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)
Although the current documentation as such does not therefore appear to cause any significant
problems in re-export and transit 163 , it is rather the decision-making mechanism followed by the
EU and the delays incurred that are of most concern to traders.
The implementation of EU phytosanitary standards carries costs, but also benefits, for EU
producers and traders (these issues are discussed in section 3.11). Furthermore, the international
phytosanitary system and the application of SPS rules, both in the international and bilateral
context, are currently built on mutual trust and confidence between trading partners NPPOs (this
issue is discussed in section 4.2). In this context, EU legislation on imports and internal trade has
an impact on the competitiveness and trade potential for EU exports of plants and plant products.
In particular:
The fewer pests of concern to third countries are regulated within EU, and the slower the
pest recognition and regulation (HO classification and listing) process, the more difficult it
is for EU exporters to document that products are in accordance with plant quarantine
legislation in third countries. In this context, a fast evaluation of the risk imposed by
emerging pests would be useful and would make it easier for exporters to adapt to the new
market situation, instead of facing emergency measures disrupting trade (e.g. Tuta
absoluta, Red palm weevil);
The terms protected zone and pest free area may cause confusion in importing countries,
thus making it more burdensome for an exporter to justify the pest status of a product.
Furthermore, some way of ensuring updated information on the pest status within EU, in
particular pest free areas for pests not regulated within the EU but of concern to third
countries, would be very useful 164 .
3.9 Activities in support of the CPHR
A number of activities and initiatives which support the CPHR are in place, although these are
not explicitly part of it at present. These include research and development, diagnostic capacity
and the laboratory infrastructure, training, and communication and consultation for policy
development and implementation.
3.9.1 Research and development and scientific advice
This section summarises the findings of the evaluation on the CPHR performance to date, taking
into consideration EQ 19 (area H) of the ToR.
163 For consignments in transit, as noted in section 3.4.7, there is some concern that lack of traceability from final
PoD back to PoE could in theory pose a problem, due to the complexity of trade patterns, where only controls at
final destination are in place. However, in practice, there has been no evidence that such problems have occurred.
Also, as noted in section 3.4.5, there was some concern for derogations regarding transit consignments, because no
phytosanitary certificate is required in some cases, but again there has been no concrete evidence of such problems.
164 E.g. EPPO provides information on Tuta absoluta but this is not updated for the latest in the EU, and this may
create more general doubts about the pest status of EU products.
Food Chain Evaluation Consortium 153