AHPA Submits Comments to FWS on American Ginseng

SILVER SPRING, Md.The American Herbal Products Association (AHPA) submitted comments to the U.S. Fish and Wildlife Service (FWS) on proposed amendments to CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora) expressing support for an amendment to the annotation for American ginseng (Panax quinquefolius). The United States might submit this proposal for consideration at the 16th regular meeting of the CITES conference, scheduled for March 2013 in Thailand.

AHPA's comments expressed support for an FWS proposal to amend the annotation for American ginseng to clarify to exporters and enforcement authorities that manufactured products, such as powders, pills, extracts, tonics, teas and confectionery, are exempt from CITES provisions.

AHPA also addressed the CITES status of goldenseal (Hydrastis canadensis), which it has recommended on numerous occasions be removed from CITES appendix two. AHPA's comments supported this position by noting that less than 10 percent of all harvested goldenseal root is subject to export, and the volume produced each year from cultivated sources, as opposed to wild plants, exceeds the export volume by nearly 300 percent. These calculations were supported with data from AHPA's most recent Tonnage Surveys of Select North American Wild-Harvested Plants, 2006-2010.

"AHPA appreciates the effort by FWS to clarify the CITES exemption for American ginseng, as efficient enforcement of raw agricultural exports provides the most effective CITES controls," said Michael McGuffin, AHPA president. "And while FWS has not supported AHPA's earlier communications that show that goldenseal is not in meaningful international commerce, we are hopeful that our new data, provided by AHPA members through a decade of compiling tonnage surveys, will be seriously considered as a clear basis for removal of goldenseal from appendix two."

CITES is a multinational treaty that aims to ensure that international trade in specimens of wild animals and plants does not threaten the survival of the species in the wild. CITES appendix two lists species that are not necessarily threatened with extinction, but may become so unless trade in specimens of such species is subject to strict regulation in order to avoid utilization incompatible with the survival of the species in the wild.