More info than you probably need about importinginto theUSA

Adam Fikso
Mon, 24 Jan 2011 12:08:30 PST
Yeah, Lee.  I too have had a plant import license for years, (more than 50) 
imported stuff from  Syria, Turkey---once in diplomatic pouch .

The current situation increases the size of government,without, I suspect, 
offering necessary protection.  Of course no studies have been done. 
"Wasteful spending".  A "threat to national security"  Gotta have bigger 
guns on it. More regulations---all of them appaently rational,  once one 
accepts the national defense premise, and the myth that privatization can do 
it cheaper.  (And it can-- if you accept the idea that jobs will be 
lost,that wil eventually  cost the government more  over the years) This is 
MY rant--probably socialist or something.

ge ----- 
From: "Lee Poulsen" <>
To: "Pacific Bulb Society" <>
Sent: Sunday, January 23, 2011 7:49 PM
Subject: Re: [pbs] More info than you probably need about importinginto 

> Can I add a little to what Bill has so kindly explained to us, based on my 
> experiences only, before and after the small lots of seeds permits were 
> instituted?
> From about the early 1990s until shortly after the 9/11 attacks, I traded 
> and even imported both seeds and bulbs from outside the U.S. into the U.S. 
> without any permits or phytosanitary certificates (PC). I also had a plant 
> import permit that did and still does require that you get a PC from the 
> originating country before bringing the plants into the U.S. So I read in 
> the material that they sent me with that permit that I didn't need to use 
> the permit to import seeds or dry dormant bulbs. And indeed that is 
> exactly what I did: I traded seeds with international friends who mailed 
> them to me in envelopes and packages. I purchased seeds from other 
> countries (e.g. Silverhill Seeds in South Africa) and had them sent 
> directly to me without any permit or anything. I ordered bulbs from 
> British and European companies directly as well as from Australia and New 
> Zealand. I even brought bulbs and seeds back with me from travels I made 
> abroad. I even brought back both bulbs and plants from
>  Japan in my luggage. I got the necessary PC at the Tokyo (Narita) Airport 
> before boarding my plane back and I only had to get the PC for the live 
> plants and not for the bulbs or seeds.
> [BTW, Japan up until 8 years ago--I haven't been back since then so don't 
> know if this is currently true--must have the best and easiest method for 
> getting a PC of any country in the world. They have inspectors at the 
> international airport. You call and make an appointment for about 2 hours 
> before you needed to check in and after arriving at the airport went to 
> the inspection office where they inspected all your plants for FREE, typed 
> up a certificate, and sent you on your way!]
> Anyway, not too long after 9/11, the USDA/APHIS/PPQ suddenly announced one 
> day that they now were going to require PCs and use of a plant import 
> permit (which is still free--yay!) for any plant material of any kind 
> including dry dormant bulbs and seeds. When many hobbyists and plant clubs 
> blew up at this, they pointed out how they had always had the right 
> according to law to do this, but had decided not to enforce it, lo! all 
> these many decades. Sure enough, there it was in the law all this time. 
> But now with increased security being in vogue, they decided to start 
> enforcing it. I guess most people relented on the bulbs since they can 
> easily carry viruses, etc. whether growing or dormant, but most seeds due 
> the biological nature of how they come to form, are usually disease-free 
> except for a few minor but important cases. Many people, spearheaded by 
> Joyce Fingerut of NARGS, as Jim W. pointed out spent a lot of effort 
> writing, emailing, and calling the USDA about how this new
> policy would essentially wipe out all legal trading of seeds, especially 
> in small quantities, between other countries and the U.S., and only large 
> corporations with the money and means to go through all the hassle of 
> doing it legally would be the only ones importing seeds. The few times I 
> called APHIS/PPQ headquarters or emailed them in the early days of this 
> policy gave me the distinct impression that many of the agents there had 
> no idea we were all trading seeds or of how difficult and/or expensive it 
> is in most countries to get a PC, especially by individuals for a very 
> small quantity of seeds. However, to their credit, as Bill has pointed 
> out, they were sensitive and listened to all these comments and objections 
> and not only invited many of us to join their stakeholders list, but came 
> up with the small lots of seeds permit, which I think is a pretty good 
> compromise and doesn't require the dreaded PC. I know there have been many 
> bumps and kinks in getting it working at al
> l the inspection stations across the U.S., but I have found that the 
> agents at the local inspection station by LAX have tried very hard to be 
> helpful while still trying to understand and follow the new regulations. 
> They have always tried to help me follow the rules better each time I get 
> some seeds through them where the sender didn't quite follow the rules 
> exactly. I really have to give them credit for that. (Still, there is room 
> for improvement...)
> I only wish there were a similarly easy way to import bulbs. I recently 
> returned from a business trip to Brazil and Argentina, and got to meet 
> with both Mauro Peixoto and Mariano Saviello again, and they both told me 
> how extremely difficult it is to get a PC. Mariano told me it's so 
> difficult in Argentina that he doesn't even try, and Mauro told me that in 
> Brazil, the government will only issue PCs to commercial entities and 
> won't issue them to private individuals making it basically impossible for 
> him to get one under any circumstance. I'm not sure if there is anything 
> in the international treaty governing PCs that addresses this, but I'm not 
> sure our USDA recognizes this difficulty based on the conversations I've 
> had with our local inspection agents and the national office. In other 
> countries it can be incredibly expensive such as Australia where they 
> charge quite a bit and you have to pay in minimum 15-minute increments. In 
> some countries, you can only obtain a PC at one l
> ocation in the capital city and nowhere else, effectively eliminating the 
> ability to get a PC for individuals who don't live anywhere close to the 
> capital (and can't afford to travel there due to cost or distance) even if 
> the U.S. citizen is willing to pay for the PC. From what I've seen, 95% of 
> the companies in other countries that I've looked into refuse to even try 
> getting PCs.
> Anyway, this brings me up to the current situation we're in today, which 
> is by no means perfect, but isn't too bad as far as seed importations are 
> concerned. I think that APHIS/PPC needs to think more on the bulb 
> importation method, since one of their stated goals is to make the 
> regulations such that Americans *want* to follow and support them and not 
> try to smuggle items in. And the current difficulties with getting PCs 
> almost everywhere (although not impossible from England or South Africa 
> for example), make the current regulations for bulb importations such that 
> people will be strongly tempted to try smuggling some in now and then. 
> --Lee Poulsen
> Pasadena, California, USA - USDA Zone 10a
> On Jan 23, 2011, at 3:00 PM, William Aley wrote:
>> the small lots of seed permits do not require a phytosanitary 
>> certificate. The seeds are inspected at 100% at the USDA Plant Inspection 
>> Station. The limits to the small lots of seed permit are 50 lots not to 
>> exceed 50 grams or 50 seeds, each, which ever is greater. Its an 
>> arbitrary number and amount~ ie:  50 grams of larkspur seed verses 50 
>> palm seed.
>> Larger lots of seed (often up to several hundreds of Kilos) imported 
>> under the standard Q37 permit are often sampled by a Department of 
>> Homeland Security Customs Border Protection (DHS CBP) inspector at the 
>> first port of US entry, usually in a Customs Bonded warehouse. The 
>> inspectors could not easily inspect 100 Kilos of seed at 100% and get all 
>> of the other inspections accomplished in a day.
>> The authorization as stated on the permit  requires a phytosanitary 
>> certificate for the general permit and except for woody tree seed, a DHS 
>> CBP inspector can inspect the seed at the first port of entry. Under the 
>> small lots of seed the shipment must go to a Plant Inspection Station for 
>> inspection.
>> Thus it is not a convenient as far as how fast or when the shipment is 
>> inspected. Also not all seed requires a permit for import into the USA, 
>> again know the rules of importation as stated in the CFR.  Restrictions 
>> are based upon disease status of seed borne pathogens and insect pests 
>> and the country of origin.
>> The pros and cons: obtain a PC and a CBP inspector can inspect and 
>> release at any port of entry OR use a small lots of seed permit, limited 
>> by weight, size and number and it must go to a plant inspection station, 
>> but no PC is required.
>> This permit is a concession to individuals who tend to trade as a 
>> collector or for breeding purposes since the import regulations were put 
>> in place for commercial imports. Again, 100 years ago most people were 
>> not importing small amounts of seed into the USA.
>> This change is less than 10 years old as a result of the way trade has 
>> evolved.
>> Hope that helps.On Jan 23, 2011, at 1:40 PM, Adam Fikso wrote:
>>> Re Ellen's good questionwhich I never asked...  Was  the thinking ever 
>>> explicated?
>>> ----- Original Message ----- From: "Ellen Hornig" <>
>>> To: "Pacific Bulb Society" <>
>>> Sent: Sunday, January 23, 2011 8:36 AM
>>> Subject: Re: [pbs] More info than you probably need about importing into 
>>> theUSA
>>>> Bill A - I'm curious (and I'm not being accusatory - it's not like 
>>>> you're responsible for this system) - what was the thinking behind 
>>>> requiring separate permits for small seed lots and general plant (or 
>>>> large seed lot) imports, when they are, at least as I understand it, 
>>>> the same type of permit. just differently designated?  Why couldn't 
>>>> those of us who own general permits be allowed to use them for small 
>>>> seed lots too?
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