Presence of Cirsium arvense in Vietnam Shipments

Presence of Cirsium arvense in Vietnam Shipments

NAEGA is continuing to follow ongoing market access issues regarding weed seed presence in U.S. shipments to Vietnam. On August 21, 2018 USDA’s Animal and Plant Health Inspection Service (APHIS) sent a letter to Hoang Trung, Director General of Vietnam’s Plant Protection Department (PPD) regarding the presence of Cirsium arvense (Canadian thistle) seed in U.S. grain shipments. According to the letter, APHIS is investigating the incidence of Cirsium arvense in U.S. export grain, both through evaluation of available scientific literature on and the grain pathway, and by review of export grain samples over a six year period.


APHIS has been working on the Cirsium arvense issue with Vietnam since June 2018.  Currently, there is a November 1 deadline in place which states that, if Cirsium arvense is detected after this date, consignments will be re-exported, and there will be a risk of suspension of U.S. grain imports. 

Currently, APHIS is engaged on a technical basis, and has proposed a bilateral meeting in the U.S. in early December 2018 to address the issue. In the meantime, APHIS has provided a pathway risk analysis in which it was argued that there is a low risk not only of Canada thistle seed being present in the grain pathway and consequently low risk of entry into Vietnam, but that with Vietnam’s tropical climate, the fragility and low germination of the seed, and the intended use of processing are taken into consideration, there is a very low risk of establishment.  Additionally, APHIS provided an identification key for thistle, noting that there are a number of other thistle seeds sharing much of the same morphology with Cirsium arvense, and inviting a technical exchange.

In response to these claims, Vietnam has stated that there is a high probability of introduction and according to international practice the appropriate level of protection for Cirsium arvense is zero at arrival of all consignments. 

NAEGA continues to monitor this situation and is pressing for a global and across U.S. Government coordinated response. NAEGA believes that Ukraine and Australia have already secured an accommodation.

As this situation continues to develop, NAEGA is seeking member input and recommendations for appropriate paths forward. Additional background information can be found below:

  1. APHIS letter to Vietnam PPD – August 21, 2018
  2. Vietnam PPD letter to APHIS – September 5, 2018
  3. PPD Exporter Announcement of November 1 Deadline