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)
On communication from the Commission to stakeholders, MS do not have precise
information on what action is taken by the Commission; one MS gives the example of the
Anoplophora chinensis, as a case where EU stakeholders were not sufficiently informed. It is
also suggested that communication and consultation with stakeholders should be made more
systematic, within a dedicated body including the Commission, the MS and the stakeholders.
In conclusion, stakeholders generally commented that currently communication is mainly
done at public level (between COM and MS authorities). A more transparent communication
of the actions to stakeholders, based upon a risk analysis and action scheme could contribute
to better results.
Clarity of import requirements under the CPHR for trading partners, especially in
developing countries:
With regard to communication to TCs, it is stressed by several MS and stakeholders that the
complexity of the legislation and the difficult reading of Directive 2000/29/EC make it
difficult for TCs to fully understand import requirements. In particular, it is hard to select the
information that is applicable in a certain situation and the structure of the Annexes
themselves also generates confusion. EU legislation has specific requirements for certain
pests and general requirements; for the latter, it is difficult for TCs to understand what they
need to do to comply. Furthermore there are non-listed pests, which can be present in TCs
and not identified as posing a risk yet (although they may already be present) in the EU. The
way the Directive deals with all these pests and the requirements that an exporting country
must comply with are not easy to understand. It is also difficult for TCs to identify which
pests apply to which products (a range of pests could apply for the same product). Only
limited published guidance is available at present to assist TCs in achieving compliance. It is
suggested that a soft measure to overcome this problem is the addition of a scheme describing
the correct use of the Annexes, to improve readability for exporters (and EU importers).
Stakeholders also suggested a searchable internet tool, on the model of those developed by
Australia and Mexico. Particular difficulties encountered by TCs are in relation with the
specific phytosanitary requirements and the additional declarations (the majority of
interceptions are due to this reason), as well as the requirements for wood materials. Annex
IV is considered to be one of the most problematic in terms of understanding. The systems of
derogations may also generate confusions for TCs.
A stronger effort from the Commission on communication on import requirements should be
undertaken and is advocated. Inviting to an informal notification system whereby anybody
could subscribe to e-mail notes providing a link to any new piece of legislation could also be
beneficial (cf. a similar system was set-up by the Canadian NPPO)
It is noted that a web page within the CPHR website is dedicated to import requirements.
Other examples of practices indicated in the survey are:
Explanation on Special Requirements for Import (Annex IV)
Requirements for Wood Packing Material;
FCEC 191