[Nhcoll-l] USFWS seizure of imports
Trina Roberts
troberts at nhm.org
Wed Jun 25 15:55:41 EDT 2025
A group of staff from the Natural History Museum of LA County met with a
senior USFWS inspector in the LAX office last week to help get us in
compliance with their current procedures and interpretations. This was
very informative! Key points below, with the caveat that the guidance we
received may be specific to this office or, in some cases, even to this
inspector. I think, though, that what we heard reinforces what others are
saying, that our USFWS colleagues are under a lot of scrutiny and that
what's been OK in the past may no longer be acceptable.
Here's what we were told:
- Do not use the US Postal Service. USPS does not have secure
inspection locations and a secure chain of custody.
- Do not try to use the "180 days" regulation to delay filing an eDec.
File all eDecs in advance.
- Do not try to use "taxonomic or systematic research" as a reason not
to file an eDec, or not to file in a timely manner. The Service
interpretation of specimens being used for taxonomic research is that they
have not yet been identified. If that is the case, you should file an eDec
anyway, it just changes how you enter the information.
- Do not use the generic "NONCITES WHATEVER" codes in the species lines
on the eDec if you have at least a genus name for the specimen. List every
species and every country of origin accurately. If the species or genus is
not in their database, type it in and let the eDecs system fill in "****"
for the species code. Use the generic codes only if the specimen really
has not yet been identified. We were told that this is supposed to be a
Service-wide change that has not yet been implemented everywhere.
- For exports (this is partly specific to our workflow and port but
perhaps still informative), file the 3-177 once the shipping label is
created and you have a tracking number. Once FedEx picks up the package,
call the office (if there's no answer, email) and they will clear it. They
will not clear the eDec while the package is still in the museum's
custody. This is a change from previous guidance.
- For exports with CITES, ESA, MBTA, MMPA, etc, make an inspection
appointment. (If you know you need an outgoing package inspected in LA and
need the link to their inspection appointment system, email the office.
They won't necessarily send it to you just because you've filed an eDec.)
Do this in advance as inspectors are not always available. Exactly how,
when, and where the inspection happens may depend on the details and the
individual inspector.
- For imports (this may be LAX-specific), file at the latest before the
package gets to Customs. If they know a package needs clearance it will
get held up at the border. If they don't know and it gets through, and you
file the eDec after you receive it, if it came in through LAX they will be
very unhappy with you (most imports don't come through LAX... but some
do).
- If you do receive a surprise package that has not been cleared (again,
at LAX; this guidance may differ for other ports), do not open it. Call
the office (don't email) and tell the duty inspector what happened and that
you're filing your eDec after the fact. The duty inspector should be
available from 8-12 and 1-4:30. They will tell you if any other action is
needed. From their perspective, we, as the importer, are responsible for
the eDec.
- If hand-carrying specimens is necessary, contact the port of entry
well in advance and ask for guidance. You may need to adjust your schedule
to theirs, wait for an inspection, and/or pay overtime fees. If you are
hand-carrying make very, very sure that all of your personal and specimen
documentation is in order.
- We were told that we need to provide the Customs Entry Number (or
Customs Document Number) on the eDec. We have never before had to provide
this information on our eDecs and are still figuring out how and when we
would be able to get this number. Are other ports requiring this? Be
aware that if you are importing through LA you may be asked for this and
may have to get the number from your carrier.
- We were told not to guess at the likely port of clearance for imports
based on the carrier -- that is, don't just put Memphis for all FedEx
packages. Find out from the carrier what the correct port is. I haven't
figured out yet whether this is possible or when/how we would get this
information.
It was also recommended to us that we start having the carriers, who are
already acting as our customs broker, file the eDec on our behalf. I am
looking into whether this would work for us and am curious whether any of
the rest of you have taken this approach. Given the amount of grief it's
causing us to file ourselves, the fees might be worthwhile.
Our USFWS colleagues are very invested in wildlife conservation and at
least in L.A. they clearly do understand that museums and scientists are a
positive force. By asking us to keep to the same procedures they've
established for commercial traffic, they're not trying to make things more
difficult for us -- merely trying to keep us from making things more
difficult for them.
Non-U.S. colleagues on this list, you can help us all a lot by spreading
the word in your own institutions that no one should send surprise specimen
packages to the U.S. (really, a good rule even without the need for an
eDec).
--Trina
--
Trina E. Roberts, Ph.D.
Associate VP, Collections
Natural History Museums of Los Angeles County
213-763-3330
troberts at nhm.org
she, her, hers
On Wed, Jun 25, 2025 at 10:45 AM 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
>
> 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
> <https://urldefense.com/v3/__http://www.calacademy.org/__;!!Ljrh0eb5atLX!pMkkB7U0o9TiyMiKlGLboMwSGbeAdr6sY_G-3UWHYObVwo_n2RYDf8kcmd7Ez8S-aSjDtx9L-kBO3-pgzzU$>
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>
>
> 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
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>>>>
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>>>>
>>>>
>>>> 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://urldefense.com/v3/__https://url.avanan.click/v2/r01/___http:/*www.calacademy.org/___.YXAzOmNhbGFjYWRlbXk6YTpnOmEyZWE3OTU2MmY0YzMyYzhjNWNjYWFjZTQ1NWZiMjU2Ojc6OTc1ZjpiNzY0NzA1NjQ0NmI4YzBlNjc4MTBjMDMzNWM2ZTA5YTNmOTU0MThjODBmMTJlOTFmOTU5ZGVlODk4YjQ3MTUxOmg6VDpO__;Lw!!Ljrh0eb5atLX!pMkkB7U0o9TiyMiKlGLboMwSGbeAdr6sY_G-3UWHYObVwo_n2RYDf8kcmd7Ez8S-aSjDtx9L-kBOWuMWNqc$>
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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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