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)
In terms of disadvantages, the following main points were mentioned:
Moving to the PFA principle may lead to further fragmentation and additional obstacles
to free movement of regulated material within the EU;
Moving to the PFA concept would involve reinforced surveillance, additional sampling,
etc., for which the resources and funding are currently lacking. The demand for high
statistical significance of sampling to demonstrate complete freedom is therefore an
important constraint in the application of the PFA principle. This leads to concern that
the PFA concept cannot be properly applied, it may even lead to weaker enforcement
than is the case at present with PZs;
Implementation of the PFA concept is also dependent on NPPO interpretations of the
ISPM guidelines and thus often contested in the international trade context; therefore the
potential trade advantages of moving to an international concept (as noted above) may be
less significant than expected.
The credibility issue (vis à vis third countries) is not unique to the EU PZ system. In the WTO
SPS and IPPC context, these are common and relatively frequently occurring problems and are
due to a relatively wide interpretation of the current IPPC guidelines on the recognition of PFAs.
To address these issues, the IPPC established an open-ended working group to examine the
feasibility of international recognition of PFAs. The WG has undertaken a survey on
international implementation of PFA system 148 , which shows divergent approaches and rules on
PFA implementation across countries.
These issues are discussed further in relation to options for the future under section 5.6.
Alternative regionalisation concepts could be considered in some cases, such as the
establishment of demarcated infested zones or establishment of buffer zones to prevent the
spread of HOs from one area to another. Demarcated areas and buffer zones have already been
introduced into the CPHR through Commission Decisions on emergency measures.
It is clear that plant health issues are different for different areas/MS and that control measures
appropriate for one area/MS may not be so for others. Climatic and geographic differences also
need to be considered, in order to take appropriate regionalised risk management actions.
The ―citrus case‖ and the Western corn rootworm Diabrotica virgifera may be good examples
supporting regionalisation and the possibility to adjust measures in line with regional risks. For
citrus, a North-South barrier or buffer zone for instance might be considered, to protect MS in
the North where there is no commercial cultivation of citrus trees and therefore no phytosanitary
risk of the relevant HOs, but which have strong commercial interests in import and trade in citrus
plant products. In this case, the South where the risk of disease is higher and the impact might be
serious, exclusion measures might be required. This would however infringe on the fundamental
CPHR principle of the free movement of plants and plant products in the EU, because
regionalisation for citrus fruit cannot be achieved without re-establishing intra-EU border
controls. For Diabrotica, the establishment of a buffer zone between the contaminated area (the
eastern part of the EU) and the non-contaminated zone (the western part of Europe) may lead to
Food Chain Evaluation Consortium 136