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Primer on Importing & Exporting CITES-Listed Species Used in the United States in Dietary Supplements, Traditional Herbal Medicines, and Homeopathic Products Prepared by The American Herbal Products Association This document is the property of the American Herbal Products Association (AHPA) and is for AHPA purposes only. Unless given prior approval from AHPA, it shall not be reproduced, circulated, or quoted, in whole or in part, outside of AHPA, its Committees, and its members. Cite as: American Herbal Products Association. November 2013. Primer on Importing & Exporting CITES-Listed Species. AHPA: Silver Spring, MD.
Primer on Importing & Exporting CITES-listed Species Table of Contents AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Statement of Purpose The American Herbal Products Association (AHPA) is a U.S. A number of AHPA's members market products that contain national trade association representing the herbal products as ingredients plant species, and in some cases animal species, industry. AHPA is comprised of domestic and foreign compa- that are listed in one of the CITES Appendices. AHPA and nies doing business as growers, processors, manufacturers, and its members therefore have an interest in CITES and need to marketers of herbs and herbal products. AHPA serves its understand the processes and practices that must be followed members by promoting the responsible commerce of products to be in compliance with CITES requirements when import- that contain herbs.
ing and exporting CITES-listed species.
The Convention on International Trade in Endangered Species The purpose of this work is to provide that understanding.
of Wild Fauna and Flora (CITES) is an international agree- ment that became effective in 1975 and that currently includes 179 countries as members (called Parties). Specific require- ments have been established for international trade in plant This document was created through the joint efforts of AHPA and animal species that are listed under CITES, and these staff and member company representatives. Particular appre- requirements differ for each of three defined CITES ciation is due to Edward Fletcher of Strategic Sourcing Inc. Appendices. The placement of a species in one of the CITES Editorial review was provided in part by staff of the U.S. Fish Appendices is determined from the perceived level of potential & Wildlife Service's International Affairs Program. Financial extinction or endangerment, and exploitation of the species in support was provided by the National Fish and Wildlife international trade. AHPA, November 2013 ahpa.org • February 2013 • Page 3
Primer on Importing & Exporting CITES-listed Species Organization of the Primer The Primer is organized into six sections. Section 1 is an fied species is provided in Section 5. introductory overview of CITES – its history and purpose and a summary of decision making and enforcement poli- Section 3 provides an overview of how CITES is implemented cies. This section does not provide extensive detail as the in the United States and identifies which government agencies CITES Secretariat maintains very comprehensive informa- are responsible for its implementation and enforcement. tion on its website (www.cites.org). Therefore, much of this Section 4 describes in detail all of the steps that are necessary introductory section refers to information available on the to import and export CITES-listed species. It provides details CITES website.
about the permitting processes for both U.S. Fish & Wildlife Section 2 of this document describes the identification of all Service and USDA Animal and Plant Health Inspection of the species, plant and animal, that are listed in the CITES Appendices and that are known to be in trade in the United Section 6 provides contact information for the U.S. agencies States as ingredients in medicinal or therapeutic agents or as responsible for the implementation of CITES and sources of ingredients in dietary supplements. These species may be in additional information. It also contains example checklists for trade in other types of products as well. A list of the identi- the basic import and export processes. AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Section 1: What is CITES?1 Interest in environmental protection in the early 20th century Countries that become signatories to CITES take on respon- led to numerous meetings and conversations about the need sibilities for monitoring and controlling international trade for a unified international approach to species conservation. in the species that have been listed in the Appendices. These IUCN2 was founded in 1948 to serve as a network of govern- responsibilities include actions that are to be taken for both ments and non-government organizations with a common importation and exportation of these species and the Parties interest in protecting nature. A resolution adopted at a 1963 each agree that they will not allow trade in any listed species meeting of IUCN proposed an "international convention on "except in accordance with the provisions of the present regulation of export, transit and import of rare or threatened Convention." Each Party to the Convention must designate wildlife species." That proposal served as the genesis for one or more Management Authorities to administer a per- CITES. Originally called the Washington Convention, as it mitting system and one or more Scientific Authorities to was signed in Washington, D.C., the text of the Convention advise them on the effects of trade regarding species listed was adopted by 80 original signatories in 1973 and came into under CITES.
force in 1975. Countries that are signatories to CITES are known as "Parties." Collectively known as the Conference of the Parties (CoP), member countries meet every two to three years to administer CITES functions by maintaining three separate lists, called the ongoing work of CITES. These meetings provide the Appendices, of internationally-traded plant and animal species opportunity to review, discuss, and negotiate changes in the that have been identified as subject to the protection of the implementation of CITES.   All major decisions, including Convention. CITES defines these lists as follows: changes in protections for certain species, are made by voting »Appendix I includes all species threatened with Parties at a CoP. extinction which are or may be affected by trade. Trade Several CITES advisory committees provide policy guidance in specimens of these species must be subject to and technical support to the Secretariat and the Conference particularly strict regulation in order not to endanger of Parties. These committees meet between CoPs, often further their survival and must only be authorized in developing documents to inform the decision-making »Appendix II includes: and operational direction to the Secretariat regarding CITES implementation and may advise other committees.  It drafts a) all species which although not necessarily now resolutions for consideration by the Conference of the Parties threatened with extinction may become so unless and carries out any activities assigned to it between meetings trade in specimens of such species is subject to of the Conference of the Parties.  The Standing Committee strict regulation in order to avoid utilization is also responsible for overseeing the development and exe- incompatible with their survival; and cution of the Secretariat's budget.
b) other species which must be subject to regulation in order that trade in specimens of certain species The fill gaps in referred to in sub-paragraph (a) of this paragraph biological and other specialized knowledge regarding species may be brought under effective control (i.e., of animals and plants that are, or may become, subject to CITES trade controls. They undertake periodic reviews of listed species, advise when trade in a particular species may be »Appendix III includes all species which any Party unsustainable, and draft documents for consideration at CoPs.
identifies as being subject to regulation within its jurisdiction for the purpose of preventing or restricting Meetings of the CoP are attended by delegations from the exploitation, and as needing the co-operation of other Parties, but are open to observers as well. Observers may be Parties in the control of trade.
countries that are not yet Parties to CITES, other organiza- tions involved in the conservation of species, and other inter- national bodies. Meetings are also open to observers from the 1 Much of the information in this section is derived from the CITES website, general public.
2 Originally the International Union for Protection of Nature; later revised to the The United States has been a Party to CITES since its International Union for Conservation of Nature and Natural Resources; now commonly known as IUCN, International Union for Conservation of Nature.
inception. Responsibility for ensuring implementation of AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species CITES in the United States has been assigned to the Wildlife Service leads the U.S. delegation to the CoP. In Department of the Interior, U.S. Fish & Wildlife Service. preparation for meetings, U.S. Fish & Wildlife Service inter- Any company that imports or exports CITES-listed species acts with federal and state agencies to gather trade and bio- into or out of the United States must be aware of and must logical data about species that are or may become listed under conform to the regulations that the U.S. Fish & Wildlife CITES. Public input and recommendations are sought using Service establishes, which are discussed in detail in Sections Federal Register notices, website postings, and public meet- ings in order to prepare the content of discussion documents In carrying out its CITES responsibilities, U.S. Fish & and U.S. negotiating positions for CoP meetings. AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Section 2: CITES-Listed Species in Commerce Since its inception in 1975, the number of taxa listed in the listing of the plant. These annotations may relate to matters CITES Appendices has grown to over 5,000 species of animals and almost 30,000 plant taxa. The large number of listed plant taxa is in part because several entire families, including The species within a particular genus that are subject to Cactaceae and Orchidaceae, are listed in the Appendices. Both U.S.-native and non-native species are listed in the Appendices. » The applicability of the CITES listing to specific The vast majority of those species, however, are not used in the country(ies) of origin, United States as medicinal or therapeutic agents or as ingredi- » The specific parts and derivatives of a plant that are ents in dietary supplements. subject to CITES control, and The list of commonly-traded species provided in Section 5 of » The exclusion of products, including finished products this document is a cross-reference of the species that are listed packaged for retail trade, which contain the listed in the CITES Appendices and that are also included in AHPA's Herbs of Commerce, 2nd ed.1, in the Homeopathic Pharmacopoeia of the United States (HPUS) The provisions of CITES do not necessarily end when CITES- 2, or in the current English edition of the Pharmacopoeia of the People's Republic of listed plant material is processed into a finished product such as a dietary supplement or traditional herbal health product. 3 (PPRC). The first of these references lists over 2,000 botanical substances in trade in the United States. The HPUS Exporters of finished botanical products need to be aware of is the official listing of homeopathic drugs for use in the the following if their product contains material from one or United States produced from a variety of botanical and animal more CITES-listed plants: species. The PPRC is the official listing of Chinese drugs, » Whether finished product exemptions have been including hundreds of botanical materials. The PPRC also lists established for the CITES-listed plant species present numerous animals that are used in traditional Chinese in their products, or » Whether any of the CITES-listed plant species While the list provided in Section 5 was accurate at the time present in their products are annotated to include only of publication of this Primer, the user is directed to the CITES specific parts or derivatives (in which case only those website for the most current information regarding the inclu- parts and derivatives used in the products would be sion or exclusio.
subject to CITES requirements). In instances where finished products are not exempt from Annotations to Species Listed in CITES requirements for a CITES-listed plant species, the exporter is legally responsible for obtaining CITES docu- mentation for the finished product, regardless of how exten- Many of the taxa listed in the CITES Appendices that are of sive the supply chain is for the CITES-listed plant species. interest to the herbal products industry have annotations that These requirements are presented in greater detail in Section define specific inclusions or limitations to the scope of the 4 of this Primer. 1 McGuffin, M et al. 2000. Herbs of Commerce, 2nd ed. Silver Spring, MD: AHPA.
2 American Institute of Homeopathy. 1897. The Homeopathic Pharmacopoeia of the United States. Boston: Otis Clapp & Sons. 3 The State Pharmacopoeial Commission of the PRC. 2010. Pharmacopoeia of the People's Republic of China (English Edition 2010). Beijing: Chemical Industry Press.
AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Section 3: How CITES is Implemented in the United States As indicated in Section 1, the U.S. Fish & Wildlife Service is and developing technical proposals for CITES the national contact for the United States with regard to implementation of CITES. Divisions within the U.S. Fish & » Monitoring trade and the status of the species in the Wildlife Service are designated as the CITES Management Authority and Scientific Authority of the United States, as required by CITES. The U.S. Fish & Wildlife Service also » Reviewing applications for export, import, and works with multiple domestic and international partners to introduction from the sea of CITES-listed species to implement the CITES requirements for the United States.
determine if trade in the species would be detrimental to the survival of the species (the CITES non- The Division of Management Authority's Branch of Permits detriment finding;. and Wildlife Trade and Conservation Branch work together to oversee the following CITES functions: » Advising on identification of species, taxonomy, nomenclature, and other scientific matters that may »Implementation of the international permit program; relate to implementation; »Reviewing permit applications for export and re-export » Representing the United States at CITES meetings; of CITES-listed species to determine if the species were legally obtained (the CITES legal acquisition » Participating on various international working groups and panels and sharing scientific expertise with »Communicating with other CITES Parties, the colleagues within and outside the United States. CITES Secretariat, and the public on CITES issues; In partnership with U.S. Fish & Wildlife Service, the U.S. »Collaborating with State and other Federal agencies on Department of Agriculture (USDA) plays a significant role in implementation issues; CITES implementation as well. The USDA's Animal and Plant »Representing the United States at CITES meetings; Health Inspection Service (APHIS) issues USDA Protected »Developing national legislation and regulations to Plant Permits for entities interested in importing CITES-listed implement CITES; and plants. USDA/APHIS is the U.S. inspection authority for all CITES-listed plant shipments exiting the United States and »Producing annual CITES trade reports and such shipments must exit through designated ports, which are monitoring trade in CITES-listed species.
listed on the USDA/APHIS website. USDA/APHIS also The Division of Scientific Authority oversees the following manages the inspection of arriving imports containing live CITES-listed plants at designated import inspection stations. For imports containing non-living CITES-listed plant species, »Identifying, assessing, and recommending species for the Department of Homeland Security's Customs and Border protection through listings in the CITES Appendices Protection (CBP) is the U.S. inspection authority for shipments or a change in their current listing status; entering the United States and those shipments must again »Conducting scientific evaluation of CITES documents enter through designated ports. AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Section 4: Import, Export, or Re-export of a CITES-Listed SpeciesThe specific requirements for the import and export of CITES- will not be detrimental to the survival of the species. listed species vary according to the CITES Appendix in which In general, the following is required for the import/export of the species is listed, as well as the individual laws of the nations Appendix-III species: of import and export, if the countries are Parties to CITES. » Import of an Appendix-III species from the country In general, the following is required for the import/export of that requested listing of the species requires that a Appendix-I species: CITES export permit be issued by the Management »An import permit is issued by the Management Authority of the country of export. Import from all Authority of the receiving country if the specific other countries requires a CITES certificate of origin. conditions for the import of Appendix-I species are » For export from the country that requested listing of satisfied. The Scientific Authority of the receiving the species, a CITES export permit must be issued country must determine that the import will not be by the Management Authority of the country of detrimental to the survival of the species. If importing export. For export from other countries, a CITES live plants or animals, the receiving country's Scientific country of origin certificate must be issued by the Authority must be satisfied that the intended recipient Management Authority of the country of export. is suitably equipped to care for the shipment.
CITES export documentation is always required from the »An export permit must be issued by the Management country of export. Importation of a CITES-listed species from Authority of the country of export. Prior to issuing the a country that is not a Party to CITES may still require the permit, the Management Authority must determine if importer to obtain documents from the exporting country the specimen to be exported was legally obtained and containing all the same information that is required on a the import permit has been issued by the receiving CITES export permit. It should be noted that some countries country. In the case of live plants, the Management apply rules that are stricter than those imposed by CITES, for Authority of the country of export must be satisfied example prohibiting all exports of their native wild plants or that the specimens have been prepared and shipped to seeds thereof.
minimize risk of damage. The Scientific Authority of the country of export must determine that the export will not be detrimental to the survival of the species.
Import and Export of CITES-listed In general, the following is required for the import/export of Species in the United States Appendix-II species: All CITES-listed species must enter or exit the United States » The national law of the receiving country determines through a port designated for inspection of the specific CITES whether an import permit is required. Note: CITES species being imported or exported. USDA/APHIS maintains does not require an import permit for the import of a listing of for plants, specimens of Appendix-II species, but certain countries while the U.S. Fish and Wildlife Service maintains a listing of (such as those in the European Union) do require such permits under their stricter domestic laws. The United States does not require the issuance of CITES import permits for imports of Appendix-II species.
Both the U.S. Fish & Wildlife Service and USDA/APHIS »An export permit must be issued by the Management have permit requirements related to the importation of plant Authority of the country of export. The Management species listed in the CITES Appendices. Importers should be Authority must determine if the exported specimen aware that it takes at least 60 to 90 days to obtain approval for was legally obtained In the case of live plants, the these permits, and they should initiate the approval process Management Authority must be satisfied that the well in advance of the planned importation date. Importers specimens have been prepared and shipped to should also determine whether any state or local requirements minimize risk of damage. The Scientific Authority of are applicable for their importation activity, such as state the country of export must determine that the export licensing for nursery operations.
AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species The U.S. Fish and Wildlife Service import permit require- ments are dependent on whether the plant species to be Testimonial from a Master File Veteran
imported is listed in CITES Appendix I or not. The import "The initial approval process for establishing a Master File into the United States of an Appendix-I species requires an for Certification for Artificially Propagated Plants (CAPP) import permit, whereas the import of an Appendix-II or -III requires completion of the application, evidence of legal species does not. A specific application is required to import acquisition of the propagule material, establishment and Appendix-I plant species. Importers should complete the maintenance of parental stock, and any other supporting appropriate form for their activity to avoid unnecessary delays documentation Fish & Wildlife Service may request. They may deem it necessary to conduct a site visit to confirm in the approval process.
information. Any importation of live plants and seeds for planting (regard- As an example, to set up a Master File for goldenseal, we less of CITES status) requires the importer to obtain a permit submitted the 11 page application, Statements of Legal under USDA's nursery stock regulation. In addition, USDA Acquisition including name and location of where material requires a Protected Plant Permit for the importation of was harvested and also where material is being cultivated CITES-listed species. including the State, County, Township, County Deed Book Number, page, and tract size. We had all documents signed, Importers should also be familiar with the requirements of the dated and notarized. with regards to the registration of We also provided our General Permit from U.S. Department facilities which manufacture or process food, including dietary of Agriculture, photos of our Closed Artificial Propagation supplements, and prior notice of imports of food that are Production showing our seedlings, transplants, and mature subject to the Act.
seven year old plants along with our State Nursery License. The entire process took over nine months from submission to approval and issuance of our permit. Export Permits and Re-export Initially the permits issued could be copied for multiple-use and were valid for up to four years. So the permittee would copy, fill in the required information including specific There are many steps and procedures that must be conducted quantity of the material being shipped and submit for properly for the export of a shipment of a CITES-listed approval which was listed as a 60-90 day process. The species from the United States across any international border. process changed in 1999 based on new requirements for the Again, both U.S. Fish & Wildlife Service and USDA/APHIS European Union member nations. This required issuance of have specific permits or certificates that must be obtained to single-use permits valid for six months. legally conduct these activities. Exporters should also be aware Currently an exporter can file for single use permits or that it takes approximately 30 to 45 days to obtain approval for establish a Master File that is valid for three years during these permits.
which you are still required to submit applications for single-use permits for each shipment based on a specific The U.S. Fish and Wildlife Service export permit and re- quantity and that are valid for six months. We found the export certificate requirements are dependent on the listing of advantage to setting up the Master File is that the U.S. Fish & the plant species in the CITES Appendices and the type of Wildlife Service approval is faster using that process." plant or plant product being exported. Re-export is defined as —Edward Fletcher, Strategic Sourcing, Inc.
the export of a specimen that was previously imported (with appropriate documentation to demonstrate the legal importa- tion of the specimen(s)). Exporters should complete the USDA Protected Plant Permit (form PPQ 621) is also required appropriate form for their activity to avoid unnecessary delays to engage in the business of exporting or re-exporting species in the approval process. Exporters with questions about which listed in CITES. application form to use should contact the Division of The U.S. exporter/re-exporter must also determine the CITES Management Authority (see Section 6).
requirements of the country that will receive the exported or For the general export of plants and plant products, USDA re-exported CITES species. For example, some countries provides Phytosanitary Certification (for live plants and require an "Import Permit" for imports of species listed in unprocessed or unmanufactured plant products) and Export Appendix II or III. After obtaining the proper U.S. docu- Certification (for processed plant products). These ments, the exporter/re-exporter should contact the importer to Certifications are intended to assist exporters in demonstrat- determine the requirements of the importing country. All ing the compliance of the exported plant or plant material to documentation related to the export/import of the CITES the importation requirements of the receiving country. The species must accompany the shipment including the ‘original' AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species CITES export permit or, in the case of a re-export, the ‘origi- certificate depends on what plant parts and derivatives are nal' CITES re-export certificate. included in the CITES listing. If the finished product contains The exporter/re-exporter, or their legal representative/broker, a CITES-listed plant species that was previously imported must schedule an appointment with an APHIS CITES officer into the United States, the exporter must apply for a re-export certificate to legally re-export the product to customers in specific CITES-listed plant species being exported. The other countries. inspector will inspect the shipment and documentation before Export of Plants Produced Via the issuance of a Phytosanitary Certificate or Export Certificate and final approval for exportation. There is a cost for the Artificial Propagation conduct of the Phytosanitary Certificate inspection, but not The provisions of CITES recognize that significant interna- for the CITES inspection. tional trade occurs for plant species which are cultivated using A certificate for the re-export of a CITES-listed species is artificial propagation instead of wildcrafting, or being col- required when re-exporting specimens of a species that was lected from wild populations. While the primary intent of previously imported into the United States. This applies to CITES is to protect the wild populations of the listed species, plant products that have not been processed as well as those CITES Parties also play a role in ensuring that artificially that may have undergone processing into other finished prod- propagated specimens were produced from legally established ucts such as dietary supplements, but the need for a re-export parental stock and without detriment to wild populations. For Table 1 – Required Forms for Import/Export of CITES Species
Import of live plants or seeds of non-CITES species Import of CITES plant species (CITES import permit for Appendix-I species) and Phytosanitary Certification1 for plants and unprocessed or unmanufactured Export of plants and plant products of non-CITES species orExport Certification1 for processed plant products Export/Re-export of CITES plant 1 If required by the receiving country.
AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Appendix-I and –II plants that have been determined to be determination that the plants to be exported meet the criteria artificially propagated (as defined by CITES) a Certificate of for artificially propagated as defined by CITES. After estab- Artificial Propagation is issued in lieu of an export permit. lishing the Master File, shipments of artificially propagated Exporters with questions about this process should contact the species can be processed after obtaining single use Certificates Division of Management Authority (see Section 6). of Artificially Propagated Plants (CAPP).  CITES has specific criteria that must be met for plant speci- Exporters should determine whether the plant specimens to mens to be considered artificially propagated.1 In simplified be exported can qualify as being considered pre-Convention. terms, artificial propagation is defined as plant specimens that Unless the specific plant material to be exported can be docu- are grown under controlled conditions, from exempt material mented as being in existence prior to the inclusion of the or cultivated parental stock that has been established legally, in species in CITES, they cannot be considered pre-Convention. a manner not detrimental to the wild species, and is main- Note that plant specimens to be exported may qualify for cer- tained in quantities to minimize the need to augment the tification under artificial propagation if the growing stock was growing stock from the wild. There are additional consider- ations for long-lived species, specimens of hybrids, grafted plants, Appendix-I hybrids, and others.
Other Information The U.S. Fish & Wildlife Service form titled "Export of Artificially Propagated Plants (Multiple Commercial Both the U.S. Fish & Wildlife Service and USDA/APHIS Shipments)" (3-200-33) allows a U.S. exporter to apply for the websites have extensive information regarding the import and establishment of a Master File that will facilitate multiple export permitting processes, and other tools such as lists of exports of approved artificially propagated plants under FAQs to assist importers and exporters in determining the CITES requirements. Establishing the Master File allows the requirements for their specific needs. Table 1 summarizes the exporter to file CITES documentation that will apply to mul- necessary licenses or permits that must be obtained for each tiple shipments of the approved plants over a three year period, import and/or export activity. Users may also reference the thus decreasing the amount of paperwork that must be com- United States Code of Federal Regulations pleted for individual shipments. Applicants are encouraged to complete all portions of the application form as thoroughly as Links to other U.S. Fish & Wildlife Service and USDA/ possible because the information requested is used to make the APHIS website information are provided in Section 6. 1 The criteria for artificial propagation, as defined by CITES, are described in Resolutions Conf. 11.11 (Rev. CoP15) Regulation of trade in plants, Conf. 10.13 (Rev. CoP16) Implementation of the Convention for timber species, and Conf. 16.10 Implementation of the Convention for agarwood-producing taxa.
AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Section 5: Commonly Traded CITES-Listed Species This table of commonly-traded species is a cross-reference of People's Republic of China5 (PPRC). Additional taxa that are species that are listed in the CITES Appendices and also not mentioned in this table may also be found in commerce included in AHPA's Herbs of Commerce, 2nd ed.3, in the and are subject to CITES regulation. The user should consult Homeopathic Pharmacopoeia of the United States (HPUS)4, or the full CITES Appendices at in the current English edition of the Pharmacopoeia of the CITES Appendix
Species Name
Common Name
(Date of Inclusion)
Adonis vernalis 1 App. II (07/19/2000) Aloe spp. 2, 6 App. II (07/01/1975) Aquilaria malaccensis 14 App. II (02/16/1995) Aquilaria sinensis 14 App. II (01/12/2005) Bletilla striata 4, 6 App. II (07/01/1975) Cactus grandiflorus (= Selenicereus grandiflorus) 9 Cactus grandiflorus, night-blooming cereus App. II (07/01/1975) Cibotium barometz 6 Scythian lamb (tree fern) App. II (02/04/1977) Cistanche deserticola 6 App. II (07/19/2000) Corallorhiza odontorhiza 4, 6 App. II (07/01/1975) Crotalus durissus South American rattlesnake App. III (04/13/1987) Cyclamen europaeum (= Cyclamen purpurascens) 6 App. II (07/01/1975) Cypripedium acaule 4, 6 pink lady's slipper App. II (07/01/1975) Cypripedium calceolus var. pubescens (= Cypripedium yellow lady's slipper App. II (07/01/1975) parviflorum var. pubescens) 4, 6 Cypripedium parviflorum 4, 6 yellow lady's slipper App. II (07/01/1975) Dactylorhiza maculata (= Orchis maculata) 4, 6 heath spotted orchid App. II (7/01/1975) Dactylorhiza majalis (= Orchis latifolia) 4, 6 App. II (07/01/1975) Dendrobium fimbriatum 4, 6 App. II (07/01/1975) Dendrobium nobile 4, 6 App. II (07/01/1975) Dendrobium officinale 4, 6 App. II (07/01/1975) Dionaea muscipula 6 App. II (06/11/1992) Equus asinus 15 Not included in CITES Euphorbia spp. 6 includes poinsettia and varieties of spurge App. II (07/01/1975) Euphorbia antisyphilitica 6 App. II (07/01/1975) Flickingeria fimbriata (= Ephemerantha fimbriata) 4, 6 Flickingeria fimbriata 7 App. II (07/01/1975) Galanthus nivalis L. 6 App. II (01/18/1990) Gastrodia elata 4, 6 App. II (07/01/1975) Guaiacum officinale 1 guaiacum (common lignum vitae) App. II (06/11/1992) Guaiacum sanctum 1 guaiacum (holywood lignum vitae) App. II (07/01/1975) Harrisia bonplandii (= Harrisia pomanensis) 9 Cereus bonplandii, midnight lady App. II (07/01/1975) App. II (07/01/1975) Hoodia spp. 3 App. II (01/12/2005) Hydrastis canadensis 8 App. II (09/18/1997) Lophophora williamsii 6, 9 App. II (07/01/1975) AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species CITES Appendix
Species Name
Common Name
(Date of Inclusion)
Malaxis muscifera 4, 6 adder's mouth orchid App. II (07/01/1975) Mauremys reevesii App. III (02/17/2005) Naja tripudians, Indian cobra App. II (02/13/1984) Nardostachys grandiflora 1 App. II (09/18/1997) Nepenthes distillatoria 6 Nepenthes, pitcher plant App. II (10/22/1987) Opuntia compressa (= Opuntia humifusa) 6, 9 Eastern prickly pear App. II (07/01/1975) Opuntia ficus-indica 6, 9, 10 App. II (07/01/1975) Orchis mascula 4, 6 App. II (07/01/1975) Panax ginseng 11 App. II (07/19/2000) Panax quinquefolius 12 App. II (07/01/1975) Peniocereus serpentinus 9 Cereus serpentus, snake cactus App. II (07/01/1975) Picrorhiza kurrooa 1 picrorhiza (kutki) App. II (09/18/1997) Podophyllum hexandrum (= P. emodi) 1 Himalayan mayapple App. II (01/18/1997) Prunus africana 6 pygeum (African cherry) App. II (02/16/1995) Pterocarpus santalinus 13 App. II (02/16/1995) Rauvolfia serpentina 1 Indian snakeroot (snake-root devil-pepper) App. II (01/18/1990) Sarracenia purpurea 6 App. II (10/22/1987) Saussurea costus (= S. lappa; Aucklandia costus) App. I (08/01/1985) Selenicereus grandiflorus 9 night-blooming cereus App. II (07/01/1975) Spiranthes autumnalis (= Spiranthes spiralis) 6 Autumn lady's tresses App. II (07/01/1975) NOTE: The following footnote numeric designations are in sterile containers; c) cut flowers of artificially propagated plants; d) fruits, and unique to this AHPA document and may differ from the parts and derivatives thereof, of naturalized or artificially propagated plants of the genus Vanilla (Orchidaceae) and of the family Cactaceae; e) stems, flowers, and numeric designations in the CITES Appendices.
parts and derivatives thereof, of naturalized or artificially propagated plants of the genera Opuntia subgenus Opuntia and Selenicereus (Cactaceae); and f) finished For a thorough definition of the meaning of these Appendices products of Euphorbia antisyphilitica packaged and ready for retail trade.
classifications, see CITES at 7 Sold as a substitute for shi hu (Dendrobium spp.) 8 Underground parts (i.e. roots, rhizomes): whole, parts and powdered.
1 Designates all parts and derivatives except: a) seeds and pollen; and b) finished 9 The Appendix II listing is for all species of all genera of the family Cactaceae, with products packaged and ready for retail trade.
the exception of certain artificially propagated hybrids and cultivars, and those 2 The Appendix-II listing is for all species of Aloe with the exception of Aloe vera species that are included in Appendix I. Also exempted are seeds and pollen (excluding A. vera var. chenensis) and of several species that are listed in from all cactus except Mexican species originating in Mexico; cut flowers from Appendix I. Species that are included in Herbs of Commerce, 2nd ed. are A. ferox, artificially propagated plants; fruit from artificially propagated or naturalized A. littoralis, A. perryi, and A. spicata, none of which are listed in Appendix I. populations; and seedling or tissue culture in vitro in solid or liquid media trans- Additional species in the genus Aloe may be in commerce.
ported in sterile containers. Taxa in the cactus family that are not listed here may be in commerce.
3 Not in Herbs of Commerce, 2nd ed., but prominently in trade. All parts and deriva- tives except those bearing a label "Produced from Hoodia spp. material obtained 10 Separate stem joints (pads) and their parts and derivatives, so long as these are through controlled harvesting and production under the terms of an agreement from artificially propagated or naturalized plants, are excluded from the listing with the relevant CITES Management Authority of [Botswana agreement No. BW/ for Opuntia ficus-indica.
xxxxxx] [Namibia under agreement No. NA/xxxxxx] [South Africa under agree- 11 Only populations of the Russian Federation are listed. Whole and sliced roots ment No. ZA/xxxxxx]". and parts of roots, excluding manufactured parts or derivatives, such as 4 The Appendix-II listing is for all species of all genera of the family Orchidaceae, powders, pills, extracts, tonics, teas and confectionery. with the exception of the fruit of cultivated vanilla and those species that are 12 Whole and sliced roots and parts of roots, excluding manufactured parts or included in Appendix I. Also exempted are cut flowers from artificially propa- derivatives, such as powders, pills, extracts, tonics, teas and confectionery. gated plants, seeds and pollen, as well as seedling or tissue culture in vitro in solid or liquid media transported in sterile containers. Taxa in the orchid family 13 Includes logs, wood-chips, powder and extracts.
that are not listed here may be in commerce 14 All parts and derivatives except: a) seeds and pollen; b) seedling or tissue cul- 5 The Appendix-II listing is for all species of Euphorbia with the exception of non- tures obtained in vitro, in solid or liquid media, transported in sterile containers; succulent species and artificially propagated specimens of Euphorbia trigona c) fruits; d) leaves; e) exhausted agarwood powder, including compressed powder in all shapes; and f) finished products packaged and ready for retail trade, this exemption does not apply to beads, prayer beads and carvings.
6 All parts and derivatives, except: a) seeds (including seedpods of Orchidaceae), spores and pollen (including pollinia). The exemption does not apply to seeds 15 The entry for Equus asinus, which is considered to be a domesticated species of from Cactaceae spp. exported from Mexico, and to seeds from Beccariophoenix donkey, is provided as differentiation from the wild species, Equus africanus. The madagascariensis and Neodypsis decaryi exported from Madagascar; b) CITES listing in Appendix I is only for E. africanus, and E. asinus is specifically seedling or tissue cultures obtained in vitro, in solid or liquid media, transported AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Section 6: Supplemental Information and Sample Checklists This section contains resources for users of this document who are in need of additional information regarding the (including American ginseng) CITES, U.S. Fish & Wildlife Service and USDA/AHPIS It also contains sample checklists for the import and export processes to help botanical product handlers fulfill the require- ments of the U.S. regulatory agencies in their oversight of US compliance with CITES.
U.S. Department of Agriculture Animal and
Plant Health Inspection Service
Supplemental Information » Permits for Plants, Plant Products, Soil, Protected Plants and Transit Shipments: Tel: 301-851-2046 Toll-Free Automated System: 877-770-5990 Fax: 301-734-5786 » Import Requirements for Plants and Plant Products: U. S. Fish & Wildlife Service
Tel: 301-851-2046 »Division of Management Authority: Fax: 301-734-3225 Tel: 800-359-2104 » Plant Inspection Stations: Tel: 703-358-2093 Tel: 301-851-2046 Fax: 703-358-2280 Fax: 301-734-5276 » (general information) » Division of Scientific Authority: Tel: 703-358-1708 » (CITES specific) Fax: 703-358-2276 U.S. Customs Border Protection
Tel: 877-227-5511 sheets in left column) AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Checklist for Importing CITES-Listed Species According to CITES, the Management Authority of each Party determines whether import permits are required for CITES-listed species other than those listed in CITES Appendix I. The United States does require import permits for the importation of species listed in CITES Appendices I and II.
NOTE: Obtaining the required permits for importation can take 90 days or more, so plan accordingly.
o Verify that the specimens to be imported are subject to the provisions of CITES (see Section 5 of this document and CITES website for most current information for listed species). Be sure to reference any annotations which define the parts or forms of the CITES-listed species that are included under or exempted from the CITES listing. o Determine whether the country of export for the specimens to be imported is a Party to CITES (see the CITES website). o If the country of export is a Party to CITES, arrange with the exporter in the country of export to obtain required export permits from that Management Authority; OR o If the country of export is not a Party to CITES, export documentation similar to that required by CITES will need to be obtained from the appropriate authority in the country of export in order to import a CITES-listed species into the United States.
o Complete the required import permit applications forms for both USDA/ APHIS and the U.S. Fish & Wildlife Service (see Section 4, Import Permits, and Table 1 of this document). The forms include detailed instructions for completing the required information in a manner that will facilitate processing. It is important to provide complete and accurate responses to the information requested on the application forms.
o Verify whether other applicable importation requirements such as state nursery licensing and Bioterrorism Act registration have been fulfilled.
o Determine at which designated port of entry the specimens will arrive for entry into the United States. The list of designated ports of entry is available on the USDA/APHIS website. Note that some of these ports of entry are CITES species-specific. o Obtain the import permits, and provide all import permit documentation to the port of entry for verification upon arrival of the imported specimens. The exporter may also need copies of the import permits to provide to the Management Authority of the country of export.
AHPA, November 2013 Primer on Importing & Exporting CITES-listed Species Checklist for Exporting / Re-Exporting CITES-Listed Species According to CITES, an export permit must be issued by the Management Authority of the country of export for a CITES-listed species to be legally exported. In the US, the Management Authority within the U.S. Fish & Wildlife Service will issue the export permit, which is based on a determination that the speci-men to be exported was legally obtained and the trade will not be detrimental to the species. For the export of a CITES Appendix-I species, the Management Authority will verify that an import permit has been issued by the receiving country. For the export of a CITES Appendix-II species, the national law of the receiving country defines whether an import permit is needed. NOTE: Obtaining the required permits for exportation can take 90 days or more, so plan accordingly.
o Verify that the specimens to be exported are subject to the provisions of CITES (see Section 5 of this document and CITES website for most current information for listed species). Be sure to pay attention to any annotations which define the parts or forms of the CITES-listed species that are included under or exempted from the CITES listing.
o Determine whether the receiving country for the specimens to be exported is a Party to CITES (see the CITES website). o If the receiving country is a Party to CITES, the importer should determine if the Management Authority of that country requires an import permit for the CITES-listed species; OR o If the receiving country is not a Party to CITES, the importer should determine what other import documentation may be needed according to the national laws of the receiving country.
o Complete the required export permit application forms for both USDA/APHIS and U.S. Fish & Wildlife Service (see Section 4, Export Permits, and Table 1 of this document). The forms include detailed instructions for completing the required information in a manner that will facilitate processing. It is important to provide complete and accurate responses to the information requested on the application forms.
o If the specimens were artificially propagated, determine whether the cultivator has established a Master File to obtain Certificates of Artificially Propagated Plants (CAPPs), or consider establishing a Master File if you are the cultivator.
o Determine at which designated port the specimens will be inspected for export from the United States. The list of designated ports of export is available on the USDA/APHIS website. Note that some of these ports of export are CITES species-specific. o Obtain the export permits, and schedule an appointment for inspection of the specimens to be exported at the designated port. Provide all export documentation to the port of export for verification during inspection of the specimens to be exported.
Additional Information for Re-Exporting CITES-Listed Species
Re-export is defined as the export of a specimen that was previously imported (with appropriate docu-mentation to demonstrate the legal importation of the specimen(s).
o Obtain the documentation that demonstrates the original legal import of the specimen, such as a copy of the export permit from the country of export stamped by either U.S. Customs and Border Protection or USDA/APHIS, and the history of transactions if the specimens were not purchased from the original importer.
AHPA, November 2013

Source: http://www.ahpa.org/Portals/0/pdfs/AHPA_CITES_Import_Export_Primer.pdf