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)
General survey results
Q 9.1 Source of inconsistencies between CPHR and PPP legislation:
6 out of 25 MS CAs and 6 out of 21 stakeholders consider that CPHR overlaps with the PPP legislation and that
such overlapping can be a source of conflict/inconsistency (3 MS CAs and 11 stakeholders do not know).
Q 9.2 Extent to which the revision of the CPHR in future should be guided by any of the principles
developed under the PPP legislation:
7 out of 25 MS CAs and 9 out of 23 stakeholders consider that the revision of the CPHR should be guided by the
PPP legislation (7 MS CAs and 11 stakeholders do not know).
Some interviewees and respondents to the general survey have highlighted their concerns on
potential inconsistencies between the obligation of phytosanitary treatment against some HOs
and the ban on usage of PPPs without provision of sufficient substitution solutions. They
consider that the modifications to the Directive on PPPs should be taken into consideration as
quickly as possible in the CPHR, e.g. through the consideration of alternative measures. Some
interviewees also consider there is a need to allow derogations for the use of banned PPPs,
depending on risks, for eradication purposes; it appears that the feasibility of applying these
rules in practice remains questionable 250 .
More specifically, MS CA comments on current or potential inconsistencies between the two
sets of legislation mainly refer to the removal of risk assessment in the new PPP legislation
versus the focus on hazard and the prohibition on the use of certain phyto-pharmaceutical
products such as methyl bromide, versus the obligation to treat against certain HOs. In their
comments, stakeholders insist on the need to have PPP available for seed treatments and
indicate that certain control measures in emergency decisions imply extensive use of
pesticides which contradict the aim of reducing their use.
Concerns have been expressed by certain stakeholders on the potential implications of the
anticipated limited availability of PPPs due to the limited number of permitted active
substances 251 . The trend in PPP registration over the past 10 years indicates that, overall, there
has been a large reduction in terms of the products available to farmers and plant producers
and that, due to the high costs for registering products, agrochemical companies tend to apply
for authorisation of products in large agricultural crops and less in minor crops (i.e. small
acreage and low value crops).
As a result, for some pathogens on some minor crops, no chemical solution may be available.
This situation could create an issue for plant health as control of certain pathogens may not be
possible if no authorised PPPs are available. The new Regulation requires that the
Commission reports to the Council and Parliament about the possibility to establish a fund for
minor uses. This report is scheduled for November 2011.
250 Under the new package, derogations may be granted on a case by case basis, but this would likely lead to
delays in approval of applications of the products.
251 As indicated by the letter submitted to the FCEC on 5 may 2010 by the European Starch Industry Association
(AAF); The European Flour milling association (The European flour millers); the European Oil and Proteinmeal
Industry (FEDIOL). The associations indicated impact analyses studies of the UK pesticides safety Directorate,
the Nomisma institute in Italy, INRA in France on the Reg. 1107/2009, which assess the impact on the
management of pests and evaluate the risks of resistance of pests and diseases given the limited number of
permitted active substances.
Food Chain Evaluation Consortium 260