Nobody welcomes criticism, especially at a national level.   At times, ‘nettles’ must be grasped, IF those drafting such rules and regulations are SERIOUS about achieving their objectives.  A better understanding of what is involved in reliably identifying plants and assessing rarity is required and then the mammoth task of promoting, in these days of high-tech, laboratory science, the need for and value of, old-fashioned field-skills and herbarium botany. 
We are NOT setting a good example in Europe or North America.  Field and herbarium botanists are dying breed….And for these changes to ultimately lead  to  success conserving species in the Himalaya, greater collaboration is required between scientists of the signatory countries to the convention.  It is NOT from a position of virtue, much as fortunate and grateful to be a British citizen, living in Britain, that as a Britisher (as we are still, mostly affectionately known in India) take it upon to draw attention to what should be happening in other countries, particularly former ‘colonies’.