Paladin brushes

The contradictory and illogical laws and regulations by 'government types' AKA officials elected by the body politic are a attempt to control the number one illegal trade and source of revenue for criminal and armed political groups. It's called the wild animal trade and in cash volume makes weapons smuggling, narcotics, stolen antiquities, blood diamonds and human trafficking nickel and dime operations. The most dangerous 'government types' job worldwide are the various enforcement agencies who are habitually understaffed, underfunded, undergunned and often alone with the highest worldwide murder rate of all law enforcement communities. Customs is the last line of defense against smuggling. 10 immigrants just died in a Texas parking lot inside a trailer and cobras were found inside cans these last two days. So yes, it's illogical to us, a PITA etc. We have equally illogical and PITA means to ship said brushes.

Ironic and are we really paying these government types

- Paladin can import a badger knot from China
- Paladin cannot export that same badger knot in a brush

I would love to hear the logic of that legislation.

The law was motivated by good intentions, but it -- and especially the regulations promulgated under it -- was not artfully drafted.

I could easily get off into a rant but won't, at least not yet.

We can export badger-hair brushes in keeping with the law, just not economically.

Dark Holler Design Works, LLC holds a permit, which we pay $100 annually to maintain. No big deal. Whenever we import knots from China, I do pre-alerts with the US F&WLS and ensure proper filing of the required declarations, which entail payment of a $93 inspection fee. Also no big deal.

The hitch comes when someone outside the US wants to buy a brush and have us ship it to an ex-US address, i.e., engage in commercial export of a badger-hair containing product. Then I have to go through all the same procedures, again entailing a $93 inspection fee, whether or not any inspection will actually occur (which is unlikely). Even without the fee, other aspects of compliance take more time than the sale of a single brush is worth. Any time I spend not making brushes is time I don't spend making brushes.

There is a special program that qualified exporters can apply for acceptance into that provides exemption from the inspection fee (but not the filing and inspection requirements). We don't qualify, however, because we import knots from China in quantities (more than 25 "items") and in dollar amounts that exceed the applicable limits.

The practical effect is that any US brush-maker that aspires to compete outside the US with foreign makers (take your pick) is screwed. If I were a hobbyist brush-maker, I wouldn't sweat it. But we're not that. I have too much invested and too much at stake to run the risks.

That said, I haven't given up on the possibility of bringing about a change in the rules. As they presently apply to shaving brushes, the regulations aren't serving the law's policy objectives; they're mainly producing unintended consequences that operate in favor of ex-US makers to the very substantial disadvantage of US makers.

Ironic and are we really paying these government types

- Paladin can import a badger knot from China
- Paladin cannot export that same badger knot in a brush

I would love to hear the logic of that legislation.

The logic is actually quite simple:

Badgers, in the US, are on a protected species list, with some subspecies wearing an "ENDANGERED" tag, and others merely "THREATENED".

The logic of the law is such: When a badger knot is purchased from a foreign country, it is a safe bet that the hairs were not illegally poached in the US.

When the badger hair brush is manufactured in the US, their is a much more involved process to either prove the hair did not come from an illegally poached source, or the purchase of a permit that allows the brush maker to be in possession of, sell, and export for sale, a byproduct of a potentially threatened species.

In essence, the law is designed to protect a threatened and endangered group of subspecies in the US.

The same type of regulations are in place for the interstate transport, and the import/export of many species of reptile and bird, their flesh or feathers, or the byproducts thereof.

Whether or not these regulations are effective, or properly enforced is an entirely different discussion that treads much too closely to the political/economical discussions that are not allowed here...

FWIW, I generally don't go around looking for opportunities to stir up discussion of this topic, but when it arises in thread related to Paladin shaving brushes, I feel obliged to respond.

I'm sure as hell not indifferent. I support the fundamental purpose and objectives of the US Fish & Wildlife Service, and I don't believe the existing law as it applies to my business was motivated by evil objectives. But in practical effect, it misses its proper mark by the breadth of the Atlantic and Pacific Oceans. No one uses US badger-hair to make shaving brushes. When I offered that comment to a high-level F&WLS officer, it was explained to me that the law exists in part to ensure reciprocal compliance under treaties with countries in Europe that have outlawed use of European badger hair in the manufacture of shaving brushes. Think about that! Any irony there?

The logic is actually quite simple:

Badgers, in the US, are on a protected species list, with some subspecies wearing an "ENDANGERED" tag, and others merely "THREATENED".

The logic of the law is such: When a badger knot is purchased from a foreign country, it is a safe bet that the hairs were not illegally poached in the US.

When the badger hair brush is manufactured in the US, their is a much more involved process to either prove the hair did not come from an illegally poached source, or the purchase of a permit that allows the brush maker to be in possession of, sell, and export for sale, a byproduct of a potentially threatened species.

In essence, the law is designed to protect a threatened and endangered group of subspecies in the US.

The same type of regulations are in place for the interstate transport, and the import/export of many species of reptile and bird, their flesh or feathers, or the byproducts thereof.

Whether or not these regulations are effective, or properly enforced is an entirely different discussion that treads much too closely to the political/economical discussions that are not allowed here...

That's not entirely accurate. I've read the law. And I've had it (variously) explained to me. Protection of US badgers has never come up in discussion. The law as it applies to import of badger hair knots from China, or as it applies but is generally not enforced with respect to badger-hair shaving brushes exported into the US from Europe has little, if anything, to do with protecting US badgers.

And even if US F&WLS inspectors had it in mind to protect US badgers when they collected inspection fees for exported shaving brushes, how do you suppose they would distinguish brushes containing US badger hair from those containing Chinese badger hair? I'm pretty sure they don't do PCR analysis at the ports.

I called my state district congressman on an issue. They were not even aware of the effort to enact this particular piece of legislation. I was THE ONLY person to contact them and provide a cogent and polite argument via email, snail mail and follow up phone calls. The opposing industry never thought the effort a threat and
never reacted. My congresswoman voted in favor and it passed by a margin of three.
How many people are members of the major forums? It only takes a small number of people to make noise on an issue left silent. The shaving community(s) can be apolitical for fear of it's own six o'clock shadow or actually do something.

Well, if there is a low risk way for friends on forums to send these across borders, that would be nice. These are by far my favorite brushes, and I’d love to see them in shave of the day photos across the world.

I have had a US F&WLS representative reference this article in support of US import/export law as applicable to badger-hair shaving brushes: https://www.researchgate.net/publication...an_badgers. The rationale being offered in support of inspection and fee requirements had nothing to do with protecting US badgers and everything to do with protecting Eurasian badgers in keeping with reciprocal treaties. That would make a more compelling argument if European makers/vendors selling and shipping brushes to individuals in the US contended with the same obstacles US makers face in selling and shipping brushes to buyers outside the US.

This isn't diatribe. It's just the way it is.

And I'm posting in this thread because I want those who live outside the US who might like to buy one of our brushes and wonder why we won't ship to them to understand it isn't because we don't care.

Well, if there is a low risk way for friends on forums to send these across borders, that would be nice. These are by far my favorite brushes, and I’d love to see them in shave of the day photos across the world.

I honestly think there is virtually no risk.

June Foray, voice actress and lifelong political activist passed today at 99. She will be remembered by older members as the voice of Rocky the Flying Squirrel, Natasha Fatale and Nell. Neat lady, I met her once protesting something or other. So, in the words of that graduate of Whatsamatter U. "watch me pull something out of my hat" and change the damn law. Now, where did that Ralph Nader book on community action go?