CITES and plant health
CITES and phytosanitary paperwork for tissue-culture labs
Two documents, two authorities, and one chain of records behind both: mother plant, explant, culture line, every passage, and the plants in the box.
See plansTwo documents, from two different authorities
A consignment of listed plants can need two separate documents, issued by two different agencies under two different bodies of law. They are not two stages of one process, and one does not stand in for the other.
| Document | Who issues it in the United States | What it answers |
|---|---|---|
| Phytosanitary certificate | Who issues it in the United StatesUSDA Animal and Plant Health Inspection Service (APHIS), Plant Protection and Quarantine — applied for through PCIT | What it answersWhether the plants meet the destination country's plant-health import requirements |
| CITES export document | Who issues it in the United StatesThe US Fish and Wildlife Service, as the United States' CITES Management Authority — not USDA | What it answersWhether trade in a listed species is lawful |
Which plants it applies to
For the plants tissue-culture labs most often ask about, per the CITES Checklist and the Appendices valid from 5 March 2026 (read 25 September 2026):
- Appendix II: the Venus flytrap (Dionaea muscipula), Sarracenia spp., Nepenthes spp. and the orchid family — in each case except the species listed in Appendix I.
- Appendix I: Sarracenia oreophila, S. rubra ssp. alabamensis, S. rubra ssp. jonesii, Nepenthes khasiana and N. rajah, and among orchids Paphiopedilum spp., Phragmipedium spp. and a short list of other species.
- Not listed: Darlingtonia, Cephalotus, Drosera, Pinguicula and Utricularia.
The three Appendix I Sarracenia are also listed as endangered under the US Endangered Species Act, which is a separate permit on a separate form. For any other family, check the Checklist yourself — we have not verified it here.
What a sterile flask changes
The Appendix II listings above carry annotation #4, which leaves out "seedling or tissue cultures obtained in vitro transported in sterile containers". That clause is part of the listing itself; whether a particular consignment qualifies is the inspecting authority's decision.
It does not reach Appendix I species in the same way. Appendix I orchids have their own, conditional note, and artificially propagated hybrids of Appendix I plants are handled differently again — read the Appendices' notes for those.
Two things hold even for flasks the annotation covers. Once plants come out of the flask they are regulated by CITES again (50 CFR 23.72(c)), so deflasked plants going overseas are a CITES export. And a flask shipment still clears the port like any plant shipment, with whatever phytosanitary certificate the destination requires (50 CFR 23.92(b)).
What a lab is asked to show for plants it propagated
US regulations set out when plants count as artificially propagated, in 50 CFR 23.64. There are three criteria:
- Controlled conditions — "a nonnatural environment that is intensively manipulated by human intervention for the purpose of plant production".
- Grown from a propagule — "seed, cutting, division, callus tissue, other plant tissue, spore, or other propagule". Tissue culture is named in the regulation itself.
- Cultivated parental stock — established lawfully, established without harming the species' survival in the wild, and maintained in enough quantity to reduce or remove the need to collect from the wild.
The regulation sets out what an authority looks for when it makes that finding. It prescribes no record format, and no file satisfies it on its own — the finding is the authority's to make.
When trade in a listed species is recorded, CITES marks where the specimens came from with a source code. For plants: A is artificially propagated — Appendix II and III specimens, and Appendix I specimens propagated for non-commercial purposes; D is Appendix I specimens artificially propagated for commercial purposes; W is taken from the wild. The difference between A and D is the appendix and the purpose, not the propagation method.
The chain behind the third criterion
Cultivated parental stock is a chain rather than a single fact, and for a tissue-culture lab every link is something the bench already handles.
Mother plant
The cultivated plant the material was taken from.
Explant
The piece taken from it, and the day it was taken.
Culture line
Every culture descended from that explant, each one pointing back to the culture it came from.
Passages
Each subculture and transfer, dated and numbered, with losses recorded where they happened.
The plants in the box
The lot that ships, traceable back through every step above.
The US paperwork, in order
As the regulations and the Fish and Wildlife Service describe it, read 25 September 2026.
| Step | Who | What it involves |
|---|---|---|
| Protected Plant Permit | WhoAPHIS | What it involvesA business exporting CITES plants needs one (7 CFR 355.11). |
| Form 3-200-33 | WhoUS Fish and Wildlife Service | What it involvesThe application for exporting artificially propagated plants, through ePermits or on paper. A single-use permit is $100 and valid for 6 months; a Master File is $200 and valid for up to 3 years, and each shipment under it then draws a $5 certificate (50 CFR 13.11). USFWS's general guidance is to allow 60 to 90 days for most CITES applications. |
| Phytosanitary certificate | WhoAPHIS, through PCIT | What it involvesWhatever the destination country requires for plant health. |
| At the port | WhoAn APHIS Plant Protection and Quarantine inspector | What it involvesThe CITES document is validated at a designated port (7 CFR 355.22). |
| Afterwards | WhoYou | What it involvesKeep the shipment records for five years (7 CFR 355.23). |
Where each one is applied for
Form 3-200-33 is on the Fish and Wildlife Service's page for it, and applications go through ePermits; the processing guidance is in their permits FAQ. A phytosanitary certificate is applied for in PCIT. The fees are in 50 CFR 13.11 and the permit, port and record-keeping rules in 7 CFR part 355.
Every one of these is a portal you sign in to. There is no interface for an exporter's own software to file through, and when a phytosanitary certificate travels electronically as an ePhyto it goes from one government's plant-protection organisation to another's — not through the exporter.
What your xPlant record already holds
An explant in xPlant records the plant it was taken from and the culture it descends from. Every transfer is dated, carries its passage number and who recorded it, and a culture split into several vessels becomes several records linked back to their source. That is most of the chain above, kept as the work happens rather than rebuilt when an exporter asks for it.
How the parent stock came to the lab has a place in the record too. Each plant has an Acquisitions tab for every delivery, top-ups included: the date it arrived, who supplied it, what arrived — seed, flasks, seedlings, young or mature plants, cuttings or divisions, roots or rhizomes — how many, the country of origin, and the numbers on the paperwork that came with it. If you bought flasks in, the Fish and Wildlife Service asks for records of how you obtained them, including who they came from (50 CFR 23.34(b)(3)). The papers themselves stay with you, attached to the entry as private files, and a record is only as good as what it points at.
What we are building
Built, and not on sale yet — a CITES provenance pack. The inputs to your Form 3-200-33 application or Master File renewal, assembled from your records: the parental stock and how it came to the lab, the chain from it to every culture and passage, and your 7 CFR 355.23 shipment record. Anything the record cannot show is marked as not recorded rather than left out, and every row says whether it is a record of what happened or complete against everything the published form lists — never whether the authority will accept it. It is part of the regulator add-on, like the phytosanitary inputs below. The Fish and Wildlife Service issues the certificate, and an APHIS inspector validates it at the port.
Built, and not on sale yet — phytosanitary consignment inputs. The consignment lines a phytosanitary certificate asks for, prepared from the lots you are shipping, as part of the regulator add-on. The add-on cannot be bought yet, and this page will say so when it can. The certificate itself is APHIS's to issue.
Questions a lab asks about this
Does xPlant apply for these documents for me?
No. You apply — for Form 3-200-33 in ePermits, and for a phytosanitary certificate in PCIT. xPlant keeps the record those applications draw on. We never file on a lab's behalf and never hold your sign-in to any of these systems.
Is a provenance pack a permit?
No. A provenance pack is the record of where a lot came from, laid out for whoever asks to see it. Permits and certificates are issued by the authorities named above, and nothing we produce stands in for one.
Do flasks of Venus flytraps or Nepenthes need CITES paperwork?
For the Appendix II entries, annotation #4 leaves seedling or tissue cultures obtained in vitro and transported in sterile containers out of the listing. Whether a particular consignment qualifies is the inspecting authority's decision, it still clears the port like any plant shipment, and the plants are regulated again once they leave the flask.
Does the record prove my plants were artificially propagated?
No record can. It is the evidence you show; the finding is the authority's to make.
Keep the chain as you work
Mother plant, explant, culture line and every passage, recorded at the bench on the day it happens. Start one line on the free plan and see how much of the chain is already there.