After some digging, I found the regulation that relates to daffodil bulbs on the U.S. Department of Agriculture web site.
http://www.aphis.usda.gov/import_export/plants/plant_imports/downloads/q37-3circular1-2006.pdf
The fourth bullet under “Bulbs That Require a Written Permit” exempts (dormant) bulbs; however, as it says, any sign of growth means it is considered “nursery stock” and not a “bulb.” Apparently “bulb” by definition is dormant, and as it says at the top, “Most bulbs do not require a written permit for entry.” The third bullet under “Other Bulb Restrictions” says “more than 12 pieces require a written permit.” These are pieces of nursery stock, not bulbs. Presumably, if you have 12 or fewer bulbs and some of them show growth, it’s still okay not to have the written permit. However, it is possible that there are agricultural agents in the U.S. (and abroad) that don’t know exactly what the above URL says, and the odds of convincing them to read it are probably small.
Now, yesterday I left a voice message at the U.S. Animal and Plant Health Inspection Service (APHIS) and was pleased when an employee returned my call this morning. She confirmed that the policy in the cited URL is current and that I should be able to receive (dormant) daffodil bulbs with a proper phytosanitary certificate and without an import permit. She did admit that not all agents know precisely what the policy is, and it would be safer for the parcel to include a copy of the import permit as well as to have the parcel go through a plant inspection station rather than directly to the purchaser. Also, a less well-informed agent at the port of entry could notice some roots starting to come out or a green leaf tip and declare it “nursery stock” rather than “bulb”, thus needing an import permit. Or the agent might not know it’s okay to have more than 12 bulbs as long as they are all dormant.
So the still unanswered question is how should Americans purchase bulbs from overseas. I have not had any problems directly receiving(dormant) bulbs from the United Kingdom or New Zealand. Sometimes a USDA agent will open the parcel, keep the phytosanitary certificate, reseal the parcel, and send the parcel on to me. The sealing tape proclaims the USDA did the opening. I have not been chastised for not including proof of an import permit. Jason on the other hand has been less fortunate, perhaps because the agriculture people in Atlanta are not fully about dormant bulbs (or because they were showing growth). Australia, however, is convinced that the U.S. does require import permits for daffodil bulbs, so it is simpler to send the grower a copy of your permit than to ask them to change the Australian regulations.
If anyone else has some good ideas about how best to assure that legal overseas purchases of daffodil bulbs get through the port of entry, please post them to Daffnet.
Kirby Fong