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)
inspection of consignments of invertebrates is currently subject to veterinary surveillance, as
well as plant health controls. They consider that an arrangement for the inspection of such
consignments is needed to avoid potential incoherence or duplication of controls.
3.12.8 Conclusions on coherence with other EU policies
The coherence of the CPHR with other policy regimes was examined in relation to a number
of policies, and the following conclusions can be drawn:
Policy
Coherence with the
S&PM regime
Coherence with
General Food Law and
Official Controls
Coherence with
environmental policy
Coherence with PPP
legislation
Coherence with
Common Agricultural
Policy (I and II pillars)
Coherence
Community
Provisions
with
Customs
Coherence with EU
Animal Health
Strategy
Conclusions
Both the legal frameworks on CPHR and S&PM are covering HOs.
Some inconsistencies were identified, such as the overlapping for some HOs, the
unclear position of RNQPs, and the existence of two certification schemes for fruit
plants. Particularly, inconsistencies are found with regard to inspections, as there is a
duplication (for PH and for certification). Within the CPHR is not possible to delegate
inspections to private operators, which is instead allowed for certification. It is
recommended that more consistency between the two regimes is ensured in relation to
inspections, the positioning of RNQPs, the registration definitions for operators, as
well as the documentation required.
Alignment to a number of elements of Reg. 882/2004 is recommended, such as the
risk based official inspections and monitoring; the requirements for NPPO‘s
performance, fees, the system of RLs (EU RLs/NRLs), contingency planning and alert,
sampling requirements, integrated control measures to reduce chemical inputs,
responsibility sharing.
Areas of potential inconsistencies were identified. It is recommended that close
collaboration is ensured in the future between plant health and environmental policies
and authorities.
Some inconsistencies and concerns were expressed by stakeholders, such as the
potential implications of the anticipated limited availability of PPPs due to the limited
number of permitted active substances. However, due to the recent entry into force of
the new PPP legislation, FCEC considers that it is premature to judge on the
inconsistencies between PPP legislation and CPHR. The extent to which the
possibility for derogation in case of minor crops and in case of serious danger for plant
health will be used and granted in practice as well as the extent to which the PPPs for
which derogation are requested are likely to be available to farmers are not known at
this stage.
Several means exist for EU financial support to plant health management such as the
solidarity regime managed by DG SANCO, the ‗Article 68‘ measures of the ‗Health
Check‘ of the CAP as well as measures 225, 226 and 227 under the Rural
Development Regulation 1698/2005, and - in a complementary role - crosscompliance
to provide incentives for better prevention. Not all schemes have the same
objectives, eligibility criteria and rules for co-financing by the EU. Given the existence
of these multiple schemes, it is recommended that improved communication is ensured
between DG AGRI and DG SANCO. The usefulness of a future plant health fund
should be further explored.
Suggestions for improved cooperation were made, such as better linkage of Plant
health and Customs IT systems (e.g. correlation between the lists of products subject
to quarantine and customs nomenclature), improved cooperation between competent
services.
No inconsistencies were identified. It is recommended that the CPHR gain from with
the experience of the EU Animal Health Strategy, in relation to some principles or
concepts.
Food Chain Evaluation Consortium 268