C04_Consolidated Q and A.pdf

Q&A RESPONSE

Importer of Record, USDA Permits & Shipment Specifications

Question 5: Importer of Record / USDA Permits

USDA APHIS will serve as the Importer of Record and provide the required USDA permits. This is not

Life Couriers' responsibility.

5.1 Role of Importer of Record

USDA Veterinary Services (VS) is designated as the ultimate consignee and holds the official VS Permit for imports. COPEG (the foreign supplier coordination entity) utilizes this permit for import by preparing the shipment paperwork for the broker in accordance with VS Permit and U.S. Customs and Border

Protection (CBP) requirements.

5.2 Designated Points of Contact by Port of Entry

The following individuals serve as USDA points of contact for Importer of Record coordination, depending on the port of entry:

Port of Entry Designated POC Primary Role

McAllen/MAB Edgar Cruz Gutierrez Shipment coordination & customs liaison

Del Rio Frank Gutierrez Shipment coordination & customs liaison

5.3 USDA Permit Management

Responsibility for USDA permit management defaults to the National Wildlife Services Division

(NWSD). The VS permit is government-held and COPEG utilizes it for import coordination. Life

Couriers is not responsible for obtaining, managing, or maintaining USDA permits.

Question 6: Customs Brokerage & Documentation Management

Life Couriers will handle all customs paperwork and documentation. Life Couriers' customs broker is not responsible for preparing or submitting USDA permits or acting as the Importer of Record.

6.1 Division of Responsibilities

Role / Responsibility Responsible Party Activities

Importer of Record USDA APHIS / VS Hold VS Permit; designate ultimate consignee

Customs Brokerage Life Couriers' Broker File CBP/customs entries; manage

ACE declarations

Shipment Coordination COPEG + Life Couriers Broker Prepare paperwork; pre-clear with

CBP HQ

6.2 Customs Documentation Process

For each shipment arriving at the designated port of entry, the following customs documentation is completed:

• FAA Notifications — Filed by the broker for incoming aircraft

• CBP Immigration Requirements — eAPIS crew documentation and immigration pre-clearance

• Cargo Manifesting & Declarations — Filed via CBP's ACE (Automated Commercial Environment) system

• Pre-Clearance Coordination — USDA (via COPEG and designated POC) provides advance notice to CBP HQ to expedite clearance

6.3 Life Couriers' Customs Broker Role

Life Couriers' customs broker is responsible for:

• Day-to-day management of all customs paperwork and CBP interactions

• Filing required customs entries and cargo declarations

• Coordinating with CBP for cargo release and clearance

Life Couriers' broker is NOT responsible for:

• Preparing or submitting USDA permits (USDA responsibility)

• Acting as or designating the Importer of Record (USDA responsibility)

• Coordinating with foreign suppliers (COPEG responsibility)

6.4 Coordination Flow

The following entities coordinate on customs matters for each shipment:

• COPEG — Prepares shipment paperwork per VS Permit & CBP requirements; coordinates with broker

• Mubarqi Aviation — Handles transport of sterile pupae; coordinates with their broker for

FAA/CBP requirements

• Life Couriers' Broker — Receives COPEG paperwork; files CBP entries; manages customs clearance

• USDA (NWSD / Edgar or Frank Gutierrez) — Provides advance notice to CBP HQ; confirms IOR status

Question 10: Shipment Container & Weight Specifications

10.1 Standard Shipping Container

The standard shipping container for sterile pupae is:

• Container Volume: 40 liters per unit

• Container Type: Climate-controlled reefer/cooler container (standard USDA format)

• Typical Shipment Size: Up to 50 units per order

• Total Capacity: 2,000 liters (50 units × 40 liters/unit)

10.2 Weight Estimation

Sterile screwworm pupae are transported in a density medium (sawdust, bran, or similar substrate). Based on typical bulk density for packaged insect pupae and standard industry practices:

Container Specification Unit Weight (est.) Quantity Total Weight

Single 40L Container ~24–28 kg 1 unit 24–28 kg

Standard Shipment ~26 kg (avg) 50 units ~1,300 kg (1.3 MT)

Weight Estimation Basis:

• Bulk Density: Sterile insect pupae + density medium = approximately 0.60–0.70 kg/liter when packed

• Per Container: 40L × 0.65 kg/L = ~26 kg per 40-liter container (including container weight)

• Total Shipment: 50 units × 26 kg = ~1,300 kg (1.3 metric tons)

• Note: Actual weight may vary ±10% depending on packing density, substrate moisture, and medium type

10.3 Shipment Handling Considerations

For transportation and logistics planning:

• Refrigeration Required: All shipments must maintain 2–8°C cold chain during transport

• Packaging: Each 40L container is sealed with tamper-evident seals and packed in secondary containment

• Hazmat Classification: Sterile pupae shipments require hazmat handling per DOT regulations

• Carrier Requirements: Temperature-monitored refrigerated transport with continuous tracking

• Delivery Window: Standard 15 calendar days from order to delivery at designated USDA facility