NCBFAA Submits Comments to APHIS on Lacey Act


In comments submitted to the Federal Register, NCBFAA RAC Committee Chairman Michael Lahar expressed support for the Animal and Plant Health Inspection Service’s proposal to create an exception from the Lacey Act declaration requirement for products containing a minimal amount of plant material, commenting that “when….products are highly processed and incorporate small amounts of plant material, combined with many other non-plant inputs, the importer cannot realistically provide meaningful information as to the specific identity of an incorporated harvested plant.”


As to the method for determining if the exception applies, NCBFAA urged the agency “to adopt an approach that is simple and straightforward, allowing importers to choose a method established by APHIS (whether based on weight, volume or value) most appropriate for their product and which can be readily and cost-effectively determined.” Lahar added, “After all, the exception will be of little value if it is too complex and costly to implement.”


NCBFAA disagreed with APHIS’ broadly worded definition of “import” and its proposed 3-day deadline for submitting the Lacey Act declaration, advocating instead that the agency align its definitions and deadlines with customs requirements to facilitate “a more uniform and efficient submission of Lacey Act declarations.”


The complete letter can be found here.


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