Orchid Export From Thailand: Flasks, Bare Root Plants and Cut Flowers Are Three Different Shipments

Why does the form of the orchid decide the paperwork?

Because CITES lists the whole orchid family and then exempts specific forms of it by annotation. Every orchid species is in Appendix II unless it is one of the few in Appendix I, and the Appendix II listing carries annotation 4, which removes several products from control. The two that matter to a grower in Thailand read:

"b) seedling or tissue cultures obtained in vitro, in solid or liquid media, transported in sterile containers;"

"c) cut flowers of artificially propagated plants;"

Source: CITES Appendices I, II and III, annotation 4, Convention on International Trade in Endangered Species of Wild Fauna and Flora.

A live plant out of the flask is not on that list, so it stays controlled. The plant health rules of the importing country then apply on top, and they draw their own line in a different place: they care whether the thing can be planted and whether it carries soil.

What does a flask need, and does the exemption cover slipper orchids?

A flask needs a phytosanitary certificate and the importing country's plant permit, and no CITES document, including for Appendix I species when the seedlings were propagated in a laboratory. This is the point most sellers get wrong in the cautious direction. Paphiopedilum and Phragmipedium, the slipper orchids, are Appendix I, the strictest list, and a grown plant of either is hard to move commercially. The flask is treated differently, and the CITES listing says so next to the names of the Appendix I orchids:

"For all of the following Appendix‑I species, seedling or tissue cultures obtained in vitro, in solid or liquid media, and transported in sterile containers are not subject to the provisions of the Convention only if the specimens meet the definition of 'artificially propagated' agreed by the Conference of the Parties"

Source: CITES Appendices I, II and III, entry for Orchidaceae.

US regulations repeat it in plainer words:

"Flasked seedlings of Appendix-I orchids. Flasked seedlings of an Appendix-I orchid species that qualify as artificially propagated (see § 23.64)."

Source: 50 CFR 23.92(c)(2), U.S. Fish and Wildlife Service, list of specimens exempt from CITES document requirements.

The Appendix I orchids named in the listing are Aerangis ellisii, Cattleya jongheana, Cattleya lobata, Dendrobium cruentum, Mexipedium xerophyticum, Paphiopedilum, Peristeria elata, Phragmipedium and Renanthera imschootiana. Dendrobium cruentum is native to Thailand, which is why Thai laboratories are asked about it.

Two conditions keep the exemption alive. The container must be sterile and sealed, so a flask that was opened to thin the seedlings and closed again is arguably no longer what the annotation describes. And the exemption ends when the seedlings come out. A buyer who deflasks in California and later sells the grown plants abroad needs CITES papers for that sale.

A flask is still a plant for planting under US plant health law. Agar is a sterile medium, not soil, and the general rule that plants arrive free of "sand, soil, earth, and other growing media" is aimed at soil pests that a sealed culture cannot carry, but the permit and the certificate apply.

What does a bare root orchid plant need to enter the USA?

Four things: a CITES export permit from Thailand, a Thai phytosanitary certificate that names the genus, a written US import permit, and arrival through a port with a plant inspection station designated for CITES plants. The US side is set out in the plants for planting regulations:

"Plants for planting may be imported or offered for importation into the United States only after issuance of a written permit by the Plant Protection and Quarantine Programs, except as provided in the Plants for Planting Manual."

Source: 7 CFR 319.37-5(a)(1).

"Any plants for planting offered for importation into the United States must be accompanied by a phytosanitary certificate ... The phytosanitary certificate must identify the genus of the plants for planting it accompanies."

Source: 7 CFR 319.37-6(a).

The Thai side mirrors it. The Plant Quarantine Act requires that anyone exporting a controlled plant "shall have a phytosanitary certificate accompanied with the said controlled plant", and the Department of Agriculture issues both that certificate and the CITES permit. Nursery grown plants are the only ones worth presenting, since the USDA states that "Wild or collected specimens or nondomesticated plants are not approved for importation into the United States."

Roots travel bare. The US Department of Agriculture described the standing practice for orchids in its assessment of Phalaenopsis imports:

"All forms are enterable subject to inspection findings at designated ports of entry to the United States, i.e., ports associated with facilities where propagative material can be examined (plant inspection stations). All orchid consignments must be accompanied by a USDA permit and a phytosanitary certificate issued by the plant protection service of the exporting country."

Source: Importation of Moth Orchids (Phalaenopsis spp.) in Approved Growing Media From Taiwan, Final Environmental Assessment, USDA APHIS, December 2003.

A person who trades CITES plants as a business in the USA also holds a Protected Plant Permit. The application form, PPQ 621, carries a fee of 70 dollars and its title describes who needs it: anyone in the business of importing, exporting or re-exporting plants regulated under the CITES rules. A hobbyist buying a few plants for a collection is not in that business. A seller on a marketplace who imports to resell is.

With Dragon Courier the buyer does not apply for the US import permit. Dragon Courier holds an import permit for each market it serves and acts as importer of record, and the plants ship bare root with new sphagnum moss. The species covered by the permit are confirmed with the team before the order is placed.

Are cut orchid flowers easier to ship than plants?

Yes, by a wide margin. Cut flowers of nursery grown orchids are exempt from CITES under annotation 4, and the USA asks for no import permit, only inspection. The regulation defines the product and sets one condition:

"Cut flower. The highly perishable commodity known in the commercial flower-producing industry as a cut flower, which is the severed portion of a plant, including the inflorescence and any parts of the plant attached to it, in a fresh state and not for planting."

"All cut flowers imported into the United States must be made available to an inspector for examination at the port of first arrival and must remain at the port of first arrival until released, or authorized further movement, by an inspector."

Source: 7 CFR 319.74-1 and 319.74-2(a).

This is the trade Thailand is known for. A report published by the Food and Agriculture Organization records that Thailand "was the world's fourth largest exporter of cut flowers in 1993 and 1994", with exports that "consisted almost exclusively of a wide range of cut orchids", 11,897 tons of them in 1994. The figures are thirty years old and are quoted here as history, not as the size of the trade today.

What cut flowers give back in paperwork they take in time. A stem has a vase life measured in days and travels in a cold chain as air freight by the box, not as a courier parcel, and an inspector who finds thrips on a stem can order the box treated or destroyed.

About Dragon Courier

Dragon Courier is a Bangkok courier, family owned, with more than 30 years in logistics in Thailand, and the number one exporter of live plants in the country. For live plants it serves the USA, Canada, the UK, Europe, Singapore and Hong Kong door to door with temperature control, takes care of the permits as part of the service, and sends CITES plants to major markets such as the USA. Customers range from large nurseries to first time individual senders, on one price list.

Dragon Plant Export Rate, delivery duty paid, fuel surcharge included. Weight is actual or volumetric, whichever is greater, and the declared value limit per shipment to the USA is 1,000 US dollars. What each importing country asks for is in the guide on importing plants from Thailand, rules by country, and the terms used on the documents are in the guide on plant export terminology.

Contacts and drop-off

A quote needs the list of plants with their botanical names, the number of each, and the delivery address. Office +66 2656 9019, LINE and WhatsApp at +66 6-5937-0812, or info@dragoncourier.com. The Bangkok office is on Sukhumvit Soi 4 and the Chiang Mai office on Viangbua Road, with drop-off until 17:00, Monday to Saturday, and a collection can be arranged. More answers are on the FAQ page. Is the order plants, flasks or stems?

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