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)
Finally, the application of the concept of protected zones in the EU and its non full alignment
to the pest free area concept (see section 3.6) can cause some confusion in third countries
leading to difficulties for an EU exporter to explain the real pest status within the EU, in
particular pest free areas for pests not regulated within the EU (e.g. Tuta absoluta).
During the evaluation, interviewees have highlighted the following points that lead to direct
or/and indirect increase of costs:
Third countries are not operating on the same transparent basis as the EU. Their
approach tends to be based on ‗guilty until you prove innocent‟. The costs borne by EU
exporters to demonstrate products are free of pests (which generally involved the
conducting of full PRAs) are often prohibitive and can be a barrier to trade. Only, large
export trade justifies the costs of carrying out full PRAs;
Many third countries do not apply the IPPC rules for import of plant and plant products;
The fact that trading partners have substantially variable requirements for additional
declarations on phytosanitary certificates, leads to very high complexity and costs to
comply for EU exporters. This is particularly the case for seed trade which is very
international and repeated re-export of seed lots is frequently occurring. This leads to
the need for phytosanitary inspections for many different HOs;
Accessibility of requirements of international trading partners is perceived as an
additional cost as today there is no global searchable database containing the
phytosanitary requirements per species and per country of origin;
EU phytosanitary import requirements for many plants and plant products are perceived
to be lighter than those of third country major trading partners. Trading partners are
generally considered to apply more import restrictions or prohibitions. Thereby markets
in third countries are perceived to be ―protected‖ while for imports into the EU the
doors are open. Differences in implementation and costs of phytosanitary import
controls may therefore lead to distortion of trade;
The concept of the EU plant health regime stating that ‗everything can be entered in the
EU unless it is prohibited‘ offers a good position to third country exporters. In addition,
plant health requirements are not difficult to be met. This, together with the eventual
lower production costs in certain third countries, promote the competitiveness of
imported commodities on EU markets, to the detriment of EU producers;
4.3 Intervention logic (future)
Following the analysis of the current performance of the CPHR, and the identified strengths,
weaknesses, opportunities and threats of the regime, and in view of the evolving needs and
challenges ahead, an adapted intervention logic was developed for the future EU plant health
policy, as presented below.
A key feature of the new intervention logic is that it proposes an adaptation to the current
regime rather than a complete change. It therefore responds to the identified need for
‗evolution rather than revolution‘ in EU plant health policy. Thus, the top level objective
includes the broader economic growth, cohesion and competitiveness goals of the Lisbon
Treaty, while the historical objective has been amplified to reflect the broader EU goals in the
Food Chain Evaluation Consortium 301