By holding the declaration's fields on your item and supplier records before goods ship, then generating each declaration from those records and the commercial invoice. The law fixes the fields: the scientific name, to genus and species; the value; the quantity with its unit of measure; and the country where the plant was harvested. Recycled paper content is declared as an average percentage. Where species or country vary and are unknown, the declaration lists every one that may have been used. For composite material where scientific names can't be given, a special use designation takes their place. Since 1 January 2026 filing is electronic only, which makes declarations generated from records the natural route.
What the usual answer says
The agency's own pages and most guides list the fields and explain the phase-in by product code. They also describe the two electronic filing routes: the customs entry system or the agency's web system. The agency's Lacey Act page, last modified in January 2026, is explicit. "As of January 1, 2026, APHIS is no longer accepting paper submissions of the PPQ 505 or 505B form." A broker's guide goes further and advises collecting "species and origin documentation before goods ship". What neither sets out is where those fields should live in a business's own systems.
What the law requires
The declaration requirement is in the statute itself. An importer must declare "the scientific name of any plant (including the genus and species of the plant)" and the value. It must give "the quantity, including the unit of measure, of the plant". It must also give "the name of the country from which the plant was taken". Where species vary and are unknown, the declaration must "contain the name of each species of plant that may have been used to produce the plant product". The same applies to countries. For paper, it gives "the average percent recycled content". Packaging used only to carry another item is excluded.
The same section makes it unlawful "to make or submit any false record, account, or label for, or any false identification of" any plant imported from a foreign country. An inaccurate scientific name is therefore a legal exposure, not a clerical one.
What changed with Phase VII
The agency's notice of 31 May 2024 announced Phase VII, and its page confirms that "On December 1, 2024, APHIS began implementing Phase VII". For wood, the notice ended two plywood exemptions kept since 2009 for products containing composite material. The notice explains that the agency "has established a special use designation for such material". So it is "eliminating the exemptions, and the entire chapter will be covered". The page explains that a special use designation can describe plant material "when you cannot provide the scientific names". It also sets a de minimis rule for plant material of "no more than 5 percent of the total weight" of each product unit. The plant material in an entry must stay at or below 2.9 kilograms per tariff line.
Where the records fall short
Item records usually carry the trade's names, such as white wood, mixed hardwood or a grade. None is a genus and species. Each trade name needs mapping to its scientific names, or to a special use designation for particle or fibre content. That is done once, on the item, with the document that supports it. A panel or a bundle of mixed hardwood needs every species that may be present, and a record holding only the main species produces an incomplete declaration. Each item needs a declared unit with its conversion. Each supplier record needs the harvest countries for each item it supplies, with dates. The declaration asks where the wood was harvested, not where it shipped from.
With those fields held, each declaration is built from item records and invoice lines. Review then shifts to the exceptions: new items, changed suppliers, de minimis claims. Store each filed declaration with the records it came from, so it can be reproduced if questioned.
Records and due care
A correct declaration doesn't make illegally harvested wood legal. A customs broker's guide notes that goods "are subject to seizure and forfeiture, regardless of whether the importer knew about the illegal harvest". It adds that "Maintaining documentation from suppliers about species and harvest origin is the foundation of a due care defense." The supplier evidence behind each item record serves both purposes, which is the main reason to hold it in one place.
When the broker's sheet is enough
Many importers never prepare a declaration themselves: a customs broker files it at entry from the supplier's species sheet. For a few dozen stable products, that is cheaper than extending the item master. The records-first approach pays off when the range is large, species or sources change often, or the importer also manufactures. Businesses that import no plant products file no declarations at all.
Where AI helps
AI can read supplier certificates and invoices into structured fields. It can propose scientific names for trade names for a person to confirm, and flag items missing a field before they ship. It shouldn't choose a species on its own, given the exposure an inaccurate declaration carries.
Quarri for wood products is built around how a wood products plant runs, where the order book meets real capacity.
Sources
- 16 U.S.C. 3372, "Prohibited acts", including (d) and (f), Legal Information Institute: law.cornell.edu
- Animal and Plant Health Inspection Service, "Lacey Act", last modified 6 January 2026: aphis.usda.gov
- Animal and Plant Health Inspection Service, "Implementation of Revised Lacey Act Provisions", Federal Register, Vol. 89, No. 106, 31 May 2024: govinfo.gov
- AACB, "The Lacey Act: What Importers Need to Know About Declaration Requirements", 2025: aacb.com
Quarri is an AI-native data platform for the timber supply chain. It connects buying, production, sales and inventory for forest management, sawmill, wood products and pulp, paper and packaging operators.