Lacey Act Declaration: Phase VII Scope and the End of Paper PPQ 505

A Lacey Act declaration used to be a lumber and furniture problem. Since Phase VII took effect on 1 December 2024, the covered HTS codes reach much further into finished goods such as guitars, wooden articles carried in handbags, instrument cases, tools with wood handles, sporting goods, footwear on wooden or cork bases, steering wheels, trailers and complete boats, because the declaration requirement now spans HTS chapters 12 through 96. On 1 January 2026 APHIS stopped accepting paper PPQ 505 forms, so importers who handled the occasional wood-containing line with a paper declaration no longer have that fallback.

Section 3372(f) of the Lacey Act requires importers of covered plants and plant products to declare the scientific name of each plant, the value, the quantity and the country where it was harvested. The declaration is filed electronically with the entry, and every species in the product has to be identified. This guide covers who must declare, what Phase VII added, how electronic filing works now that paper is gone, the data suppliers have to provide and the errors that trigger holds. Rules checked against the Federal Register and APHIS guidance as of September 2026.

Who Must File and Which HTS Chapters Are Covered

The obligation falls on the importer of record for any shipment containing plant material classified in an HTS code that APHIS has placed in the declaration implementation schedule. Plant material means wood, bark, bamboo, rattan, cork and other plant parts, whether they are the whole product or a small component of it. The trigger is the HTS code of the product combined with the presence of plant material, not the importer’s view of how much wood the product contains.

APHIS has phased in the requirement over many years, starting with raw and lightly processed wood and moving steadily toward finished goods. Phase VII, published at 89 FR 47122 and effective 1 December 2024, extended the requirement to additional HTS codes across chapters 12 through 96, including all of heading 4412 (plywood, veneered panels and similar laminated wood). No Phase VIII has been published as of September 2026.

Because the scope is keyed to HTS codes, a HTS classification review is the first screen. Any code within the covered chapters should prompt a second question: does the product contain plant material, and if so, how much by weight?

What Phase VII Added and Why It Caught Importers Off Guard

Earlier phases covered a narrower list of HTS codes, weighted toward wood products and furniture, where the wood content is obvious to everyone involved. Phase VII changed the profile of the affected importer. A compliance team that never filed a Lacey Act declaration because the company does not sell furniture now has to review codes for musical instruments, sporting goods, tools, accessories, footwear, steering wheels, trailers and boats with any wood or bamboo content, and check each one against the current schedule rather than against what applied before December 2024.

The practical effect is that the declaration requirement now touches merchandise categories where the buyer never asked the supplier which tree the material came from. A wooden steering wheel or a small wood article sold to be carried in a handbag can be commercially trivial and still require the full declaration if it exceeds the de minimis threshold.

The de minimis rule is narrow. A line qualifies only if the plant material is no more than 5% of the product’s weight and no more than 2.9 kg per line, in which case the importer disclaims the requirement with disclaim code G. The exception is not available if the plant material is a species listed under CITES, the Endangered Species Act or a state conservation law (7 CFR 357.4(c)). Anything above either limit requires the declaration, so the weight data has to be real rather than estimated from the product photo.

Paper PPQ 505 Ended January 1, 2026: Electronic Filing Only

Until the end of 2025, importers could submit a paper PPQ 505 (and the PPQ 505B continuation sheet) for lines that did not fit an electronic workflow. According to APHIS, paper forms stopped being accepted on 1 January 2026. The two remaining channels are the Lacey Act message set in ACE, filed with the entry, and LAWGS, the APHIS Lacey Act web system for declarations submitted outside the entry.

For most commercial imports the ACE message set is the efficient route, because the declaration data travels with the entry and the licensed customs brokerage filing the entry can transmit it in the same transaction. LAWGS remains useful for cases where the declaration is prepared separately, but it adds a step that has to be reconciled with the entry number.

Importers sometimes confuse these channels with other APHIS systems. APHIS eFile replaced the old ePermits system for permits, and APHIS Core is the ACE message set for non-Lacey APHIS data. Neither replaces the Lacey Act declaration. A shipment can need a permit through eFile, APHIS Core data and a Lacey Act declaration at the same time, and each has its own data requirements.

Genus, Species and Country of Harvest Data

The statute requires four data elements for each plant in the product: the scientific name at genus and species level, the value, the quantity with its unit of measure, and the country of harvest. Every species has to be declared. A chair built from two woods needs both species; a plywood panel with a face veneer of one species and a core of another needs both.

Country of harvest is where the tree was cut, not where the product was made, and it is not the same answer as the customs country of origin determination used for marking and duty. A table assembled in Vietnam from timber harvested in several countries has one country of origin for customs purposes and several countries of harvest for Lacey Act purposes. Suppliers who fill in the manufacturing country in both fields create a declaration that is wrong on its face.

Collecting the data is a supplier management task. The furniture factory usually knows its panel or lumber supplier, but the harvest country and species sit one or two tiers back. Importers need a standard data request that travels with the purchase order, asks for species and harvest country per component, and requires the supplier to update it when sourcing changes.

• Scientific name: genus and species for each plant, not a trade name such as “hardwood” or “oak-type”.
• Value: the value of the importation, as declared for the line.
• Quantity: amount of plant material with the unit of measure.
• Country of harvest: where the plant was harvested, one entry per country when there is more than one.

Common Lacey Act Declaration Errors

The same handful of mistakes account for most holds and follow-up requests. Almost all of them trace back to supplier data that was never collected or never checked against the product.

The consequences go beyond a delayed shipment. Filing false information on a declaration, or failing to file one for covered goods, is a violation of the Lacey Act in its own right, independent of whether the wood itself was legally harvested. Importers should treat the declaration as a sworn statement about their supply chain and keep the supplier evidence behind every line. Compliance teams that already run lumber tariffs reviews on the same goods can combine the two data requests into one supplier questionnaire.

• Trade names instead of scientific names, or a genus with “spp.” where the species is knowable.
• Only the dominant species declared on composite products with several woods.
• Country of manufacture entered as country of harvest.
• De minimis claimed without weight data showing the product is at or below 5% and 2.9 kg per line, or claimed for a species listed under CITES, the Endangered Species Act or a state conservation law.
• Phase VII goods (instruments, tools, accessories, steering wheels, trailers and boats) shipped with no declaration because the product does not look like a wood product.
• Paper PPQ 505 prepared after 1 January 2026 and presented at entry.

Building the Declaration Into the Entry Workflow

The declaration works best as a product master data field, not a per-shipment task. Each SKU that contains plant material carries its species, harvest countries and plant weight; the broker pulls that data into the ACE Lacey Act message set for every entry; and the importer updates the record when a supplier changes sourcing. That approach removes the last-minute email chain that usually precedes a late filing.

It also makes review possible. A trade compliance management program can sample SKUs each quarter, ask suppliers to reconfirm species and harvest data, and compare the declared data against the CBP Form 7501 lines filed. The Lacey Act declaration sits alongside other agency requirements, such as US import licenses and permits, and deserves the same audit cadence.

Frequently Asked Questions