Carol Ekarius, co-author with me of The Fleece and Fiber Sourcebook, was our primary coordinator of obtaining samples that I then analyzed, washed, recorded, and spun. Therefore she's the one who needed to figure out the logistics and legalities of moving wool, in the quantities we needed, across various types of boundaries.
She wrote up her findings. I've added some links and the 2012 update of countries' Foot and Mouth Disease (FMD) status; the need to prevent the spread of FMD is the reason for caution in transferring animal products between countries.
In short: It's easy to ship wool. You can make it VERY easy by knowing what the regulations are and putting a couple of extra sheets of paper inside your package. For the most part, the papers aren't necessary and the wool goes through without a hitch (as it should). But we're all about preventing problems, whenever possible. (Moving meat products across borders is a whole different issue.)
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Getting Your Raw Wool Fix from Far Away:
Or, importing raw fleeces to where you call home from foreign ports of call. . . .
by Carol Ekarius, co-author of The Fleece & Fiber Sourcebook
I have seen a few questions popping up in places where people are talking about The Fleece and Fiber Sourcebook that go something like, “Now I am finding out about all these breeds, I’d like to be able to [buy/sell] fleeces to or from [fill in the name of a locale]. Can I order them from overseas and have them shipped in, or are there issues with importing raw wool?”
I actually looked into this somewhat as we were working on the book thanks to a conversation I had with Tim Booth, our wonderful friend at the British Wool Marketing Board (BWMB). Tim went above and beyond the call of duty to (with the help of some other BWMB staff) get us many fleece samples and photos for some tougher-to-find British breeds. He said that BWMB was a bit cautious about sending fleeces to the United States because they sometimes got held up at customs, and occasionally rejected. Rejects got shipped back, which cost a bunch of money on what is still a low-value commodity overall.
Was I familiar with the regulations? he asked me.
“Not offhand, but I’ll find out,” I responded.
Importing to the United States
I called the Animal Plant Health Inspection Service of the United States Department of Agriculture (it’s called APHIS for short). I was quickly connected with a veterinarian who said it is fine to import wool from many countries, as long as it isn’t covered in blood or manure. He explained that there are countries where Foot and Mouth Disease (FMD) is active, and those countries have a few more considerations that have to be taken into account, but those that are FMD-free—including the United Kingdom—should not be a problem.
I told him Tim’s story of shipments that were turned around by U.S. Customs, and he said sometimes the customs agents, who actually do the inspections, may not understand the rules regarding wool. He told me to check out the Animal Product Manual chapter on Hides and Related Byproducts and he suggested that I send Tim the link with a note to check tables 3.7.14 through 3.7.17 (these charts are available at our Fleece & Fiber website), and he also suggested that the best way to ensure that customs agents know what to do is to include a written statement (see the sample) that this was raw wool from a healthy animal from an FMD-free country (notarized if you are concerned about validating fully), and include the table that shows the customs agent that he or she should release the fleece from customs with no problem so long as it is free from blood.
Lo and behold, these tables are a great resource. They help quickly clarify the process for fibers coming into the United States from FMD-free or FMD-troubled countries. Blood and excess manure are to be diligently avoided, but if you are buying fleece for handspinning, you sure as heck want it to be well skirted, and there should never be any appreciable blood stains on a fleece from a well-sheared critter.
So, if someone in an FMD-free country (list at the bottom of this post) wants to sell wool to someone in the United States, copy the first chart (3.7.14) and include it in the package, along with your statement that this is raw wool from [type of animal] (usually sheep, but could be goat, musk ox, yak, alpaca, or other ungulate not protected as a threatened and endangered species), grown in an FMD-free country. If you are in an FMD-troubled country, include the appropriate chart, and no matter which chart you are using, use a yellow highlighter to emphasize the correct decision mode.
Here's a link to the APHIS publication listing foreign countries and their disease status (including FMD) as of January 2012. It's the resource from which we developed the list included in this post. If you are reading that original APHIS document, note that some requirements (marked FMD/SR) apply to meat-based products only.
Exporting from the United States
This gets a bit more complicated for me, because each country has its own rules, but for European Union (EU) countries, I can define the current status. On February 25, 2011, the EU Commission adopted Regulation No. 142/2011, which allows that “fully treated” hair or wool can be imported into the EU countries from the U.S. and no documentation or APHIS approval is required. The U.S.-based exporter should have the European importer confirm in advance with the Border Inspection Post (BIP), through which the product will enter the EU, that the hair/wool is considered fully treated. In general hair/wool is considered by the EU to be fully treated if the wool/hair has undergone factory washing or been obtained as a by-product of the tanning of hides/skins. Hair or wool that is not “fully treated” doesn’t require shipment certification either, but it must be shipped from a U.S. facility that has been inspected and approved by APHIS Veterinary Services to ship untreated hair/wool to the EU. You can find a list of these facilities at https://webgate.ec.europa.eu/sanco/traces/output/listsPerActivity_en.htm#
The other suggestion from the U.S. veterinarian is to contact the relevant country's agricultural service (in Britain, this is DEFRA, the Department of Environment, Food and Rural Affairs, and ask if they need an import permit. He also suggested that you can check with United States embassy in your country and ask for the trade or import/export department, which may be able to help.
—Carol Ekarius
Donna Druchunas
Thanks, I am saving this info for future reference. Lots of new ideas to mull over…
Lesley
I’m in the UK and am often asked to export raw Bowmont to the USA. I investigated this with our govt Animal Health Export team and was told that RAW wool from UK to USA must be accompanied by an official export health certificate. This documentation has been agreed between your authorities and ours. I got a copy. It clearly states that I cannot export wool to the USA unless it has been commercially scoured in a commercial scouring plant. Raw wool is not acceptable. Without an Export Health Certificate my raw wool would not, as far as I undertasnd it, be a legal export to the USA. You rightly point out FMD as a main worry but dont forget weed seeds and insect pests. These can ber just as big a concern and will travel very happily in raw wool – however carefully skirted. I would very much like to export raw wool to the USA but as a responsible farmer I have to abide by the rules as described to me by my own government animal/byproducts health export team. I believe that Tim Booth is no longer rxporting raw fleeces from the WMB for the same reason but havent spoken to him for a few months about it.
Deb Robson
Lesley, that's very interesting. The information that we've linked to is the CURRENT U.S. Department of Agriculture regulations concerning the U.S. side of that discussion. We’d be interested in seeing the documentation that you have a copy of that contradicts what USDA/APHIS on this side told us and have published.
USDA/APHIS is our agency responsible for all agriculturally associated risks, so would be keeping in mind weed seeds and insects as well as diseases. http://www.aphis.usda.gov/
It will be interesting to see if the new (or newly discovered) sheep virus affects matters. http://bit.ly/zeHMtA
Sarah
To ship untreated wool into the UK/EU it needs a vet certificate relating to the health of the animals, and also needs to be imported to a certified wool handling centre.
Deb Robson
Sarah, is there an online link to those regulations? This topic overall is fascinating.
Sarah
Deb, The DEFRA website has the regs here:
http://www.defra.gov.uk/animal-trade/imports-non-eu/
for import from outside the UK.
I’ve spent a lot of time talking to defra about this and the main sticking point is that fleece has to go to a “registered handler/processor”. I have explained time and time again, that as spinners, we don’t want to import processed fleece, and that we don’t want to import fleece to send to a processing mill. Both of which are their official regulations for import of fleece.
There are some provisions made for “artistic use” however, and I am currently arguing that fibre crafts come under this bracket.
Deb Robson
Thanks so much, Sarah. As handspinners, we not only do not need (or want) commercially processed fiber, because commercial processing can damage the material, but we are talking about very small quantities. There is also the question of study samples: the minor amounts necessary for research projects like The Fleece & Fiber Sourcebook.
The challenge in all this is to find ways to meet the needs of various parties and protect the environments and animals of the countries on the receiving end.
The problem is by no means new; a most interesting article (there are books on the topic as well) is J. Donald Hughes' "The European Biotic Invazion of Aztec Mexico," in Capitalism Nature Socialism (interesting title for a journal), v. 11, no. 1 (2000), pages 105-112.
Do let us know what you discover and if there is anything we can do to facilitate the process. NONE of us wants to endanger animals. Yet there have to be ways to manage this.
At this moment, all resources are going to be tied up with efforts to deal with, and limit the damage from, the Schmallenberg virus, newly evident and only named in December. http://tgr.ph/xGAMfc – The current theory is that the virus transferred by way of midges that blew across the Channel.
Until that situation has been at least scoped out, our fleece transporting concerns are minuscule.
Koren
I’m in Australia, which has very strict quarantine laws because we are relatively isolated from many agricultural diseases and pests.
Although I don’t know the specific regulations relating to importing fibre, I would be 99.99% sure that anything that hadn’t been thoroughly washed would not be allowed in. Otherwise there would be the risk of VM and other potential disease-carrying organisms hitching a ride.
Deb Robson
Koren, not only isolated from hazards but also with one of the few economies that depend strongly on wool as a commodity.
Astrid Holdstein
This article is very interesting, thank you very much. Do you know, if there are any problems now concerning the new virus in Europe, Schmallenberg?
Kind regards
Astrid Holdstein
Deb Robson
Astrid, thanks for your note and your question. There are not current restrictions in place due to the Schmallenberg virus (which is theorized to be insect-borne), but there could be at any time. The UK is being affected by the virus and the DEFRA (official UK) site for breaking news is here: http://bit.ly/yHVPey .
textilehistorIE
Fantastic resource. So useful. Thanks for collating all of that.