Wood and plant goods into the US: who files the Lacey Act declaration, and which fields

Wednesday night the Los Angeles broker writes: “Need Lacey data tonight or we hold the entry. Scientific name + country of harvest, not ‘oak wood’.” The box is solid-wood dining chairs from Nankang. The contract seller is a Hong Kong company. The timber PO says “northeast oak / Vietnam rubberwood mixed.” The carton shows only the store’s English name. Sales attaches last week’s phytosanitary scan and a photo of a pallet with an IPPC mark, and replies “plant papers complete, Friday clearance.” The broker replies: that is not Lacey, and it is not the pallet stamp.

Thursday the plant sends a Chinese note that says “oak.” The broker asks again for genus and species, and for the country where each piece of wood was harvested — not the country where the chair was assembled. Sales sends the Alibaba.com master login “so you can read the product page.” The broker says ACE wants a scientific name; a showcase page will not fill that box. The forwarder then asks for a “Lacey certificate,” and says ISF cannot move without it.

Do not reply “we have a clearance channel; Lacey is in the freight.” Stop three things first: do not send the master login, do not retitle a phytosanitary scan or a pallet photo, and do not click a Trade Assurance release date that ACE has not accepted. Who the US importer is sits on the importer is not the forwarder. Wood-packaging marks sit on ISPM 15. The usable order is: name who may file, then whether this booking is on the current HTS schedule, then scientific name and country of harvest, then pallets, composites and bamboo, and only then what to stop if the filing is late or wrong.

Name the importer first: only the importer of record or their agent may file

APHIS writes the duty on the importer of record or their agent. A broker who files needs that importer’s power of attorney. The importer and the agent stand behind the accuracy of the declaration. A Hong Kong PI, a mainland chair line and a Shenzhen booking can sit on the same shipment and still leave no one who is automatically the Lacey filer.

Before sales answers the first mail, do not start with “who is cheaper for Lacey.” Ask the US side for three written sentences: the importer’s legal name on this booking; whether the broker holds that importer’s authorisation; and whether this filing goes through ACE or LAWGS. If those three sentences do not come back, do not write “we will file Lacey,” and do not send the plant to register an ACE account.

Membership wired to ALIBABA.COM HONG KONG LIMITED buys a showcase. APHIS and CBP cannot see that store, and will not register it as a filer. The contract seller is responsible for delivery and documents. That is not the same as being the US importer.

FOB and a nominated forwarder do not mean the declaration already has an owner. The nominated house books space and moves the bill. Whether they are the importer, an authorised broker, or only a messenger still needs their writing. Incoterms allocate freight. They do not sign the Lacey box.

Check the tariff first: is this booking on the current APHIS schedule?

Not every wooden article needs a declaration. APHIS writes that you file when all of the following apply: the product contains plant material; it is classified under an APHIS-listed HTS code; it is imported as a formal entry; and it falls under one of the listed entry types. You do not file this box if the goods are free of plant material, arrive in personal baggage or international mail, sit in a finished HTS code that is not listed, enter as an informal entry, will not remain in the United States, or meet the published de minimis exception.

APHIS restates CBP’s definitions: formal entries generally have an aggregate value of 2,500 US dollars or more and must be covered by a bond; informal entries are usually valued under that threshold and typically do not require a bond. APHIS writes that the value can change, and that some high-risk products cannot use informal entry regardless of value. Ask the broker which entry type this booking will use. Do not exempt yourselves in the group chat as “samples” or “e-commerce parcels.”

APHIS’s de minimis exception is not CBP’s value-based de minimis. Plant material that is no more than five percent of the weight of the individual product unit, and whose total plant weight in the same ten-digit HTS provision on that entry does not exceed 2.9 kilograms, can sit outside the declaration — unless the plant is listed in a CITES appendix, under the Endangered Species Act, or on a state conservation list. When the exception applies in ACE, APHIS writes that disclaimer code G may be used. A low invoice value is not, by itself, a Lacey waiver.

Whether the HTS code is on the table follows the current APHIS implementation schedule. Do not copy last month’s dining-chair file onto this upholstered sofa. Furniture, cork, tools with wooden handles, and bags or footwear with plant parts may sit in later phases. If the broker cannot name a ten-digit code, stop the draft. Do not trade a “wood / furniture” line for a receipt.

What the seller hands over is a scientific name and a country of harvest, not the word “oak”

APHIS lists the information: scientific name (genus and species) of any plant in the shipment; description; value; quantity of the plant in published metric units; the country from which the plant was taken; importer and consignee name and address; HTS; bill of lading; container number; manufacturer identification code; and a contact for the importer or their agent. Do not invent an “official twelve-box form.” Tick the broker’s list for this booking.

What Hong Kong sellers usually hold, and what brokers most often lack, comes in four groups. Plant identity: genus and species for each solid piece, veneer, rattan or cork, in Latin, not “oak” or “Southeast mixed wood.” Place of harvest: the country where the plant was taken, not the country of assembly. A chair finished in Nankang from logs harvested in Russia or Vietnam writes the harvest country, not “China” as a default. Quantity: kilograms, cubic metres, square metres — APHIS names piece, count and board feet as invalid. Value: a figure that can match the commercial invoice. Do not invent a second “entry price.”

When the species varies and the exact species is unknown, APHIS requires every species that may have been used. When the plant is commonly taken from more than one country and the exact country is unknown, list every country it may have come from. “Mixed wood” will not do. For composite, recycled or reused material, after due care, APHIS’s special-use designations may apply; a thin solid-wood veneer does not meet the SPECIAL COMPOSITE type. If you know the species, write the real name.

APHIS points filers to GRIN, PLANTS, ITIS and IPNI for scientific names. If the plant PO only has a Chinese trade name, go back to the sawn-timber supplier for the Latin name and the harvest country. Do not let sales guess a genus from an encyclopedia. Keep the goods description on the same words as the export document checklist, the invoice and the packing list.

Several woods in one chair is the usual Nankang or Shunde break. An oak seat, rubberwood legs and another veneer do not collapse into one line of oak. The broker wants a scientific name and a harvest country for each plant part. The plant splits the bill of materials by part: part name, supplier, Latin name, harvest country, quantity on this booking. If the supplier will only write “northeast hardwood,” send it back that day. Do not let sales invent a genus to buy a receipt.

Manufacturer identification code sits on APHIS’s information list. Brokers usually build it from the manufacturer’s legal name and address. What the seller hands over is the factory’s legal name and address, not a store name or a forwarder warehouse. Container number and bill of lading should match ISF and the commercial invoice. Several boxes on one booking report plant quantity per container. Do not add four boxes into one line of “mixed hardwood 2000 kg.”

The mail to the sawn-timber house is a full sentence: “This booking of dining chairs contains plant material. The US importer must declare scientific names and countries of harvest to APHIS. Please write, for this lot, the Latin genus and species of the seat, the legs and the veneer, and the country where each log was taken. If the species is uncertain, list every species that may have been used. If the country is uncertain, list every country it may have come from. Use cubic metres or kilograms. A Chinese trade name or ‘mixed wood’ is not enough.” When the supplier sends a PDF, check the letterhead and the company name. Do not accept a WeChat image with no title.

ACE or LAWGS: paper 505 is no longer the routine door after 1 January 2026

APHIS writes two routine doors. One is CBP’s ACE, using the Lacey Act message set — the primary path. Most formal entries ride with the broker’s entry package. The other is APHIS’s LAWGS website, for importers or agents who prefer not to file in ACE, and for foreign-trade-zone importations that ACE does not yet cover. If customs data go through ACE and the Lacey declaration goes through LAWGS, mark disclaimer code C in ACE.

APHIS writes that as of 1 January 2026 it no longer accepts routine paper PPQ 505 or 505B. Paper is only a possible path in an emergency, and only with prior APHIS approval. Do not stuff a completed 505 into the packing list and tell the buyer it has been mailed. CBP’s older guidance still mentions paper; use APHIS’s current “how to file” page.

APHIS writes that you should file when the shipment lands in US jurisdiction; most importers file the ACE message set before arrival. If you missed it, write lacey.act.declaration@usda.gov with the number of missing declarations, the entry numbers and the arrival dates. APHIS will discuss a fix, which may include a late LAWGS filing. Do not mail an expired paper form on your own, and do not promise “it will clear before arrival.”

Do not staple ISF’s ten elements, FDA Prior Notice, the export declaration and a phytosanitary scan into one “US plant pack.” Those filings may share a goods description and a weight. One retitled receipt will not fill the Lacey box. Food into the US sits on FDA Prior Notice.

Pallets, composites and bamboo: do not merge them with phytosanitary or ISPM 15

Plants used exclusively as packaging to support, protect or carry another item sit outside the declaration, unless the packaging itself is the imported article. New wooden products in HTSUS 4415 that formally enter as merchandise need a declaration. Used, recycled and reclaimed 4415 wooden products, empty or under load, used to carry imported goods, sit outside as APHIS writes. The solid seat of the Nankang chair needs a declaration. The old pallet under the box follows the packaging exception, and still needs its ISPM 15 mark.

Bamboo: cultivated bamboo planted for commercial harvest does not need a declaration, APHIS writes. Bamboo taken from wild stands, or bamboo whose source you cannot tell, still needs a declaration if the HTS code is on the schedule. The plant must still have been legally harvested. “Bamboo is not wood” is not a waiver.

Common cultivars and common food crops, scientific specimens for lab or field research only, and plants that will remain planted or will be replanted sit on APHIS’s “no declaration” list — unless the material is protected. Protected means a CITES appendix, the Endangered Species Act, or a state or foreign law that protects plants.

A phytosanitary certificate is whether the destination NPPO wants a plant-health paper on the goods, see who applies for phytosanitary. ISPM 15 is the mark on wood packaging. Lacey is the importer’s declaration to APHIS about plant origin. Three papers can sit on one booking. Who applies, whose name is on the paper, and which system accepts it are not the same errand.

An upholstered sofa may only have a wood frame and wood feet; the cover is synthetic. The whole booking can still sit on the schedule — APHIS looks at the finished HTS code, not at “how much plant you can see.” If the code is listed and the entry is formal, file the scientific names for the plant parts. Do not say “all you see is fabric, so we skip it.” Conversely, if the finished code is not listed, a plant extract in the glue can sit outside this box, APHIS writes — unless the species is protected.

Paper, paperboard, particleboard, MDF and HDF are composites: the original plant was broken down mechanically or chemically and recomposed. Use SPECIAL COMPOSITE only after due care still cannot name the species. If one layer is a known solid-wood veneer, that layer still writes the real name. Do not write SPECIAL COMPOSITE across a whole table and hide a solid-wood edge.

Online retail and small orders into the United States: APHIS’s example is that a listed HTS code, a formal entry and a listed entry type still need a declaration. A low value that CBP treats as informal sits outside APHIS’s current enforcement of this box — still use the entry type the broker names on this booking. Do not exempt yourselves in the group chat as “Amazon fulfilment.”

When the forwarder wants a “Lacey certificate” or the master login

Lacey is filed in ACE or LAWGS, not in the Alibaba.com admin. Sending the master login will not complete a scientific name. It only adds another person who can open the store. Membership wired to ALIBABA.COM HONG KONG LIMITED still only buys a showcase.

If the forwarder wants an “official Lacey certificate,” or wants you to hang ACE yourselves, stop. The duty sits on the importer or their agent. A Hong Kong seller with no US importer identity who files anyway will put the wrong person on the message. Most factories hand over the fields and let the importer’s side file.

Sales writes a full sentence: “APHIS requires a plant and plant-product declaration, filed by the importer of record or their agent through ACE or LAWGS, for formal entries of plant material on the current implementation schedule. Please confirm in writing the importer’s legal name on this booking, whether the broker holds that authorisation, and whether this filing is ACE or LAWGS. As contract seller we can supply scientific names, country of harvest, metric quantity, value, and a matching invoice and packing list. We will not send the store master login. Membership buys a showcase. It is not a filing with CBP or APHIS.”

Do not write: “here is the master login,” “the phytosanitary equals Lacey,” “the pallet is fumigated so we are done,” “we will pay the official fine, just put oak,” or “we are mailing a paper 505.” Those last lines break both the channel and the fields.

If the name does not match, or the filing was missed: what sales and the plant stop

CBP reminds filers that false or misleading information to the US government can bring civil or criminal action and may lead to seizure and forfeiture. Outcomes follow the current statute and enforcement notices. Do not write a chat-room dollar figure into the PI, and do not write “Lacey fines are in the unit price.”

What sales stops that day is the external promise. Stop: Friday clearance, Lacey complete, an official plant fee in the unit price. Do not stop: asking the plant and the sawn-timber supplier for Latin names and harvest countries; asking the buyer for the importer’s legal name; asking the broker for the entry type and the ACE or LAWGS acknowledgement. Do not click a Trade Assurance “released” node before the broker confirms the entry package was accepted.

What the plant stops that day is any move that locks the cargo to the wrong species. If the scientific name is still open, do not send unlocked seats to the terminal. Do not print Lacey / APHIS / cleared on the carton. Do not split the same solid wood into a second “sample” booking — APHIS looks at the formal entry’s HTS and plant content, not at your internal sample label.

Finance deletes “official Lacey fee” and “APHIS official charge” from the unit price that day. There is no site-wide official price. A broker’s document fee on this booking belongs in the clearance breakdown. A change of vessel, a shut-out, or a reclassified HTS cannot reuse the old entry number by changing the title. New HTS, new species list, new filing. The old PDF is dead.

In the contract and the PI, delete “seller handles all US Lacey and clearance,” “the Hong Kong company is registered with APHIS,” “Lacey fines are in the unit price,” and “store verification equals Lacey.” Write: the Lacey Act declaration is filed by the US importer or their agent through ACE or LAWGS; the seller supplies scientific names, country of harvest, metric quantity and value on this booking; whether the HTS code is on the schedule follows the current APHIS table; handling follows current notices; the unit price does not lock a dollar penalty. Do not print “Lacey certified” on the showcase. You may say the seller is a Hong Kong company, the plant-origin declaration is filed by the importer, and the seller supplies fields per booking.

If the inquiry says “shipper will provide Lacey certificate,” copy that sentence into an attachment and add: the filer is the importer or their agent, not the showcase name; what the seller supplies is a scientific name and a country of harvest, not a certificate for sale. Empty words become a who-pays fight after a hold. Do not reply “the factory will handle it.” The factory is not automatically the filer.

1. That day, get in writing: the importer’s legal name, whether the broker holds authorisation, ACE or LAWGS, and whether the ten-digit HTS is confirmed on the schedule.
2. The same day, the plant and the sawn-timber supplier hand over Latin names, country of harvest and metric quantity for every solid or plant part. Unlocked species do not go to the terminal.
3. Until the broker confirms ACE or LAWGS accepted the declaration, sales does not click Trade Assurance released and does not write a Los Angeles pickup date.
4. Pallet photos and phytosanitary scans go in the packaging folder, not in the Lacey folder as a fake receipt.
5. Cartons and invoices do not say Lacey certified. Membership receipts do not go into the broker pack.

A booking that mixes finished solid-wood goods and new wooden cases imported as merchandise needs two questions for the broker: is the finished HTS on the schedule; are the new 4415 cases merchandise on this booking. Old pallets follow the packaging exception. New cases sold as goods do not share one “pallet already fumigated” photo. Sales puts the two files in separate folders for the broker: one plant table for the finished goods, one for the packing sold as merchandise.

Instruments, cork stoppers, tools with wooden handles, bags with plant parts — inquiries often say “not furniture, so no Lacey.” Check the finished HTS first, then the entry type. Listed and formal means file. Unlisted means look at protected species next. Do not replace APHIS’s table with a spoken product category.

A buyer-nominated US warehouse, overseas warehouse or platform warehouse often refuses to be the importer and still asks the factory to “finish Lacey.” Split the sentence that day: the filer is still the importer or their agent; the factory hands over scientific names and harvest countries; who is the importer sits on the importer page. Do not put a warehouse address in the filer box. A warehouse consignee is not the importer of record.

Corpable can sit with you on whether this booking is on the current schedule, which scientific name or harvest country is still empty, and whether the pallet is a different errand. We do not file in ACE or LAWGS, do not become the importer or the broker, and do not guarantee release at a US port. Membership still goes to ALIBABA.COM HONG KONG LIMITED.

Questions teams actually ask

Related reading

• The buyer wants a phytosanitary certificate
• ISPM 15 marks on wood packaging
• The US importer is not the forwarder
• US ISF: the clock faces loading
• Contact Corpable · info@aliad.hk

Written by Corpable Marketing Limited for Alibaba.com Hong Kong-channel sellers. Not legal, tax, or audit advice. Platform, customs, bank, and auditor outcomes follow the latest official notices. Membership fees go to ALIBABA.COM HONG KONG LIMITED. Corpable does not collect them.