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)
5.2 Prevention strategies at import (risk analysis and targeting of risks)
A clear outcome of the evaluation is the need for more and better prevention in the system.
Prevention measures start with controls at external borders (and before that, from compliance
to requirements by the exporting country). The monitoring of the internal EU territory is
another key factor that allows a quick action in case HOs have been introduced. Improving
prevention strategies touches upon the extent to which there is a need to prioritise and how to
achieve this, so as to better target measures, in view of the evolving challenges and current
resource constraints. The emphasis of any prioritisation would be to improve prevention, and
does not therefore imply a narrowing of the scope of the regime.
Measures within the EU could also be strengthened for a more coordinated and consistent
approach than is the case at present, and to face up to the new challenges.
5.2.1 Background
The EU is currently the largest food importer in the world. As discussed in section 4.1.2, in
the context of the significant expansion in trade volumes and change in trade patterns (new
products and sources of supply), the EU is faced both with increasing and emerging risks of
introduction of HOs. These trends, which have already been witnessed in the last decade, are
occurring in the context of reduced administrative and financial resources at MS level for
inspections. The current system of import controls may therefore not be fully appropriate to
cope with these new challenges. The question is therefore whether new tools or strengthening
of the existing ones should be foreseen. Measures within the EU could also be strengthened
for a more coordinated and consistent approach than is the case at present (as discussed in
section 3.4), and to face up to the new challenges.
A range of measures can be envisaged to improve prevention at point of entry. The need for a
more precautionary approach via a long list of HOs to be subject to specific import controls
(adjusting current Annexes 1 and 2 of the Directive) has been identified, along with a specific
approach for risk analysis of new trade in plants for planting and plant propagating material
based on commodity pathway analysis. In all cases, any revisions to the lists need to be based
on Pest Risk Analysis (PRA), but the process needs to be accelerated (fast track) in
emergency situations. The existing EPPO lists (A.1 and A.2 as well as the Alert list) and
PRAs need also to be taken into account in this process.
Within the continuum of risk and risk management (presented in following figure), in an ideal
system, the exporting country‘s certification system should be first in the spectrum of risk
management; in accordance with international principles (IPPC, EPPO) the primary
responsibility for ensuring phytosanitary compliance in international trade rests with the
exporting country. Import inspections follow next, their role being to provide a check on the
first point. The less the objective of phytosanitary controls is attained at the first point of the
spectrum (i.e. by exporting country), the more there is need for intervention at the following
point (i.e. by the importing country). Furthermore, the less the importing country is effective
in detecting risks at an early phase (for which collaboration with exporting country is
essential), the more it would be obliged to increase the severity of the measures taken, moving
towards the end of the spectrum. Post-entry inspections, quarantine and prohibitions are
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