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 most important substantive compliance tasks for the private operators under the CPHR,
as identified by FCEC, are the payment of fees for import checks and inspections at the place
of production as well the implementation of measures to eradicate or, if this is considered
impossible, to inhibit the spread of the HO.
Considering the 4 administrative obligations mentioned above, the total administrative costs
for the private operators in the 24 MS considered in the cost analysis amount to €51,445,518
on average per year. The obligation to keep records is the most important cost item and
represents 80.42% of the total administrative costs.
Table 3-29: Average annual administrative costs for private operators (EU 24)
Annual cost for Private
Administrative obligations
Operators (€)
Obligation 1: Registration 1,613,816
Obligation 2: Authorization to issue Plant Passport 171,827
Obligation 3: Issuance of plant passport 8,286,093
Obligation 5: keeping of records 41,373,782
Source: compiled by FCEC based on the results of the specific cost survey
The total costs provided for each administrative obligation are not comparable, as they do not
refer to the same number of private operators. The total administrative costs estimated for the
compilation and submission of a registration dossier (obligation ‗registration‘) as well as for
the compilation and submission of a dossier to be authorized to issue plant passport
(obligation ‗Authorization to issue Plant Passport‘) refer to the number of private operators
newly registered and authorized on average each year, whereas we can assume that a larger
number of private operators had to fulfil that obligation at start, when it first became
compulsory to them.
In addition, based on the fact that several MS CAs apply fees for the registration (i.e. AT, DE,
DK, EE, IT, LT, LV, NL, PT, SK and SE) and/or for the authorization to issue plant passports
(i.e. AT, BE, DE, EE, FR, IT, LT, NL, SK, SI and UK), respectively 7.63% and 21.8% of the
costs estimated for these two obligations concern the payment of fees.
The estimation of the average administrative costs per private operator gives a better picture
of the highest cost items, as follows:
Table 3-30: Average annual administrative costs per private operator
Administrative obligations
Nb of private operators
Total cost (€) (POs) concerned
Average cost per
PO (€)
Obligation 1: Registration 1,613,816 4,971 325
Obligation 2: Authorization to
issue Plant Passport 171,827 1,517 113
Obligation 3: Issuance of plant
passport 8,286,093 36,068 230
Obligation 5: keeping of records 41,373,782 118,321 350
FCEC 228