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)
Flexibility as regards planning and logistics for producers and traders, as they do not have
to rely on official services to get the paper documents and to organise their day-to-day
activity;
Cost-effectiveness, as the issuing of PPs can be optimally integrated in the daily activities
rather than being delayed awaiting official documents;
Reduction of overlapping activities in cases where the PP is associated with the S&PM
certificate (e.g. seed potatoes).
For CAs the major issues are linked to the understanding of the system. Larger companies that
are used to issuing a large number of PPs know the system quite well, but this is not the case for
all smaller companies, even if they are sufficiently informed on the requirements. In these cases,
the real purpose of the PP is unclear to operators mainly because the origin of the plant material
so easily disappears in the marketing chain between MS. Additionally, registered nurseries are
not always aware which plant species need a PP and therefore they provide PPs to plants which
are not covered by such requirements. At the same time, the NPPO is not always informed about
the species that are present at the premises of registered operators. These elements conjointly
lead to a degree of dysfunctionality within the current system.
CAs interviewed have also reported that some obligations related to record keeping are not
performed satisfactorily, as the private operators consider that they will do their ―paperwork‖
later and finally this is not properly done until they are inspected.
In the case of issuing of replacements PPs, only the CA should be competent to do this according
to the legislation; this is not currently the case as this task is mostly delegated i.e. in cases where
replacement PPs are used, these are prepared by the registered holdings and not by the NPPOs as
required by the legislation. This point is also highlighted in the 2005 FVO report. Producers
generally use the normal PP instead of the replacement PP mainly because they are not fully
aware of the obligations and for practical reasons.
Finally, there is concern that, with the reduction of field inspections at registered nurseries, the
phytosanitary status may be at risk because private operators currently have incentives to sell
plant products not free of HOs rather than destroying them.
3.5.5 Traceability issues
The plant passport is an official label which provides evidence that the provisions of Directive
2000/29/EC related to plant health standards and special requirements are satisfied. The PP was
never intended to be used just as a traceability tool, although there is reference to the possibility
of setting up a system to trace back to origin in the base Directive (Art. 6(6) 135 ). On the other
hand, the list of required information and the movement of the PP document with the
consignment are elements that contribute to a certain level of traceability (e.g. registration
number, individual serial or week or batch number, botanical name, and country of origin or
consignor country for third country products).
135 “[…] a system may be set so that certain plants, plant products and other objects may, if necessary and in so far
as possible, be traced back to their origins, bearing in mind the nature of the production or trading conditions”.
Food Chain Evaluation Consortium 121