AHPA comments to FWS provide recommendations for CITES

In comments submitted to the U.S. Fish and Wildlife Service (FWS), AHPA requested that the agency propose at the 18th Conference of the Parties (CoP18) of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) to amend the annotation for American ginseng (Panax quinquefolius) to exclude sliced roots from CITES export and import controls.

AHPA's comments explain that any sliced American ginseng subject to export or import is cultivated material so there is no need to make nondetriment findings for sliced root.

Cultivated American ginseng is produced annually in the United States and Canada in much greater quantities and is sold at a much lower cost. It is not uncommon for producers of this artificially propagated commodity to slice the roots into cross-sectional slices. In contrast, a significant premium is paid for whole, intact roots with the rhizome or "neck" still attached so no one who exports wild American ginseng roots would consider slicing these roots because it would significantly reduce the value.

In January, FWS published a request for information in the Federal Register to solicit information and recommendations on plant and animal species that should be considered as candidates for U.S. proposals to amend Appendices I and II of CITES at CoP18 scheduled to be held in Sri Lanka in 2019.

AHPA's did not recommend adding any other plant species that is native to the United States to CITES Appendix I or Appendix II, or for reclassifying any such species from one Appendix to the other.