WORLD TRADE  
ORGANIZATION  G/SPS/GEN/761 
26 February 2007 
 (07-0795) 
Committee on Sanitary a nd Phytosanitary Measures Original:   English 
  
 
 
PRIVATE SECTOR STANDARDS AND DEVELOPING COUNTRY EXPORTS  
OF FRESH FRUIT AND VEGETABLES 
 
Communication from the United Nations Conf erence on Trade and Development (UNCTAD)
 
 
 
 The following communication, received on 22 Fe bruary 2007, is being circulated at the 
request of UNCTAD  
_______________ 
 
Table of Content 
 
Page 
I.
 INTRODUCTION ................................................................................................................... .2 
A. CONTEXT ............................................................................................................................... ......2  
B. PRIVATE -SECTOR STANDARDS IN THE FRES H FRUIT AND VEGETABLE SECTOR ...........................2  
C. RELATIONSHIP BETWEEN GOVERNME NT REGULATIONS AND PRIVATE -SECTOR 
STANDARDS ............................................................................................................................... ..3 
II. ISSUES ADDRESSED IN THE CASE STUDIES.................................................................3  
A. TRADE IMPLICATIONS ..................................................................................................................3  
B. APPROACHES TO NATI ONAL GAP SCHEMES .................................................................................5  
C. BENEFITS OF GAP SCHEMES .........................................................................................................6  
D. OBSTACLES TO GAP IMPLEMENTA TION IN DEVELOPING COUNTRIES ..........................................6  
E. DEVELOPMENT ASPECTS TO BE CONSIDERED  IN DEVELOPING NAT IONAL GAP SCHEMES ...........7  
F. THE ROLE OF GOVERNMENTS IN PROMOTING GAP IMPLEMENTATION .........................................7  
G. FACILITATING EUREPGAP CERTIFICATION ...................................................................................8  
H. ISSUES RELATED TO EUREPGAP STANDARD -SETTING PROCESSES ...............................................9  
I. HARMONISATION OF STANDARDS AND THE EUREPGAP BENCHMARKING OPTION .......................9  
III. CONCLUSIONS AND RECOMMENDATIONS................................................................11  
 
 G/SPS/GEN/761 
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  I. INTRODUCTION  
A. C
ONTEXT  
1. The issue of private standards was first discu ssed at the meeting of the WTO Committee on 
Sanitary and Phytosanitary Measures on 29-30 June 2005.  It had been raised by Saint Vincent and the 
Grenadines, in particular in relation to the EurepG AP Fruit and Vegetables standard. An information 
session was subsequently organized on the margins of the 11-12 October 2006 meeting with 
representatives of EurepGAP and UNCTAD.  A number of developing countries suggested that the issue of private and commercial standards in gene ral should be included on th e agenda of the next 
SPS Committee meeting.  The Chairman suggested th at Members could prepare contributions with 
specific examples of their experiences for a substa ntive discussion.  The current note is being made 
available by the UNCTAD secretariat.  It high lights key issues addressed in country-case studies 
carried out in the context of a technical coope ration project implemented under the umbrella of 
UNCTAD’s Consultative Task Force on Envir onmental Requirements and Market Access for 
Developing Countries (CTF). 
2. The CTF has so far paid special attention to  the EurepGAP standard because it offers an 
interesting case study of the increasingly important role of private-sector standards in the market-
place, their possible implications for developing coun tries’ exports and possible pro-active adjustment 
policies.
1  An analysis of the EurepGAP standard is al so interesting because its secretariat claims that 
the standard, in particular its benchmarking optio n, can contribute to the global harmonization of 
standards for good agricultural practices (GAP).2 CTF activities have not focused on the interface 
between private standards and WTO disciplines, but  rather on the implications for developing 
countries, and for small and medium-sized producers in particular, of the increasing influence of 
private standards on market access and export success. 
3. The CTF project has included country-case studies by local experts, as well as national and 
subregional stakeholder dialogues in Africa (Ghana , Kenya and Uganda), Latin America (Argentina, 
Brazil and Costa Rica) and South-East Asia (Malay sia, Thailand and Viet Nam). Publications that 
collect the results of these activities in Latin America and South-East Asia and place them in a 
broader analytical context are under preparation.  The results of the African studies will be published 
following the Workshop on Good Ag riculture Practices in Eastern and Southern Africa: Practices and 
Policies, organized by the FAO a nd UNCTAD secretariats in coope ration with the Kenyan National 
Task Force on Horticulture (Nairobi, Kenya, 6 - 9 March 2007).  Furthermore, a study on the strategic 
concept of EurepGAP benchmarking and procedur al requirements of the benchmarking process was 
prepared by Nigel Garbutt (Chairman of EurepGAP) and Elmé Coetzer (FoodPlus GmbH). 
B. PRIVATE -SECTOR STANDARDS IN THE FRESH FRUIT AND VEGETABLE SECTOR  
4. The fresh fruit and vegetables (FFV) sector provides opportunities for economic and social 
development gains. Donors and NGOs have supported projects aimed at increasing production and 
                                                      
1 The EurepGAP Fruit and Vegetables standard is a scheme for good agricultural practices (GAP) at 
the farm level, developed by EUREP, an association of European fresh produce retailers and importers.  It is a 
pre-farm gate standard, which applies to primary production. 
2 At the tenth session of the UNCTAD Commission on Trade in Goods and Services, and Commodities 
(Geneva, February 2006), participan ts encouraged the CTF to continue its efforts to facilitate a dialogue 
between public and private stakeholders on the impact of and adjustment to voluntary, private-sector-set environmental requirements. It was noted that work on the EurepGAP standard, as it relates to horticultural 
exports of developing countries, provides an interesting example.  It was emphasized that UNCTAD’s work 
relating to EurepGAP codes of practice does not mean that it endorses any particular set of private standards.. See Report of the Commission on Trade in Goods an d Services, and Commodities, on its Tenth Session  
(TD/B/COM.1/80, 13 March 2006).  G/SPS/GEN/761 
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  exports of FFV as a means of achieving poverty alleviation, export dive rsification and rural 
development and employment objectives.  Although  many developing countries have benefited from 
tariff preferences and development assistance to in crease FFV exports, the possible implications of 
Government regulations and private-sector standa rds in developed countries for small producers in 
developing countries have been an issue of con cern. Private-sector standards are playing an 
increasingly important role in the marketplace.  Many supermarket chains have formulated their own 
standards, either as individual chains or on an in dustry-wide basis (e.g. the European supermarket 
sector).  The most important reasons for the spr ead of private-sector standards are the stiff 
competition between retailers (leading to very slim margins); the intention of retailers to reduce in-
house monitoring and inspection costs and transfer  them to exporters/producers; and the global 
sourcing of products.  Estimat es suggest that retailers currently obta in about a quarter of all fresh fruit 
and vegetables sold in developing countries (OECD, 2006). 
5. Certain private-sector standards, such as Eurep GAP,  require compliance with the regulations 
of both the country of production and the product-rela ted regulations of the country of destination, 
involving multidimensional food safety, occupationa l health and safety, environmental and, 
sometimes, social requirements.  It has been argued that private-sector standards may be more 
stringent than public-sector regulations. Similarl y, concern has been expressed that, due to the 
existence of a multitude of private-sector sta ndards, technical cooperation programmes aimed at 
assisting producers in developing countries to comp ly with Government regulations in developed 
countries may be insufficient to effectively facilitate  market access if the implications of private-
sector standards are not addressed. 
6. Private-sector standards appear to contribute to the exclusion of weaker players (i.e. countries 
with low volumes of FFV exports a nd smallholder producers) from value chains even in developing 
countries where infrastructure and services operate effi ciently and reliably.  This may have significant 
impacts on poverty because the smallholder supply b ase has strong links with rural development in 
developing countries (COLEACP, 2007).  A recent Na tural Resources Institute (NRI)/International 
Institute for Environment and Development (IIED) study found that in Kenya in 2006 there were 
60 per cent fewer smallholders (less than 1 ha ) exporting to the United Kingdom than in 2002 
(Graffham and Vorley, 2005).  
C. RELATIONSHIP BETWEEN GOVERNMENT REGULATIONS AND PRIVATE -SECTOR STANDARDS  
7. The relationship between government regulation and private-sector standards is rarely explicit 
and largely unexamined.  However, some have argued that the regulatory and standard-setting 
activities of governments and the private sector may be mutually supportive in important respects. 
Each focuses on a separate aspect of risk management.  Government regulations aim at outcomes : the 
characteristics of the finished product are specified , and producers and importers are responsible for 
ensuring, by whatever means, that  these requirements are met. Private-sector standards, by contrast, 
focus on processes :  requirements are set for the entire system of production and supply, with specific 
instructions on production methodologies and te sting procedures (Chia-Hui Lee, 2006).  This 
separation of objectives may bring bene fits to both government legisl ators and private sector standard 
setters, to the extent that the relationship between the two could be characterized as a "tacit alliance".3 
II. ISSUES ADDRESSED IN THE CASE STUDIES 
A. TRADE IMPLICATIONS  
8. The trade impacts of EurepGAP and other private- sector standards that play an important role 
in the market place depend on issues such as the co sts of adjustments required to comply with the 
                                                      
3 For more information see:  UNCTAD (2007a) G/SPS/GEN/761 
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  standard;  the stringency of specific control points and compliance criteria (see also the next section);  
the availability of certification infrastructure, laboratories and other facilities;  whether or not training and extension services are provided by Government  institutions and others;  and whether or not 
Government support is provided (for example in certif ication costs).   Meeting high quality and food 
safety standards may also provide developing count ries with a competitive edge in specific FFV. An 
often-cited example is Peru’s asparagus sector (O’Brien and Díaz Rodríguez, 2004). 
9. The individual farmer or groups of farmers se eking to comply with EurepGAP or other GAP 
standards has to incur costs of investment in equi pment and facilities, training, record keeping and use 
of tracking systems, audit and certification.  
10. The total implementation and certification costs depend on the provider of technical support; 
the need for new infrastructure; and the extent of  the producer’s prior knowledge of GAP as well as 
their prior experience in record-k eeping.  For example, depending on the existing facilities before 
GAP compliance is sought, producers may have to  make significant investment in building safe 
storage facilities for fertilizers and crop protection products.  Up-front costs to upgrade the farm in 
order to meet GAP requirements may be significant. Indeed, investment in infrastructure may often be 
the major cost element.
4  Whereas many requirements are likely to result in higher costs, there may 
also be cost savings, e.g. as a result of reduced p esticides use.  The Brazilian standards for Integrated 
Fruit Production (see below), for example, have been  successful in drastically reducing the application 
of agrochemicals by a range of 20-80 per cent per product and crop (Andrigueto, Nasser and Teixeira 
2006).5 
11. With regard to certification, some examples he lp to illustrate the kind of costs involved. 
According to Eco-LOGICA, a national certification body in Costa Rica, the average basic cost of 
certification for a producer ranges from $800 to $1,2 00, plus additional costs that depend on the 
farmland extension, location and conditions of acce ss to the farm.  The costs during the consulting 
period (when technical support is provided to prep are for the certification inspection) vary from 
$3,000 (if a group of companies receives certificati on and technical support) to $12,000. In Brazil, 
indicative certification costs for individual farms ar e estimated to range from $1,000 to $1,500, plus 
some $700- $800 per audit.  For group certificati on, the costs are estimated at $200-$300 per 
producer. In addition, there are general administra tion and registration fees as well as travelling costs 
of the inspector. 
12. The extent to which the above factors affect  FFV exports of individual exporting countries 
depends also on factors such as (a) the destination of FFV exports and (b) the producer profiles of key 
FFV crops in the exporting country.  The EurepGAP  standard seems especially relevant for many 
Latin American countries (such as Brazil which expor ts some 85 per cent of its total FFV exports, 
excluding nuts, to the EU market) and Africa.  C onversely, South-East Asian countries export their 
                                                      
4 OECD case studies (OECD 2006) found that "in Gh ana, EurepGAP compliance costs for a 15-20 acre 
pineapple farm were about USD 400-500 but for large farms they can be more substantial.  For example, a 
1 000 acre pineapple exporter producer has spent USD 80 000 to be EurepGAP ready. In Chile, a grape producer estimated compliance costs so far had been USD 220 000 but that further investments were still 
required, e. g. in machinery and a loading platform".  In Morocco, Aloui and Kenny (2004) report that several of 
the medium- and large-scale tomato grower/exporters were  required to make substantial investments in facilities 
and equipment in order to meet the EurepGAP requirem ents.  Many lacked storage rooms for pesticides and 
fertilizers and appropriate changing/washing facilities for farm workers. One farm operating with ten hectares 
under plastic greenhouses and a work force of sixty people needed to invest some $50,000 in buildings, facilities, and equipment to become EurepGAP compliant. Taking into account proper depreciation of these 
investments over time, the firm estimates that meas ures taken for EurepGAP co mpliance account for some 12 
per cent of its farm production costs and 4 percent of the FOB value of its tomato exports (World Bank 2006). 
5 Others argue that certain requirements in the area of pesticides use may force farmers to use more 
expensive chemicals.    G/SPS/GEN/761 
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  FFV largely to regional markets, shipping only a small portion to the EU market.  Therefore, the 
direct implications of EurepGAP requirements are likel y to be less urgent for South-East Asia than for 
the other regions. 
13. Yet, for exports to the EU market, the importa nce of EurepGAP certification as a requirement 
for participation in value chains is not always cl ear.  Not all customers in the EU market require 
assurance that the FFV they buy have been prod uced in accordance with EurepGAP or other GAP 
standards.  Even retailers who are members of Eu repGAP may not require EurepGAP certification, as 
its standard does not oblige them to source EurepGAP -certified produce only.  Ne vertheless, there is a 
general view that EurepGAP is an increasingly importa nt factor in the market place.  With regard to 
Asian developing countries, even though the share of exports to the EU markets as a share of total 
exports may be small, it is to be noted that EurepGAP and other GAP standards for primary FFV 
production are gaining importance in regional Asian ma rkets.  For example, authorities in China and 
Japan are developing national GAP schemes and seek ing benchmarking of their own schemes against 
the EurepGAP standard.  Some have argued that  benchmarking national GAP codes to EurepGAP 
could facilitate mutual acceptance of national GAP  codes among Asian developing countries and 
perhaps be easier to accomplish than formal mutual recognition agreements. 
14. Another important factor is the producer profile  of key exporting sectors. In general, large 
producers and exporters of FFV to the European  Union have managed to achieve EurepGAP 
certification when necessary.  In certa in cases, they have also assisted at least some of their suppliers 
in complying with EurepGAP requirements.  Ho wever, small-scale producers tend to face major 
difficulties in meeting those requirements.6  Only if there is sufficient financial and technical 
assistance as well as monitoring and management oversi ght will smallholders be able to meet private 
standards (this is currently only achieved by successful  out-grower networks run by exporters, or by 
relatively large, well-functioning producer coopera tives) (OECD, 2006: 20).  However, reliance by 
governments and industry on donor and NGO funds and assistance runs the risk of creating a 
"dependence syndrome" of otherwise unsustainable  small-holder production for global supply chains.7 
B. APPROACHES TO NATIONAL GAP SCHEMES  
15. Several developing countries have been devel oping national GAP codes in order to achieve 
food-safety objectives and promote sustainable FFV  production while at the same time facilitating 
access to export markets.  However, there are certa in differences in the approaches to the development 
of national GAP schemes and the prio rities of such schemes in different regions.  With regard to Latin 
America, the Brazilian Ministry of Agriculture, Liv estock and Food Supply (MAPA) is the owner of 
the standards for Integrated Fruit Production (PIF  in accordance with its acronym in Portuguese).  
Unlike EurepGAP, PIF standards are crop-specific,  currently covering some 17-20 different fruit 
categories.  In Argentina, the Government has issued voluntary guidelines for hygiene and good agricultural practices for fruit and vegetables. Co sta Rica does not have a national GAP scheme.  The 
Chamber for Agriculture and Agro-industry h as been elaborating an initiative for GAP 
implementation, but it is not clear whether there would be interest in seeking EurepGAP 
benchmarking. Smallholders who ow n the land they cultivate but are not yet certified may be the main 
                                                     
 
6  A recent NRI/IIED study concludes that on average, establishment of EurepGAP for a smallholder in 
Kenya costs at least 1,760 euros per grower and mainte nance at least 1,130 euros (some exporters work with 
more than 1,000 smallholders). 
7 The OECD goes a step further by highlighting that "the sums necessary for small-holders to be 
certified under the private voluntary standards' schemes, the management efforts required and uncertainties as to the long-term viability of small-holder certification  rais e questions about development strategies postulated on 
small-holder production of high-value agricultural produce for export …  The question then becomes whether 
public efforts, instead of aiming for global value-chain access for small- holders, should be directed to either 
helping them to adapt out of agriculture or to supply the local or other less demanding markets in terms of 
quality and certifications" (OECD, 2006: 21 and 17).    G/SPS/GEN/761 
Page 6  
 
  beneficiaries. The Chamber believes that any GAP  standard should also take into account the 
requirements of the United States market.  
16. In South-East Asia the development of na tional GAP schemes is largely driven by 
Governments.  In Thailand, the Ministry of Ag riculture and Cooperatives (MOAC) has developed a 
national GAP programme. Farmers who fulfil the requi rements of the GAP standard can label their 
products with the GAP logo, the "Q" quality mark (a third-party certification system owned by 
MOAC).  In Malaysia, the Department of Agricu lture developed the Malays ian Farm Certification 
Scheme for GAP (SALM) in 2002.  SALM is recognized by Singapore, Malaysia’ largest market for FFV exports (and the destination of over 50 per cent  of Malaysian FFV expor ts in value terms in 
2005) through a bilateral agreement, but is not rec ognized in other markets.  In 2003, a private-sector 
entity, QA Plus Asia-Pacific Sdn. Bhd, proposed to  develop a national standard that could also be 
benchmarked against EurepGAP.  Work started in 2004 and in January 2005 the standard was adopted 
by the Department of Standards Malaysia (DSM),  after considering public comments, as MS-GAP: 
Malaysian Standard: Crop Commodities-G ood Agricultural Practice (MS 1784:2005). 
17. ASEAN countries generally propose a gradual approach which could start with a scheme 
focusing on national food safety with major government  involvement and subsequently be used as a 
basis for the development of local or even na tional "premium" GAPs that would mainly aim at 
facilitating access to key export markets.   Work has started on an ASEAN GAP
8 that would consist of 
four modules covering food safety, environmental management, worker heal th, safety and welfare, 
and produce quality.  Each module can be used alone or in combination with other modules.  This 
enables progressive implementation of GAP schem es, based on individual country priorities. 
C. BENEFITS OF GAP SCHEMES  
18. GAP codes that reflect national development priorities and agronomic conditions can bring 
benefits to developing countries by promoting th e production of safe and healthy foods, improving 
workers’ health and safety, and reducing environm ental impacts.  Several developing countries have 
been developing national GAP  programmes (see below). 
19. GAP programmes can assist farmers and exporte rs in developing countries in meeting the 
regulatory and private-sector requirements of domestic and international markets.  GAP 
implementation and certification in developing countri es is also seen as an instrument to secure access 
to markets.  Some ASEAN governments (e.g. in Thailand) are encouraging producers/exporters to 
adhere to GAP schemes.  In combination with other measures such as mandatory certification of 
pesticides residues, this is seen as a means to help prevent products from being denied access to 
external markets.  
D. OBSTACLES TO GAP IMPLEMENTATION IN DEVELOPING COUNTRIES  
20. There can be a number of general obstacles to GAP implementation, such as lack of 
awareness about the benefits of good agricultural pr actices, low levels of education, difficulties in 
keeping records and undertaking regular self-ins pection, poor access to unadulterated inputs (e.g. 
seeds), lack of trained personnel, high costs of GAP implementation, insufficient access to credit 
needed to finance necessary impr ovements in installations and mach inery and the absence of price 
premiums for products from certified farms. 
                                                      
8 An ASEAN-wide quality assurance (QA) system  being developed by interested ASEAN member 
States with assistance from two Australian experts as part of ASEAN Australian Development Cooperation 
Program Stream - Quality Assu rance Systems for ASEAN Fru it and Vegetables Project.  G/SPS/GEN/761 
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  21. There are also specific obstacl es to EurepGAP certification. Small-scale producers have been 
reported as facing difficulties in meeting the control points/compliance criteria concerning the use of pesticides of registered chemicals, storage of  fertilizers and crop protection products, hygiene 
procedures in harvesting and produ ce handling and risk assessments (for example for new plantings 
and hygiene in harvesting). In many developing countries, laboratories are not yet accredited to ISO 
17025 or an equivalent standard for testing, as required by the control points on crop protection 
residue analysis and water quality. 
22. A significant constraint mentioned in almost all case studies is uncertainty about the extent to 
which retailers and importers in overseas market s will actually demand certification, which raises 
doubts about the importance of certification in the marketplace. 
E. D
EVELOPMENT ASPECTS TO BE CONSIDERED IN DEVELOPING NATIONAL GAP SCHEMES  
23. National GAP schemes in developing countries can take account of local development and 
agronomic conditions.  However, there is also a n eed to seek harmonization with global requirements 
to gain recognition in external markets and to  reduce the need for multiple audits.  These two 
objectives should be carefully balanced. 
24. National GAP schemes should pay special attention to the needs of smallholders. Several case 
studies highlight the need for effective stakeholder involvement, in particular producers, in the development of GAP standards.  Brazil’s standard  emphasizes, among other things, the key role of 
training, technological development and infrast ructural support (such as the establishment of 
laboratories to carry out analyses of chemical  residues according to internationally accepted 
methodologies, and the application of sampling met hods in accordance with international standards) 
and partnerships with the private sector, local  governments and non-governme ntal organizations.  
F. T
HE ROLE OF GOVERNMENTS IN PROMOTING GAP IMPLEMENTATION  
25. A pro-active government role may fall into the following clusters: 
•  Policy analysis:  facilitating conceptual  clarity on enhancing the developmental 
contribution of GAP, including addressing smallholder concerns, and optimizing the 
balance between benefits and costs. 
•  Facilitating investment in hard and soft infra -structure for SMTQ systems (i.e. standards, 
metrology, testing, and quality assurance), tran sport, cooling chain and directing related 
donor funding. 
•  Devising flanking or supportive policies su ch as on extension services and financial 
support. 
•  Assuring policy coherence among government agencies on GAP development and 
implementation. 
•  Facilitating and engaging in stakeholder di alogue on the developm ent and implementation 
of GAP. 
26. Governments should generally pl ay an enabling role without being an obstruction (UNCTAD, 
2007c).  They have a key role to play in s upporting extension services that may facilitate GAP 
implementation by producers, in particular small and medium-sized ones.  Furthermore, they can 
support GAP implementation by: 
•  Creating or enhancing awareness of the benefits of GAP among producers. G/SPS/GEN/761 
Page 8  
 
  •  Supporting training.  
•  Elaborating criteria for assessing new sites for FFV production.  
•  Addressing problems with the regist ration of crop prot ection products. 
•  Assuring effective control of some aspects covered by EurepGAP control points, such as 
seed quality, registration of agrochemicals, and developing national legislation in the areas 
of environmental protection and workers’ health and safety. 
•  Providing the necessary infrastructure for compliance with control points (e.g. appropriate 
disposal of empty packages of agrochemicals) and promoting research and development and technical assistance (e.g. to facilitate accr editation of laboratories to ISO 17025 or an 
equivalent standard for testing).  
•  Providing The EurepGAP Fruit and Vegetabl es standard is a scheme for good agricultural 
practices (GAP) at the farm level, developed by EUREP, an association of European fresh produce retailers and importers.  It is a pre -farm gate standard, wh ich applies to primary 
production.effective regulations for companies supplying services and inputs relevant to 
GAP, such as laboratories, suppliers of fer tilizers and agrochemicals, and providers of 
calibration products and services. 
27. Government agencies may assist small growers in GAP implementation and certification.  In 
Brazil, public-sector funds are available for training a nd sharing the costs of certification, in order to 
assist producers in adhering to the Government -run PIF programme, although such funds are 
generally not available for certification against private-sector schemes.  
28. One question is to what extent Government s and donors should use public-sector funds to 
help producers implement and comply with private-s ector standards.  One could argue, however, that 
private-sector standards can also play a useful ro le in meeting public policy objectives in various 
areas, including food safety, improved environmental ma nagement and diversifi cation of exports into 
high-value products.  
29. As discussed in the 2006 Annual CTF Meeting,  even when Governments could not take 
responsibility for private-sector standard setting ac tivities, they could engage in discussions with 
private-sector organizations, organize informal semina rs and invite private-sector bodies to participate 
in certain technical cooperation workshops for de veloping countries.  Some donors have cooperated 
with private-sector organizations in projects to  assist developing country producers in meeting 
private-sector food-safety and environmental standa rds (for more information, see UNCTAD, 2006).  
G. F
ACILITATING EUREPGAP CERTIFICATION  
30. Developing countries can explore several options  to facilitate EurepGAP certification for 
producers, such as group certification, the develo pment of national interpretation guidelines and 
benchmarking of a locally developed standard for GAP  against the EurepGAP standard. They can also 
seek to promote recognition of nationa l GAP schemes in export markets. 
31. Group certification may be a viable option fo r small-scale producers who participate in 
already-established producer groups or who are s uppliers of large exporte rs, but small growers 
generally need support, in particular in implementi ng quality control systems, to achieve certification.  
Training and investment costs incurred in implemen ting and maintaining an internal control system 
tend to be high.  The minimum number of produ cers in a group will depend on the turnover of the 
group and its capacity to maintain the internal cont rol system.  A key element in the EurepGAP group 
certification option is a documented Quality Mana gement System that allows the external 
Certification Body to certify the entire group rather than each individual group member.  The German  G/SPS/GEN/761 
 Page 9 
 
 
  Association for Technical Cooperation (GTZ) de veloped a manual that has been approved by 
EurepGAP and which includes operational procedur es and recording forms for a fictional farmer 
group. 
32. The EurepGAP group certification option was ch osen as an appropriate option to help 
pineapple producers in Ghana overcome obstacles to e xporting, in particular those related to meeting 
EU maximum residue levels for pesticides. The prob lems first triggered the sector’s engagement with 
EurepGAP and later the EU-funded Pesticide Initiative Programme.  In Ghana, the pineapple sector is 
the largest contributor to the country’s non-traditi onal exports. Most fruits for export come from 
commercial farms. However, about 45 per cent of total exports are obtained from smallholders’ farms, 
made up of over 600 farm families. By late 2003, around one third of pineapple exporters in Ghana 
had obtained EurepGAP certification, either as i ndividual companies or as a grower group under the 
produce marketing organization scheme.  Recently , EurepGAP, in cooperation with some donors, 
launched a major multi-stakeholder project aimed at integrating small scale farmers into the global 
supply chain.    
33. National interpretation guidelines may make  EurepGAP control points and compliance 
criteria easier to understand.  In  Kenya, for example, a national technical committee is developing 
interpretation guidelines for Kenyan smallholders. The benchmarking option is analysed below.   
H. ISSUES RELATED TO EUREPGAP STANDARD -SETTING PROCESSES  
34. Over the years the EurepGAP standard setting processes may have become more transparent. 
For example, some have taken the proceedings of  the EurepGAP annual conference in Prague in 
2006, which focused on the revision process, as an indicator of progress: for the first time, the 
proposed changes for the 3rd revision of EurepGAP standards were presented in a participatory 
approach, outside the technical committees.9  Yet developing countries may have difficulties in 
effectively participating due to the costs involved, frequent meetings in different parts of the world 
and high membership fees.  
35. National Technical Working Groups (NTWGs) fo r fruit and vegetables have been established 
in some 14 countries, including 5 developing countri es (Argentina, Brazil, Colombia, Malaysia and 
Turkey).10 NTWGs could develop national interpretation guidelines, explore and - if appropriate - 
support national benchmarking processes and cha nnel inputs from national experts to EurepGAP 
Technical Standards Committees.  In addition, NT WGs should draw attention to problems resulting 
from the short revision cycles of EurepGAP protocols. 
I. HARMONISATION OF STANDARDS AND THE EUREPGAP BENCHMARKING OPTION  
36. Henson (2006: 29) argues that "Indeed, there is  evidence that the tendency and speed towards 
harmonization of private food safety and quality st andards far exceeds sim ilar efforts in public 
spheres".  For example, the BRC Global Standard a nd the International Food Standard are collective 
private food standards.  The Global Food Safety In itiative (GFSI) has been developing guidelines for 
the benchmarking of private food safety standards to  promote harmonization or mutual recognition of 
differing codes.11  The above-mentioned standards cover food processing.  However, in 2004 the 
GFSI guidance document was extended to include pr e-farm gate standards.  Subsequently, SQF 1000 
was assessed and recognized as equivalent. 
                                                      
9 GTZ newsletter No. 40 - November 2006  http ://www.gtz.de/de/dokumente/en-trade-news-40.pdf 
10 Source:  EurepGAP website. 
11 The BRC Global Standard, IFS, Dutch HACCP, SQ F 1000 and SQF 2000 have been assessed and 
recognized as equivalent to the GFSI Guidance Document. G/SPS/GEN/761 
Page 10  
 
  37. The EurepGAP benchmarking option provides an option for promoting harmonization and 
equivalence of pre-farm gate standards.  Some  developing countries have already benchmarked 
national standards to EurepGAP and others have e xpressed an interest in benchmarking.  ChileGAP is 
a private-sector scheme owned by the Fundación de Desarrollo Frutícola  (Fruit-growing 
Development Foundation), developed w ith support from the Government.  In Mexico, the Ministry of 
Agriculture (SAGARPA)
12 led the development of MexicoGAP.  Interestingly, Chile and Mexico, the 
two Latin American countries that have successf ully completed the benchmarking process, only send 
a relatively small proportion of their FFV to the EU market (compared, for example to Brazil, 
Colombia, Argentina and most African countries).  Many Chilean growers were already EurepGAP-
certified before the benchmarking process began, but  needed GAP certification for the United States 
market as well .  In this way, producers/exporters need onl y one certification, ChileGAP, to export to 
both markets.  They also needed a scheme that was easy to understand for smallholders.  The Kenyan 
Fresh Produce Exporters Association (FPEAK), with the assistance of COLEACP, has been 
developing a national standard which is currently going through benchmarking.    
38. Currently, too few benchmarked national GAP sta ndards exist to draw conclusions on their 
success in general. ChileGAP seems to be very successful (Villalobos and Santocoloma, 2005).   
39. Benchmarking, however, is not an easy process and may not be a viable option for many 
developing countries.  It should be noted that in  order for a national standard to be formally 
recognized it must comply with all control points and compliance criteria as set out in the relevant 
EurepGAP standard.  Garbutt and Coetzer (2005) argue that this "strict interpretation of equivalence" 
is necessary if buyers are to have confidence in th e comparability of different standards.  The concept 
of equivalence employed in the context of Eurep GAP benchmarking is stricter than the concept of 
equivalence in the SPS and TBT agreements.  It shoul d also be noted that while the WTO Agreements 
use the concept of equivalence of outcomes , EurepGAP uses the concept of equivalence of processes . 
In addition, a national standard has to re-apply fo r benchmarking to take account of revisions of the 
EurepGAP standard (the third revision of th e EurepGAP standards was published on 8 February 
2007). 
40. The benchmarking process may be time-consuming.   Benchmarking may also imply the need 
to introduce into existing national protocols new requi rements that may not be particularly relevant or 
appropriate to local conditions, and that may creat e obstacles to small growers (including those who 
have already been trained to implement the local  standard) who are primarily interested in the 
domestic market.  Governments may be reluctant to incorporate requirements of a private-sector 
standard, like EurepGAP, into a government-owned GAP  standard, such as PIF.  This may be the case 
in particular where countries already have a we ll-developed Government-owned scheme, such as 
Brazil.  
41. Most GAP schemes in developed countries are owned by the private-sector. In developing 
countries, however, there are both GAP schemes owned by the private sector (generally developed 
with Government support) and Government-owned  GAP schemes.  Government-owned standards 
may at times be developed and impl emented with little participation of  producers, in particular small 
growers.  However, in Malaysia the national GAP st andard was proposed by the private sector and is 
being developed in close cooperati on between the public and private sectors.  The implementation of 
MexicoGAP is being carried out by an export promo tion body owned by the Ministry of Agriculture, 
known as Mexico Quality Supreme, which has clo se links with the main producers and exporters. 
42. Benchmarking may be easier between two private-sector schemes than between a private-
sector scheme (such as EurepGAP) and a Government-own ed scheme, in particular where the latter is 
already well-developed. The EurepGAP benchmarki ng process needs to be better adapted to already-
                                                      
12 Secretaria de Agricultura, Ganadería, Desarrollo Rural, Pesca y Alimentación.  G/SPS/GEN/761 
 Page 11 
 
 
  existing GAP protocols in developing countries, a nd the concept of “equivalence” should take full 
account of the achievements of such programmes.  
43. Some have argued that benchmarking a Gove rnment-owned national GAP standard to a 
private-sector standard (such as EurepGAP) may raise systemic WTO issues because the link could be subject to WTO disciplines (Gandhi, 2005).  It shoul d be noted, however, that a GAP scheme is not 
generally mandatory.  It is a voluntary standard, wh ether it is owned by the Government or the private 
sector. 
III. CONCLUSIONS AND RECOMMENDATIONS 
44. There is a need for more dialogue between re presentatives of private-sector standard-setting 
organizations, governments and produc ers/exporters in developing countries.  Such dialogues could 
focus on (a) conceptual issues and appropriate appro aches to the development of national GAPs;  and 
(b) clarification of the role of governments and other stakeholders.  
45. Donors can play an important role in facilitati ng consultations in this regard.  Donors may 
also wish to support participation of devel oping-country representatives in annual EurepGAP 
meetings and in the work of its technical comm ittees. National Technical Wo rking Groups could play 
a key role in facilitating participation in EurepGAP standard-setting processes. 
46. UNCTAD's Consultative Task Force (CTF) on Environmental Requirements and Market 
Access for Developing Countries has already su pported national and sub-regional stakeholder 
dialogues and plans to intensify these activities in  the future, in close co-operation with FAO.
13 
                                                      
13 For more information see UNCTAD (2006). G/SPS/GEN/761 
Page 12  
 
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