[MPWG] exporting American ginseng roots

[Patricia_Ford at fws.gov]

United States Department of the Interior

                         FISH AND WILDLIFE SERVICE
                          Washington, D.C. 20240


                                                            August 31, 2005

In Reply Refer To:
DOI/FWS/DSA

Dear State Ginseng Coordinator:

Our CITES non-detriment finding for the export of American ginseng (Panax
quinquefolius) harvested in 2005, issued on August 3, 2005, has resulted in
some questions and misunderstandings that require clarification.  Based on
new information and further consultations with ginseng experts, we are also
modifying our previous guidance on aging of roots.

With our finding, we increased the minimum age for exports of wild American
ginseng to 10 years while maintaining a minimum age of 5 years on
woods-grown and wild-simulated ginseng.  In our finding, referred to
10-year-old plants as having four leaves, or prongs, and we provided
information from three published sources regarding the aging of plants in
the field based on numbers of leaves.  We wish to clarify that the Fish and
Wildlife Service does not regulate the harvest of ginseng, and the
information relating numbers of leaves to age was only meant to serve as a
guide to diggers to be able to age plants in the field before digging.  We
did not intend to impose a Federal requirement for a minimum number of
leaves on ginseng at the point of harvest.  We note, however, that a number
of States do have such requirements as a result of our previous minimum-age
requirement of 5 years, imposed in 1999-2004.  We are aware that the number
of leaves may vary, even for plants of the same age.  For export purposes,
roots are aged at the time of export based on the number of bud-scale
scars, not leaves.  Furthermore, we have in the last week received new
information (J. McGraw, pers. comm.) indicating that most 10-year-old
plants can be expected to have no more than 3 leaves (i.e., 3 prongs).

Regarding aging of ginseng roots, in our finding we advised that roots from
10-year-old plants should possess 10 bud-scale scars, just as we had
previously advised that roots from 5-year-old plants should have 5 scars.
After a further review of the literature, coupled with information provided
by ginseng experts, we are revising this guidance, so that wild roots (10
years old or older) must possess a minimum of 9 bud-scale scars, and
woods-grown and wild-simulated roots must have at least 4 bud-scale scars.
This allows for the fact that, during their first year of growth, ginseng
plants do not form a bud-scale scar.  We acknowledge that wild ginseng seed
typically is sown, through natural dispersal or planting by diggers, 18–20
months prior to actual germination, to allow for the stratification process
required by the species.  However, seeds may lie dormant for even longer
than 18-20 months (i.e., as part of a seed bank), so wild plants can only
be aged practically based on the year when they germinated, not when they
were sown.

We appreciate the feedback we have received to improve and clarify the
information we are using to make our finding, and to provide more accurate
information to the States and other stakeholders.  If you have any further
questions about this finding, please do not hesitate to contact me
(telephone, 703-358-1708; or e-mail, scientificauthority at fws.gov).  For
questions on permit procedures, please contact the Division of Management
Authority, 4401 North Fairfax Drive, Room 700, Arlington, Virginia 22203
(telephone, 703-358-2104; or e-mail, managementauthority at fws.gov).

                                    Sincerely,
                                    /s/ Robert R. Gabel
                                    Robert R. Gabel
                                    Chief, Division of Scientific Authority