[Nhcoll-l] USFWS seizure of imports
Timothy Whitfeld
whitf015 at umn.edu
Wed Jun 25 18:00:51 EDT 2025
Thanks for all the information, Ben. This is very useful.
Sincerely,
Tim
On Wed, Jun 25, 2025 at 2:02 PM Benjamin Hess <bmhess at umich.edu> wrote:
> 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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>>>>>> NHCOLL-L is brought to you by the Society for the Preservation of
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>>>>>> <https://url.avanan.click/v2/r01/___http://www.spnhc.org___.YXAzOmNhbGFjYWRlbXk6YTpnOmEyZWE3OTU2MmY0YzMyYzhjNWNjYWFjZTQ1NWZiMjU2Ojc6ODMzNjo1NjVmYWYyODgzNTUyZjgwN2Y0YzAxMjZkYzMyZjgzYTY2NDZhMmUwMDEzNThlNTFmM2Q0ZWNkN2U5NzQ3NGFkOmg6VDpO>
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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/
>>>>> <https://url.avanan.click/v2/r01/___https://www.bellmuseum.umn.edu/plants/___.YXAzOmNhbGFjYWRlbXk6YTpnOmEyZWE3OTU2MmY0YzMyYzhjNWNjYWFjZTQ1NWZiMjU2Ojc6ZDhiMjozNDUwMjdkODA3ODg0NDEzMzQ0MTMyZjNmMDZiMGUxMDM5MDM1Y2VhMTMwMWUwNDYyYTZhYmVjODlhNTIzMTk2Omg6VDpO>
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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
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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.
>>> Advertising on NH-COLL-L is inappropriate.
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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.
>> Advertising on NH-COLL-L is inappropriate.
>>
>
>
> --
>
> *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
>
>
> _______________________________________________
> Nhcoll-l mailing list
> Nhcoll-l at mailman.yale.edu
> https://mailman.yale.edu/mailman/listinfo/nhcoll-l
>
> _______________________________________________
> 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.
> Advertising on NH-COLL-L is inappropriate.
>
--
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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