On May 27, 2014 the US Fish & Wildlife Service (USFWS) noticed a great number of revisions of its CITES regulations to incorporate provisions made at the 14th and 15th Conferences of the Parties of CITES (79 FR 30400, 30412 and 30428). The most relevant to the hunting community is the change in the definition of “sport-hunted trophy.” Once again, as of the effective date of June 26, 2014, trophies include not just raw parts and taxidermied items, but also “worked, manufactured and handicrafted items that are recognizable parts of the trophy.” The USFWS has revised its 2007 regulation that hunters, export authorities and export brokers must use separate permits and a “personal use” rather than “trophy” Purpose Code to import worked parts of trophies.
The USFWS will now treat trophy items such as elephant hair bracelets, knife and rifle scabbards made of animal skin, footstools and other “manufactured” items as the trophies they are and have always been on the condition that certain information is included on the face of the permit and the parts are in the same trophy shipment that it is to be connected with.
If not handled correctly, the item, though now recognized as a trophy, will no doubt be seized as contraband, so the following is the actual regulation verbiage for all to master: 23.74 – How can I trade internationally in personal sport-hunted trophies?
(b) Sport-hunted trophy means a whole dead animal or a readily recognizable part or derivative of an animal specifically identified on accompanying CITES documents that meets the following criteria:
(1) Is raw, processed, or manufactured;
(2) Was legally obtained by the hunter through hunting for his or her personal use;
(3) Is being imported, exported, or re-exported by or on behalf of the hunter as part of the transfer from its country of origin ultimately to the hunter’s country of usual residence; and (4) Includes worked, manufactured, or handicraft items made from the sport-hunted animal only when:
(i) Such items are contained in the same shipment as raw or tanned parts of the sport-hunted animal and are for the personal use of the hunter;
(ii) The quantity of such items is no more than could reasonably be expected given the number of animals taken by the hunter as shown on the license or other documentation of the authorized hunt accompanying the shipment; and
(iii) The accompanying CITES documents (export document and, if appropriate, import permit) contain a complete itemization and description of all items included in the shipment.
I have quoted it verbatim here because if handled differently, the trophy part will no doubt be treated as contraband, seized and forfeited. To be clear, if it is coded as “P” for a “personal use” purpose rather than as a hunting trophy purpose code, as has been required since 2007, it will be a violation of the revised regulations. If any broker, hunter, taxidermist or otherwise has an interpretation issue with the new regulation, please call it to my attention so we can get clarification from the USFWS before someone’s trophy is seized and forfeited.
Conservation Force was the first to discover and contend with the elimination of worked or utilitarian parts of trophies in 2007 and launched a campaign to change it back. We succeeded in getting the CITES Secretariat to make it a business item at the 14th CoP where the Parties reconfirmed the long-standing understanding that a trophy consisted of all identifiable parts regardless of their useful form. This USFWS regulation is just the USFWS’s regulation revision to follow the Parties’ definition with some of its own added procedural requirements. The hunting community opposed these add-on procedural requirements and suggested limiting those requirements to Appendix I listed species, but USFWS has made the required procedural steps mandatory.
Under no circumstances should any hunter treat an item as a personally taken hunting trophy for personal use when it is not. The USFWS has no tolerance for anyone shipping in commercial items as trophies. Numerous hunting and anti-hunting interests battled out the definition on a Trophy Working Group.