AHPA comments on CITES at FWS public meeting

(Monday, December 11, 2006, Silver Spring, MD) —American Herbal Products Association (AHPA) President Michael McGuffin provided comments today at a public meeting convened by the U.S Fish and Wildlife Service (FWS) to gather input on issues to be addressed at the next Conference of the Parties (CoP14) to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).

With regard to proposals for species listings or revisions, McGuffin expressed support for FWS' planned proposal to exempt Taxus x media from the provisions of CITES. Although several other Taxus species are listed on CITES Appendix II, McGuffin observed that FWS correctly identifies Taxus x media as a man-made hybrid that does not occur naturally in the wild and has no effect on wild species.

McGuffin also restated AHPA's request to remove goldenseal (Hydrastis canadensis) from Appendix II and noted that FWS has yet to respond in a substantive fashion to earlier such requests. Appendix II includes those species that, although not necessarily threatened with extinction, may become so unless international trade is regulated in order to avoid utilization incompatible with their survival. International trade in Appendix II species is allowed but is strictly controlled, and goldenseal has been included in this classification since 1997.

"AHPA has provided data showing that only 7 percent of the annual harvest of goldenseal root enters international trade. Because there is no meaningful export of this species, goldenseal should not be listed on CITES, which intends to govern only species affected by international trade," McGuffin said. "Further, the amount of cultivated goldenseal exceeds the quantity in international trade by a factor of 3 to 1, a fact that FWS should also consider."

Other issues raised by McGuffin included an expression of support for an FWS proposal to revise an annotation that provides an exception for finished products that contain some of the species listed on Appendix II, whether marketed as pharmaceuticals or food supplements.

"But this exception for finished products needs to be extended to all of the Appendix II listed species — both plant and animal — that are found in our products," McGuffin added. "This change would eliminate unnecessary and redundant re-export certificates for finished products, as documentation requirements are met when raw materials first enter into international commerce."

AHPA will submit additional written comments to FWS on this topic by December 22, 2006.

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The American Herbal Products Association (AHPA) is a trade association representing the core of the botanical trade — comprised of the finest growers, processors, manufacturers and marketers of herbal products. AHPA’s 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 herbs are manufactured, labeled, and sold. Website: www.ahpa.org.

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