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)
Stakeholders also commented that interests of stakeholders and sectors are definitely taken
into account in some MS, but communication, involvement and achieving 'shared' solutions
needs to be improved.
With regard to consideration of sectors involved, different comments were made:
The CPHR does not sufficiently take into account actions that are already carried out by
stakeholders, it imposes inspections with an intensity that is independent of the
guarantees already given by the private operator (with reference in particular to
certification and quality assurance schemes that may cover phytosanitary aspects);
Many stakeholders are dissatisfied with certain aspects of the CPHR as it stands. For
traders there is a perception that it imposes regulations which are possibly of little
benefit to them and often of doubtful benefit to their region or country, and that the
guarantee it provides to their customers is only partial as most (indigenous) HOs are
unregulated for the purposes of the CPHR. This indicates a certain confusion on the
scope and objectives of the CPHR as such, and uncertainty as to the what is regulated;
Representation of stakeholder interests also depends on the capacity of MS to defend
their positions within the SCPH;
A variety of stakeholders are usually involved in the field of plant health, with
conflicting interests in many cases (e.g. trade interests versus production interests,
divergent interests across MS depending on production and trade interests). There is
therefore a certain perception that producers may be seeking stricter regulation not
necessarily for plant health reasons but as a means of restricting competition, while
traders may have the opposite seeking the minimum restrictions on plant movements.
Traders tend to be better organised and represented than plant producers, in part due to
the divergence of interests and MS representation in the organisations of the latter.
With regard to the last point, it is indeed generally acknowledged that the CPHR has to seek a
sensitive balance among conflicting interests. Furthermore it is stressed that interests of
stakeholders may not correspond to plant health protection: therefore – in the context of plant
health being perceived as a public good – some MS consider the interests of stakeholders
should be taken into account insofar as these are in line with plant health objectives, and not
be the priority for policy making in this field.
On communication, one MS indicated that in future the Commission could also address
stakeholders and the general public with specific information about pest risks and the
reasoning and implication of the various legislation, as well as ‗soft‘ guidance to stakeholders
and the public on how they can support CPHR objectives. This would also contribute towards
the more general objective of raising awareness on plant health issues.
Communication to national stakeholders is considered primarily to be an NPPO task, and
therefore there may be degrees of variability among MS in terms of the information provided
to stakeholders, but also the priority given to certain HOs. It is suggested that it is difficult to
reach the relevant stakeholders and therefore communication may not be adequate. One MS
mentioned that in its case, a continuous dialogue on new regulatory issues is secured through
a national advisory board briefing and consultation process.
FCEC 190