Thank you all for your input. It looks like FWS do need to have the ginseng tops certified. Since there is no way to certify the leaves, I guess the leaves/prongs have to be on the stems to be certified.
It is a gray area, no clear language is available. except that you can only harvest five years or older any parts of the plant when the season starts.
However, like fibers, we can not export the leaves out of the country as they can't determine the age.
Woods grown is cultivated ginseng and there is no problem and may be the only way to go.
