Key takeaways
- Two duties: do not import illegally sourced wood, and declare the species and country of harvest.
- The declaration needs scientific names for every wood in the product, including plywood and MDF parts.
- Paper PPQ 505 forms stopped being accepted on 1 January 2026.
What the Lacey Act requires
The Lacey Act is a US law that, for plants and plant products such as wood, does two things:
- Prohibition. It is unlawful to import wood that was harvested, transported or sold in breach of the laws of the country where it was harvested, or products made from it.
- Declaration. For products on the APHIS enforcement schedule, the importer files a plant and plant product declaration (PPQ 505) at entry.
A complete declaration does not make illegal wood legal. The two duties are separate.
Phases and HTS codes
APHIS has phased in the declaration requirement by HTS code. For wooden furniture the position is:
| Phase | From | What it means for furniture |
|---|---|---|
| Early phases | 2009–2010 | Most wooden furniture codes began to need a PPQ 505 declaration |
| Phase VII | 1 December 2024 | About 250 more codes, including the remaining Chapter 94 lines |
| Omitted from Phase VII | After a future notice | 9403.40.9040, 9403.40.9060 and 9403.40.9080 were left to be added after notice. Their current status is unconfirmed: check the APHIS enforcement schedule on the day you ship |
| Electronic filing only | 1 January 2026 | Paper PPQ 505 forms are no longer accepted; file through CBP ACE or APHIS LAWGS |
The PPQ 505 declaration
For each product the declaration asks, among other things, for:
- the scientific name (genus and species) of every plant in the product;
- the country of harvest, meaning where the tree was felled, not where the furniture was made;
- the quantity and value of the product.
Confirm the current field list and the rules for composite and recycled materials in the APHIS guidance before filing.
What this means for goods made in India
| Material | Trade name | What to check |
|---|---|---|
| Sheesham | Indian rosewood | Usually Dalbergia sissoo. Check the current CITES status of Dalbergia species before shipping |
| Mango | Mango wood | Mangifera indica; usually from farms and orchards |
| Acacia | Acacia, babool | Several species are sold as acacia; get the exact genus and species from the supplier |
| Plywood, MDF, particleboard | Panels | Panels can contain several species; ask the panel mill and follow APHIS guidance on composites |
| Imported timber | e.g. pine, oak | Country of harvest is the country the logs came from, not India |
Indian timber is often bought at auctions and from many small farm holdings, so the factory may not have one clean record per order. Ask for timber purchase invoices covering your order, and agree in the purchase order that the supplier names every species used, including in panels, drawer bottoms and backs.
Do not assume sheesham's CITES status. CITES listings and annotations for Dalbergia have changed over time. Check the CITES checklist and confirm with India's CITES authorities whether your product needs a permit.
Due care
Penalties under the Lacey Act take into account whether the importer exercised due care: the care a reasonable person would take in the circumstances. The law sets no fixed checklist. Steps that help show it include knowing who supplied the timber, collecting purchase records, checking that the declared species match the goods, and acting on red flags such as species that do not match the paperwork.
How an inspection helps
An inspection cannot certify that wood is legal or file your declaration. It gives you independent evidence from the factory that supports due care:
- Species check. The wood seen in the goods is compared with the species on your purchase order and the draft PPQ 505 data. Doubtful cases are sampled for lab species identification.
- Timber purchase records. Invoices or auction slips for the timber used are checked for species and quantity against the order, and photographed for your file.
- Component materials. Each component is recorded as solid wood, plywood, MDF or other panel, with species where known, so nothing is left off the declaration.
- Packing and marks. Cartons, product codes and packing lists are checked against the order, so the declaration matches what is shipped.
A species mismatch or missing record is something you need to decide on before the goods leave, so it is reported as Hold. See how the verdict works.
Sources
- USDA APHIS, Lacey Act declaration requirements and enforcement schedule
- Federal Register, Lacey Act Phase VII implementation notice (31 May 2024)
- 16 U.S.C. 3372 (Lacey Act prohibited acts and declaration), Cornell LII
- U.S. Customs and Border Protection, ACE
- CITES checklist of listed species
The APHIS site did not load during our 12 Oct 2026 review, so some points rest on the Federal Register notice and secondary sources. Re-check each point against the primary text before relying on it. This guide is general information, not legal advice.