PPQ Form 587

[Chococatte]

I want to acquire a Paphiopedilum vietnamense. I understand that species under this genus or genera falls under Appendix I of CITES. But what if I import them as seeds or in vitro (seedlings)? Am I allowed to put that as an option on, Part 2: Plants or Plant Products to be Imported, under Plant Parts of the PPQ Form 587 to acquire an import permit? Will I still be require to have a CITES certificate? Grateful to all for your wisdom.

[Ray]

In theory, no, but there have been issues in the past wherein the convention was misinterpreted.

Why not call APHIS and ask them?

[Chococatte]

Originally Posted by Ray

Why not call APHIS and ask them?

Because when I called the person wouldn't be back in her office until July 7th when I called back again to reach somebody they didn't have no idea and directed me back to the lady that was on vacation. I thought I ask here to see if anyone recently submitted Permit for Importing Plants to see what other option they might put under that section of the form.

[Ray]

As I stated more briefly earlier, CITES has all paphs as Appendix I, meaning they cannot be internationally traded. However, CITES also clearly states (Article VII) that "Specimens of an animal species included in Appendix I bred in captivity for commercial purposes, or of a plant species included in Appendix I artificially propagated for commercial purposes, shall be deemed to be specimens of species included in Appendix II.", meaning that it CAN be imported with the proper permit and CITES docs from the exporter.

Further, right in the appendices, under the "Orchidaceae" heading, it states "For all of the following Appendix-I species, seedling or tissue cultures obtained in vitro, in solid or liquid media, transported in sterile containers are not subject to the provisions of the Convention".

Where the "gotcha" comes in is interpretation at the port of importation, as there have been cases in the recent past with Paph. vietnamense or Phrag kovachii in which APHIS has reused to even allow flasks in.

[Ray]

Maybe you should just apply for a general permit, then print out that section of the appendix, highlight it, and have the vendor attach it to the documentation!

[Chococatte]

Originally Posted by Ray

Maybe you should just apply for a general permit, then print out that section of the appendix, highlight it, and have the vendor attach it to the documentation!

Isn't the PPQ587 for the general permit I understand PPQ621 ($70) is required for businesses wanting to import endangered species of plants and plant products for experimental purposes.

Originally Posted by Ray

As I stated more briefly earlier, CITES has all paphs as Appendix I, meaning they cannot be internationally traded. However, CITES also clearly states (Article VII) that "Specimens of an animal species included in Appendix I bred in captivity for commercial purposes, or of a plant species included in Appendix I artificially propagated for commercial purposes, shall be deemed to be specimens of species included in Appendix II.", meaning that it CAN be imported with the proper permit and CITES docs from the exporter.

Further, right in the appendices, under the "Orchidaceae" heading, it states "For all of the following Appendix-I species, seedling or tissue cultures obtained in vitro, in solid or liquid media, transported in sterile containers are not subject to the provisions of the Convention".

Where the "gotcha" comes in is interpretation at the port of importation, as there have been cases in the recent past with Paph. vietnamense or Phrag kovachii in which APHIS has reused to even allow flasks in.

Yeah I read that that were I became confused by the wording of the CITES. So vendors importing flasks of species under Appendix I have to have attached a CITES cert. stating that the seedling in this flask have been artificially propagated using wild collected specimens (with approval) from the country of origin before APHIS will allow the flasks to enter the country. What's even more confusing is interpretation of small lot of seeds in CITES Appendix I and ESA?

[Ray]

It's nuts.

Obviously, plants in flasks are "artificially propagated" and "sterile", negating the need for CITES or Phytosanitary certs!

By the way, I just took a look at the APHIS site, and PPQ 587 is for the general import permit, 588 is the permit to import for scientific purposes, and 621 is the "application for protected plant permit to engage in the business of importing, exporting or re-exporting terrestrial plants or plant products that are protected".

Reading the instructions related to 587, it is apparently applicable to individuals or commercial entities nowadays.