Market
In the United States, dried butterfly pea (Clitoria ternatea) is a niche botanical ingredient used in herbal infusions and as an input for butterfly pea flower extract, a color additive listed in 21 CFR § 73.69 for specified food and beverage categories. The U.S. market functions primarily as an import-dependent consumer and ingredient market, with imports subject to FDA food import controls (including Prior Notice and FSMA/FSVP importer obligations) and customs entry workflows. Plant-health admissibility depends on product presentation and origin; APHIS guidance indicates certain commercially packaged dried teas/herbal infusions can be generally admissible, but importers should verify conditions in ACIR for their exact commodity. The most material risks are compliance failures tied to pesticide residues, documentation errors at entry, and mispositioning/labeling when the ingredient is marketed for coloring versus tea use.
Market RoleImport-dependent consumer and food-ingredient market
Domestic RoleSpecialty botanical ingredient used in herbal infusions and in downstream natural-color formulation supply chains
SeasonalityYear-round availability is typical due to shelf-stable dried form and import-driven supply.
Risks
Food Safety HighShipments of imported dried botanicals/foods can face detention without physical examination (DWPE) or refusal if illegal pesticide residues are detected, disrupting supply continuity for U.S. buyers.Implement FSVP-aligned supplier approval, require pesticide-residue testing/COAs, and monitor FDA import alerts affecting relevant product categories and origins.
Regulatory Compliance MediumIf the product is positioned for coloring use (e.g., processed into butterfly pea flower extract), U.S. color additive specifications, use restrictions, and labeling rules apply; mispositioning or off-spec material can trigger enforcement action.Confirm intended use (infusion ingredient vs. color additive), align labeling, and ensure any extract production meets 21 CFR § 73.69 specifications (including heavy metal limits) and GMP.
Documentation Gap MediumFailure to submit accurate FDA Prior Notice for imported food shipments can result in refusal and mandatory holds at the port of entry.Standardize entry data (manufacturer/shipper, product identifiers, quantities) and submit Prior Notice via ABI/ACE or FDA PNSI within required timeframes.
Regulatory Compliance MediumSome plant products may require a Lacey Act declaration depending on HTS classification and formal entry conditions; missing species/origin details can create penalty and seizure exposure.Maintain species-level identification and harvest-country records; file Lacey Act declarations via ACE or LAWGS when required and validate HTS-based applicability.
Sustainability- Legal harvest and supply-chain due diligence for plant products (Lacey Act ‘due care’ expectations where declarations apply)
FAQ
Do U.S. imports of dried butterfly pea for tea use require FDA Prior Notice?If the shipment is a food (including food ingredients), FDA generally requires Prior Notice before it is offered for import into the United States, submitted electronically via CBP systems or FDA’s Prior Notice System Interface.
Can butterfly pea be used legally as a color additive in the United States?Butterfly pea flower extract is listed in U.S. regulations as a color additive exempt from certification with defined specifications and permitted uses (for example, it is permitted to color certain beverages and foods listed in 21 CFR § 73.69), and it must be used consistent with good manufacturing practice and applicable restrictions.
Does USDA APHIS generally require a permit or phytosanitary certificate for commercially packaged dried herbal teas/infusions?APHIS publishes a list of generally authorized non-propagative plant products indicating certain commercially packaged dried teas, herbal teas, and herbal infusions can be generally admissible without a permit or phytosanitary certificate under stated conditions; importers should still confirm the exact commodity/origin requirements in APHIS ACIR for their specific product.