FALSE entries CITES (Convention International Trade in Endangered Species)

The Convention on International Trade in Endangered Species of Wild Fauna and Flora

* I have for many years deliberated about drawing attention to the short-comings of aspects of CITES in relation to Himalayan flora included in Appendices I & II. I am supportive of what the convention was trying to achieve, however, it is essential that GENUINELY 'Rare and Endangered' species are the ones targeted. With the best will in the world, resources to implement the terms of such conventions are going to be limited. It makes a mockery if the wrong species are included in the Appendices.

A better understanding of what is involved in reliably identifying plants and assessing rarity is required and then the mammoth task of promoting, in these days of high-tech, laboratory science, the need for and value of, old-fashioned field-skills and herbarium botany.

We are NOT setting a good example in Europe or North America. Field and herbarium botanists are dying breed.... Success conserving plant species in the Himalaya requires greater collaboration between Indian botanists and scientists in the West plus other signatory countries to the convention. It is NOT from a position of virtue, much as I am fortunate and grateful to be a British citizen, living in Britain, that I as a Britisher (as we are still, mostly affectionately known in India) take it upon MYSELF to draw attention to what should be happening in other countries, particularly former 'colonies'.

Just in case those reading this wonder if I am alone in expressing concerns about reliable identification of Himalayan plants, see the section of this web-site on the 'Flora of Ladakh', particularly the link to the field-work and articles published by the late Leo Klimes - an outstanding botanist from the Czech republic who sadly went missing in Ladakh or possibly Kashmir: https://sites.google.com/a/shpa.org.uk/main/flora-of-ladakh

CITES is a multilateral treaty to protect endangered plants and animals. It was drafted as a result of a resolution adopted in 1963 at a meeting of members of the International Union for Conservation of Nature (IUCN). The convention was opened for signature in 1973, and CITES entered into force on 1 July 1975. Its aim is to ensure that international trade in specimens of wild animals and plants does not threaten the survival of the species in the wild, and it accords varying degrees of protection to more than 35,000 species of animals and plants...

Appendix I, covers about 1200 species that are threatened with extinction and are or may be affected by trade. Commercial trade in wild-caught specimens of these species is illegal (permitted only in exceptional licensed circumstances). THE MAIN FOCUS IS ON ANIMALS.

Appendix II, about 21,000 species, are species that are not necessarily threatened with extinction, but may become so unless trade in specimens of such species is subject to strict regulation in order to avoid utilization incompatible with the survival of the species in the wild.

Appendix III, about 170 species, are species that are listed after one member country has asked other CITES Parties for assistance in controlling trade in a species. The species are not necessarily threatened with extinction globally. In all member countries, trade in these species is only permitted with an appropriate export permit and a certificate of origin from the state of the member country who has listed the species. "

FOR FURTHER DETAILS SEE: http://www.cites.org/



Appendix I


Upon my first look through the details of CITES I missed that this species was included in Appendix I - in part this may have been that I, rightly, assumed that no species from the Western Himalaya could have been claimed to have been in eminent danger of becoming extinct - after all, I knew that the flora of the region remains inadequately studied to make such a precise assessment. Yes, the flora of the UK is sufficiently well-known to judge correctly the status of individual species - this situation does not exist in a majority of the countries of the world. To imagine, with limited resources and very few professional or amateur botanists (we have many of the latter in the UK of professional standard) to undertake extensive surveys of the vast areas, such as the Western Himalaya with high and steep terrain could possibly be adequately know plant-wise, is beyond my comprehension.

As to the FALSE claims that S.costus is 'critically endangered'? Just on what basis has this been decided? Where is the evidence? Few Indian botanists spend much time surveying for plants. Very few have the field skills to reliably identify plants during these infrequent trips to the mountains. One cannot assess how abundant or rare any plant species is from an office! I have travelled more extensively in the Himalaya particularly the Western districts and borderlands of Western Tibet than anyone. I have studied and researched the flora of this region in greater depth than anyone else. I am able to recognise the common and readily distinguished species during my visits. This, combined with research of species recorded by other botanists (which can be relied upon) enables me to judge which are common and occur in large quantity. So when I come across claims that such species are 'rare and endangered', I can refute such FALSE claims. I cannot say which species are genuinely rare and endangered in the Western Himalaya but nobody can - its flora has not been studied sufficiently. Many genera are urgently in need of revision taxonomically.

I have known S.costus since the mid-1980s when I led two botanical tours to Lahoul, Himachal Pradesh, where this plant has been cultivated for at least a century. In 2012, I found this species being widely grown, in large quantity (though not as much as Inula racemosa - another species which is not rare or endangered but is claimed to be). I keep coming across records of Saussurea costus in articles about surveys in different valleys/districts of the Western Himalaya - how can this be the case if it really is 'critically endangered' i.e. about to become extinct?

Saussurea costus in cultivation


A tall robust perennial with large trainagular long-stalked basal leaves and large clasping upper leaves. Dense rounded terminal cluster of a few purple flower-heads.

Garden worthiness: whilst not unattractive flower-heads (when examined close-up), very few gardeners would bother growing it - it bears little resemblance to the dwarf high-alpine Saussureas, sometimes known as "snow-ball plants", which appeal to alpine gardeners, though are virtually impossible to grow for most.

Status: 'Flowers of the Himalaya' observed that it was cultivated as a field-crop also found as a casual in irrigated areas. Stewart knew it from forest undergrowth in Kashmir also in Hazara and Zanskar. I know of it from Ladakh, Kishtwar, Kinnaur and in Lahoul in abundance. Its occurrence in Kashmir is insufficiently well-known, being poorly surveyed for. Given how readily it is grown as a field crop, practically as an agricultural crop, to rate it more than uncommon is questionable. Completely unjustified to be under Appendix I. Its status is not sufficiently known to justify inclusion under Appendix II either!

Appendix II



A large climber with twining stem. Leaves ovate-long-pointed, stalked, base cordate with rounded lobes. Fruit a broad 3-winged capsule. Seeds winged. The thick fleshy tuberous rootstock is not edible but was (mostly in the past) used for washing clothes. I have noted it growing abundantly in a number of places, close to habitation in the Kulu Valley. Dr Ralph Stewart recorded it as common throughout Northern Pakistan and Kashmir from 600-2700m. I am confident it remains common in suitable habitats. Polunin & Stainton gave its distribution as from Afghanistan to SW China. Even when the rootstock was collected, this species flourished. Once it was discovered that the tubers contain diosgenin - which can be converted chemically into the hormone progesterone, considerable additional interest has been aroused. However, I dispute the claim that it is either 'Rare' or 'Endangered', let alone 'Critically Endangered' as one article has claimed, supposedly due to an 80% reduction in population but even if this were true, it can only have applied to a very small sample area. It is grossly misleading to suggest otherwise. This has led others to emphasise the FALSE 'Endangered'/ 'Under Threat' aspects in subsequent articles....

According to Mohammad Amin Siddiqi in DIOSCOREACEAE (Flora of West Pakistan, 1973), "The tubers contain saponin, acrid resin, diosgenin, starch and calcium oxalate. They are used for washing shawls and woollen cloth as well as a vermifuge and an anthelmintic for purginmg out intestinal worms. Diosgenin is said to be a basic material for hormone production". He gave its distribution as Afghanistan, W.Pakistan and throughout the Himalaya; very common from 1000-3000m in Kashmir and Swat

Garden worthiness: of minimal merit, likely to be grown as a curiosity - most gardeners would consider someone crazy to bother to grow it!

Status: widespread, probably common! Strange it never attracted much attention when, fro decades, if not centuries, its only use was as a soap.......And what of the related DIOSCOREA BELOPHYLLA, which Stewart noted WAS RARE in Pakistan, at the Western end of its range back in the 1970s? Since it was found at lower elevations, habitat destruction is almost certainly have taken place in the intervening period... Perhaps this species NOT DIOSCOREA DELTOIDEA should be listed under CITIES? But the truth is nobody actually knows if it is still rare in the region (or elsewhere)?


This warning label was attached the sheets with specimens of DIOSCOREA DELTOIDEA in a US herbarium

Label of herbarium specimen of DIOSCOREA DELTOIDEA collected by Walter Koelz in 1933


I have never come across this, reputedly highly attractive alpine, in the wild, though its roots were at the Institute of Traditional Medicine in Thimphu, when I was a consultant to the 'Royal Government of Bhutan' on the 'Cultivation of Medicinal Plants for Traditional Medicine Project' in the 1990s. Found from Uttar Pradesh to SW China, on rocks, ledges and open slopes up to 4800m, it does not occur in the North-Western Himalaya or borderlands of Tibet, where a majority of my exploration has taken place, so not finding this is no surprise - though Polunin & Stainton said it was not common. A favourite perfume of ancients, the root is a substitute for valerian and used in many medicinal treatments, whilst the oil obtained from the root is used as a hair tonic and for many other preparations. I cannot assess its status, nor can anyone else, other than within limited, accessible areas. I doubt if the scientist who proposed this as being 'Rare and Endangered' had NOT been to many rock ledges at 4000m+ to check.

Although this plant seems to be quite distinctive, including possessing a lingering odour, misidentifications of species gathered for medicine is common-place, along with deliberate adulteration... As most doctors of traditional medicine (known as amchis in Ladakh) learnt to recognise the individual plants after instruction from their father's, often in an isolated valleys, there has always been much potential for misidentification. 'Plant Identification Seminars' run by Amchi Tsewang Smanla in Ladakh, proved that inconsistencies of naming was widespread. The situation is complicated further by sometimes more than one 'species' (according to Western methods of identification), genus or even family, collected as the same Tibetan plant.... I have no doubt that many of those who gather medicinal herbs make mistakes as to what they gather - in addition to not collecting in a responsible or sustainable way by decimating colonies.

Whilst in Bhutan I noted that 36kg of 'Jatamansi' (NARDOSTACHYS JATAMANSII) was collected officially each year for use at the National Institute of Traditional Medicine in Thimphu with a record of 68kg confiscated off a truck leaving Langtang National Park in Nepal. R.A. Clement in 'FLORA OF BHUTAN' gives NARDOSTACHYS GRANDIFLORA as a synonym, whereas Prakash has treated the latter as a distinct separate species, recorded as 'Rare' in Sikkim. Clement could NOT distinguish it in material examined from Bhutan. I thus suggest that counting N.GRANDIFLORA as a separate, 'Rare' and thus 'Endangered' species, is highly questionable.....


I am familiar with this from rocky slopes in Kashmir and Himachal Pradesh, where it is still likely to be common. Prior to my arrival in Bhutan on the project mentioned above, I was sent a partial list of species utilised in Bhutanese Medicine, which included PICRORHIZA KURROOA. I immediately knew this was a misidentification, as this species only extends as far East along the Himalaya as Uttar Pradesh (now Uttarakund). It was obviously the similar PICRORHIZA SCROPHULARIAFLORA, found from U.P. through to SW China. According to Appendix II, the latter species is not considered 'Rare or Endangered'. How could they tell? They couldn't, nor did the botanist who identified the specimens from Bhutan, distinguish between the two species - who probably worked for the same Institution which submitted PICRORHIZA KURROOA as 'Rare and Endangered'. Its flowers are pale or purplish blue. The stamens are very much longer. Leaves almost all basal, spathulate to narrow elliptic, coarsely saw-toothed. Stewart found this to be common on alpine meadows in Kashmir, as did I in the 1980s. Unrest in Kashmir for over 20 years meant it was unsafe for me to visit until 2012 and many of those meadows remain "out-of-bounds" due to concerns about militants crossing over the nearby border with Pakistan. Nevertheless, I saw enough to tell that healthy populations of this species still occur in Kashmir - and in all probability healthy populations in Himachal Pradesh. The amount of grazing in the border areas having been reduced significantly. If any individuals come searching to dig it up, they may well be arrested or shot. Endangered? Not at all.... The roots are an old Indian remedy for fever and colds. Koelz found in the 1930s that many people, usually Tibetans and Rampuris were making a business of collecting the herb for sale wherever it grew in the high mountains and their encampments were often found amongst the peaks in the summer.

Whilst working as a consultant to the Royal Government of Bhutan in 1994, I noted that 150kg of 'Hong-len' (the roots of PICRORHIZA SCROPHULARIIFOLIA) were officially collected for use in the National Institute of Traditional Medicine in Thimphu and had a record of 70kg being confiscated from a truck heading out of Langtang National Park, Nepal.


I have been aware that this was a CITES plant for many years, so have made a special effort to "keep an eye out" for it and once again, dispute the claim it is either 'Rare' or 'Endangered' along the Himalaya. This distinctive herbaceous perennial has an erect unbranched stem bearing two large terminal lobed leaves encircling the single large white or pale pink flower (I have only seen white forms in the Himalaya). The fruits are large scarlet or reddish berries. Being quite an important medicinal plant, the rhizome containing greater amounts of podophyllin than the American May-Apple - hence the interest. Found in forests and open slopes, I have seen populations close to Gulmarg, in Kashmir, a popular resort for Indian tourists and many other places, as far East as Bhutan.

Koelz found that in the 1930s cough medicine was still being made from the fruit (sometimes called 'bear's apple'). The root is a dangerous poison used by physicians as a purgative.

Garden worthiness: Attractive - widely established in Western gardens amongst specialist growers, whilst of minimal interest to the average gardener.

Status: Widespread, not uncommon. Found, in sheltered sites, within the borderlands of Tibet but dies out if too arid.

Whilst working as a consultant to the Royal Government of Bhutan in 1991 I noted that 14kg of 'Ol-mo-se' (the name for the fruit of PODOPHYLLUM HEXANDRUM) was collected officially for use at the National Institute of Traditional Medicine in Thimphu.

Fruit of Podophyllum

Pressed specimen of PODOPHYLLUM HEXANDRUM collected for Urusvati Institute


Most authorities this just to be a subspecies of the widespread TAXUS BACCATA (commonly found in churchyards in the UK; possibly originally planted there in pre-Christian times).

A tree to nearly 30m but usually not more than 10m, with dark green foliage. Leaves linear, flattened, curved, spiny-tipped, dark glossy green. The wood is used for cabinet-making, furniture, poles and axles of carts. The fleshy fruit is eaten (presumably, the actual seed is poisonous, as in the UK). The foliage is used as litter and fed to cattle in Pakistan. The leaves contain an alkaloid poisonous to livestock but the alkaloid content varies from area to area. I remember many Yew trees at Narkanda, beyond Shimla, India - all the branches had been heavily cropped.


Appendix III

*I have never knowingly seen any of the Himalayan species included under Appendix III. This does NOT automatically confirm their rarity, just because neither I, nor many others, capable of identifying them, have visited the habitats they grow in - not that even, I could, do so in the field, so good quality herbarium specimens or close-up digital images.


I had not heard of this species. It was not recorded from Bhutan or Sikkim within 'Flora of Bhutan' Vol 1 Part 2 (1984). But it gets a brief mention as being cultivated in Kathmandu and in various villages ('An Enumeration of the Flowering Plants of Nepal' (Vol 2, 1979)! I cannot find out much information about this species or its variety but the above suggests it is NOT a native species of Nepal, so why has it been selected in the first place?


In 'Flowers of the Himalaya' (1984) this species was described as like MECONOPSIS PANICULATA but with fewer and larger yellow flowers, entire lanceolate leaves which are regularly and coarsely toothed, not lobed. Densely covered with silvery or golden silky hairs. The authors commented that the abobe species and MECONOPSIS NAPAULENSIS show many intermediate forms. They considered MECONOPSIS TAYLORII, MECONOPSIS DHWOJII and MECONOPSIS GRACILPES to be part of the complex and not easy to distinguish in the field.

Subsequently, a number of new species of Meconopsis have been recognised from Nepal. I came across a lovely blood-red species below Dhaulagiri in 1990, which did not fit well the descriptions of existing species. It was latter identified as MECONOPSIS STAINTONII. It has been the examination of living specimens raised from seed of known provenance, which allowed these new species to be separated with confidence by taxonomists.

Some species represent a real challenge to identify. Quite what the limits of MECONOPSIS 'REGIA' were when added to Appendix III is open to question. IF, a species cannot readily be separated from related ones, how can it be described as 'RARE and ENDANGERED', let alone be included

under Appendix III.


This tree, a member of the PODOCARPEACEAE, is known from the sub-tropical forests of the Darjeeling foothills @ 900-1400m. It is possible that I might have driven past an example when travelling from Bagdogra airport to and back from Darjeeling. Apparently the tree produces high-quality timber. No indication of rarity was given in 'Flora of Bhutan' Vol 1 Part 1 (1983).

It was recorded from Nepal (again, no indication of rarity) within 'An Enumeration of the Flowering Plants of Nepal' (1978), which gives as distribution of Assam, Burma, China, Taiwan and Malaysia. I am aware that some conifers are endangered, though again, why this species is included within Appendix III, and not others? Are not several under as much, if not greater threat?


This is a new genus and family (TETRACENTRACEAE) for me. 'An Enumeration of the Flowering Plants of Nepal' records it from Eastern Nepal to NEFA, N.Burma, W & C. China. 'Flora of Bhutan' states this Tree up to 30m, occurs in cool brood-leaved forests @ 2200-2900m. No comment was made about rarity. So why is it listed and who actually can judge its true occurrence.....