NAMM Prepares for Updates to Lacey Act and CITES Regulations

NAMM Policy Program Manager Claire Kreger-Boaz attended the World of Wood Convention in San Diego, CA, April 9–12, 2024, on a mission to gather the latest information on Phase VII of the Lacey Act and upcoming CITES discussions scheduled for this July as well as to strengthen the relationships NAMM and its partners have forged with regulatory and enforcement agencies. The IWPA’s annual convention convenes the globally sourced wood products industry. With 300 importers, U.S. manufacturers, exporters, wholesalers, offshore suppliers and service providers attendees get critical market insights and business changing intelligence.

Meetings with key stakeholders during the convention included:

• APHIS (Animal and Plant Health Inspection Service, a division of the USDA)

• Department of Homeland Security

• U.S. Fish and Wildlife

• International Wood Products Association (IWPA)

On Friday, April 12, NAMM hosted C.F. Martin & Co. Procurement Manager Albert Germick, APHIS National Policy Manager (Lacey Act) Erin Otto and APHIS General Natural Resources and Biological Sciences Manager José Granada for an in-depth discussion that delved into the nuances of education, compliance and enforcement for NAMM members navigating the regulatory maze as the next phase of Lacey Act compliance looms this fall.

NAMM underscored that our members remained at the forefront of responsible practices and emphasized its leadership through working groups and a shared sustainability vision despite challenges, such as labor shortages, post-pandemic supply chain and shipping disruptions.

In conversations with IWPA Executive Director Ashley Amidon, we learned of a grant facilitated by APHIS that, in partnership with IWPA, provides access to invaluable Lacey Act compliance training at no cost to NAMM members through September 2024. This vital partnership allows members to capitalize on this resource, ensuring their operations align with regulatory mandates while upholding their commitment to environmental stewardship. This training is a significant step towards empowering our members to navigate the next phase of an evolving and complex regulatory landscape with confidence.

Draft Lacey Act Phase VII list of Harmonized Tariff Codes (HTC) for Import Declaration

Chapter 42

     4202925000 – musical instrument cases

Chapter 45

     4501 & 4502 – cork

Chapter 85

     851821 – loudspeakers

     851822 – multiple mounted loudspeakers

     853810000 – boards, panels, consoles, cabinets

     854370918 – amplifiers

     8543709820 – special effects pedals for use with musical instruments

Chapter 92

     92059012 – keyboard pipe organs

     92059014 – harmoniums or similar

     92059015 – piano accordions

     92059018 – accordions or similar

     92059019 – mouth organs

     92099180 – other musical instrument parts (seeking clarification)

     92099905 – metronomes, tuning forks, pitch pipes

     92099910 – mutes for instruments, pedals, dampers and spurts for drums; pedals and holders for cymbals,                               lyres and other music holders for attachment to musical instrument; collapsible stands 

     92099961 – parts for music boxes

APHIS expects its review of the newly added HRTs to be complete before the fall of 2024. Once the final list is posted in the Federal Register, industries will have 60 days to file comments and six months to comply with the new listings. NAMM will be following closely and will keep members apprised of when the “clock” starts ticking toward the compliance deadline. However, we strongly encourage affected members to prepare for Phase VII of the Lacey Act Declaration in advance by reviewing their supply chain and taking advantage of the IWPA’s Lacey Act on-demand training modules.