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)
Tracing back the origin of plant health issues may be of high interest in outbreaks, to optimise
the definition and implementation of eradication plans. Tracing forward is also valuable in many
situations to ensure full traceability along the production and marketing chain (e.g. in the case of
propagating material, difficulties are linked to tracing the whole history of a plant) 136 . The
question is whether the actual provisions and current implementation of the PP system are
sufficiently reliable to achieve this goal.
The current PP system is based on the registration of producers issuing PPs, the issuance of a PP
in case of plants and plant products leaving the holding, and registration of the PP documents for
a period of one year for growers and traders. These elements associated with the information that
has to appear on the labels are considered by most of the interviewees as being in theory a
relevant approach that should lead to some level of traceability.
Most MS (13 out of 26 MS CAs – 2 do not know) and stakeholders (16 out of 26 – 6 do not
know) (Q 4.2.c) that responded to the general survey consider that the PPs allow sufficient
traceability for plants and plant products moving within the EU. The interviews and field visits
have confirmed that both CAs and stakeholders recognise that there is a need for a complete
traceability system, but several issues of the PP system as such do not allow achievement of
complete traceability, as follows:
Traceability can only be achieved if the PP obligations are fully respected. The way the PP
system is implemented, as reported above can only lead to defective traceability;
Traceability remains possible in the MS of production or origin but is more difficult in
relation to products from other MS - this creates the need to refer to the authorities of those
MS who could probably provide trace-back;
Traceability is limited to one step back and one step forward, significant efforts and
resources would be needed to trace back all along the complete supply chain;
Traceability can only be fully achieved by using the PP in combination with trade
documents. Quite often the main criteria assuring traceability are mentioned in the trade
documents and not on the PP label and therefore traceability is achieved through
commercial logistics systems instead;
Examples given included problems with exports to Russia, concerning the transit of
consignments across MS, demonstrating that traceability is limited to one step back and
one step forward. In cases of outbreaks for example it is necessary to trace further back
and/or forward and the current PP does not allow this degree of traceability;
The current exemptions to the obligations of the PP, e.g. final consumption use, do not
allow traceability to the retailer end-user for e.g. pot plants;
Commercial considerations on the use of information: to avoid competition, traders prefer
that buyers do not see from whom the trader buys the products, because otherwise the
buyer could go to the producer directly.
There have been some discussions concerning a centralised IT database which would allow the
set-up of a complete traceability system to include all data on the circulation of consignments,
136 No reference made to tracing forward in the above-mentioned paragraph
Food Chain Evaluation Consortium 122