HerbalEGram Volume 17, Issue 5, May 2020

 

Strengthening Sustainable International Trade in Medicinal and Aromatic Plants

Updates from the 18th meeting of the Conference of the Parties to CITES and potential future directions

By Patricia De Angelis, PhD, and Anastasiya Timoshyna

More than 800 species of medicinal and aromatic plants (MAPs) are included in the appendices of the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), a multinational agreement that regulates international trade of more than 35,000 animal and plant species.¹

Given that many CITES-listed plant species are sources of ingredients used in cosmetic, food, and health products, and almost all of the world’s trading nations are members, or Parties, of this Convention, it is important for the botanical industry to understand exactly which CITES-listed plant species require CITES permits. Effective CITES implementation also can be challenging for CITES authorities given the large number of listed species, the lack of baseline biological data for many species, the complexity of global supply chains, and difficulties in monitoring trade, particularly on internet platforms. These are among the issues that CITES attempts to address in its meetings, which are held every two to three years.

At the 18th meeting of the Conference of the Parties to CITES (CoP18), which was held in Geneva, Switzerland, in August 2019, CITES Parties took several actions that are relevant to international trade in MAPs and aim to improve CITES implementation for MAPs. CoP18 addressed the following: a new source code* for plants in trade, a new finished products exemption, and efforts to monitor the impacts of international trade on specific CITES-listed and non-listed MAPs, as well as more general efforts to look at the sustainable use and conservation of CITES-listed MAPs. Emerging concepts explored in other fora were also presented at CoP18 and may assist stakeholders along MAP supply chains to meet the requirements of CITES. These emerging concepts, followed by the detailed CoP18 outcomes, are summarized below.

What is CITES? The goal of CITES is to ensure that international trade in specimens of listed animals and plants is conducted legally and does not threaten their survival in the wild. The text of CITES was agreed on at a meeting of representatives of 80 countries in March 1973, and the Treaty entered into force in July 1975. Currently, 182 countries and the European Union (EU) are members of CITES. Each country that implements CITES is referred to as a “Party.” Every two to three years, CITES Parties hold a Conference of the Parties (CoP) to make important decisions about CITES implementation, the inclusion or deletion of species in the CITES appendices, or the transfer of species among appendices.1 CITES helps regulate international trade of listed species (including their parts, derivatives, and products) through a system of permits issued by officially designated national authorities and based on determinations that the trade is legal and does not threaten the survival of the species. Species protected under CITES are included in one of three appendices that provide different levels of protection: Appendix I includes species threatened with extinction that are or may be threatened by trade, and provides the greatest level of protection, including restrictions on commercial trade. Appendix II includes the majority of species that are currently not threatened with extinction but that may become so without regulations to ensure that trade is legal and sustainable. Appendix III includes species protected in at least one country to which the species is native and in which the country seeks the cooperation of other Parties in the control of international trade. Changes to Appendices I and II must be proposed by a Party at least 150 days before a CoP, providing requisite biological and trade data (as per Resolution Conf. 9.24 [Rev CoP17]). At the CoP, Parties decide whether to adopt the proposed changes. By contrast, individual Parties may include plant and animal species in Appendix III at any time by notifying the CITES Secretariat, but the species must be protected by law in that country. Recognizing the importance of scientific knowledge that supports the actions and policies adopted by the CoP, the Parties created three committees that meet between CoPs to provide guidance to improve CITES implementation. The Standing Committee addresses issues related to implementation and enforcement while the Plants Committee and Animals Committee address scientific and technical issues. In the United States, the US Fish and Wildlife Service (USFWS) is the lead agency (i.e., national authority) responsible for the implementation of CITES. The United States undertakes a significant public engagement process to prepare for CITES meetings, which includes obtaining public input on species listing proposals and other agenda items as well as in the development of US positions on agenda items to be discussed at a CoP (US positions inform how the USFWS plans to addresses issues at the meeting). (The Federal Register, for example, included several notices regarding species proposals for consideration at CoP18.3-7) The USFWS also chairs the Medicinal Plant Working Group (MPWG) as part of the Plant Conservation Alliance, a national federal/nonfederal collaboration to conserve and restore native plants and their habitats. The MPWG fosters a greater understanding of the multifaceted US botanical industry, furthers the sustainable use and long-term conservation of many US native plant species that are harvested for international trade, and creates connections among growers, consumers, harvesters, and practitioners that support US obligations and input to CITES. (More information about the Plant Conservation Alliance and the MPWG listserve is available here.) How CITES Works CITES works through a system of permits issued by trading countries. Each CITES Party must designate a Management Authority and Scientific Authority to carry out the treaty. The Management Authority ensures that CITES-listed species are traded legally through the issuance of permits. The Scientific Authority determines whether trade in a particular animal or plant species could be detrimental to its survival in the wild. Commercial international trade in Appendix II species requires certain conditions have been met, including: The exporting country must make a non-detriment finding (NDF) for a CITES export permit to be issued. In other words, the exporting country should be satisfied that plants or plant parts have been collected in a way that does not threaten the survival of species — in essence, the materials should be sustainably harvested. The exporting countries also must make legal acquisition findings (LAFs), which ensure that the plants were collected in accordance with all relevant national laws. Countries sometimes may impose stricter import or export controls, often referred to as “stricter domestic measures.” For example, the EU requires import findings for Appendix II specimens, although this is not required by CITES. Some countries may not allow the export of wild-collected plant species listed in Appendix II. For example, Canada allows only the export of cultivated American ginseng (Panax quinquefolius, Araliaceae) because the country has determined that any commercial harvest of wild American ginseng plants would be unsustainable. Rarely, some importing countries may unilaterally suspend trade with countries where there is concern that NDFs have not been properly made.

Emerging Concepts in Meeting CITES Appendix II Permitting Requirements: The Role of Voluntary Certification

Meeting CITES requirements for sustainable and legal trade and any applicable stricter domestic measures can be challenging for herb producers and traders. A recent analysis of global CITES trade data found that 119 million pounds (54 million kg) of Appendix II MAP species were traded from 2006 to 2015, nearly half of which was wild-sourced.⁸ The trade involved mainly 43 species, including commodities such as candelilla (Euphorbia antisyphilitica, Euphorbiaceae) leaf wax, pygeum (Prunus africana, Rosaceae) bark, and aloe (Aloe spp., Asphodelaceae; CITES uses a previous family name, Liliaceae) juice or latex. The main importing countries (responsible for 77% of the imports) were France, the United States, Japan, Germany, and Spain, while Mexico, Cameroon, and South Africa were the most significant exporting countries (responsible for 75% of the exports).

Under CITES, commercial international trade in Appendix II plant species (including wild-collected plants) is allowed but regulated through a system of permits that aim to ensure that their trade is essentially sustainable and legal. As such, a CITES Appendix II permit for wild-collected plants may be viewed as recognition that the traded plant material is both sustainably harvested and legally obtained, which in turn supports long-term supply chain sustainability for botanical producers and serves as a potential marketing point to consumers.

A January 2019 workshop organized by TRAFFIC, a non-governmental organization focused on the sustainable international trade of plants and animals, explored whether existing voluntary certification standards (VCSs) support government agencies that implement CITES and industry members who use and trade in CITES-listed MAPs to meet CITES permitting requirements.⁹ This workshop had been preceeded by a side-event with the CITES Plants Committee, a thorough desk-review of available literature on the subject, and a stakeholder questionnaire to government agencies and industry. These findings were summarized in an information document to the CITES CoP18.¹⁰

Workshop attendees discussed whether third-party certification programs that use rigorous on-the-ground methodology to verify the sustainability of harvesting practices and supply chain traceability can serve a complementary role in meeting the implementation requirements of CITES (in particular, the making of non-detriment findings [NDFs] as well as the determination of legal acquisition).

The group examined the specifications of four VCSs that can be applied to MAPs — FairWild Standard Version 2.0 Performance Indicators,¹¹ Field Checklist for Union for Ethical Biotrade (UEBT)/UTZ Certified Herbal Tea,¹² Forest Stewardship Council (FSC) International Generic Indicators,¹³ and European Commission Organic Rules and Regulations (EC) 834/2007¹⁴ and EC 889/2008¹⁵ — and compared them against CITES requirements. According to a TRAFFIC report on the workshop, the FairWild Standard appears to address all relevant CITES indicators, and the UEBT/UTZ and FSC provide some relevant insights but with some indicators being more site-specific than species-specific. The EU Organic Rules and Regulations do not appear adequate to inform CITES requirements.

Participants observed that, due to variations in supply chains, species management, and other factors,⁹ VCSs may better address CITES permitting requirements for some supply chains and species than others — particularly goldenseal (Hydrastis canadensis, Ranunculaceae) root and rhizome, candelilla leaf wax, and non-CITES-listed frankincense (Boswellia spp., Burseraceae) gum-resin exudate — and that practical examples of synergies between the VCSs and CITES implementation are needed. One such project is already underway, funded by the UK government’s Darwin Initiative, to pilot the use of FairWild Standard certification to aid in the implementation of CITES for Appendix II-listed essential oil derived from the rhizomes of jatamansi (Nardostachys grandiflora, Valerianaceae).

Finally, workshop participants discussed opportunities to improve the perception of CITES within the botanical sector. CITES is sometimes perceived as a hindrance to trade, and some companies may avoid using CITES-listed species for that reason. Two common misconceptions about CITES is that all CITES-listed species are endangered and that CITES is a ban on commercial international trade in wild plants. While this is the case for a limited number of species in CITES Appendix I, it is not true for the vast majority of CITES-listed plant species that are included in Appendix II or III.

CoP18 Decisions About CITES-listed MAPs in Trade

Decisions are adopted or modified by the Parties at each meeting to improve implementation of CITES. At CoP18, the Parties adopted several decisions that aim to improve the conservation of medicinal plant species that are harvested for international trade.

Integrated approach to trade

These decisions (18.300-18.303) continue the CITES Parties’ long-standing efforts to improve the sustainable use and conservation of CITES-listed MAPs by ensuring that trade is legal, sustainable, and traceable. CITES recognizes that trade in MAPs provides an essential contribution to the health and livelihoods of indigenous people and local communities (IPLCs) and that IPLCs can, in turn, play a role in strengthening global supply chains. The decisions adopted at CoP18 take a fresh and holistic look at current challenges and opportunities in implementing CITES for MAPs and include: (1) engaging the key players in trade supply and value chains to raise awareness and understanding of CITES regulations for MAP species; (2) examining case studies involving local and traditional knowledge; (3) using participatory assessments, monitoring, and management of CITES-listed MAP species; and (4) reviewing ongoing work on sustainable and traceable supply and value chains for MAP products, focusing on certification schemes, standards, and guidelines.

Notably, the original focus of these decisions on “medicinal” plants was extended to “medicinal and aromatic” plants based on input from TRAFFIC and the IUCN Medicinal Plant Specialist Group during discussion at the meeting. This change recognizes that CITES-listed plant species are traded not just for their medicinal uses but also for aromatherapy, cosmetics, and culinary uses. MAP supply chains share certain similarities, and the use of this broader term may engender wider engagement of these stakeholder groups and industry members who play a role in sustainable use and conservation of these plant resources.

Ongoing focus on agarwood-producing taxa

These decisions (18.203-18.204) call for the continued monitoring of the conservation impacts of international trade on the long-term survival of agarwood-producing species (Aquilaria spp. and Gyrinops spp., Thymelaeaceae) and the gaps in the way trade in the wood of these species is being managed. The Plants Committee is tasked with analyzing trade data and available information on the conservation status of agarwood-producing species and presenting findings at the next CoP.

Gathering information on frankincense trees

These decisions (18.205-18.208) direct the Parties to provide information about populations, status, trade, and threats to Boswellia species, as well as management and propagation of the species, which are widely used for religious (as incense), cosmetic, aromatherapy, and other purposes. Although Boswellia species are not currently included in the CITES appendices, concerns are growing that international trade in the products (exudates) of these tree species may not be sustainable. Several range countries, including Ethiopia, Oman, Kenya, Senegal, and Chad, strongly supported looking more closely at the conservation and sustainable use of these species. Trading countries, including the United Arab Emirates, EU countries, the United States, and the Republic of Korea, also supported adoption of these decisions.

Exemption for certain orchid products

These decisions (18.327-18.330) focus on assessing the conservation impact of exempting some finished products of orchid species or genera from CITES regulation. The entire orchid family (Orchidaceae) is currently included in the CITES appendices, with the majority of species in Appendix II. While most orchid species are traded for horticulture, many are also used as ingredients in cosmetic, personal care, and medicinal products. These include, for example, species of Dendrobium and Vanda, Gastrodia elata, as well as orchids used to make traditional foods like salep and chikanda. Under the present CITES Appendix-II listing, all orchid products are regulated under CITES, and these decisions will explore the conservation value of or risk to exempting orchid products. To ensure a common understanding in this work, the CITES Parties agreed on a working definition of the term “cosmetic” as: “Any product or mixture of products which is applied to an external part of the body only (e.g., skin, hair, nails, genitals, lips or teeth or the mucous membranes of the oral cavity) with the intent to clean, odorise, change the appearance or protect. Cosmetics may include the following: make-up, perfume, skin cream, nail polish, hair colorants, soap, shampoo, shaving cream, deodorant, sunscreens, toothpaste.” The Plants Committee will continue to consolidate information (including from industry and other stakeholders) on cosmetic and personal care uses and conservation risks association with any potential exemptions.

Improving implementation for pygeum

These decisions (18.260-18.262) encourage efforts to improve the sustainable use and conservation of pygeum, also known as African cherry, by building the capacity of CITES authorities in pygeum’s range countries to implement the Appendix II listing. Work related to these decisions will include compiling information from a recent workshop held in Africa (as part of the CITES Tree Species Programme [CoP18 Doc. 16]) to be presented at the next CoP.

A new source code for plants in trade

A new CITES source code “Y” (meaning “assisted production”) for plants was adopted for trade in plant specimens that are not wild-harvested (CITES source code “W”) nor artificially propagated (CITES source code “A”), as described in CoP18 Doc. 59.2. The new term “assisted production” is intended for plant specimens derived from sustainably sourced, artificially propagated, or CITES-exempted plant material grown in an environment with some level of human intervention for the purposes of plant production (Resolution Conf. 11.11 [Rev. CoP18]). Use of the new definition and source code will continue to require the Management and Scientific Authorities of the country of export to make the required determinations that such specimens intended for export were established in accordance with the provisions of CITES and relevant national laws, and in a manner not detrimental to the survival of the species in the wild. The proper use of “assisted production” may help promote more effective implementation of CITES for plants, reduce international trade of wild-collected specimens, and help promote the conservation and long-term sustainability of CITES-listed plants.

Progress on CITES implementation for tree species

Many of the more than 900 tree species included in the CITES appendices are harvested for their timber, but several are harvested for their bark or sap to be used as MAPs, including agarwood, pygeum, and African sandalwood (Osyris lanceolata, Santalaceae). The CITES Tree Species Programme funds projects submitted by range countries to address research and technical needs that will assist in effective CITES implementation for listed tree species. At CoP18, the Secretariat reported on progress and ongoing work in various countries to address the sustainable use and conservation of these important species.

CoP18 Proposals to Amend the Appendices Relevant to MAPs Species

There were nine proposals to amend the CITES appendices for plant species, including two pertaining directly to MAPs. The changes to CITES listings mentioned below became effective on November 26, 2019. The updated appendices can be found here.

Change to the annotation for Cape aloe (Aloe ferox) to exempt finished products from CITES regulations

The Parties adopted a proposal (CoP18 Prop. 55) to exempt finished products containing secondary processed derivatives while continuing to control international trade in extracts known as “bitters.” Supplemental information on the proposed exemption was provided in an information document. Several related Decisions (18.323-18.326) were also adopted that ask Parties to monitor and report to the Plants Committee any impacts that this exemption may have on the conservation status and harvest of Cape aloe.

Amended annotation for Grandidier’s baobab (Adansonia grandidieri, Malvaceae)

This change (CoP18 Prop. 56) was a technical correction to the existing annotation to remove the words “live plant” from the annotation because it was unnecessary and redundant. For all CITES-listed plant and animal species, whole specimens, whether alive or dead, are always subject to the provisions of the CITES in accordance with Article I, paragraph (b).

Other CoP18 Issues Relevant to a Range of Taxa, Including Plants

Enhancing traceability

At CoP18, the Parties adopted a working definition of “traceability” (Decisions 18.144-18.145). This provides an important opportunity to strengthen CITES implementation through modern traceability approaches. The overarching intent is to improve the ability for CITES Management and Scientific Authorities to make legal acquisition findings and non-detriment findings for trade in CITES-listed specimens.

Non-detriment findings

These findings are required for the export of all Appendix I and II species. The CITES Scientific Authorities of the exporting country must make a determination that the trade will not be detrimental to the survival of the species in the wild. The NDF and the legal acquisition finding made by the CITES Management Authority of the exporting country are the cornerstones of CITES in ensuring the sustainable and legal trade of Appendix II species. The Decisions adopted at CoP18 (18.132-18.134) called for the review of materials and guidance on making NDFs that are currently available to the Parties, identification of gaps and needs, development and adoption of new or updated materials as needed, and may involve one or more dedicated expert workshops to develop any new or updated NDF materials.

The role of rural communities and livelihoods in CITES

Several CoP18 documents reported outcomes of discussions around the importance of engaging rural communities in national CITES processes, such as the development of proposals to amend the appendices and as a source of expertise on sustainable use of CITES-listed species (Decisions 17.57 [Rev. CoP18] and 18.31-18.37). Although a proposal to establish a permanent Rural Communities Committee was rejected, Parties agreed to continue to explore mechanisms for engaging communities. The Parties agreed to use the term “Indigenous Peoples and Local Communities” (IPLCs) for future discussions in this context, similar to the terminology used in other multilateral environmental agreements. The CITES and Livelihoods Working Group was also re-established, with a mandate to continue to collect case studies that demonstrate how the sustainable use of CITES-listed species contributes to the livelihoods of IPLCs (Decision 18.33).

Demand reduction to combat illegal trade

These Decisions (18.86-18.87) chart the next steps for critically needed actions on demand reduction, including the development of nonbinding guidance for CITES Parties. This work will continue and strengthen CITES investment in tackling the entire network of illegal trade, from source to destination, and in addressing consumer demand as the underlying driver of wildlife trafficking. The importance of the balance between the demand and supply reduction, and for the demand reduction approaches not to limit legal trade were recognized.

Improving identification materials

These Decisions (18.135-18.139) call for the Animals and Plants Committees to review and revise outdated identification material and to make the materials more accessible. They also call for a review of the processes currently in place for the development of identification material and make recommendations for improvement. Parties are asked to provide information on the identification of species in trade within one year of acceptance of the listing. Updated and accurate identification materials are essential to the effective implementation of CITES, including MAPs.

CoP18 Information Documents Pertaining to MAPs

Information documents on the protection, conservation, or management of wild fauna and flora may be submitted by CITES Parties, observers, or the Secretariat for the attention of the participants at a meeting of the CoP. Such documents are for information purposes only and, as such, are not discussed or endorsed in any official capacity at the meetings. Several information documents submitted at CoP18 pertained to MAPs. The full list of information documents can be found here.

Voluntary certification standards and the implementation of CITES for trade in medicinal and aromatic plant species

Document CoP18 Inf. 36 reported on a project to explore the potential for VCSs to support the implementation of CITES for Appendix II-listed MAPs, namely in assisting the making of NDFs and legal acquisition findings. The project summary is available here.

Elements for a potential workplan for CITES implementation for trade in medicinal plant species

Document CoP18 Inf. 11 lays out possible MAPs-related activities and priorities that CITES Parties might undertake to:

(1) enhance mutual awareness and understanding between CITES bodies and medicinal plant trade stakeholders;

(2) enable efficient and effective making of legal acquisition and non-detriment findings;

(3) support in situ conservation by incorporating traditional knowledge and networks, and increased attention to local livelihoods; and

(4) strengthen CITES regulation and national Management Authorities and Scientific Authorities capacities for implementing CITES provisions for medicinal plants.

Report of the Prunus africana-related discussions within the CITES tree species regional meeting for Africa

Document CoP18 Inf. 62 includes a report on a CITES Tree Species Programme project that addressed the sustainable use and conservation of African cherry.

Medicinal plant listings in CITES (Korean Pharmacopoeia and Korean Herbal Pharmacopoeia)

Document CoP18 Inf. 48 provides an overview from the Republic of Korea of plant species traded for therapeutic purposes and regulations pertaining to their management.

Trade in Boswellia

Document CoP18 Inf. 53 outlines a project for an objective, science-based assessment of the conservation and trade of materials derived from this genus.

Workshop proceedings: Sustainable wildlife management beyond 2020

Document CoP18 Inf. 10 provides a summary of the discussions on the post-2020 global biodiversity framework as it applies to fauna and flora, drawing particular attention to the importance of a global target and commitment on addressing the issues of species over-exploitation (unsustainable and/or illegal use and trade) and enhanced benefits to conservation and wellbeing from sustainable and legal use and trade.

Conclusion

The wide array of MAP issues discussed at this meeting demonstrates a continued commitment among CITES Parties to bolster the sustainable use of CITES-listed MAPs, harness information and expertise to focus on risks to wild resources, and adapt to evolving challenges in global trade.

The next meeting of the Plants Committee is expected to be held July 17-23, 2020, in Geneva, Switzerland. The meeting will bring scientific input and specialized knowledge on specific issues pertaining to the plants subject to trade controls. Working groups sometimes are formed either during the meeting or afterwards to further elaborate on specific issues. The USFWS will share information about the meeting when it becomes available, both on its website and over the MPWG listserve. Please see the FWS CITES Plants Committee webpage for additional background information, including the process by which non-governmental observers may participate in the meeting. The meeting agenda and documents to be discussed will be made available at least 60 days before the meeting. Please check the CITES Plants Committee website for information as it becomes available. The American Botanical Council (ABC) and the ABC Sustainable Herbs Program will also make information available about the Geneva meeting to its US and international stakeholders.

* A source code is a letter used on CITES permits and certificates to indicate the source of the specimen covered therein (e.g., the source code W denotes that the specimen was taken from the wild).²

Patricia De Angelis, PhD, is a botanist in the Division of Scientific Authority for CITES in the International Affairs Program of the U.S. Fish and Wildlife Service, with more than 16 years’ experience on the impacts of trade on plant and animal species. She also chairs the Plant Conservation Alliance-Medicinal Plant Working Group, supporting information sharing among stakeholders and the role of generational and traditional knowledge to inform the sustainable use and conservation of medicinal plants in the United States.

Anastasiya Timoshyna is TRAFFIC’s Senior Programme Coordinator – Sustainable Trade. She coordinates approaches to develop better regulations for sustainable trade, develop private sector standards, and enable businesses and consumer behavioral change. She has over ten years of experience of working on implementing FairWild best practices for sustainability of harvesting and trade in wild-collected plants (in China, East and Southern Africa, Viet Nam, India, Nepal, and Europe). Anastasiya is also a Co-Chair of the IUCN/SSC Medicinal Plant Specialist Group and is a member of the ABC Sustainable Herb Program’s Advisory Group.

References

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3. US Fish and Wildlife Service. Conference of the Parties to CITES; Eighteenth Regular Meeting; Provisional Agenda; Announcement of Public Meeting. Federal Register. 2019; 84(44):8104-8105.
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8. Furnell S and Timoshyna A. Potential of certification schemes to support management and scientific authorities with the implementation of CITES Appendix II measures for medicinal and aromatic plant species. CITES Plants Committee-Information document July 2018;PC24 Inf. 12. Available at: https://cites.org/sites/default/files/eng/com/PC/24/Inf/E-PC24-Inf-12.pdf. Accessed December 19, 2019.
9. Timoshyna A, Furnell S, Harter D. CITES and voluntary certification for wild medicinal and aromatic plants. TRAFFIC Bulletin. October 2019;31(2). Available at: www.traffic.org/site/assets/files/12507/cites-wild-maps.pdf. Accessed December 19, 2019.
10. The FairWild Standard sets forth ecological and fair trade guidelines, focused on wild-sourced products. Available at: www.fairwild.org/the-fairwild-standard. Accessed March 3, 2020.
11. Furnell S, Timoshyna A, Harter D. Voluntary certification standards and the implementation of CITES for trade in medicinal and aromatic plant species. CITES: Geneva, Switzerland; July 2019. Available at: https://cites.org/sites/default/files/eng/cop/18/inf/E-CoP18-Inf-036.pdf. Accessed June 22, 2020.
12. The UEBT/UTZ certification combines fair trade standards with sustainable practice standards. Available at: www.ethicalbiotrade.org/utz. Accessed March 3, 2020.
13. The FSC certification proscribes forest management practices that are environmentally responsible and socially beneficial. Available at: https://us.fsc.org/en-us/certification. Accessed March 3, 2020.
14. Council Regulation (EC) No 834/2007 of 28 June 2007 on organic production and labelling of organic products and repealing Regulation (EEC) No 2092/91. Available at: eur-lex.europa.eu/eli/reg/2007/834/oj. Accessed June 4, 2020.
15. Commission Regulation (EC) No 889/2008 of 5 September 2008 laying down detailed rules for the implementation of Council Regulation (EC) No 834/2007 on organic production and labelling of organic products with regard to organic production, labelling and control. Available at: eur-lex.europa.eu/eli/reg/2008/889/oj. Accessed June 4, 2020.