Comments on Implementations of Revised Lacey Act Provisions
The Retail Industry Leaders Association (RILA) appreciates this opportunity to provide comments on implementation of revised Lacey Act provisions in response to the above Federal Register notice published by the Animal Plant Health Inspection Service (APHIS) on September 2, 2009. Illegal logging is a global problem that has serious environmental and economic consequences, and effectively addressing this problem is an important goal that retailers support. Nevertheless, unless thoughtfully implemented, the declaration requirement of the Lacey Act could pose an unworkable burden on importers and raise a significant barrier to trade. RILA supports pragmatic and effective solutions to the significant implementation challenges presented by the Lacey declaration requirement.