[Nhcoll-l] USFWS seizure of imports

Benjamin Hess bmhess at umich.edu
Wed Jun 25 15:00:05 EDT 2025 

Dear All,

I would like to provide some additional information. As part of my
position, I am in frequent communication with U.S. federal agencies. Our
process of what used to be "simple imports/exports of museum specimens" has
changed dramatically over the last few years.

USFWS broad overview

   - USFWS 3-177 Import/Export Declaration is for non-fossilized faunal
   material. This includes all material collected from the archaeological time
   scale - late Stone Age, Bronze Age, Iron Age.
   - A 3-177 *does not apply to Herbarium material*. A USDA permit may
   apply.
      - USDA regulates the plant CITES, ESA, Lacey Act (USFWS laws).
   - Exports should have a CLEARED USFWS 3-177 before the shipment leaves
   your institution.
   - Imports should be declared 48-72 hours in advance when known. A 3-177
   eDec should be submitted as soon as possible.
      - International entities should at the minimum send a USFW 3-177 PDF (
      https://www.fws.gov/sites/default/files/documents/Wildlife%20Shipments%20-%20Declaration%20Form%203-177%20and%20Instructions.pdf)
      with all shipments.
      - Upon arrival, the US institution should submit a 3-177 eDec as soon
      as possible. The PDF 3-177 is no longer the expectation, the
eDec should be
      submitted even if a PDF was part of the documentation.
   - Shipments using international vendors (e.g., DHL, FedEx, and UPS)
   should coordinate with the respective USFWS ports.
      - DHL: Erlanger, KY USFWS: fwsole_ercvg at fws.gov | fws.cvg at dhl.com |
      usfwsall at dhl.com
      - FedEx: Memphis, TN USFWS: fwsole_memphis at fws.gov
      - UPS: Louisville, KY USFWS: fwsole_louisville at fws.gov
   - NOTE: Although you have 180 days to amend a 3-177, it is expected that
   it is submitted as early as possible.
      - Whenever possible, contact the USFWS port of entry before the
      specimens arrive.

US CUSTOMS COMMUNICATION

   - As noted, the importation of biological material is more regulated in
   the U.S. as is other countries globally.
      -
      https://www.cbp.gov/border-security/protecting-agriculture/importing-biological-materials-united-states
   - I recommend communication with the US CBP Biological Specialist group
   (Group email:  aptlabtc at cbp.dhs.gov).
      - This email can help to connect you to US CBP Biological Agents at
      any port.
      - This is crucial for any hand-carry imports, but is also recommended
      for shipments requiring additional permits or agency oversight.
   - NOTE: Double check your personal documentation. All identification,
   passports, visa or other travel authorizations are being heavily checked.

FINAL THOUGHTS

   - Correspond with your international partners before shipments are sent.
   The import requirements within many countries are more stringent than in
   the past.
      - This can greatly improve the communication with the USFWS, and
      avoid delays.
   - If you are not already doing this, include the relative Harmonized
   Tarriff Codes (listed earlier by Genevieve) in a cover letter. This is
   required by some countries, and becoming more common with the couriers.

Kind Regards,

Ben

On Wed, Jun 25, 2025 at 1:59 PM Cody Thompson <cwthomp at umich.edu> wrote:

> Hi, all!  It is my understanding that any plant that is covered by the
> Lacey Act is under the purview of USFWS law enforcement.  I am not 100%
> certain whether that means 3-177s for all, but I think in the current
> political environment that it would be best to check with the port before
> sending.
>
>
> Cody W. Thompson, PhD
> Mammal Collections Manager
> & Associate Research Scientist
> University of Michigan
> Museum of Zoology
> 3600 Varsity Drive
> Ann Arbor, Michigan 48108
> Office: (734) 615-2810
> Fax: (734) 763-4080
> Email: cwthomp at umich.edu
> Website: codythompson.org
>
> *Please click here to support the UMMZ Mammal Division, its collections,
> and research mission!!!*
> <https://lsa.umich.edu/ummz/mammals/donate-to-the-mammal-division.html>
>
>
> On Wed, Jun 25, 2025 at 1:52 PM Chris Grinter <cgrinter at calacademy.org>
> wrote:
>
>> Thanks all, I think our future for international loans of wildlife is not
>> long for this world. LAX office is also rejecting all USPS imports through
>> their office as well. Agents are very frustrated that we use USPS, and even
>> though it's not illegal they have the ability to reject anything they want.
>>
>> I think it's correct that plants *do not* require USFWS clearance and a
>> 3-177.
>>
>> Chris
>>
>> Christopher C. Grinter
>> Senior Collection Manager of Entomology
>> Secretary, The Lepidopterists’ Society
>> Subject Editor: Lepidoptera, The Pacific Coast Entomological Society
>> California Academy of Sciences
>> 55 Music Concourse Dr
>> San Francisco, CA 94118
>> T 415.379.5320
>> We regenerate the natural world through science, learning, and
>> collaboration.
>> Learn more at calacademy.org <http://www.calacademy.org/>
>> <https://www.instagram.com/calacademy/>
>>
>>
>> On Wed, Jun 25, 2025 at 8:31 AM Eli Wyman <eliswyman at gmail.com> wrote:
>>
>>> Chris,
>>>
>>>    Thanks so much for the update. It is a bit chilling that you can't
>>> even get a response from USFWS after this much time. I don't see how they
>>> could reasonably bring charges against you for a package sent to you from
>>> another person that you never received. Anyone can send packages of
>>> specimens without prior notice to you, it happened to me all the time when
>>> I was at the AMNH.
>>>
>>>   I did recently have a phone conversation with a USFWS inspector in NJ
>>> and he told me they are under a lot of scrutiny from DOGE right now and for
>>> that reason are crossing a lot of Ts. He also emphasized that early
>>> notification and sending emails in addition to filing the 3-177 was
>>> critical, that they want us to successfully do our work, but they are under
>>> a lot of pressure.
>>>
>>> @Tim; I would assume so. A 3-177 should be filed ANY time ANY plant or
>>> animal materials cross into or out of the US. It definitely used to be the
>>> case that we could file the 3-177 after the import for returns since it was
>>> understood that we frequently weren't given advanced notice of a shipment
>>> and that foreign institutions often don't know our laws etc. Seems that may
>>> no longer be the case.
>>>
>>> Eli
>>>
>>>
>>> On Wed, Jun 25, 2025 at 11:01 AM Timothy Whitfeld <whitf015 at umn.edu>
>>> wrote:
>>>
>>>> Hi Chris,
>>>> Thank you for the information and the update. Let's hope you're able to
>>>> resolve this issue. Do you happen to know if a 3-177 is also required for
>>>> returning loans of herbarium specimens (plants,fungi, lichen) coming back
>>>> to the US from other countries?
>>>> Thanks,
>>>> Tim
>>>>
>>>>
>>>> On Tue, Jun 24, 2025 at 6:22 PM Chris Grinter <cgrinter at calacademy.org>
>>>> wrote:
>>>>
>>>>> Hi everyone,
>>>>> As an update to our issue with USFWS, there is no news nor return of
>>>>> specimens. Our loan has been seized and a formal petition to the USFWS for
>>>>> return of property has been met with silence. The package was declared, but
>>>>> written in Mandarin and was not translated by CBP. The box did lack a
>>>>> 3-177, which is why they are citing us in violation of the CFR, Lacey Act,
>>>>> and Endangered Species Act. We haven't gotten criminal or civil charges
>>>>> from this import, but it's not out of scope for the current administration
>>>>> to enforce. On top of packages being seized, please note that students or
>>>>> immigrant visa holders entering the US should avoid carrying specimens at
>>>>> all times. Failure to declare or failure to "properly declare" has now been
>>>>> used by customs and border to detain at least one student, who is facing
>>>>> federal criminal charges for smuggling frog embryo slides before her
>>>>> eventual deportation.
>>>>>
>>>>> This is just a reminder in the current climate that all paperwork must
>>>>> be accurate and submitted well in advance for all wildlife transactions
>>>>> into and out of the US. As Dirk mentioned in a followup, it is much
>>>>> preferred to *send parcels into the US via private carrier* and
>>>>> not through national postal mail. Offices in NY are particularly intense
>>>>> right now and are screening packages entering via USPS from Europe and
>>>>> China. And for anyone entering with hand-carried specimens into LAX
>>>>> airport, they also require an in-person 3-hour scheduled meeting with USFWS
>>>>> officers to clear your hand-carry. If you schedule ahead there is a good
>>>>> chance officers will waive your inspection, but failure to schedule will
>>>>> result in seizures and possible detention. If your flight arrives after
>>>>> hours you are required to pay overtime fees for this inspection, or
>>>>> schedule your meeting during business hours.
>>>>>
>>>>> Hope this helps,
>>>>> Chris
>>>>>
>>>>> Christopher C. Grinter
>>>>> Senior Collection Manager of Entomology
>>>>> Secretary, The Lepidopterists’ Society
>>>>> Subject Editor: Lepidoptera, The Pacific Coast Entomological Society
>>>>> California Academy of Sciences
>>>>> 55 Music Concourse Dr
>>>>> San Francisco, CA 94118
>>>>> T 415.379.5320
>>>>> We regenerate the natural world through science, learning, and
>>>>> collaboration.
>>>>> Learn more at calacademy.org
>>>>> <https://url.avanan.click/v2/r01/___http://www.calacademy.org/___.YXAzOmNhbGFjYWRlbXk6YTpnOmEyZWE3OTU2MmY0YzMyYzhjNWNjYWFjZTQ1NWZiMjU2Ojc6NWIzNDo2NmFmYmE0MWEzMTQwZTg0NmM3M2FiZjYwNmFkMDUyNWQ0NzYyYTkyNjZkOWQ1MTkxMWIyOTEwOTBmOTliMmIyOmg6VDpO>
>>>>>
>>>>> <https://url.avanan.click/v2/r01/___https://www.instagram.com/calacademy/___.YXAzOmNhbGFjYWRlbXk6YTpnOmEyZWE3OTU2MmY0YzMyYzhjNWNjYWFjZTQ1NWZiMjU2Ojc6MGM5YjozNTMyMjhhYWQyOTM0MDkyZjdlMmIwOTBhN2M5YWVkYjE5NzJiYWY4MzY5ZTc2YjY3ODdlYjczYjRiMzM0NDZkOmg6VDpO>
>>>>>
>>>>>
>>>>> On Mon, Apr 21, 2025 at 1:54 PM Chris Grinter <cgrinter at calacademy.org>
>>>>> wrote:
>>>>>
>>>>>> Hi all,
>>>>>> I want to give everyone a warning that the NY USFWS office has been
>>>>>> seizing packages that do not contain pre-cleared 3-177 documents. I've just
>>>>>> received an official notice of seizure for a loan that came back from China
>>>>>> (via NY for some reason). The package was clearly labeled with a
>>>>>> declaration of specimens, loan for systematic research, etc—however the
>>>>>> agents at JFK seized the material as a violation of the Lacey Act, failure
>>>>>> to mark appropriately (lacking 3-177 is how I interpret this), and failure
>>>>>> to obtain clearance. The package was intercepted in September 2024 and I
>>>>>> got notice today. No one at the NY office will pick up the phone or return
>>>>>> my messages.
>>>>>>
>>>>>> If you're receiving material from anywhere abroad it's critical to
>>>>>> get a pre-cleared 3-177 and keep a close eye on the tracking number.
>>>>>> Unfortunately if a package is seized by USFWS there is no update posted to
>>>>>> USPS, it just shows as "in transit".
>>>>>>
>>>>>> Chris
>>>>>>
>>>>>> Christopher C. Grinter
>>>>>> Senior Collection Manager of Entomology
>>>>>> Secretary, The Lepidopterists’ Society
>>>>>> Subject Editor: Lepidoptera, The Pacific Coast Entomological Society
>>>>>> California Academy of Sciences
>>>>>> 55 Music Concourse Dr
>>>>>> San Francisco, CA 94118
>>>>>> T 415.379.5320
>>>>>> We regenerate the natural world through science, learning, and
>>>>>> collaboration.
>>>>>> Learn more at calacademy.org
>>>>>> <https://url.avanan.click/v2/r01/___http://www.calacademy.org/___.YXAzOmNhbGFjYWRlbXk6YTpnOmEyZWE3OTU2MmY0YzMyYzhjNWNjYWFjZTQ1NWZiMjU2Ojc6OTc1ZjpiNzY0NzA1NjQ0NmI4YzBlNjc4MTBjMDMzNWM2ZTA5YTNmOTU0MThjODBmMTJlOTFmOTU5ZGVlODk4YjQ3MTUxOmg6VDpO>
>>>>>>
>>>>>> <https://url.avanan.click/v2/r01/___https://www.instagram.com/calacademy/___.YXAzOmNhbGFjYWRlbXk6YTpnOmEyZWE3OTU2MmY0YzMyYzhjNWNjYWFjZTQ1NWZiMjU2Ojc6MTA5MzoxM2RkYzE4ZGQxODA0ZmE2MmIwZjY3ZGQwNjA2MjgwYzc4OWEzZTU2NTI2NjU2NTc2YTUxMDRjNjhiOWNiMmMzOmg6VDpO>
>>>>>>
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>>>>>
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>>>>
>>>>
>>>> --
>>>> Timothy J. S. Whitfeld, PhD
>>>> Collections Manager
>>>> Bell Museum Herbarium (MIN)
>>>> University of Minnesota
>>>> 1445 Gortner Avenue
>>>> St. Paul, Minnesota 55108-1095
>>>> USA
>>>> (612) 625-0215
>>>>
>>>> https://www.bellmuseum.umn.edu/plants/
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>> NHCOLL-L is brought to you by the Society for the Preservation of
>> Natural History Collections (SPNHC), an international society whose
>> mission is to improve the preservation, conservation and management of
>> natural history collections to ensure their continuing value to
>> society. See http://www.spnhc.org for membership information.
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> natural history collections to ensure their continuing value to
> society. See http://www.spnhc.org for membership information.
> Advertising on NH-COLL-L is inappropriate.
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-- 

*Benjamin M. Hess | EEB Museums Registrar | **EEB Museums Safety
Representative to the RMC *

University of Michigan | LSA Ecology & Evolutionary Biology | Research
Museums Center

3600 Varsity Drive, Ann Arbor MI 48108-2228

bmhess at umich.edu | 734-764-2432
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