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AHPA submits comments to U.S. Fish and Wildlife Service notice on potential CITES listing proposals
February 4, 2025
Comments focus on white sage and American ginseng
The American Herbal Products Association (AHPA) has submitted comments in response to the U.S. Fish and Wildlife Service (FWS) Federal Register notice (89 FR. 105074-105089) issued on December 26, 2024, announcing the twentieth regular meeting of the Conference of the Parties to CITES (CoP20) scheduled to be held in Samarkand, Uzbekistan on November 24-December 5, 2025. CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) is an international treaty that oversees international trade in endangered species.
In this Federal Register notice, FWS responded to recommendations received from the public concerning proposed amendments to the CITES Appendices (species listing proposals) that the United States might submit for consideration at CoP20, and invited comments and information relevant to these proposals. The Notice includes a list of plant and animal species and proposed actions of “likely,” “unlikely,” or “undecided” on whether FWS will submit a species listing proposal for consideration at CoP20.
AHPA's comments focused on two botanical species for which FWS indicated a currently “undecided” position – white sage (Salvia apiana) and American ginseng (Panax quinquefolius), which is currently listed in CITES Appendix II. For both of these botanicals, FWS has expressed the intent to conduct further outreach to other range states, as well as consideration of additional recommendations, trade analyses, or biological information on the species in question prior to finalizing a U.S. position for the CoP20 meeting.
Regarding white sage, FWS is considering whether to propose that this herb be added to CITES Appendix II, the second highest and most common level of CITES control. AHPA noted that multiple interested parties had submitted substantive information regarding the potential need to monitor international trade of this species through a CITES listing, due to illegal harvest, habitat encroachment, and increasing international trade demand. In its comments, AHPA provided information reported for white sage for it 2021-2023 tonnage survey, which is in the final stages of editing prior to publication. AHPA invites any of its members with an interest in white sage to provide specific information on its conservation status and potential need for protection during international trade for the FWS's consideration.
For American ginseng, FWS indicates it is evaluating two potential proposals. The first is a suggestion to transfer American ginseng from its current Appendix II listing to Appendix I, the highest level of CITES control. AHPA strongly objects to this potential proposal as no documentation has been provided that the species meets the requirements for an Appendix I listing. The second potential action is to amend the current annotation to the American ginseng listing to allow for an exemption for cultivated American ginseng that is packaged for retail trade when it enters international commerce. Such an exemption is provided for several other CITES listed species, such as Rhodiola spp.
The December 26, 2024 Federal Register notice was the second in a series of public comment opportunities that FWS provides in preparation for CITES CoP meetings. FWS will also conduct a public meeting 2-3 months prior to the CoP meeting to provide the public with another opportunity to shape the U.S. positions on CITES listing proposals to be reviewed at CoP20. More information about the U.S. preparations for CoP20 can be found on the FWS website.
AHPA holds the position of authorized observer with CITES and has been directly involved with official activities of the international treaty since 2002, ensuring the interests of AHPA members are represented given that CITES listing of plant species have a direct impact on manufacturers and marketers of products containing these botanicals as ingredients. AHPA's CITES primer provides an understanding of the processes and practices that must be followed to be in compliance when importing and exporting CITES-listed species.