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)
• Objective: prevention of the entry, establishment and spread of HOs either to
protect free EU territory or to protect production/trade
• Coverage CPHR: all HOs with zero tolerance + RNQPs with tolerance levels
other than zero
• Coverage S&PM: all HOs for which "substantially free" is satisfactory
• Consequences: most HOs move from S&PM to CPHR. New annex of CPHR is
created for HOs for which non zero tolerance is applied– example: potato scab
The simplest option would be to maintain the status quo (i.e. PH regime remains quarantine as
currently) and simply review some of the ‗borderline cases‘ (option i). A disadvantage of this
approach might be that being determined on a case by case basis rather than by a systemic
review of the overall approach, the differences in objectives and intervention logic of the two
regimes, and the consequences for listing HOs in one or the other set of legislation, might
remain unclear and sustain the existing confusion.
The two variants (options ii and iii) introduce RNQPs in the current PH regime, but in option
ii tolerance remains zero and in option iii tolerance can be greater than zero. In terms of the
suitability of the plant health regime to cover RNQPs with threshold levels other than zero
(option iii), the question to address is whether RNQPs should be introduced into what has so
far been a quarantine regime, as this would imply the introduction of the principle of tolerance
levels and may therefore alter the objectives and the appropriateness of the measures foreseen
by the current plant health regime.
Option ii largely concurs with the outcome of the Commission‘s 2004 WG on RNQPs (see
section 3.2.2), which concluded that the concept of RNQP with tolerance > 0 may be very
complex, expensive and difficult to implement under the mechanisms provided by the
Directive 2000/29/EC.
Due to the overlap of this theme with the S&PM acquis, the potential benefits of synergies
between the CPHR and S&PM could not be considered in the context of the present
evaluation and would need to be explored further if options ii or iii are to be followed.
Recommendation 3:
The analysis of the options suggests that option ii (Zero tolerance regime, PH: RQPs +
RNQPs; tolerance = 0) would be the most recommended, on the basis that it represents
the best balance of advantages/disadvantages against anticipated impacts. It is noted that
the assumption is made that the improvements suggested in the status-quo will also be
taken on board.
It is also recommended that the potential benefits of synergies between the CPHR and
S&PM are further explored.
Food Chain Evaluation Consortium 326