2454 final report.pdf - Agra CEAS Consulting

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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
Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) comparison of actual fee levels across the EU (and between sectors) is extremely difficult. The study results also suggest that it is quite unclear whether cost-based fees truly reflect actual costs incurred by the CAs of the MS for the performance of the inspections for which the fees are collected. In more general terms, the study investigated whether the main objective of the inspection fees system as in place at the moment has been reached, i.e. ensuring that MS have sufficient financial resources to carry out the official controls (Article 26 of the Regulation). The study suggests that this main objective has largely not been fulfilled at present for the EU as a whole. To address these shortcomings, a range of options are proposed from full harmonisation to full subsidiarity. The Commission‘s <strong>report</strong> on the implementation of Regulation 882/2004 227 concludes that the results of the study call for a review of the current system of inspection fees and charges. The Commission has started this review which foresees a wide consultation with MS and other stakeholders in view of carrying out an impact assessment of the available options in the course of 2010. On this basis, a legislative proposal to review the current system of inspection fees under Regulation 882/2004 may follow if considered appropriate. In conclusion, Directive 200/29/EC foresees a fee system similar to the one of Regulation 882/2004. The above analysis of the national fee systems implemented in the phytosanitary sector indicates a lack of harmonisation among the systems applied by MS. Suggestions for the future mainly relate to the harmonisation of the fee system, preferably based on the use throughout the EU of a cost calculation approach. In this context, an alignment to the evolving fees system of Regulation 882/2004 may eventually need to be considered for the fee provisions of the CPHR. Nevertheless, the research on fees carried out under this evaluation remains too broad compared to the above specific study carried during the evaluation of the fee system of Regulation 882/2004. Therefore, further investigation would be needed to understand the implications from the on-going review of Regulation 882/2004 and potential options for reviewing the fee system applying in the phytosanitary sector. 3.11.6 Opportunities for cost reduction The specific cost survey also enquired about potential opportunities for cost reduction with equivalent or increased benefits, i.e. promoting greater cost-effectiveness. Specific survey results Q 3.1. Opportunities for cost reduction with equivalent or increased benefits 7 out of 24 MS CAs and 1 out of 8 stakeholders suggest the cancellation of one or more obligations (7 MS CAs and 6 stakeholders do not know) 9 out of 24 MS CAs and 4 out of 9 stakeholders suggest the reduced frequency for one or more obligations (4 MS CAs and 4 stakeholders do not know) 5 out of 24 MS CAs and 1 out of 7 stakeholders suggest the reduced intensity for one or more obligations (7 MS CAs and 4 stakeholders do not know do not know) 7 out of 24 MS CAs and 4 out of 9 stakeholders suggest the delegation of one or more obligations (4 MS CAs and 3 stakeholders do not know) 227 As outlined in COM/334/2009/<strong>final</strong>. adopted on 8/7/09. Food Chain Evaluation Consortium 241
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