All Rhodiola species will enter the list of species covered by CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora), and will be subject to additional import and export requirements in countries that participate in the global treaty to protect endangered plants and animals.

Over 38,700 species—including roughly 5,950 species of animals and 32,800 species of plants—are protected by CITES against over-exploitation through international trade.

Already, a number of species used in dietary supplements have been indexed in CITES, including American Ginseng and Goldenseal. In the most recent conference of the parties (CoP), the entire genus of Rhodiola was added to Appendix II, effective Feb. 23.

“This implementation took place due to declines in wild populations, increased international trade, and, ultimately, a difficulty in differentiating Rhodiola species without DNA barcoding,” said Heather Harcum, permits biologist at the U.S. Fish and Wildlife Service, at a panel discussion held by the American Herbal Products Association (AHPA). “It covers all parts and derivatives except for seeds, pollen, and finished products already packaged and ready for retail sale.”

If Rhodiola has already been shipped before the listing date, and is arriving at the importing country after the implementation of that listing, a CITES permit is required, even though the shipment was in action prior to the listing, Harcum noted. She said the only Rhodiola shipments exempt from CITES requirements are finished products that are packaged and retail-ready.

“This may greatly impact the supply of Rhodiola in the short term, as there is a lot of documentation necessary, and if an importer or exporter wasn’t ready or thinking about this pre-documentation, you now have to prove your material adheres to CITES retrospectively,” said Wilson Lau, vice president of Nuherbs. “There aren’t that many people growing Rhodiola, and growers will be okay for the most part, but wild material users will need to build the case that things were done in a sustainable fashion to meet all requirements.”

The price of wild Rhodiola may increase as a result of the increased paperwork and risks involved for raw material suppliers, Lau noted.

“Each country’s implementation of CITES is different, as this treaty is just a framework,” Lau said. For instance, the U.S. implements CITES through the Endangered Species Act, and all CITES provisions are enforced by the U.S. Fish and Wildlife Service.

“There are slight differences everywhere, and you’re dealing with two unique legal systems at minimum, along with those systems’ self-interpretations and applications of rules. It’s all based on paper certificates, stamps, and signatures, so a lot can go wrong, and you need to be very hands-on with the paper trail […] when things go sideways, it can be really bad.”

Regulatory Structure

CITES was formed in 1963, and the U.S. has been an active party since its inception. Today, the treaty has 184 member countries which form national policies that adhere to the agreement.

Every few years, a conference of the parties (CoP) is held, where members review species that are subject to unsustainable trade which need to be listed in one of three CITES appendices.

Appendix I is the strictest, and covers wild specimens which are often used for commercial purposes that are generally prohibited. Appendix II covers commercially-traded wild specimens which are under controls to reduce the chance of extinction. Appendix III, the most lenient, covers species which require some degree of international cooperation to prevent or restrict species exploitation.

The overwhelming majority of CITES-listed plants appear in Appendix II in which it’s required that an exporter receives permits for legally-obtained specimens that were prepared and shipped in a manner that minimizes risk of harm.

CITES listings often come with further criteria for inclusion or exclusion, said Jane Wilson, director of program development at AHPA. “This can include things like the physical form of the specimen, different plant parts, raw materials versus finished products, the country of origin, and more. All of these conditions and limitations need to be considered.”

There are four source codes used to classify CITES-indexed materials based on how the plants are grown. Code W is for wild-sourced materials; Code Y involves assisted growth with some level of human intervention for the purpose of plant production; Code A is for fully-artificial cultivation; and Code O covers a specimen obtained prior to the enactment of the CITES provisions which were applied to it.

Shifting Toward Cultivation

Devin Stagg, COO at PLT Health Solutions, told Nutraceuticals World that he doesn’t anticipate any challenges or supply chain disruptions as a distributor of one of the few cultivated forms of Rhodiola.

“PLT innovation partner Nektium (Las Palmas, Spain) has been at the forefront of managing sustainability issues with its Rhodiola harvesting and traceability practices for decades,” Stagg said. “In 2017, we undertook a third-party sustainability and ingredient identity audit of Nektium’s Rhodiola operation working with Botanical Liaisons and NaturPro Scientific.”

PLT’s cultivation program with Nektium’s Rhodiola rosea debuted in September of 2022.

“This is a groundbreaking project that was the result of over a decade of work on Nektium’s part, where we are able to achieve a physical and phytochemical profile identical to wildcrafted Rhodiola sources,” said Stagg. “Cultivation of Rhodiola rosea has been attempted around the world for some time, but few if any have achieved success on anything approaching a commercial scale. That material is available to customers at a commercial scale today […] The steps taken over the last five-plus years to ensure the sustainable harvest and cultivation of Rhodiola rosea have aided immensely in the permitting process and, as a result, Nektium and PLT do not anticipate any challenges with complying with all requirements nor any disruption to the supply chain for Rhodiolife.” 

When conducted properly, wildcrafting is highly sustainable, according to Stagg, however, when demand reaches a certain peak, cultivation may become the most suitable option, with or without CITES listing.

“Conducted properly, wildcrafting is a highly sustainable method of obtaining botanical raw materials,” Stagg said. “But, when an ingredient like Rhodiola rosea which grows slowly and is sourced from remote regions becomes popular, nature isn’t always in the position to respond to a global surge in demand. It’s important that we understand this and constantly take steps to ensure sustainability. We don’t want to put down wildcrafting, but instead we can consider that there is sometimes a better way.”

Nektium has a Rhodiola ID Assessment program that offers customers insight into ingredient identity and quality. Nektium’s quality assurance team conducts multiple identity tests on each batch of Rhodiolife, Stagg said, including macroscopic and sensorial analysis, the development of chromatographic profiles, and independent DNA barcode analysis to ensure the authenticity of the raw material.

“The extracted material is standardized to provide precise levels of bioactive compounds. The resulting HPLC ‘fingerprint’ of the Rhodiolife extract is consistent from batch to batch and matches with that of the native root.”

PLT and Nektium are also working with Trish Flaster, co-founder of Botanical Liaisons, in order to conduct third-party auditing of its activities in order to ensure cultivation is done sustainably.

“Nektium’s first of its kind cultivation achievement relieves the pressures from the alpine terrain,” said Flaster. “As part of our sustainability audit, we reviewed propagation and growing techniques, growing locations, water sources, harvest timing and technique, and post-harvest handling. PLT also takes cultural sustainability seriously, caring for those who handle the product at every stage of the process.”