Compliance guidance. DATES AND RULES AS SEEN ON 7 NOVEMBER 2026. The Lacey Act points are from the US Department of Agriculture (APHIS) page, last modified 19 October 2026. Duty rates and fire-test rules could not be read from a primary document this session, so none is quoted. US trade rules change often: confirm every figure with a licensed customs broker and the importer of record on the day. This is not legal, customs or engineering advice; confirm with your contract adviser or the relevant authority. Nothing here says that Make Bespoke Studio or any partner workshop ships to the US, files any declaration, or holds any document listed.

At a glance

ItemWhat it saysDetail seen 7 Nov 2026Source
Wood declarationLacey Act declaration for covered plant products, now including furniture.Scientific name and where harvested, per piece of plant materialAPHIS page, modified 19 Oct 2026
Phase for furnitureAPHIS began implementing Phase VII, which covers furniture among other products.From 1 December 2024APHIS page
How it is filedElectronic only: ACE, or APHIS’s LAWGS web interface.Paper forms not accepted from 1 January 2026APHIS page
Who filesThe importer of record or their agent.Agree who this is before shippingAPHIS page
Small amountsA de minimis disclaimer (code G) exists for very small plant content.Up to 5% of unit weight and 2.9 kg per entry, per the pageAPHIS page
DutiesA US tariff on timber and wooden furniture derivatives is reported.Rate and date NOT confirmed from a primary documentSecondary reports only
Fire rulesUS federal, state and contract rules differ from UK ones.Not equivalent to the UK rules; not readAsk the importer

Checked 7 November 2026. Only the Lacey Act rows come from a primary document. No duty rate and no US fire-test requirement is quoted; each is listed in the unverified notes.

The Lacey Act wood declaration

The US Lacey Act declaration is a customs-entry requirement for covered plant products. The Animal and Plant Health Inspection Service (APHIS) page, last modified 19 October 2026, says APHIS began implementing Phase VII on 1 December 2024, and that this phase covers furniture among other products. From 1 January 2026 APHIS no longer accepts paper forms (PPQ 505 or 505B): filers use ACE, the customs system, or APHIS’s LAWGS web interface. The importer of record or their agent files.

For each piece of plant material the importer needs the scientific name and where the plant was harvested. That is the supplier’s job to supply, early: a trade name such as “oak” or a country of manufacture does not do it. The page allows a special use designation in certain circumstances where genus and species cannot be given, and a de minimis disclaimer (code G) where plant material is no more than 5 percent of a unit’s weight and the entry’s total stays within 2.9 kilograms. Neither is likely to suit a solid-timber or veneered piece, so confirm with the broker before relying on either.

The page does not list which tariff headings are in scope or how composite panels are treated; it points to an implementation schedule searchable by heading, which we could not read. Whether a given bespoke piece is covered is for the broker.

Four checks before a piece ships to the USFour boxes in a row: wood declaration, duty status, fire rules, importer of record.1 WOODSpecies and countrywhere the woodwas harvestedLacey Act declaration2 DUTYWhich tariffheading, and therate on the dayCheck with a broker3 FIREFederal and stateupholstery rulesdiffer from the UKAsk the importer4 FILERWho is importerof record andfiles the entryAgree in writingRates and rules move. Date every figure, and check the day you rely on it.
Four checks before a US-bound piece ships. Original drawing by Make Bespoke Studio.

What to collect from the workshop before the order

The declaration is only as good as the species and origin records behind it. For furniture built from solid timber, veneer, plywood and board from several sources, those records have to be asked for at the start, not at the point of shipment.

ItemWhat the importer needsWho usually has it
Scientific nameGenus and species of each piece of plant material, not the trade name. A special use designation is allowed in some cases where genus and species cannot be given.The workshop, from its timber, veneer and panel suppliers.
Where harvestedThe country (and place) where the plant was harvested, not where the piece was made.Sawmill or veneer supplier, passed up the chain.
Plant material in the pieceWhich parts are wood, veneer, panel or other plant material, including in composite panels.The workshop, from the bill of materials.
Entry filerThe importer of record or their agent, filing in ACE or LAWGS.The US importer or broker.

The same records answer the questions in UK Timber Regulation due diligence and specifying FSC and PEFC, but they are a different legal test. A certificate alone was not established as a substitute for the species and harvest data.

Duty: what we can and cannot say

Reports from customs and trade firms, dated January 2026, describe a US Section 232 action on timber, lumber and derivative products that reaches upholstered wooden furniture and kitchen cabinets, with a postponed increase scheduled for 1 January 2027 and a separate, lower treatment for goods of UK origin. We could not read the proclamation or the tariff schedule this session, so no rate is given here and none of that should be relied on. Duty depends on the heading a piece is classified under, its origin, its value and the day it is entered. Agree with the broker, in writing, which heading and which rate are being assumed.

For a designer, the practical point is the contract: say who pays duty, who is importer of record, and what happens to the price if the rate changes between order and entry. See commodity codes for bespoke FF&E for why classification decides this.

Fire and flammability: do not assume equivalence

The UK upholstery route (see domestic or contract fire regulations) does not carry across. The US has a federal upholstered furniture rule, state rules (California’s technical bulletins are the best known) and hospitality contract tests that buyers write into their own specifications. We could not read any of them this session, so we state no test, pass mark or label wording.

Ask the US importer or the project’s US specifier which regime applies to the destination state and building type, whether a UK test report will be accepted or a retest is required, and what label the piece must carry. Do not describe a UK-tested piece as meeting a US requirement. Test reports are read in how to read an upholstery fire test report.

What to ask the US importer

  • Who is importer of record, and which broker files the entry?
  • Which tariff heading and which duty treatment are assumed, and as of what date?
  • Is a Lacey declaration needed for this item, and what does the broker need from the supplier?
  • Which flammability and labelling rules apply in the destination state and building type?
  • Which Incoterm-style split of cost and risk applies to freight, duty and damage? Put it in the contract.
  • Does the packaging need any treatment or marking for US entry? See packaging and crating specification.

Specification wording

Paste into your schedule or specification and replace anything in [square brackets] with your own figures. Wording is a starting point: your specification governs.

Importer of record
For items entered into the United States, the parties state in writing before order who is importer of record and which customs broker files the entry: [the Buyer / named importer / named broker].
Lacey Act information
Where the Supplier is not the importer of record, it provides before shipment, for [each item / consignment], the scientific name (genus and species) of each plant material in the item and the place where it was harvested, so far as within its knowledge, with its supplier records as evidence. A change of species, source or supplier requires written notice before shipment.
Duty and classification
The tariff heading, the duty treatment assumed and the date it was checked are recorded in [the order]. [The Buyer / the Supplier] bears duty and any change in rate between order and entry.
Fire requirements
The flammability requirements of [state / building type] for the items are stated in [the specification]. The Supplier states in writing before order whether its test evidence meets them or whether a retest is needed.

Terms used on this page

Lacey Act declaration
A US customs-entry declaration for covered plant products giving, among other data, the scientific name and where the plant was harvested. Filed through ACE or APHIS’s LAWGS.
Importer of record
The party legally responsible for a US customs entry and its duties; it may use a customs broker as agent.
HTS (tariff) heading
The classification code under which goods are entered. It decides the duty and whether other rules apply.

All specification and delivery terms

Standards and sources

  • USDA APHIS: Lacey Act (plant imports): Read 7 Nov 2026; page modified 19 Oct 2026.
  • US Section 232 timber and lumber proclamation; HTSUS chapter 99: Not read this session. Confirm current text and rates with a customs broker.
  • US upholstered furniture flammability rules (federal, state, contract): Not read this session. Confirm with the importer.

Questions we are asked

Does the Lacey Act apply to furniture?

APHIS says it began implementing Phase VII on 1 December 2024 and that the phase covers furniture. Whether a particular piece is in scope depends on its tariff heading and materials, which your broker confirms.

What does the declaration need?

For each piece of plant material, the scientific name and where it was harvested, filed by the importer of record or their agent through ACE or LAWGS. Paper forms stopped on 1 January 2026.

What is the duty on UK-made furniture?

This sheet does not state one. Reports in early 2026 described a lower UK treatment and a postponed increase, but we could not confirm either from a primary document. Ask a customs broker for the figure on the day.

Can I say a UK-tested piece meets US fire rules?

No. The regimes are different and we did not establish equivalence. Ask the importer which rules apply and whether a retest is needed.

Who files the declaration?

The importer of record or their agent, not normally the UK supplier. The supplier provides the species and harvest data.

Is this legal advice?

No. Rules and rates move, so confirm with a licensed customs broker or trade lawyer before you rely on anything here.

Download the factsheet

A two-page A4 PDF with the four checks for a US-bound piece, what the Lacey Act declaration needs, what to ask the importer and wording to paste into a specification, as seen on 7 November 2026.

Factsheet TL-SPE-42 v1.0 (PDF)