On August 23, 2007 revised Fish and Wildlife CITIES Regulations were published in the Federal Register with an effective date of September 24, 2007. http://www.fws.gov/policy/library/07-3960.pdf
A Fish and Wildlife Service Public Notice appeared on their website on September 18th which attempted to highlight the changes in this 93-page revision. http://www.fws.gov/le/PubBulletins/PB09182007RevisionCITES.htm
It is important that your clients importing Fish and Wildlife CITES animal products fully understand these new requirements to avoid delays and possible seizure of improperly documented shipments. We have confirmed that at least two countries, Zimbabwe and Argentina, continue to utilize CITES Permit Forms that do not meet the sample CITES Permit Form published on the CITES site http://www.cites.org/eng/res/12/12-03R13a2.pdf. There is no box 5 or 5a on the current ZW and AR forms. These countries must determine at what point, on their current form, their Management Authority will agree to affix the proper Purpose Code, and then what kind of stamp from the Management Authority would be affixed over or near it so the indication is legible.
We have been told, but cannot confirm, that a “Chief’s Memo†was internally issued by FWS that will provide for a grace period through April 2008 for these out of date forms. Many countries claim not to have been notified about the U.S. changes.
One of the major changes is the definition of Hunting Trophies. Separate permits are now required for “H†Hunted Trophies, and “P†Personal for articles made-up from the hunted trophies.
All CITES permits will require completion of Box 14 which indicates export endorsements to include the bill of lading number as well as the actual piece count of the animal products. This will become mandatory by April 2008.
Off the record we are being told FWS will impose specific time frames prior to the April 2008 mandatory implementation. First, there will be a period of warnings issued, which will change to mandatory export, then finally seizure.
Carol Rutkowski