Irwin asked me to elaborate on how Homeland Security practices are
effectively prohibiting one-time imports of honey from Canada.  I'll be glad
to, especially in the hope that someone out there knows a way to make such
an import.

As background, for more than 20 years we have been able to drive to Canada,
load up or truck, trailer, or car with food and import it into the US
*providing
that the purchase price is less than $2,000.*  That $2,000 limit has not
changed, but at today's general price levels it does not provide for the
importation of very much honey.

If the value is over $2,000, customs/import regulations come into effect and
following 9/11 they hae become very stringent.  For many years, I drove my
truck to Canada and picked up products with a total value of close to
$2,000.  So many, that Customs officials reconized me, which was a great
help.  About three years ago, there was a time when I wished to import
product with a value of approximately $5,000.  I knew about the $2,000
restriction so set out to do whatever was necessary to make my import.

I started with a local customs broker who I use to import non-food products
from Europe.  Sure, they said, we will handle it just let us know when you
are ready.  So, about a month prior to my desired date I let them know, they
arranged a trucker pickup and referred everything to their normal border
agent, Federal Express, in northern New York.  Then came the dreaded phone
call from my broker..."the border agent says they can't handle it, and we
have not been able to find anyone who will".  (My broker doesn't normally
deal with food products.)

So, I got involved.  I called Customs.  They said approximately "You should
not have any problem.  However, before we can process the paperwork you need
to register with the Food and Drig Administration.  Ok, I imagined a really
big deal but found that registration was easy provided that my
NHB assessments were fully paid.  They were, and I was granted an FDA
registration number in about a week.

I called Customs back.  By the way, I was working with a senior person at
the Canadian border crossing at the Thousands Islands.  When I called back
and told him I had my number, he said approximately "just be sure your
number is on all the paperwork, and tell them if they have any questions
they should call me".  So, I went back to my broker, who went back to the
border agent...

Now, for the benefit of those who do not bring in commercial goods from
Canada, at each crossing there are border agents who handle the paperwork to
get the goods into the US.  The Thousands Island crossing is a large busy
place handling a lot of material from Ontario and Quebec.  There are at
least 50 border agents there, each in their own set of trailers, and
employing what must be several hundred people.   Regulations issued after
9/11 provide that the paperwork for each import must be at the crossing a
set number of days before the actual import and must conform to regulations
that include provisions that the border agents 'know' the importer as well
as the exporter.  So, when a tractor trailer carrying material from 15
different exporters and designated to 10 importers (pick your own numbers)
arrives at the border, Customs knows exactly what is on board and can choose
to inspect all, any portion, or just wave through.  Mostly, the trailers are
waved through.

The 'rub' comes from the requirements that the border agents 'know'
the exporter and importer.  While they do not have to actually meet you,
shake your hand and look you in the eye, they do have to do more than talk
to you on the phone or process your paperwork.  In effect, they have to do
enough work to have some certainty that neither the exporter or importer is
a terroist.  Presumably this involves checking at least some references,
listings in trade directories, etc.  It takes time.

Now, the border agents are in business to make money.  With large
importers/exporters they charge fixed, negotiated fees.  With smaller
importers/exporters they charge based on the value of the goods.  The
difficulty with someone "unknown" trying to make a single (or two or three)
imports a year from exporters who are not 'known', is that the border agents
are of the view that they cannot possibly charge enough to recover their
costs and make a profit.  I went so far as to tell more than one agent "give
me a number on what you'd have to charge to make the import; maybe I'd agree
to pay it".  None would even do that.

So, back I went to the senior Customs agent.  "Any way I can import without
using a border agent, perhaps by renting a truck so I would not have to get
combined with others?"  Answer*:  No, we require that an approved Agent get
the material pre-cleared before importation*.  Question "Do you know that
none of the Agents at the crossing will take on an unknown importer trying
to bring in material from an unknown exporter unless they agree to make
mutiple imports during the year?"  Answer*:  "No, I didn't know that and I'm
reasonably sure this has not been brought to our attention.  But I do know
that there is extensive work involved so I can understand that Agents might
decline one-time imports from unknown parties." *
**
So, there it stands.  I know of one comb honey producer in SAS that has
looked into exporting to the US and has essentially 'given up' for the same
reason.  Thankfully, up until now he has been able to sell everything
produced to customers in Canada.  Long term he hopes to make arrangements
with just one US importer who will redistribute to others, but that will
raise the cost and may limit the market.

If anyone out there has been able to make one-time imports of honey woth a
value of over $2,000, I'd like to know about it so I might be able to
emulate the procedures followed.

Lloyd

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