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)
including import into and movement through the Community as well as exports of consignments
outside the Community. Such a system exists in animal health (TRACES 137 ). An equivalent
system in plant health could allow the electronic preparation of PPs, the electronic issuing of
plant health certificates and the tracing of consignments. This system has already been presented
to the Standing Committee of Plant Health and received some interest from MS. However the
major issue linked to the establishment of such a system is the cost and staff required for settingup
and managing such a database, knowing that volumes of movements are much higher in plant
health than animal health (this issue is discussed further in section 5.2).
3.5.6 Implementation of exemptions
3.5.6.1 Small producers for the local market
Article 6(7) of Directive 2000/29/EC exempts small producers or processors whose entire
production and sale of relevant products are intended for final usage on the local market and who
are not professionally involved in plant production (local movement) from the requirements for
the registration of establishments, therefore from the official inspections and from the need to
issue PPs.
The definitions of “small producers” and of “local market” are not established in the base
Directive, but are left to the MS to decide on. Not all MS have established national rules to apply
this potential exemption, as follows:
Table 3-12: MS implementation of exemptions from certain PP provisions
Type of exemption
MS that have established national provisions on
―small producers‖ and ―local market‖ to use
exemption as defined in base Directive
MS that have NOT established national provisions
on ―small producers‖ and ―local market‖ to use
exemption as defined in base Directive
MS where applied
SI, EE, DK, PT, FI, BE, UK, BG, IT, , DE, IE (wood
material), MT, HU, RO, CZ, AT, PL, FR, EL
CY, NL, SE, LT, ES, LV
Source: FCEC, based on general survey results
The analysis of national provisions shows that these are variable across MS and the interpretation
of the term ―local market‖ also varies considerably between MS.
The main reason indicated by MS for not implementing provisions to establish exemption is
mainly the perception that these exemptions create a lack of clarity and make the system
unnecessarily complex and less enforceable. Additionally, the risk of spread of HOs from a local
market is not negligible. At the time of marketing, there is no full guarantee that the plant will be
used only at the local market, Finally, when it comes to inspection, it is apparently confusing to
137 TRACES allows the electronic exchange of intra-EU trade certificates and import documents between the CAs
(customs and veterinary) in charge of animal health controls. Economic operators could be involved in drafting these
documents.
Food Chain Evaluation Consortium 123