CITES Scientific Authority The Netherlands

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1 CC17/516 CITES Scientific Authority The Netherlands Reference: Imports of Galanthus woronowii bulbs exported by Georgia with source code A have been a topic of discussion for many years. The bulbs are not only harvested from the wild as source W within quota, but apparently also as source A from agricultural plots/ cultivation fields. This A (Artificial Propagation) material does not meet the CITES definition of artificial propagation as outlined in CITES Resolution Conf (Rev. CoP15). Georgia s wild G. woronowii populations appear to be widespread and still relatively abundant after at least a decade of exports of million wild-harvested plants per year. A document Assessing non-detrimental trade for a CITES Appendix II-listed plant species: The status of wild and cultivated Galanthus woronowii in Georgia available from: [accessed Sep 8, 2017]. At CoP17, a working group was established that will work on CITES Resolution Conf It seems obvious that AP of Galanthus will be considered as a test case. Meanwhile, Georgia would like to continue exporting both A and W bulbs. For W, the SRG has decided a positive opinion within the set quota (15 million) in This was confirmed at SRG78 ( ). For A, however, the SRG sent a letter to Georgia in December 2016 (following SRG77, see below) which outlines a way forward in the discussion and explores possibilities to make the export of AP bulbs (source A) possible in the near future, while the PC working group is working on definitive solutions. Georgia, in their answer to this letter, indicated that such export was not foreseen for Nevertheless, later in 2017, Georgia has sent a number of messages to the EC/SRG and The Netherlands (as main importer) in which Georgia announces the export of A bulbs to the EU. Proposition The Netherlands CITES SA proposes to discuss the matter and analyze the information sent by Georgia to decide to which extent these responses answer the questions in the SRG letter of December Background information see: 1

2 PC21/ Doc. 17 Twenty-first meeting of the Plants Committee Veracruz (Mexico), 2-8 May 2014 (this document has been prepared by the CITES Management and Scientific Authorities of Georgia) Agenda documents of SRG78: [SRG a) Galanthus woronowii GE[ and [SRG b) Galanthus woronowii GE] 2

3 Consultation: SRG 77 (november 7th, 2016) The EC sent a letter to Georgia on 6th December 2016 in which the European position toward Artificial propagated bulbs is explained (see letter below) The criteria mentioned are: 1. The SRG suggested in particular that imports of Galanthus woronowii bulbs exported by Georgia with source code A could be accepted under the condition that the bulbs are propagated on plots that have been approved and registered by the Georgian authorities for a certain duration, for example for at least 5 years. 2. The SRG suggested also that bulbs harvested from plots approved and registered by the Georgian authorities for a shorter period of time (e.g. for less than 5 years) could be considered as wild sourced, though it could be specified on export permits that such bulbs come from cultivated areas approved and registered for less than 5 years. 3. The SRG indicated also that it would welcome an update about the bulb production system in Georgia. EUROPEAN COMMISSION DIRECTORATE-GENERAL ENVIRONMENT Directorate E Global and Regional Challenges, LIFE ENV.F.3 Multilateral Environmental Cooperation Brussels, Ares(2016) - Ministry of Environment and Natural Resources Protection of Georgia 6 Gulua street, 0114, Tbilisi GEORGIA biodepbio@moe.gov.ge, k.amirgulashvili@moe.gov.ge, teonakarchava@yahoo.com, t.karchava@moe.gov.ge, Subject: Trade and conservation measures for snowdrops (Galanthus spp.) Dear Sir or Madam, 3

4 I am writing to you in connection with the legislation designed to implement the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) in the European Union (EU). In accordance with this legislation, the CITES Scientific Authorities of the EU Member States, before authorising the import of CITES-listed products, must be sure that current or expected levels of trade in species to be imported into the EU will not have a harmful effect on the conservation status of the species. At its last meeting on 7 November 2016, the Scientific Review Group (SRG), where all EU Scientific Authorities come together, assessed the issue of imports into the EU of the species Galanthus woronovii from Georgia. The SRG highlighted the very good cooperation between Georgia and the EU in relation to the CITES Convention, and in particular in relation to trade in snowdrop bulbs. The SRG appreciated in particular the efforts made by Georgia to ensure the sustainability of trade in Galanthus woronovii and the detailed information shared by Georgia on this matter over the last years. At the same time, the SRG reviewed the status of imports of bulbs of the species exported from Georgia to the EU with the source code A, and raised questions as to the compliance of such bulbs with the CITES criteria for artificially propagated plants. The SRG recognized once again that applying the CITES definition of "artificial propagation" to bulbs was challenging, and welcomed the establishment of a working group at the 17 th session of the CITES Conference of the Parties to review the definition of "artificial propagation" for plants, based on a proposal from Georgia and other Parties. The SRG concluded that, pending the outcome of this CITES working group, an interim approach may need to be further developed to treat the specific case of Galanthus woronowii bulbs exported to the EU with source code A. The SRG suggested in particular that imports of Galanthus woronowii bulbs exported by Georgia with source code A could be accepted under the condition that the bulbs are propagated on plots that have been approved and registered by the Georgian authorities for a certain duration, for example for at least 5 years. The SRG suggested also that bulbs harvested from plots approved and registered by the Georgian authorities for a shorter period of time (e.g. for less than 5 years) could be considered as wild sourced, though it could be specified on export permits that such bulbs come from cultivated areas approved and registered for less than 5 years. We would welcome your views about the approach suggested by the SRG. The SRG indicated also that it would welcome an update about the bulb production system in Georgia. We would therefore be very grateful if Georgia could provide us with further information concerning: - The methods, locations and processes relating to the harvest of wild bulbs on the one hand, and the plant nurseries and harvest of artificially propagated bulbs on the other hand, outlining how the bulbs from these two sources can be distinguished in the CITES export and import process; - The annual quota for wild bulbs and the number of artificially propagated bulbs to be exported in 2017 and, if possible, a prognosis for the development in these quotas for the following years; - Whether all bulbs exported to the EU under source code A are propagated on plots approved and registered by the Georgian authorities for a certain period [e.g. for more than 5 years], and whether bulbs from plots approved and registered by the Georgian authorities for a shorter period will be considered as Wild sourced; - Whether Georgia has updated the 2009 Wild stock survey to reconfirm that trade in wild stocks continues to be sustainable, and possibly to consider adjusting the quota based on the field assessment of wild stocks; - Whether a monitoring plan of sites where artificially propagated bulbs are produced has been developed, allowing, inter alia, for annual inspections of each site. We would welcome receiving a reply from the Georgian authorities by 7 January 2017, so that it can be considered by the EU authorities at their next meeting. 4

5 In accordance with our provisions regarding the publication of documents submitted to the SRG, we would like to draw your attention to the fact that your reply will be made public unless you indicate to the contrary. We thank you in advance for your cooperation and look forward to hearing from you. Yours sincerely, Emmanuelle Maire Head of Unit c.c.: EU Delegation in Georgia EEAS.III.B.2 Responses Georgia (2017) 10 januari 2017: Letter from: Head of the Biodiversity and Forest Policy Department, Carl Amirgulashvili, First Deputy Minister, MINISTRY OF ENVIRONMENT AND NATURAL RESOURCES PROTECTION OF GEORGIA. Artificial Propagation of Bulbs, Registration Process and Exports for 2017: I would like to highlight the importance of Decisions adopted at COP17 and the forthcoming CITES Plants Committee review of the definition of Artificial Propagation for plants. We hope that the Plants Committee review will result in a positive and practical outcome and note that at CoP the EU and its member States emphasized the difficulties in implementation raised by problems in interpreting the definition (Summary Report of the Tenth Session of Committee II,CoP17, paragraph 43). It is for this reason that according to Georgian legislation, registration is required for plots of artificial propagation subject to strict criteria including size and ownership of plots, original source of stock, date of first planting and management procedures. The plots are registered for a maximum 3 year period. Since the registration period of the first tranche of approved plots has expired, renewed registration is now required. Each plot is scientifically assessed during the registration process and this includes, inter alia, an assessment of the number of commercial sized bulbs at each site and potential maximum harvest of AP bulbs. Exporters are allowed to apply for a permit for total commercial size stock at one harvest or divide it for the period of site registration i.e. over 3 years. In the case of issuing permit for total stock, no permits are issued for following years. Formally no export quota is set for AP bulbs. As all registrations are now expired we await to see what applications we receive for reregistration or new registrations in the coming period. For this reason, we currently have no information on potential exports of artificially propagated bulbs from registered sites in

6 I hope this information meets your requirements. To assist in your considerations please find attached document (Annex 1) a short summary document on work carried out to date. Experts from that Annex 1: Artificial Propagation 2017 According to Georgian legislation, registration is required for plots of artificial propagation subject to strict criteria including size and ownership of plots, original source of stock, date of first planting and management procedures. The plots are registered for maximum 3 - year period. Since the registration period of the first tranche of approved plots has expired, renewed registration is now required. Each plot is scientifically assessed during the registration process and this includes, inter alia, an assessment of the number of commercial sized bulbs at each site and potential maximum harvest of AP bulbs. Exporters are allowed to apply for a permit for total commercial size stock at one harvest or divide it for the period of site registration i.e. over 3 years. In the case of issuing permit for total stock, no permits are issued for following years. Formally no export quota is set for AP bulbs. As all registrations are now expired we await to see what applications we receive for re-registration or new registrations in the coming period. For this reason, we currently have no information on potential exports of artificially propagated bulbs from registered sites in Future Plans The initial Significant Trade survey was carried out in 2008/2009 and the 10 - year harvest license programme for wild exports expires in Georgia would like to carry out a review of the programme and overall CITES trade and establish a 10 year plan for sustainable use of its resources within the CITES framework to implement post the 2018 season. Such a programme would enhance synergies with other Conventions and agreements and look towards greater co-operation within the region. However, no funding source has yet been identified for this process. 9 june 2017: Letter from: Head of the Biodiversity and Forest Policy Department, Carl Amirgulashvili, First Deputy Minister, Solomon Pavliashvili, MINISTRY OF ENVIRONMENT AND NATURAL RESOURCES PROTECTION OF GEORGIA. With this letter we would like to inform you that in April 21, 2017, the Ministry of Environment and Natural Resources Protection of Georgia issued 3 Permits for export of artificially propagated Galanthis woronowii bulbs (total amount of bulbs) cultivated at the private plots (SA NL: here, Georgia announces the export of A bulbs from Georgia to The Netherlands): Besides that, in May, 29, 2017, the Ministry of Environment and Natural Resources Protection of Georgia issued one permit for export of the artificially propagated Galanthis woronowii bulbs (total amount of ) cultivated at the private plots for export to the Netherlands. 14 july 2017: Letter from: Head of the Biodiversity and Forest Policy Department, Carl Amirgulashvili, First Deputy Minister, MINISTRY OF ENVIRONMENT AND NATURAL RESOURCES PROTECTION OF GEORGIA. In addition to our letter N5103 of June 9, 2017, concerning the Permits on Export, issued for export of snowdrop (Gallantus woronowii) bulbs artificially propagated at private plots, 6

7 we are sending some photo material reflecting the harvest of artificially propagated snowdrop bulbs. 16 august 2017: Letter from: First Deputy Minister, Solomon Pavliashvili, MINISTRY OF ENVIRONMENT AND NATURAL RESOURCES PROTECTION OF GEORGIA I would also like to address our latest communication through the EU SRG. As you may remember, in January 2017, the Ministry of Environment and Natural Resources Protection of Georgia, which is the CITES MA in Georgia, has submitted information to be reviewed at the 77th meeting of the SRG. The report clearly stated: As all registrations are now expired we await to see what applications we receive for re-registration or new registrations in the coming period. For this reason, we currently have no information on potential exports of artificially propagated bulbs from registered sites in Since then, based on the applications received by the Ministry, the sites of the artificial propagation were registered and export permits were issued. All registered plots comply with the requirements of registration defined by the national legislation including annual monitoring requirement. It should be mentioned that registration of the plots is not permanent, the plots may be registered for up to 3 years. After the registration is expired, registration is renewed based on applications received and new surveys. Though, according to the legislation, it is required that propagation of snowdrops should take place for more than five years. Details of the registration system were described in the previously submitted reports. Finally, the export permits were issued having in mind that no negative decision made by the SRG has been communicated to us. Based on the letter provided by the exporter, we assume that negative decision was made at the SRG meeting on 21st June However, so far, the decision and its reasons have not been communicated to Georgian side. Information regarding the issued permits, including the photographs of the registered sites, was communicated through the letters # and # (see appendix : 516 Galanthus woronowii A Georgia Pictures A and B) 7

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