Overview reportPhytosanitary Controls on Plants for Planting and Seeds to be Exported to the European Union

DG Health and Food Safety

Health andFood Safety

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EUROPEAN COMMISSIONDIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY

Health and food audits and analysis

DG(SANTE) 2019-6865

OVERVIEW REPORT

ON A SERIES OF AUDITS CARRIED OUT IN NON-EU COUNTRIES

IN ORDER TO EVALUATE THE PHYTOSANITARY CONTROLS

ON PLANTS FOR PLANTING AND SEEDS

TO BE EXPORTED TO THE EUROPEAN UNION

Ref. Ares(2019)6455266 - 18/10/2019

Executive Summary

This overview report describes the outcome of a series of audits carried out by the Directorate-General for Health and Food Safety of the European Commission in non-EU countries between May 2015 and March 2018 to evaluate the system of official plant health controls for the export of plants for planting and seeds to the European Union (EU).The report concludes that the plant health risk of importing plants for planting and seeds from the audited countries varies by country, grower and type of product. Many harmful organisms (HOs) regulated by the EU are widespread in the exporting countries with various levels of prevalence. The production technologies can reduce the plant health risk but cannot ensure that the place of production or the consignment is free from HOs.The competent authorities of the exporting countries had generally appropriate capacities for inspections related to exports to the EU. However, it was not the case for countries with the highest export volumes or with seasonal peaks in trade. The developing countries had no budgetary resources for completing the export inspection tasks. In the exporting countries official controls are not always carried out in line with EU import requirements, in particular concerning the frequency of inspections at the place of production In some cases only a non-representative part of the place of production or of the export consignment is sampled and checked. In addition, in many cases the inspections are insufficiently thorough considering the HOs associated with the plants for planting and seeds concerned. This, in turn, impacts on the effectiveness to detect these HOs when present in the place of production or in the consignment.The audits identified the following specific issues, which pose a phytosanitary risk for the EU: Bemisia tabaci is widespread in each country audited. The EU requires that the place of

production is free from the pest. This is not the case in many countries and therefore it is not guaranteed that the imported goods are free from this whitefly and the viruses transmitted by it;

The majority of the countries audited do not fully observe the EU requirements related to the growing medium, in particular, for plants with an open field growing phase. There is a plant health risk that soil-born HOs, in particular nematodes, are present in the growing medium of the imported plants. It is advisable for the Member States to sample and test the growing medium attached to the plants for planting.

The majority of the competent authorities in the countries audited struggled with understanding and interpreting EU import rules. As a consequence there are numerous interceptions of plants for planting and seeds due to reasons other than HO presence, in particular concerning inaccurate additional declarations on the phytosanitary certificates. Additional efforts are needed to inform the exporting countries about the EU rules in commonly understandable form and about the pragmatic aspects of achieving conformity with those in particular as revised EU plant health rules enter into application by the end of 2019.

To protect the health of plants in the EU, the European Commission continues to conduct audits, train staff from exporting countries and regularly updates EU legislation to limit the potential risks.

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Table of Contents1 Introduction ....................................................................................................................................12 Objectives and scope......................................................................................................................13 Legal Basis .....................................................................................................................................2

3.1 Relevant EU Legislation..........................................................................................................23.2 International standards.............................................................................................................3

4 Background ....................................................................................................................................34.1 EU imports of plants for planting and seeds ...........................................................................34.2 EU interceptions of consignments of plants for planting and seeds........................................4

5 Main findings and conclusions of the audits..................................................................................55.1 Impact of production technologies to the plant health risk for the EU ...................................55.2 Organisational aspects of the plant health controls ...............................................................135.3 Phytosanitary status of harmful organisms in the countries audited .....................................155.4 Procedures for inspections for export to the EU ...................................................................175.5 Phytosanitary certificates.......................................................................................................215.6 Action taken in response to internal findings and EU notifications ......................................24

6 Matters for consideration .............................................................................................................257 Actions taken or planned by Commission services......................................................................26

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ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT

Abbreviation Explanation

ADAdditional declaration on the phytosanitary certificate to certify the conformity of the consignmentswith certain EU import requirements

CA(s) Competent Authority(ies)

CN Combined Nomenclature of the EU for classifying goods for customs and statistical purposes

ConsignmentAs defined by ISPM 5: a quantity of plants, plant products and/or other articles being moved from one country to another and covered, when required, by a single phytosanitary certificate

DG Health and Food Safety Directorate-General for Health and Food Safety of the European Commission

ELISA Enzyme Linked Immunosorbent Assay

EU European Union

EUROPHYT-Interceptions European Union Notification System for Plant Health Interceptions

EUROSTAT EU Statistical Office

HOOrganism, harmful to plants or plant products (harmful organism) as defined by Article 2(1)(e) of Council Directive 2000/29/EC and listed in Annex I and II of that Directive.

IPM Integrated pest management

IPPC International Plant Protection Convention

ISPM International Standard for Phytosanitary Measures

MS Member State of the European Union

NPPO National Plant Protection Organisation

PC Phytosanitary certificate, as defined by ISPM 7 and ISPM 12

PCR Polymerase Chain Reaction

Plants for planting Plants, intended for planting, as defined by Article 2(1)(d) of Council Directive 2000/29/EC.

Seeds Seeds, subject to EU import phytosanitary requirements, as referred to by Annex IV Section I Part A and Annex V part B of Council Directive2000/29/EC.

SOP Standard Operating Procedures

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1 INTRODUCTION

This overview report summarises the findings and conclusions of a series of audits, carried out by the Directorate-General for Health and Food Safety of the European Commission (DG Health and Food Safety) in non-EU countries, which are the major exporters of plants or plant parts intended for planting (plants for planting) and seeds for sowing, subject to EU import phytosanitary requirements (seeds). Eleven audits were carried from February 2015 to March 2018. Annex II contains information about the countries visited, audit dates, reference numbers and provides links to the website of the DG Health and food safety, where the reports are published.

2 OBJECTIVES AND SCOPE

Plants for planting and seeds are considered as high-risk products from a plant health perspective. They provide a viable pathway for organisms harmful to plants or plant products (HOs) to introduce and spread within a territory of the EU in particular as they are grown on after the entry into the EU or serve as propagating material rather than being consumed shortly after the importation. In addition to listing the HOs the EU legislation sets specific requirement for the import of plants for planting and seeds to manage the existing plant health risk. In line with the provisions of the International Plant Protection Convention (IPPC), the National Plant Protection Organisation (NPPO) of the exporting country is obliged to guarantee that the exported goods meet EU import requirements.

The objective of the audit series was to assess the system of official plant health controls in the exporting countries of plants for planting and seeds. Specific attention was paid to the factors which influence the plant health risk related to the EU imports in particular: The presence and level of prevalence of the HOs in the entire country or areas and places

of production and; The cultivation method, in particular pest controls, applied by the growers,

Concerning the HOs and products the assessment concentrated on: The HOs, where the EU requires that the place of production (or the area/country) is free

from the pest (Bemisia tabaci, Liriomyza sp. a range of viruses and virus like organisms); Xylella fastidiosa and Anoplophora chinensis, which are subject to specific EU

requirements; The growing medium in which plants for planting are imported; Bonsais from China; Tomato (Lycopersicum esculentum) pepper (Capsicum sp.) and bean (Phaseolus sp.)

seeds.

For the audit the countries with the possibly highest phytosanitary risk were selected, based on the range and volume of imports (see chapter 4.1.) and the number of interceptions for plant health reasons (see chapter 5.2.). In the official controls on plants for planting and seeds were assessed as part of a broader scope audit.

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The audits were carried out as part of the planned annual programmes of the DG Health and Food Safety and in agreement with the National Plant Protection Organisation (NPPO). Most missions lasted for six to ten working days and were carried out by a team of two auditors of DG Health and Food Safety, assisted by one expert of the CA of an EU Member State (MS). The audits included usually meetings and visits to places as follows: Meetings with representatives of the NPPO and other CAs involved in the phytosanitary

export controls at country, regional or local level; Places, where plants for planting and seeds were produced, processed and packed for

export to the EU (production sites, packaging houses); Places where the consignments of plants for planting and seeds, prepared for export to

the EU were officially inspected; Places where the export phytosanitary certificates (PCs) were issued; Laboratories, which carried out analysis of samples, collected during official inspections

and surveys.The visited places were selected by the NPPO or suggested by the audit team based on the information of the notifications about the intercepted consignments (see chapter 4.2).

3 LEGAL BASIS

3.1 RELEVANT EU LEGISLATION

Council Directive 2000/29/EC provides for protective measures against the introduction into and spread within the EU of HOs. This Directive requires that each consignment of plants for planting and seed must be accompanied by a PC. The Annexes of the Directive contain detailed import rules. For many plant species specific conditions are set, mainly in the form of options, depending on the plant health status of the country, the area, the place of production and the specific HO(s) of concern to the EU. The NPPO of the exporting country shall certify on the PC in the form of an additional declaration the chosen option and certify that the required conditions are met.

Following outbreaks of Anoplophora chinensis in the EU emergency measures were published to prevent the introduction into and the spread of this longhorn beetle. Decision (EU) 2012/138 sets specific conditions for the production and import of host plants of the pest.

Following outbreaks of Xylella fastidiosa in the EU territory emergency measures were implemented. Decision (EU) 2015/789 introduces an import ban on Coffea sp. plants from Honduras and Costa Rica and sets specific import provisions for a wide range of plant species and genera, referred to as 'specified plants' in relation to the pest. Import conditions depend on whether the bacterium is present in the exporting country or not.

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All EU legislation referred to in this overview report is listed in Annex 1. References to legislation are to the latest amended version, where applicable.1

3.2 INTERNATIONAL STANDARDS

Article X (4) of the International Plant Protection Convention (IPPC) establishes that contracting parties should take into account, as appropriate, international standards when undertaking activities related to the Convention. The International Standards for Phytosanitary Measures (ISPMs), issued by the IPPC provide a basis, in addition to the EU import requirements, for evaluating official export controls in contracting parties. The full text of the IPPC and of all adopted ISPMs is available on the IPPC website (www.ippc.int). The ISPMs of particular relevance to this overview report are listed in Annex III.

4 BACKGROUND

4.1 EU IMPORTS OF PLANTS FOR PLANTING AND SEEDS

There are no detailed statistical data available about the volume and value of the EU import for plants for planting and seeds subject to import phytosanitary requirements as the Combined Nomenclature for customs and statistical purposes (CN) does not include specific codes for these products. CN codes 0602 (live plants including their roots, cuttings and slips) and 120991 (vegetable seeds for sowing) cover the vast majority of the products subject to the audit and provide an estimate about the volume and value of the imports.

According to the figures of the EU Statistical Office (EUROSTAT), in the period 2013-2017, the annual volume of EU imports of consignments with CN code 0602 varied between 82,000 and 114,000 tonnes with an annual value of 280 to 322 million euros (see Table I and II in Annex IV). The audited countries supplied about 55-65% of the total EU imports of these products. East-African and Asian countries, Israel and Guatemala export dominantly high value cuttings without growing medium, while plants with growing medium or rooted large canes are dominating the imports from Central America and China.

In the period 2013-2017 the annual volume of EU imports of consignments belonging to CN code 120991 varied between 9,700 and 10,500 tonnes with an annual value between 283 and 405 million euros (see Tables III and IV in Annex IV). The audited countries supplied about 25-35% of the total EU imports of these products.

1 See the EUR-LEX database https://eur-lex.europa.eu/advanced-search-form.html. It may assist the reader to consult the consolidated text of the act, stored in EUR-LEX, although it has been prepared purely as a documentation tool and has no legal effect. Consolidation consists of the integration in a legal act of its successive amendments and corrigenda. It provides more transparency and easier access to EU law. Several legal texts published in different issues of the Official Journal of the European Union (OJ) are combined in one easy to read document. The EU institutions do not assume any liability for the consolidated contents. The authentic versions of the relevant acts including the amendments are those published in the Official Journal of the European Union and also available in EUR-LEX.

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The majority of tomato and pepper seeds, exported to the EU are of high value hybrid varieties. In the period 2013-2017 the volume of vegetable seed imports from China decreased significantly, while the value remained the same probably due to the increasing share of hybrid seeds.

The CAs of the audited countries provided statistics about the production and export to the EU of plants for planting and seeds (see web-links to the audit reports in Annex II). Annex V provides for a summary of the types of products and lists the main plant species, which are exported by the audited countries to the EU.

MSs import a wide range of types of plants for planting, such as unrooted cuttings, rooted cuttings in growing medium, air layered or free cut canes with callus, potted plants, scions or grafted plants. The imported products belong to numerous species and genera of herbaceous annual, perennial or multiannual, semi-woody or woody plants. Annex V. indicates the main plant species/genera and type of products imported from the audited countries. The majority of the plants for planting are imported by the Netherlands, Spain, Italy, Germany, Poland and Belgium. Vegetable seeds are mainly imported by the Netherlands, Italy, France, Romania and Bulgaria.

4.2 EU INTERCEPTIONS OF CONSIGNMENTS OF PLANTS FOR PLANTING AND SEEDS

In the period of 2013-2017 MSs and Switzerland reported the interception of 448 consignments of plants for planting and 97 consignments of seeds due to the presence of HO to the EU Notification System for Plant Health Interceptions (EUROPHYT-Interceptions). The countries subject to audits were the origin of 42-58% of the interceptions (see Table I in Annex VI).

Annex VI contains detailed information about the number of interception, intercepted HOs, plants and seeds from the audited countries. In the case of plants for planting the most often intercepted HOs were the whitefly Bemisia tabaci, leaf miners (Liriomyza sp.) thrips species (Thysanoptera) soil nematodes (e.g. Aphelenchoides sp., Ditylenchus sp., Meloidogyne sp,. Xyphinema sp.), moths (e.g. Spodoptera sp.), viruses and virus like organisms (e.g. chrysanthemum stunt viroid). In some consignments form China Anoplophora chinensis was also intercepted. In the consignments of seeds viruses and virus like organisms (potato spindle tuber viroid, lettuce mosaic virus, tomato spotted wilt virus) and harmful bacteria (in particular Clavibacter michiganensis subsp. michiganensis and Xanthomonas axonopodis pv. phaseoli). Annex VII contains detailed information about the interceptions with HO from the audited countries.

In the period of 2013-2017 the number of consignments intercepted for reasons other than presence of harmful organisms was 2,679 for plants for planting and 2,303 for seeds (see Table II. in Annex VI). The main issue was the absence of the PC followed by the absent or inappropriate additional declarations.

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5 MAIN FINDINGS AND CONCLUSIONS OF THE AUDITS

5.1 IMPACT OF PRODUCTION TECHNOLOGIES TO THE PLANT HEALTH RISK FOR THE EU

5.1.1General aspects

Growers in the countries audited apply significantly different production and pest control technologies of plants for planting and seeds which have different impacts on the plant health risks for EU. In general the growers of plants for planting are large or medium size companies which made considerable investments to establish appropriate production facilities for meeting the specific quality requirements of the EU market. The seed production is usually carried out or organised by multinational seed companies in isolated greenhouses, or by contracted and supervised growers.

The production takes place according to the requirements of the EU clients, who usually supply the high grade mother plants of stock seed and also supervise the crops and the export preparation.

The presence of any pest or disease in the consignment or any symptoms of suspected infection or infestation is usually considered as a quality issue. Therefore the growers aim to produce goods free from any known pest. The tropical or subtropical climate at the places of production and the microclimate of the greenhouses provide favourable conditions for any pest and disease, including HOs. Ensuring that the crop and/or the consignment are free from HOs requires specific efforts by the growers.

The growers consider that the application of integrated pest management (IPM) is an asset for meeting quality standards and provides for additional guarantees. However, the level of IPM implementation varied broadly in the countries and among the growers visited by the audit teams.

The use of sticky traps and regular scouting the crops for pests was a common practice. The majority of the growers applied weekly or more frequent chemical treatments in the crops. In addition extra spot treatments were carried out if the scouts detected any issue. Usually directly before the harvest the crops were treated with pesticides. These measures were in line with the approach recommended by ISPM No. 36. However, the EU interceptions indicate that the frequent use of pesticides often leads to resistance and it does not guarantee that the crop or the consignment is free from HOs.

The growers and NPPO inspectors met by the audit teams often highlighted that it is very difficult to ensure that the place of production and/or the export consignment is free from HOs while the products must also be in compliance with the pesticide residue requirements of the EU or of the private standards set by the EU importers.

It was also highlighted that there is an increasing tendency for using of bio-control agents in the production of plants for planting for EU export due to the positive environmental, work security and pesticide residue effects. However, bio-control agents often have a lower effectiveness and leave a low HO prevalence in the crops, which is not in compliance with EU requirements..

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Many growers use greenhouses covered by insect proof nets for production for the EU market. The commonly applied mesh size is 50 (the number of openings per inch, an average opening size of 300 microns). This net can efficiently prevent the penetration of the HOs (the only exceptions are some thrips species). Strict observation of other conditions, such as double-door system with restricted access, pressurised environment, hygiene protocols and immediate reparation of any net damage is essential for the isolation.

The growers maintained significantly different levels of HO protection in the screen-houses. In many cases the construction and the applied measures provided very high level of protection against HOs. However, even in the highest standard establishments HO presence could be detected occasionally. At many growers issues, such as improper double doors, mechanical damages, and unregulated access strongly compromised the level of HO protection.

Some growers used filtered and UV treated water for irrigation, which provided for good protection against the introduction of HOs, in particular bacteria. However, the majority of the growers used untreated water without checking the possible presence of HOs.

During the harvest and packaging the majority of the growers operate multi-level quality control systems. The control staff is usually well aware of the symptoms of the major pests in the crop, including HOs of EU relevance. However, a typical shortcoming was that not the entire consignment was subject of quality controls.

5.1.2Unrooted cuttings

EU importers prefer the equatorial highland areas for the production of unrooted cuttings production as the climatic conditions and the standard day length allows year-around cropping. The high grade mother plants usually originate from the EU in the form of unrooted cuttings or in-vitro culture. The exported cuttings are generally the second to fourth generation of the imported stock. Some growers export to the EU cuttings originated from own breeding or from material sourced locally.

In the case of species imported in the largest volumes (e.g. Chrysanthemum sp.) the EU market requires material which is free from any viral or bacterial infection. Therefore companies use in vitro nuclear stock which is tested and apply a statistically based private testing regime for the different generations of mother plants. The crops are kept in screen-houses, where a strict pest control regime is applied. The life span of the mother plant crops varies between 3-4 months and many years. After the crop is established (3-8 weeks after planting), cuttings are harvested continuously with a usual frequency of 2-3 times per week. The cuttings are subject to multi-level quality during the harvest and packaging and are sent to the EU by air (see figures I to III).

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Figure I. Mother plants in screen-houses for unrooted cutting production for export to the EUin Guatemala and in Uganda

Figure II. Pelargonium sp. and Ajuga sp. mother plants in Kenya

Figure III. Unrooted cutting production in a screen-house in Israel

The growers with advanced facilities ensured high level of protection against the introduction of HOs to the crops. However, even in the screen-houses of the highest standard HOs could be detected occasionally, especially Bemisia tabaci.

In many isolated places of production the HO protection was not ensured due to issues with inadequate double doors, hygiene protocols and maintenance. In some of the greenhouses the audit teams detected white flies during their visits (see figure IV).

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Figure IV. Insufficient protection against insect vectors and a cutting infested with white flies (Kenya, Tanzania)

Although the EU legislation requires that plants for planting of all herbaceous species, Ficus sp. and Hibiscus sp. must originate from places of production free from Bemisia tabaci, some species, which the growers consider as non-host of the pest, were produced in non-isolated environments (e.g. Ajuga spp. was considered as non-hosts until the first EU interceptions).

5.1.3Rooted cuttings produced in greenhouses

Cuttings of certain plant species are imported into the EU in growing medium. The cultivation method is similar to that described in chapter 5.1.2. The mother plants are usually kept in screen-houses. The harvested cuttings are planted in small containers or trays with holes. The growing medium is usually a mixture of peat (imported from the EU) and coconut fibre (imported from Asia). Some companies apply heat treatment before export, but others not because the peat moss is of EU origin and the coconut fibre is considered as sterile (see figure V).

The rooting lasts for a couple of weeks in isolated or non-isolated greenhouses, depending on the species. The plants are usually kept on tables or shelves, which ensures the isolation from the ground soil and prevents HO migration into the growing medium. Only a few companies use treated water.

Figure V. Rooted cuttings in Tanzania ready for export to the EU

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5.1.4Plants with a field growing phase or exported in growing medium

Central-American countries are the main exporters of plants with an open-air growing phase. Various growing technologies are applied for the different plant genera and species.

Yucca sp. plants are cultivated in plantations or also grown in the wild to produce canes of a stem length and diameter for export. Canes with leaves, collected from the field, are in growing beds for 10-12 days for callus development, then treated with pesticides and exported without leaves in sawdust filled containers (see figure VI).

Figure VI. Yucca sp. canes kept in greenhouses in Honduras after harvested in farms and packed for export to the EU

Beucarnea, Dracaena and Scheflera spp. mother plants are grown in open fields. Selected and pruned shoots are air-layered (see figure VII). In some cases sawdust is used for promoting the rooting. When the roots reach appropriate size, the shoots are harvested and usually kept in growing beds for a couple of weeks. Before the packing the plants are dipped in pesticide solution and exported in containers filled with coconut fibre or sawdust.

Figure VII. Air-layered Dracaena sp. mother plants in Costa Rica

Ornamental palms (Caryota, Chamedorea and Chrysalidocarpus spp.) and Cycas revoluta plants are grown from seeds, harvested from the producers' mother plants, while Cycas spp. seeds are imported from Japan. The germination takes place in greenhouses, in pots. The growing medium generally contains coconut fibre, sand and wood shavings. The young plants are then transplanted to an open field for at least one year. Species, including Codiaeum spp., Euphorbia spp., Polisias spp. and Sansevieria spp. are produced from cuttings and spend several years in an open field. During the production scheduled chemical

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treatment is applied. The presence of soil-born HOs (nematodes, bacteria) in the soil is generally not checked and no controls are applied against these.

When export size is reached the plants are uprooted and the majority of the soil is removed, but the roots are not washed. The plants are then potted. The growing medium is a mixture of peat and coconut fibre and may contain sawdust or wood shavings. It is usually treated with pesticides but not heat treated in line with the ISPM requirements. In some cases the soil from the open field composes up to 50% of the growing medium in the pot (see figure VIII).

Figure VIII. A palm potted for export to the EU in a nursery in Honduras with large volume of soil from the field phase

The potted plants are kept in greenhouses or under shading for 4-8 weeks for re-rooting. Only a part of the nurseries ensure that the pots are isolated from the ground soil (i.e. kept on tables, or there the surface is of concrete or covered by plastic sheets) (see figure IX). The vast majority of potted plants are exported to the EU in sea containers.

Figure IX. Good and insufficient isolation of potted plants from ground soil during re-rooting for export in nurseries in Costa Rica

5.1.5Bonsais

China was the only country audited which exports bonsais to the EU. In order to ensure compliance with the specific EU import conditions laid down in point 43 of Annex IV, Part A of Directive 2000/29/EC the plants are grown for two consecutive years before export in officially registered nurseries, in pots, in growing medium either heat treated or treated with pesticides. In general, the plants are kept on shelves at least 50 cm above the ground. However, some nurseries did not ensure the isolation from the ground soil.

The growers apply regular, programmed pesticide treatments to minimise the occurrence of pests and diseases. Before the export, the roots are washed and the growing medium is replaced. The growing medium, in which the bonsais are exported, is a mixture of coconut

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fibre and peat (see figure X). Some companies sterilise it with high pressure steam, while others submerge the potted plants in nematicide solution.

Figure X. Bonsais produced and re-planted for export to the EU in China

5.1.6Aquatic plants

Sri Lanka was the only country audited which exported aquatic plants to the EU. The farm visited by the audit team had a combined open air and insect-proof production facility. The grower kept the host species of Bemisia tabaci in the screen-house and applied regular chemical controls to keep the place of production free from the pest. Before export the crops were submerged in water for two weeks or for 24 hours depending on the species. Before export the plants were submerged in pesticide solution to eliminate snails. Although required by EU legislation the production technology does not ensure that the place of production is free from Bemisia tabaci.

5.1.7Host plants of Anoplophora chinensis

In China, host plants of Anoplophora chinensis are grown in screen-houses in line with the requirements of Article 2 of Decision 2012/138/EU. Insect traps are sited in the places of production and regularly checked for any possible capture. The plants were grown also on elevated shelves in growing medium treated with heat or pesticides (see figure XI). A good level of protection was provided against HO introduction to the crops.

Figure XI.Production of Anoplophora chinensis host plants in a screen-house in China

5.1.8Host and specified plants for Xylella fastidiosa

Before the introduction of EU emergency measures in 2015 (Decision (EU) 2015/789) the Central-American countries, where Xylella fastidiosa is present, exported a range of specified plants to the EU such as Coffea sp., Hedera helix, Pelargonium sp. (see chapter 3.1) The

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plants were generally produced in non-insect proof greenhouses. Costa Rica used to be a large exporter of Phoenix roebelenii, which used to be produced with an open air phase of at least three years. Coffee plants were collected from commercial plantations. For the specified plants no specific measures were applied to control the cicada vectors of Xylella fastidiosa. (See figure XII).

Figure XII. Production of Phoenix roebelenii plants for export to the EU in Costa Rica

5.1.9 Production of seeds for export to the EU

The majority of tomato and pepper seeds imported from the countries audited are produced in high-tech insect-proof greenhouses. The stock seed is often of EU origin. Only China exported seeds of own or free to multiply varieties. The growers apply strict protocols to guarantee that no insects are present in the greenhouse during the vegetation period, as cross-pollination and infection of non-HO viruses is a quality issue. The majority of the production sites are certified according to industrial standards requiring high level of hygiene.

China was the only country audited, which exports tomato and pepper seeds, from open-air production. The crops are cultivated in the North-West part of the country in high altitude (1,000-2,000 m) areas with limited agricultural production, where the climate and the cropping structure ensures the absence or limited prevalence of HOs. The seeds are usually by numerous small farms, supervised by the seed companies which include crop inspections and advice for pest control.

China and the East-African countries produce bean seeds for export to the EU, open-air by farmers, supervised by the seed companies including also crop inspection and advice on pest control.

As part of the extraction procedure tomato seeds are commonly treated with hydrochloric acid in line the EU requirements. Pepper seeds are also often treated. In particular the Chinese producers fumigate bean seeds with phosphine. In some case the seed coat contains pesticides in accordance with the customer's needs.

The risk of HO presence in the screen-houses is limited; however a level of risk exists from open-air production.

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Key issues concerning the impact of production technologies to the plant health risk for the EU

Ensuring that the place of production is free from HOs requires specific efforts Measures applied by numerous growers of plants for planting cannot guarantee full compliance with EU requirements;

A screen-house does not always mean HO free environment; The production technologies do not guarantee that the growing medium is free from

HOs; Specified plants for Xylella fastidiosa, produced in Central America could not meet

the specific EU import requirements; The plant health risk of seeds produced in high-tech isolated screen-houses is

minimal, but it is not the case for the open-air production; Quality controls and treatments during and after harvest reduce the plant health risk

but cannot guarantee HO-free status of the consignments.

5.2 ORGANISATIONAL ASPECTS OF THE PLANT HEALTH CONTROLS

5.2.1 National plant protection organisation

Each country audited is a contracting party of the IPPC and has an NPPO, which is established and operates in accordance with the relevant provisions of the international convention. The plant health activity is regulated by various legal acts and regulations. In each country the national legislation duly authorises the NPPO inspectors to check places of production, goods or consignments to be exported, including sampling for visual inspection and laboratory tests. The plant health related duties of the producers and exporters such as granting access to the places and goods to be inspected or submitting documents are also subject to the national legislation.

5.2.2Resources

In each country audited the plant health inspectors, responsible for the inspection of goods to be exported to the EU are public servants, employed by the NPPO or by its associated organisations. There are minimum educational requirements for the inspectors which is usually third level or technical degree in agronomy or related fields. Most of the NPPOs require plant health field experience, initial training or mentored work before a new inspector is charged with export checks.

In general the NPPOs of the audited countries have appropriate capacity for inspections related to exports to the EU. However, in countries with the highest export volumes or seasonal peaks, the number of inspectors was not sufficient for completing the necessary for those duties (see chapter 5.4).

Some of the audited countries already increased or plan to increase inspection capacities to cope with tasks related to exports to the EU, including substantial investments in IT infrastructure. In general the developing countries had no budgetary resources for completing

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the export inspection tasks, even after participation in programmes assisted by EU and other international aid.

5.2.3Guidelines and training

In each country audited the NPPO developed and applied standard operating procedures (SOPs), guidelines, manuals and work instructions for export controls. The scope of the documents varied significantly. In the majority of the cases the documents provided sufficient guidance on the general procedural aspects of controls, including organisation of the work, maintaining contacts with growers and traders, sampling for visual inspection and for laboratory analysis, reporting and documentation and dealing with non-compliances. In particular, the documents contained detailed rules for inspecting the places of production and the export consignments.

NPPO inspectors had access to a range of material in printed form or on-line for identification of the symptoms of the HOs. These documents were prepared with the assistance of scientific bodies, international plant protection organisations or international aid programmes.

However, in the majority of the audited countries the inspectors did not have comprehensive, detailed and up-dated documentation about the EU import requirements in force. The NPPOs often dealt with outdated versions of the EU legislation, or provided information to the inspectors, which was obtained from the traders or other non-official sources.

Each NPPO had a training regime for the inspectors, which included regular or ad-hoc courses. The national courses usually dealt with general aspects of the inspections and no specific information was provided about the EU requirements. Only a few courses dealt particularly with EU import requirements.

In the countries audited many plant health events were organised with the help of EU aid. In some of the countries phytosanitary experts from MS assisted the NPPO in enhancing the knowledge of the inspectors. Despite this, many inspectors met by the audit teams did not have appropriate knowledge about the EU import requirements.

5.2.4Laboratories and technical support

The NPPO of most countries had a central laboratory and regional laboratories with testing capacities, equipment and trained staff for the identification of HOs with morphological keys or with conventional tests. The use of serological methods, including enzyme-linked immunosorbent assay (ELISA) commercial kits was also a common technique. Only a few NPPO laboratories had facilities and had experience for HO testing with molecular methods, such as polymerase chain reaction (PCR) or loop mediated isothermal amplification (LAMP). The majority of the laboratories were not accredited according to ISO 17025.

Many NPPOs had contracts or agreements with universities or research institutes for testing export samples. Israel also delegated some official tests of seeds to private laboratories subject to regular NPPO audits. Many contracted laboratories had general scope or HO specific ISO accreditation.

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5.2.5 Communication with stakeholders

Many NPPOs publish information on the government websites about the phytosanitary requirements of the main export destination, including the EU. In some cases general policy documents, warnings or actual information about HOs is also distributed. Some of the NPPOs also publish bulletins, leaflets and articles about the situation of the major pests in the country, including some of the HOs.

Each NPPO maintains work relations with grower and trader organisations and other professional groups to exchange information about how to produce goods for export. In some countries specific committees were also established with the participation of each relevant party.

The NPPOs usually distributed to the growers posters, brochures or other forms of printed material which indicated the main HOs, the symptoms, possibilities for identification and control. These materials were prepared with assistance from scientific bodies and international organisations. The growers and packing houses displayed this material at the premises for assisting the staff involved in crop scouting, quality controls during the harvest and preparation of the consignments to be exported to the EU.

The phytosanitary inspectors during their visit to the producers and export sites disseminate information about the import requirements and provide advice to the growers and traders about how to produce and prepare the goods in line with the import requirements.

Key issues of the organisational aspects of the plant health controls

The NPPOs had generally appropriate capacities for inspections related to exports to the EU. However, it was not the case for the countries with the highest export volumes or with seasonal peaks in trade. The developing countries had no budgetary resources for completing the export inspection tasks;

In the majority of the countries audited NPPO inspectors did not have adequate knowledge about EU requirements and particular, were not aware of rules related to plant species, type of products or HOs;

In the countries audited the laboratories were capable to identify HOs. The only exception was testing for Xylella fastidiosa, where the EU legislation requires molecular tests;

The NPPOs maintain good relations with producers, traders and professional organisation.

5.3 PHYTOSANITARY STATUS OF HARMFUL ORGANISMS IN THE COUNTRIES AUDITED

Annex IV, Part A, Section I of Directive 2000/29/EC contains options for countries with different status of HOs relevant for their export of plants for planting and seeds. For numerous plant species, product type and HO combinations the legislation requests a declaration from the NPPO that the plants originate either from a country, an area, or a place

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of production which is free from the given HO. References to the points of that Annex, most relevant for the audited countries are listed in Annex VII of this report.

The countries audited were requested to provide information about the pest status of the HOs relevant for their export of plants for planting and seeds to the EU, according to the categories defined by ISPM No.82. The audit reports (see Annex II for web-links) contain detailed information about the pest status of HOs relevant for the EU.

The audit teams checked whether the country was free from the relevant HOs, whether any area and/or place of production was established by the NPPOs in line with provisions of the relevant international standards3 .

The NPPOs confirmed that many HOs, in particular Bemisia tabaci, a range of viruses transmitted by that whitefly, soil nematodes and leaf-miner species were wide-spread in the tropical and sub-tropical production areas of their countries. For these HOs the only the relevant option was to certify that the goods originate from a Pest-Free place of production established for the HO in question. (Only for certain products and HOs does the legislation provide a treatment option).

NPPOs declared that the entire territory or some areas of the country were free from a range of HOs. These declarations were generally based on information from scientific publications and databases (e.g. IPPC, regional plant health organisations, scientific bodies such as the Centre for Agriculture and Bioscience International - CABI). For pests, officially listed as quarantine organisms for the country, it was generally considered that the lack of interceptions means no presence in the country.

Some NPPOs stated that in the country or in certain areas of it surveys had been carried out in the main agricultural crops for detecting the presence of any HO. If a particular HO is not detected during those surveys, it is considered that the pest is absent. These surveys generally targeted the pests and crops with particular economic impact for the country. Therefore production areas and HOs relevant for the export of plants for planting and seeds to the EU were not or not representatively covered.

Some of the audited countries operated eradication or containment programmes for some pests, but not for HOs, relevant to their current export of plants for planting and seeds to the EU.

One of the possible reasons is that for a range of products and HOs the NPPOs did not use correctly the options provided by the EU legislation (i.e. did not declare the status of the country, area or place of production in relation of the given HO properly) was the lacking or improper information about the HO (see chapter 5.5.2).

2 Absent, no reports; absent, confirmed by surveys; absent, occasional occurrences, eradicated; present, widespread; present, widespread, under official control; present, limited distribution; present, limited distribution, under official control; present, few reports; present, few reports, under official control; Present, no distribution details3 ISPM No. 8 – Determination of the pest status in an area; ISPM No. 4 – Establishment of pest free areas) and ISPM No. 10 – establishment of pest free places of production and pest free production sites

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None of the countries audited established pest free areas for HOs relevant to their export to the EU in line with provisions of ISPM No. 4. The NPPOs generally considered that screen-houses meet the requirements of pest free place of production or pest free production site, laid down in ISPM No. 10 in relation to the HOs, relevant for their export to the EU. However, many screen-houses visited by the audit teams did not fulfil these requirements.

Key issues of the phytosanitary status of HOs in the countries audited

Many relevant HOs are widespread in the countries audited; The available information was not always sufficient for the determination the status of

the country or of an area in relation to a HO; The NPPOs in the countries audited did not establish pest free areas for the HOs

relevant to their export; The NPPOs declared that a range of places of production were free from a particular

HO, however in many cases the provisions of ISPM No 4 were not complied with.

5.4 PROCEDURES FOR INSPECTIONS FOR EXPORT TO THE EU

Annexes I and Annex II Part A to Directive 2000/29/EC list the HOs whose introduction and movement within the EU is banned. Annex V, Part B lists the plants, plant products and other objects that must be subject to a plant health inspection and must be accompanied by a PC (see Annex II and Annex VIII of this document).

Annex IV, Part A, Section I of the same Directive establishes a range of specific requirements for plants for planting and seeds, depending on the geographical location of the place of production, the plant species and the type of product to be exported. In the majority of the cases the EU legislation requires certification that the area or place of production is free from certain HOs and/or during the production of the plants for planting and seeds specific phytosanitary conditions were applied.

ISPM No. 7 (Phytosanitary certification), ISPM No. 23 (requirements for inspections) and ISPM No. 31 (sampling of consignments) contain provisions for inspections of plants for planting and seeds.

5.4.1 Registration of nurseries, seed companies and packing houses

In each audited country the NPPO kept registers of nurseries and seed companies with production for export to the EU. The registers contained information with various levels of details about growers and places of production. In some countries, the data scope was too general (e.g. only address of the headquarters) and was not sufficient for the preparation of the inspections at the production sites. Many registers contained information about the location and size of the places of production, about the range of products intended to export to the EU. However, some of the registers were not regularly updated.

The growers apply different systems for recording the production and labelling the products. Each system provided sufficient traceability to the crop, and up to the nuclear stock. NPPO

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inspectors had access of the growers' documentation about the place of production, the conditions and pest control applied during the production.

In each of the countries audited it is a legal obligation to keep records of the chemical treatments applied to the crops and to the goods prepared for export. In addition the records of pest scouting, carried out by the companies in the crops were also available for the NPPO inspectors.

5.4.2 Inspections of the export production sites

Conformity with the vast majority of EU requirements for plants for planting and seeds can only be certified if the sites of production are officially inspected during production. The NPPOs of the audited countries applied various schemes and practices for checking the sites of production.

In general an inspector or inspectors were assigned to a grower, and visited the premises several times a year.

The inspectors maintained good relations with the growers and were familiar with the growing technologies and the HOs of concern during the production. During the visits the place of production, including its close vicinity was visually inspected. Catches in the sticky traps, scouting and pest control records of the growers were checked.

The inspectors looked for the presence of any insects, including the juvenile forms and any other symptoms of damages, possibly caused by HOs. Laboratory samples were taken if the identification of the pest was not possible at the place of production. Usually no samples were taken from the growing medium to check the presence of harmful nematodes.

For the screen-houses the inspectors usually did not check the proper level of isolation or the implementation of the existing hygiene protocols or whether there were growers' records on physical damage and the time needed for the repair.

In the majority of cases the NPPO documents did not provide guidance about the details of the inspection including the number of plants to be checked per crop. Some of the inspections observed by the audit teams were not meticulous enough for detecting a low level of infection/infestation in the crop. Therefore it was not always guaranteed that the inspection could properly assess the pest status at the place of production. In addition it was not guaranteed either that each crop of each plant species for intended to export to the EU was physically checked at least once during its lifetime, although this is required for the majority of the plants for planting by the EU legislation.

In each country a written report was prepared; the grower received a copy of it which was presented during the consignment inspections and PC issuance. (See chapters 5.4.3 and 5.5.1).

The audit team observed a good practice in Costa Rica, where the NPPO supplied a book to each grower. The inspectors indicated the findings, conclusions and recommendations after each visit into the book in the form of an official report. The method ensured that during each inspection the plant health history of the company could be checked. Some countries

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uploaded inspection reports a central database which could be checked during the consignment inspections or before the issuance of the PC. In other cases, the consignment inspection and PC issuance relied on the hard copy of the reports presented by the grower. The reports did not always contain a full list of the inspected plants, therefore the traceability was not always ensured.

The EU legislation contains specific requirements concerning the frequency of official inspections for the majority of the plants for planting. To ensure that the place of production was free from Bemisia tabaci, inspections are required at least once each three weeks during the nine weeks prior to export and for Amauromyza maculosa and Liriomyza spp. at least monthly during three months before the shipment takes place. In addition, in the case of findings of Bemisia tabaci at the places of production for the re-establishment of the HO free status at least weekly official inspections are required during the nine weeks prior to export. These requirements were not observed in many of the countries audited.

The EU legislation requires that at the time of planting the growing medium in which the plants are exported be free from soil and organic matter or found free from HOs by official inspections. Alternatively it was subject to appropriate heat treatment or fumigation and since planting appropriate measures have been taken to ensure that the growing medium has been maintained free from HOs or the growing medium was removed before export.

As described in chapters 5.1.3 and 5.1.4 the production technology does not ensure full conformity with EU requirements. In particular, for the plants with a field growing phase the ground soil, which was not subject to official inspections or specific treatment, is not completely removed and in many cases there is a possibility that HOs migrate into the export pots from the ground soil or with irrigation water. In some countries the official inspections did not verify the conformity with EU requirements as: It was not checked whether the soil was completely removed after the field growing

phase; The mixture of coconut fibre and peat was generally considered as a substance free of

HOs without any sampling and laboratory test; It was not checked whether the plants were kept separated from the ground after the field

phase or whether the irrigation water contained any HO.

Therefore plants exported in growing medium and in particular those with a field growing phase pose a potential plant health risk for the EU, in particular related to soil nematodes.

For bonsais the EU legislation requires inspections at the place of production at least six times per year and specific requirements such as keeping the plants on elevated shelves and completely changing the growing medium before the export. In China the frequency of the official inspections was in line with EU requirements, however the audit team identified non-compliances in relation the use of sufficiently treated growing medium.

The NPPO inspectors usually visited the sites, where tomato seeds were produced in screen-houses at least once a year. Open-air production sites of tomato seeds or bean seeds were usually not inspected during the vegetation period. Despite this the NPPOs sometimes

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selected the option for certifying the conformity with EU import rules, that the place of production was free from the HOs in question.

5.4.3 Inspections of consignments prepared for export

The countries audited used different systems for inspecting consignments intended to export to the EU. Plants in growing medium exported in sea containers were checked at the place of production before or during loading. Cuttings, transported by air were either checked at the place of production during packaging or at phytosanitary inspection posts of the international airports. Seeds, which were mainly transported by parcel companies, were generally checked at the seed companies.

In the countries audited SOPs and other guidance documents generally provided appropriate guidance for the inspectors, in relation to sampling practice and rates and the identification of the main HOs by visual means. However, in many cases the officially prescribed sampling rates were lower than those referred to by the hypergeometric tables of ISPM No. 31 and did not provide a good level of confidence to detect low levels of HO presence in the consignments. The national documents did not always specify the meanings of the terms consignment, lot and unit, in line with requirements of ISPM No. 31. Only few companies applied the risk based options for sampling provided for by the international standard, however, the criteria which were taken into consideration were not fully appropriate for the determination of the existing plant health risk.

During the demonstrations for the audit teams the NPPO inspectors randomly selected units of plants for inspection, according to the national guidance documents. The individual plants were checked meticulously with the help of magnifying glasses for the presence of any insects and symptoms of any possible infection/infestation. However, the growing medium was not always checked. Laboratory samples were taken in the case of suspicion or if the inspector was not able to identify the insect species which was found.

For consignments, where the PC was not issued at the place of production or packing, an inspection report was prepared. The exporter had to present this document for the PC issuance. In some countries the inspection reports were uploaded to a central database.

In the case of inspections at the place of production/packaging it was not always ensured that the entire consignment, prepared for export to the EU, was checked. Inspectors were not present during the entire loading period of the container or during the practically continuous preparation of consignments of cuttings. Therefore inspection results of the goods present at the premises at the time of inspection were extrapolated to the entire consignment or to goods exported in the period between the official visits.

In the case of consignments checked at the international airports the audit teams noted that the technical time provided by the forwarders between the arrival of the goods and loading of the air cargo was not always sufficient for the visual inspections according to the national SOPs.

Due to the issues described above there is a risk that HOs remain undetected in consignments exported to the EU. The plant health risk is mitigated by the quality controls applied by the

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growers (see chapter 5.1) and by the official inspections carried out at the places of production.

5.4.4 Facilities for performing inspections

The inspectors possessed the basic tools necessary for the visual inspections and sampling (e.g. magnifying glasses, knives, disinfectants, sampling bags). In some cases the inspectors possessed advanced IT tools for recording the results.

The conditions provided by the growers at the places of production and packing were sufficient for the inspections (light, inspection tables, assistance for the random selection of samples. However, at the inspection points operated in at the international airports, usually in warehouses, the conditions were not fully sufficient for the inspections.

Key issues of the official inspections related to exports to the EU

Due to the frequency of the visits and the applied methodology the inspections do not always assess properly the HO status of the place of production. It is not guaranteed either that each crop, for which the EU requires a statement about the HO status, is inspected at least once during the production cycle;

Specific requirements related to the frequency of inspections at the places of production for Bemisia tabaci were not observed in many countries audited, leading to interceptions with the pest;

Specific requirements related to the growing medium were not observed in many countries audited and therefore there is a potential risk of introduction of soil-born HOs, in particular by importing plants with a field growing phase;

The consignment is not always subject to official inspection before exported to the EU;

The inspection and sampling method is not always appropriate to ensure that the consignment meets EU import requirements, in particular concerning the detection of the low level presence of HOs.

5.5 PHYTOSANITARY CERTIFICATES

Article 2(1)(i) of Directive 2000/29/EC establishes the requirements for a measure or statement, to be considered as 'official'. Paragraph 3 of Article 13a of the same Directive establishes requirements for the phytosanitary certificate. These requirements are in line with provisions of ISPM No. 7 (phytosanitary certification process), ISPM No. 12 (guidelines for PCs). Paragraph (4) of Article 13a contains requirements relating to the use of additional declaration on phytosanitary certificates. Annex IV, Part A Section I establishes specific requirements which must be met in order to export plant and certain plant products to the EU.

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5.5.1 Issuance of the phytosanitary certificate

The NPPOs use various procedures for the PC issuance. In general the format and information content of the document was in line with the requirements of ISPM No. 12. In the majority of the countries audited, PCs are issued by a computerised system. In some cases the exporters enter consignments data on-line to the system, which is verified by the plant health inspector. Some countries are already capable of issuing electronic PCs, in line with the new IPPC requirements. Some African countries still use typewriters for the PC issuance.

The general practice was that the PCs were issued at the points of exit before the export Customs clearance. The forwarders had to apply at the border offices of the NPPO for export consignment inspections or when it was already completed during packing for the issuance of the PC only. Paper copies of NPPO inspections related to the goods were always requested.

The NPPOs which use electronic systems could provide a higher level of assurance that the PCs entirely reflect the inspections at the place of production and/or on the export consignments and could better prevent any possible fraudulent case.

5.5.2 Additional declarations

The audit teams checked examples of PCs issued for the major types of plants for planting and seeds for the correctness of the ADs. Only Israel issued in each case declarations which dealt correctly with all points of Annex IV, Part A, Section I of Directive 2000/29/EC, relevant to the exported plant species, type of product and country/area/place of production. The vast majority of the statements by the NPPO of Kenya were also appropriate.

There were relatively few cases where the required statement was missing, however many ADs did not reflect correctly the plant health status of the place of production and/or of the consignment in relation to the plant species, type of product and the relevant HO.

The ADs often referred to one of the options provided for by Annex IV, Part A, Section I of Directive 2000/29/EC, which did not reflect correctly the phytosanitary status of the plant, its production site and the applied treatments and official inspections. In particular it was stated that: The country was free from the relevant HO(s), while there was evidence that the pest in

question was present in the country (as shown scientific report, EU interceptions); The plants originated from an area free from the relevant HO(s), while the NPPO had not

established such areas according to the provisions of ISPM No. 8 (e.g. for Thrips palmi). If this option is chosen the EU legislation requires the indication of the name of the area on the PC, which was usually missing.

The place of production was free from the relevant HO(s), while the NPPO had not established any places of production free from the HO (e.g. for Liriomyza sp. or Bemisia abaci), in accordance with provisions of ISPM No. 10. If this option is chosen the EU legislation requires the indication of the name of the place of production on the PC, which was usually missing.

In these cases the chosen option did not reflect the real situation, while another option could have.

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While some of the required ADs were missing, declarations were often added which were irrelevant to the plant species or product. In some cases no options were indicated or multiple options were cited with regard to a single requirement when only one should be indicated. Some ADs did not reflect correctly the phytosanitary conditions during the production phase (e.g. that the growing medium was kept free from HOs) or the applied phytosanitary treatment was not indicated, or chemical treatment was indicated as heat treatment.

For Bemisia tabaci and Liriomyza sp the AD declared that the frequency of official inspections at the place of production, required by the EU legislation, was met, while the audit teams found evidence that this was not the case.

Only some of the NPPOs established a central database for the ADs, which indicate the text relevant to the exported plant species and type of the product. In those countries at the issuance of the PCs the appropriate text can be selected and added to the document.

In many countries the NPPO indicated a text as AD on the PC, which was provided the exporters and obtained from the NPPO of the importing EU Member State via their trade partners. However, the correctness of the text was not cross-checked with the relevant provisions of Directive 2000/29/EC.

The NPPOs in Central-America prepared and issued the ADs based on a document obtained from the authorities from a MS. The document was generally of a good quality and grouped the requirements according the major products imported by the EU. However, the document was not based on the latest amended version of Directive 2000/29/EC; therefore some of the related statements were incorrect. In one of the audited countries the AD was prepared by the exporter in a separate sheet, which sometimes contained the header of the company. The inspector stamped and signed this document and indicated the PC number.

As required by the importing MS the ADs do not quote the entire text of the EU requirement or the chosen option but refer to the relevant points, paragraphs or even indents Annex IV, Part A, Section I of Directive 2000/29/EC. This practice contributes to the persons who issue the PC having no or very limited knowledge about the actual meaning of the AD. This is one of the reasons for the improper declarations.

Although the EU informs the authorities of the exporting countries about the changes in the import requirements via the relevant channels, the NPPOs in many of the visited countries had no updated information about the import rules in force. Some NPPOs were not aware of the existence and availability via internet of the consolidated version of Directive 2000/29/EC and therefore did not add the correct ADs.

In many cases the consignment, which is exported with a single PC contains a range of plant species and sometimes different types of products. As a pragmatic solution some NPPOs prepared few 'standard sets' of ADs, to be used for a range of plants and type of products, containing references to many points or options of the EU legislation. As many options are only valid for a certain range of plant species and type of products, adding a 'standard' AD to some products means irrelevant statements.

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Key issues for the phytosanitary certificates

The issuance of the PCs is in line with EU requirements and international standards. Many of the ADs do not reflect correctly the plant health status of the place of

production and/or the consignment in relation to the HOs relevant to the given product. The main reason for this is the inadequate knowledge of the NPPO and the plant health inspectors about the EU import requirements in force.

5.6 ACTION TAKEN IN RESPONSE TO INTERNAL FINDINGS AND EU NOTIFICATIONS

ISPM No. 7 describes the basic elements of the phytosanitary certification process and the requirements for a certification system to fulfil these functions. Section 6 (System review) requires that the NPPO should periodically review the effectiveness of all aspects of its export certification system and implement changes to the system if required.

ISPM No. 23, Section 2.6 (Review of inspection systems) establishes that NPPOs should conduct periodic reviews of import and export inspection systems to validate the appropriateness of their design.

5.6.1 Internal interceptions

The NPPOs generally stated that for plants for planting and seeds they rarely find HOs during the inspections at the place of production or in the consignments prepared for export. If a HO is found during the field visits the export is suspended and chemical treatment is requested. A follow-up inspection is carried out usually after the grower reports that the treatment was completed and no HO is present. In general the follow-up check is carried out with the same methodology applied for a normal inspection, but concentrates on the units of the place of production where the HO was found. When the absence of the HO was officially confirmed the export ban is lifted.

The NPPOs reported that there were rare cases when a HO was found in export consignments. The general practice is that the consignment is refused. It can be presented for export inspection after chemical treatment or re-sorting.

However, the audit teams noted that in many countries after finding Bemisia tabaci infestation at the place of production, the length of the suspension of the export to the EU was significantly shorter than what is required by the EU legislation (see chapter 5.4.2).

5.6.2 EU notification of interceptions

The EUROPHYT-Interceptions system sends e-mail notifications to the addresses provided by the NPPOs immediately after the intercepting MS enters the relevant information to the database. The e-mails are usually received by the headquarters of the NPPO, who notify the relevant regional unit or inspector about the case.

For interceptions with HO the common practice is that a responsible inspector visits the place of production and the place of preparation of the consignment and tries to identify the reasons

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and any background. If the EU requires that the place of production is free from the pest the future exports are suspended until the issue is rectified. Otherwise recommendations are made for the grower concerning the changes in pest management or for the introduction of stricter own quality controls.

When the interception is due to missing or inappropriate ADs the NPPOs usually issue a new PC with the appropriate text. However, for this it is not always checked whether the required conditions at the place of production were verified by official inspections (see chapter 5.4.2)

The measures implemented by the NPPOs as follow-up to EU interceptions do not always achieve the desired impact and result in significant reduction of the EU interceptions. For those countries the audit reports requested the review of the inspection system.

Key issues related to the response of internal findings and EU notifications

Measures implemented by the NPPOs are generally in line with the requirements of the international standards;

The measures implemented after the EU interceptions do not always prevent the recurrence of the cases.

6 MATTERS FOR CONSIDERATION

Numerous HOs are widespread in the audited countries with various level of prevalence. The production technology can reduce the plant health risk but does not ensure that the place of production or the consignment is free from HOs. The plant health risk varies by country, type of products and grower.

The official inspections aim at detecting the presence of any HO or symptoms caused by those. Therefore the number of EU interceptions of plants for planting and seeds with HO is relatively low. However, in some cases the inspections do not cover the entire production area or all the consignments. In addition, in many cases the frequency and meticulousness of the inspections are inappropriate and there is a risk that HOs remain undetected.

The audits identified the following main issues, related to the imports of plants for planting and seeds, which mean a phytosanitary risk for the EU:

Bemisia tabaci is widespread in each country audited. The EU requires that the place of production is free from the pest. It is not observed in many cases and therefore it is not guaranteed that the imported goods are free from this whitefly and the viruses transmitted by this insect;

The majority of the countries audited do not fully observe the EU requirements on the growing medium, in particular for plants with open field growing phase. There is a plant health risk that soil-born HOs, in particular nematodes are present in the growing medium of the imported plants. It is advisable for the MS to sample and test in laboratory the growing medium attached to the plants for planting.

The majority of the NPPOs in the countries audited struggled with understanding and interpreting the complex EU import rules. As a consequence there are numerous

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interceptions of plants for planting and seeds due to reasons other than HO presence in particular concerning of ADs on the PCs.

Additional efforts are needed to inform the exporting countries about the EU rules in an understandable form and about the pragmatic aspects of achieving conformity with them. Assistance could be provided by the EU or bilaterally by the main importing EU Member States.

Regulation (EU) 2016/2031 on protective measures against pests of plants enters into application on 14 December 2019. This Regulation replaces Directive 2000/29/EC and together with its implementing legislation introduces a new legal basis for the imports for plants for planting and seeds. The new legislation is aimed to provide enhanced protection against the introduction and spread of HOs into and within the territory of the EU, taking into consideration the existing plant health risk. It will introduce significant changes in the import requirements for a range of products, including plants for planting and seeds.

7 ACTIONS TAKEN OR PLANNED BY COMMISSION SERVICES

After each audit a report was prepared which included recommendations to deal with the identified non-compliances. The draft report was sent for comments to the NPPO and an action plan was requested to address the recommendations. The NPPOs of the audited countries sent comments to the draft report and provided action plans for addressing the recommendations.

In the final audit reports the NPPO comments were taken into consideration, and then the reports were published on the website of DG Health and Food Safety together with the NPPO comments on the draft reports and the response to the recommendations (see web-link to the reports in Annex I).

For many countries and many recommendations the Commission services concluded that the actions proposed by the NPPOs were unsatisfactory and updates or clarifications were needed. In the majority of cases asking for an update was necessary as no detailed information was communicated about the measures or the schedule with clear deadlines was not indicated. In the majority of cases the NPPOs updated the action plans with the requested information.

Concerning the implementation of the proposed actions DG Health and Food Safety carried out administrative follow-up. The NPPO was requested to provide written information about the state of play of implementation of the proposed measures.

The EU continuously updates the legislation related to the import rules of plants for planting and seeds, based on the changes in risk patterns and the assessment of the risk related to existing, newly identified harmful organisms and new trades. The risk assessment is carried out by the European Food Safety Authority and by the relevant organisations of the MS. The specific legislative proposals take into consideration findings and conclusions of the audits. One of the changes relevant for plants for planting entered into force on 1 September 2019,

27

which considers that peat and coconut fibre used in the growing medium for plants for planting is free from HOs. Consequently, if the growing medium is composed only from these substances, there is no specific requirement for fumigation or other treatment. It needs to be ensured, however, that during the growing period measures are applied to prevent the introduction of HOs.

Several elements of the new plant health legislation, which enters into application on 14 December 2019 deal with the issues dealt with by this overview report and intend to contribute to the improvement of the situation, reflected by the findings. For example, it will become mandatory to quote in the AD the specific option under which the non-EU country exports the product in question. It will help the inspectors who issue the export PC to verify the relevance of the option with the pest status of the country, area, place of production or the consignment as appropriate.

The EU's new electronic Integrated Management System for Official Controls, into which all functions of the current EUROPHYT-Interceptions system will be integrated, will signal in real time all the non-compliance of the imported consignments with EU legislation and will enable a quick and focused communication with the NPPOs of the exporting countries.

The European Commission is planning to develop a publicly available database which indicates the import phytosanitary requirements for commodities in relation to the origin of those (e.g. prohibition, specific import requirements – options related to the phytosanitary status of the origin of the goods, emergency measures etc.). This database will assist the NPPOs of the exporting countries in interpreting the import rules and organising the phytosanitary controls and the issuance of the PC accordingly. It will also provide guidance for the growers and traders of the commodities concerned.

In the framework of the Better Training for Safer Food initiative of the DG Health and Food Safety (http://ec.europa.eu/chafea/food/index_en.htm) regional training events were organised about the sanitary and phytosanitary import requirements of the EU for the competent authorities of the main exporting countries. Representatives of the NPPOs of the audited countries attended some of these courses. The aim of these workshops was to provide detailed information about

The phytosanitary requirements for importing plants and plant products to the EU including the new rules of the plant health law and

Inspection methods to ensure that the goods are produced and exported fully in compliance with EU rules

However, due to the complexity of the EU legislation these workshops could not deal with the entire scope of the import rules and inspection methods on plants for planting and seeds. Therefore the information which was cascaded to the phytosanitary inspectors in the exporting countries was not sufficient for organising appropriate inspections and issuing proper PCs. Specific training courses concentrating on plants for planting and seeds could better enhance the level of knowledge about EU requirements in the exporting countries.

In the African countries, besides the Better Training for Safer Food Initiative, other international aid programmes could also assist in enhancing knowledge about the EU import rules and developing the production and of official plant health control systems.

ANNEX 1 – LEGAL REFERENCES

Legal Reference Official Journal TitleDir. 2000/29/EC OJ L 169, 10.7.2000,

p. 1-112 Council Directive 2000/29/EC of 8 May 2000 on protective measures against the introduction into the Community of organisms harmful to plants or plant products and against their spread within the Community

Dec. 2012/138/EU OJ L 64, 3.3.2012, p. 38-47

2012/138/EU: Commission Implementing Decision of 1 March 2012 as regards emergency measures to prevent the introduction into and the spread within the Union of Anoplophora chinensis (Forster)

Dec. 2015/789/EU OJ L 125, 21.5.2015, p. 36–53

Commission Implementing Decision (EU) 2015/789 of 18 May 2015 as regards measures to prevent the introduction into and the spread within the Union of Xylella fastidiosa (Wells et al.)

Reg. 2016/2031 OJ L 317, 23.11.2016, p. 4–104

Regulation (EU) 2016/2031 of the European Parliament of the Council of 26 October 2016 on protective measures against pests of plants, amending Regulations (EU) No 228/2013, (EU) No 652/2014 and (EU) No 1143/2014 of the European Parliament and of the Council and repealing Council Directives 69/464/EEC, 74/647/EEC, 93/85/EEC, 98/57/EC, 2000/29/EC, 2006/91/EC and 2007/33/EC

ANNEX II. DETAILS OF THE INDIVIDUAL AUDITS

Country Dates of audit DG SANTE reference number Web-link

SRI LANKA* 3 – 13 February 2015

2015-7643 http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3460

HONDURAS 12 – 20 May 2015 2015-7935http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3503

COSTA RICA21 September – 1

October 20152015-7644 http://ec.europa.eu/food/audits-

analysis/audit_reports/details.cfm?rep_id=3610

CHINA1 – 11 December

20152015-7645 http://ec.europa.eu/food/audits-

analysis/audit_reports/details.cfm?rep_id=3639

GUATEMALA 12 – 21 April 2016 2016-8808http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3668

GHANA*

6 – 15 September 2016

12 – September 2017

2016-8983

2017-6262

http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3706

http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3900

UGANDA* 6 – 15 September 2016

2016-8806 http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3748

THAILAND* 21 February – 03 March 2017

2017-6172 http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3834

TANZANIA11 – 22 September

20172017-6175 http://ec.europa.eu/food/audits-

analysis/audit_reports/details.cfm?rep_id=3917

KENYA* 21 November – 1 December 2017

2017-6174 http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3959

ISRAEL* 6 – 15 March 2018 2018-6493http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=4008

* The system of official controls of plants for planting and seeds to be exported to the EU was audited as part of a broader scope plant health audit

ANNEX III. INTERNATIONAL STANDARDS QUOTED IN THE OVERVIEW REPORT

International Standard Title

ISPM No. 4 International Standard on Phytosanitary Measures Publication No 4, Requirements for the establishment of pest free areas, Food and Agriculture Organisation, Rome, Adopted 1995; published 2017, https://www.ippc.int/en/publications/614/

ISPM No. 5 International Standard on Phytosanitary Measures Publication No 5, Glossary of phytosanitary terms, Food and Agriculture Organisation, Rome, Adopted 2018; published 2018; https://www.ippc.int/en/publications/622/

ISPM No. 6 International Standard on Phytosanitary Measures Publication No 6, Surveillance, Food and Agriculture Organisation, Rome, Adopted 1997; published 2019, https://www.ippc.int/en/publications/615/

ISPM No. 7 International Standard on Phytosanitary Measures Publication No 7, Phytosanitary certification system, Food and Agriculture Organisation, Rome; Adopted 2011; published 2016; https://www.ippc.int/en/publications/613/

ISPM No. 8 International Standard on Phytosanitary Measures Publication No 8, Determination of pest status in an area, Food and Agriculture Organisation, Rome; Adopted 1998; published 2017, https://www.ippc.int/en/publications/612/

ISPM No 10. International Standard on Phytosanitary Measures Publication No 10, Requirements for the establishment of pest free places of production and pest free production sites, Food and Agriculture Organisation, Rome; Adopted 1999; published 2016; https://www.ippc.int/en/publications/610/

ISPM No. 12 International Standard on Phytosanitary Measures Publication No 12, Phytosanitary certificates, Food and Agriculture Organisation, Rome; Adopted 2014; published 2017, https://www.ippc.int/en/publications/609/

ISPM No. 13 International Standard on Phytosanitary Measures Publication No 13, Guidelines for the notification of non-compliance and emergency action, Food and Agriculture Organisation, Rome; Adopted 2001; published 2016 https://www.ippc.int/en/publications/608/

ISPM No. 17 International Standard on Phytosanitary Measures Publication No 17, Pest reporting, Food and Agriculture Organisation, Rome, Adopted 2002; published 2017, https://www.ippc.int/en/publications/606/

ISPM No. 23 International Standard on Phytosanitary Measures Publication No 23, Guidelines for Inspection, Food and Agriculture Organisation, Rome, Adopted 2005; published 2016 https://www.ippc.int/en/publications/598/

ISPM No. 27 International Standard on Phytosanitary Measures Publication No 27, Diagnostic protocols for regulated pests, Food and Agriculture Organisation, Rome, Rome, Adopted 2006; published 2016, https://www.ippc.int/en/publications/593/

ISPM No. 31 International Standard on Phytosanitary Measures Publication No 31, Methodologies for sampling of consignments, Food and Agriculture Organisation, Rome, Adopted 2008; published 2016 https://www.ippc.int/en/publications/588/

ISPM No. 36 International Standard on Phytosanitary Measures Publication No 36, Integrated measures for plants for planting, Food and Agriculture Organisation, Rome, Adopted 2012; published 2016 https://www.ippc.int/en/publications/636/

ANNEX IV. EU IMPORT OF PLANTS FOR PLANTING AND SEEDS

Table I. EU imports of plants for planting(1) (2013-2017, tonnes)

Import volume (tonnes)Exporting country

2013 2014 2015 2016 2017 Share(3) Costa Rica 24,749 22,784 21,451 16,239 19,914 4.4%

China 11,810 11,560 9,798 14,239 24,793 5.4%Former Yugoslavian Republic of Macedonia 3,685 3,457 4,904 6,629 6,207 1.4%

Guatemala 5,162 5,728 5,992 4,221 3,697 0.8%

Serbia 6,683 4,261 2,150 4,637 4,178 0.9%

United States of America 2,982 3,106 3,416 5,187 4,614 1.0%

Honduras 4,486 4,074 3,432 1,947 2,666 0.6%

Thailand 1,829 1,868 2,127 3,112 4,487 1.0%

Kenya 2,203 2,838 2,082 1,804 2,536 0.6%

Ukraine 82 952 4,249 3,061 1,397 0.3%

Tanzania 1,343 1,279 1,126 1,727 4,173 0.9%

Uganda 1,536 1,543 1,613 1,668 1,744 0.4%

Sri Lanka 1,898 1,795 1,512 1,320 1,284 0.3%

Turkey 1,498 1,331 1,506 1,452 1,677 0.4%

Israel 1,534 1,487 1,091 1,632 1,512 0.3%

EU import TOTAL 87,903 84,054 82,011 89,069 114,156

Table II.EU imports of plants for planting(1) (2013-2017, thousand euros)

Value of import (thousand euros)Exporting country

2013 2014 2015 2016 2017 Share(3)

Kenya 46,162 42,079 48,994 41,509 42,997 14.8%

Costa Rica 27,521 25,657 28,983 24,277 24,018 8.7%

Israel 30,162 26,816 24,404 23,388 25,560 8.7%

China 22,320 25,544 27,666 24,614 27,589 8.6%

Uganda 18,590 18,942 21,722 21,083 23,760 7.0%

Ethiopia 15,830 16,559 16,956 18,272 19,401 5.8%

Tanzania 13,161 13,686 10,743 12,951 14,161 4.3%

United States of America 10,880 10,702 11,261 15,869 11,116 4.0%

Turkey 8,866 8,717 11,675 11,783 12,628 3.6%

Guatemala 9,045 8,613 9,965 11,024 13,129 3.5%

Honduras 6,524 6,443 7,045 7,425 8,221 2.4%

Taiwan 8,126 8,117 5,941 6,572 6,581 2.4%

Morocco 3,762 4,978 4,908 7,211 9,432 2.0%Former Yugoslavian Republic of Macedonia 3,826 3,871 4,833 6,172 7,807 1.8%

Thailand 3,726 3,777 5,370 7,639 5,052 1.7%

Switzerland 3,504 3,833 3,901 4,590 5,115 1.4%

Sri Lanka 3,235 3,000 3,123 3,468 3,828 1.1%

EU import total 285,888 280,468 301,257 303,910 322,097

Table III. EU imports of vegetable seeds(2) (2013-2017,tonnes)

Import volume (tonnes)Exporting country

2013 2014 2015 2016 2017 Share(3)

China 3,735 2,540 1,710 1,534 1,025 21.0%

New Zealand 1,795 1,885 2,312 1,991 2,215 20.3%

Ukraine 1,078 1,773 2,492 1,810 2,731 19.7%

United States of America 1,463 1,560 1,876 1,894 1,938 17.4%

India 331 469 260 431 455 3.9%

Australia 220 271 265 314 213 2.6%

Chile 276 204 215 241 231 2.3%

South Africa 215 222 220 198 255 2.2%

Turkey 202 137 166 78 115 1.4%

Serbia 76 80 95 155 184 1.2%

Japan 89 69 81 137 76 0.9%

Argentina 68 73 100 77 116 0.9%

Thailand 36 40 39 55 46 0.4%

Israel 14 16 37 34 35 0.3%

Tanzania 10 12 16 14 15 0.1%

EU import total 9,953 9,719 10,367 9,770 10,481

Table IV. EU imports of vegetable seeds(2) (2013-2017, thousand euros)

Value of import (thousand euros)Exporting country

2013 2014 2015 2016 2017 Share(3)

United States of America 45,267 52,778 74,055 86,933 86,811 20.1%

China 57,399 47,939 47,601 53,640 54,459 15.1%

Chile 35,554 28,513 32,196 40,741 42,560 10.4%

Israel 19,763 26,358 31,611 32,962 31,530 8.3%

New Zealand 27,043 18,648 24,483 21,072 34,143 7.3%

Peru 21,136 20,333 27,966 26,367 28,246 7.2%

Thailand 11,644 10,589 12,733 14,653 20,118 4.0%

Australia 11,836 14,323 14,446 14,241 12,811 3.9%

India 7,812 7,634 9,250 11,359 14,171 2.9%

Japan 8,142 7,830 8,251 11,408 9,816 2.6%

South Africa 6,677 6,017 7,317 7,620 10,965 2.2%

Guatemala 9,186 4,403 8,042 9,650 4,524 2.1%

Mexico 4,769 4,818 8,504 6,159 6,052 1.8%

Tanzania 3,977 4,537 6,293 5,568 5,482 1.5%

EU import total 297,162 283,010 352,441 385,352 405,864

Data source: EUROSTAT

Explanatory notes for (1) CN code 0602;(2) CN code 120991(3) Share in EU imports (average of 2013-2017)Highlighted - countries audited in the series

ANNEX V. PRODUCTS AND MAIN PLANT SPECIES/GENERA IMPORTED FROM THE COUNTRIES AUDITED

Country Plants for planting Seeds

Sri Lanka

Aquatic plants of genera Anubias, Cryptocoryne, Hygrophila, Bacopa, Rotala and Echinodorus.Unrooted or rooted cuttings without growing medium. A wide range of species and genera, including Dracaena, Epipremnum, Phylodendron, Codiaeum, Dieffenbachia, Aglaonema, Canna, Euphorbia, Piper, Spathifyllum, Maranta, Kalanchoe, Crossandra and Chlorophytum.

The export volume is insignificant

HondurasCanes of Yucca elephantiphes without roots and leaves in growing medium.Ready to sale plants in growing medium: Caryota spp. Chamedorea spp., Chrysalidocarpus (syn. Dyspis) lutescens and Coffea arabica (until the EU banned imports in 2015), Cycas revoluta.

The export volume is insignificant

Costa Rica

Unrooted cuttings: Aster, Ajania, Impatiens, Phlox, Solidago and CodiaeumRooted cuttings or canes, air layered plants in growing medium or potted plants in growing medium either for further propagation or ready for sale to consumers. The most important genera are: Aglaonema, Beucarnea, Bromeliaceae, Codiaeum, Coffea arabica (until the EU banned imports in 2015), Chrysalidocarpus, Cycas, Dieffenbachia, Dracaena, Eupatorium, Ficus, Lavandula, Monarda, Phylodendron, Polyscias, Sanseviera, Schefflera, Solidago and Yucca. Dracaena sp. plants are exported to EU in the largest volume. Until the introduction of specific import rules on host plants of Xylella fastidiosa, Phoenix roebelenii potted plants were exported in the largest volume before the relevant provisions of Commission Decision (EU) 2015/789 entered into force.

The export volume is insignificant

China

Bonsais of numerous species, including Buxus, Carmona, Camelia, Caragana, Chaenomeles, Eugenia, Ficus,Ginko, Ilex, Ligustrum, Loropetalum, Metasequoia, Pachira, Podocarpus, Rhododendron, Sageretia, Serissa, Syzygium, Wisteria and Zelkova. The plants are exported ready for sale to consumers.Unrooted cuttings, rooted cuttings in growing medium, air layered plants in growing medium. The main plant genera are: Dracaena, Phalaenopsis, Guzmania, Ficus, Rosa, Vriesea, Cacti,Tillandsia, Pachira, Gerbera, Paeonia, Myosotis spp., Nymphaceae, Clusia spp, Carmona, Echinacea, Agave, Scirpoides, Podocarpus, Cordyline, Heliconis, Euphorbia, Rhododendron.Rooted cuttings of Acer spp. in growing medium (host of Anoplophora chinensis)

Hybrid and commercial grade seeds of Lycopersicum esculentum, Capsicum spp. and Phaseolus spp. Mainly produced open-air (hybrids as well) in remote areas of the country

Guatemala

Unrooted cuttings, unrooted canes; Rooted cuttings, air layered plants in growing medium; potted plants ready for sale to consumers.The major plant genera are: Beucarnea, Chlorophytum, Cissus, Codiaeum, Cycas, Dieffenbachia, Epipremnum, Ficus, Hedera, Impatiens, Imperata, Miscanthus, Pennisetum, Peperomia, Phylodendron, Phlox, Solidago, Tillandsia and Yucca.

Hybrid seeds of Capsicum spp. and Lycopersicum esculentum grown in screen-houses

Ghana Potted plants of Ficus benjamina. The export volume is insignificant

UgandaMainly unrooted cuttings and limited amounts of rooted bedding plants. Many species and varieties; The most important plant genera are: Aster, Begonia, Bouvardia, Celosia, Chrysanthemum, Cotoneaster, Euphorbia, Hedera, Hydrangea, Impatiens, Pelargonium and Vinca.

The export volume is insignificant

ThailandVarious orchid species, Ficus sp. plants in growing medium.Rooted or unrooted cuttings of herbaceous plants in growing medium of various many species such as Hibiscus, Persea, Araceae, Marantaceae, Musaceae, spp. and Strelitziaceae

The export volume is insignificant

TanzaniaUnrooted or rooted cuttings in growing medium of numerous herbaceous annual or perennial plants. Chrysanthemum sp. cuttings are exported in the largest volume, followed by Begonia, Callisia, Kalanchoë and Pelargonium.

Hybrid seeds of Capsicum spp. and Lycopersicum esculentum (grown in screen-houses); seeds of Phaseolus spp. grown open air

KenyaUnrooted or rooted cuttings of numerous herbaceous annual or perennial plants. The most important plant genera are: Ajuga, Chrysanthemum, Dianthus, Gypsophyla, Kalanchoë, Pelargonium, Phlox, Poinsettia and Solidago

Hybrid seeds of Lycopersicum esculentum grown in screen- houses

Israel

Mostly unrooted cuttings of herbaceous plants belonging to numerous plant genera, including Calibrachoa, Chrysanthemum, Dianthus, Impatiens, Lantana, Lobelia, Myrtus, Petunia, Poinsettia Saliva and Thymus.Rooted cuttings of many herbaceous and woody species in growing medium, potted plants, scions (e.g. Mangifera sp.) and grafted plants.

Hybrid seeds of Capsicum spp. and Lycopersicum esculentum grown in isolated greenhouses

ANNEX VI. INTERCEPTIONS OF CONSIGNMENTS OF PLANTS FOR PLANTING AND SEEDS , REPORTED TO EUROPHYT-INTERCEPTIONS

Table I. Number of consignments of plants for planting and seeds intercepted due to the presence of HOs (2013-2017)

Number of consignments intercepted with HOs 2013 2014 2015 2016 2017

Plants for planting 100 104 74 112 58

Seeds 18 18 25 17 19

Total 118 122 99 129 77

From the audited countries 69 64 42 74 39

Share of the audited countries 58.4% 52.5% 42.4% 57.4% 50.7%Source: EUROPHYT- Interceptions

Table II. Number of consignments of plants for planting and seeds intercepted for reasons other than the presence of HOs (2013-2017)

Number of consignments intercepted for reasons other than the presence of HOs 2013 2014 2015 2016 2017

Plants for planting 598 473 556 434 618

Prohibited goods 35 47 73 29 112

PC absent 211 209 228 204 287 PC incomplete, illegible, fake, expired 76 47 41 33 56

Problems with additional declarations 279 172 209 159 155

Seeds 430 366 339 568 600

Prohibited goods 2 5 3 3 4

PC absent 252 212 183 454 486 PC incomplete, illegible, fake, expired 56 77 76 42 40

Problems with additional declarations 108 77 72 63 78

Interceptions for other reasons, total 1,028 839 895 1,002 1,218Source: EUROPHYT-Interceptions

ANNEX VII. INTERCEPTIONS WITH HARMFUL ORGANISMS OF CONSIGNMENTS OF PLANTS FOR PLANTING AND SEEDS FROM THE AUDITED COUNTRIES

Intercepted consignmentsCountry

2013 2014 2015 2016 2017Intercepted HOs Intercepted plant

species/genera

Sri Lanka 7 16 2 4 2 Plants for planting: Bemisia tabaci, Radopholus similis

Plants for planting: Aquatic plants, rooted and unrooted cuttings of various herbaceous species.

Honduras 1 2 1 0 0 Plants for planting: Xylella fastidiosa, Helicoverpa sp. Spodoptera sp.

Plants for planting: Coffea sp., Areca sp., Dyspis lutescens

Costa Rica 16 8 5 11 7Plants for planting: Bemisia tabaci, Xylella fastidiosa, soil nematodes (Meloidogyne sp., Longidorus sp., Xyphinema sp.), Spodoptera sp.

Plants for planting: Coffea sp, palm and other herbaceous species (e.g.., Dracaena sp., Dypsis sp., Monarda sp., Filodendron sp., Tillandsia sp. potted plants, rooted and unrooted cuttings

China 18 19 16 26 8

Plants for planting: Soil nematodes (Aphelenchus sp., Ditylenchus sp., Helichotylenchus sp., Meloidogyne sp., Tylenchorichus sp., Xyphinema sp.), Anoplophora chinensisSeeds: Clavibacter michiganensis subsp. michiganensis, potato spindle tuber viroid, Xanthomonas axonopodis pv. phaseoli, lettuce mosaic virus

Plants for planting: Mainly bonsais, potted plants and rooted cuttings of various species; Seeds: Solanum lycopersicum, Capsicum sp., Phaseolus vulgaris, Lactuca sp., Cucumis sp.

Guatemala 0 0 0 1 1 Plants for planting: Synchoporus acupunctatus

Plants for planting: Beaucarnea sp., Sanseviera sp.

Ghana 0 1 0 0 1 Plants for planting: Aleurocanthus wogulmi, Aphelenchoides sp.

Plants for planting: Citrus, Khaya, Musa – rooted or unrooted cuttings

Uganda 1 0 2 0 4Plants for planting: Bemisia tabaci, Helicoverpa sp., Spodoptera sp., Aleyrodidae, Tripidae

Plants for planting: Chrysanthemum sp., Cotoneaster sp., Eupatorium sp., Sutera sp. unrooted or rooted cuttingsSeeds: no interceptions

Tanzania 1 2 3 8 2Plants for planting: Bemisia tabaci, Aleyrodidae, Lyriomyza, Spodoptera, Tetranichidae, Thysanoptera

Plants for planting: Unrooted or rooted cuttings of many herbaceous genera (Begonia, Callisia, Chrysanthemum, Pelargonium)Seeds: no interceptions

Thailand 5 7 4 7 3

Plants for planting: Bemisia tabaci, Thrips palmi, soil nematodes (Aphelenchoides sp,, Helichotylenchus sp. Hirschmaniella sp. Meloidogyne sp., Radopholus sp.)

Plants for planting: Unrooted cuttings or plants in growing medium. More than twenty plant genus or species was intercepted

Kenya 4 2 3 6 8Plants for planting: Bemisia tabaci, Liriomyza sp. Tripidae, Chrysanthemum stunt viroid, Tomato spotted wilt virus

Plants for planting: Unrooted or rooted cuttings of numerous different herbaceous species (e.g. Ajuga, Chrysanthemum, Dianthus, Gypsophyla, Solidago) Seeds: various species of flowering plants

Israel 16 7 6 11 3

Plants for planting: Bemisia tabaci, Liriomyza sp., Spodoptera sp., potato spindle tuber viroid Seeds: Xanthomonas axonopodis pv. vesicatoria

Plants for planting: Unrooted or rooted cuttings; Many herbaceous species (e.g. Chrysanthemum, Dianthus, Impatiens, Lantana, Lobelia, Mangifera, Myrtus, Petunia sp. Saliva sp., Thymus sp.Seeds: Capsicum sp.

Audited countries 69 64 42 74 39

ANNEX VIII. SPECIFIC REQUIREMENTS LISTED IN ANNEX IV, PART A, SECTION I OF DIRECTIVE 2000/29/EC, MOST RELEVANT FOR THE IMPORT OF PLANTS FOR PLANTING AND SEEDS FROM THE AUDITED COUNTRIES; REQUIREMENTS OF COMMISSION DECISIONS (EU) 2012/138 AND 2015/789

Point of ANNEX

IVPlant species, type of product

Harmful organism or other conditions to be

declared on the PC

18

Plants of Citrus, Fortunella, Poncirus and their hybrids, other than fruit and seeds and plants of Araceae, Marantaceae, Musaceae, Persea spp. and Strelitziaceae, rooted or with growing medium attached or associated

Radopholus citrophilus and Radopholus similis

18.1

Plants of Aegle, Aeglopsis, Afraegle, Atalantia, Balsamocitrus, Burkillanthus, Calodendrum., Choisya, Clausena , Limonia., Microcitrus, Murraya, Pamburus, Severinia, Swinglea, Triphasia, other than fruit (but including seeds); and seeds of Citrus, Fortunella and Poncirus, and their hybrids, originating in third countries

Candidatus Liberibacter spp., causal agent of Huanglongbing disease of citrus/citrus greening,

18.2 Plants of Casimiroa, Choisya, Murraya, Vepris and Zanthoxylum, other than fruits and seeds, originating in third countries Trioza erytreae

18.3

Plants of Aegle, Aeglopsis, Afraegle, Amyris, Atalantia, Balsamocitrus, Choisya, Citropsis, Clausena, Eremocitrus, Esenbeckia, Glycosmis, Limonia, Merrillia, Microcitrus, Murraya, Naringi, Pamburus, Severinia, Swinglea, Tetradium, Toddalia, Triphasia, Vepris, Zanthoxylum, other than fruit and seed, originating in third countries

Diaphorina citri

28 Plants of Dendranthema sp., intended for planting, other than seeds Chrysanthemum stunt viroid

28.1 Plants of Dendranthema sp., intended for planting, other than seeds Chrysanthemum stem necrosis virus

29 Plants of Dianthus sp., intended for planting, other than seeds

Erwinia chrysanthemi pv. dianthicola, Pseudomonas caryophylli and Phialophora cinerescens

31Plants of Pelargonium sp., intended for planting, other than seeds, originating in countries where Tomato ringspot virus is known to occur:

Xiphinema americanum as vector of Tomato ringspot virus

31.1 Plants of herbaceous species, intended for planting, other than: bulbs, corms, plants of the family Gramineae, rhizomes, seeds, tubers

Liriomyza sativae and Amauromyza maculosa

32.3Plants of herbaceous species, intended for planting, other than: bulbs, corms, plants of the family Gramineae, rhizomes, seeds, tubers, originating in third countries

Liriomyza huidobrensis and Liriomyza trifolii

33 Plants with roots, planted or intended for planting, grown in the open air

Clavibacter michiganensis ssp. sepedonicus, Synchytrium endobioticum, Globodera pallida, Globodera rostochiensis

34

Soil and growing medium, attached to or associated with plants, consisting in whole or in part of soil or solid organic substances such as parts of plants, humus including peat or bark or consisting in part of any solid inorganic substance, intended to sustain the vitality of the plants, originating in non-European countries, other than Algeria, Egypt, Israel, Libya, Morocco, Tunisia

Harmful insects and nematodes

36.1 Plants, intended for planting, other than: bulbs, corms, rhizomes, seeds, tubers, originating in third countries Thrips palmi

37. Plants of Palmae intended for planting other than seeds, originating in Palm lethal yellowing

Point of ANNEX

IVPlant species, type of product

Harmful organism or other conditions to be

declared on the PCnon-European countries mycoplasm and Cadang-

Cadang viroid

37.1

Plants of Palmae, intended for planting, having a diameter of the stem at the base of over 5 cm and belonging to the following genera: Brahea, Butia, Chamaerops, Jubaea, Livistona, Phoenix, Sabal, Syagrus, Trachycarpus, Trithrinax and Washingtonia

Paysandisia archon

41Annual and biennial plants. other than Gramineae, intended for planting, other than seeds, originating in countries other than European and Mediterranean countries

HOs in general

42

Plants of the family Gramineae of ornamental perennial grasses of the subfamilies Bambusoideae, Panicoideae and of the genera Buchloe, Bouteloua, Calamagrostis, Cortaderia, Glyceria, Hakonechloa, Hystrix, Molinia, Phalaris, Shibataea, Spartina, Stipa and Uniola intended for planting, other than seeds, originating in countries other than European and Mediterranean countries

HOs in general

43 Naturally or artificially dwarfed plants intended for planting other than seeds, originating in non-European countries

Specific rules on regular inspections, removal of soil

44

Herbaceous perennial plants, intended for planting, other than seeds, of the families Caryophyllaceae (except Dianthus), Compositae (except Dendranthema), Cruciferae, Leguminosae and Rosaceae (except Fragaria), originating in third countries, other than European and Mediterranean countries

HOs in general

45.1Plants of herbaceous species and plants of Ficus and Hibiscus, intended for planting, other than bulbs, corms, rhizomes, seeds and tubers, originating in non-European countries

Bemisia tabaci

46Plants intended for planting, other than seeds, bulbs, tubers, corms and rhizomes, originating in countries where the relevant harmful organisms are known to occur.

Bemisia tabaci as vector of Bean golden mosaic virus, Cowpea mild mottle virus, Lettuce infectious yellow virus, Pepper mild tigré virus, Squash leaf curl virus, other viruses transmitted by Bemisia tabaci

48 Seeds of Solanum lycopersicum

Clavibacter michiganensis ssp. michiganensis, Xanthomonas campestris pv. vesicatoria and Potato spindle tuber viroid

51 Seeds of Phaseolus sp. Xanthomonas campestris pv. phaseoli

Decision (EU)

2012/138

Plants for planting that have a stem or root collar diameter of 1 cm or more at their thickest point, other than seeds, of Acer spp., Aesculus hippocastanum, Alnus spp., Betula spp., Carpinus spp., Citrus spp., Cornus spp., Corylus spp., Cotoneaster spp., Crataegus spp., Fagus spp., Lagerstroemia spp., Malus spp., Platanus spp., Populus spp., Prunus laurocerasus, Pyrus spp., Rosa spp., Salix spp. and Ulmus spp.

Anoplphora chinensis specific rules for imports from China

Decision (EU)

2015/789Plants for planting listed in Annex I of the Decision

Xylella fastidiosa Import conditions as detailed in Article 17 of the Decision

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