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 consideration of two regions for which the disease and HO management objectives would be
specific.
However, respondents reported many disadvantages and constraints linked to implementation of
a regionalisation concept, as follows:
Regionalisation could only be implemented with some form of internal control on
movement within the EU, which would lead to the reintroduction of border controls.
These are not consistent with the single market principles and would therefore be
politically unacceptable 151 ;
Implementation of such a concept could be very complex as regionalisation would need
to be applied on a case by case basis. Additionally, in case of regionalisation, traceability
would have to be fully applied in order to correctly target and track plant and plant
products and HO(s) movements. Today there is no tool establishing traceability within
the EU, and the plant passport system is not intended or considered suitable in its current
form for this purpose (as demonstrated by the weaknesses of the implementation of the
plant passport provisions as well as the fact that not all species need to be accompanied
by a plant passport);
The idea of regionalisation raises the concern of potential additional administrative
burden, which would require internal EU checks, and therefore this is probably neither an
acceptable nor a viable solution;
The implementation of one or another regionalisation concept is linked to the fundamental
question of who should bear the major burden of plant health measures. In case of outbreaks of a
regulated HO, the burden is principally on the MS where the outbreaks occur, but the solidarity
regime ensures support from the other MS via EU co-financing. In the case of PZs, those MS
who apply the PZ conept bear the costs of surveillance to ensure the absence of the relevant HO
and have the benefits of the free status (less costs for pest control; export facilitation). Suppliers
in other MS bear inspection costs for being able to move plant material to the PZs. The fairness
of the distribution of administrative and financial burden between MS largely depends on the
balance between infested and non-infested countries. When the outbreak of a HO is confined to a
single MS, the other MS will expect all costs to be borne by that MS (except for solidarity cofinancing).
However, when a MS wishes to be recognised as a PZ while all others are already
infested, other MS will also have to bear some costs under the current system; this is therefore
currently considered as an unfair distribution of costs and benefits by those MS that bear such
costs in relation to certain PZs that are of unique benefit to other MS. . The attribution of costs
and benefits should moreover be considered in terms of its impacts on the effective management
of HOs which occur in one part of the EU (through imports or natural spread) but may possibly
be most relevant and damaging for another part of the EU. Therefore, in any system, a fair
balance needs to be struck, possibly on a case-by-case basis, between the distribution of costs
and benefits over infested and non-infested MS, and the consequences of potential infestation for
the EU as a whole, taking into account liability aspects, incentives, feasibility and
proportionality.
151
It is noted that regionalisation applies in the animal health sector, but the organisation of internal inspections and
controls is different in this sector while advanced animal identification and traceability systems are in operation.
Food Chain Evaluation Consortium 137