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)
The overall feedback from the general survey and the expert interviews and field visits is that,
while the general concept of PZs was in the past considered useful and effective in slowing down
the spread of certain HOs, e.g. Erwinia amylovora (fire blight) in the 1980s, continued variations
in implementation of the concept at MS level have led to a loss of credibility. This can further
undermine the utility of the system as a plant health control measure.
The main reasons underlying the loss of credibility of the concept, as indicated by interviewees,
can be listed as follows:
Strictness of the PZ requirements and lack of effective enforcement at MS level;
Complexity of using a PZ for trade purposes;
Findings of HOs in a PZ in practice often do not lead to the loss of the PZ status.
The level of guarantees that the PZs are free from the respective HO(s) depends largely on how
the PZ principles have been implemented by MS. For example, if the methods and frequency of
surveillance in PZs have not been harmonized for a given HO, then the level of guarantees is
likely to differ between MS. Interviewees reported several examples where MS do not meet
control and reporting obligations or do not establish reliable surveillance programmes. This is
also confirmed from systematic report findings: although most MS carry out monitoring in PZs,
some overview reports on this (FVO reports, reports to annual meeting of the SCPH), reveal
different depths of monitoring by MS.
The level of guarantees that PZs are free from specific HOs is also dependent on the biology of
the pathogen. In cases in which the HO can spread naturally, maintenance of the PZ is more
difficult than for HOs whose spread is strictly associated with the movement of plant and plant
products. For example, transmission of Erwinia amylovora can occur by air, rain or by vectors
(insects), and in open conditions there are more genera of host plants for this particular HO.
Respondents also observed a lack of reporting to the EU, with several examples of MS not
submitting the required reports to the European Commission and to other MS. For example,
Regulation (EC) No 823/2009 mentions the lack of reporting from Greece that did not notify the
Commission of any results of such surveys on the presence of the HOs concerned over a period
of five years 139 . An analysis of data on reports submitted by MS 140 since 2001 has shown several
cases where reports are not submitted, and cites a few examples of HOs for which reports are
systematically not submitted by some MS.
Several stakeholders have reported that PZs are maintained more on purely commercial/political
grounds and are therefore no longer effectively serving plant health objectives, i.e. having a PZ
offers an economic advantage for local growers when exporting within and outside the EU.
139 Reg. 823/2009 gives to Greece recognition as a protected zone (with respect to those HOs) until 31 March 2010,
in order to carry out survey and to notify its results to the Commission. This decision was made on the basis of
information provided by Greece in March 2009, showing that the necessary legal, financial and organisational steps
had been taken to carry out regular and systematic official surveys for those HOs,
140 Notification of the results of surveys in PZs, submitted to the Commission pursuant to Article 2(h) fifth
paragraph of Directive 2000/29/EC.
Food Chain Evaluation Consortium 131