Commercial Import Checklist: Framed Entomological Art Shipment to the U.S.

This comprehensive document serves as an actionable guide for initiating your international shipment and integrating regulatory compliance into your business plan. It includes critical forms, specific data points for prefilling, and links to necessary resources.

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I. Pre-Shipment Documentation & Supplier Requirements

The following documents must be secured from your international supplier and included with the shipment paperwork:

Requirement	Purpose	Key Details	Citation
1. Commercial Invoice	U.S. Customs and Border Protection (CBP) Duty Assessment.	Must accurately list product, value, country of origin, and the Harmonized Tariff Schedule (HTS) code 9705.21 (Specimens of insects).[1] This code usually results in a 0% import duty rate.[2]	[1, 2]
2. Ethical/Sourcing Declaration	USDA APHIS clearance for biological risk.	A letter on the producer’s letterhead declaring that the specimens are dead, dried, or preserved insects and are not considered pathogenic for livestock or poultry.[3] This is essential for utilizing the USDA dead specimen permit exemption.[4, 3]	[4, 3]
3. Export Permit (Conditional)	Compliance with country of origin wildlife laws.	If the specific species is protected under local conservation laws (even if non-CITES), the supplier must obtain an export permit or required authorization from their government.	[5]
4. Exclusion of Contaminants	Mandatory for USDA permit exemption.	The supplier must ensure the framed product contains NO plant material, NO soil, and NO unauthorized plant pests.[6, 1] The finished, sealed product format inherently helps mitigate this risk.	[6, 1, 3]

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Sample Letter: Supplier’s Ethical/Sourcing Declaration

This letter must be on the **supplier’s official letterhead** and must accompany the commercial invoice to satisfy USDA APHIS requirements for the **dead specimen exemption**.[3] Ensure the letter is **dated** and includes a **wet signature or official stamp**.

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II. U.S. Importer & Customs Broker Actions (Immediate)

These steps must be initiated immediately, as several require advanced notification to U.S. authorities.

Step	Action Required This Week	Compliance Agency/Fee	Citation
1. File USFWS Form 3-177	MANDATORY. Electronically file the Wildlife Declaration Form (Form 3-177 PDF Link) via the USFWS eDecs system (requires a Login.gov account).	U.S. Fish and Wildlife Service (USFWS)
2. Notify Port of Entry	CRITICAL for clearance speed. You or your broker must contact the USFWS office at the specific designated port where the shipment will enter the U.S.	USFWS	[7]
3. Coordinate Inspection	Notify the USFWS agent at least seven days in advance of the shipment’s expected arrival date.[7] This is the best practice for coordinating clearance.	USFWS
4. Engage Customs Broker	REQUIRED if the shipment’s declared commercial value is over $2,500.[8] The broker handles the formal entry procedures via the ACE manifest system.	U.S. Customs and Border Protection (CBP)	[8]
5. Plan for Fixed Fees	Every commercial entry is subject to a fixed, mandatory $93.00 Base Commercial Fee for inspection.[9] Maximize your shipment volume to dilute this per-unit cost.	USFWS Base Commercial Fee	[9]
6. Secure Local Licensing (Tucson)	Apply for your Arizona TPT License (Joint Tax Application JT-1) [10, 11] and City of Tucson Business License.[12, 13]	AZ DOR ($12 fee) & City of Tucson ($20 fee)	[12, 10, 11, 13]

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III. Business Identification, Compliance, and Financial Strategy

A. Importer Data Profile for Forms (The Uncarved Block)

Use this data to prefill all necessary customs, wildlife, and tax forms:

B. Strategic Compliance Summary for Profit Maximization

For your business plan, the profitability hinges on the financial structure that this import plan enables:

C. Local Zoning and Home Occupation Compliance (Pima County/Tucson)

Since the business is home-based, compliance with local zoning is mandatory. The operation must function as a **Home Occupation** that meets strict limits:

• **Allowable Use:** A home occupation is defined as a home office, **online sales**, etc., meeting zoning code limitations. Activities like auto repair, kennels, or tattoo parlors are generally **not** allowed.
• **Size Limitation:** The area used for the business (office, storage, packing) must not exceed **25% of the floor area of one floor of the residence** OR **200 square feet of an accessory building**.

D. Federal Import/Export License and Record Keeping Requirements

For large-volume, repeated commercial importation, you must secure a **Commercial Import/Export License** (FWS Form 3-200-3a application). Crucially, this dictates mandatory record keeping:

• **Record Retention:** All business records concerning the import and subsequent sale/transfer of wildlife inventory (e.g., invoices, bills of sale, inventory logs) must be maintained for a minimum of **five (5) years** from the date of the license expiration or the import date.
• **Inventory Location:** Records and wildlife inventories must be kept at the address listed on the license (1302 W Ajo Way) unless an alternative location is specified in the application.

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IV. Designated U.S. Fish and Wildlife Service (USFWS) Ports

All commercial wildlife imports, even non-CITES insects, must enter the U.S. through one of the ports designated below. Using a non-designated port without a specific **Designated Port Exception Permit (DPEP)** will lead to delays and potential seizure.[9]

For specific addresses and contact numbers to issue the mandatory 7-day advance notification, refer to the official USFWS Importers & Exporters page [14] and download the “Wildlife Inspection Offices” PDF.

• Anchorage, Alaska
• Atlanta, Georgia
• Baltimore, Maryland
• Boston, Massachusetts
• Chicago, Illinois
• Dallas/Fort Worth, Texas
• Honolulu, Hawaii
• Houston, Texas
• Los Angeles, California
• Louisville, Kentucky
• Memphis, Tennessee
• Miami, Florida
• New Orleans, Louisiana
• New York, New York
• Portland, Oregon
• San Francisco, California
• Seattle, Washington

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V. Logistics and Handling Mandates

Your international freight arrangements must account for the high fragility and value of the framed specimens.

• Packaging Mandate: Advise your supplier that framed specimens are classified as highly fragile cargo and require stringent protection, likely involving layered cushioning and custom crating.[15, 16]
• Declared Value & Insurance: Ensure robust cargo insurance is purchased. If using standard parcel carriers, note that they may recommend a maximum declared value limit (e.g., no greater than $1,000 for standard artwork services) unless using specialized premium freight or art boxes.[17]
• Port Compliance: Ensure the shipment is routed to a **designated USFWS port** authorized to handle wildlife imports. Importing through a non-designated port without an expensive Designated Port Exception Permit (DPEP) will cause substantial delays and potential seizure.

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VI. Final Compliance Checklist: Avoiding Seizure and Delay

The vast majority of import issues stem from simple administrative failures. To ensure the smoothest entry, focus on these critical failure points:

• **Declaration Failure:** The most common violation is simply **failing to file USFWS Form 3-177** (eDecs) or submitting it with incorrect or incomplete information.
• **Labeling and Documents:** Failure to have **all supporting documents (Invoice, Declaration, Permits)** physically present with the shipment and clearly labeled will cause immediate delays.
• **Premature Clearance:** Customs (CBP) clearance and release of the goods **before FWS clearance** is a common cause of violation. This highlights why broker coordination and advanced FWS notification are essential.
• **Unauthorized Port:** Using a non-designated port for commercial wildlife without a DPEP will result in seizure.[9]