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)
General survey results
Q2.1.c Are there HOs which are currently not regulated under the Directive 2000/29/EC, but under the
Directives on the Marketing of S&PM, and should be transferred to the plant health Directive?
5 out of 24 MS CAs consider that some HOs should be transferred from the S&PM acquis to the CPHR (9 MS CAs
do not know); no stakeholders considered so (22 stakeholders do not know).
Q2.1.d Are there HOs which are currently listed in the plant health Directive 2000/29/EC but should be
transferred to the Directives on the Marketing of S&PM?
11 out of 25 MS CAs and 8 out of 28 stakeholders consider that some HOs should be transferred from the CPHR
acquis to the S&PM (8 MS CAs and 17 stakeholders do not know).
In general terms, both MS and stakeholders indicated that there is no inconsistency between the
CPHR and the S&PM acquis, but overlaps exist and should be removed e.g. some HOs are listed
in both sets of Directives (Q9.1). This conclusion was already present in the S&PM acquis
evaluation carried out by the FCEC in 2007-08.
Some MS CAs and other interviewees have suggested that pests which could be considered as
RNQPs should be identified and moved from the S&PM acquis and from Annexes I and II of
Directive 2000/29/EC to a new Annex of the Directive specific to RNQPs. Furthermore, for
plants for planting (including seeds and potted plants) as pathways for spreading, these should be
included in the plant health Directive, aligning with the IPPC.
MS CAs in particular see some advantages in the inclusion of RNQPs in the plant health regime.
This would, in the view of some MS, simplify the application of regulations for stakeholders,
strengthen effectiveness of both PH and S&PM inspections, while ensuring a better level of
protection.
It is also suggested that, given the difficulty of controlling RNQPs and to fully take into account
regional aspects, substantial prioritisation would be needed and the actual number of RNQPs be
kept fairly limited, at least during the period when the concept was being introduced. For the
same reason, leaving the Marketing Directives with some ‗softer‘ non-harmonised, non-SPSrelated
provisions might be advisable, at least in a transitional period.
On the other hand, it is suggested by a larger number of MS that a number of HOs 101 , mostly
listed in the Annex II part A section II 102 , which are widespread in the Community and for which
there are no PZs – but for which official supervision on containment measures is required -
should be regulated in the S&PM Marketing Directives, de-listed or liberalised for the
local/regional conditions. This point should be considered carefully as only certified material is
being inspected in S&PM, leading to the point that moving some HOs from the CPHR regime to
the S&PM acquis would lead to a complete elimination of inspections. The proposed approach is
only valid for crops and species for which seed certification is required.
101 Strawberry blackspot is an example. Other examples are HOs for planting material, such as strawberry diseases
viruses and virus like organisms.
102 A way of identifying these HOs would be to compare the Annex II part A section II with the list A2 of EPPO:
those in 2.A.2 not the object of PZ and not listed in the EPPO A2 would be transferred to the S&PM Marketing
Directives and then managed through certification (some examples are provided).
Food Chain Evaluation Consortium 73