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
Q3.3 Extent to which the implementation of Community derogations present a potential phytosanitary risk:
12 MS CA out of 23 and 6 stakeholders out of 10 consider that the implementation of the derogation measures
present a phytosanitary risk. (3 MS CA and 11 stakeholders do not know).
About half of the respondents to the survey (MS CAs and stakeholders) consider that derogations
present a potential phytosanitary risk in terms of their current implementation and have
commented as follows. A potential risk always exists; for example, import derogations for ware
potatoes from Egypt (for which a large number of comments were also received in the
interviews) means a high risk of spreading HOs but these derogations are still in force; some
HOs have been repeatedly found in bonsai plants from Japan imported under derogation,
according to reports of MS. For derogations regarding small quantities not used for commercial
purposes, it has been reported that small quantities carried by passengers can still carry
pathogens, as was the case in the outbreak of Citrus tristeza closterovirus and in the spreading of
Aculops fuchsiae (fuchsia gall-mite) in the EU. For derogations regarding transit consignments,
where no phytosanitary certificate is required in some cases, this could also pose a problem.
One area where it seems that there are less concerns is in the case of derogations for
breeding/scientific and sampling material, which are reported to be working well. The main
reason for this specificity is the fact that this type of material is being used by professional
scientists and/or plant breeders who are concerned by the phytosanitary status of this type of
material. However, MS are applying this derogation in different ways (e.g. France requires
inspection and disinfection of small samples which may have a negative impact on germination
and on the scientific tests intended to be performed with these seeds) and therefore further
harmonisation is required according to the seeds industry.
3.4.6 Use and usefulness of additional declaration and special arrangements (Annex VI)
Additional declarations to the phytosanitary certificates may apply for some of the plants, plant
products or other objects listed in Part A section I and Part B of Annex IV of Directive
2000/29/EC, for which special arrangements are in force pursuant to Article 13(1). The purpose
of the declarations is to specify which special requirements out of those listed as alternatives in
the relevant positions in the different parts of Annex IV have been complied with. This provision
is described further in Annex 1 (Theme 2).
From both the general survey and the interviews, it can be concluded that the system is working
sufficiently well, and no particular problems were noted. The majority of both CAs and
stakeholders consider the additional declaration to have been effective in preventing the
introduction of HOs in the Community, which points to the use and usefulness of the current
system in this respect. The only negative comment noted was the fact that additional declarations
may vary from origin to origin and this could pose a problem in the amount of information that is
available to enable authorities to check that the appropriate special requirements are fulfilled
(e.g. the case of wood consignments from Russia).
Food Chain Evaluation Consortium 99