AHPA Submits Comments on Special Forest Products and Proposed Fees

(January 25, 2008) — The American Herbal Products Association (AHPA) has submitted comments to the USDA Forest Service in response to that agency’s proposed rule governing the sale and disposal of nontimber forest products that are harvested on National Forest System lands. The proposed rule, which was issued last October, sets requirements for the Forest Service to monitor such harvests and ensure that they occur at sustainable levels, and establishes programs for collection of fees from harvesters.

“Our National Forests and National Grasslands provide many commercially valuable plants to the trade,” said AHPA President Michael McGuffin. “AHPA and its members are committed to sustainable use of our plant resources and we applaud the Forest Service for its management efforts. We are also supportive of reasonable fees that can be used to manage those resources, but those fees must be established at levels that do not disrupt the income of individual collectors and other small businesses that are engaged in sustainable harvest operations.”

Among its comments to the Forest Service, AHPA suggested that fees for harvested forest products be calculated at the point of harvest, rather than further along the distribution or value-added chain, and that these fees should be 3 percent of each product’s value at the point of harvest. AHPA also suggested that existing resources should be used in both monitoring and pricing activities. These include AHPA’s tonnage surveys, the AHPA/AHP Good Agricultural and Collection Practice for Herbal Raw Materials(1), and the ISSC-MAP(2).

The Federal Register notice for the Forest Service’s proposed rule can be downloaded

here. AHPA’s comments are available here.


1) Jointly published in December 2006 by AHPA and the American Herbal Pharmacopoeia, this document is available at http://www.ahpa.org/portals/0/pdfs/06_1208_AHPA-AHP_GACP.pdf.

2) International Standards for Sustainable wild Collection of Medicinal and Aromatic Plants, available at http://www.floraweb.de/proxy/floraweb/MAP-pro/Standard_Version1_0.pdf



The American Herbal Products Association (AHPA) is the only national trade association devoted to herbal issues. Representing the core of the botanical trade—comprised of the finest growers, processors, manufacturers and marketers of herbal products—our mission is to promote the responsible commerce of herbal products. AHPA committees generate self-regulations to ensure the highest level of quality with respect to the way herbal products are manufactured, labeled, and sold. Website: www.ahpa.org.

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