Subject: Re: Importing herbarium specimens

Joseph H. Kirkbride, Jr. jkirkbri at ASRR.ARSUSDA.GOV
Fri May 24 09:47:04 CDT 2002

From: Sally Shelton [Shelton.Sally at NMNH.SI.EDU]
Sent: Thursday, May 23, 2002 2:22 PM
Subject: Re: Importing herbarium specimens

From: Tom Wendt <twendt at>

Importing herbarium specimens

Folks, We have just received the renewal of our USDA plant
import permit, and I was going over it and going back
through the PERMIT-L archives (to see about the requirement
for phytosanitary permits and such) this morning when Polly
Lehtonen's very useful posting arrived. I've put together
the following guidelines for students, faculty and staff of
our herbarium (TEX/LL = Univ. of Texas at Austin) who will
be collecting plants in Neotropical countries (especially
Mexico) and trying to bring these back with them. The rest
of this posting is just a cut-and-pasted version of those
guidelines and suggestions. It doesn't address all of the
intricacies or possible/probable frustrations, but it gives
people an idea of what to expect. I post it here in case
anyone finds it useful, and also in case anyone suggests
improvements or finds glaring errors. Read no further if
this is of no interest. It is of course tailored to our
specific needs crossing the border by vehicle (as opposed to
flying) is very common in our case. Tom Wendt

(TEX/LL, 4/2002)

Documents that you should have (copies available from the
1. Import Permit for Plants and Plant Products, issued by
2. PPQ Circular Q.37-11 "Dried Plant Material and Certain
Plant Material Regulated by Other Agencies."
3. CITES permit.
4. Federal Noxious Weed List.
5. Copy of "Importing herbarium specimens&quot, a posting
by Polly Lehtonen of APHIS to the PERMIT-L discussion
6. This document.

Acronyms that you should know:
USDA: U. S. Department of Agriculture
APHIS: Animal and Plant Health Inspection Service (a
subunit of USDA)
PPQ: Plant Protection and Quarantine (a subunit of APHIS)
CITES: Convention on International Trade in Endangered
Species of Wild Fauna and Flora

1. It is assumed that the plants are legally collected,
i.e., that you have the necessary collecting permits (if
required) from the country where collected. If you do not,
you are on your own.

2. Herbarium specimens of non-regulated plants [see below],
whether dried or in the process of drying, do not
technically require a USDA import permit (see the attached
PPQ Circular Q37-11), although viable seed on the specimens
may need the permit. HOWEVER, almost no agriculture
inspectors at the border pay any attention to this policy,
and thus they will invariably ask for the USDA
permit--probably this makes them feel more comfortable about
your being a legitimate plant collector.

3. The USDA import permit states that a phytosanitary
permit from the country of origin is necessary for import
this regulation has been on the books for many years, but
much stricter adherence to this began 1/2002. HOWEVER,
herbarium specimens do not require the phytosanitary permit,
since, technically, you don't need the import permit for
herbarium specimens in the first place, as noted above. This
point is emphasized by Polly Lehtonen of APHIS in her
posting to the PERMIT-L discussion list (5/23/2002) =
document 5 listed above. However, inspection agents at the
border may not see it this way (see point 2) and thus you
may need to discuss it with them.

4.  Things will generally go more smoothly if you have a
list of all the taxa being imported. This is obviously far
more difficult if you are doing general collecting than if
you are just collecting a single genus or family. However,
field notes with field determinations can be very useful in
this regard. Generally, the concern of the inspectors is to
be sure that you do NOT have certain prohibited plants (see
below), and the field IDs can be helpful in determining

5. There are long and in some cases complicated lists of
plant taxa that cannot be imported or certain parts of which
cannot be imported. These can be generally divided into: a)
taxa prohibited because of agricultural pests and diseases
they might carry b) federally listed noxious weed species
and c) rare or endangered plants protected under CITES.
Below is a BRIEF AND INCOMPLETE summary of the taxa of
greatest concern for TEX/LL botanists working in the

A. Taxa of agricultural concern. A complete list of
prohibited taxa is available from the Curator (from "Part
319.37" mentioned on the USDA import permit.) In most cases,
herbarium specimens and seeds of these may be imported, but
nursery stock, cuttings, etc. cannot. However, in some cases
no seeds, or no material of any sort, may be imported. The
taxa of greatest relevance to plant collectors in Mexico and
northern Latin America are listed below if you're going
elsewhere, consult the above-mentioned list. Some of the
taxa listed below may be imported, but only with special

For the following, NO MATERIAL (no herbarium specimens nor
anything else) can be imported:
Rutaceae--essentially all general
Seeds in all kinds of pulp.

For the following, herbarium specimens WITHOUT VIABLE SEEDS
can be imported, but no seeds, cuttings, nursery stock, etc.
can be imported:
Poaceae: Leptochloa, Leersia, Zizania
Solanum--all tuber-bearing species

For the following, herbarium specimens and seeds can be
imported, but no cuttings, nursery stock, etc.:
Abies spp.
Fragaria spp.
Gossypium spp.
Ipomoea spp.
Malus spp.
Manihot spp.
Palms: Phoenix spp., Cocos nucifera (including fruit unless
without husk & milk),
Gaussia spp., an a number of other palm
genera that may be cultivated in the area.
Theobroma spp.
Vitis spp.

Parasitic plants need special permits.

B. Federally listed noxious weeds. See the attached list.
You should avoid importing any of these in any form
(including herbarium specimens, especially with seed)
without a special permit.

C. Rare and endangered taxa. There is a rather detailed
list of taxa that are controlled by CITES. Our CITES permit
technically only for the non-commercial shipment of
specimens between herbaria that are registered with the
CITES secretariat, so it is not really for use in bringing
back field-collected material. Thus, you should either avoid
collecting listed species, or take care of all required
permitting ahead of time. Having a copy of our CITES permit
with you at the border can at times be helpful however, most
USDA inspectors are far more interested in "A" (above) and
"C" (below), so don't take out the CITES permit unless it is

The CITES appendices of "listed species" include most tree
ferns, cacti, and orchids, some Fouquieria species, and many
other specific Neotropical taxa. Different regulations apply
depending on whether a given taxon is listed in Appendix I
(more restricted) or Appendix II. The complete information
is available from the Curator.

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