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2454 final report.pdf - Agra CEAS Consulting

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Evaluation of the Community Plant Health Regime: Final Report<br />

DG SANCO Evaluation Framework Contract Lot 3 (Food Chain)<br />

5.2.2 Options and analysis<br />

In general terms, the evaluation results as confirmed by the February conference have<br />

demonstrated that there is need to reassess the current system of import controls with a view<br />

to improving its role in the overall EU phytosanitary regime. In particular, consideration<br />

should be given to defining the appropriate tools for effective and efficient risk assessment<br />

and risk management, within the continuum of risk (see figure above).<br />

In this context, the options identified for further consideration are as follows:<br />

i. Status quo with improvements („soft‟ interventions);<br />

ii. Widen the list of HOs subjected to import controls (Annexes to Directive 2000/29/EC);<br />

iii. For emerging risks (particularly new trade in plants for planting/ propagating<br />

material (PM): commodity pathway analysis;<br />

iv. For plants for planting/propagating material strengthen measures:<br />

a. Official post entry inspections for latent HOs;<br />

b. Improve collaboration with country of origin, including via pre-export inspections<br />

where necessary (e.g. on the basis of repeated interceptions for certain products<br />

from certain origins);<br />

c. On the basis of commodity pathway analysis, introduce import bans where<br />

necessary.<br />

As indicated within the above figure on the risk management continuum, a more targeted<br />

approach by pathway is suggested to target higher risk import flows. This would differentiate<br />

between:<br />

Fresh produce: for which entry inspections appear to provide sufficient control. For this<br />

category of products, further improvements to the current reduced frequency checks<br />

system could also be considered, to improve both the effectiveness and the efficiency of<br />

the inspections (thereby releasing resources to focus on higher risk products). Also<br />

synergies with existing certification systems where these are established to cover quality<br />

issues could be considered, e.g. to extend coverage to phytosanitary issues;<br />

Plants for planting/PM (e.g. entry and post-entry inspections at growing sites): for which<br />

there should be some shift from inspections at the point of entry, where detection of latent<br />

pests and diseases is difficult, to inspections at growing sites. For this category of products,<br />

in addition to strengthening inspections, a series of further measures can be taken, the<br />

severity of which will depend on risk analysis. Such measures range from a more targeted<br />

approach for new types of trade by modelling risks of imports from emerging supply<br />

sources, to pre-export inspections, or even import bans where necessary. Within this sector,<br />

a more specific approach may be considered for the seeds industry (seeds for planting),<br />

which is generally already using extensive certification systems to monitor product quality,<br />

and – subject to further examination of the appropriateness of these systems in the context<br />

of phytosanitary inspections - there may be scope to take these into account to adjust<br />

accordingly the level of inspections that may be required for these products.<br />

Food Chain Evaluation Consortium 332

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