The 126-year-old Lacey Act makes it a federal crime to import wood harvested illegally anywhere in the world.

United States v. Boise Cascade Company

On April 27, 2026, Boise Cascade Company was sentenced for a scheme in which hardwood plywood manufactured in China was routed through Malaysia to evade U.S. anti-dumping duties. By the time the product reached U.S. customs, it appeared to originate in Malaysia — not China. Chinese hardwood plywood is subject to both anti-dumping tariffs and heightened scrutiny under the Lacey Act given China's complex timber sourcing environment. The penalty for Boise included a $6,382,000 criminal fine, five years of probation, and a court-mandated compliance plan covering supply chain transparency and responsible sourcing practices.

What Is Trans-Shipment?

Trans-shipment is the practice of routing goods through an intermediate country before final import, often to obscure their true country of origin. Trans-shipment-based origin fraud is rarely a single bad actor. It frequently involves more than one stakeholder: a shipper in the exporting country who reclassifies goods; a freight forwarder who processes the paperwork; a customs broker who files the declaration; a manufacturer in the transit country who may or may not know what flows through their facility. By the time wood products reach a U.S. importer, the chain of custody has likely passed through three or more jurisdictions, each with its own documentation, and none of it visible to the ultimate buyer that is held accountable under the Lacey Act. 

What is the Lacey Act?

The Lacey Act's timber provisions, added by the Food, Conservation, and Energy Act of 2008, require importers to file a declaration for certain plant products — including wood — specifying the scientific name of the species, the value, the quantity, and the country of harvest. A company that only declares manufacturing origin can be in violation of the Lacey Act if the timber contained in a product was illegally harvested in a third country. Enforcement has focused on cases where: 

·      The origin declaration is materially false (as in Boise Cascade), 

·      The underlying timber violates foreign law (illegal logging in source countries)

·      Anti-dumping evasion is intertwined with origin misrepresentation

The Department of Justice has made clear it will pursue both civil and criminal penalties under the Act, and recent sentencing patterns suggest courts are willing to impose substantial fines and probationary compliance requirements.

Authentic Due Diligence as the Defense

Companies that can demonstrate they took reasonable steps to verify origin, species, and legality before importing are in a better legal position than companies that do not know (negligent) or rely on synthetic data (AI guesswork / Trade data). 

What does meaningful due diligence look like in a high-risk timber supply chain?

1.        Map the timber supply chain to the forests with supplier-verified data, collecting an audit trail along the way as well as evidence (orders, payment receipts, shipment records) from suppliers every step of the supply chain.

2.        Look for the signals of trans-shipment risk. These include: unusually short manufacturing lead times for a product that requires seasoning or processing; declared origin in a country with limited capacity in the relevant species; pricing inconsistencies relative to country-of-origin production costs; routing patterns that pass through known trans-shipment hubs.

3.        Verify species and harvest origin independently. DNA analysis and isotopic tracing of wood can now provide forensic confirmation of harvest location — a capability that has been used in multiple Lacey Act investigations. This isn't standard for every shipment, but should be considered on a sampling basis to demonstrate reasonable care. 

4.        Document your process. If a Lacey Act investigation begins, a documented due diligence program, supplier risk assessments, and verified sourcing records are the evidentiary record that will build a solid defense.

The EUDR Connection

The EUDR requires companies to demonstrate that commodities — including timber and wood products — have not contributed to deforestation, with geographic traceability to the plot of land. It, too, requires companies to perform due diligence  through the extended supply chain down to the forests that timber is sourced from. Trans-shipment fraud poses a similar risk for EUDR compliance as it does for the Lacey Act. Companies building EUDR-ready supply chain programs are, in effect, building Lacey Act-ready programs as well, and should seek to include both markets in one standard, global mapping and timber supplier due diligence program. 

About Sourcemap

Sourcemap helps companies build supply chain traceability programs that extend to the harvest and production level — providing the documentation and visibility needed to meet Lacey Act, EUDR, and responsible sourcing requirements. Get in touch with our deforestation regulatory experts to learn more: https://www.sourcemap.com/