January 19, 2022, Washington DC: Forest Trends welcomes the recent amendments to the 2022 preliminary edition of the Harmonized Tariff Schedule of the United States (HTSUS). These changes are a welcome step in allowing more systematic and impactful data collection and monitoring of timber shipments entering the U.S. to help ensure legality of imports. The amendments may also lead to more efficient and cost-effective operations of U.S. Customs and Border Protection (CBP).
The HTSUS are 10-digit codes used by U.S. CBP to classify and track the goods being imported into the country. As of January 1, 2022, these now include 25 new codes to better capture and track the trade in tropical wood for imports under HS codes 4408 (veneers), 4409 (flooring) and 9403 (wooden office furniture).
While some tropical species entering the country are low risk, others are much higher risk of having been illegally logged or traded. Previously, since many tropical species were categorized under the same HTSUS code, CBP had no way to track of capture data on the volume of high risk species imported into the U.S.
Forest Trends was among six signatories to a June 2021 letter of support for a proposal to a U.S. inter-agency committee to revise the classification of wood and furniture products under the HTSUS. The newly announced amendments are an important step in the efforts to improve available information on the trade in high value, yet endangered and vulnerable, timber species that are at an elevated risk of illegal logging and trade.
Background
Certain sections of the HTSUS require companies to report their imports by species name. However, there are significant shortcomings when it comes to tariff codes for tropical timber species that are most likely to have been illegally logged and trafficked. Over time, there has been a lack of sufficient information when it comes to these specific species, without which U.S. enforcement agencies have found it difficult to implement the U.S. Lacey Act.
The scale of U.S. wood and furniture imports, valued at roughly $44 billion in 2020, highlights this enforcement challenge. While the U.S. Lacey Act includes ambitious provisions for the U.S. government to target imports of illegal plant and plant products, successful enforcement depends on the ability of U.S. government agencies to collect information on imported species.
Identifying the species of wood in international trade through tariff codes is vitally important in efforts to capture additional timber trade data, conserve species biodiversity, and tackle timber trafficking. A complex and pervasive global problem, illegal logging and associated trade has an estimated value of $30–157 billion annually worldwide, enriching criminals, facilitating transnational organized crime, and threatening U.S. national security. In many countries where illegal logging exists, it is associated with weak law enforcement and prosecution, corruption, collusion, money laundering, forced labor, illegal arms sales, and even regional conflict. As one of the world’s largest international traders in forest products, the U.S. has a strong interest in the legality and viability of forest management globally.
“This is a start of some much-needed change in the way that CBP captures and tracks information on high-risk tropical timber entering the U.S. We hope that this is the just the start and that further amendments will be made.”
Marigold Norman, Associate Director, Forest Policy, Trade, and Finance Initiative, Forest Trends
“We believe that this will greatly improve the ability for the U.S. enforcement authorities to monitor potential illegal imports or imports in violation of existing sanctions. It might even allow private companies that are importing lower risk tropical species to have less time spent on unnecessary enforcement checks.”
Kerstin Canby, Senior Director, Forest Policy, Trade, and Finance Initiative, Forest Trends