Validation is the completion of the bottom section on CITES export permits where there are blocks for an inventory of the parts in the shipment, the government seal, signature and date. The seal, signature and date are separate from that for the issuance of the permit. One might state the permit is not complete until the validation part is completed at the time of export.
A designated CITES Authority must seal, sign and date this part of the form. Of course, this takes place at the time of export, which can be months after the export permit is acquired.
Just a few years back, many countries did not do this, particularly for CITES hunting trophies. Some countries did not even have a section on their CITES export permits. The practice of many countries was to complete the validation section for commercial traded items but not for hunting trophies. Export permits for large commercial shipments may contain hundreds of skins or parts and consequently may contain a quantity above that on the face authorization unless an inventory is completed and signed-off. This is normally not the situation with hunting trophies (a skull and a skin) though in one seizure we know of, an elephant skin was cut up into many parts and was thought to exceed those of the intended elephant.
The 2007 U.S. CITES regulations you have heard so much about include a mandatory requirement that import permits be validated. Some countries did not even have it on their export forms and others did not make it a practice to complete for hunting trophies. The Director of USF&WS and the Chief of its Law Enforcement Division issued an Order that the regulation be phased in. That phasing in was extended several times. From the start, some countries, like Zimbabwe, had to add it to their export permit forms. Trophy shipments were held up in such instances. In a number of instances trophies were detained or seized but ultimately returned to the hunter. On the other hand, trophies were not returned if the import permit had expired during the delay, which was a second violation.
The leniency period has now passed. From San Francisco to New York export permits are being treated as invalid if the validation section is not completed in every detail. It does not matter if the parts are only two or a few and perfectly match the face of the permit. Law Enforcement port inspectors are not just seizing excess parts but all parts, even though the validation would have only been perfunctory, i.e. one skin and one skull and no excess part above that on the face. Trophies are being seized and forfeited regardless of the innocence of the owner, the value of the trophy or mitigating circumstances, and without any questions being raised about the underlying lawfulness of the hunt.
It is now imperative that exporters secure the validation before shipment. The exporters are the professional export brokers, taxidermists and hunting operators who present the trophy to the authorities before delivery to the shipping carrier (airline).
Trophies have been forfeited because the export broker presented it to Customs for clearance without pointing out the shipment contained a CITES listed species, without separately presenting the export permit to the Customs official and without examining the permit to make sure Customs completed the validation. Other trophies have been seized because the form did not even have a validation space on its face.
Believe me, everyone must know this and see that it is done or your CITES listed trophy will be at risk. At least one person has lost over $100,000 in trophies.
