NAMM Lacey Update: declaration form comment, advocacy update; Lacey compliance webinar May 18
NAMM Lacey Update – declaration form comment, advocacy update
Over two years have passed since implementation of the 2008 amendments to the Lacey Act and one year has passed since enforcement of Lacey Act Import Declaration requirements on all shipments of imported pianos and other stringed instruments (e.g., guitars and violins). Many questions continue concerning compliance and the impact of these regulations especially for vintage guitar dealers and small-shop guitar makers.
Review the attached formal comment that NAMM offered on April 14 via a public comment period from the Animal and Plan Health Inspection Service (APHIS).
Since the amendment of 2008, NAMM has advocated and achieved the finally following adjustments to compliance – work continues:
1. NAMM is active participant in broad business coalition seeking to contain fallout from Lacey Amendments.
2. As part of business coalition, NAMM negotiated two Consensus Statements with environmental groups pointing out problems with law and needed changes.
3. Persuaded APHIS to phase in import declaration requirement to cover only pianos and stringed instruments for the near future.
4. Persuaded APHIS to issue guidance providing for easier completion of import declarations for pre-2008 products.
5. Persuaded APHIS to exclude need for import declarations for so-called "informal entries," i.e., those with value less than $2500.
6. NAMM continues to press APHIS for additional modifications to import declarations.
Lacey Compliance Update Webinar, May 18
Enforcement and implementation of the Lacey Act, especially the requirement that imported wood and certain plant materials be accompanied by a declaration, has been a work in progress. The Animal and Plant Health Inspection Service ("APHIS") has requested public Comment several times on implementation of the 'new' Lacey Act (including a Comment period ending April 14, 2011); APHIS issued "guidance" several times clarifying requirements for certain "special cases" of imports based on those cases; the first cases of enforcement of the Act have surfaced; and we expect more changes to come.
Ensuring that you and your company are educated about these developments and are in compliance with the most up-to-date requirements under the Lacey is not only a good legal decision, but also a good business decision. Proper completion of import declarations in line with the most recent US government guidance can save you time and money by avoiding unnecessary delays on your imports and potential exposure under the penalty provisions of the Lacey Act.
Carrie Kroll of the Venable law firm who practices international trade and advises music manufacturers on Lacey Act issues, and Jim Goldberg of Goldberg Associates who has supported NAMM Member efforts on wood import regulations for the past several years, will lead this Lacey Compliance Update webinar.
Please join NAMM for a “Lacey Update Webinar” on May 18, 2011, 12 noon EDT to update its members on these recent developments.
Topic: Lacey Act Update
Date: Wednesday, May 18, 2011
Time: 12 noon, Eastern Daylight Time (New York, GMT-04:00)
Meeting Number: 805 008 829
Meeting Password: Wood
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Developments in Compliance and Enforcement under the Lacy Act.
Download the Power Point Presentation