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Permit Guidelines
Permit Basics – Importing Biological Samples Collected from Wildlife
International conventions, individual countries and governmental bodies have an array of permit requirements for work to be conducted on wildlife and for the transport of specimens or samples collected from wildlife. Legally, all samples not accompanied by the proper paperwork can be confiscated and destroyed. Fines and imprisonment are also possible for people illegally transporting samples. Generally speaking, government agencies are concerned about issues related to permission to conduct studies, trade or transport of legally protected species or parts thereof, and agriculture/livestock regulations. On this page, we can not provide a complete set of regulations for every country and every situation, but for bringing samples to the U.S. from other countries, please bear in mind the following:
THE NECESSARY PAPERWORK:
CITES and the USFWS
The Convention on Trade in Endangered Species (CITES) is an international treaty between many countries, designed to regulate transport and trade of endangered or threatened species. For Appendix I (endangered) species, CITES requires the importing country to issue an import permit and the exporting country to issue an export permit. In general, an export permit will not be issued until a valid import permit is presented to the office issuing the export permit. For Appendix II (threatened) species, only a CITES export permit is required. A database of CITES Appendix I and II species can be found at http://www.cites.org/eng/resources/species.html.
To obtain a CITES export permit from the country where the samples were collected, you must contact the country’s wildlife authority. This is often the same entity that would grant permission for wildlife research work to be conducted in the first place. Requirements for obtaining the CITES export permit vary from country to country.
To import wildlife samples into the United States, the U.S. Fish and Wildlife Service’s (USFWS) Office of Management Authority must issue a CITES import permit. In general, they require written proof of permission to conduct the work in the host country before an import permit will be issued. Typical time for processing a well-written application is four to six months. The permit application can be found at http://international.fws.gov/permits/dmapermits.html.
In addition, the USFWS maintains a list of endangered (ESA) species that, in some cases, varies from CITES Appendix I and II species. Any species listed by the USFWS as endangered, even if it is not classified so by CITES, also requires an import permit. The ESA list can be seen at http://endangered.fws.gov/wildlife.html#Species.
If a species is listed by CITES and ESA, only one application is required as long as the conditions for both are met. The U.S. Fish and Wildlife Service’s (USFWS) Office of Management Authority will issue one permit that covers both regulations.
The USFWS allows import of wildlife samples only at certain ports of entry, whether they be airports, harbors, or border crossings. A list can be seen at http://www.le.fws.gov/inspectors.htm. If at all possible, you must arrange for the samples or specimens to arrive at a designated USFWS port of entry. If this is not possible, you must apply for an additional permit, to arrange for a special designated port. The application can be found at http://forms.fws.gov/3-200-2.pdf. A simple application will take 6-8 weeks to process.
No matter what the species or what its status is (CITES I, II, ESA or not listed at all), all specimens or samples from wildlife must be “declared” to the USFWS at the port of entry. The declaration form (#3-177) and instructions for properly filling it out, can be found at http://www.le.fws.gov/faqs.htm.
The USFWS office at the Port of Entry requires notification of expected import, 48-hours prior to sample arrival.
The USDA
The US Department of Agriculture issues permits to import biological materials from birds, ungulates, and plants. Permits are also required for importation of parasites and materials potentially containing bacteria, viruses, or fungi, which may pose a threat to U.S. livestock or agriculture. In addition to an import permit, samples from these organisms usually require sterilization prior to importation onto the U.S. mainland. One method is to arrange for the samples to be picked up at the airport by a USDA courier and then irradiated at the USDA’s Foreign Animal Disease facilities on Plum Island. Fees are charged for this service. Another method of treatment is to preserve the specimens in formalin, or to heat-treat the specimens. Typical time for processing the simple application form is two to three weeks. You can apply for a permit here: https://web01.aphis.usda.gov/IAS.nsf/Mainform?OpenForm.
In a few instances, certain countries have been declared free of certain diseases affecting birds, ungulates, and plants. If you are importing specimens from those countries, you may not need a USDA import permit, or any sterilization for the samples. A list of these particular countries can be found at http://www.aphis.usda.gov/vs/ncie/country.html.
If there is any question at all whether your samples fall under USDA jurisdiction, what type of sterilization treatment is acceptable, or whether a particular country has been declared free of a certain disease, you should contact the USDA permit office with your questions. Any samples imported illegally pose a serious threat to wild and domestic animals and plants in the United States. More information and contact numbers can be found at http://www.aphis.usda.gov/vs/ncie/index.html.
Some international conventions require government reporting of diseases of human health or economic importance for livestock. Because of the economic and political ramifications of this fact, some foreign agriculture authorities may have restrictions on the exportation of samples for diagnostic tests. Additionally, the USDA requires written proof of permission for the samples to be tested by their laboratories. This written permission must come from the exporting country’s agricultural authority, which is often separate from the wildlife authority.
The USDA requires advance notice of arriving samples, to arrange for inspection and pick-up, if required.
Other Entities
U.S. Center for Disease Control (CDC): For public health reasons, the CDC issues the permit required for the importation of samples from non-human primates. The application can be found at http://www.cdc.gov/od/ohs/biosfty/gen_app.pdf.
Marine Mammal Commission (MMC): Under the authority of the U.S. Commerce Department, the MMC must approve any work involving U.S. based individuals working with marine mammals anywhere in the world, regardless of sample collection. Additionally, for work requiring the importation of samples, the MMC works with USFWS in the application review process for issuing import permits. More information can be found at http://www.nmfs.noaa.gov/pr/permits/mmpa_permits.htm.
Migratory Bird Treaty Act: An office of the U.S. Fish and Wildlife Service, the MBTA is the domestic law that affirms the United States' commitment to four international conventions for the protection of a shared migratory bird resource. The Act protects more than 800 species of migratory birds and generally prohibits the import/export of live birds, bird parts, nests, eggs and products made from them unless there is a permit. The permit application can be found at http://forms.fws.gov/3-200-6.pdf
AT THE PORT OF ENTRY:
In general, it’s best to have three copies of the following documents prepared and available for inspection upon arrival at the airport or other port of entry:
a) U.S. customs declaration form for duty free importation for non-profit or government organizations
b) USFWS import declaration form #3-177
c) CITES and/or ESA import permit (if applicable)
d) CITES export permit (if applicable)
e) USDA import permit (if applicable)
f) C.D.C. import permit (if applicable)
g) NOAA import permit (if applicable)
Declare the samples at Customs, and request that the Customs Agent call the USFWS inspector on duty, as well as the USDA inspector (if applicable). Have the USFWS inspector stamp one copy of the paperwork (declaration form, and import and export permits, if applicable) for you to keep. This documentation shows that you imported the samples legally, and can be important for future permit applications. Originals will usually be kept by the inspector(s). In some cases, USFWS may arrange for importation to be pre-cleared in lieu of inspection at the airport. In this case, show permits at port of entry to appropriate individuals and mail two sets to the USFWS inspector. Ask them to stamp one set as cleared and return to you for your records.
USFWS must be contacted and supplied the declaration form and other required paperwork, no other government agent at the port of entry has the authority to exempt you from obtaining clearance from USFWS.
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