CITES Secretariat
CITES Chairman
Past, Present and Future Plants Committee Participants from the United States (USDA, FWS, & EPA) and United Kingdom (Royal Botanical Gardens, Kew)

January 10, 2002

Dear Sirs,

In anticipation of the 12th Meeting of the CITES Plants Committee I am writing to express my concerns and views with regards to the "Illegal Trade in Paphiopedilum spp.", as discussed at the 11th Meeting of the Plants Committee (PC11 Doc. 24.4). I greatly appreciate your time and consideration of this letter.

I strongly encourage the Plants Committee to review and act on this matter in high priority. Rapid action will result in a rapid decrease in trade of illegal Paphiopedilums. Furthermore, I submit the following plans and ask the Plants Committee to consider these ideas with regards to the five (5) recommendations set forth in PC11 Doc. 24.4 which were accepted at the 11th Meeting:

In summary:

Recommendation #1 - The exemptions of Article VII, paragraph 4 and provisions of Resolution Conf. 11.11 must not be repealed. The elimination of these provisions nullifies all other recommendations set forth in PC11 Doc. 24.4, and helps to ensure the demise of both captive and wild Paphiopedilum populations.

Recommendation #2 - If the provisions set forth for range country grower guidelines, then CITES and governmental organizations should ENCOURAGE the continued and expanded legal production of these species. This may serve to eliminate the demand for black market (illegally traded) Paphiopedilum specimens.

Recommendation #3 - This plan to authorize and train legal Paphiopedilum nurseries for the production of newly discovered species in range countries must become reality. The benefits for both species preservation and economic growth of range countries are tremendous. Again, the development of a legitimate world market for Paphiopedilums helps to reduce the demand for illegally traded plants.

Recommendation #4 - While my understanding of the fourth recommendation is vague, I believe it implies two basic ideas. First, to better control the trade of illegal Paphiopedilum simply by enforcing the rules for CITES registration of nurseries which are already in effect. Secondly, and more importantly, to turn to these nurseries as an additional option for the development of new species when range countries do not have the facilities or desire to participate in the plans set forth in Recommendation #2 & #3. Both of these recommendations should be fully implemented in order to guarantee diverse options when considering species production and arking in captivity.

Recommendation #5 - The clear and public dissemination of a list of all clearly illegal Paphiopedilum species MUST be accomplished. Through my research it has come to my attention that even commonly available species such as Paphiopedilum henryanum and P. lynniae could actually be plants of illegal origin, and thus every specimen in widespread captive populations would be deemed an "illegal" plant. A readily available and highly publicized list would be of great benefit to all parties involved, as it would eliminate any and all doubt as to which Paphiopedilum species are NOT legally available. I strongly believe that the vast majority of Paphiopedilum growers would gladly comply with CITES regulations and avoid illegal species if they only KNEW which species were illegal.

In addition to the 5 (five) recommendations set forth in PC11 Doc. 24.4, I also support the following:

Additional Recommendation #1 - I was also very intrigued by the concept of developing genetic identification methods for non-blooming Paphiopedilum specimens as mentioned in PC11 Doc. 24.4. These tests would provide valuable enforcement tools to the agencies in charge of inspecting and controlling trade in CITES fauna and flora; specifically in the identification of species "blacklisted" by the recommendations of #5. Additionally, if such tests could be developed which were economical enough for the average individual and or commercial grower to utilize, we would all benefit from this testing. I encourage the CITES Plants Committee to consider researching this idea and (if feasible) implementing this plan as well.

Additional Recommendation #2 - Once commercial growing facilities have been established for the culture of new Paphiopedilum species, a period of amnesty (a.k.a. "grace period") should be allowed for individuals in possession of illegal recently-identified Paphiopedilum species to voluntarily relinquish these plants without legal action to the possession of registered CITES growers for the sole purpose of captive propagation and commercial distribution of these species. This concept is not unlike the successful efforts by US law enforcement to collect illegal and excess legal firearms.

If you are further interested in a full discussion of the current status of Paphiopedilum and CITES, please visit

Best Regards,

Matt Pedersen - Orchidist -