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)
have at the same physical place (e.g. a market) the same products but some from ―small‖ or local
exempted producers and others from larger producers or those outside the local market
perimeter; this may lead to market distortions.
General survey results
Q4.6 Extent to which there is a potential phytosanitary risk from the current implementation of the “small
producers serving the local markets” derogation
20 MS have established provisions to use these exemptions, even if 12 out of 26 MS CAs consider there is a
potential phytosanitary risk from the current implementation of these exemptions (2 do not know), as these small
producers are not aware of the relevant legislation that covers HOs and their control. 10 out of 24 stakeholders (9 do
not know) are satisfied with the current implementation of these exemptions.
Any exemptions will involve a certain degree of risk and the issue is whether the level of risk is
acceptable or not. In this case most of the MS CAs considered that the degree of risk is
acceptable and therefore have applied these exemptions.
3.5.6.2 Professional use vs. final consumption use
Another exemption from certain inspection requirements is related to final consumption use (i.e.
non-industrial and non-commercial purposes) of plants and plant products, provided there is no
risk of spreading HOs (Article 6(5) and Article 10(2) of the base Directive).
This exemption has been implemented in the same MS as in the case of the exemption for ―small
producers on local markets‖. MS have established both exemptions, mainly for reasons of
simplification.
Generally this exemption has been implemented for the same reasons as the previous exemption,
although certain specificities have been reported, as follows:
It is difficult to prevent the movement of unregulated home produced plants and plant
products and any regulation to be applied to such products would lead to important burdens
for inspections;
The final consumer can always remove the plant passport when buying products in e.g. a
garden centre and therefore the added value of a plant passport at this stage is very limited;
The possibility of identifying the infected material at this stage and then eliminating it are
quite low, therefore there is no reason to regulate this stage.
On the other hand, several MS have not implemented this exemption for the opposite reasons. In
particular, products destined for final consumption are considered by those MS to pose a
significant risk of introducing HOs to private and public gardens. In this context, garden centres
can be crucial in tracking and tracing infested consignments. For example, the Danish authorities
mentioned cases of Phytophthora ramorum and Plum pox virus found during growth inspections
in garden centres in 2008 and 2009.
Food Chain Evaluation Consortium 124