[MPWG] Black Cohosh and CITES

[Patricia_DeAngelis at fws.gov]

Hello All,

It has recently come to my attention that there is confusion as to whether 
the US Fish and Wildlife Service plans to list black cohosh under the 
Convention on International Trade in Endangered Species of Wild Fauna and 
Flora (CITES) or the Endangered Species Act (ESA).  With the e-mail I hope 
to clarify this issue and also provide some additional information that 
may be of interest.

Black cohosh (Cimicifuga racemosa; Actaea racemosa) is not and has not, to 
the best of my knowledge, ever been under consideration to be listed under 
ESA. 

Confusion may have arisen from the fact that we have reviewed this species 
for listing under CITES, which is implemented under ESA.  Here is a 
synopsis of that activity:
>In June 2001, we initiated a review of the species for possible inclusion 
in CITES Appendix II (66 FR 31686). 
>In April 2002, we announced that we did not intend to seek an Appendix-II 
listing in favor of considering an Appendix III listing (67 FR 19207). 
>As of March 2006, we withdrew the species from active consideration of an 
Appendix III listing, although we continue to monitor the species (see 
summary, below).

Despite these developments, information regarding the initial review of 
this species for Appendix II continues to linger on various websites and 
publications.  This may be a cause for continued confusion.   If you are 
aware of any publications or websites that require updated information, I 
encourage you to forward this information to them. 

Thank you,
Patricia De Angelis


Patricia S. De Angelis, Ph.D.
Botanist - Division of Scientific Authority
Chair - Plant Conservation Alliance - Medicinal Plant Working Group
US Fish & Wildlife Service
4401 N. Fairfax Dr., Suite 750
Arlington, VA  22203
703-358-1708 x1753
FAX: 703-358-2276
Working for the conservation and sustainable use of our green natural 
resources.
<www.nps.gov/plants/medicinal>

- - - - 
Black cohosh summary:

Black cohosh (Cimicifuga racemosa; Actaea racemosa) is native to the 
woodland habitat of Appalachia.  Black cohosh is popular domestically and 
abroad as a medicinal (primarily obtained from the rhizome) and as an 
ornamental (for the fairy-like bloom in mid-to-late-summer).  Black cohosh 
is a popular “natural” alternative to hormone replacement therapy and is 
the main ingredient in several popular products (including Remifemin).  It 
is estimated that more than 95% of black cohosh entering medicinal trade 
is wild-harvested. 

Distribution and conservation status:  This perennial understory herb has 
a broad range in the deciduous forests of eastern North America, from the 
Southern Appalachians in Georgia to Southern Ontario in Canada.  Black 
cohosh is generally considered to be more abundant in the southern portion 
of its range.  It is considered weedy in some areas but is state-listed 
elsewhere (C. racemosa is listed as endangered in Illinois and 
Massachusetts).  A large population of black cohosh might consist of 250 
to 500 individuals, or from 400 to 600 plants per acre. 

Threats:  Habitat destruction is a threat to this species throughout its 
core range, especially in Ohio, West Virginia and North Carolina. 
Wild-harvested seeds, rhizomes and whole plants are sold in the medicinals 
trade.  Seeds and whole plants are also harvested for the horticultural 
trade. 

Harvest:  According to the American Herbal Products Association’s (AHPA) 
Tonnage Survey, the average annual wild-harvest of black cohosh between 
1997 and 1999 amounted to 322,507 dry pounds, or 4,515,098 plants per 
year.  During the same period, the U.S. Forest Service granted permits 
totaling over 16,000 dry pounds of black cohosh.  This equates to an 
annual harvest of 5,333 dry pounds, or 229,000 wild-harvested black cohosh 
roots per year.  Given the current estimates of black cohosh population 
sizes, these harvest levels can be considered quite large.  There is a 
disparity between harvest as reported by industry and the amount of 
permitted harvesting on public land.  The effect unpermitted harvesting is 
unknown.

Export:  According to a market report, at least 753,000 dry pounds of 
black cohosh root was exported in 1998, 1999, and 2001.  This equates to 
an annual export of 251,000 dry pounds, or 3,514,000 wild-harvested roots 
per year.  Export data obtained from the PIERS Exports database and 
phytosanitary certificates between 1999 and 2002, showed that an excess of 
1,317,004 roots were exported over the four year period.  This equates to 
more than 329,251 roots per year between 1999 and 2002.  This figure is 
significantly lower than the harvests reported by industry.

Conclusion:  Black cohosh, whose range spans the entire Appalachian chain, 
is in demand for its medicinal properties and is primarily wild-harvested 
for this purpose.  Incomplete or inaccurate harvest and trade data make it 
difficult to determine the effect of the medicinals trade on black cohosh. 
 As with most medicinal plants in the United States, black cohosh would 
benefit from the increased monitoring and tracking system that an 
Appendix-III listing in CITES could provide.  However, we are not pursuing 
such a CITES listing at this time.  Updated information on abundance, 
collection permits, harvest levels, the effect of harvest on this species, 
and the potential for illegal harvest are pending.  We continue to monitor 
this species. 



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