The Food Marketing Institute (FMI) is pleased to respond to the United States Department of Agriculture’s (USDA’s) Animal and Plant Health Inspection Service (APHIS) October 8, 2008, request for comments on implementation of revised Lacey Act provisions. 73 Fed. Reg. 58925 (October 8, 2008). As discussed more fully below, although we appreciate the Agency’s efforts to implement the law in a manner that minimizes burdens on importers and the potential for trade disruption, we recommend APHIS adopt several additional steps to ensure importers can comply with the newly enacted declaration requirements.

Full Comments