2454 final report.pdf - Agra CEAS Consulting

Evaluation of the Community Plant Health Regime: Final Report
DG SANCO Evaluation Framework Contract Lot 3 (Food Chain)
measures to regulate non quarantine pests, i.e. to apply an official control programme for the
mentioned HOs. It notes that the same instruments (protected zones, plant passports, registration
and yearly compulsory checks) used for RQPs can be used for RNQPs.
Based on the IPPC defining criteria, the Commission working group arrived at the conclusions
that the following organisms might qualify as RNQPs:
Most likely HOs listed in Annex II, Part A, Section II to Directive 2000/29/EC (“HOs known
to occur in the Community and relevant for the entire Community” 100 ), and possibly HOs
listed in other Annexes such as Annex I, Part A, Section II and Annex II, Part B;
HOS for which plant health requirements are listed in the S&PM Directives (i.e. those “HOs
which reduce the usefulness of the seed and plant propagating material shall be at the lowest
possible level”), in particular those transmitted on plants for planting.
This working group highlighted several issues related to the definition and implementation of the
RNQPs in the EU regulation. The main ones can be listed as follows:
As a RNQP should be ―present and maybe widely distributed‖, the question is who assesses
the presence or not of the given HOs, on which criteria and how to qualify these;
The concept of RNQPs applies to plants for planting, which includes seeds and potted plants.
How can the criterion that plants for planting are ―the‖ main source of pest infestation be
assessed;
How to segregate commercial from non-commercial use, as required by ISPM No. 16? Is this
always feasible?
ISPM No. 16 refers to specific plants (species, varieties, etc.) and ISPM No. 21 indicates that
generally the taxonomic unit is the species, leading to the question how to anticipate
problems when a given HO is present on several species.
The report concludes that the concept of RNPQ may be ―very complex, expensive and difficult
to implement‖, identifying in particular three main critical points: lack of clear advantages versus
the current system; difficulty and costs of verifying compliance with thresholds; different status
of the HO in parts of the EU or of MS.
The question that has been addressed in the survey and during the interviewees is whether the
RNQPs should be regulated under the S&PM acquis or the CPHR. In the general survey, the
position of MS on this question is inconclusive. Five MS indicated that some HOs currently
listed in the S&PM Marketing Directives should be listed in Directive 2000/29/EC, while 11 MS
indicated that some HOs should be de-listed from Directive 2000/29/EC and be transferred to the
S&PM Marketing Directives:
100 On the basis of the IPPC criteria, the WG Report identifies three examples of HOs which qualify as RNQPs:
Aphelenchoides besseyi Cristie, Phytophthora fragariae Hickmann var. fragariae and Plum pox virus, currently
listed in Annex II Part A, Section II.
Food Chain Evaluation Consortium 72