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)
alia to the currently system of inspections, deemed to be insufficient, as demonstrated by the
2005 FVO review of the plant passport system 294 and subsequent FVO report updates), nor to
allow product traceability back and forward in the chain to ensure corrective action can be
taken in case of outbreaks.
These findings were largely confirmed by the feedback of participants to the February
conference, with participants generally acknowledging that there is need to review some
aspects of the system, although the views on what this may involve were more mixed. This
may be due to the fact that implementation and the experience of MS has been so uneven, that
it will be difficult to find consensus. There is also lack of sufficient incentives, as compliant
cases have invested heavily in implementing the current system, while non compliant cases
have no incentive to strengthen implementation. Reluctance and the lack of incentives to
revise the system has been demonstrated by the failure of past attempts e.g. to improve
harmonisation of plant passport document. These issues need to be taken into account when
examining possible options for the future.
A variant option which has emerged from the discussion at the February conference would be
to cancel the plant passport document (i.e. going further than option iii) below) and replace it
by a plant health mark or logo. This draws in particular from the identification system applied
in the animal health sector, where a health mark is used on products of animal origin when
stipulated by the legislation 295 and in conjunction with the electronic traceability system
established in this sector (TRACES 296 ). The objective of this option is to improve traceability
via a fully harmonised product identification system, supported by an electronic database.
Anticipated benefits would therefore include improved identification, traceability, and
simplification from the current system. However, the costs of moving to this system could be
substantial. TRACES records some 50,000 movements of intra-EU transactions in products of
animal origin per month, and the management of the database costs some €2 million per year
and involves 10 IT specialists (costs at the level of the Commission alone, excluding MS
costs/resources in providing inputs to the database). In the plant health sector, where the scope
of products/trade flows is larger, the number of movements is expected to be significantly
higher (provisional estimates are that there may be more than a million of intra-EU exchanges
per month).
Certain stakeholders and a few MS CAs are advocating the need for increased business
operator involvement in the way official inspections are carried out under the plant passport
system, with more responsibility given to business operators to carry out checks, particularly
294 Overview report of the result of a series of missions carried out in MS in order to evaluate the implementation
of the Plant Passport System (2005). It covered the results of the missions carried out in 17 MS (BE, EL, DE,
DK, IT, SE, SK, UK, NL, PT, FR, SI, CZ, PL, HU, LV, ES).
295 Where required by Regulation (EC) No 853/2004 (laying down specific hygiene rules for food of animal
origin), products must be given a health mark applied in accordance with Regulation (EC) No 854/2004 on
official controls on products of animal origin or, failing this, an identification mark applied during or after
production; this mark must be legible, indelible and clearly visible for the CAs, and must show the name of the
exporting country and the establishment's approval number.
296 TRACES: TRAde Control and Expert System) is a trans-European network for veterinary health which
notifies, certifies and monitors imports, exports and trade in animals and animal products
Food Chain Evaluation Consortium 353