Burden Reduction from the Proposed Expansion of Crop Grouping Program

BURDEN REDUCTION FROM THE PROPOSED EXPANSION OF CROP GROUPING PROGRAM

Prepared by:

BIOLOGICAL AND ECONOMIC ANALYSIS DIVISION OFFICE OF PESTICIDE PROGRAMS

July 1, 2019

U.S. Environmental Protection Agency 1200 Pennsylvania Ave, NW Washington, DC 20640

Executive Summary ...... 3 Chapter 1 Introduction ...... 4 1.1 Background ...... 4 1.2 Tolerances ...... 5 1.3 Crop Groups and Representative Commodities ...... 5 1.4 Problem Statement ...... 5 1.5 Affected Community ...... 6 1.6 Summary of Impacts ...... 7 Chapter 2 Proposed Changes ...... 7 Chapter 3 Method ...... 8 3.1 Estimating the Value of the Revised Crop Grouping ...... 8 3.2 Data ...... 9 Chapter 4 Analysis & Results of Cost Savings Estimation ...... 13 4.1 Herbs Cost Savings ...... 14 4.2 Spices Cost Savings ...... 15 4.3 Results of Cost Savings Estimation ...... 17 4.4 Cost and Negative Impacts of the Rule...... 18 4.5 Characterizations and Uncertainties ...... 18 Appendix ...... 20

Executive Summary

EPA is proposing that the current “Crop Group 19: Herbs and Spice Group” be separated into two new crop groups, “Crop Group 25: Herb Group” and “Crop Group 26: Spice Group.” The new Crop Group 25 will have 317 commodities, and the new Crop Group 26 will have 166 commodities. The current Herbs subgroup (19A) has 37 commodities. The current Spice subgroup (19B) has 31 commodities.

This is a burden-reducing regulation. Crop grouping saves money by permitting the results of pesticide residue studies for some crops, called representative crops, to be applied to other, similar crops in the group. The regulation creates two new groups out of one and expands the groups to include more crops. Once final, EPA expects these revisions to promote greater use of crop groupings for tolerance-setting purposes, both domestically and in countries that export food to the United States. This is the fifth in a series of planned crop group updates expected to be prepared over the next several years.

The proposed herb group will still have four representative commodities: Fresh basil and dried basil will continue to be representative commodities, but fresh chives and dried chives will be replaced with fresh mint and dried mint. Although the number of representative crops will stay the same, the number of residue field trials will change. The current number of residue field trials needed per commodity is three, for a total of 12 for an herb subgroup tolerance. Under the proposal, 16 residue field trials will be needed for a group tolerance because fresh mint and dried mint need five field trials, not three.

The current spice subgroup has three options for representative crops (black pepper, celery seed and dill seed), but only needs residue trials on two of the crops (black pepper, and either celery seed or dill seed) for a tolerance on the spices subgroup. The proposed spice group will have two options for representative crops (celery seed and dill seed), but will only need a residue trial for one of these two crops for a group tolerance. The number of field trials needed will be reduced from six to three.

Herb growers, spice growers, and registrants are anticipated to be the biggest beneficiaries of this rulemaking. It is expected that growers will benefit from this rule via more registered pesticide products for small scale commodities like herbs and spices, and registrants will benefit from reduced data generation costs. The estimate of cost savings from creating the new, separate herb group and spice group is $55.1 million annually. The estimate of cost savings from creating the new herb group and expanding the crops within is around $38.4 million annually. The estimate of cost savings from the new spice group is around $16.7 million annually. The total estimated cost savings from the rule should be considered an overestimate because the method used here implicitly assumes that all of the crops in the group have a field trial that is replaced by field trials of the representative crops. However, many of the herb and spice crops would never have been the subject of a tolerance petition that required a field residue trial.

Chapter 1 Introduction

EPA is proposing revisions to its pesticide tolerance regulations for crop grouping, which allow the establishment of tolerances for multiple related crops based on data from a representative set of crops. The data in question are primarily for use in the exposure analysis of dietary risk assessment. EPA establishes tolerances for each pesticide on each crop or crop grouping based on the potential risks to human health posed by that pesticide. A tolerance is the maximum permissible residue level established for a pesticide in raw agricultural produce and processed foods.

EPA is proposing to revise one commodity definition, add three new commodity definitions, and amend the current herbs and spices crop group currently included in Crop Group 19. The 68 crops/commodities in current “Crop Group 19: Herbs and Spices Group” will be separated into two new crop groups, “Crop Group 25: Herb Group” and “Crop Group 26: Spice Group.” The new Crop Group 25 will be expanded to include 317 commodities, and the new Crop Group 26 will be expanded to include 166 commodities. The members of the new Crop Group 25 are proposed based on similarities of growth habits as well as herbs being marketed as either fresh or dried leaves, similar pest problems, sources of essential oil, geographical distribution, lack of animal feed items, comparison of established tolerances, and for international harmonization purposes. The members of the new Crop Group 26 are proposed based on similarities of growth habits and the specific edible parts of the plant that are exposed similarly to pesticides, geographical distribution, lack of animal feed items, comparison of established tolerances, and for international harmonization purposes.

This is a burden-reducing regulation. Crop grouping saves money by permitting the results of pesticide exposure studies for one crop to be applied to other, similar crops. The regulation expands two crop groups to include more crops. Because of this expansion, it is expected that registrants will benefit from reduced data generation costs and that herb and spice growers will benefit from this rule via more registered pesticide products. Having additional pesticides for use may help growers to lower costs (e.g. due to more effective pesticides helping growers to manage weeds or other pests) or increase yields (e.g. due to less competition from weeds or other pest damage reducing the quality or quantity of commodities harvested), which could lead to increases in grower incomes and/or decreases in prices for consumers if producer savings get passed on. It will also save EPA resources since there will be fewer studies overall for Agency scientists to review for all commodities in these new groups. The potential cost savings to EPA are not estimated in this economic analysis.

Once final, EPA expects these revisions to promote greater use of crop groupings for tolerance- setting purposes, both domestically and in countries that export food to the United States. This is the fifth in a series of planned crop group updates expected to be prepared over the next several years.

1.1 Background

EPA establishes maximum residue limits (MRLs) or tolerances for pesticide chemical residues in or on food commodities under section 408 of the FFDCA (21 U.S.C. 346a). EPA establishes

pesticide tolerances only after determining that aggregate exposure to the pesticide is considered safe. The U.S. Food and Drug Administration (FDA) and the U.S. Department of Agriculture (USDA) enforce compliance with tolerance limits.

1.2 Tolerances

A tolerance is the maximum permissible pesticide residue level established for pesticides in raw agricultural produce and processed foods. To establish a tolerance a petition is submitted to the Agency, requesting the tolerance and furnishing information on the chemical identity, composition, use pattern, toxicity, and nature and magnitude of the residue of the proposed use. EPA uses these data to determine the appropriate tolerance level. In order to obtain these data, it is usually necessary for the petitioner to conduct residue field trials for the pesticide on a given (representative) commodity.

1.3 Crop Groups and Representative Commodities

Traditionally, tolerances are established for a specific pesticide and commodity combination. However, under EPA’s crop grouping regulations (§180.41), a single tolerance may be established that applies to a group of related commodities. EPA regulations currently enable the establishment of tolerances for a group of crops based on residue data for designated crops that are representative of the group, e.g., citrus fruit crop group 10 has the representative commodities sweet orange; lemon and grapefruit. Crops are grouped based on similarities in cultural production practices, edible food portions and animal feed items, residue levels, geographical locations, and pest problems. All of the crops in a group may be granted a tolerance based on residue data from designated representative commodities within the group. Once a crop group tolerance is established, the tolerance level applies to all commodities within the group.

Representative commodities are selected based on EPA’s determination that they are likely to have the highest residues that could occur on any crop within the group. The minimum residue data required for a group tolerance consists of residue on all representative commodities for a group. Once the group tolerance is established, the tolerance level generally applies to all agricultural commodities in the group.

1.4 Problem Statement

All registered pesticides used on commercially produced commodities must have either a tolerance or an exemption from a tolerance. Only EPA is authorized to establish tolerances for pesticide residues in or on food commodities under Federal Food, Drug and Cosmetic (FFDCA) section 408. EPA has defined by regulation groups of raw agricultural commodities for which group tolerances may be established (40 CFR 180.41), and changing the crop groups requires an EPA regulatory action.

EPA is evaluating existing crop grouping because the representative crops may not be the best choices for a group, and because there are many small commodities that are not covered by an

existing group. In some cases, there may be other reasons for revisions; this is the case for the herbs and spices group, when crops that are not similar are grouped together.

Splitting the current herbs and spices crop group into their own separate groups will enable herb growers to benefit since the current Crop Group 19 has several representative commodities, including spices, that impacts establishing tolerances for the entire group. Very few tolerances for the current Crop Group 19 have been established since black pepper, a spice, is one of the representative commodities in current Crop Group 19 and is not grown in the United States. This factor may have reduced the number of tolerances actions for this crop group. It is possible that removing black pepper as a representative commodity for spices (which also decreases the number of field trials needed for a tolerance), may lead to increases in the new spice group at a rate faster than what was seen in the past.

1.5 Affected Community

The affected community for this rule includes several types of entities that are engaged in agricultural production, food production and pesticide manufacturing. Among the beneficiaries are minor crop (a crop grown on less than 300,000 acres or one that meets other criteria for being a minor use) producers and consumers. Minor crop producers should benefit because lower registration costs will encourage more products to be registered on herbs and spices, providing additional tools for pest control. If these pest control options lead to cost savings or increased yields, then consumers may also benefit if lower prices result from these changes.

Other beneficiaries are those who register or produce pesticides that are or will be used on herbs and spices that are contained in the future herb group or spice group. These firms will be able to obtain tolerances on a greater number of herbs and spices by performing field trials only on representative crops.

Third party groups who perform field trials necessary to obtain pesticide tolerances may also be affected. These include crop consultants who can perform field trials under contract, and participants in the nation-wide cooperative project the Interregional Research Project Number 4 (IR-4), who perform field trials on minor crops. The IR-4, which is publicly funded, is also expected to benefit from this rule as it will help IR-4 use its resources more efficiently in its efforts to ensure that minor/specialty crop growers have access to legal, registered uses of essential pest management tools such as pesticides and biopesticides.

The EPA will also benefit from broader operational efficiency gains, which result from fewer emergency pesticide use requests from specialty crop growers, the ability to conduct risk assessments based on crop grouping, greater ease of establishing import tolerances, greater capacity to assess risks of pesticides used on crops not grown in the U.S., further harmonization of crop classification and nomenclature, harmonized commodity import and export standards, and increased potential for resource sharing between EPA and other pesticide regulatory agencies. Revisions to the crop grouping program will result in no appreciable costs or negative impacts to consumers, specialty crop producers, pesticide registrants, the environment, or human health.

Firms in the following list of North American Industrial Classification System (NAICS) are potentially affected: • Crop production (NAICS code 111). • Food manufacturing (NAICS code 317). • Pesticide manufacturing (NAICS code 3250A1)

1.6 Summary of Impacts

Herb growers, spice growers, and registrants are anticipated to be the biggest beneficiaries of this rulemaking. The total quantified additional cost savings from creating the new, separate herb group and spice group is $55.1 million annually. These cost savings only represent the savings from a reduction in data generation costs and does not include the benefits to growers. The estimate of cost savings from creating the new herb group and expanding the crops within is $38.4 million annually. The estimate of cost savings from the new spice group and expanding the crops within is $16.7 million annually.

EPA will also likely experience cost savings as well, but these savings were not estimated. The crop grouping will allow the EPA to more efficiently use the resources it devotes to review tolerance petitions for specialty crop registrations, but these efficiencies are not quantified in this analysis. This includes personnel and resources used to guide tolerance petitions through the registration process, and scientific review process. Under the new crop grouping program, the Agency utilizes a similar level of resources to review tolerance petitions, but can establish a greater number of tolerances for specialty crops.

Broader operational efficiency gains are also likely to accrue to the Agency. It is anticipated that crop grouping changes in the rule facilitate risk assessments based on crop grouping, increase the ease of establishing import tolerances, facilitate the risk assessment of pesticides used on crops not grown in the US, promote harmonization in crop classification and nomenclature, harmonize commodity import and export standards, increase the potential for resource sharing between EPA and other pesticide regulatory agencies, and reduce the need to process emergency pesticide use requests on specialty crops under Section 18 of FIFRA.

Chapter 2 Proposed Changes

Currently the representative crops for the Crop Group 19: Herbs and Spices, are basil (fresh and dried); black pepper; chive (fresh and dried); and celery seed or dill seed. Crop Group 19 has two subgroups: 19A for herbs and 19B for spices. The two subgroups also have representative commodities, so that a tolerance could be granted for the subgroup, rather than the full Herbs and Spices Group. The representative crops for the herb subgroup 19A are basil (fresh and dried) and chive (fresh and dried). The representative crops for the spices subgroup 19B are black pepper and celery seed or dill seed. EPA is proposing to eliminate Crop Group 19, and create Crop Group 25 (Herbs) and Crop Group 26 (Spices).

EPA’s proposed representative commodities for the new Herb Group 25 are the following four commodities: basil, fresh leaves; mint, fresh leaves; basil, dried leaves; and mint, dried leaves. These representative commodities will account for more than 99% of the harvested U.S. acres for

the members of the new crop group. The representative commodities are based on similarities in cultural production practices, edible food portions, geographical locations pest problems, as well as their high production (both acres and yield) and consumption.

Within the Herb Group 25, EPA is proposing two subgroups: Herb, fresh leaves (subgroup 25A) and Herb, dried leaves (subgroup 25B). The representative crops are fresh basil and fresh mint for Subgroup 25A, and dried basil and dried mint for Subgroup 25B.

EPA’s proposed representative commodities for the Spice Group 26 are celery seed or dill seed. There are no subgroups proposed for Group 26.

Chapter 3 Method

3.1 Estimating the Value of the Revised Crop Grouping

Generally, the value of a crop grouping can be viewed as the savings from reducing the number of residue field trials needed to obtain a tolerance for all crops contained within the crop group. This valuation therefore assumes that the value of a registration to a minor crop in the group is the cost of field trials. Instead of conducting field trials for each individual crop in the group, field trials are required only for the representative crops in the crop group. To estimate the value of the crop grouping rule change, the cost to obtain a tolerance for all the crops contained in the crop group after the rule is promulgated is compared to the cost under the current crop grouping. If the cost after the rule change results in lower overall costs, then there is a “cost savings” from the rule. The estimated value or “cost savings” from the crop grouping rule can come from three sources: (a) increasing the number of crops in the crop group, (b) reducing the number of representative crops required to obtain a tolerance on the entire crop group and/or (c) reducing the number of field trials needed per representative crop. For this rule there are cost savings expected from increasing the number of crops in both crop groups and from reducing the number of representative crops needed for the spices crop group (from 2 to 1). The number of representative crops for the herb crop group will stay the same, but one of the representative crops will change (chives will be replaced with mint). In addition, the total number of field trials needed for the herb crop group will increase (from 12 to 16). This could potentially lead to cost increases from the field trials necessary to obtain a tolerance on the entire group, unless this is offset by an increase in the number of crops in the group, costs could increase from a crop grouping action. For this rule, the increase in the number of crops in the group does more than offset any increase in cost from doing additional field trials.

The estimate of the annual value of a crop group j at time t is

, = , , , , , , , , , (1).

𝑉𝑉𝑡𝑡 𝑗𝑗 𝐴𝐴𝑡𝑡 𝑗𝑗 �𝐶𝐶 ∙ � 𝑇𝑇𝑡𝑡 𝑗𝑗 𝑖𝑖 ∙ 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝑡𝑡 𝑗𝑗 𝑖𝑖 − 𝐶𝐶 ∙ � 𝑇𝑇𝑡𝑡 𝑗𝑗 𝑖𝑖 ∙ 𝑅𝑅𝑡𝑡 𝑗𝑗 𝑖𝑖� 𝑖𝑖 𝑖𝑖

At,j is the number of tolerance actions for new tolerances on crop group j per year. C is the cost of a field trial required to obtain a tolerance, Tt,j,i is the number of field trials per action needed to obtain a tolerance in crop i which is a member of group j at time t; this can vary by crop. Cropst,j,i is crop i which is a member of group j at time t. Rt,j,i is representative crop i in group j at time t. More discussion of these variables and their estimates is provided in Section 3.2 below. The cost savings (Srule,j) of the crop grouping rule for group j, then, is the difference between Vt,j at t = 0 (prior to the rule) and t = 1 (after the rule):

, = , ,

𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟 𝑗𝑗 1 𝑗𝑗 0 𝑗𝑗 𝑆𝑆 𝑉𝑉 −=𝑉𝑉 , , , , , , , , ,

𝐴𝐴1 𝑗𝑗 �𝐶𝐶 ∙ � 𝑇𝑇1 𝑗𝑗 𝑖𝑖 ∙ 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶1 𝑗𝑗 𝑖𝑖 − 𝐶𝐶 ∙ � 𝑇𝑇1 𝑗𝑗 𝑖𝑖 ∙ 𝑅𝑅1 𝑗𝑗 𝑖𝑖� 𝑖𝑖 𝑖𝑖 , , , , , , , , , (2).

− 𝐴𝐴0 𝑗𝑗 �𝐶𝐶 ∙ � 𝑇𝑇0 𝑗𝑗 𝑖𝑖 ∙ 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶0 𝑗𝑗 𝑖𝑖 − 𝐶𝐶 ∙ � 𝑇𝑇0 𝑗𝑗 𝑖𝑖 ∙ 𝑅𝑅0 𝑗𝑗 𝑖𝑖� 𝑖𝑖 𝑖𝑖 Equation (2) will be used for estimation of the cost savings from the crop grouping rule. The estimates will be done separately for the new herb group and the new spice group, and these will be summed to find an estimate of the total cost savings of the rule (see Chapter 4). In equation (2), the terms in brackets represent the difference in costs between field trials for every crop in the group and field trials only on the representative commodities, which is the main source of estimated value for the crop grouping rule. This value equation, then, implicitly assumes that every crop in the group has an equal value, which is unlikely. Equation (2) is best interpreted as a maximum value for cost savings if a registrant would have planned to pursue a registration on every crop in the group. Without the crop grouping, a registration action for each of these crops would require the completion of field trial data, but after the rule, only the representative crops need field trial data.

3.2 Data

The terms in equation (2) and the data needed for estimation are described in this section.

Tolerances Actions per Year (At,j)

For estimation of the value of the crop grouping rule for herbs and spices, the assumption is that the number of tolerance actions per year is the same after the rule and prior to the rule (A1,j = A0,j). The history of registration actions for the herbs and spices crop group shows that herbs have historically had about one tolerance (1.1) action per year and that spices have had about one-half (0.6) of one tolerance action per year (Table 1).

EPA publishes an annual report of the decisions made in each fiscal year for conventional pesticide chemicals (Report of Conventional Chemical Registration Decisions). These annual reports are publicly available at the EPA website1, and document registration decisions by year

1https://www.epa.gov/pesticide-registration/reports-previous-fiscal-year-registration-decisions 9

from 2001 to the present. These annual reports list, by chemical, the use(s) (e.g. crops, non- agricultural/food sites, commodities, etc.), the data submitter (e.g. registrant, IR-4, or their authorized agent), the date of the decision, a link to the decision in the federal register, and the decision number. Most decisions are for tolerances, which can be new, amended, or import tolerances. In addition, this report lists other decisions such as those that do not require a new tolerance, such registration actions for non-food uses (which do not require a tolerance) and withdrawals of use, as well as crop group changes, typically conversions or expansions.

EPA extracted data on all tolerance actions for the past ten years (2008-2017) from these reports for the relevant crops and crop groupings for this rule. The crops and crop groupings for which data were extracted included: herbs and spices group, the herbs subgroup, the spices subgroup, basil, mint, dill seed, black pepper, celery seed, and chives. EPA analyzed the data for the current crop grouping and subgroups, and the current and proposed representative crops. The purpose of this analysis was to document the number of tolerance actions on these crops and crop groupings, and to determine if there were any substantial differences in estimates for the number of tolerance actions over the past decade. Prior to extracting the data, EPA reasoned that using the prospective representative crops would provide the best basis upon which to form an estimate for future tolerance actions for the new and separate herbs crop group (25) and spices crop group (26).

The reports show that the number of tolerance actions using the herbs and spices subgroups separately or using the proposed representative crops for each subgroup is roughly the same for the past ten years. There were 11 herbs subgroup and 6 spices subgroup tolerance actions from 2008 to 2017. That means an average of 1.1 and 0.6 tolerance actions per year for the herbs subgroup and spices subgroup, respectively (Table 1).

Regarding the representative crops, there were 10 tolerance actions for basil (4) and mint (6) combined from 2008 to 2017. The 10 active ingredient tolerance actions established for these two crops are unique, i.e. there was no single tolerance action that granted registration on both crops during this time period. Dill seed had 5 tolerance actions over this same time period. There were no tolerances for celery seed established during this period. Thus, the estimate of average annual tolerance actions for the herbs crop group, based on the past tolerances for basil and mint is 1 (At,H); and for the spices crop group, based on dill seed’s past tolerances, the estimate of average annual tolerance actions is 0.5 (At,S) (Table 1). It is possible that the number of registration actions per year on the crop group could vary before and after the crop grouping rule takes effect. If the new crop grouping provides substantial value to the industry, then A1,j may be greater than A0,j, and the value of this rule would be underestimated.

Table 1. Historical Averages of Tolerances for Relevant Crops/Groups (2008-2017) Expected for the Expected for the Current Herbs Current Spices Herbs1 Spices2 subgroup subgroup (Proposed Group (Proposed Group (19A) (19B) 25) 26) Total 11 6 10 5 Average 1.1 0.6 1 0.5 1 Proposed representative crops only: basil, mint 2 Proposed representative crops only: dill seed, celery seed Source: EPA Estimates

This analysis only includes conventional pesticides chemicals.

Cost of the field trial (C)

The cost of the field trial to obtain a tolerance, C, is estimated to be $93,700 per trial, based on estimated cost of OPP data requirement 860.1500. The estimated costs of the data requirements for registration are available on the EPA pesticide registration website2. The estimates were obtained by EPA from independent laboratories and are adjusted for inflation annually, although they may also change when the Agency has new information on the cost of tests that satisfy data requirements. Although actual costs of studies may vary, the use of these cost estimates ensures the criteria for determining if a pesticide use meets the criteria for a minor use is applied consistently across all manufacturers.

Number of field trials (Tt,j,i)

The number of field trials required to obtain a tolerance, Tt,j,i, will vary based on the representative crop, R. The number of residue field trials per commodity is based on EPA guidelines for crop field trials (Residue Chemistry Test Guidelines OPPTS 860.1500 Crop Field Trials). The number of field trials per commodity is determined in part by “economic (acreage) importance and/or dietary significance.3” For commodities with acreage between 2,000 and 30,000, the number of trials required is three (e.g. dill seed). For commodities with acreage between 30,001 and 300,000, the number of trials required is 5 (e.g. mint). The minimum number of field trials for any representative commodity is 34. Table 2 below gives the number of residue field trials needed for all relevant representative commodities in this rulemaking.

2 https://www.epa.gov/pesticide-registration/cost-estimates-studies-required-pesticide-registration 3 http://www.oecd.org/chemicalsafety/testing/47102246.pdf, pg 14 4 https://www.epa.gov/test-guidelines-pesticides-and-toxic-substances/series-860-residue-chemistry-test-guidelines, pg 74 11

Table 2. Current and Proposed Representative Commodities and Number of Residue Field Trials Required for each to Establish a Tolerance Current Proposed Current Proposed Representative Subgroup 19A: Group 25: Subgroup 19B: Group 26: Commodity Herbs Herbs Spices Spices Basil, fresh leaves 3 3 N/A N/A Basil, dried leaves 3 3 N/A N/A Chive, fresh leaves 3 - N/A N/A Chive, dried leaves 3 - N/A N/A Mint, fresh leaves1 - 5 N/A N/A Mint, dried leaves1 - 5 N/A N/A Black pepper N/A N/A 3 0 Celery seed or N/A N/A 3 3 Dill seed Total 12 16 6 3 1 Mint includes peppermint and spearmint; either one can be used for mint field trials. Source: EPA5

Representative Commodities (Rt,j,i)

Currently, the herbs subgroup has four representative commodities: fresh basil, dried basil, fresh chives and dried chives. In order to obtain an herbs subgroup tolerance (subgroup 19A), presently, a registrant has to conduct 12 field trials; three field trials for each representative crop (Table 2). Under the proposed rule, there will still be four representative commodities for herbs, but chives will be replaced by mint. The four representative commodities are dried basil, fresh basil, dried mint and fresh mint. In order to obtain a Group 25 (Herbs) tolerance a registrant will have to conduct 16 field trials. For the proposed subgroup 25A herbs, fresh leaves, there are three fresh basil and five fresh mint field trials required. For the proposed subgroup 25B herbs, dried there are three dried basil and five dried mint field trials required (Table 2). Mint includes peppermint and spearmint; either one can be used for the mint field trials.

The spices subgroup currently has three representative commodities: black pepper, celery seed, and dill seed. In order to obtain a spice subgroup tolerance (subgroup 19B), currently, a registrant must conduct six field trials, three for black pepper and three for either celery seed or for dill seed (Table 2). Under the new rule, black pepper will no longer be a representative crop, so there will only be two options for representative commodities for spices: celery seed and dill seed. In order to obtain a Group 26 (Spices) tolerance, a registrant will have to conduct three field trials for either celery seed or dill seed (Table 2).

5 https://www.epa.gov/test-guidelines-pesticides-and-toxic-substances/series-860-residue-chemistry-test-guidelines 12

Number of Commodities in the Group (Crops)

For this rule, the herbs and spices commodity group is being split into two separate crop groups: Group 25 (Herbs) and Group 26 (Spices). Under the old crop grouping, the Herbs and Spices Group (Group 19), there are 37 commodities in the herbs subgroup, and 31 commodities in the spices subgroup. After the rule, there will be two crop groups: herbs, which will have 317 commodities, and spices, which will have 166. Therefore, for herbs, the sum of Crops0,H,i is 37, while after the rule the sum of Crops1,H,i is 317, and for spices the sum of Crops0,S,i is 31, and Crops1,S,i is 166.

The proposed expansion of the commodities covered within the two crop groups is not the only reason for the increase in the number of commodities. Under the proposed rule, there is a change in nomenclature for most of the herb commodities and some of the spice commodities (see the Appendix for a complete list). The change for herb commodities consists of listing the fresh and dried types of the commodities separately. For example, on the proposed list there are two commodities, “Balm, fresh leaves” and “Balm, dried leaves,” but under the current list, this herb is listed as “Balm (lemon balm).” On the proposed list of herb commodities to be added, about 90% have both fresh and dried types listed.

There is similar situation with some of the spice commodities, but the type variations are more diverse than just ‘fresh and dried.’ With spices, there are other parts of the plant that can be used, not just the leaves, so there are more types of distinctions. Most of these distinctions fall into two categories, ‘fruit and bark’ or ‘seed and fruit’ (e.g. “Cinnamon” would now be listed as “Cinnamon, bark” and “Cinnamon, fruit”; “Fennel (common)” would now be listed as “Fennel, common, fruit” and “Fennel, common, seed”). There are also other categories of plant parts that exist, usually among the new commodities being added, like ‘leaves and seed,’ ‘berry and leaf,’ etc. (e.g. “Daharian angelica, leaves” and “Daharian angelica, seed”; “Pepperbush, berry” and “Pepperbush, leaf”). On the proposed list of spice commodities to be added, about 20% have these distinctions.

This change in nomenclature contributes to the increase in the number of commodities covered under the proposed rule. The estimates presented in the next section will be adjusted to reflect this change, which will allow for an appropriate basis of comparison for cost savings before and after the rule. The adjustments are described in Section 4.1.2 and 4.2.2.

Chapter 4 Analysis & Results of Cost Savings Estimation

Estimation of the total additional cost savings for this rule will be done in two steps, with estimation of cost savings for herbs (SRule,H) and spices (SRule,S) done separately since they will now be in two completely separate crop groups, so the total cost savings for the rule will be the sum of the estimated cost savings of the individual crop groups:

SRule = SRule,H + SRule,S (3)

First the ‘old’ or baseline current savings will be estimated for the two groups, then the ‘new’ or proposed savings due to this rule will be estimated as in equation (2). The difference between them is the cost savings of this rule, i.e. the additional or incremental savings from the rule changes. SRule,H is the additional savings from this rule related to herbs. SRule,S is the additional savings from this rule related to spices; these will be summed to find the total savings from the rule SRule.

4.1 Herbs Cost Savings

The savings for the new herb group (25) is the difference between the cost of generating field trial data for the new herb group and the old herb subgroup 19A:

, = , , (4).

𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟 𝐻𝐻 1 𝐻𝐻 0 𝐻𝐻 𝑆𝑆 𝑉𝑉 − 𝑉𝑉 As in Equation (1), the value at each time is can be written:

, = , , , , , , , , , (5),

and 𝑉𝑉0 𝐻𝐻 𝐴𝐴0 𝐻𝐻 �𝐶𝐶 ∙ � 𝑇𝑇0 𝐻𝐻 𝑖𝑖 ∙ 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶0 𝐻𝐻 𝑖𝑖 − 𝐶𝐶 ∙ � 𝑇𝑇0 𝐻𝐻 𝑖𝑖 ∙ 𝑅𝑅0 𝐻𝐻 𝑖𝑖� 𝑖𝑖 𝑖𝑖

, = , , , , , , , , , (6),

𝑉𝑉1 𝐻𝐻 𝐴𝐴1 𝐻𝐻 �𝐶𝐶 ∙ � 𝑇𝑇1 𝐻𝐻 𝑖𝑖 ∙ 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶1 𝐻𝐻 𝑖𝑖 − 𝐶𝐶 ∙ � 𝑇𝑇1 𝐻𝐻 𝑖𝑖 ∙ 𝑅𝑅1 𝐻𝐻 𝑖𝑖� 𝑖𝑖 𝑖𝑖

4.1.1 Baseline of Savings from the Current Herb Subgroup

Under the current crop grouping for herbs, the value of herb subgroup 19A as given by equation (5) is equal to $9.3 million. There are 37 commodities in the current subgroup, Crops0,H,i. If there are three field trials, T0,H,i, required per commodity at a cost (C) of $93,700 each, then the total cost of receiving a tolerance on the entire group would be $10.4 million without the crop grouping. The current representative commodities for the herb subgroup are basil and chives, which have six field trials each, three for the fresh and three for the dried types of each representative commodity. With six field trials for both then the total cost of receiving a tolerance on the entire group is $1.1 million with the current herb subgroup. The difference between obtaining a tolerance on each individual commodity, $10.4 million, and the entire group using representative commodities, $1.1 million, is the current baseline of cost savings or $9.3 million. Since the number of tolerance actions, A0,H , is one per year, this is also the annual cost savings under the current rule.

4.1.2 Savings under the Proposed Herb Crop Grouping

Under the proposed crop grouping for herbs, the value of herb group 25 as given by equation (6) is equal to $47.7 million. There are 317 commodities in the proposed crop group, Crops1,H,i. If there are three field trials, T1,H,i, required per commodity at a cost C of $93,700 each, then the total cost of receiving a tolerance on the entire group would be $89.1 million without the crop group. There is one key difference between Crops1,H,i and Crops0,H,i that must be accounted for when estimating the additional cost savings from this rule. As previously mentioned in the Data Section of this document, the herb commodities under the old rule do not have a fresh and dried distinction, while most of the commodities in the new herb group do make this distinction. About 90% or 284 of the herbs listed in the proposed crop group of 317 (total) herb commodities do have this distinction. The herb cost savings estimate must account for the fact that the new crop group lists an herb with a dried and fresh distinction that would have (herb commodities being added) or does (current herb subgroup members) correspond to only one herb in the existing group [see Appendix Table A-1]. Therefore, to make a proper comparison with the baseline list, the cost savings for commodities (284) with this distinction will be halved. This adjustment is equivalent to reducing the number of crops, Crops1,H,i, from 317 to 175. After this adjustment, the total cost for the entire proposed herb group is not $89.1 million, but $49.2 million.

The four proposed representative commodities for herbs (R1,H,i) are basil (fresh and dried) and mint (fresh and dried). The number of field trials (T1,H,i) needed for basil is the same under the current and proposed rule: three each, for both the fresh (T1,H,fresh basil) and dried basil (T1,H,dried basil). Mint has a higher number of field trials required, so T1,H,fresh mint and T1,H,dried mint are both equal to five. Under the proposed rule, there are 16 field trials (6 total for basil and 10 total for mint) required at a cost (C) of $93,700 each, then the total cost of receiving a tolerance on the entire group is $1.5 million with the commodity grouping using just the representative commodities. The difference between obtaining a tolerance on each individual herb commodity in the proposed group, $49.2 million, and the entire herbs group using representative commodities, $1.5 million, is the cost savings under the proposed herbs rule: $47.7 million. Since the number of tolerance actions, A1,H, is one per year, this is also the annual cost savings under the proposed rule.

4.1.3 Annual Additional Cost Savings from Creating the Herbs Crop Group

The incremental value of the proposed changes that create the new herb group 25 is the difference between the current herb subgroup and the proposed herb group, or V1,H – V0,H. The difference between the current cost savings, $9.3 million, and the proposed cost savings, $47.7 million, is the additional cost savings from the proposed rule for herbs, $38.4 million.

4.2 Spices Cost Savings

The savings for the new spice group (26) is the difference between the value of the new spices group and the old spice subgroup 19BA:

, = , , (7).

𝑆𝑆𝑟𝑟𝑟𝑟𝑟𝑟𝑟𝑟 𝑆𝑆 𝑉𝑉1 𝑆𝑆 − 𝑉𝑉0 𝑆𝑆 15

As in Equation (1), the value at each time is can be written:

, = , , , , , , , , , (8), and 𝑉𝑉0 𝑆𝑆 𝐴𝐴0 𝑆𝑆 �𝐶𝐶 ∙ � 𝑇𝑇0 𝑆𝑆 𝑖𝑖 ∙ 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶0 𝑆𝑆 𝑖𝑖 − 𝐶𝐶 ∙ � 𝑇𝑇0 𝑆𝑆 𝑖𝑖 ∙ 𝑅𝑅0 𝑆𝑆 𝑖𝑖� 𝑖𝑖 𝑖𝑖

, = , , , , , , , , , (9),

𝑉𝑉1 𝑆𝑆 𝐴𝐴1 𝑆𝑆 �𝐶𝐶 ∙ � 𝑇𝑇1 𝑆𝑆 𝑖𝑖 ∙ 𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶𝐶1 𝑆𝑆 𝑖𝑖 − 𝐶𝐶 ∙ � 𝑇𝑇1 𝑆𝑆 𝑖𝑖 ∙ 𝑅𝑅1 𝑆𝑆 𝑖𝑖� 𝑖𝑖 𝑖𝑖

4.2.1 Baseline of Savings from the Current Spices Subgroup

Under the current crop grouping for spices, the value of spice subgroup 19B as given by equation (8) is equal to $8.2 million. There are 31 commodities in the current subgroup, Crops0,S,i.. If there are three field trials, T0,H,i, required per commodity at a cost (C) of $93,700 each, then the total cost of receiving a tolerance on the entire group would be $8.7 million without the commodity grouping. The current representative commodities for spices are black pepper, and either dill seed or celery seed. There are three field trials each (T0,H,i) for both of the two representative commodities chosen, for a total of six field trials required. If there are six field trials in total needed at a cost (C) of $93,700 each, then the total cost of receiving a tolerance on the entire group is $0.6 million using just the representative commodities. The difference between obtaining a tolerance on each individual spice commodity, $8.7 million and the entire group using representative commodities, $0.6 million, is the current baseline cost savings or $8.2 million. Since the number of tolerance actions, A0,S , is one-half per year, the annual cost savings under the current rule is $4.1 million.

4.2.2 Savings under the Proposed Spices Crop Grouping

Under the proposed crop grouping for spices, the value of spice group 26 as given by equation (9) is equal to $20.8 million. There are 166 commodities (Crops1,S,i), in the proposed crop group for spices. If there are three field trials (T1,S,i), required per commodity at a cost (C) of $93,700 each, then the total cost of receiving a tolerance on the entire group would be $46.7 million without the crop grouping. As previously mentioned in the Data Section of this document, the spice commodities under the old rule do not have a fruit and bark, leaf and seed, etc. distinction. However, approximately 20%, or 34 of the spices listed in the proposed crop group (of 166 total spice commodities), do have one of these distinctions. The spice cost savings estimate must account for the fact that the new crop group lists some spices with a distinction that would have (spice commodities being added) or does (current spice subgroup members) correspond to only one spice in the existing group [see Appendix Table A-2]. Therefore, to make a proper comparison with the baseline list, the cost savings for commodities (34) with this distinction will be halved. This adjustment is equivalent to reducing the number of crops, Crops1,S,i, from 166 to

150. After this adjustment, the total cost for the entire proposed spice group is therefore $41.9 million, rather than $46.7 million.

The proposed representative commodity for a tolerance on spices is either dill seed or celery seed. The number of field trials needed for either dill seed (T1,S,dill seed) or celery seed (T1,S,celery seed) is the same under the current and proposed rule: three. If there are three field trials required at a cost (C) of $93,700 each, C, then the total cost of receiving a tolerance on the entire group is $0.3 million with the commodity grouping, i.e. using just the representative commodity. The difference between obtaining a tolerance on each individual spice commodity in the proposed group, $41.9 million, and the entire group using representative commodities, $0.3 million, is the cost savings under the proposed spice rule: $41.9 million. Since the number of tolerance actions, A1,S , is one-half per year, the annual cost savings under the proposed rule is $20.8 million.

4.2.3 Annual Additional Cost Savings from Creating the Spices Crop Group

The incremental value of the proposed changes that create the new spice group 26 is the difference between the current spice subgroup and the proposed spice group, or V1,S – V0,S. The difference between the current cost savings, $4.1 million, and the proposed cost savings, $20.8 million, is the incremental cost savings from the proposed rule for spices: $16.7 million.

4.3 Results of Cost Savings Estimation

The estimate of cost savings from creating the new herb group and expanding the crops within is $38.4 million annually. The estimate of cost savings from the new spice group and expanding the crops within is $16.7 million annually. The additional cost savings from the proposed rule, which creates both the new herb and spice group is $55.1 million annually (Table 3).

Table 3. Estimated Annual Cost Savings from Creating the Proposed Herb and Spice Groups Total Cost for Total Cost Total Field Trials Total Field Representative Representative without Cost Needed for Number of Trials Commodities Commodities Crop Savings Representative Commodities Needed (million) Grouping (Vt,j) Herbs 2 12 $1.1 37 111 $10.4 $9.3 (current) Herbs 2 16 $1.5 317 521 $49.2 $47.7 (proposed)

Total Additional Savings from Herbs (SRule,H): $38.4 Million Spices 2 6 $0.6 31 93 $8.7 $4.11 (current) Spices 1 3 $0.3 166 450 $41.9 $20.82 (proposed)

Total Additional Savings from Spices (SRule,S): $16.7 Million

Total Additional Savings from Rule (SRule): $55.1 Million Source: EPA Estimates 1 $8.7 - $0.6 = $8.2 X 0.5 (A0,S) = $4.1. 2 $41.9 - $0.3 = $41.6 X 0.5 (A1,S) = $20.8

4.4 Cost and Negative Impacts of the Rule

The Agency anticipates that revisions to the crop grouping program result in no appreciable costs or negative impacts to consumers, specialty crop producers, pesticide registrants, the environment, or human health.

While this rule increases the number of pesticides with tolerances for minor crops, it does not necessarily increase the amount of pesticides released into the environment and may result in the use of safer pesticides. This is because changes to the crop grouping program broadens the choice of pesticides for specialty crop producers and makes newer pesticides available. It is also likely that growers have a greater ability to use integrated pest management systems that could reduce environmental damage resulting from the use of pesticides.

Revisions to the crop grouping program maintain EPA standards for protecting human health. Representative crops for groups and subgroups are chosen on the basis that they have the highest residues in the group. For this reason, risk assessments conducted for crop groups are as conservative and comprehensive as risk assessments conducted for individual crops.

4.5 Characterizations and Uncertainties

The estimates provided in Section 4.1, 4.2, and 4.3 should be regarded with caution. They are based solely on the number of field trials potentially avoided by the crop grouping rule. This limitation means that other sources of value to society, like making it easier to register pesticides

for minor herb and spice crops, are not captured in the estimates above. Easier registration of pesticides would have value to growers, who would then have access to more means of pest control, but it would not be included in the value estimated by the reduced cost of field trials.

There are other additional benefits that are not counted in the estimate above. The crop grouping will allow the EPA to more efficiently use the resources it devotes to review tolerance petitions for specialty crop registrations. This includes personnel and resources used to guide tolerance petitions through the registration process, and scientific review process. Under the new crop grouping program, the Agency utilizes a similar level of resources to review tolerance petitions, but can establish a greater number of tolerances for specialty crops.

Broader operational efficiency gains are also likely to accrue to the Agency. It is anticipated that crop grouping changes in the rule will result in the following: (1) facilitate risk assessments based on crop grouping, (2) increase the ease of establishing import tolerances, (3) facilitate the risk assessment of pesticides used on crops not grown in the US, (4) promote harmonization in crop classification and nomenclature, (5) harmonize commodity import and export standards, (6) increase the potential for resource sharing between EPA and other pesticide regulatory agencies, and (7) reduce the need to process emergency pesticide use requests on specialty crops under Section 18 of FIFRA.

While the estimate does not capture some important societal benefits, it is likely to be an overestimate for cost savings from reduced field trials. This is especially true for the new herb and spice groups; for these, it is most appropriate to consider these as maximum possible estimates of the value of reduced field trials. This particular crop grouping includes many minor herb and spice crops, and the method used here implicitly assumes that all of the crops in the group have a field trial that is replaced by field trials of the representative crops. The problem is that many of these crops would never have been the subject of a tolerance petition that required a field residue trial. Because of that, even if there is a demand for a pesticide on one of the herb and spice crops after a tolerance is granted, it does not reflect an actual savings, but merely a potential savings if a registrant or IR-4 were planning to submit field trial residue data to support a tolerance petition.

The decision by EPA to establish a tolerance or place a crop into a crop group does not reflect a registrant’s business decision to market a pesticide on that crop. There are other important factors, such as the size of the potential market, and other costs, such as efficacy and crop safety studies that might have been an equal or greater deterrent to registration than the field residue trial. If so, then the actual benefit to registrants of including a site in the crop grouping for that pesticide and crop combination is zero, since they would not have pursued a field residue trial for a pesticide that would not be profitable to market. This is especially true for herbs and spices, which are produced on limited acreage, and for many of which estimates of the size of the crops are unavailable.

Appendix

Table A-1. Correspondence Between the Current Crop Group and the Proposed Herb Crop Group Related Commodities in the Related Commodities in the New Herb Group crop Existing Herb crop subgroups Subgroup subgroups

Agrimony, fresh leaves, Agrimonia 25A eupatoria L. Agrimony, dried leaves, Agrimonia 25B eupatoria L. Angelica, fresh leaves, Angelica Angelica (Angelica 25A 19A archangelica L. archangelica) Angelica, dried leaves, Angelica Angelica (Angelica 25B 19A archangelica L. archangelica) Angelica, fragrant, Angelica dahurica (Hoffm.) Benth & Hook. F. ex Franch. & 25A Sav. Angelica, fragrant, Angelica dahurica (Hoffm.) Benth & Hook. F. ex Franch. & 25B Sav. Applemint, fresh leaves, Mentha 25A suaveolens Ehrh. Applemint, dried leaves, Mentha 25B suaveolens Ehrh. Avarum, fresh leaves, Senna auriculata 25A (L.) Roxb. Avarum, dried leaves, Senna auriculata 25B (L.) Roxb. Balm (lemon balm) Balm, fresh leaves, Melissa officinalis L. 25A 19A (Melissa officinalis) Balm (lemon balm) Balm, dried leaves, Melissa officinalis L. 25B 19A (Melissa officinalis) Balloon pea, fresh leaves, Lessertia 25A frutescens (L.) Goldblatt & J. C. Manning Balloon pea, dried leaves, Lessertia 25B frutescens (L.) Goldblatt & J. C. Manning Barrenwort, fresh leaves, Epimedium 25A grandiflorum C. Morren Barrenwort, dried leaves, Epimedium 25B grandiflorum C. Morren Basil (Ocimum Basil, fresh leaves, Ocimum basilicum L. 25A 19A basilicum) Basil (Ocimum Basil, dried leaves, Ocimum basilicum L. 25B 19A basilicum) Basil, American, fresh leaves, Ocimum 25A americanum L. Basil, American, dried leaves, Ocimum 25B americanum L.

Basil, Greek, fresh leaves, Ocimum 25A minimum L. Basil, Greek, dried leaves, Ocimum 25B minimum L. Basil, holy, fresh leaves, Ocimum 25A tenuiflorum L. Basil, holy, dried leaves, Ocimum 25B tenuiflorum L. Basil, lemon, fresh leaves, Ocimum x 25A citriodorum Vis. Basil, lemon, dried leaves, Ocimum x 25B citriodorum Vis. Basil, Russian, fresh leaves, Ocimum 25A gratissimum L. Basil, Russian, dried leaves, Ocimum 25B gratissimum L. Sweet bay (bay leaf) Bay, fresh leaves, Laurus nobilis L. 25A 19A (Laurus nobilis) Sweet bay (bay leaf) Bay, dried leaves, Laurus nobilis L. 25B 19A (Laurus nobilis) Bisongrass, fresh leaves, Anthoxanthum 25A nitens (Weber) Y. Schouten & Veldkamp Bisongrass, dried leaves, Anthoxanthum 25B nitens (Weber) Y. Schouten & Veldkamp Blue mallow, fresh leaves, Malva 25A sylvestris L. Boneset, fresh leaves, Eupatorium 25A perfoliatum L. Boneset, dried leaves, Eupatorium 25B perfoliatum L. Borage, fresh leaves, Borago officinalis Borage (Borago 25A 19A L. officinalis) Borage, dried leaves, Borago officinalis Borage (Borago 25B 19A L. officinalis) Borage, Indian, fresh leaves, Plectranthus 25A amboinicus (Lour.) Spreng. Borage, Indian, dried leaves, Plectranthus 25B amboinicus (Lour.) Spreng. Burnet (Sanguisorba Burnet, fresh leaves, Sanguisorba spp. 25A 19A minor) Burnet (Sanguisorba Burnet, dried leaves, Sanguisorba spp. 25B 19A minor) Burnet, garden, fresh leaves, Sanguisorba 25A officinalis L.

Burnet, garden, dried leaves, Sanguisorba 25B officinalis L. Burnet, salad, fresh leaves Sanguisorba 25A minor Scop. Burnet, salad, dried leaves Sanguisorba 25B minor Scop. Butterbur, dried leaves, Petasites hybridus (L.) G. Gaertn. Et al., P. frigidus 25B (L.) Fr. Calamint, fresh leaves, Clinopodium spp. 25A Calamint, dried leaves, Clinopodium spp. 25B Calamint, large-flower, fresh leaves, 25A Clinopodium grandiflorum (L.) Kuntze Calamint, large-flower, dried leaves, 25B Clinopodium grandiflorum (L.) Kuntze Calamint, lesser, fresh leaves, 25A Clinopodium nepeta (L.) Kuntze Calamint, lesser, dried leaves, 25B Clinopodium nepeta (L.) Kuntze Calendula, fresh leaves, Calendula 25A officinalis L. Calendula, dried leaves, Calendula 25B officinalis L. Caltrop, fresh leaves, Tribulus terrestris 25A L. Caltrop, dried leaves, Tribulus terrestris 25B L. Camomile (Chamomile), fresh leaves, Camomile (Anthemis 25A 19A Chamaemelum spp. and Matricaria spp. nobilis) Camomile (Chamomile), dried leaves, Camomile (Anthemis 25B 19A Chamaemelum spp. and Matricaria spp. nobilis) Camomile (Chamomile), German, fresh 25A leaves, Matricaria recutita L. Camomile (Chamomile), German, dried 25B leaves, Matricaria recutita L. Camomile (Chamomile), Roman, fresh 25A leaves, Chamaemelum nobile (L.) All. Camomile (Chamomile), Roman, dried 25B leaves, Chamaemelum nobile (L.) All. Caraway, fresh leaves, Carum carvi L. 25A Caraway, dried leaves, Carum carvi L. 25B Cat’s claw, dried leaves, Uncaria tomentosa (Willd.) DC., Uncaria 25B guianensis (Aubl.) J. F. Gmel. 22

Catnip (Nepeta Catnip, fresh leaves, Nepeta cataria L. 25A 19A cataria) Catnip (Nepeta Catnip, dried leaves, Nepeta cataria L. 25B 19A cataria) Catnip, Japanese, fresh leaves, 25A Schizonepeta multifida (L.) Briq. Catnip, Japanese, dried leaves, 25B Schizonepeta multifida (L.) Briq. Celandine, greater, fresh leaves, 25A Chelidonium majus L. Centaury, fresh leaves, Centaurium 25A erythrarae Rafn. Centaury, dried leaves, Centaurium 25B erythrarae Rafn. Celandine, lesser, fresh leaves, Ficaria 25A verna Huds. Chaste tree, fresh leaves, Vitex agnus- 25A castus L. Chaste tree, dried leaves, Vitex agnus- 25B castus L. Chervil (dried) Chervil, dried leaves, Anthriscus 25B (Anthriscus 19A cerefolium (L.) Hoffm. cerefolium) Chinese chastetree, dried leaves, Vitex 25B negundo L. Chinese foxglove, dried leaves, 25B Rehmannia glutinosa (Gaertn.) Steud. Chive, dried leaves, Allium Chive (Allium 25B 19A schoenoprasum L. schoenoprasum) Chive, Chinese, dried leaves, Allium Chive, Chinese 25B 19A tuberosum Rottler ex Spreng. (Allium tuberosum) Cicely, sweet, fresh leaves, Myrrhis 25A odorata (L.) Scop. Cicely, sweet, dried leaves, Myrrhis 25B odorata (L.) Scop. Coriander (cilantro or Cilantro, dried leaves, Coriandrum Chinese parsley) 25B 19A sativum L. (leaf) (Coriandrum sativum) Clary, fresh leaves, Salvia sclarea L. 25A Clary (Salvia sclarea) 19A Clary, dried leaves, Salvia sclarea L. 25B Clary (Salvia sclarea) 19A Coriander, Bolivian, fresh leaves, 25A Porophyllum ruderale (Jacq.) Cass.

Coriander, Bolivian, dried leaves, 25B Porophyllum ruderale (Jacq.) Cass. Coriander, Vietnamese, fresh leaves, 25A Persicaria odorata (Lour.) Sojak. Coriander, Vietnamese, dried leaves, 25B Persicaria odorata (Lour.) Sojak. Costmary Costmary, fresh leaves, Tanacetum 25A (Chrysanthemum 19A balsamita L. subsp. Balsamita balsamita) Costmary, dried leaves, Tanacetum 25B balsamita L. subsp. Balsamita Creat, dried leaves, Andrographis 25B paniculata (Burm. f.) Wall. Ex Nees Culantro, fresh leaves, Eryngium Culantro (leaf) 25A 19A foetidum L. (Eryngium foetidum) Culantro, dried leaves, Eryngium Culantro (leaf) 25B 19A foetidum L. (Eryngium foetidum) Curry leaf, fresh leaves, Bergera koenigii Curry (leaf) (Murraya 25A 19A L. koenigii) Curry leaf, dried leaves, Bergera koenigii Curry (leaf) (Murraya 25B 19A L. koenigii) Curryplant, fresh leaves, Helichrysum 25A italicum (Roth) G. Don Cut leaf, fresh leaves, Prostanthera incisa 25A R. Br. Cut leaf, dried leaves, Prostanthera 25B incisa R. Br. Dillweed, dried leaves, Anethum Dill (dillweed) 25B 19A graveolens L. (Anethum graveolens) Dokudami, fresh leaves, Houttuynia 25A cordata Thunb. Echinacea, dried leaves, Echinacea 25B angustifolia DC Epazote, fresh leaves, Dysphania 25A ambrosioides (L.) Mosyakin & Clemants Epazote, dried leaves, Dysphania 25B ambrosioides (L.) Mosyakin & Clemants Eucommia, dried leaves, Eucommia 25B ulmoides Oliv. Evening primrose, fresh leaves, 25A Oenothera biennis L. Evening primrose, dried leaves, 25B Oenothera biennis L.

Fennel, common, fresh leaves, Foeniculum vulgare Mill. Subsp. vulgare 25A var. vulgare Fennel, common, dried leaves, Foeniculum vulgare Mill. Subsp. vulgare 25B var. vulgare Fennel, Florence, dried leaves , Foeniculum vulgare Mill. Subsp. vulgare 25B var. azoricum (Mill.) Thell. Fennel, Spanish, fresh leaves, Nigella 25A spp. Fennel, Spanish, dried leaves, Nigella 25B spp. Fenugreek, fresh leaves, Trigonella 25A foenum-graecum L. Fenugreek, dried leaves, Trigonella 25B foenum-graecum L. Feverfew, fresh leaves, Tanacetum 25A parthenium (L.) Sch. Bip. Feverfew, dried leaves, Tanacetum 25B parthenium (L.) Sch. Bip. Field pennycress, fresh leaves, Thlaspi 25A arvense L. Flowers, edible, fresh, multiple species 25A Flowers, edible, dried, multiple species 25B Fumitory, fresh leaves, Fumaria 25A officinalis L. Fumitory, dried leaves, Fumaria 25B officinalis L. Galbanum, dried leaves, Ferula gummosa 25B Boiss. Gambir, fresh leaves, Uncaria gambir 25A (W. Hunter) Roxb. Geranium, fresh leaves, Pelargonium spp. 25A Geranium, dried leaves, Pelargonium 25B spp. Geranium, lemon, fresh leaves, Pelargonium crispum (P. J. Bergius) 25A L’Her. Geranium, lemon, dried leaves, Pelargonium crispum (P. J. Bergius) 25B L’Her. Geranium, rose, fresh leaves, 25A Pelargonium graveolens L’Her.

Geranium, rose, dried leaves, 25B Pelargonium graveolens L’Her. Germander, golden, fresh leaves, 25A Teucrium polium L. Germander, golden, dried leaves, 25B Teucrium polium L. Gotu kola, dried leaves, Centella asiatica 25B (L.) Urb. Gumweed, fresh leaves, Grindelia 25A camporum Greene Gumweed, dried leaves, Grindelia 25B camporum Greene Gymnema, dried leaves, Gymnema 25B sylvestre (Retz.) Schult. Gypsywort, fresh leaves, Lycopus 25A europaeus L. Gypsywort, dried leaves, Lycopus 25B europaeus L. Heal-all, fresh leaves, Prunella vulgaris 25A L. Heal-all, dried leaves, Prunella vulgaris 25B L. Honewort, fresh leaves, Cryptotaenia 25A canadensis (L.) DC. Honeybush, dried leaves, Cyclopia 25B genistoides (L.) R. Br. Horehound, fresh leaves, Marrubium Horehound 25A 19A vulgare L. (Marrubium vulgare) Horehound, dried leaves, Marrubium Horehound 25B 19A vulgare L. (Marrubium vulgare) Horsemint, fresh leaves, Mentha 25A longifolia (L.) Huds. Horsemint, dried leaves, Mentha 25B longifolia (L.) Huds. Hyssop, fresh leaves, Hyssopus officinalis Hyssop (Hyssopus 25A 19A L. officinalis) Hyssop, dried leaves, Hyssopus Hyssop (Hyssopus 25B 19A officinalis L. officinalis) Hyssop, anise, fresh leaves, Agastache 25A foeniculum (Pursh) Kuntze Hyssop, anise, dried leaves, Agastache 25B foeniculum (Pursh) Kuntze Jasmine, fresh leaves, Jasminum 25A officinale L., J. odoratissimum L.

Jasmine, dried leaves, Jasminum 25B officinale L., J. odoratissimum L. Labrador tea, fresh leaves, Rhododendron groenlandicum (Oeder) Kron & Judd, R. 25A tomentosum Harmaja Labrador tea, dried leaves, Rhododendron groenlandicum (Oeder) Kron & Judd, R. 25B tomentosum Harmaja Lavender, fresh leaves, Lavandula Lavender (Lavandula 25A 19A angustifolia Mill. officinalis) Lavender, dried leaves, Lavandula Lavender (Lavandula 25B 19A angustifolia Mill. officinalis) Lemongrass Lemongrass, fresh leaves, Cymbopogon 25A (Cymbopogon 19A citratus (DC.) Stapf citratus) Lemongrass Lemongrass, dried leaves, Cymbopogon 25B (Cymbopogon 19A citratus (DC.) Stapf citratus) Lemon verbena, fresh leaves, Aloysia 25A citrodora Palau Lemon verbena, dried leaves, Aloysia 25B citrodora Palau Lovage (leaf) Lovage, fresh leaves, Levisticum 25A (Levisticum 19A officinale W.D.J. Koch officinale) Lovage (leaf) Lovage, dried leaves, Levisticum 25B (Levisticum 19A officinale W.D.J. Koch officinale) Love-in-a-mist, fresh leaves, Nigella 25A damascena L. Love-in-a-mist, dried leaves, Nigella 25B damascena L. Mamaki, dried leaves, Pipturus 25B arborescens (Link) C. B. Rob. Marigold (Calendula Marigold, fresh leaves, Tagetes spp. 25A 19A officinalis) Marigold (Calendula Marigold, dried leaves, Tagetes spp. 25B 19A officinalis) Marigold, African, fresh leaves, Tagetes 25A erecta L. Marigold, African, dried leaves, Tagetes 25B erecta L. Marigold, Aztec, fresh leaves, Tagetes 25A minuta L.

Marigold, Aztec, dried leaves, Tagetes 25B minuta L. Marigold, French, fresh leaves, Tagetes 25A patula L. Marigold, French, dried leaves, Tagetes 25B patula L. Marigold, Irish lace, fresh leaves, Tagetes 25A filifolia Lag. Marigold, Irish lace, dried leaves, Tagetes 25B filifolia Lag. Marigold, licorice, fresh leaves, Tagetes 25A micrantha Cav. Marigold, licorice, dried leaves, Tagetes 25B micrantha Cav. Marigold, Mexican mint, fresh leaves, 25A Tagetes lucida Cav. Marigold, Mexican mint, dried leaves, 25B Tagetes lucida Cav. Marigold, signet, fresh leaves, Tagetes 25A tenuifolia Cav. Marigold, signet, dried leaves, Tagetes 25B tenuifolia Cav. Marjoram (Origanum spp.) (includes sweet or annual marjoram, Marjoram, fresh leaves, Origanum spp. 25A 19A wild marjoram or oregano, and pot marjoram) Marjoram (Origanum spp.) (includes sweet or annual marjoram, Marjoram, dried leaves, Origanum spp. 25B 19A wild marjoram or oregano, and pot marjoram) Marjoram, pot, fresh leaves, Origanum 25A onites L. Marjoram, pot, dried leaves, Origanum 25B onites L. Marjoram (Origanum spp.) (includes sweet Marjoram, sweet, fresh leaves, Origanum or annual marjoram, 25A 19A majorana L. wild marjoram or oregano, and pot marjoram)

Marjoram (Origanum spp.) (includes sweet Marjoram, sweet, dried leaves, Origanum or annual marjoram, 25B 19A majorana L. wild marjoram or oregano, and pot marjoram) Marshmallow, fresh leaves, Althaea 25A officinalis L. Marshmallow, dried leaves, Althaea 25B officinalis L. Meadowsweet, fresh leaves, Filipendula 25A ulmaria (L.) Maxim. Meadowsweet, dried leaves, Filipendula 25B ulmaria (L.) Maxim. Mint, fresh leaves, Mentha spp. 25A Mint, dried leaves, Mentha spp. 25B Mint, corn, fresh leaves, Mentha arvensis 25A L. Mint, corn, dried leaves, Mentha arvensis 25B L. Mint, Korean, fresh leaves, Agastache 25A rugosa (Fisch. & C. A. Mey.) Kun Mint, Korean, dried leaves, Agastache 25B rugosa (Fisch. & C. A. Mey.) Kun Monarda, fresh leaves, Monarda spp. 25A Monarda, dried leaves, Monarda spp. 25B Motherwort, fresh leaves, Leonurus 25A cardiaca L. Motherwort, dried leaves, Leonurus 25B cardiaca L. Mountainmint, fresh leaves, 25A Pycnanthemum spp. Mountainmint, dried leaves, 25B Pycnanthemum spp. Mountainmint, clustered, fresh leaves, 25A Pycnanthemum muticum (Michx.) Pers. Mountainmint, clustered, dried leaves, 25B Pycnanthemum muticum (Michx.) Pers. Mountainmint, hoary, fresh leaves, 25A Pycnanthemum incanum Michx. Mountainmint, hoary, dried leaves, 25B Pycnanthemum incanum Michx.

Mountainmint, Virginia, fresh leaves, Pycnanthemum virginianum (L.) T. 25A Durand & B.D. Jacks. Ex B.L. Rob. & Fernald Mountainmint, Virginia, dried leaves, Pycnanthemum virginianum (L.) T. 25B Durand & B.D. Jacks. ex B.L. Rob. & Fernald Mountainmint, whorled, fresh leaves, Pycnanthemum verticillatum (Michx.) 25A Pers. Mountainmint, whorled, dried leaves, Pycnanthemum verticillatum (Michx.) 25B Pers. Mugwort, fresh leaves, Artemisia vulgaris 25A L. Mugwort, dried leaves, Artemisia 25B vulgaris L. Mulberry, white, dried leaves, Morus 25B alba L. Mullein, fresh leaves, Verbascum 25A densiflorum Bertol. Mullein, dried leaves, Verbascum 25B densiflorum Bertol. Nasturtium, fresh leaves, Tropaeolum Nasturtium 25A 19A spp. (Tropaeolum majus) Nasturtium, dried leaves, Tropaeolum Nasturtium 25B 19A spp. (Tropaeolum majus) Nasturtium, bush fresh leaves, 25A Tropaeolum minus L. Nasturtium, bush dried leaves, 25B Tropaeolum minus L. Nasturtium, garden, fresh leaves, 25A Tropaeolum majus L. Nasturtium, garden, dried leaves, 25B Tropaeolum majus L. Nettle, fresh leaves, Urtica dioica L. 25A Nettle, dried leaves, Urtica dioica L. 25B Oregano, fresh leaves, Origanum vulgare 25A L. Oregano, dried leaves, Origanum vulgare 25B L. Oregano, Mexican, fresh leaves, Lippia 25A graveolens Kunth

Oregano, Mexican, dried leaves, Lippia 25B graveolens Kunth Oregano, Puerto Rico, fresh leaves, 25A Lippia micromera Schauer Oregano, Puerto Rico, dried leaves, 25B Lippia micromera Schauer Oswego tea, fresh leaves, Monarda 25A didyma L. Oswego tea, dried leaves, Monarda 25B didyma L. Pandan leaf, fresh leaves, Pandanus 25A amaryllifolius, Roxb. Pandan leaf, dried leaves, Pandanus 25B amaryllifolius, Roxb. Pansy, fresh leaves, Viola tricolor L. 25A Pansy, dried leaves, Viola tricolor L. 25B Paracress, fresh leaves, Acmella oleracea 25A (L.) R.K.Jansen Paracress, dried leaves, Acmella oleracea 25B (L.) R.K.Jansen Parsley (dried) Parsley, dried leaves, Petroselinum 25B (Petroselinum 19A crispum (Mill.) Fuss crispum) Pennyroyal, fresh leaves, Mentha Pennyroyal (Mentha 25A 19A pulegium L. pulegium) Pennyroyal, dried leaves, Mentha Pennyroyal (Mentha 25B 19A pulegium L. pulegium) Peppermint, fresh leaves, Mentha X 25A piperita L. Peppermint, dried leaves, Mentha X 25B piperita L. Perilla, fresh leaves, Perilla frutescens 25A (L.) Britton Perilla, dried leaves, Perilla frutescens 25B (L.) Britton Rooibos, dried leaves, Aspalathus 25B linearis (Burm. f.) R. Dahlgren Rose, fresh, Rosa spp. 25A Rose, dried, Rosa spp. 25B Rosemary Rosemary, fresh leaves, Rosmarinus 25A (Rosemarinus 19A officinalis L. officinalis) Rosemary Rosemary, dried leaves, Rosmarinus 25B (Rosemarinus 19A officinalis L. officinalis)

Sage (Salvia Sage, fresh leaves, Salvia officinalis L. 25A 19A officinalis) Sage (Salvia Sage, dried leaves, Salvia officinalis L. 25B 19A officinalis) Sage, Greek, fresh leaves, Salvia 25A fruticosa Mill. Sage, Greek, dried leaves, Salvia 25B fruticosa Mill. Sage, Spanish, fresh leaves, Salvia 25A lavandulifolia Vahl Sage, Spanish, dried leaves, Salvia 25B lavandulifolia Vahl Savory, summer, fresh leaves, Satureja Savory, summer and 25A 19A hortensis L. winter (Satureja spp.) Savory, summer, dried leaves, Satureja Savory, summer and 25B 19A hortensis L. winter (Satureja spp.) Savory, winter, fresh leaves, Satureja Savory, summer and 25A 19A montana L. winter (Satureja spp.) Savory, winter, dried leaves, Satureja Savory, summer and 25B 19A montana L. winter (Satureja spp.) Sorrel, fresh leaves, Rumex spp. 25A Sorrel, dried leaves, Rumex spp. 25B Sorrel, French, fresh leaves, Rumex 25A scutatus L. Sorrel, French, dried leaves, Rumex 25B scutatus L. Sorrel, garden, fresh leaves, Rumex 25A acetosa L. Sorrel, garden, dried leaves, Rumex 25B acetosa L. Southernwood, fresh leaves, Artemisia 25A abrotanum L. Southernwood, dried leaves, Artemisia 25B abrotanum L. Spearmint, fresh leaves, Mentha spicata 25A L. Spearmint, dried leaves, Mentha spicata 25B L. Spearmint, Scotch, fresh leaves, Mentha x 25A gracilis Sole Spearmint, Scotch, dried leaves, Mentha x 25B gracilis Sole Spotted beebalm, fresh leaves, Monarda 25A punctata L.

Spotted beebalm, dried leaves, Monarda 25B punctata L. Squaw vine, dried leaves, Mitchella 25B repens L. St. John’s Wort, dried leaves, Hypericum 25B perforatum L. Stevia, dried leaves, Stevia rebaudiana 25B (Bertoni) Bertoni Swamp leaf, fresh leaves, Limnophila 25A chinensis (Osbeck) Merr. Tansy, fresh leaves, Tanacetum vulgare Tansy (Tanacetum 25A 19A L. vulgare) Tansy, dried leaves, Tanacetum vulgare Tansy (Tanacetum 25B 19A L. vulgare) Tarragon, fresh leaves, Artemisia Tarragon (Artemisia 25A 19A dracunculus L. dracunculus) Tarragon, dried leaves, Artemisia Tarragon (Artemisia 25B 19A dracunculus L. dracunculus) Thyme, fresh leaves, Thymus spp. 25A Thyme (Thymus spp.) 19A Thyme, dried leaves, Thymus spp. 25B Thyme (Thymus spp.) 19A Thyme, creeping, fresh leaves, Thymus 25A serpyllum L. Thyme, creeping, dried leaves, Thymus 25B serpyllum L. Thyme, lemon, fresh leaves, Thymus 25A ×citriodorus (Pers.) Schreb. Thyme, lemon, dried leaves, Thymus 25B ×citriodorus (Pers.) Schreb. Thyme, mastic, fresh leaves, Thymus 25A mastichina (L.) L. Thyme, mastic, dried leaves, Thymus 25B mastichina (L.) L. Toon, Chinese, fresh leaves, Toona 25A sinensis (A. Juss.) M. Roem. Toon, Chinese, dried leaves, Toona 25B sinensis (A. Juss.) M. Roem. Vasaka, dried leaves, Justicia adhatoda 25B L. Veronica, fresh leaves, Veronica 25A officinalis L. Violet, fresh leaves, Viola odorata L. 25A Violet, dried leaves, Viola odorata L. 25B Watermint, fresh leaves, Mentha aquatica 25A L.

Watermint, dried leaves, Mentha aquatica 25B L. Waterpepper, fresh leaves, Persicaria 25A hydropiper (L.) Delarbre Wild bergamot, fresh leaves, Monarda 25A fistulosa L. Wild bergamot, dried leaves, Monarda 25B fistulosa L. Wintergreen Wintergreen, fresh leaves, Gaultheria 25A (Gaultheria 19A procumbens L. procumbens) Wintergreen Wintergreen, dried leaves, Gaultheria 25B (Gaultheria 19A procumbens L. procumbens) Wood betony, dried leaves, Stachys Woodruff (Galium 25B 19A officinalis (L.) Trevis. odorata) Woodruff, fresh leaves, Galium odoratum Woodruff (Galium 25A 19A (L.) Scop odorata) Woodruff, dried leaves, Galium odoratum 25B (L.) Scop Wormwood Wormwood, fresh leaves, Artemisia 25A (Artemisia 19A absinthium L. absinthium) Wormwood Wormwood, dried leaves, Artemisia 25B (Artemisia 19A absinthium L. absinthium) Wormwood, Roman, fresh leaves, 25A Artemisia pontica L. Wormwood, Roman, dried leaves, 25B Artemisia pontica L. Yarrow, fresh leaves, Achillea 25A millefolium L. Yarrow, dried leaves, Achillea 25B millefolium L. Yellow gentian, fresh leaves, Gentiana 25A lutea L. Yellow gentian, dried leaves, Gentiana 25B lutea L. Yerba santa, fresh leaves, Eriodictyon 25A californicum (Hook. & Arn.) Torr. Yerba santa, dried leaves, Eriodictyon 25B californicum (Hook. & Arn.) Torr. Yomogi, fresh leaves, Artemisia princeps 25A L.

Yomogi, dried leaves, Artemisia princeps 25B L. Note: one crop, Rue (Ruta graveolens), is in the existing herb subgroup but is not part of the new Herb Crop Group, and is instead now part of the new Spice Crop Group.

Table A-2. Correspondence Between the Current Crop Group and the Proposed Spice Crop Group Related Related Commodities in the Commodities in the New Spice Group crop crop Existing Spice Subgroup subgroups subgroups

Ajowan, seed, Trachyspermum ammi (L.) 26 Sprague ex Turrill Allspice, Pimenta dioica (L.) Merr. 26 Allspice (Pimenta dioica) 19B Ambrette seed, Abelmoschus esculentus (L.) 26 Moench Amia, Phyllanthus amarus Schumach 26 Angelica, seed, Angelica archangelica L. 26 Angostura bark, Angostura trifoliata (Willd.) 26 T. S. Elias Anise (anise seed) Anise seed, Pimpinella anisum L. 26 19B (Pimpinella anisum) Anise pepper, Zanthoxylum piperitum (L.) DC. 26 Anise, star (Illicium Anise, star, Illicium verum Hook. f. 26 19B verum) Annatto seed, Bixa orellana L. 26 Annatto (seed) 19B Asafoetida, Ferula assa-foetida L. 26 Ashwagandha, fruit, Withania somnifera (L.) 26 Dunal Balsam, Peruvian, Myroxylon balsamum (L.) 26 Harms var. pereirae (Royle) Harms Batavia-cassia, bark, Cinnamomum burmanni 26 (Nees & T. Nees) Blume Batavia-cassia, fruit, Cinnamomum burmanni 26 (Nees & T. Nees) Blume Belleric myrobalan, Terminalia bellirica 26 (Gaertn.) Roxb. Betel vine, Piper betle L. 26 Black bread weed, Nigella arvensis L. 26 Blue mallee, Eucalyptus polybractea R. T. 26 Baker Boldo, leaves, Peumus boldus Molina 26 Buchi, Agathosma betulina (P. J. Bergius) 26 Pillans 35

Calamus-root, Acorus calamus L. 26 Candlebush, Senna alata (L.) Roxb. 26 Canella bark, Canella winterana (L.) Gaertn. 26 Caper buds (Capparis Caper buds, Capparis spinosa L. 26 19B spinosa) Caraway, fruit, Carum carvi L. 26 Caraway (Carum carvi) 19B Caraway, black (Nigella Caraway, black, Nigella sativa L. 26 19B sativa) Cardamom (Elettaria Cardamom, black, Amomum spp. 26 19B cardamomum) Cardamom, Ethiopian, Aframomum corrorima 26 (A. Braun) P. C. M. Jansen Cardamom, green, Elettaria cardamomum (L.) 26 Maton Cardamom, Nepal, Amomum subulatum Roxb., 26 Amomum aromaticum Roxb. Cardamon-amomum, Amomum compactum 26 Sol. ex Maton Cascada buckthorn, bark, Frangula purshiana 26 (DC.) A. Gray Cassia bark (Cinnamomum Cassia bark, Cinnamomum spp. 26 19B aromaticum) Cassia buds Cassia fruit, Cinnamomum spp. 26 (Cinnamomum 19B aromaticum) Cassia, Chinese, fruit, Cinnamomum 26 aromaticum Nees. Cassia, Chinese, bark, Cinnamomum 26 aromaticum Nees. Cat’s claw, roots, Uncaria tomentosa (Willd.) 26 DC., Uncaria guianensis (Aubl.) J. F. Gmel. Catechu, bark, Senegalia catechu (L. f.) P. J. 26 H. Hurter & Mabb. Celery seed, Apium graveolens var. dulce Celery seed (Apicum 26 19B (Mill.) Pers. graveolens) Chervil, seed, Anthriscus cerefolium (L.) 26 Hoffm. Chasteberry, berry, Vitex negundo L. 26 Chinesetree, roots, Vitex negundo L. 26 Chinese hawthorn, Crataegus pinnatifida 26 Bunge Chinese nutmeg tree, Torreya grandis Fortune 26 Chinese-pepper, Zanthoxylum simulans Hance 26

Chinese prickly-ash, Zanthoxylum bungeanum 26 Maxim Cinnamon (Cinnamomum Cinnamon, bark, Cinnamomum verum J. Presl 26 19B verum) Cinnamon (Cinnamomum Cinnamon, fruit, Cinnamomum verum J. Presl 26 19B verum) Cinnamon, Saigon, bark, Cinnamomum 26 loureiroi Nees Cinnamon, Saigon, fruit, Cinnamomum 26 loureiroi Nees Clove buds, Syzygium aromaticum (L.) Merr. Clove buds (Eugenia 26 19B & L.M. Perry caryophyllata) Copaiba, Copaifera officinalis (Jacq.) L. 26 Coptis, Coptis chinensis Franch., Coptis spp. 26 Coriander, fruit, Coriandrum sativum L. 26 Coriander (cilantro) (seed) Coriander, seed, Coriandrum sativum L. 26 19B (Coriandrum sativum) Cubeb, seed, Piper cubeba L. f. 26 Culantro (seed) (Eryngium Culantro, seed, Eryngium foetidum L. 26 19B foetidum) Cumin (Cuminum Cumin, Cuminum cyminum L 26 19B cyminum) Cumin, black, Bunium persicum (Boiss.) B. 26 Fedtsch. Daharian angelica, leaves, Angelica dahurica 26 (Hoffm.) Benth. & Hook. f. ex Franch. & Sav. Daharian angelica, seed, Angelica dahurica 26 (Hoffm.) Benth. & Hook. f. ex Franch. & Sav. Damiana leaf, Turnera diffusa Willd. 26 Dill (seed) (Anethum Dill, seed, Anethum graveolens L. 26 19B graveolens) Dorrigo pepper, berry, Tasmannia stipitata 26 (Vick.) A.C. Smith Dorrigo pepper, leaf, Tasmannia stipitata 26 (Vick.) A.C. Smith Epimedium, Epimedium spp. 26 Eucalyptus, Eucalyptus spp. 26 Eucommia, bark, Eucommia ulmoides Oliv. 26 Felty germander, Teucrium polium L. 26 Fennel, common, fruit, Foeniculum vulgare 26 Mill. subsp. vulgare var. vulgare Fennel, common, seed, Foeniculum vulgare Fennel (common) 26 19B Mill. subsp. vulgare var. vulgare (Foeniculum vulgare)

Fennel, Florence, fruit, Foeniculum vulgare Mill. subsp. vulgare var. azoricum (Mill.) 26 Thell. Fennel, Florence, seed, Foeniculum vulgare Fennel, Florence (seed) Mill. subsp. vulgare var. azoricum (Mill.) 26 (Foeniculum vulgare 19B Thell. Azoricum Group) Fennel flower, seed, Nigella hispanica L. 26 Fenugreek, seed, Trigonella foenum-graecum Fenugreek (Trigonella 26 19B L. foenumgraecum) Fingerroot, Boesenbergia rotunda (L.) Mansf. 26 Frankincense, Boswellia sacra Flueck. 26 Frankincense, Indian, Boswellia serrata Roxb. 26 ex Colebr. Galbanum, Ferula gummosa Boiss. 26 Gambooge, Garcinia gummi-gutta (L.) N. 26 Robson Grains of Paradise, Aframomum melegueta K. Grains of paradise 26 19B Schum. (Aframomum melegueta) Grains of Selim, Xylopia aethiopica (Dunal) A. 26 Rich. Guarana, Paullinia cupana Kunt 26 Guaiac, Guaiacum officinale L. 26 Guggul, Commiphora wightii (Arn.) Bhandari 26 Gum arabic, Senegalia senegal (L.) Britton 26 Gum ghatti, Anogeissus latifolia (Roxb. ex 26 DC.) Wall. ex Guill. & Perr. Gum karaya, Stercula urens Roxb. 26 Gum tragacanth, Astragalus gummifer Labill. 26 Gymnema, dried leaves Gymnema sylvestre 26 (Retz.) Schult. Haw, black, Viburnum prunifolium L. 26 Honewort, seed, Cryptotaenia canadensis (L.) 26 DC. Imperatoria, Peucedanum officinale L. 26 Iva, Achillea erba-rotta All. subsp. moschata 26 (Wulfen) I. Richardson Jalap, Ipomoea purga (Wender.) Hayne 26 Juniper berry (Juniperus Juniper berry, Juniperus communis L. 26 19B communis) Kaffir lime, leaf, Citrus hystrix DC. 26 Kewra, Pandanus fascicularis Lam. 26 Kokam, Garcinia indica (Thouars) Choisy 26 Linden, dried leaves, Tilia americana L. 26

Lovage, seed, Levisticum officinale W.D.J. Lovage (seed) (Levisticum 26 19B Koch officinale) Mace, Myristica fragrans Houtt. 26 Mace (Myristica fragrans) 19B Magnolia-bark, Magnolia officinalis Rehder & 26 E. H. Wilson Mahaleb, Prunus mahaleb L. 26 Malabar cardamom, Amomum villosum Lour. 26 Malabathrum, Cinnamomum tamala (Buch- 26 Ham.) Nees & Eberm. Malabar-tamarind, Garcinia spp. 26 Mastic, Pistacia lentiscus L. 26 Micromeria, white, Micromeria fruticosa (L.) 26 Druce Milk thistle, Silybum marianum (L.) Gaertn. 26 Mioga, Zingiber mioga (Thunb.) Roscoe 26 Miracle fruit, Synsepalum dulcificum 26 (Schumach. & Thonn.) Daniell Mustard (seed) (Brassica Mustard seed, Brassica spp. and Sinapis spp. 26 19B juncea, B. hirta, B. nigra) Mustard, black, Brassica nigra (L.) W.D.J. Mustard (seed) (Brassica 26 Koch juncea, B. hirta, B. nigra) Mustard, brown, Brassica juncea (L.) Czern. Mustard (seed) (Brassica 26 var. juncea juncea, B. hirta, B. nigra) Mustard, white, Sinapis alba L. ssp. alba 26 Myrrh, Commiphora myrrha (Nees) Engl., 26 Commiphora africana (A. Rich.) Engl. Myrrh, bisabol, Commiphora kataf (Forssk.) 26 Engl Myrtle, dried leaves, Myrtus communis L. 26 Myrtle, anise, Syzygium anisatum (Vickery) 26 Craven & Biffen Myrtle, lemon, Backhousia citriodora F. 26 Muell. Nasturtium, pods, Tropaeolum spp 26 Nasturtium, bush, pods, Tropaeolum minus L. 26 Nasturtium, garden, pods, Tropaeolum majus 26 L. Nutmeg (Myristica Nutmeg, Myristica fragrans Houtt. 26 19B fragrans) Pepper, black (Piper Pepper, black, Piper nigrum L. 26 19B nigrum) Pepper, white, Piper nigrum L. 26 Pepper, white 19B Pepper, Cubeb, Piper cubeba L. f. 26

Pepper, Indian long, Piper longum L. 26 Pepper, leaf, Piper auritum Kunth, Piper lolot C.DC, Piper sanctum (Miq.) Schltdl., Piper 26 umbellatum L. Pepper, long, Piper longum L. 26 Pepper, Javanese Long, Piper retrofractum 26 Vahl. Pepper, Sichuan, Zanthoxylum spp. 26 Pepperbush, berry, Tasmannia spp. 26 Pepperbush, leaf, Tasmannia spp. 26 Peppertree, Schinus spp. 26 Peppertree, Brazilian, Schinus terebinthifolius 26 Raddi Peppertree, Peruvian, Schinus molle L. 26 Perilla leaf, Perilla frutescens (L.) Britton 26 Perilla seed, Perilla frutescens (L.) Britton 26 Pine, maritime, Pinus pinaster Aiton 26 Pipsissewa, leaves, Chimaphila umbellata (L.) 26 W. P. C. Barton Poppy seed, Papaver somniferum L. subsp. Poppy (seed) (Papaver 26 19B somniferum somniferum) Pygeum, Prunus africana (Hook.f.) Kalkman 26 Quassia, bark, Quassia amara L. 26 Quebracho bark, Aspidosperma quebracho- 26 blanco Schltdl. Quinine, Cinchona pubescens Vahl 26 Qing hua jiao, Zanthoxylum schinifolium 26 Siebold & Zucc Quillaja, Quillaja saponaria Molina 26 Rue, Ruta graveolens L 26 Rue, Ruta graveolens L 19A Saffron crocus, Crocus sativus L. 26 Saffron (Crocus sativus) 19B Sassafras, leaves, Sassafras albidum (Nutt.) 26 Nees Saunders, red, Pterocarpus santalinus L. f. 26 Simaruba, bark, Simarouba amara Aubl. 26 Slippery elm, Ulmus rubra Muhl. 26 Sumac, fragrant, Rhus aromatica Aiton 26 Sumac, smooth leaf, Rhus glabra L. 26 Tasmanian pepper berry, Tasmannia 26 lanceolata (Poir.) A. C. Sm Tasmanian pepper leaf, Tasmannia lanceolata 26 (Poir.) A. C. Sm. Tsao-Ko, Amomum tsao-ko Crevost & Lemarié 26

Vanilla (Vanilla Vanilla, Vanilla planifolia Jacks. 26 19B planifolia) Wattleseed, Acacia spp. 26 White willow, Salix alba L. 26 Willow, Salix spp. 26 Yellow gentian, roots, Gentiana lutea L. 26