USDA Import Requirements: Permits, ISPM 15 Pallets and Lacey Act Declarations by Product Type

For an enterprise importer with hundreds of SKUs and many suppliers, USDA requirements rarely fail because nobody knew the rule. They fail because one document was missing from one supplier's pack: an unmarked pallet, a permit that was never applied for, a veterinary certificate that did not travel with the goods, or a Lacey Act declaration with no scientific plant name. When the goods are a seasonal launch, a short-shelf-life food or a retailer delivery window, a hold at the port costs more than the paperwork would have.

This guide sets out the USDA agencies that act at the border, the requirements that apply to each vertical, and a checklist of what to have in hand before goods ship. Every requirement below is taken from the regulation or the agency's own guidance, linked in the sources at the end.

Who regulates what at the border

Three USDA units and FDA divide most consumer-goods and food imports between them. The same shipment can answer to more than one.

APHIS states the overlap directly: if you import animal products for human consumption, you must meet FSIS requirements in addition to the Veterinary Services requirements. A cured ham from Europe, for example, can be subject to both.

Do you need a USDA import permit? Which one, and where to apply

Plant products (APHIS PPQ)

APHIS points new importers to its Agricultural Commodity Import Requirements (ACIR) database, which lists requirements by commodity and country for fresh and processed fruits and vegetables, cut flowers, plants and seeds, soil, and wood products. Permits are applied for and issued through APHIS eFile. The underlying application forms include PPQ 587 (Application for Permit to Import Plants or Plant Products) and PPQ 585 (Application for Permit to Import Timber or Timber Products).

For fresh produce the rule is explicit. Under 7 CFR 319.56-3(b), all fruits and vegetables imported under that subpart must be imported under an APHIS permit and under the permit's conditions. The main exceptions are dried, cured or processed fruits and vegetables (frozen produce is not included in that exception) and fruits and vegetables grown in Canada, subject to limited carve-outs. A permit can also restrict which ports the produce may enter. Our guide to importing fruits and vegetables covers the produce process in more detail.

Animal products (APHIS VS)

APHIS says that, generally, you need a VS permit for materials derived from animals or exposed to animal-source materials, and that its VS Permitting Assistant in eFile has the most current information on which products do or do not need one. Applications go through eFile or on VS Form 16-3. APHIS also publishes guidelines for animal-derived products that do not need a permit, but those products are still reviewed at the port of entry.

The Lacey Act declaration: Phase VII reaches consumer goods

The Lacey Act makes it unlawful to import plants or plant products taken in violation of U.S. or foreign law, and it requires an import declaration for certain plant products. APHIS has phased in enforcement of the declaration since April 1, 2009. On December 1, 2024, APHIS began implementing Phase VII, which APHIS describes as covering all remaining plant product HTS codes that are not 100 percent composite materials.

APHIS lists furniture, additional essential oils, sporting goods, housewares, tools, boats and vehicles, and cork among the products that did not need a declaration before and now do. The Phase VII notice (89 FR 47122) names tariff lines that matter to each vertical, including:

• Fashion and accessories: footwear made on a base or platform of wood or cork, umbrellas, other buttons (9606.29.60), combs and hair-slides, sunglasses and non-plastic spectacle frames, watch straps entered with certain watches, and wood articles carried in the pocket or handbag.
• Cosmetics and personal care: brushes for the application of cosmetics (9603.30), other essential oils (3301.29.51), floral waters, room fragrance preparations, manicure and pedicure sets, and personal toilet travel sets.
• Home and consumer goods: wooden, bamboo and rattan furniture and seating, wood furniture parts, kitchen and table implements, knives, wooden Christmas ornaments, board games, jewelry boxes, and plywood and densified wood.

A product in a listed HTS code needs a declaration only if it contains plant material and no exception applies. APHIS lists the exceptions: products free of plant material, informal entries, goods that will not remain in the United States (in-bond movements and carnets), common cultivars and common food crops, and products that meet the de minimis exception. That exception covers plant material that is no more than 5 percent of the weight of the product unit, with no more than 2.9 kilograms of plant material in the entry under the same 10-digit HTS provision. Protected species are never exempt. Always check the current APHIS implementation schedule for your exact 10-digit code.

What the declaration needs from your supplier

APHIS lists the information required: the scientific name (genus and species) of each plant in the product, a description, the value, the quantity of plant material in metric units, the country where the plant was harvested, importer and consignee details, the HTS code, bill of lading, container number and manufacturer identification code. Where the exact species or country of harvest varies, the declaration must list each species and each country that may have been used. APHIS also allows special use designations for some composite and commonly grouped materials.

The data is the hard part. A furniture supplier that buys veneer, frames and inlays from several mills needs to trace each species and country of harvest back through its own supply chain. That can take time, so ask before the order is placed.

ISPM 15 wood packaging: the requirement that hits every vertical

A shipment of silk scarves or serums with no plant content at all can still be held for its pallets. Under 7 CFR 319.40-3(b), regulated wood packaging material must be treated under 7 CFR part 305 and marked on each article, preferably on at least two opposite sides, with the IPPC mark. The mark must show the IPPC symbol, the two-letter ISO country code, the producer number assigned by that country's plant protection organization, and the treatment code, HT for heat treatment or MB for methyl bromide fumigation.

Regulated wood packaging material includes pallets, crating, dunnage, packing blocks, drums, cases and skids. It excludes manufactured wood materials, loose wood packing materials and wood pieces less than 6 mm thick. APHIS lists alternatives that it does not regulate, including plastic pallets, plywood or pressboard, oriented strand board and metal frames.

The consequence is direct. Under 7 CFR 319.40-3(b)(3), an inspector at the port of first arrival may order the immediate reexport of wood packaging material that lacks the required mark, and APHIS states that shipments containing noncompliant wood packaging will not be allowed to enter. Inspectors may issue an Emergency Action Notification when a shipment fails to comply.

What applies to each vertical

Food and beverage

• Meat, poultry and egg products (FSIS). Product must come from a country FSIS has found eligible and from an establishment the foreign inspection system has certified to FSIS; foreign establishment certifications must be renewed annually (9 CFR 327.2; 381.196 for poultry). Egg products must come from a country FSIS has found eligible (9 CFR 590.910). Each consignment needs an electronic or paper foreign inspection certificate in English (9 CFR 327.4). An import inspection application must reach FSIS before the shipment arrives at the official import establishment and no later than when the entry is filed with CBP (9 CFR 327.5). Every lot is then reinspected at an official import inspection establishment (9 CFR 327.6).
• Animal disease rules on the same products (APHIS VS). 9 CFR part 94 restricts meat, pork, dairy, gelatin and poultry products by region and disease status, so an eligible FSIS product can still need APHIS conditions or certification.
• Produce and plant ingredients (APHIS PPQ). Fresh fruits and vegetables need a permit and must meet its conditions, as set out above. Check dried herbs, spices, seeds and other plant ingredients in ACIR.
• Everything else goes to FDA. Most other food, including game meats such as bison, deer and rabbit, falls under FDA rules such as prior notice and FSVP.

Fashion, footwear and accessories

• Wool and hair. Under 9 CFR 95.18, wool, hair or bristles from ruminants or swine enter without other restriction if they have been scoured, thoroughly washed or dyed, if they come directly from a region not declared infected with foot-and-mouth disease, or if they meet the other listed conditions. Bloodstained wool, hair or bristles may not be imported under any condition. Material that meets none of the conditions must go to an approved establishment under 9 CFR 95.19.
• Hides and skins. The restrictions in 9 CFR 95.16 and 95.17 are written for untanned hides and skins. Untanned hides from regions free of the relevant diseases, or that are hard dried, pickled or limed as the rule describes, enter without further restriction; others go to an approved establishment. If you buy crust or raw hides for finishing in the United States, this is the rule to check.
• Feathers and down. APHIS says unfinished hides and feathers from regions affected by highly pathogenic avian influenza or virulent Newcastle disease (for bird items) must be processed at an APHIS-approved establishment unless they are accompanied by a VS import permit or a foreign government certificate. Confirm the status of raw or semi-processed down and feather fill in the VS Permitting Assistant before you book it.
• Plant-based components. Wood or cork platforms on footwear, buttons, umbrellas, some eyewear and wooden accessories sit in Phase VII Lacey Act codes, as listed above.

Cosmetics and personal care

• Animal-derived ingredients. 9 CFR 95.4 prohibits imports of tallow, tallow derivatives, processed fats and oils, glands, and blood products, and products containing them, unless the rule's conditions on species, BSE risk and facility controls are met. Under 95.4(c), those conditions include both a foreign government veterinary certificate and a VS import permit. Bovine collagen is restricted under 9 CFR 95.7 unless, for example, it is derived from hides and skins. Bovine tallow derivatives, defined as chemicals obtained through hydrolysis, saponification or transesterification of tallow, have their own conditions in 9 CFR 95.9. Run each animal-origin ingredient through the VS Permitting Assistant.
• Plant-based items. Cosmetic brushes, some essential oils and room fragrance products are in Phase VII Lacey Act codes.
• FDA still applies. The cosmetic itself is FDA-regulated. See our FDA import compliance guide.

Home and consumer goods

• Lacey Act. Wooden, bamboo and rattan furniture, kitchen implements, knives, games and wooden decorations are among the product lines listed in Phase VII.
• Timber and wood articles. Wood products beyond packaging are regulated under 7 CFR 319.40, and some need a PPQ 585 permit. Check ACIR for the article and origin.
• Wood packaging. Heavy consumer goods often ship on wooden pallets and in crates. Confirm the ISPM 15 mark with every supplier and every forwarder that builds the load.

How APHIS data reaches CBP in ACE

APHIS-regulated commodities are declared in ACE through the APHIS Core message set, part of the partner government agency (PGA) data transmitted with the entry. APHIS publishes lookup tools that show when the APHIS Core message set is required, by entry type and by tariff code, and an implementation guide through CBP. The Lacey Act has its own separate message set. APHIS notes that importers who do not use ACE may still submit APHIS-required information on paper, but that this may slow customs review. For the Lacey Act, paper is no longer an option.

In practice this means the data in the message set, from permit number to scientific name and country of harvest, has to exist before the licensed customs broker files. If it arrives after the goods, the entry waits.

Before goods ship: a USDA readiness checklist

1. Screen every SKU for USDA content. Flag plant material, animal-origin material and meat, poultry or egg content by HTS code and bill of materials, not by product name alone.
2. Check requirements by commodity and origin. Use ACIR for plant products and the VS Permitting Assistant for animal-derived products. For FSIS products, confirm the country and the specific foreign establishment are eligible.
3. Hold the permit before the goods move. Apply in eFile, and pass the permit number and conditions (port, treatment, labeling) to the supplier and forwarder.
4. Collect the certificates that must travel with the goods. Phytosanitary certificates, foreign government veterinary certificates and FSIS foreign inspection certificates are issued in the country of export, not in the United States.
5. Build the Lacey Act data. Genus and species, country of harvest, quantity of plant material in metric units and value for each line in a Phase VII code, or the basis for an exception or disclaimer.
6. Confirm ISPM 15 in writing. Ask the supplier to confirm the IPPC mark on all wood packaging, or to ship on unregulated alternatives. Put it in the contract.
7. File FSIS and APHIS data on time. The FSIS import inspection application goes in before arrival, and APHIS Core and Lacey Act data go in with the entry.
8. Check FDA in parallel. Most food and every cosmetic also has FDA requirements that can hold the same shipment.

You can also read how Greenwich works or start with an import readiness review.

Frequently asked questions

Does USDA or FDA regulate my food import?

FSIS regulates meat from amenable species such as cattle, sheep, swine and goats, domestic poultry, and egg products. APHIS regulates plant products such as fresh fruits and vegetables, and applies animal disease rules to animal-derived foods, in addition to FSIS requirements. FDA regulates most other food, including game meats such as bison, deer and rabbit. One shipment can answer to more than one agency.

Do wool or leather products need a USDA permit?

It depends on how processed the material is. Under 9 CFR 95.18, wool and hair that has been scoured, thoroughly washed or dyed enters without other restriction. The hide and skin restrictions in 9 CFR 95.16 and 95.17 are written for untanned hides and skins, which must meet disease-freedom or treatment conditions or go to an APHIS-approved establishment. Raw or unfinished fibers, hides and feathers are where permits, certificates and special processing come in, so check them in the APHIS VS Permitting Assistant.

Which consumer products need a Lacey Act declaration?

Products in the HTS codes on APHIS's implementation schedule that contain plant material, unless an exception applies. Phase VII, which APHIS began implementing on December 1, 2024, added furniture, cork, sporting goods, housewares, tools and some essential oils. Its notice also lists items such as cosmetic brushes, wood-platform footwear, umbrellas and kitchen implements. Informal entries, common food crops and products meeting the de minimis exception do not need one.

What happens if my pallets are not ISPM 15 marked?

Under 7 CFR 319.40-3, regulated wood packaging material must be treated and carry the IPPC mark with the country code, producer number and treatment code. An inspector at the port of first arrival may order unmarked wood packaging reexported immediately, and APHIS states that shipments with noncompliant wood packaging will not be allowed to enter. Plastic pallets, plywood and metal frames are not regulated.

Do cosmetics with animal-derived ingredients need USDA clearance?

They can. APHIS says material derived from any animal is potentially subject to USDA regulations. 9 CFR part 95 restricts ingredients such as tallow and tallow derivatives, processed fats and oils, glands, blood products and bovine collagen, with conditions based on species and BSE risk. Check each animal-origin ingredient in the APHIS VS Permitting Assistant. FDA requirements for the cosmetic apply as well.

Who files the APHIS and Lacey Act data in ACE?

The importer of record or its agent. APHIS-regulated commodities are declared through the APHIS Core message set, and Lacey Act declarations through a separate Lacey Act message set or APHIS's LAWGS system. Paper Lacey Act forms have not been accepted since January 1, 2026. Greenwich does not file entries; licensed U.S. customs broker partners review and file them.

The bottom line

USDA requirements are not only a food problem. APHIS reaches wool, hides, feathers and animal-derived cosmetic ingredients; the Lacey Act now reaches furniture, footwear, brushes and housewares; and ISPM 15 reaches every shipment on a wooden pallet. Most of what USDA asks for has to come from the supplier or the exporting country's government, which is why it has to be collected before goods ship. Build the USDA check into purchase orders and supplier onboarding, and review the pack before the container is loaded.

Greenwich coordinates U.S. customs brokerage through licensed customs broker partners. Before any filing, a licensed U.S. customs broker verifies classification and entry details.

Primary sources: eCFR, 7 CFR 319.40-3, 7 CFR 319.40-1, 7 CFR 319.56-3, 9 CFR part 94, 9 CFR part 95, 9 CFR part 327, 9 CFR 381.196 and 9 CFR 590.910; APHIS, File a Lacey Act Declaration, Lacey Act requirements and implementation schedule; APHIS, Implementation of Revised Lacey Act Provisions, 89 FR 47122, May 31, 2024; APHIS, Import ISPM 15-compliant wood packaging material and Wood Packaging Material; APHIS, How to import plants and plant products; APHIS, Animal Product Imports, products that do not require a permit and approved establishments; APHIS, Filing APHIS Core Message Set Data in ACE; FDA, FDA Regulated Meats and Meat Products. Requirements depend on the exact product, origin and HTS code, so confirm them in ACIR, the VS Permitting Assistant and the Lacey Act implementation schedule before shipping. This article is operational guidance for importers and is not legal advice.