From March 3–14, 2013, more than 2,000
participants from around the world met in Bangkok, Thailand, for the 16th
meeting of the Conference of the Parties (CoP16) to the Convention on International
Trade in Endangered Species of Wild Fauna and Flora (CITES).1 In
addition to important conservation decisions adopted for threatened animal
species — including increased protection for tortoises and turtles, five shark
species, and manta rays — Parties discussed and adopted several important
proposals concerning aromatic and medicinal plants.
CITES is among the largest international conservation agreements, with 178 member governments aiming to ensure “that
international trade in specimens of wild animals and plants does not threaten
their survival.”2 CoP16 marked the 40th anniversary of
the adoption of CITES itself. The triennial meeting of the CITES CoP brings
together representatives of the countries that have signed the
Convention — also known as the Parties3 — to discuss changes in the
implementation of CITES, including modifications and additions to the
Appendices.
Species protected by CITES are included in one of three Appendices, which
convey varying levels of protection.4 Appendix I includes “species
that are the most endangered,” Appendix II “lists species that are not
necessarily now threatened with extinction but that may become so unless trade
is closely controlled” (including look-alike species that appear similar to listed species), and Appendix III
“is a list of species included at the request of a Party that already regulates
trade in the species and that needs the cooperation of other countries to
prevent unsustainable or illegal exploitation.” Depending on the Appendix in
which the species is included, international trade may be limited to primarily
non-commercial trade, closely regulated commercial trade, or monitored commercial
trade.
Annotation Changes
Several proposals at CoP16 focused on amending the annotations for certain
CITES-listed plant species. Annotations clarify the scope of an Appendix
listing, often by specifying when certain plant populations, parts, or
derivatives are or are not affected by the listing.5 Annotations are
relevant for medicinal plants, particularly for internationally traded finished
products that contain parts or derivatives of CITES-listed plant species. Because
some finished medicinal plant products are not the dominantly traded commodity
creating a demand for the wild plant resources, regulating finished products
would have no conservation value. For other species, however, regulating
finished products has been deemed an important aspect of conserving the species
in the wild, particularly when the finished products are manufactured in the
range country. Because CITES Parties use annotations to include and exclude
certain commodities from a plant listing, this allows enforcement and conservation
efforts to be spent where the wild resource will benefit most.
The following is a list of the changes that were made to medicinal plant
annotations at CoP16 (with new text underlined):
- Asian and American Ginseng
(Panax ginseng, P. quinquefolius). Both of these adaptogenic herb species, used widely in
Traditional Chinese Medicine as well as Western herbal medicine, are currently
listed in Appendix II.6
Annotation #3 was revised to read: “Designates whole and sliced roots
and parts of roots, excluding manufactured parts or derivatives such as
powders, pills, extracts, tonics, teas, and confectionery.”
This underlined text previously had been removed by a 2007 CoP amendment, which
caused confusion among some ginseng exporter and inspection authorities as to
whether manufactured products were regulated under the listing. Thus, the
United States proposed at CoP16 to reinstate the explanatory text in order to
clarify which ginseng commodities are and are not regulated under CITES. The
CoP16 amendment, which was supported by the American Herbal Products
Association (AHPA), was adopted unanimously by the Parties.
However, according to Uwe Schippmann, PhD, head of the German CITES Scientific
Authority on Plants, “In my view this
is not a reason to change an annotation, rather this should be an incentive for
increased efforts in enforcement training” (email, April 22, 2013).
- Hoodia spp. Currently listed in Appendix II, succulent species in this genus —
namely H. gordonii — are known for their appetite-suppressing
usages in traditional medicine.8 Annotation #9 for hoodia had been
criticized for being ineffective and creating confusion.9 While its purpose was to exclude plant material with approved
sustainable production certifications, these certification schemes were never
put in place by the three range countries. Therefore, the annotation has never been
implemented and some Parties have suggested that it should be repealed.
The
amendment proposed and agreed upon at CoP16 involved only a slight change in
wording
to clarify that the agreements will be individually
entered into between the CITES authority and a producer in that range country:
“Produced from Hoodia spp. material obtained
through controlled harvesting and production under the terms of an agreement
with the relevant CITES Management Authority of [Botswana under
agreement no. BW/xxxxxx] [Namibia under agreement no. NA/xxxxxx] [South Africa
under agreement no. ZA/xxxxxx].” [Editor’s
note: All commodities derived from Hoodia spp. continue to be regulated under CITES,
including seeds, plants, and finished products packaged and ready for retail
trade, except for those products produced in accordance with the requirements
of the revised annotation. All international trade requires the issuance of
CITES permits and certificates from any CITES member country, including the
United States.]
- Brazilian rosewood (Aniba rosaeodora). This tree species, currently listed in Appendix II, is used as a
source of an essential oil for skin care and aromatherapy purposes.10
Proposed by Brazil and unanimously adopted, Annotation #12 now reads: “Logs,
sawn wood, veneer sheets, plywood and extracts. Finished products containing
such extracts as ingredients, including fragrances, are not considered to be
covered by this annotation.”11 This revision clarifies the exemption
of extract-based finished products, and also uses the term “extract,” whereas
the previous version used “essential oil.” This subtle change is due to a
revised definition of “extract” approved at CoP16: “Any substance obtained
directly from plant material by physical or chemical means regardless of the
manufacturing process. An extract may be solid (e.g., crystals, resin, fine or
coarse particles), semi-solid (e.g., gums, waxes), or liquid (e.g, solutions,
tinctures, oil and essential oils).”
During the time between CoP16 and CoP17, the CITES Standing
Committee’s working group on annotations will discuss, among other issues, if only pure rosewood oil
or dilutions and mixtures are to be controlled. [Editor’s Note: The common
name “Brazilian rosewood” also has been used to refer to Dalbergia nigra
(a species of rosewood also native to Brazil, but that is listed in CITES
Appendix I and traded primarily as timber and also used in perfumery).
According to the American Herbal Products Association’s Herbs of Commerce,
2nd ed., which is the US standard reference for common names of
botanical ingredients used in supplements (21 CFR 101.4(h)), the standardized common
name “Brazilian rosewood” is associated with Aniba rosaeodroa, not Dalbergia
nigra.]
- Agarwood-producing taxa (Aquilaria spp., Gyrinops
spp.). Species in these Appendix II
genera are used in traditional medicine systems, including Ayurveda, for a
variety of uses.12 China, Kuwait, and Indonesia
proposed replacing the previous annotation with a new annotation that is
specific to the agarwood trade. After extensive discussion, the following amended
annotation was adopted: “All parts and derivatives, except: a) seeds and
pollen; b) seedling or tissue cultures obtained in vitro, in solid or
liquid media, transported in sterile containers; c) fruits; d) leaves; e)
exhausted agarwood powder, including compressed powder in all shapes; f)
finished products packaged and ready for retail trade, this exemption does not
apply to beads, prayer beads and carvings.”13
While it was easily agreed that these specific products pose no conservation
risk, many Parties argued that some are not readily recognized by customs
officers and that identification of such commodities would be difficult. Additionally, Parties adopted an exemption for personal effects of agarwood
items when they are personally hand-carried or carried in accompanying baggage,
including up to 1 kg of agarwood woodchips, 24 ml oil, and two sets of beads,
(or prayer beads, or two necklaces or bracelets) per person.
Appendix II Additions
Several plant species were included in Appendix II at CoP16. Representatives
from Madagascar proposed listing seven endemic (native only to Madagascar) plant
species in Appendix II, including: Adenia firingalvansis, A.
subsessifolia, Cyphostemma laza, Operculicarya decaryi, Senna
meridionalis, Uncarina grandidieri, and U. stellulifera. All Parties
in attendance approved the proposals, and the listings include all recognizable plant parts (including seeds) and derivatives.
These Madagascan plants are slow-growing and do not regenerate well, and most
are succulents with bonsai-like appearance.10 Seeds and seedlings of
these plants are harvested from the wild and are traded internationally for
ornamental use, while some of the species also have local medicinal uses and
may be in international trade for therapeutic applications to a lesser extent. Senna
meridionalis leaves, for example, are used to treat hemorrhoids; this
tropical deciduous tree belongs to a genus that also is widely known for its
laxative effects. Uncarina species are used to treat dandruff and to
reverse hair loss, and A. firingalavensis is a liana that is used
to treat scabies. It is not clear, at this point, to what extent these seven plant
species are traded internationally for therapeutic applications, if at all, but
because seeds and all parts and derivatives are included in the listings,
materials in trade for medicinal use will also be regulated under CITES.
Dr. Schippmann noted, “All these proposals were agreed on by consensus to show
support for Madagascar, despite the fact that both the CITES Secretariat and
the IUCN/TRAFFIC analysis in their recommendations had stated that these
species would not meet the criteria for listing species in Appendix II.” The
United States, however, fully supported the proposals, finding that
wild-harvested seeds and seedlings of these species are imported to the United
States and that — based on the life-history traits of the species and their
status in the wild — the species qualify for listing in Appendix II.
Representatives from Kenya proposed to include East African sandalwood (Osyris
lanceolata) in Appendix II, with coverage of the entire species range,
which includes sub-Saharan Africa, the Iberian Peninsula and Balearic Island,
India, and Southeast Asia.14 East African sandalwood is traded internationally
for its aromatic wood and oil, which is used in the cosmetic and fragrance
industries, and it also has medicinal applications. At the meeting, the
proposal was modified to include only the East African sandalwood populations in
Burundi, Ethiopia, Kenya, Rwanda, Tanzania, and Uganda. The proposal was
adopted by consensus. The listing includes all parts and derivatives except
seeds, pollen, and finished products packaged and ready for retail trade.
Several species of tropical timbers were proposed for Appendix II listing,
including Thailand rosewood (Dalbergia cochinchinensis), black rosewood
(D. retusa), granadillo rosewood (D. granadillo), Honduras
rosewood (D. stevensonii), Madagascan rosewood (D. spp.), and Madagascan
ebony (Diospyros spp.). These proposals were unanimously adopted by the Parties. It was notable that China, a major importer of these timbers, did not oppose or prevent the consensus adoptions. While this was
praised as a conservation milestone by many, illegal logging and illegal trade in these species remain a challenge for the CITES Parties and efforts are underway to effectively implement the listings.
These listings, which perhaps drew the most public attention, were due to
concerns about the timber trade and should not impact the medicinal and
aromatic plant industry.
For all of these species, the amendments and listings will become effective on
June 12, 2013, 90 days after the conclusion of the CoP16 meeting. The next
CITES Conference of the Parties, CoP17, will be held in South Africa in 2016.
—Patricia DeAngelis,1 Pat Ford,
1 Lindsay Stafford Mader, 2 Anne St. John3
1 US Fish and Wildlife Service, Division of Scientific
Authority
2 American Botanical Council
3 US Fish and Wildlife Service, Division of Management
Authority-Wildlife Trade and Conservation Branch
References
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