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)
Although the findings of the evaluation on the significant failures of the current
implementation of the PZ system were largely confirmed by the feedback of participants to
the February conference, and despite earlier indications in the general survey response, the
conference and subsequent response identified insufficient support for a more profound
revision of the system. As in the case of the plant passport system, to some extent this reflects
the fact that implementation of PZs and the experience of MS has been very varied, and this
makes it difficult to find consensus 298 . MS that currently benefit from PZs largely want to
maintain the status quo, while MS that do not benefit or may actually incur costs from the
system (for example because their products cannot enter a PZ) want to revise the system.
These issues need to be taken into account when examining possible options for the future.
An analysis of the PFA concept and comparison to the EU PZ system was already provided in
section 3.6.3). It is important to note that the PZ and PFA concepts are not necessarily
alternatives and indeed could be complementary. Both concepts aim to guarantee freedom
from pests. However, while the PZ concept in practice focuses on guarantees to prevent the
introduction of a pest into the protected zone via intra-EU movements and imports (with the
ability to export under the same guarantees being a subsidiary objective), the PFA focuses on
ensuring that products can be exported from the area free of pests (with the ability to enforce
requirements on guarantees for imported products as a subsidiary objective). In this sense, the
PZ system allows protection via specific requirements on imports while the PFA system
allows freedom to export via certification. It is therefore possible that a MS or area within an
MS applies the two concepts simultaneously.
As also previously noted (in section 3.6.3), the credibility issue (vis à vis third countries) is
not unique to the EU PZ system, but these are common problems and relatively frequently
occurring with PFA recognition in the WTO-SPS and IPPC context (IPPC established an
open-ended working group to examine the feasibility of international recognition of PFAs and
concluded that this was not seen as achievable).
In conclusion:
The key problem with PZ system is loss of credibility from poor implementation, but PFAs
can also be difficult to implement and can thus result in poor implementation;
In this sense, whatever option will be selected the key objective needs to be to restore
credibility;
PFAs are not an alternative to PZs, indeed in the context of the single market (i.e. no
internal controls on movement of products within the EU) the PFA concept would be
difficult to implement without the form of regionalization currently offered by PZ (
protection within the area);
298 It is noted that in the general survey a large number of respondents (6 MS CAs and 15 stakeholders) indicated
‗do not know‟, and it was confirmed that this largely reflects the divergence in positions even within
organisations.
Food Chain Evaluation Consortium 358