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)
samples are taken, it may take several days or weeks before the results are available, leading to
logistic issues, as often there is not enough space and equipment to store consignments while
awaiting the results of laboratory testing. Therefore, for some specific plants in or on which
latent diseases may be present (particularly plants for planting), the need for more extensive
post-entry inspections may be justified.
There is significant concern that lack of traceability from final PoD back to PoE could in theory
pose a problem, due to the complexity of trade patterns, where only controls at final destination
are in place (consignments in transit). Some MS commented that this was a problem and called
for better direct communication between national CAs to address this. Conversely, it has also
been mentioned that checks at PoD should be reduced in situations in which there are regular
controllable trade flows (e.g. imports of wood by Finland/Sweden from Russia for paper
industry, always arriving by the same train route).
For traders it is important to have phytosanitary controls at the final PoD to avoid logistic issues
slowing down the trade, and the possibility of having controls at PoD does not per se reduce the
severity of the controls, although several interviewees indicated they are not sure how the rules
are applied at PoD.
Interviewees have observed that the inspections that are done by customs and PH inspection
services are excessively focused on local/regional or national issues and not sufficiently
dedicated to pests or diseases of EU-wide relevance. For example, when an inspector from a
given MS checks trucks coming from a third country, they make an inspection based on their
own priority MS issues only, even if the final destination of the consignment is intended to be
another MS where plant health issues are different. This issue may create a degree of laxity in
import control. However, a focus on national HO problems is not surprising, given MS‘ need to
prioritise in the context of resource constraints.
The effectiveness of border controls between MS is also perceived to be variable. This is due to a
widely reported lack of harmonisation in inspection methods and procedures. However, the lack
of harmonisation is widely attributed to a problem of implementation of plant health import
controls by MS, and not to the CPHR regime as such, although greater clarity in the base
Directive would improve the situation and may result in more harmonised approaches across
MS. For example, it was widely reported that there is need for more precise specifications on
which goods need to be controlled to fulfil the provisions of Annex I of the base Directive, and
which goods might be eligible to add (on a precautionary basis) to the list of goods specified in
Annex II.
These shortcomings may be explained by the fact that there is no pan-European informationsharing
process between customs and PH inspection officers and that best practices are not
shared across MS. A higher level of harmonisation of import inspection, as well as better
communication between MS inspectorates, would contribute to a higher level of protection of the
Community and would avoid any potential for trade distortions.
Food Chain Evaluation Consortium 102