CITES II and Galanthus - Currently with APHIS

William Aley
Sun, 23 Dec 2007 07:22:13 PST

Times are different now. There is The Department of Homeland Security.  
Those are the folks in dark blue that protect our borders. APHIS and  
other government agencies like Fish and Wildlife and Public Health are  
no longer working at the entry points of the USA.

That being said, USDA requires all propagative plant material  to have  
a phytosanitary certificate from the exporting country. There are a  
few exceptions - (small lots of seed permits  and experimental  
permits) CITES material would be documented on the Phyto as well as  
with the CITES documents. It is up to the exporting country to  
determine the necessity of CITES documents.
In the situation you described below, this is how it works today..
Your  would  be better off contacting the US CITES representative at  
APHIS HQ in Riverdale, MD. The folks at the Plant Inspection Stations  
are good, but they are only validators and enforcement officers.
Much has changed in 10 years.
USA and APHIS as the enforcement agency for USA must follow the laws  
of CITES. In reality there "should" be no exceptions. It is an  
international agreement, USA has agreed to participate with CITES and  
ESA. For the most part this is the enforcement element that everyone  
notices the most. It seems unfair when an individual is traveling with  
a few rare plants and the government "seizes" them for no apparent  
reason and then "destroys them" contrast this to whole suppliers of  
rare plants.

So what really happens?
When the plants are presented or discovered at the ports of entry in  
the USA. Certain documents are necessary to allow those plants to  
enter. As mentioned the Phyto is the most important document. For rare  
plants, a CITES document. Because the US is currently busy funding a  
freedom operation to the folks in the middle east, government  
resources are limited and now importers myst pay a small fee for an  
CITES import permit  $70 which is every two years (don't be too  
concerned- because in the very near future, the price will  triple to  
about $350 for all import permits- Thanks be to George).
If you don't have the documents- the government has to follow some  
specific guidelines to process the plant material.
1. the importer is provided 21 days to obtain the necessary documents  
from the exporting country. The plants sit in a not so nice place  
(usually depending of the plant inspection station it's as good as  
they have) at least it's not anything like where the plants were  
growing prior to being transported to the USA.
After this period of time, the importer should be contacted to verify  
that they have produced the documents or the plants will be sent to  
the country of export or to a rescue center.
  Usually 15 days is the grace period for this.
If the importer fails to obtain the documents. USA will contact the  
country of export and offer the material back to that country. The  
exporting country must pay for freight costs only. 99% of the time  
this is rejected. Then the plants are referred to Fish and Wildlife  
who looks art the address of the importer and follows a list of  
available rescue centers. They try to make the the rescue center NOT  
the same as the address or State of the importer. Too many folks at  
botanical gardens pulled fast ones and eventually the government  
figured it out.
Then, now almost 60 days after the initial import into the USA, the  
plants are off to a rescue center. They arrive often very tired and in  
bad shape. Definitely not happy plants.

But this doesn't mean you can't import. You just have to be aware of  
what the rules are and know who to contact.

Remember the official documents. Those need to be obtained before the  
plants leave the country by the appropriate government official. Not  
every government is good at posting their information on the web, so  
you may have to research. Sometimes difficult when in Burma and your  
skill in either Gurma, Fulani, Dejula, or Tuareg is a little rusty  
trying to find out who and communicate to their government CITES  
representative  may pose some problems.
I'd recommend ordering plants on line or doing a lot of research  
before you travel.
Have your permits in place before the plants or money are exchanged.
Be prepared to work with people who may not know as much about what  
you are trying to do as you know. Often regulatory people have to do a  
lot of things and sometimes they just don't know what it is you are  
trying to accomplish. It's bad, it's unfortunate- but think about all  
the things someone expects you to do and how much do you know about  
all the things you don't do an a daily basis.

Word of caution, trying to fool people will work for a while, but when  
you run into someone as smart- or smarter than yourself, you may have  
to explain your actions and if you have a history, often the  
Government is not so forgiving and challenges all that you've done in  
the past as probably not so innocent. They are the Department of  
Homeland Security and doubt and paranoia are part of the corporate  
APHIS is still in charge of policy-  For now.
some contact information:

CITES Program Coordinator
(APHIS headquarters in Riverdale Md)

East Coast CITES Specialist
(Jamaica, NY)

West Coast CITES Specialist
(San Francisco, CA)

Permit information

A link to the manual used to regulated CITES plants- slow to download  
but this is what the government uses…

Plant Inspection Info (large pdf document) with current information…


On Dec 22, 2007, at 8:55 AM, Judy Glattstein wrote:

> A decade or two ago I was lecturing / visiting in England. A friend
> there offered me some Galanthus cultivars. Since Galanthus is on CITES
> Appendix II, I telephoned John Arcery at the Kennedy Airport APHIS
> inspection station to explain the situation. I suggested that my  
> friend
> and I would go to a notary in said friend's town and testify to the  
> fact
> that these were A) cultivars and B) propagated, not wild collected
> (though how one could wild-collect cultivars in the first place . . .)
> After all, I already had a general import permit that included
> Amaryllidaceae (I'd gone for plant families when applying for the
> permit, why be niggardly and restrict to genus, let alone a specific
> species.)
> Not possible, said John. I would need government level export and  
> import
> documents.
> What would happen if I brought them in without said documentation on
> both sides?
> I was sternly informed that the bulbs would be confiscated and sent to
> the nearest approved educational institution. Which, in this instance,
> would be the New York Botanical Garden. Where I was then and am now an
> instructor. I thought about this for a bit, but decided that was  
> getting
> complicated.
> Galanthus bulbs do look very much like those of Narcissus  
> bulbocodium . . .
> Judy in New Jersey, where gray skies and patchy iced-over snow look
> gloomy rather than festive
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