Lately it has come to our attention that kratom (MITRAGYNA SPECIOSA) is being targeted more frequently in the past couple of months. Specifically, U.S. Customs and Border Protection (“Customs” or “CBP”) and the U.S. Food and Drug Administration (“FDA”) have been examining and detaining kratom shipments from overseas. Additionally, express consignment operators such as FedEx, UPS, and DHL, are cautious to ship the product because of the potential problems associated with this botanical.
These delays can be attributed to FDA’s import alert 54-15. The alert provides for:
DETENTION WITHOUT PHYSICAL EXAMINATION OF DIETARY SUPPLEMENTS AND BULK DIETARY INGREDIENTS THAT ARE OR CONTAIN MITRAGYNA SPECIOSA OR KRATOM
The language of the import alert focuses on “DIETARY SUPPLEMENTS AND BULK DIETARY INGREDIENTS.” These types of goods implies an end use for human consumption purposes. By classifying the product plainly and vaguely as kratom (MITRAGYNA SPECIOSA) on Customs and shipping documents, you are leaving the examining officers at ports of entry across the U.S. with the ultimate decision as to admissibility. We have also seen declarations such as: incense, soap scrubs, and clothing dye. Accordingly, the intended use of kratom when imported provides an important factor in determining the kratom’s admissibility. Thus, one must articulate to the federal agencies the use of the kratom properly so as to argue that it falls outside the scope of the import alert.
We currently represent numerous kratom importers to establish a plan and dialogue with the federal agencies who regulate kratom so as to avoid unnecessary delays and improve clearance of their shipments. As a result, we have been successful in getting kratom released from detention/seizure by Customs/FDA. Contact us immediately if your shipment is being detained by the federal agencies.
For more information about an importing kratom or for assistance with any of the issues noted above, contact Abady Law Firm, P.C., at 800.549.5099, to speak with a international trade attorney today!
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India’s import and export method is managed by the Foreign Trade Act of 1992 (full text) and India’s Export Import (EXIM) strategy.
Making registration with local licensing authority is a precondition for the import and export of products.
The customs will not let for clearance of goods except the importer has get hold of an Import Export Code (IEC) from the local authority.
You can find Import export data in Mumbai to find more information online!Policy of ImportThe Indian Trade Classification (ITC) - Harmonized System (HS) differentiates the products into three different groups which include Restricted, Canalized and Prohibited.
There is no requirement to find any import license or even permission to import the products.
The goods added into the license must be disposed of in the way particular by the license authority, which must be clearly showed in the license particularly.
This whitepaper documents ComplianceQuest’s position regarding compliance to Electronic Records; Electronic Signatures 21 CFR Part 11.
Some industrial segments need to be exponentially stringent with their quality and compliance processes compared to other segments.
The Life Science industry is part of this stringent segment.
They need to ensure the quality of their products because they deal with human safety.
The accuracy and efficiency of their work could well be a matter of life and death.
