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)
information was available it would need to be related to the flow and pattern of trade to
provide meaningful results.
The main difference between the CPHR regime and the majority of third countries is based on
the import conditions that are conceptually different. The concept of the EU plant health
regime states that ‗everything can enter the Community unless it is prohibited‘ while for the
majority of third countries the approach tends to be based on ‗guilty until proven innocent‟.
Import permits are required even for individual consignments in the case of Argentina. These
fundamental differences in approach have the following implications in practice for EU
traders exporting to third countries:
Imports of plants and plant products into some of the selected third countries require
authorisation based on the evaluation of the import permit request (PRAs). This exercise
can take several months to several years (sometimes decades);
In addition to authorising imports, several third countries, e.g. the US and Canada, have
in place offshore inspections (pre-clearance programs) and foreign site audits;
Authorisation of imports of certain plants and plant products may be subject to the need
to position products in post-entry quarantine.
In addition, several other differences between the current EU and selected third country
phytosanitary regimes are noted, as follows:
The number of HOs listed in the various regimes is quite different. It can range from
less than 200 HOs listed in Canada to more than 400 in e.g. Argentina. In the US there
is no comprehensive closed list of HOs defined in the regulation;
As a possibility defined by the IPPC Convention, a limited number of IAS plants are
already included in the list of regulated HOs by most of the presented third country
regimes;
No clear prioritisation system is in place in the majority of the studied regimes. The US
national survey program (CAPS) follows some prioritisation, and is shifting its strategy
from being ―pest-specific‖ to surveying for several pests on a ―commodity‖ basis 260 ;
Passengers are inspected in several countries e.g. USA, Australia and NZ;
Emergency teams are in place e.g. in the USA (Rapid Response Teams).
During the interviews with the selected third country official representatives, several
comments were made on how third countries perceive the EU system, as follows:
The fact that the EU legislation is applied to the whole EU territory is being seen as an
inconsistency as agro-climatic conditions and hence plant health issues are different
from one region to another. Therefore the application of a unique list of regulated pests
to the whole EU-27 is not seen as being consistent e.g. regulation of citrus pests in
countries with temperate climates in which citrus plants are not grown;
The separation of responsibilities and competence between DG SANCO for the import
regime and DG TRADE for export support to individual MS is being seen as a major
260 The US CAPS model is examined further under the options for the future (prevention intra-EU: surveillance,
section 5.3).
Food Chain Evaluation Consortium 270