2454 final report.pdf - Agra CEAS Consulting

3.6.4 Conclusions on performance of the PZ system
Evaluation of the Community Plant Health Regime: Final Report
DG SANCO Evaluation Framework Contract Lot 3 (Food Chain)
The overall conclusion that emerges from this evaluation is that, while the concept of Protected
Zones (PZs) is generally considered to be useful and effective in slowing down the spread of
certain HOs, continued persistent variability in the implementation of the concept at MS level
has led to loss of credibility, hence undermining the usefulness of the system as a plant health
measure.
PZs should be technically justified and the justification needs to be transparent. Despite
significant progress in that direction in recent years, the general perception continues to be that
PZs are not designated only on technical grounds but that significant commercial/political
considerations continue to be present. The evaluation has found that these concerns are largely
linked to an on-going debate on the cost and benefit distribution of the current implementation of
the PZ system. Moreover, the distribution of costs and benefits is generally assessed from the
perspective of individual MS or regions, largely ignoring the cost-benefit distribution of the
current system of PZs for the EU as a whole. From a narrow (individual MS) perspective, PZs
are seen to offer an economic advantage for local growers in the PZ areas when exporting from
the PZ, but to result in additional costs for traders in the non-PZ areas to prepare and check that
correct documentation is attached to the plants and plant products imported into or moving
through the PZ.
Many of the problems of PZs have come from MS failure to apply the agreed measures, and are
not due to flaws in the concept per se. There is evidence of MS failure to carry out surveillance
and report the results; as well as evidence of certain failures in the correct implementation of the
PZ plant passport system (‗ZP‘ marking) as this creates additional administrative and financial
burdens for traders. As a result, due to implementation problems, the principle is no longer
giving sufficiently reliable guarantees that the PZs are free of the targeted HO(s).
The consensus view is therefore that controls should be strengthened and legislation fully
enforced (e.g. surveillance and reporting obligations) to restore the credibility of the PZ concept.
In this context, options to pursue further the IPPC PFA concept, which is the approach followed
internationally, could also be explored. The two concepts could potentially be applied in
parallel. It is noted, however, that 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 with the application of the PFA concept.
Alternatively, regionalisation concepts could be considered, e.g. Diabrotica virgifera may be a
good example of the need for a concept that uses definitions of demarcated infested zones and
pest-free zones. However, this approach should be restricted to limited cases and not be widely
adopted , to avoid excessive complexity in the implementation of plant health measures.
Ultimately, a critical success factor for the application of any regionalisation concept will be to
ensure a fair balance between the distribution of costs and benefits at MS level and for the EU as
a whole. This will need to be determined on a case-by-case basis, considering infested and noninfested
MS, and the consequences of potential infestation for the EU as a whole, taking into
account liability aspects, incentives, feasibility and proportionality.
Food Chain Evaluation Consortium 138