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Importation of Soil Amendments or

Plant Health Enhancers, (Including

Fertilizers, Compost, Sludge, and

Other Materials Used to Enhance

Plant Growth

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The Animal and Plant Health Inspection Services (APHIS) of the United States

Department of Agriculture (USDA) is charged with protecting the health and value of

American agriculture and natural resources from the introduction of destructive

plant and animal diseases and pests. USDA-APHIS processes permit applications for

a variety of organic soil amendments/plant health enhancers from various countries

for commercial purposes.

These commodities have numerous names that typically are descriptive of their

intended use, but the products typically contain living microorganisms and plant

and/or plant parts that may have been composted or mechanically processed.

Permits or other documentation may be required for entry of these products into the

U.S. from foreign countries, and in the absence of these documents, shipments can

be denied entry. The following guidance is intended to assist potential importers of
these commodities. Individuals wishing to import these commodities must also

follow the statutes of other regulatory agencies and programs such as the

Environmental Protection Agency (EPA), Centers for Disease Control (CDC), Food and

Drug Administration (FDA), and Fish and Wildlife Services (FWS), etc.  State

Departments of Agriculture may regulate fertilizers, and they may issue permits or

other documentations authorizing the use of domestic products within their States. 

Please note that State Departments of Agriculture do not regulate foreign

commerce, and their documentation is not sufficient for the entry of these products

into the U.S.

What are soil amendments/ plant health

enhancers?

Soil amendments/plant health or growth enhancers are materials that typically are

added to soil, plants, or the plant-growth environment to enhance plant growth.

These include fertilizers, compost, sludge, manure, microbes, additives, and others

or combinations thereof. For regulatory purposes any material that meets this

definition will be called ‘Plant Growth Enhancer.’

Plant Growth Enhancers (PGEs)

PGEs may enhance plant growth by various mechanisms. These include: providing

supporting nutrients (fertilizers), and improving soil condition (i.e., adjusting the pH

of the soil, improving soil structure and texture, aeration adjustment, and moisture

conservation among others), or controlling or suppressing plant pests. These PGEs

could contain organic and inorganic components, and could be of natural or

synthetic origin. Inorganic PGEs are composed of synthetic chemicals and/or

minerals, while organic PGEs are often composed of organic matter from

plant/animal sources, and/or microbes. Thus, organic amendments may include

materials such as manure, earthworm castings, soil, sphagnum peat, grass clippings,

straw, wood chips, various composts, seaweed, guano, or naturally occurring

mineral deposits (e.g. saltpeter), and living microorganisms among others.
Regulatory policy pertaining to the importation of

PGEs into the U.S

PGEs have the potential to contain pests or plants and plant parts that present a risk

to American agriculture and the environment. Therefore, release of these

commodities into the environment could be detrimental to U.S. agriculture and the

environment. APHIS regulates living organisms that could impact animal and plant

health. These products could contain human and animal pathogens, which may be

regulated by other agencies.  APHIS has the authority to regulate microbial

organisms that are biocontrol organisms or have biopesticidal properties.  See “

Guidelines and Regulations for Microbial Pathogens Used to Control Invertebrate

Plant Pests” for more information.  

APHIS may also regulate many of the following components: microbial organisms,

mollusks, arthropods, nematodes, plants and plant parts, noxious weed seeds, soil,

earthworm castings and animal products such as manure and bedding materials.

Animal products that may present a risk to animal health are regulated by APHIS

Veterinary Services (VS). VS may be contacted by email at APIE@usda.gov or by

phone at 301-851-3300. For information pertaining to soil, plant and plant products,

organisms, and biocontrol/microbial biopesticides, contact APHIS Plant Protection

and Quarantine (PPQ) by email at pest.permits@usda.gov, or by phone at 866-524-

5421. Other Federal, State, and local Agencies may also regulate these products.

Permitting policy pertaining to the importation of

PGEs into the U.S

APHIS can either authorize importation through the issuance of a permit, or

deny the application, because there is no acceptable safeguard to mitigate the

risk associated with a commodity that contains plant pests or

biocontrol/biopesticide organism, if the application is for environmental release.

APHIS could authorize importation of the commodity into containment for

further research, but deny its release into the environment.

Permit applications for environment release require rigorous evaluation and

may be subject to regulations of other Agencies.  Permits for research that

includes environmental release can only be authorized for field studies of 10
acres or less. See below for a questionnaire that will enable importers to

provide required information to APHIS.

APHIS also evaluates the media in which the organisms are contained to ensure

that it is free of plant or animal health risk.

If APHIS determines that the PGEs do not represent a pest risk to American

agriculture or the environment, APHIS is still required to meet the requirements

of the National Environmental Policy Act (NEPA) and the FWS Endangered

Species Act (ESA) prior to authorization of the entry and release of these

commodities into the U.S. APHIS will issue letters of decision on a case-by-case

basis following the evaluation of the risk associated with the components of the

product.

Letters of decision include; “letters of denial,” “letters of no permit required,” or

“letters of no jurisdiction.”  Letters of no permit required or letters of no

jurisdiction should accompany shipments in order to facilitate entry into the

U.S.  A letter of denial will indicate that APHIS will not issue a permit, based on

the risk to American agriculture.

If a product is authorized to enter the U.S., certificates of purity and identity

may be required.

What is not regulated?

PGEs that are free of organic material; organic materials that are exempt from

USDA regulations are described in the soil circular (50.67 KB). These include

volcanic rock, pumice, and peat (if processed to uniform consistency and are

free of plant parts and seed). Sterile media is not regulated, and certification of

the sterilization process is required.

PGEs that only contain pure cultures of organisms of known identity that are

not human, animal, or plant pests or pathogens or biocontrol

organisms/biopesticides.

From what locations are the PGEs regulated?

All foreign sources, Hawaii, and all U.S. territories.

Parts of U.S. under Federal quarantine as authorized under 7CFR 301

regulations and quarantines.
What information is required by APHIS to

facilitate the evaluation and decision process?

Please provide answers to the following questions as well as the additional

information requested below:

1. If your product contain live organisms, please:

Provide a complete scientific name and strain for each microbe; the

country where the organism was originally isolated; and the environment

where it was isolated (e.g., soil, water, animal, plant, detritus, etc.).

Indicate if the presence of each microbe was confirmed in your final

product as determined by an analysis. If so, please describe the method

used and provide a copy of the results.

Provide data and scientific literature citations addressing whether each

microbe is pathogenic (or non-pathogenic) to plants, humans, animals, and

non-target organisms likely to be present in the environment where the

material will be released, if applicable.

2. Please provide a complete list of all ingredients in each product.

3. Please indicate whether your product is for research or commercial purposes

(sale / distribution). If for research, please specify if for field, laboratory, growth

chamber, and/ or greenhouse use.

4. Does your product contain soil? Does your product contain earthworm castings,

sludge, manure, farm waste, or other organic materials? Please describe.

5. Does your product contain plant matter including decaying materials? Please

describe where the plant matter was obtained and/ or what it was derived from.

6. Has your product been processed or treated? If so, please describe such

processing or treatment and provide a detailed protocol for each method.

7. Please describe the mechanism of action by which the product enhances plant

growth. Provide the scientific basis for such mechanism of action.

8. Does it target and/ or control a plant pest(s) or noxious weed? If so, what is the

target pest(s) and/ or noxious weed?

9. Have the microbes been reported in the scientific literature to produce toxins or

antibiotics? If yes, do you believe these have a role in providing the intended

plant health benefit? Please describe.
Please Note: Answers to the questions can be supplemented with file attachments,

photos etc. Also, follow-up questions may be asked.

Commercial sale of imported PGEs containing organic matter and/or organisms of

unknown identity is not authorized unless the material has been treated to destroy

all organisms, Federal noxious weed seeds, and other contaminants. These

treatments are similar to those approved for soil. For additional information, see the

APHIS Regulated Organism and Soil Permits Web site.  Please contact APHIS before

shipment of such materials.

Additional Information

APHIS Web Sites

Regulated Organism and Soil Permits

Earthworm Policy

Earthworm- (FAQs)

Outside of APHIS

Environmental Protection Agency and Pesticide Registration

Centers for Disease Control and Prevention

Food and Drug Administration

U.S. Fish and Wildlife Service

Contact Information

For questions about permits for regulated organisms and soil:

Pest Permits Team

Email: pest.permits@usda.gov

Phone: 301-851-2285

Alt-Phone: 866-524-5421
For PPQ/VS 

Email: APIE@usda.gov

Telephone:  301-851-3300.