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)
Several formats of PP exist even within a given MS and as the information is often in a
national language it is difficult to find and to understand when material circulates across MS.
The required information is spread through the document and sometimes scattered on
several pages;
Some producers place the required PP data directly on the package, the label is adhesive and
therefore it is difficult to keep a copy at the premises for the required legal period of one
year;
Some MS use only the invoice or other relevant trade documents as PPs, leading to
difficulties in extracting the PP information from the trade related information;
When the PP consists of an official label and an accompanying document, too often the
official label is not made of appropriate material and not attached to the plants, to their
packaging or to the vehicles transporting them as required by Article 10(2) of the basic
Directive and Article 3(2)(h) of Commission Directive 92/105/EC.
It would appear that the content of the plant passport is considered as adequate, but the layout
and presentation needs to be harmonised in order to facilitate readability and easy recognition of
the information contained therein and to ensure that all necessary information is included. It was
also indicated that the PP document needs to be separated from any other information that is
accompanying the consignment, and especially the trading documents, in order to allow fast and
reliable identification of the phytosanitary requirements.
The majority of the interviewees consider that the EU Commission should define and propose a
unique format and a standardised lay-out to avoid having to use one unique language. Examples
from each MS should be published on CIRCA.
Some interviewees indicated that, where possible, synergies need to be sought with the
documentation required under other regulatory obligations. For example, when the PP
obligations are combined with obligations for certified plant propagating material and material
belonging to the Conformitas Agraria Communitatis (CAC) in common documents the system
appears to work better.
3.5.3 Functioning of the producer registration system
According to Art.5 of Directive 2000/29/EC, producers, importers, collective warehouses and
dispatching centres must be registered 133 and the name and details of the operator listed in an
official register, managed by the NPPO; each operator shall be identifiable through an individual
registration number. Official inspections are carried out in the registered establishments in order
to ensure that products are not contaminated by HOs as listed in Annex I and Annex II (and that
seeds listed in Annex IV part A meet the special requirements), with the exemption of the
movement of small quantities for local markets (see section 3.5.6.).
133 Art. 5, third subparagraph of Council Directive 2000/29/EC requires registration for producers of plants, plant
products and other objects listed in Annex V, Part A to Council Directive 2000/29/EC and for seeds listed in Annex
IV part A; art. 6 establishes that: with effect from 1 June 1993, MS shall provide that producers of certain plants,
plant products or other objects not listed in Annex V, Part A, specified through comitology, or collective warehouses
or dispatching centres in the production zone, shall also be listed in an official local, regional or national register and
that they may at any time be subjected to inspection.
Food Chain Evaluation Consortium 118