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)
* Fees are not yet applied in Ireland
** A new fee regime on the basis of the standard fee system of Annex VIIIa of Directive 2000/29/EC will be soon
introduced in MT
Source: compiled by FCEC based on responses to the specific cost survey
Analysis of the results to the cost survey indicates that, when MS apply the standard fee of
Annex VIII, the fees collected cover between 34% and 75% of the costs associated with the
documentary, identity and plant health checks. In the MS defining fees on the basis of the
detailed cost calculation, the fee is usually set on a full cost-recovery base, adapted to the
actual cost level.
Differences in the fee systems applied in the MS result in heterogeneity of the fees charged to
private operators. The standard fee of Directive 2000/29/EC is below the fees calculated
based on the detailed cost calculation. For MS cost recovery based fees, significant
differences in the organisation, structure and staffing (number and profiles of staff) between
MS results in different total costs for import checks and therefore in different fees applied.
The fact that the amounts mentioned in the Annex VIII of the Directive 2000/29/EC have not
been indexed for a few years, while costs of import inspections have gone up, increases the
difference in the fees applied under a full cost recovery system and under the standard system.
In its position paper, Freshfel indicates that ‗Fees paid are disproportionately high in relation
to the produce value because of the product quantity shipped, the small mixed loads and
controls during evenings of the weekend. The current application of the fees system under the
CPHR results in a distortion of competition between MS given the different options provided
by the Directive 2000/29/EC. Therefore, as one internal market exists, there should be also
only one fee system/a full harmonisation of the fee system‟.
According to the results of the specific cost survey, 11 respondents consider that the current
application of the fee system result in a distortion of competition (14 do not know).
Specific cost survey results
Q 1.3.e (CA) or d (stakeholders) Extent to which the current application of the fees system result to
any distortion of competition:
7 out of 25 MS CAs and 4 out of 8 stakeholders consider that the current application of the fees system
results in distortion of competition (13 MS CAs and 1 stakeholder do not know)
As indicated by 5 MS in their comments to the specific cost survey, this heterogeneity in the
fees applied may impact on the competitiveness of the concerned operators or, in the cases
where there is a significant distinction between neighbouring MS in the applied fees, to the
selection of the cheapest point of entry.
It is indeed difficult for a trader to understand why import inspection fees are different
between neighbouring MS for, a priori, the same service. As a consequence, the trader will be
tempted to choose the cheapest entry point. Nevertheless, import inspection fees are only one
of the different factors taken into account by the trader when he is choosing an entry point.
Airport taxes, extra charges for security, efficient logistics, etc also play an important role in
Food Chain Evaluation Consortium 236