If the HTS code of your wooden, bamboo or other plant-based product appears on the APHIS Lacey Act Implementation Schedule, the importer of record or its agent must file a Lacey Act declaration at entry that names the plant’s scientific name, the country where it was harvested, the value, and the quantity in metric units. Since Phase VII began on December 1, 2024, APHIS has required declarations for all remaining plant product HTS codes that are not 100-percent composite materials, which pulls in furniture, cork, sporting goods and housewares that never needed one before. As of January 1, 2026, APHIS no longer accepts paper PPQ 505 forms: the filing goes through CBP’s ACE or APHIS’s LAWGS (APHIS pages read 2026-10-15).
This guide covers the Lacey Act declaration for wood products imported for Amazon FBA. It gives the criteria APHIS publishes; it does not rule on whether a specific product or shipment is covered or compliant.
The Sources, and How Current They Are
| Source | Date | What it settles |
|---|---|---|
| File a Lacey Act Declaration — APHIS | “Last Modified: January 06, 2026”, read 2026-10-15 | Who may file, Phase VII start, ACE and LAWGS, end of paper forms |
| Lacey Act Declaration Requirements — APHIS | “Last Modified: December 24, 2025”, read 2026-10-15 | Data elements, who files, when to file |
| Frequently Asked Questions About Lacey Act Declaration Requirements — APHIS | “Last Modified: July 30, 2025”, read 2026-10-15 | Phase VII scope, composites, disclaimer codes, de minimis, packaging, corrections, penalties |
| Lacey Act Declaration Implementation Schedule — APHIS | “Last Modified: January 13, 2026”, read 2026-10-15 | The HTS chapters and headings that require a declaration |
| Implementation of Revised Lacey Act Provisions — Federal Register notice 2024-11901 | Published 2024-05-31 | The Phase VII product list |
| APHIS Will Implement Lacey Act Phase VII Requirements on Dec. 1 — APHIS program update | Read 2026-10-15 | 2009 start of enforcement, items in earlier phases |
APHIS says it will announce future phases in the Federal Register, so treat everything below as the reading on 2026-10-15. The HTS table on the Implementation Schedule page loads dynamically; check your own codes on the live page rather than on any copied list.
When a Lacey Act Declaration Is Required for Wood Products
The trigger is the tariff code, not the product name. APHIS’s FAQ puts it directly: “If your product is listed, then it is subject to the Lacey Act declaration requirement unless otherwise exempted.” That means three checks, in order:
- Classify the product. You need the 10-digit HTS code your customs broker will enter. If that is still open, start with how to find the HTS code for an Amazon product.
- Look the code up on the Implementation Schedule. APHIS says all codes currently in force, “including Phase VII codes,” are uploaded there.
- Check the exemptions and disclaimer codes in the next section before assuming a declaration is due.
What Phase VII changed
APHIS began enforcing the declaration on April 1, 2009, and added product groups in phases; earlier phases covered items such as timber, some furniture and essential oils. Phase VII, effective December 1, 2024, is the widest. According to the APHIS FAQ, “Lacey Act declarations will be required for all remaining plant product Harmonized Tariff Schedule (HTS) codes that are not 100-percent composite materials.” The same answer names “furniture, cork, sporting goods, and some essential oils” as examples, and APHIS’s main declaration page adds housewares, tools, and boats and vehicles to the goods that never needed a declaration before.
That is why this matters to Amazon sellers now. Bamboo kitchenware, wooden toys, picture frames, tool handles, cork boards and solid-wood furniture are common private-label categories built on plant material. Whether your code is on the schedule is a lookup, not a judgment call; run it for every SKU with wood, bamboo, rattan, cork or other plant content.
The FAQ adds one point that is easy to miss: even for products not on the schedule, “you must still meet all other provisions of the Lacey Act (for example, must be legally harvested).” The declaration follows listed codes; the ban on trading illegally harvested plants applies to everything.
Exemptions, Composites and Disclaimer Codes
When ACE flags a listed HTS code but your goods do not need declaration data, the filer answers the Lacey message set with a disclaimer code. The APHIS FAQ (read 2026-10-15) lists these:
| Code | Name on the APHIS FAQ | When APHIS says it applies |
|---|---|---|
| A | Not Regulated | Common cultivars, common food crops, scientific specimens, plants for planting, and products with zero plant material. Protected plant species are not part of these exemptions |
| B | Not Required | Product identified in APHIS policy as not requiring a declaration, such as used, recycled or reclaimed wooden packaging in HTSUS 4415 |
| C | Filed Through Other System | Declaration already submitted in LAWGS |
| D | Filed Through Paper Submission | Declaration already submitted on paper PPQ 505/505B |
| G | De minimis | Plant material is no more than 5 percent of the weight of each product unit, and total plant material in the entry line (single HTS code) does not exceed 2.9 kilograms |
Three cases come up often with finished consumer goods:
- Composites still need a declaration. APHIS defines composites as plant material that has been “mechanically or chemically broken down” and recomposed, naming paper, paperboard, particleboard, MDF and HDF. For composite products the FAQ answer is “Yes, unless otherwise exempted.” Phase VII excludes only codes that are 100-percent composite.
- Packaging that only carries goods is outside the Act, unless the packaging is itself the import. New wooden pallets and crates in HTSUS 4415 still trigger the ACE prompt; APHIS says to answer with code A when they only support, protect or carry another item.
- Lacey de minimis is about weight, not value. APHIS contrasts it with CBP’s Section 321 de minimis, which is based on shipment value. The test runs per product unit and per entry line.
Who Files: Importer of Record or Agent
APHIS’s requirements page says “Only the importer of record or their agent, like a customs broker, may file a Lacey Act declaration.” For most Amazon FBA sellers, the practical filer is the customs broker who files the entry in ACE on behalf of the importer of record.
So the importer-of-record question comes first. Amazon does not act as importer of record for FBA inventory, so the role falls on you or on a party you contract, such as a forwarder offering a delivered-duty-paid service. The obligations of that role are covered in importer of record and customs bonds for Amazon FBA.
Two consequences follow from the APHIS rules:
- Responsibility stays with the importer of record. The FAQ says “Only importers of record can revise a Lacey Act declaration.” A broker keys the data; the importer of record owns the declaration and its corrections.
- The broker can only file what you give it. Species and harvest country come from your supply chain. APHIS tells importers to get from suppliers the scientific name for each piece of plant product and where it was harvested.
What the Declaration Must Name
The APHIS requirements page lists the plant-specific information needed for each declaration (read 2026-10-15):
| Data element | What APHIS asks for |
|---|---|
| Scientific name | Genus and species of any plant contained in the shipment |
| Country of harvest | Name of the country from which the plant was taken |
| Value | Value of the product |
| Quantity | Quantity of the plant, in metric units of measure only |
| Description | Description of the shipment |
| Importer | Importer name and address |
The same page also lists consignee name and address, HTS code, bill of lading, container number, Manufacturer Identification Code (MID), and contact details for the importer of record or its agent, which your broker normally already holds from the entry.
Country of harvest is where the tree or plant was taken, which is often not where the product was made. A bamboo cutting board assembled in Vietnam from bamboo grown in China has different answers for country of harvest and for origin marking, which is a separate obligation covered in country of origin marking for Amazon imports.
When you cannot provide genus and species, APHIS allows a Special Use Designation (SUD). According to the FAQ, “The proper use of a SUD in a Lacey Act declaration fulfills the requirements of the Lacey Act for the declaration of the scientific names.” The rest of the declaration must still be complete.
APHIS also states that you cannot submit a blanket declaration, and that the 2008 amendments “do not impose any additional paperwork or reporting requirements beyond the import declaration.” Supply chain documents are not filed, but the FAQ expects importers to know their supply chain as part of due care. We put species, harvest country, plant weight per unit and composite share on the purchase order, before production, because they are hard to reconstruct after the container sails.
How It Is Filed: ACE, LAWGS, and the 2026 End of Paper
APHIS names two filing channels:
- ACE. “ACE is a U.S. Customs and Border Protection (CBP) system.” APHIS calls it “the primary method for filing Lacey Act declarations.” The broker submits the Lacey data in the APHIS Lacey Act message set with the entry, and ACE flags shipments based on the HTS codes on the Implementation Schedule.
- LAWGS. The Lacey Act Web Governance System is APHIS’s web-based interface and the alternative to ACE. When a declaration was filed in LAWGS, the ACE entry answers the Lacey prompt with disclaimer code C.
The 2026 change is about paper. The APHIS page reads: “As of January 1, 2026, APHIS is no longer accepting paper submissions of the PPQ 505 or 505B form.” If an old broker checklist still lists the paper form, update it.
On timing, the requirements page says to file when the shipment reaches U.S. jurisdiction, and notes that most importers file the declaration in ACE before arrival through the Lacey Act message set. The data rides with the entry your broker files, alongside the ISF filing for Amazon FBA and, for regulated consumer products, CPSC eFiling.
Corrections and Penalties
If a declaration filed in ACE is wrong, the APHIS FAQ says you may correct it in ACE within the allowable timeframe; past that window, contact APHIS at [email protected]. LAWGS filings are corrected through the LAWGS help desk.
APHIS’s FAQ (read 2026-10-15) states these penalty levels for the declaration requirement:
| Situation | Civil | Criminal (individual) |
|---|---|---|
| Violates the declaration requirement | Administrative penalty of not more than $250 | — |
| Knowingly violates the requirement or knowingly falsely labels | Administrative penalty of not more than $10,000, adjusted for inflation | Up to 5 years in prison and a fine of $250,000 or twice the gross gain or loss, where the offense involves importation or a sale over $350 market value |
| Plant product imported in violation of the requirement | May be subject to civil forfeiture | — |
The FAQ also says the Act’s civil forfeiture provisions “are enforced on a strict liability basis”: goods made from illegally harvested plants may be seized whether or not the importer knew. That is the strongest reason to get species and harvest data from suppliers in writing.
Lacey Act Declaration Checklist for Amazon FBA Importers
- List every SKU with wood, bamboo, rattan, cork or other plant material
- Confirm the 10-digit HTS code and look it up on the live Implementation Schedule; record the date
- Test exemptions: common cultivar or food crop, zero plant material, packaging only, de minimis
- Collect genus, species and country of harvest from the supplier; use a SUD only where species cannot be determined
- Record plant quantity in metric units and the product value
- Confirm who is importer of record and that the broker files the Lacey data in ACE
- Remove paper PPQ 505 steps from your SOP
For the full border sequence, see shipping from China to Amazon FBA.
Frequently Asked Questions
Do bamboo products need a Lacey Act declaration?
It depends on the HTS code. Bamboo is plant material, so if the product’s code is on the APHIS Implementation Schedule and no exemption or disclaimer code applies, a declaration is required.
Can I still file PPQ Form 505 on paper?
No. As of January 1, 2026, APHIS no longer accepts paper submissions of the PPQ 505 or 505B form. File through ACE or LAWGS.
Is MDF or particleboard furniture exempt?
Not automatically. APHIS counts MDF, HDF and particleboard as composite materials, which need a declaration unless otherwise exempted. Where the species in a composite cannot be determined, a Special Use Designation can replace genus and species.
Conclusion
The Lacey Act declaration for wood products comes down to one lookup and one data request: your HTS code against the APHIS Implementation Schedule, and genus, species and harvest country from your supplier before the goods ship. Your broker files it in ACE; paper PPQ 505 is no longer an option.