1 
 Revision of GB  approach for r isk targeted plant health import 
inspections  
 
Purpose of this document  
1. The aim of this document is to set  appropriate baseline levels of inspections for specified 
categories of goods of plant health relevance. Inspection frequenc ies for  physical and identity  
checks at border control points (BCPs) and control points (CPs)  which are  inland versions of 
BCPs  are proposed . Industry will have the choice of where to have checks carried out and they 
may choose to vary be tween BCP and CP according to circumstances. As such this document 
provide s a single list of frequencies applicable to both types of inspection point.  
 
Introduction  
2. The inspections carried out by GB plant health services on consignments of imported plants,  
plant products and other objects serve as an audit  to check that goods  comply with GB 
phytosanitary requirements. The inspections are intended to monitor imports for known and 
new threats and reduce the  likelihood of  the introduction and spread of organisms harmful to 
plants or plant products .  Inspections  are crucial in protecting GB against risks arising from 
trade in plants and plant material  as well as providing intelligence about new and emerging 
issues, which need to be assessed to determine i f requirements and controls need to be 
updated . They  help to  protect our nation’s crops, produce, trees and other plants from the 
threat of harmful pests and diseases and help support the government’s goal of leaving the 
natural environment in a better sta te than we found it.  
 
3. In principle all consignments of regulated plants and plant products , i.e., those which could 
pose a n unacceptable risk to plant health and which must be accompanied by a phytosanitary 
certificate , could be inspected on arrival  at BCP s or shortly afterwards at inland CPs . However, 
this is impractical and , in line with the World Trade Organisation ( WTO ) Protocol amending 
the Marrakesh Agreement establishing the World Trade Organization, Decision of 27 
November 2014 (Agreement on Trade Facilitation ), GB phytosanitary agencies concentrate 
inspection efforts on higher -risk consignments and expedite the release of lower -risk goods 
taking pest threats into account to inform decision making.  
 
4. Although the UK has departed from the EU, for plant health purposes, the GB regime  currently 
distinguishes  between goods from the EU, Switzerland and Liechtenstein , and good s from  
other  countries  (referred to in this document as “rest of the world” (RoW) ). Currently , on a 
temporary basis, regulated  plant health goods from the EU , Switzerland and Liechtenstein and 
goods from other countries  are inspected at different frequencies (frequency being 
inspections per consignment imported ). Current inspection frequenc ies for goods  from other 
countries  are a legacy from the UK’s EU membership . Here we aim to develop a single 
inspection regime appli cable t o key goods of phytosanitary relevance from both RoW and EU , 
Switzerland and Liechtenstein .  
 
Phytosanitary i nspection rates for o ther commodities  
5. It has already been determined that commodities listed in Part B of Annex XI t o Implementing 
Regulation EU 2019/2072  (as retained ) from RoW will be inspected at a frequency of 1%, i.e., 
a physical inspection of 1 in every 100 consignments will be conducted. The type of plant 
material covered by this legislation includes for example,  specified cut flowers, fruits, 
vegetables and herbs as well as some cereal seed. Such material has been deemed low risk. 
For a detailed list of the plants and plant products, together with CN codes, refer to the 
legislation. The rate of inspection of such  consignments from the EU , Switzerland and 
Liechtenstein,  will also be 1% in future . 2 
  
Items that do not need phytosanitary inspection  
6. Commodities listed in Part C of Annex XI to Implementing Regulation EU 2019/2072  (as 
retained ) do not require phytosanita ry certificates to enter GB and do not require 
phytosanitary inspection. They are therefore excluded from being part of a risk targeted 
inspection regime.   
 
Implementation  and revision of inspection frequencies  
7. The proposed baseline frequency of inspections provides  a harmoni sed starting point for 
inspections of selected goods from RoW  and the EU,  Switzerland and Liechtenstein . Following 
consultation, which may result in changes to the policy , inspection frequencies will be applied 
from 1st July 2022 . Inspection will allow monitoring of risk and c ollection of data to inform 
decisions and potentially adjust inspection frequencies.  
 
8. Inspection frequencies are dynamic and when the UK was part of the EU , inspection 
frequencies on produce trades were altered  in response to perceived threats. The UK Imports 
Threat and Horizon Scanning sub -group  (which reports to the UK Plant Health Risk Group)  will 
monitor import and  interception data .  If there is an upsur ge of interceptions of pests or new 
threats are detected  with a particular commodity or country of origin ( considering  factors  such 
as compliance data, new scientific evidence and country controls) , the frequency of 
inspections may  be adjusted rapidly in r esponse.  However, adjustments to inspection 
frequencies and hence fees will more routinely  be made on an annual basis. Any proposed 
changes to inspection frequencies will be made  by the UK Imports Threats  and Horizon 
Scanning sub -group and considered by t he UK Plant Health Risk Group  in response to a change 
in the evidence for the relative risk associated with a particular commodity and origin.   
Interception data will be available on UK  Plant Health Inspection Notification System 
(UKPHINS ) and the Plant H ealth Advisory Forum will be informed of proposed  changes to 
inspection frequencies  before their introduction .  
 
Overview  
9. Plants for planting will receive the highest levels of inspections because they are generally 
considered as presenting a higher risk of pest introduction than other commodities. This is 
because , first,  pests can survive, and possibly reproduce, on their living hosts or in growing 
media during transport of the plants for planting .  Secondly,  once at destination, the plants 
will rema in planted or be replanted, facilitating survival and possible spread of the pest (EPPO, 
2012) when hosts are likely to be nearby.  Taking these factors into account, but also noting 
support for a scheme which includes plants, a broad categorisation of dif ferent types of plants 
for planting has been proposed to determine relative risk profiles, and thereby inspection 
frequencies.  It is not anticipated that these categories/profiles will be routinely updated in 
the same way as for produce, due to the inhere nt risk factors associated with plants for 
planting, as described above.  Uncertainty about the exact provenance and history of plants 
being traded in addition to the risk factors above mean that a broad categorisation based on 
intended use/lifespan/growin g environment is a more proportionate and appropriate 
approach as regards plants for planting.  Notwithstanding this novel approach, and the 
intention to maintain broad categories and inspection levels, if persistent interceptions  or new 
threats  were detec ted on categories of plants eligible for reduced inspections, these would be 
considered in the review process, to determine if there should be re -adjustment of inspection 
levels for the category concerned, including the possibility of reverting to 100% if necessary.  
 
10. Whilst part of  the EU, we inspected some fruits, vegetables and cut flowers at higher rates 
than now proposed. The reduction in such inspection intensity is based on the lower risk of 
pest outbreaks result ing from such imports  to GB.  
 3 
 Annex 1 : Baseline inspection frequencies for higher risk items of 
phytosanitary relevance  
 
Approach  
 
11. ISPM 32 (FAO, 2009) allocates plant - based commodities into risk categories according to the 
degree of processing they have been subject to, and the intended use of the commodities. 
Similar principles can be further applied to discriminate between commodity risks. Some 
intended uses of commodities, e.g. plants for planting, result in a much higher probability of 
introducing pests than others such as plant material for processing (FAO, 2009).  
 
12. Inspections could also be reduced for reasons such as:  
 
a. the degree of processing likely to have occurred prior to export e.g. at harvest  and pre-
packing e.g. sorting and washing. D uring such procedures infested material can be 
rejected, removing pests from the pathway ,  
b. the manner of storage and shipping, for example rapid cooling, fumigation, cold storage 
and movement in controlled atmospheres (high C0 2, low O 2); such factors inhibit pest 
survival,  
c. low likelihood of pest transfer.   
d. Finished plants, retailed to the public are likely to be of high quality, and plants such as 
bedding plants which are annual or biennial plants are short lived and provide a shorter 
window of opportunity for pests to transfe r compared to pests carried on perennials.  
e. Houseplants will be kept indoors and any pests on them will be physically isolated with 
limited opportunity to spread to hosts outside or in other house s.  
f. Seed for sowing are likely to have been tested and a leve l of quality reached before 
marketing can take place.  However , for some viruses, very large numbers of seeds need 
to be tested to determine whether a consignment is likely to be infected (Constable et al., 
2019; Dall et al., 2019) . 
g. Industry assurance schemes within supply chains contribute to providing biosecurity 
protection. In dustry assurance schemes can have higher standards than phytosanitary 
legislation requires and include criteria unrelated to plant health, such as quality 
specificatio ns, which nevertheless contributes to improved biosecurity protection.  
 
Caveat  
13. Reducing import checks on high er risk commodities will have more serious consequences than 
reducing checks on lower risk but still regulated co mmodities , such as apple fruit , an d 
manufactured items such as timber products without bark. This is because lower risk 
commodities are perceived to be less likely to introduce plant pests or cause pest outbreaks 
than higher risk commodities due to factors such as the pests on the commodit y and the 
intended use of the commodity  (MacLeod, 2019) . Nevertheless, reducing inspections is not 
risk free; risk managers recognise this and balance the need to provide inspections, which 
essentially audit a pathway in terms of compliance with GB import requirements, with the 
resources available to conduct inspections. The impact on trade also needs to be consider ed. 
 
Suggestions for inspection frequencies  
 
14. Five frequencies of inspection are used i .e. 3%, 5%, 10% , 50% and 100%.  
 
15. For root and tubercle vegetables that are not for planting, a 1% level of inspection was 
considered but because 1% is used for lower risk items in Art icle 73, a slightly higher frequency 4 
 was thought appropriate in this case. However, as data is collected a nd considered in future 
the frequency of checks could be revised (up or down), as is the case for all items.   
 
 
16. As baseline data is collected on trades the targeted inspection regime future decisions 
regarding inspection frequencies will become better inf ormed.  
 
 
Regarding vegetable and oil seed, 5% is proposed as the seed has been regarded as higher 
risk than Article 73 goods  
 
17. Regarding controlled wood, wood products and isolated bark, a 100% frequency of inspection 
is being considered due to the high ri sk of pest introduction from these commodities.  
 
 
Identifying finished plants  and plant products  that do or do not need 100% of 
consignments inspected  
 
18. Some categories  of plants for planting that are destined for final retail present a lower risk 
than plan ts in the same category that are going to be grown for a further period before they 
are sold to retailer because the period in which plants are grown on will increase the risk of  
pest  spread .  For a reduced frequency of inspection to apply to such plants, there will need to 
be evidence from their packing or labelling or by other means that they are intended for direct 
sale to final consumers not involved in professional plant production . 
 
19. Longer lived plants such as trees and shrubs are considered to present a greater plant health 
threat than shorter lived plants such as annual bedding plants.  This assessment is based on 
factors such as the opportunity for pest spread being greater for lon ger lived plants and the 
high potential impacts of tree pests.  
 
20. Some categories of plants (e.g. Narcissus bulbs) will be inspected at a lower  rate if they are to 
be grown on for retail sale rather than propagated further before they are used in production 
because the process of propagation provides an opportunity for pests to multiply further 
before the production stage.  
 
21. Regarding ware potatoe s, they generally represent a low likelihood of introducing harmful 
organisms, but GB will target inspections and testing of ware potatoes from countries where 
a specific pest threat has been identified , such as Egypt, Poland, Portugal, Romania and Spain . 
Non -EU countries which are allowed to export ware potatoes have previously been assessed 
as having a low risk to EC plant health (with the exception of Egypt), and therefore should 
have a similar treatment as the EU , Switzerland and Liechtenstein . 
 
22. Higher rates of inspection have been proposed for some trades for which there have been a 
high number of pest interceptions and/or there is a particular risk associated with the trade; 
these include: Luffa. sp., Telfaria from Nigeria, Ocimum from the R oW, Corchor us, poinsettias 
(Euphorbia pulcherrima ) and cut roses from countries where rose rosette virus is present.