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)
From the results of the specific cost survey, it appears that the most frequently appearing
suggestion is the full harmonisation via the use throughout the EU of the cost calculation
approach; second comes the suggestion to maintain the current fee system with annual
indexation to correct for inflation.
Several respondents have indicated that applying standard fees throughout the EU is not
desirable. Many of them underlined the fact that different levels of cost of living in the MS
(which affects staff salaries and costs) and the different organization of the CA services
(which affects the number of staff for instance) lead to different total costs in every MS. The
income of private operators subjected to the payment of fees is also different from one
country to the other. There is therefore no justification for this kind of harmonisation.
In particular one MS CA suggested an alternative according to which the import taxes on the
crop sector, including the import fee, should be paid directly to the EU budget to reimburse
the entry points. The remuneration of entry points could be based on the number of lots
inspected and their effectiveness.
Finally, one MS CA considers that the current fees system (in the case of full cost recovery) is
not appropriate for importers under the ‗reduced frequency checks‘ regime. The principle
according to which fees apply to all lots, whether or not they are included in the inspected
sample, results in the effect that the financial contribution of these importers is
disproportionate compared to the reduced frequency of the inspection applied to their
consignments. Instead, this MS CA suggests amending the Directive so that, in addition to an
distribution among lots, it would also be possible to distribute at the level of the importers.
They envisage a system in which the costs of the documentary and the general processing and
phytosanitary release costs are charged to all lots equally but the lots included in the sample
would also be charged for the cost involved in the actual inspection. This alternative would
allow distributing the inspection costs proportionally among the importers over the year,
provided sampling is properly carried out.
In conclusion, there is a general concern about the existing heterogeneity in the fees systems
applied in the different MS. However, due to difficulty in comparing the fees applied in the
different MS, it is difficult to estimate the extent to which this heterogeneity has led to
distortions in competitiveness between MS. Other key factors also affect competitiveness.
The majority of respondents are in favour of increased harmonisation in the future, preferably
via the use of the cost calculation approach throughout of EU.
It is noted that the FCEC study of the fees system applied for veterinary inspections under
Articles 26-29 of Regulation (EC) 882/2004 226 has highlighted very similar issues and
concerns, leading to the conclusion that the fees system under this Regulation needs to be
reconsidered.
The study established that there is a significant degree of variation in the enforcement of the
financing provisions of the Regulation by MS and a significant lack of clarity and
transparency of the various national fee systems as currently implemented. As a result, direct
226 Undertaken by the FCEC for DG SANCO in 2008-09.
Food Chain Evaluation Consortium 240