*Courtesy: Conservation Force, John J Jackson III & African Indaba. © Copyright reserved. No part of this section of the publication may be reproduced without the prior permission of Conservation Force and/or John J Jackson III.
Conservation Force created a draft checklist of recurring problems/errors that should be looked for before the shipment of any CITES trophy. It is imperative that all errors are proactively discovered and corrected before shipment of any trophy. The checklist has been evolving and will be revised from time to time.
Tag. Must be 1) permanently attached 2) through a hole. Ear, eye, mouth, nose, bullet holes are okay, but not around the leg above the foot. Tag number must match that on the permit.
Permit expiration. Get a faxed copy of the import permit before exporting. Do not ship an Appendix I species without seeing a copy of the import permit to be sure it will not expire before the shipment arrives. Examine the export permit for expiration date and look for date errors.
Export permit. Examine for errors of name of permittee and name and number of species, signature and seal by CITES-designated officers.
Validation. Make sure section 14 of export permit is fully completed, i.e. all parts itemised, signed and sealed by designated CITES officer before the final step of shipment.
Purpose code. If crafted or worked item of trophy parts (feet, tail swish, bracelet, scrimshawed tusks, boots, gun cases, clothing, etc), export permit must be coded “P” for person instead of “H” for hunting trophy. If part of an elephant or rhino trophy on Appendix II, it must have an Appendix I import permit (Form 3-200-37) because it is not treated as a trophy. Only trophy trade is on Appendix II, not trophies converted into “personal” items.
Valuation. Understatement of value is the cause of excessive seizures, i.e. forfeiture of $50 000 trophies for a $500 offense. A true representative value should be used, not understatement. Pro-rated cost of acquisition (cost of the hunt) is best or insurance value. Note: trophies are not taxed upon entry into the US but they most certainly are seized. The exporter should use the full value from the get-go as import brokers carry it over onto their declarations.
In transit. Transfer through intermediate countries must be immediate, without delay. A hunter travelling with his trophy cannot lay over in an intermediate country without appropriate import and re-export permits from that country.
Post-shipment corrections. Exporting authorities must immediately contact and confer with US authorities before issuing a retrospective permit or replacement permit, not months later or after issuing a new permit. Retrospective and replacement permits must be issued immediately, not weeks or months later. The importing agent must set corrective action in motion immediately and use a true value for the trophy on the 3-177 Declaration entry form rather than carry over as the value the export fee or some other incorrect value from the export documents.
Reshipment. Send trophies back whenever you can, else it is treated as illegal to possess contraband like stolen goods or illegal drugs without any protectable interest.
Reshipment import permits. When trophies are returned to the exporting country and reshipped new, original import permits are required.