SCI recently received complaints from several hunters that U.S. Department of Agriculture (USDA) inspections have delayed their trophy shipments, causing significant airline storage costs. This is not a new issue, but it may be flaring up in some West Coast ports. SCI is working to address the issue with USDA. In the meantime, hunters should understand the USDA regulations and think carefully about how their trophies may be handled at the port of entry.
By way of background, hunters should know that USDA has the authority, and the mandate, to inspect shipments to prevent transmission of animal-borne diseases. Thus, imported trophies may be inspected by all or any of U.S. Fish and Wildlife Service, Customs and Border Patrol, and USDA. Well before the Covid-19 pandemic (and not as a result of it), USDA had special regulations in place for unfinished trophies that risked introducing certain wildlife diseases, particularly bird flu, African swine fever, and primate-borne diseases. In practice, USDA requires either that all avian, swine, and primate trophies must be finished (i.e., tanned or mounted) before import, or that, after import, unfinished avian, swine, and primate trophies must be sent to an “approved establishment” taxidermist for special processing. USDA also requires special processing for trophies from countries that pose a risk of transmission for hoof-and-mouth disease.
At the same time, finished/mounted trophies, cleaned and dried bones, antlers, horns, and hooves being used as trophies, and hard dried ruminant hides “may be imported from any region without other restriction,” as long as an inspector can determine based on inspection and the paperwork that these trophies are hard-dried. 9 C.F.R. § 95.16. USDA’s “Fact Sheet” for hunters states that “flint dried or hard dried hides from countries without African swine fever do not need to go to an approved establishment.”
In other words, finished trophies, antlers, horns, and bones, and hard dried ruminant skins should not have to undergo additional processing. Nor should finished avian, swine, and primate trophies. But unfinished avian, swine, and primate trophies will always need special processing, and other trophies shipped in the same container may be sent along. For this reason, shipping agents will often recommend that hunters have swine or avian trophies finished in the country of export to avoid delays at the border. Sometimes having a warthog hide tanned in the country where it was hunted can save themselves some hassle during import.
By using a reputable customs broker or following the USDA Fact Sheet, hunters can usually navigate this process without too much difficulty. But in a few recent examples, USDA inspectors have applied the “approved establishment” regulation to trophies that are specifically exempted. In Dallas and Houston, USDA inspectors have sent all unfinished trophies to approved establishments. This includes cleaned and dried antlers and horns and hard dried hides. It also includes animals that are not susceptible to bird flu, swine fever, or primate diseases, and ungulates from countries with no known outbreaks of hoof-and-mouth disease. There are quite a few approved establishments near these ports, so the procedure has not caused significant delay or additional cost. But hunters shipping through these ports should be prepared that their trophies will likely be sent to an approved establishment, even if the trophies are not avian, swine, or primate.
SCI has also been informed that USDA inspectors in Dallas have required hunters to phone ahead to schedule inspection appointments for Gould’s turkey imports from Mexico. Pre-scheduling such an inspection was not previously required. Now, hunters should be sure to call ahead and schedule an inspection before attempting to import any species from Mexico. In two West Coast ports (Seattle and Los Angeles), a handful of hunters have recently experienced delays, and incurred significant airline storage costs, due to questionable USDA inspections. In one case, a USDA inspector sent an ibex skull, horns, and hide to an approved establishment, even though the trophy was properly cleaned in the exporting country. If the hide is hard dried, USDA should allow its import without further processing, and hunters can invoke this regulation (9 C.F.R. § 95.16) when dealing with inspections. Another option is to have the hide tanned in the exporting country so the shipment is “finished” when it gets to the U.S.
In a few recent cases importing through Los Angeles, USDA inspectors have held up fully finished trophies under the “approved establishment” regulation. In two of these cases, the shipment included a warthog skull or hide. Hunters can avoid delays by having the warthog packed separately in the shipment, or by ensuring the trophy is finished in the exporting country and having complete paperwork to show the trophy has been finished.
In one egregious case in Los Angeles, a hunter incurred significant storage fees (exceeding $3,000) when the inspector wanted to send already finished kudu and buffalo trophies to an approved establishment. Although this seems like an outlier, hunters should know their rights: fully finished trophies do not need further processing under USDA regulations. Hunters should ensure that their export paperwork makes clear that the trophies have been fully finished before they are shipped, to avoid any such situation upon import.
What Hunters Can Do: The bottom line is that, to avoid animal-borne disease transmission, USDA has the authority to send certain trophies for further processing at an “approved establishment.” Finished trophies, including hard dried ruminant trophies, and bones/antlers/horns should be exempt from this requirement. Hunters should ensure their export paperwork is clear, to avoid any confusion with inspectors at a designated port.
In the still-rare case that your shipment is held up, know the USDA regulations, as explained here. Most agents are not targeting hunters or acting out of malice. USDA agents rotate through different postings as often as once per month. Thus, an agent is not likely trying to hassle you. More realistically, he or she may is not super familiar with the regulations, and just needs a gentle nudge in the right direction. Be sure to get the agent’s name and supervisor’s name, for follow-up.
As another option, a hunter can have his or her trophies finished in the exporting country. And as another option, a hunter could pre-arrange to send all trophies to an approved establishment for processing. Consider speaking with an approved establishment in advance to determine the cost/benefit of prearranging processing.
USDA maintains a database of approved establishments through which a hunter can arrange processing. Be sure to call the establishment in advance, as the list is not fully up-to-date. When shipping trophies to the U.S., be sure to identify the approved establishment as the consignee and schedule an inspection with Customs and Border Protection. The shipment will then be delivered to the approved establishment for processing, and the hunter can arrange further transport from there. More information is available on the USDA “Fact Sheet” for hunters.
SCI members can always ask questions of the customs brokers, especially those with booths at SCI’s Convention. These brokers are experts in shepherding shipments through USDA and other hurdles—more than that, they are happy to answer questions from SCI members to help you avoid the hurdles in the first place. SCI members should contact Barbara Crown at SCI’s Hunter Information Service (520-798-4859 or [email protected]) if they run into issues with USDA when importing trophies. SCI is actively working to reduce the burden on hunters and to ensure that designated ports are applying standard operating procedures.
To download the USDA Factsheet on the Approved Establishment Program go to https://www.aphis.usda.gov/animal_health/downloads/infosheets/guidanceforhunters.pdf.