[NHCOLL-L:5443] Shipping of specimens / updates import requirements for Europe / Germany

Thu May 19 06:42:10 EDT 2011

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 indetermined 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/

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