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)
It was also noted, however, that there is scope for improvements to be made (Q3.9), on the basis
that all major pest incursions in the EU continue to take place through trade. Indeed, taking
examples from recent years, the import regime in place has not prevented some HOs to enter the
Community, e.g. Anoplophora sp., Rhynchophorus ferrugineus, Tuta absoluta, Dryocosmus
kuriphilus, Gibberella circinata, Pepino Mosaic Virus, Citrus Tristeza Virus and PWN.
In particular, a number of weaknesses or shortcomings were identified by the evaluation, as
follows:
The effectiveness of border controls between MS is perceived to be variable. Plant health
checks are thought to be excessively focused on regional/national plant health issues rather
than pests of EU-wide relevance, which is not surprising given MS‘ need to prioritise in the
context of resource constraints. It is indicated that this problem could to some extent be
addressed by Community training (e.g. BTSF), networking development between inspectors,
and the development of general guidelines at Commission level for the drafting by MS of
more uniform specific guidelines on import controls 126 ;
Delays in EUROPHYT notifications are significant, up to 50 days in certain cases. This,
combined with the fact that many notifications are for minor infringements in terms of
paperwork, is leading to limitations in the extent to which the system can be used as a risk
analysis tool, and results in its limited use for risk based inspections at MS level;
Analysis of EUROPHYT data indicates that some pathways (in particular plants for planting
including ornamentals, from certain third countries) are particularly prevalent, indicating the
scope for a pathway approach in some cases;
For some specific plants on which latent diseases may be present (particularly plants for
planting), the need for more extensive post entry inspections and/or introduction of
obligations for destructive sampling has been identified;
Current implementation of derogations is considered to present a potential phytosanitary risk,
in particular those regarding small quantities not used for commercial purposes (see also
passenger transport below), and regarding transit consignments - it may therefore be
opportune to review the system of derogations in these cases;
There is widespread concern that a lack of traceability from Point of (final) Destination back
to Point of Entry could in theory pose a problem due to the complexity of trade patterns
where controls at final destination are in place (consignments in transit);
The use of reduced frequency checks is very variable between MS: the majority of MS (18
out of the 26, Q3.2) have not used the possibility of conducting reduced frequency checks;
where, however, this option has been taken (8 MS) it was considered to have been effective.
This mixed view of the system was confirmed by the interviews and field visits, with MS that
apply reduced frequency checks strongly in favour and those that do not apply them
generally mistrustful of their ability to work effectively. The limited use of reduced
126 There exists already a harmonised vademecum for import controls prepared by the Commission, but it has not
been kept up-to-date for about a decade. In the past (15 years ago) the Inspectorate within the Commission (ex –
FVO) prepared vademecums by sector (for fruits, forestry inspections, for plant products etc.). These never received
an official status and were applied to a limited extent. Although there is some interest now, the current resources at
DG SANCO/FVO do not allow the fuller development of such guidelines.
Food Chain Evaluation Consortium 112