arrival of the
parcel. Therefore, statements in the commercial invoice (if printed
separately) are crucial for import and decide whether the shipment is
inspected, or not. 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. The "country of origin" must be named; 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. For any shipment containing vertebrates, there must be a passage in
the shipping docs that the specimens where either originally preserved
in 4 % formalin solution at least for three days or warm water macerated
and therefore do not carry any potential animal diseases or pests. There
have been reported cases where up to 80,- EUR (= 100 USD) have been
charged from the consignee for vet inspections because of insufficient
shipping docs. All claims against these charges are fruitless in cases
of wrong / insufficient import docs.

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 your loan agreement *AND*
either in your commercial invoice or in your shipping doc. Phrases like
*dried insects*, *entomological samples* or *DNA samples* in your
commercial invoice are  *NOT SUFFICIENT* for customs clearance! This is
a perpetuating problem and issue, causing distress and custom holds! In
case of missing or inadequate information, especially FedEx staff tends
to convey shipments to customs inspections in order to avoid any
potential claim against FedEx for violating customs procedures for entry
of "bio-shipments" into the EU.

In the case of *undetermined 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 CUSTOMS
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. 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).

7. *DO NOT NAME THE CONSIGNEE FIRST* ! Naming your colleagues/persons
prior to the institute / museum implies (in customs terms) a private and
therefore commercial nature of your shipment! Avoid "private shipments";
the first line in the address of the consignee must give the name of the
institute or museum first ! (This issue was explicitly stressed from
customs at Frankfurt/ Main Airport, which is the main gateway for postal
shipments to Europe, especially FedEx)

8. Different airports in Germany serve as main gateways for entry of
international shipments to Europe for the following carriers: UPS
(Cologne), FedEx (Frankfurt/Main), DHL (Leipzig). With exception for the
UK, most shipments addressed to European Institutions / Museums are
handled in one of the three cities, which are in different federal
states in Germany. Because of the federal legislation, it is extremely
difficult (literally impossible) to have a common regulation for all
arriving shipments containing scientific material, since different
authorities are involved (customs, vets, species protection) with
slightly different federal legislation and procedures in each of the
single states. FedEx will move its international operation to Cologne
end of 2009, so we are currently starting to negotiate agreements
achieved in Frankfurt again in Cologne ...

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/