COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on protective measures against pests of plants
Date: 2013-05-06
Institutions: European Commission
Subjects: biodiversity, destruction of crops, import (EU), marketing standard, plant health control, plant health treatment, plant propagation

EUROPEAN 
COMMISSION 

Brussels, 6.5.2013  
SWD(2013) 169 final 

COMMISSION STAFF WORKING DOCUMENT 

IMPACT ASSESSMENT 

Accompanying the document 

Proposal for a  

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 

on protective measures against pests of plants 

{COM(2013) 267 final} 
{SWD(2013) 168 final} 

EN 

   EN 

 
 
 
 
  
 
 
TABLE OF CONTENT 

SECTION 1: PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1.  CONSULTATIONS   
1.2.  DATA COLLECTION 
1.3. 
1.4. 

INTER-SERVICE STEERING GROUP 
FOLLOW-UP OF RECOMMENDATIONS OF THE IMPACT ASSESSMENT BOARD 

SECTION 2: PROBLEM DEFINITION 

2.1.  BACKGROUND 
2.2.  PROBLEM IDENTIFICATION 
2.2.  RELATED ISSUES 
2.2.  PARTIES AFFECTED 
2.4.  HOW WOULD THE PROBLEM EVOLVE, ALL THINGS BEING EQUAL? 
2.5  DOES THE EU HAVE THE RIGHT TO ACT (SUBSIDIARITY)? 

SECTION 3: OBJECTIVES 

INTERMEDIATE OBJECTIVES 

3.1.  GENERAL OBJECTIVES 
3.2. 
3.3.  SPECIFIC OBJECTIVES 
3.4.  CONSISTENCY WITH OTHER EU POLICIES AND HORIZONTAL OBJECTIVES 

SECTION 4: POLICY OPTIONS 

4.1.  POLICY OPTIONS INCLUDED IN THE ANALYSIS 
4.2.  DISCARDED POLICY OPTIONS 

SECTION 5: ANALYSIS OF IMPACTS 

5.1.  OPTION 1:  IMPROVE ONLY THE FORM AND CLARITY OF THE REGIME 
5.2.  OPTION 2:  PRIORITISE, MODERNISE AND STEP UP PREVENTION 
5.3.  OPTION 3:  PRIORITISE, MODERNISE, STEP UP PREVENTION AND REINFORCE ACTION   

AGAINST OUTBREAKS 

5.4.  OPTION 4:  PRIORITISE, MODERNISE, STEP UP PREVENTION, REINFORCE ACTION  

AGAINST OUTBREAKS AND EXPAND THE SCOPE TO IAS PLANTS 

SECTION 6: COMPARING THE OPTIONS 

6.1.  COMPARING OPTIONS IN TERMS OF ECONOMIC, SOCIAL AND ENVIRONMENTAL IMPACTS 
6.2.  COMPARING THE OPTIONS IN LIGHT OF THE OBJECTIVES 
6.3.  HIGHLIGHT THE TRADE-OFFS AND SYNERGIES ASSOCIATED WITH EACH OPTION 
6.4.  PREFERRED OPTION 

SECTION 7: MONITORING AND EVALUATION 

LITERATURE 

SECTION 8: ANNEXES 

ANNEX I:   EXECUTIVE SUMMARY OF THE EVALUATION STUDY 
ANNEX II:   LEGAL STRUCTURE OF THE REGIME AND FORESEEN CHANGES 
ANNEX III:   INTERNATIONAL PLANT PROTECTION CONVENTION 
ANNEX IV:   WTO SANITARY AND PHYTOSANITARY AGREEMENT 
ANNEX V:   CONVENTION ON BIOLOGICAL DIVERSITY 
ANNEX VI:   OVERVIEW OF THE EU AGRICULTURE AND FORESTRY SECTOR 
ANNEX VII:  RELEVANCE OF HARMFUL ORGANISMS AND INVASIVE ALIEN PLANT SPECIES TO THE EU  

4 
5 
6 
6 

7 
12 
20 
21 
22 
22 

25 
25 
25 
26 

27 
28 

31 
31 
34 

37 

40 
41 
42 
45 

46 

48 

51 
74 
76 
78 
81 
85 
94 

AGRICULTURE AND FORESTRY, ENVIRONMENT, LANDSCAPE AND PUBLIC AND PRIVATE GREEN  

ANNEX VIII: COSTS AND EXPECTED IMPACTS OF THE BASELINE SCENARIO 
104 
ANNEX IX:   OUTLINE OF AMENDMENTS TO THE REGIME IN OPTIONS 1-4 AND FORESEEN IMPACT ON COSTS  109 
ANNEX X:  SUMMARY OF THE OPINIONS OF STAKEHOLDERS AND MEMBER STATES 
121 
ANNEX XI:   LIST OF CONSULTED STAKEHOLDERS  
129 
ANNEX XII:   EXECUTIVE SUMMARY OF THE SUPPORTING ECONOMIC STUDY 
131 

 
 
 
 
Acronyms 

Better Training for Safer Food programme 
Common Agriculture Policy 
Convention on Biodiversity 
Conference of Parties of the CBD 
Chief Officers for Plant Health 
Commission on Phytosanitary Matters of the IPPC 
Common Strategic Framework 
European Food Safety Authority 
European and Mediterranean Plant Protection Organisation 
European Union 
Food and Agriculture Organisation of the United Nations 
Food Chain Evaluation Consortium 
General Agreement on Tariffs and Trade 
Impact Assessment 
Invasive Alien Species 
International Plant Protection Convention 
International Standard on Phytosanitary Measures 
Inter-Service Steering Group 
International Seed Testing Association 
Information Technology 
Member State 
Non-Governmental Organisation 
National Plant Protection Organisation 
Plant Health Directive 
Plant Health Regime 
Pest Risk Analysis 
Plant Reproductive Material 
Protected Zone 
Regional Plant Protection Organisation 
Small and Medium-sized Enterprises 
Sanitary and Phytosanitary Agreement under the WTO 
Task Force 
Treaty on the Functioning of the European Union 
Trade Control and Expert System 
Wood Packaging Material 
World Trade Organisation 

BTSF 
CAP 
CBD 
COP 
COPHs 
CPM 
CSF 
EFSA 
EPPO 
EU 
FAO 
FCEC 
GATT 
IA 
IAS 
IPPC 
ISPM 
ISSG 
ISTA 
IT 
MS 
NGO 
NPPO 
PHD 
PHR 
PRA 
PRM 
PZ 
RPPO 
SME 
SPS 
TF 
TFEU 
TRACES 
WPM 
WTO 

Acronyms of consulted stakeholders' organisations are provided in the Annexes.

 
 
 
 
Section 1: Procedural issues and consultation of interested parties 

1.1. Consultations 

Member States 

The Council on 21 November 2008 invited the Commission to proceed to an evaluation 
of  the  EU  plant  health  regime  (PHR)  and  to  consider  possible  modifications  to  the 
existing  legal  framework  and  the  impact  of  such  modifications1.  The  Commission 
initiated a comprehensive evaluation of the regime from the introduction of the internal 
market  (1993)2  and  contracted  the  necessary  study  out  to  an  external  consultant3. 
Member  State  (MS)  experts  participated  in  the  Inter-Service  Steering  Group  for  the 
evaluation. A conference took place on 23-24 February 2010 to inform the stakeholders 
and MS on the progress of the evaluation and to consult them on the provisional options 
for the future developed by the consultant. The input received framed the final options 
and  recommendations.  The  report  of  the  evaluation4  (Annex  I)  was  presented  in  a 
second  conference5  on  28  September  2010  including  stakeholders,  the  general  public, 
and representatives of MS and third countries. Linked to this conference was a public 
consultation  on  the  recommendations  from  the  evaluation  and  the  scope  of  the 
subsequent impact assessment. 

In preparation for the impact assessment (IA), the options recommended by the external 
consultant  were  discussed  with  the  MS  in  Council  with  the  Chief  Officers  for  Plant 
Health (COPHs)6 and, as concerns the coherence with the Plant Reproductive Material 
(PRM) regime, the Heads of Service for that regime and the relevant Working Party7. 
Four task forces with MS experts and Commission were set up and twice convened8 to 
further  discuss  the  main  areas  of  change.  A  fifth  task  force  was  set  up9  to  discuss  the 
inclusion of plant health controls in Regulation 882/2004/EC. Task force reports were 
approved  by  the  Council  Working  Party  of  the COPHs,  with  whom  final  meetings  on 
the  foreseen  changes  and  the  impact  assessment  took  place  on  3-4  May  and  7-8  June 
2011. At the 3-4 May 2011 meeting, a consultation document concerning the strategic 
review options was launched. In addition, input for the consultations and position papers 
were received from several MS and data for the evaluation and IA were supplied by the 

1 Council of the European Union, 2906th Economic and Financial Affairs/Budget, Brussels, 21 November 

2008. Council Conclusions on the Review of the EU Plant Health Regime (104228). 

2 Taking account of a previous evaluation of the financial aspects of the regime, completed in 2008. 
3  Food  Chain  Evaluation  Consortium  (FCEC),  consisting  of  Civic  Consulting,  Agra  CEAS  Consulting 

(project leader), Van Dijk Management Consultants and Arcadia International.  

4 http://ec.europa.eu/food/plant/plant_health_biosafety/rules/docs/final_report_eval_en.pdf  
5 Opened by the Commissioner for Health and Consumers, the Chair of the Parliamentary Committee for 
Agriculture  &  Rural  Development  and  the  Belgian  Presidency's  Federal  Minister  responsible  for 
agriculture. 

6  On  29  September  2010,  8  October  2010  (jointly  with  Heads  of  Service  for  Plant  Reproductive 
Material), 8-9 November 2010, 30 November 2010, 1 December 2010, 3-4 May 2011 and 7-8 June 
2011. 

7 On  8 October 2010 (jointly with the Chief Officers for Plant Health) and 13 December 2010. 
8 Remit of the Task Forces: List of harmful organisms, prioritisation, positioning of harmful organisms 
(TF1);  Plant  passport,  protected  zones  and  responsibility  sharing  (TF2);  Import  regime  and 
surveillance (TF3); Emergency measures and solidarity (TF4). The Task Forces were convened on 
resp. 10, 17, 18 and 29 November 2010, 3, 14 and 16 February 2011 and 11 March 2011. TF3 was 
additionally convened on 27 May 2011.  

9 TF5 was convened on 26 May 2011. 

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MS  to  the  external  consultant.  The  MS  were  also  informed  on  the  review  via  the 
Standing Forestry Committee on 28 June 2011. 

Stakeholders 

Stakeholders (industry association representatives and NGOs) were consulted from the 
very start of the review process, prior to the initiation of the evaluation of the PHR10, 
during  the  evaluation  study  and  again  during  the  preparation  of  the  IA.  An  ad-hoc 
Working  Group  on  Plant  Health11  was  set  up  under  the  Advisory  Group  on  the  Food 
Chain, Animal and Plant Health. The progress was furthermore presented and discussed 
in  the  aforementioned  Advisory  Group  itself12,  in  other  Advisory  Groups13  and  on 
invitation  in  meetings  of  COPA-COGECA,  EUROPATAT,  ESA  and  UNION 
FLEURS14. Stakeholder consultation was a key element of the evaluation study and the 
supplementary  economic  study  contracted  out  to  an  external  consultant.  The 
consultation concerned changes of the EU plant health regime itself as well as elements 
of the regime to be transferred to or from the PRM regime and the future chapeau EU 
regime on official controls15 on food and feed, animal health and welfare, plant health 
and plant reproductive material. 

The  conferences  organised  during  the  review  process  ensured  stakeholders'  input  and 
views  concerning  the  recommendations  and  the  scope  of  the  impact  assessment,  both 
orally at the conferences and through the linked public consultation. A consultation on 
the  technical  change  proposals  was  linked  to  the  meeting  of  the  Working  Group  on 
Plant  Health  on  18  February  2011  and  targeted  the  preferred  way  forward  for  the 
changes with major impact. Consultations were additionally published on the dedicated 
web page16 of DG SANCO. A final consultation17 on the strategic options was launched 
on 13 May 2011.  

Summary of the consultation of the interested parties 

Throughout  the  evaluation,  IA  and  policy  making  process  interested  parties'  (MS  and 
stakeholders) views have been sought in order to design the policy options and assess 
their  potential  usefulness  and  impacts.  Annex  X  gives  an  overview  of  their  positions 
and Annex XI lists the stakeholders that were consulted during the process and/or sent 
in opinion papers. 

1.2. Data collection 

The collection of data commenced with a comprehensive evaluation of the PHR by the 
external consultant from 2009 to 2010. The evaluation included an ex post analysis of 

10 On 9 December 2008. 
11  On  1  July  2009,  23-24  February  2010  (jointly  with  the  Chief  Officers  for  Plant  Health)  and  18 

February 2011. 

12 On 29 May 2009, 4 December 2009, 26 March 2010, 17 February 2011 and 14 March 2011. 
13 Advisory Groups on Seeds (19 April 2010; 10 November 2010), Advisory Group on Cotton (11 June 
2010), and Advisory Group on Floriculture and Ornamentals (9 November 2009; 18 October 2010; 
12 October 2011). 

14 On 8 May 2009, 14 and 17 October 2009, 12 October 2010, 16 December 2010 and 27 January 2011. 
15  A  recast  of  Regulation  (EC)  882/2004  on  official  controls  performed  to  ensure  the  verification  of 

compliance with feed and food law, animal health and animal welfare rules. 

16 http://ec.europa.eu/food/plant/plant_health_biosafety/rules/index_en.htm  
17  The  stakeholders  were  consulted  through  continuous  targeted  consultation  of  all  known  actors  with 
possible interest, rather than a web-based public consultation, given the highly specialized nature of 
this policy area.  

4 

 
 
                                                 
the  regime  for  the  period  1993-2008,  the  collection  of  economic  data  on  costs  and 
administrative  burden  for  competent  authorities  and  stakeholders  stemming  from  the 
regime,  as  well  as  the  development  ex  ante  of  options  and  recommendations  for  the 
future. The evaluation report was delivered in May 2010. 

The internal process to develop the IA was further supported by a second contract with 
the  consultant.  This  contract  concerned  a  study  on  the  quantification  of  costs  and 
benefits of amendments to the regime, supplementary to the data that had been collected 
during  the  evaluation.  The  study  consisted  of  modules  addressing  the  ex  ante 
assessment of the economic impact of specific technical options for the revision of the 
legislation.  The  scope  of  the  issues  to  be  addressed  had  been  subject  to  stakeholder 
consultation. The modules were set up in such a way that aggregation was possible to 
potential overall policy options. In July 2011, the final report of the study (Annex XII) 
was  delivered  by  the  consultant.  Where  necessary  further  information  was  gathered 
from  the  literature,  study  reports  and  queries  to  assess  the  key  impacts  the  change  in 
policy  would  have.  Furthermore,  the  social  and  environmental  impacts  of  the  policy 
options were assessed by Commission's services.  

The data gathered as described above are used and referenced throughout the IA, along 
with  data  from  the  scientific  literature  and  reports  of  studies  carried  out  for  the 
Commission and the MS in relation to harmful organisms (pests of plants) and invasive 
alien plant species and their impacts.  

1.3. Inter-Service Steering Group 

A  Commission  Inter-Service  Steering  Group  (ISSG)  on  the  IA  for  the  revision  of  the 
legislation was established. The group was led by DG SANCO with the participation of 
the  following  Commission  Directorates  General  and  Services:  Agriculture  and  Rural 
Development, Budget, Environment, Enterprise and Industry, Research and Innovation, 
Taxation  and  Customs  Union,  Trade,  Legal  Service  and  the  Secretariat-General.  The 
group  met  on  6  December  2010  (planned  approach  and  problem  analysis  were 
discussed), 15 April 2011 (report from the contractor on progress, collection of data and 
a  first  draft  of  the  impact  assessment  were  discussed)  and  26  September  2011 
(exchange of views on draft final impact assessment report). Final comments received 
from the ISSG members were incorporated as appropriate. 

1.4. Follow-up of recommendations of the Impact Assessment Board 

The IA was discussed at a meeting of the Impact Assessment Board on 14 December 
2011.  The  recommendations  of  the  Board  prior  to  the  meeting  in  its  quality  checklist 
and following the meeting in its opinion have allowed improving the report. Firstly, the 
revised  IA  report  further  clarifies  the  budgetary  implications  of  co-financing  direct 
operator losses due to action to tackle EU priority pests. As requested, Annex IX now 
provides  further  details  on  the  level  of  those  costs,  the  respective  rules  for  Union  co-
financing and capping of those costs and the mechanisms to cope with high demand, the 
modalities  to  allow  operators  to  obtain  the  financial  compensation,  and  the  interplay 
with  the  listing  of  priority  pests.  Secondly,  the  report  further  underpins  the  need  for 
Union financial support for early detection and eradication of pest outbreaks. Thirdly, 
the report explains the extent to which smaller firms could use approaches suitable to 
their  size.  Fourthly,  the  differences  between  invasive  alien  plant  species  and  harmful 
organisms (pests) of plants and the implications for their management are clarified.   

5 

 
 Section 2: Problem Definition 

2.1. Background 

2.1.1. Rationale for the EU plant health regime 

Plant health is a key factor for sustainable and competitive agriculture, horticulture and 
forestry.  Healthy  seeds  and  propagating  material  are  required  for  profitable  crops  and 
ensuring  jobs,  plant  innovation  and  food  security18.  In  the  case  of  trees  and  shrubs, 
protecting plant health is essential for the preservation of the Union's forests, landscape 
and public and private green. As a rule, organisms (insects, fungi, nematodes, bacteria, 
viruses)  that  are  injurious  to  plants  co-evolved  with  host  plant  species  on  their  own 
continent,  where  they  cause  mild  damage  and  can  be  managed  by  good  agricultural 
practices  such  as  crop  diversification,  rotation,  resistant  plant  varieties  and  the  use  of 
plant protection products (pesticides). However, these approaches are often insufficient 
to address pests and diseases from other continents, against which European plants and 
trees usually lack genetic resistance (no co-evolution) and for which no natural enemies 
occur  in  Europe.  When  introduced  into  Europe,  such  pests  and  diseases  cause  severe 
economic  damage  and  reduce  the  growth  of  agriculture:  they  jump  to  previously 
unaffected and even entirely new host species, spread fast across countries, and cause 
lasting yield reduction and permanently increased costs for production and control. The 
often  severe  economic  losses  undermine  the  profitability  and  competitiveness  of 
agriculture and forestry and put additional burden on Member State (MS) expenditures. 
In  addition,  the  establishment  of  new  pests  and  diseases  often  elicits  trade  bans  from 
third countries, causing further damage (economic, jobs) to EU exports. 

Therefore,  the  first  objective  of  the  EU  plant  health  regime  (PHR)  is  to  protect 
European  agriculture  and  forestry  by  preventing  the  entry  and  spread  of  non-native 
harmful  organisms  (pests  and  pathogenic  micro-organisms).  The  main  tool  hereby  is 
Council Directive 2000/29/EC, which also reflects international trade agreements in this 
area. The PHR secures safe trade by the establishment of EU import requirements and 
intra-EU movement conditions for plants and plant products19. Outbreaks of the listed 
organisms have to be eradicated or, if that is impossible, contained to protect the rest of 
the EU territory. A second objective of the regime is to ensure the availability and use 
of healthy plant material at the beginning of the chain of plant production by preventing 
the  spread  of  harmful  organisms  with  seeds  and  planting  material.  This  objective  is 
shared with the EU regime for plant reproductive (planting) material. Healthy planting 
material is critical for organisms (e.g. viruses) against which no pesticides are available. 
Where  available,  pesticide  use  is  mainly  restricted  to  agriculture,  horticulture 
(applications  in  forestry  are  very  limited)  and  gardens  and  may  bring  along 
environmental and human health risks. 

The  EU  PHR  is  unique  in  that  it  is  an  open  regime:  movements  of  plants  and  plant 
products into and within the EU are allowed on condition that specific restrictions and 
requirements  are  respected  (e.g.  provenance  from  a  pest  free  area  or  appropriate 
treatment). The high volumes of imports from other continents (Annex VI) nevertheless 

18 The Great Famine in Ireland in the 19th century was caused by the introduction of a potato pest new to 
Europe.  Today,  food  supplies  crops  worldwide  continue  to  be  threatened  by  pest  and  disease 
outbreaks and the threat increases rather than decreases (Bruce, 2010).  

19 Securing export potential is not an objective of the PHR. The success of the regime however impacts 
on the possibilities to export EU plants and plant products to third countries with similar quarantine 
requirements.  

6 

 
 
                                                 
imply  a  high  probability  of  future  outbreaks  of  alien  harmful  organisms.  The  PHR  is 
therefore indispensable both for protecting the health, economy and competitiveness of 
the EU plant production sector as well as for maintaining the Union's open trade policy. 

There  are  close  analogies  between  the  PHR  and  the  EU  animal  health  regime,  which 
have similar objectives and intervention logic (stamping out)20.  

2.1.2. International legal framework 

The  international  framework  for  regulatory  plant  health  is  the  International  Plant 
Protection Convention (IPPC; Annex III), to which the EU and the MS are contracting 
party.  The  WTO  Sanitary  and  Phytosanitary  Agreement  (SPS;  Annex  IV)  recognises 
the right of WTO members to decide on the appropriate level of protection of plant life 
or  health,  while  setting  out  rules  how  that  level  may  be  achieved  without  undue 
interference with trade. The Convention for Biological Diversity (CBD; Annex V) aims 
to  prevent  the  introduction  and  spread  of  invasive  alien  species  (IAS)  in  general, 
including  non-native  pests  of  plants.  Reversely,  the  IPPC  definition  of  'pest'  (the 
equivalent  for  'harmful  organism'  in  the  EU  legislation)  includes  invasive  alien  plant 
species, i.e., a subset of the IAS covered by the CBD. Since 2004, the CBD and IPPC 
officially  cooperate  to  promote  synergy  and  avoid  overlaps  and  unnecessary 
duplication.  No  IAS  plants  have  been  regulated  so  far  under  the  PHR  other  than 
parasitic plants. 

2.1.3. The Plant Health Directive 

The  main  instrument  of  the  PHR  is  Council  Directive  2000/29/EC  on  protective 
measures against  the  introduction  into the  Community of organisms harmful  to plants 
or  plant  products21  and  against  their  spread  within  the  Community  (hereafter:  Plant 
Health Directive).  It is a consolidation of the initial Council Directive 77/93/EEC that 
dates  back  to  1977,  when  the  import  requirements  of  the  MS  were  harmonised  while 
plant health controls were maintained for movements between MS. Major updates: 

−  At the creation of the internal market (1993), border controls between MS were 
abolished,  including  those  for  plant  health.  A  fundamentally  new  system  was  
developed  to  balance  the  free  trade  of  plant  material  across  the  EU  and  the 
protection  of  parts  of  the  EU  that  should  remain  free  from  harmful  organisms 
occurring  elsewhere  in  the  EU  (the  'protected  zones'  (PZ)).  To  this  end,  a 
document ('plant passport') was introduced to accompany plant material moved 
between  MS,  replacing  the  phytosanitary  certificate  foreseen  under  the  IPPC. 
The passports also have to be used for movements inside a MS. Official controls 
on  plant  passports  were  now  to  be  made  at  the  source  (operator  premises) 
instead of the border or destination and a registration obligation was established 
for operators handling regulated plant materials; 

−  An EU co-financing system was put in place in 1997 for the costs of control and 

20  The  PHR  however  regulates  far  higher  numbers  (thousands)  of  plants  and  harmful  organisms  and 
combinations of these and, other than for animal diseases, a world-level list of quarantine pests does 
not exist. The PHR has a wider impact as regards the environment but in principle does not relate to 
human  health.  The  timeframe  is  longer:  while  culled  animals  can  be  replaced,  felled  forests  may 
require  decades  to  recover.  The  economic  relevance  is  similar  (EU  crop  production  in  2009  €175 
billion, animal production €136 billion). 

21 Plants are defined as living plants and specified parts thereof (seeds, fruit, vegetables, cut flowers, etc.). 
Plant  products  are  defined  as  products  of  plant  origin,  unprocessed  or  having  undergone  simple 
preparation. 

7 

 
                                                 
eradication of harmful organism outbreaks (Council Directive 97/3/EC); 

−  The import regime was reinforced in 2002, on which occasion the scope of plant 
material  subject  to  import  controls  was  expanded,  a  system  for  reduced 
frequency  checks  was  created  as  well  as  an  obligation  to  levy  fees  for  import 
controls. 

The scope of the Plant Health Directive includes requirements concerning: 

− 

Import  and  intra-EU  movements  of  plant  material  and  harmful  organisms 
(including plant passports and protected zones); 

−  Surveillance, notification, eradication and containment of outbreaks (including a 

framework for emergency measures); 

−  Financial measures.  

The EU plant health regime is an open regime. Movements of plants and plant products 
into  and  within  the  EU  are  allowed  on  condition  that  specific  restrictions  or 
requirements  are  respected.  This  relates  to  import  (prohibitions  of  specific  high-risk 
plant  materials;  conditions  to  be  fulfilled  and  attested  on  the  phytosanitary  certificate 
for  others)  and  intra-EU  movements  (plant  passporting  requirements,  with  a  special 
variant for protected zones). The Plant Health Directive does not cover export22, other 
than setting out the format of the phytosanitary certificate (the IPPC format) that is to 
be used for export certification, which otherwise is the responsibility of the MS. 

As  concerns  the  harmful  organisms  covered,  the  Directive  in  its  Annexes  lists  the 
particularly  dangerous  harmful  organisms  against  which  official  measures  shall  be 
taken.  In  order  to  be  able  to  take  measures  against  outbreaks  of  new,  as  yet  unlisted 
harmful organisms, the scope of the Directive allows covering any harmful organism if 
justified by its potential socio-economic and environmental impacts. National measures 
concerning  non-listed  harmful  organisms  shall  be  notified  to  the  Commission  and  the 
other MS, justified by a Pest Risk Analysis (PRA) and subsequently harmonised at EU 
level  or  rescinded.  Measures  should  not  be  taken  against  harmful  organisms  of  minor 
importance  (no  justification  under  IPPC  and  SPS)  or  widespread  harmful  organisms 
where territorial protection is not relevant. The scope of the Plant Health Directive does 
not  include  the  official  control  of  widespread  harmful  organisms  (for  example  native 
pests and pathogens)23, which are to be managed by good agricultural practices such as 
crop diversification and rotation. 

At  its  update  on  the  occasion  of  the  creation  of  the  internal  market,  the  Plant  Health 
Directive was designed to focus on the movements of plants and plant products and the 
eradication or containment of outbreaks. The spread of harmful organisms other than by 
movement of consignments (natural spread) was explicitly excluded from any EU co-
financing, even though the mandatory eradication and containment of outbreaks would 
often require acting against follow-up outbreaks resulting from natural spread.  

The provisions in the Plant Health Directive impose obligations on the MS to transpose 
and implement the Directive and officially control compliance. The Directive imposes 
indirectly restrictions on private operators, subjects them to official controls for which 
fees  may  (plant  passport)  or  shall  (import)  be  levied  and  subjects  them  to  measures 

22 Data from surveillance under the PHR for regulated harmful organisms may however be used to clarify 

the EU pest status for those organisms.  

23 The regime does not include such harmful organisms even when operators take measures against them 
for export purposes to third countries where these pests and pathogens are prohibited from entry. 

8 

 
                                                 
upon  findings  of  regulated  harmful  organisms.  It  does  not  provide  incentives  for 
compliance. Private operators may however be authorised to issue plant passports under 
official  supervision,  and  private  laboratories  may  be  authorised  for  official  analyses 
under official supervision. 

2.1.4. The Control Directives for potato 

With  respect  to  four  specific,  internationally  recognised  regulated  pests  of  potato, 
Control  Directives  were  adopted,  two  of  which  antedate  the  Plant  Health  Directive. 
Control Directives for potato cyst nematodes and potato wart disease were adopted in 
1969,  followed  by  Control  Directives  for  potato  ring  rot  (1980)  and  potato  brown  rot 
(1998).  These  harmful  organisms  occur  in  several  MS  and  cannot  be  completely 
eradicated from the Union territory. The objective of the Control Directives is to control 
(contain)  the  presence  of  the  regulated  harmful  organisms  in  infested  fields,  thus 
mitigating  the  risk  of  further  spread  in  the  EU.  The  four  harmful  organisms  are  also 
listed in the Annexes of the Plant Health Directive. 

2.1.5. The Marketing Directives for plant reproductive material 

Plant  reproductive  material  is  the  cornerstone  for  agricultural  production.  Therefore, 
ensuring  the  availability  of  PRM  of  sufficient  quality  and  health  is  crucial  for  the 
production  of  food,  feed  and  other  agricultural  commodities.  The  PRM  legislation  is 
based on the registration of varieties and the certification of PRM lots. It consists of a 
horizontal  Council  Directive  on  the  Common  Catalogue  of  varieties  of  agricultural 
plant  species  and  11  vertical  Council  Directives  on  the  marketing  of  commodities  of 
seed and propagating material. About 200 harmful organisms are regulated which may 
be widespread in the EU, but impact on quality and can usually not be detected visually 
(market  failure).  Some  of  these  overlap  with  those  regulated  under  the  Plant  Health 
Directive  and  the  Control  Directives  for  potato.  Under  the  IPPC,  these  harmful 
organisms are called Regulated Non-Quarantine Pests. 

laboratory 

including  mandatory 

Plant  health  controls  are  part  of  the  certification  system  of  the  Marketing  Directives, 
which leads to issuance of a certification label which may be combined with the plant 
passport  issued  under  the  Plant  Health  Directive.  Certification  is  based  on  a  systems 
approach  consisting  of  field  inspections  during  the  season  and  inspections  on  lots 
prepared  for  marketing, 
testing.  Equivalence 
agreements  have  been  concluded  with  specific  third  countries,  under  specific 
certification  schemes,  in  which  case  no  systematic  import  controls  are  in  place.  In 
absence  of  equivalence,  the  import  into  the  EU  is  prohibited  or  temporarily  allowed 
under  specific  requirements.  For  the  implementation  of  those  Directives  that  foresee 
process  control,  like  in  the  Plant  Health  Directive,  private  operators  have  to  be 
registered and authorised. In some MS but not in others, the competent authorities for 
PRM  coincide  with  those  under  the  Plant  Health  Directive.  The  responsibilities  of 
operators  are  similar  to  in  the  PHR,  although  differences  exist  in  relation  to  the 
possibilities  for  official  delegation  of  tasks.  Laboratory  testing  of  seed  is  carried  out 
using  the  protocols  of  the  International  Seed  Testing  Association  (ISTA).  The  PRM 
regime  is  under  review,  including  improvement  of  the  coherence  with  the  PHR. 
Changes  in  arrangements  between  the  two  regimes  are  addressed  in  this  impact 
assessment. 

9 

 
2.1.6. Regulation (EC) No. 882/2004 on Official Controls 

Regulation  (EC)  No.  882/2004  provides  a  harmonised  framework  of  general  rules  for 
the official  controls performed to ensure the verification of compliance with  feed and 
food  law,  animal  health  and  animal  welfare  rules.  Certain  aspects  of  this  Regulation 
already  apply  to  the  plant  health  sector  and  in  particular  those  concerning  the 
establishment  of  multi-annual  control  plans  and  Union  inspections  in  MS  and  third 
countries.  A  recast  of  the  Regulation  is  being  developed  which  will  cover  fully  also 
PHR  and  PRM  controls.  The  horizontal  principles  of  the  amended  Regulation  will 
replace those in sectoral legislative acts. The present impact assessment addresses the 
changes  in  the  traditional  pillars  of  the  PHR,  also  if  specific  provisions  (for  example 
fees)  will  be  absorbed  by  that  Regulation.  This  is  essential  since  the  PHR  review 
concerns the functioning of the regime as a whole. 

2.1.7 The development of an EU Strategy on invasive alien species 

Invasive  alien  species  are  organisms  (animals,  plants,  microbes)  that  are  introduced 
accidentally  or  deliberately  into  the  EU  where  they  are  not  native.  They  represent  a 
serious threat to native plants and animals in Europe which needs to be addressed if the 
EU is to achieve its goal of halting the decline of biodiversity by 2020. IAS cause some 
EUR 12.5 billion worth of damage each year in the EU24. The Commission published a 
Communication25  "Towards  an  EU  Strategy  on  Invasive  Species"  in  December  2008 
and  noted  that  while  some  EU  instruments  exist  to  deal  with  other  drivers  of 
biodiversity loss, there is currently no comprehensive instrument at EU level to tackle 
IAS, although action has been taken at EU level to address certain aspects of this threat. 
The  European  Commission  adopted  its  EU  post-2010  biodiversity  strategy26  in  May 
2011,  including  a  target  dedicated  to  IAS:  "By  2020,  IAS  and  their  pathways  are 
identified and prioritised, priority species are controlled or eradicated, and pathways are 
managed to prevent the introduction and establishment of new IAS". Two actions have 
been  identified  to  support  this  target  (scheduled  for  2012):  (i)  to  integrate  additional 
biodiversity  concerns  into  the  plant  and  animal  health  regimes;  and  (ii)  to  fill  policy 
gaps  in  combating  IAS  by  developing  a  dedicated  legislative  instrument.  The  current 
review of the PHR aims to reinforce the Union's protection against invasive pests and 
pathogens, while where possible contributing to wider biodiversity goals. 

The future IAS legislation will not cover pests and pathogenic microbes of plants and 
animals, as these are covered already by the PHR and the EU animal health legislation, 
but  will  close  the  existing  legislative  gap  for  other  invasive  organisms  such  as 
introduced  grey  squirrels  and  tiger  mosquitos  (a  vector  of  dengue  and  other  human 
diseases).  Depending  on  the  outcome  of  the  review  of  the  PHR,  the  IAS  legislation 
would  or  would  not  also  cover  invasive  plants,  such  as  water  hyacinths  and  ragweed. 
Invasive plants differ from the harmful organisms regulated under the PHR in that they 
do not cause direct harm to plants, like pests and diseases do, but compete with other 
plants  for  nutrients  and  space.  Invasive  plants  may  affect  not  only  terrestrial  but  also 
aquatic  and  marine  ecosystems,  which  are  presently  not  dealt  with  by  the  PHR.  Both 
the  harmful  organisms  currently  regulated  by  the  PHR  and  invasive  plants  require 
import  prohibitions  and  restrictions  to  protect  the  EU  territory.  However,  the  strict 
eradication  measures  of  the  PHR  ("stamping  out")  may  not  be  suitable  for  invasive 
plants in natural habitats, where management by suppression may be more appropriate. 

24 European Commission, Our life insurance, our natural capital: an EU biodiversity strategy to 2020. 
25 http://ec.europa.eu/environment/nature/invasivealien/docs/1_EN_ACT_part1_v6.pdf 
26 http://ec.europa.eu/environment/nature/biodiversity/comm2006/pdf/2020/1_EN_ACT_part1_v7%5b1%5d.pdf  

10 

 
                                                 
Also,  restricted  local  release  of  invasive  plants  may  be  justified  in  certain  cases  (for 
example  gardening)  while  the  release  of  regulated  pests  and  pathogenic  microbes 
should be fully prohibited. There are pros and cons for including invasive plants in the 
future PHR. 

2.2. Problem identification 

Since  its  creation  in  1977,  the  PHR  successfully  protected  the  EU  against  the 
introduction and spread of many pests (e.g. potato and citrus pests). The situation has 
however changed due to the on-going globalisation of trade, resulting in ever increasing 
imports from new parts of the world. This has led to a sharply increased influx of new 
harmful organisms, especially in the last decade. Europe increasingly fails to stop that 
influx where North America succeeds relatively well (see graph below)27. The problems 
are being exacerbated by climate change, which allows new pests to establish and thrive 
that  previously  did  not  survive  in  the  EU  as  well  as  higher  vulnerability  of  EU  crops 
and forests to alien pests (e.g. Robinet et al., 2011). The EU is thus confronted with an 
increased  risk  of  entry  of  pests,  increased  opportunities  for  their  establishment  and 
spread,  and  increased  vulnerability  of  agricultural  and  natural  ecosystems  (including 
forests).  The  enlargement  of  the  EU  has  moreover  resulted  in  a  wider  diversity  of 
climates,  agricultural  cropping  systems,  forest  types,  landscapes  and  natural  habitats, 
often  differing  in  sensitivity  or  resilience  to  harmful  organisms  which  leads  to  even 
more significant and wider impacts at EU level. Indeed, globalisation of trade, climate 
change and evolutionary adaptation of harmful organisms to new host plants are being 
considered  major  drivers  of  the  increasing  problems  with  plant  pests  and  diseases 
(Waage et al., 2007). 

Temporal changes in new records per year in Europe of alien invertebrates. (a) Total number of alien 
invertebrates.  (b)  Total  number  of  alien  insects  associated  with  woody  plants  in  Europe  compared  to 
North  America.  Source:  A.  Roques,  Invasive  patterns  of  alien  terrestrial  invertebrates  in  Europe  (in: 
Pimentel, 2011). 

27  It  should  however  be  noted  that  the  US  does  not  have  an  equally  open  regime  for  plant  material 
imports. While a closed system indeed offers more effective protection than the EU open system, a 
transformation of the PHR to a closed system would cause unacceptable damage to the EU economy. 
This  underlines  the  importance  of  the  measures  proposed  in  the  current  revision,  which  will 
strengthen the PHR while maintaining its open character. 

11 

 
 
                                                 
Major  outbreaks  in  the  past  decade  of  dangerous  import-related  harmful  organisms 
affecting  forestry  (e.g.  pine  wood  nematode,  citrus  longhorn  beetle,  red  palm  weevil) 
have  raised  societal  and  political  awareness  of  the  costs  and  impacts  of  inadequate 
protection. The evaluation of the PHR (2010) has shown that the regime has to adapt in 
order to be able to fully address these increased risks and recommends to modernise it 
through  more  focus  on  prevention,  better  risk  targeting  (prioritisation)  and  more 
solidarity (moving from a MS based to EU approach for joint action to tackle risks of 
EU  significance).  A  mismatch  between  currently  available  resources  and  targeted 
objectives is reported to underpin many of the identified shortcomings and weaknesses. 
The  need  is  underlined  for  a  reinforced  financial  instrumentation  to  ensure  better 
preparedness in case of emergency. 

The  main  problems  identified  relate  to  insufficient  focus  on  prevention  in  relation  to 
increased imports of high-risk commodities, the need for prioritising harmful organisms 
at  EU  level  across  all  27  MS,  the  need  for  better  instruments  for  controlling  the 
presence and natural spread of pests in case they eventually reach the Union territory, 
and  a  need  for  modernising  and  upgrading  the  instruments  concerning  intra-EU 
movements  (plant  passports  and  protected  zones),  and  a  need  to  foresee  additional 
resources.  The  science  base  of  the  regime  (research,  laboratories)  also  needs  to  be 
reinforced.  These  problems  should  be  addressed  to  reinforce  the  positive  cost-benefit 
balance  of  the  current  regime  in  the  long  term.  Failure  of  regulatory  action  against 
outbreaks would undermine the credibility of those actions, discourage investments in 
the regime and stimulate MS to give priority to short-term national interests above EU 
priorities (vicious circle). This would damage the EU economy as a whole. 

Pine wood nematode 

The  pine  wood  nematode  (PWN),  Bursaphelenchus  xylophilus,  is  a  serious  pest  of 
conifers,  vectored  by  bark  beetles.  It  is  native  to  north  America,  where  it  does  little 
harm to pine trees (co-evolution). It spread to southeast Asia in the early 20th century 
where it caused mass mortality of forests in Japan, China, Korea and Taiwan. Its main 
spread to new areas is with infested wood. To offer protection against wood-vectored 
pests, the IPPC developed the International Standard for Phytosanitary Measures No. 
15 concerning appropriate treatment of wood packaging material. 

An outbreak in Portugal in 1999 led to EU emergency measures for PWN eradication. 
Despite  these,  PWN  spread  within  Portugal,  the  continental  part  of  which  is  now 
considered infested as well as Madeira. Three outbreaks occurred in Spain which are 
being  eradicated  with  large-scale  felling  (in  a  radius  of  500-3000  m  around  the 
infested trees), monitoring and testing. The area at risk in the EU is 13 mio hectares of 
coniferous forest in southern Europe where 50-90% mortality is predicted (valued at 
EUR  39-EUR  49  billion)  (FCEC,  2011).  Spread  of  PWN  would  additionally  impact 
on central European forests and on exports from Scandinavian forests. 

12 

 
 
Red palm weevil 

The red palm weevil, Rhynchophorus ferrugineus, is an extremely damaging pest of a 
wide  range  of  productive  and  ornamental  palm  trees.  The  pest  reached  the  EU  with 
infested  planting  material  from  third  countries.  Red  palm  weevil  has  spread  across 
most of the Mediterranean where it has killed thousands of palms. The impact of the 
pest in the EU is estimated to have reached at least EUR 50 mio in containment and 
eradication  costs  for  the  MS  competent  authorities  alone  and  to  have  involved  the 
destruction of at least 65,000 trees, which is only a fraction of those infested. On the 
basis of the destroyed palms alone, the value of the trees lost is estimated at EUR 65-
EUR  195  mio,  on  the  basis  of  the  infested  palms,  EUR  96-EUR  288  mio  (FCEC, 
2011). The red palm weevil threatens the survival of three endemic, endangered palm 
species in Europe: Phoenix theophrasti in Crete, P. canariensis in the Canary Islands, 
and Chamaerops humilis in the western Mediterranean region. 

2.2.1. Insufficient focus on prevention in relation to imported high-risk organisms 

The  evaluation  has  shown  that  the  instrumentation  of  the  regime  has  shortcomings  as 
concerns prevention of the entry, establishment and spread of import-related high-risk 
organisms.  The  Plant  Health  Directive  in  its  current  form  addresses  risks  related  to 
imports  from  third  countries  by  prohibitions  of  the  import  of  some  plant  species  and 
specific requirements for numerous other plants and plant products. Detailed rules exist 
on  official  import  controls.  The  instrumentation  for  the  follow-up,  including 
surveillance,  contingency  planning,  rapid  outbreak  eradication  and  containment,  is 
weak  should  a  harmful  organism  have  gone  unnoticed  during  import  inspection.  It 
consists mainly of the obligation to notify outbreaks and take the necessary measures, 
along  with  a  possibility  to  adopt  national  and  EU  emergency  measures.  No  general 
surveillance obligation exist. The evaluation report recommends introducing mandatory 
general epidemio-surveillance at EU level for priority HOs and co-financing to improve 
surveillance.  EU  co-financing  is  currently  limited  to  costs  for  eradication  and 
containment.  For  many  years  the  EU  budget  was  EUR  1  million  per  year;  for  2011 
EUR  12  million  was  allocated28.  So  far,  the  EU  has  not  co-financed  losses  of  private 
operators  for  destroyed  plant  material  following  official  measures  (contrary  to  the 
policy for culled animals under the EU animal health regime29). This is a disincentive 

28 The budget sharply increased in recent years due to measures necessary to eradicate and contain pine 
wood  nematode  outbreaks  in  Portugal  and  Spain  as  well  as  outbreaks  of  the  red  palm  weevil  and 
longhorned beetles. 

29  The  annual  EU  budget  under  the  EU  animal  health  regime  for  compensating  farmers  for  losses  of 
culled animals varies from €10 million to, in exceptional cases, almost € 1 billion. The objective is to 
allow  MS  to  provide  swift  and  adequate  compensation  of  the  livestock  farmers  for  the  costs  of 
slaughter  and  destruction  of  animals  and  animal  products,  contaminated  feed  and  equipment, 
cleaning  and  disinfection.  Consequential  losses  from  marketing  and  movement  restrictions  are  not 
compensated but can be insured, with EU co-financing through the Common Agriculture Policy. 

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
 
for  growers  to  notify  outbreaks  of  regulated  harmful  organisms  and  comply  with  the 
measures,  while  eradication  measures  need  to  be  taken  in  the  very  early  phase  of 
invasions when infestations are still small (Pluess et al., 2012). 

Costs of late detection of outbreaks due to lack of surveillance 

Pine wood nematode was detected in 1999 in Portugal in the Setubal peninsula. At the 
time of detection, > 500 000 hectare of forest proved already infested (the PHR does 
not  oblige  MS  to  carry  out  systematic  surveys  for  new  harmful  organisms).  Up  to 
2011,  the  Union  granted  EUR  >  38  million  to  eradicate  the  pest  in  Portugal. 
Eventually, eradication proved impossible and the pest is now under containment.  

Three  isolated  PWN  outbreaks  subsequently  occurred  in  Spain,  close  to  Portugal. 
They were immediately identified and successfully eradicated by large-scale felling of 
forest. This was achieved with a Union support, up to 2011, of below EUR 5 million. 

Successful eradication of the citrus longhorned beetle 

The  longhorned  beetles,  Anoplophora  chinensis  (citrus  longhorned  beetle)  and  A. 
glabripennis  (Asiatic  longhorned  beetle),  affect  a  wide  range  of  deciduous  (broad-
leaved)  tree  species.  Pest  risk  analysis  has  shown  that  the  potential  economic  and 
environmental impact of both CLB and ALB is high to massive. In their home range, 
these  beetles  have  caused  the  death  of  millions  of  trees.  Outbreaks  of  longhorned 
beetles in the EU have been related to the import of infested live woody plants.  

The citrus longhorned beetle was detected in Boskoop (Netherlands), a leading area of 
European nursery stock production in December 2009. This concerned two larvae and 
one exit hole in a Carpinus tree in a hedgerow of a nursery in the town centre, linked 
to ornamental trees imported from Asia. Thanks to a massive intervention in a radius 
of 2 km surrounding the finding, confirmation of pest eradication was ascertained by 
the end July 2010. This required clear-cuts of all susceptible host plants in a radius of 
100  m  from  the  infested  tree,  systematic  monitoring  of  all  private  and  public  green 
and large-scale destructive sampling of nursery stock in the buffer zone.  The clear-
cut  included  removal  of  plants  and  roots  of  at  least  316  trees,  809  square  meters  of 
hedge, 241 large shrubs (1.5 m or higher) and 1291 small shrubs (smaller than 1.5 m) 
as  part  of  public  and  private  green.  Examination  of  each  plant  did  not  result  in  any 
further signs of the pest. In the nurseries in the 2 km buffer zone in total 85,000 plants 
were  cut  and  inspected  for  the  presence  of  larvae  of  the  citrus  longhorned  beetle 
inside  the  stem,  not  resulting  in  any  findings  of  the  harmful  organism.    The  Union 
granted EUR 1,08 million to co-finance the costs of the measures. 

14 

 
 
 
 
 
 
 
 
 
 
 
Horizon  scanning  for  emerging  risks  is  not  specifically  addressed  in  the  regime. 
Problems  exist  with  high-risk  trade  from  third  countries,  in  particular  plants  for 
planting.  Many  major  outbreaks  of  the  last  decade  stemmed  from  imports  of  such 
material,  carrying  latent  pests  and  diseases  which  could  not  be  detected  at  import  but 
only  after  considerable  time,  when  the  organisms  had  spread  and  eradication  had 
become  very  difficult.  Furthermore,  passenger  luggage,  currently  exempted  from  the 
import  prohibitions  and  restrictions  and  border  controls,  has  shown  to  be  a  source  of 
influx of prohibited regulated harmful organisms30. 

Third countries with the largest number of interceptions in trade to the EU, 2005-2011 (Source: FVO). 

Numbers  of  interceptions  by  Member  States  concerning  the  presence  of  harmful  organisms  in 
commodities imported from third countries, 2011 (Source: FVO). 

30 The introduction of small quantities of plants for gardening, potentially infested with dangerous pests, 
can  start  unnoticed  epidemics.  For  example,  orchids  with  regulated  pests  from  Thailand  are  being 
found by Member States. All major countries worldwide (e.g. US, Japan, Australia, New Zealand) 
regulate plant material in passenger luggage. 

15 

 
 
 
                                                 
2.2.2. Need to focus on harmful organisms of EU priority 

The  evaluation  has  shown  that  the  PHR  does  not  adequately  allocate  the  available 
resources to the major EU risks. The Plant Health Directive classifies the 250 regulated 
harmful  organisms  in  two  Annexes  divided  into  Parts  and  Sections  in  relation  to  the 
plant material covered and presence in the EU, without prioritising them according to 
risk  or  impact.  In  practice,  MS  allocate  resources  as  they  see  appropriate  and  priority 
may  be  given  to  national  interests31  above  EU  priorities.  Harmonisation  can  be 
promoted  through  EU  emergency  measures,  which  have  been  put  in  place  for  11 
organisms,  or  through  Control  Directives  which  only  exist  for  harmful  organisms  of 
potato32. This may however be at the expense of preventive actions against organisms 
that may be equally dangerous but have not yet led to outbreaks.  

While the PHR needs a mechanism to ensure that priority is given to the interests of the 
Union  as  a  whole,  it  also  needs  a  flexible  system  for  risk-based  de-prioritisation. 
Organisms  regulated  under  the  PHR  may  become  established  and  spread  to  an  extent 
that  territorial  protection  is  no  longer  justified.  In  such  cases  amending  their  status  to 
quality  pests  under  the  PRM  regime  or  de-listing  may  be  appropriate.  This  rarely 
happens. The Commission in 1991 listed 24 organisms as candidates for transfer from 
the Plant Health Directive to the Marketing Directives, of which by 2011 only one had 
been deregulated33. A major obstacle is the coverage of harmful organisms under two 
EU  regimes,  with  separate  Competent  Authorities  at  MS  level  and  separate  Standing 
Committees  at  EU  level.  De-listing  in  the  Plant  Health  Directive  simultaneously  with 
inclusion  in  the  Annexes  of  the  Marketing  Directives  requires  two  Commission 
Decisions.  The  lack  of  a  common  policy  on  harmful  organisms  and  joint  decision 
making has resulted in a lack of timely status change and double listing of organisms. 

2.2.3. Need for better instruments for controlling presence and natural spread of pests 

If  a  listed  harmful  organism  is  detected  in  a  part  of  MS  territory  in  which  it  was 
unknown,  the  MS  shall  take  all  necessary  measures  to  eradicate  the  pest  or,  if  that  is 
impossible,  inhibit  its  spread.  Measures  taken  concerning  outbreaks  originating  from 
natural  spread  are  however  not  eligible  for  EU  co-financing.  The  emphasis  on 
movements of host plants rather than natural spread of pests reflects the history of the 
regime, which was shaped to protect agriculture and horticulture while at the same time 
supporting the creation of the internal EU market. Natural spread of harmful organisms 
in relation to eradication can temporarily be addressed in EU emergency measures by 
Commission Decisions. Control measures to permanently contain regulated organisms 
that could not be eradicated have to be laid down in Council Directives, which requires 
considerable time, disproportionate to the urgency of the matter. 

Natural  spread  can  in  practice  not  be  separated  unambiguously  from  spread  with 
movements (e.g. hitch-hiking insects in an airplane or truck not carrying plant material). 
Excluding  natural  spread  from  EU  co-financing  is  a  disincentive  to  action  by  the 
competent authorities and has undermined the success of eradication and containment 
measures34. Where forests and the landscape are affected, natural spread is often even 

31 For example: surveillance and controls for organisms relevant to national production; maintenance of 

protected zones to support the export position of national growers.  

32 Outdated Control Directives exist for carnation leaf-roller and San José scale but will be repealed. 
33 In the same period, 16 new organisms were added to the Annexes of the Plant Health Directive. 
34  An  example  is  the  Emergency  Decision  for  the  Western  Corn  Rootworm,  Diabrotica  virgifera,  in 
maize. The lack of EU co-financing for outbreaks outside the Buffer Zone if due to natural spread 

16 

 
                                                 
the key factor which cannot be excluded. The interests of society have moved from a 
private to a public good emphasis: the protection of the natural environment, landscape 
and public and private green (the concepts of "greening" and "ecosystem services"). 

2.2.4.  Need  to  modernise  and  upgrade  the  instruments  of  the  intra-EU  movements 
regime 

The  evaluation  expresses  concern  about  the  credibility  of  the  plant  passport  and 
protected  zone  systems.  These  were  at  the  core  of  the  1993  review  and  created  to 
balance  free  trade  (movement)  of  plants  and  plant  products  within  the  EU  with 
protection  of  certain  pest-free  zones  in  the  EU  against  spread  of  pests  with  such 
commodities  coming  from  other  MS.  Plant  passports  were  created  to  replace 
phytosanitary  certificates,  previously  issued  by  the  Member  States,  for  intra-EU  trade 
on the single internal market. Protected zones were created to accommodate the unequal 
presence  of  certain  harmful  organisms  across  the  EU  (regionalisation).  Plant  material 
moved into a protected zone requires a specific "Zona Protecta" plant passport linked to 
enhanced  phytosanitary  safeguards.  Enterprises  within  protected  zones  have 
competitive advantages over operators outside those zones, which have to meet higher 
standards  to  send  plant  material  to  the  protected  zones,  and  they  have  competitive 
advantages for export to third countries as they can attest that their material originates 
in a pest-free area.  

The problems with the plant passport relate to its limited scope, lack of harmonisation 
of  its  format,  ambiguity  in  its  use  as  a  traceability  tool  and  overlap  in  use  with  the 
certification  label  of  the  PRM  regime.  Operators  ask  for  more  room  for  self-controls 
and  issuance  of  the  label  under  official  supervision  and  for  full  responsibility  for 
ensuring  traceability  of  lots  (rather  than  including  such  information  on  the  plant 
passport). This would allow them to save costs. They perceive the role of private sector 
in the PHR in relation to the plant passport as more restrictive than for the certification 
label of the PRM regime. Unnecessary burden stems from coherence problems between 
these  regimes,  e.g.  the  positioning  of  harmful  organisms  in  two  regimes,  one  for 
territorial  protection  and  one  for  ensuring  quality,  legally  prohibits  the  inclusion  of 
territorially regulated pests in the EU certification schemes for quality pests, while this 
would  enhance  effectiveness  and  reduce  burden.  Finally,  unequal  implementation 
between MS (fees, room for self-control) distorts the level playing field.  

Several  problems  with  the  protected  zones  are  due  to  MS  failure  to  apply  the  legal 
measures and not flaws in the concept per se. There is evidence of failure to carry out 
surveillance  and  report  the  results  and  failures  in  the  implementation  of  the  PZ  plant 
passport system. This is possible because the wording of the obligations is too general 
and  does  not  fix  how  to  manage  outbreaks.  The  status  of  protected  zones  is  thus 
regularly  maintained  despite  multiple  outbreaks,  counter  to  the  aim  of  the  legislation. 
The  zones  are  in  such  cases  perceived  by  the  private  sector  as  a  distortion  of 
competition35.  

(flight) of the beetle prompted MS to stepwise move the Buffer Zone to include the new outbreaks. 
Refraining from drastic outbreak measures saved the affected farmers' income but the Buffer Zone 
steadily moved westwards across Europe. This has considerably reduced the benefits of the measures 
(the costs of non-action are €475 million per year; Wesseler & Fall, 2010). Problems also exist with 
the unbalance of costs (on MS with outbreaks) and benefits (for MS that are free from the pest), for 
which insufficient EU compensation is possible.  

35 According to the evaluation, the general perception is that protected zones were not designated only on 

technical grounds but that significant commercial/political considerations are also present. 

17 

 
                                                                                                                                               
Number of interceptions of harmful organisms in trade between Member States (EUROPHYT)36. 

2.2.5. Erosion of the science base of the regime 

The  PHR  was  developed  in  decades  where  adequate  support  from  R&D  and 
laboratories  was  available,  while  since  then  severe  erosion  has  taken  place  of  the 
science base for the regime. A major shift has occurred in the academia from classical 
biological disciplines (plant pathology, taxonomy) to molecular-biological sciences and 
biotechnology.  Molecular  diagnostics  however  cannot  replace  classical  diagnostic 
expertise  but  are  supplementary.  The  erosion  of  the  science  base  of  the  PHR  creates 
risks as concerns the continuity of the regime in terms of the technical justification of 
legal provisions37 and measures and rapid and reliable diagnosis. A solid legal base for 
official plant health laboratories, as provided by Regulation (EC) 882/2004, is lacking. 
The need for scientific support for policy development and for diagnostic laboratories 
via  the  establishment  of  EU  reference  laboratories  for  plant  health  will  be  addressed 
under the review of Regulation 882/2004 and via the Horizon 2020 programme. 

2.2.6. Lack of resources for the regime 

The initial absence of co-financing from the regime reflects its supposed private good 
nature, assuming that measures against harmful organisms would be good agricultural 
practice and costs from such measures should therefore be considered a risk inherent to 
entrepreneurship. The initial private good nature of the EU plant health regime links to 
a  low  level  of  public  awareness  and  a  low  political  profile.  This  is  reflected  in  a  low 
level  of  resources  and  cuts  in  staff  and  budget  of  MS  competent  authorities.  The 
outbreaks in forests and public and private green in the past decade have highlighted the 
public  good  aspects  and  demonstrated  the  political  need  for  public  (EU)  financial 
compensation. Although the EU budget available to the regime has increased from EUR 

36  No  figures  are  available  in  EUROPHYT  concerning  notifications  relative  to  MS  intra-EU  trade 
volumes,  which  strongly  influence  the  absolute  numbers  of  notifications  shown  in  this  graph.  For 
example, the exceptionally large share of The Netherlands in import, intra-EU movement and export 
influences the total number of outbreaks. 

37 EFSA set up a Panel on Plant Health in 2006 to provide in scientific opinions concerning plant health 

risks. The Panel draws on the expertise available in the field in Europe.  

18 

 
 
                                                 
1  mio  to  EUR  12  mio  (for  2011),  the  level  available  is  too  low  to  cover  the  needs. 
Budget  is  lacking  altogether  for  co-financing  of  mandatory  EU  surveillance  and 
operator losses from destruction measures. In essence, the lack of resources is due to a 
lack  of  awareness  of  the  benefits  of  short-term  actions  to  safeguard  the  long-term 
interests of the Union (lack of recognised justification of the regime) and market failure 
(public goods, externalities, information asymmetry). 

2.2.7. Inconsistent implementation of the regime 

Implementation of the regime has been hampered by a lack of appropriate instruments 
and  resources,  resulting  in  failure  of  actions  concerning  outbreaks.  MS  may  give 
priority to short-term national interests above EU priorities, taking the advantages and 
opportunities for specific harmful organisms relevant to them (e.g. protected zones) and 
avoiding  the  disadvantages  and  costs  of  action  (e.g.  surveillance  and  eradication 
measures)  for  others  which  are  not  directly  relevant  to  them.  This  hampers  the 
effectiveness,  reliability  and  credibility  of  the  regime  and  the  level  playing  field  (the 
unequal levying of fees being a special case, in particular for plant passports where no 
fee  obligation  exists  as  yet).  The  current  Directive  contains  minimal  obligations 
concerning eradication of outbreaks and none on surveys, other than for the recognition 
of protected zones or in the case of emergency measures. On its own, enforcement by 
the Commission of the implementation by the Member States of the Directive, through 
infraction  procedures,  will  not  address  the  fundamental  problems  of  the  regime. 
Financial incentives need to be introduced to stimulate growers to notify outbreaks and 
to  stimulate  Member  States  to  impose  the  necessary  eradication  measures.  Unnoticed 
outbreaks and inadequate measures will allow pests to become established and spread 
to an extent where eradication is either no longer feasible or extremely expensive. 

2.2.8. Need for a framework to regulate invasive alien species 

The economic and environmental impacts of IAS are increasingly apparent. Especially 
the import of new IAS is of concern to the EU. The Commission has announced that a 
dedicated EU legislative instrument which could tackle outstanding challenges relating 
inter  alia  to  IAS  pathways,  early  detection  and  response  and  containment  and 
management of IAS will be developed. IAS plant species, although part of the scope of 
the  IPPC  to  the  extent  that  they  are  terrestrial  plants,  are  not  addressed  in  the  Plant 
Health  Directive  (parasitic  plants  excepted).  It  should  be  investigated  in  how  far  IAS 
could  be  included  in  the  scope  of  the  plant  and  animal  health  regimes  in  order  to 
optimise  the  use  of  resources  and  infrastructures,  while  avoiding  duplication  of 
requirements under the future general invasive alien species legislation. 

2.3. Related issues 

2.3.1. Need for modernised governance 

The expectations of society as concerns governance have changed. The current regime 
defines obligations to stakeholders, obliges them to pay fees for the mandatory controls, 
but  involves  them  only  to  a  limited  extent  in  the  policy  development  and 
implementation. This is no longer seen as appropriate; a new balance needs to be struck 
as concerns costs and responsibility sharing (partnership development). In this respect, 
it  should  be  noted  that  the  Commission  proposals  for  the  CAP  2014-2020  facilitate 
explicitly  the  use  of  insurances  and  mutual  funds  to  cover  losses  from  outbreaks  of 
plant pests as well as losses resulting from eradication measures pursuant to Directive 
2000/29/EC. 

19 

 
With the Better Regulation (SMART) agenda, and exacerbated by the current financial 
crisis, there is a strong need to reduce unnecessary costs and administrative burden. A 
modernisation need furthermore exists in terms of incentives. 

2.3.2. Changed emphasis on public good 

When  the  regime  was  created,  agricultural  productivity  and  food  security  were  the 
global  objectives  of  the  Common  Agricultural  Policy  (CAP)  of  the  EU.  A  need  for 
"greening" of the CAP has emerged and objectives relating to the natural environment 
and  landscape  have  gained  importance.  This  impacts  on  the  intervention  logic  of  the 
PHR  which  is  moving  from  a  private  good  regime  for  agriculture  to  a  mixed 
public/private good regime for agriculture, forestry, natural environment and landscape. 
The  assumptions  and  modalities  for  the  financing  of  the  regime  are  equally  impacted 
(from  private  insurances  and  mutual  funds  only  to  mixed  public/private  funding 
reflecting responsibilities and objectives). In the near future, the PHR will however no 
longer be linked financially to the CAP38, except for access to the crisis reserve. 

2.3.3. Damage incurred by the regime in the past decade 

The eroding benefits of the regime and the decline of resources have partly undermined 
the  credibility  of  the  regime,  accelerated  the  erosion  of  the  regime's  science  base  (in 
itself an autonomous evolution) and allowed an increasing backlog in the organisational 
arrangements, capacities and quality assurance systems of plant health laboratories. 

2.3.4. Overly complex legislation 

The current text of the Plant Health Directive, the product of 34 years of amendments to 
the text of 1977, is highly complex and needs simplification. Missions of the Food and 
Veterinary  Office  of  the  Commission  have  shown  that  misunderstandings  and 
differences in interpretation of the Directive are an important cause of non-compliances 
and, therefore, failure to achieve the objectives of the regime. 

2.4. Parties affected 

the  private  sector  (farmers/growers/traders 

The  regime  affects 
in  agriculture, 
horticulture, forestry), which is subject to obligations, prohibitions, restrictions, official 
controls  for  which  fees  are  levied  and,  in  case  of  findings  or  outbreaks,  official 
measures. The costs of the regime impact on the profitability of the sector. The impact 
is  small  to  sectors  with  a  high  profit  margin  (such  as  the  seed  industry)  but  more 
substantial to sectors with low profit margins (such as importers of fruit and vegetables 
and  bulk  commodities).While  the  private  sector  as  a  whole  benefits  from  the  regime, 
the economic impacts of measures on individual operators in case of an outbreak may 
be negative (up to bankruptcies).  

The regime affects landscape managers, citizens, environmental NGOs and other parties 
interested  in  the  conservation  of  the  natural  environment,  landscape  and  public  and 
private  green.  The  impacts  of  non-action  for  these  public  goods  can  be  considerable, 
including  the  disruption  of  ecosystems  and  disappearance  of  forest  and  street  tree 

38 Historically, the PHR expenditures have been financed through the CAP under Heading 2 of the Multi-
annual  Financial  Framework  (MFF).  As  of  2014,  the  PHR  will  be  part  of  the  Food  Safety 
programme of the MFF under Heading 3, without any remaining link to the CAP. 

20 

 
                                                 
species.  The  impacts  of  eradication  and  containment  measures  to  prevent  that  from 
happening may, on a local scale, be dramatic and costly for the owners.  

The regime affects citizens in case of eradication measures in case of outbreaks in so far 
as  the  measures  also  concerns  private  gardens.  As  small  quantities  of  plant  material 
intended for non-commercial use by the owner in passenger luggage are exempted from 
the provisions, travellers are at present not impacted by the regime. 

Regulated harmful organisms of trees may be spread with wood. The regime therefore 
regulates  wood  and  wood  packaging  material  used  in  shipment  and  transport  of 
commodities. This impacts on the wood industries, wood packaging material industries, 
logistics industries and industry and trade at large.  

Traders and growers in third countries are affected in that they have to comply with the 
EU  provisions  and  pay  for  export  controls  and  issuance  of  phytosanitary  certificates. 
The competent authorities in third countries are affected because they have to perform 
these controls prior to export to the EU. 

The  competent  authorities  of  Member  States  are  affected  as  they  shave  to  ensure 
infrastructural and staff resources for surveillance, official controls, official laboratory 
analyses,  registration,  authorisation  and  supervision  of  operators,  training  of  staff  and 
research and development. 

2.5. How would the problem evolve if no action was taken? 

The  increasing  influx39  of  new  harmful  organisms  would  cause  new  epidemics  in  EU 
agriculture  and  forestry.  The  resulting  losses  would  affect  the  economic  viability  of 
agriculture  and  forestry  and,  at  longer  term,  the  rural  environment,  undermining  food 
security  and  damaging  the  landscape  and  natural  environment.  Eradication  and 
containment would continue to fail due to lack of resources and erosion of confidence 
in the regime. There would be growing opposition from private sector to carry the costs 
of  the  regime,  given  its  lack  of  effectiveness  and  the  limited  sharing  of  costs  and 
responsibilities between competent authorities and operators. As a consequence of on-
going outbreaks and spread of dangerous harmful organisms, exports of EU plants and 
plant products to third countries would decline due to recurrent trade bans. The negative 
financial impact could range up to billions of Euros per year (FCEC, 2011). 

Further  to  the  text  boxes  provided,  cases  of  damaging  outbreaks  in  agriculture  and 
forestry  in  Europe  and  on  other  continents  are  provided  in  Annex  VII.  The  no-action 
scenario is further elaborated in Annex VIII. 

2.6. Does the EU have the right to act (subsidiarity)? 

2.6.1. Right of the EU to act 

The Plant Health Directive and the Control Directives were based on Article 37 of the 
EC  Treaty,  now  Article  43  of  the  Treaty  on  the  Functioning  of  the  European  Union, 
implementing  the  Common  Agricultural  Policy.  The  objectives  of  that  policy  are  to 
increase agricultural productivity, to ensure a fair standard of living for the agricultural 

39 In their Strategic Plan, the US phytosanitary authorities (APHIS-PPQ, 2011) similarly note that "over 
the  past  five  years  introductions  of  plant  pests  and  diseases  are  occurring  with  increasing 
frequency"). 

21 

 
                                                 
Agricultural losses from plant pests 

Losses from harmful organisms have been estimated to be attributable for 30% to new 
pests  and  diseases  (Pimentel,  2005),  although  poor  agricultural  practices  may  be 
responsible  to  a  larger  extent  in  less  developed  countries.  On  a  global  scale,  losses 
would be 50–80% in the absence of control measures such as resistant cultivars, crop 
protection chemicals and crop rotations.  

Even  today,  ca.  40%  of  staple  cereal  crops  are  lost  to  pests,  diseases  and  weeds 
worldwide,  equivalent  to  approximately  a  billion  tonnes.  Kenis  &  Branco  (2010;  as 
quoted  by  Pimentel,  2011)  estimate  annual  economic  losses  for  the  EU  of 
approximately  €10  billion  caused  by  already  introduced  alien  insects,  not  including 
control,  eradication,  or  quarantine  costs,  nor  costs  linked  to  foreign  trade  or  market 
aspects.  This  does  not  yet  consider  similar  costs  due  to  introduced  viruses,  bacteria, 
fungi and nematodes, which add up to a multiple of that figure. 

The FAO (2006) forecasts that global food production will need to increase by 40% 
by  2030  and  70%  by  2050  because  of  increasing  demand  due  to  population  growth 
and  changing  diets,  while  crop  losses  caused  by  pests  have  not  decreased  since  the 
1960s, if anything they have increased (Bruce, 2010). 

Examples of damaging plant pests in agriculture 

Diabrotica  virgifera  virgifera  (Western  corn  rootworm):  the  "billion  dollar  bug" 
causes  US  $1  billion  losses  annually  in  the  United  States  and  induces  the  highest 
insecticide use in the world. 

Ralstonia solanacearum (potato brown rot): the bacterium causes up to 75% losses 
in the tropics and up to 40% in northern Europe, threatening an EU production value 
of about EUR 9 million. 

Xanthomonas  axonopodis  pv.  citri  (citrus  canker):  following  its  introduction  into 
Florida,  the  US  authorities  have  spent  EUR  800  million  in  their  fight  against  the 
bacterium. The production value of citrus in the EU, where the pest could cause huge 
damage, is about EUR 3.9 billion. 

Examples of damaging plant pests in forestry 

The impact of new pests and pathogens on forests could be disastrous. Some common 
tree species might disappear, as happened before to other once common tree species. 

Invasions  from  China  of  the  so-called  Dutch  elm  disease,  caused  by  a  fungus 
(Ophiostoma ulmi) that was foreign to Europe, have wiped out most of Europe's and 
America's  elms  while  elms  used  to  be  as  common  as  poplars  are  today  (Brasier  & 
Buck, 2011).  

The  once  widespread  chestnut  forests  in  the  US  have  disappeared  due  to  the 
introduction of the chestnut blight fungus (Cryphonectria parasitica). 

Mortality  of  western  Canada's  pine  forests  due  to  the  mountain  pine  beetle 
(Dendroctonus ponderosae) outbreaks currently approaches 80% and reversed these 
vast forests from carbon sink to carbon source. Scandinavian pine forests are still free 
from the pest but are equally susceptible (FCEC, 2011). 

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
community, to stabilise markets, to assure the availability of supplies and to ensure that 
supplies reach consumers at reasonable prices. In the framework of the current review, 
it  is  considered  to  widen  the  legal  basis  to  also  include  TFEU  Articles  114  (internal 
market) and 191 (environment). 

2.6.2. Necessity for the EU to act 

Regulating plant health at EU level allows for coordinated and in the long run cheaper 
action  on  EU  priorities,  making  it  more  effective  and  less  expensive  than  actions  by 
individual  MS.  For  example,  border  controls  for  differing  national  lists  of  harmful 
organisms  would  be  highly  inefficient  and  ineffective,  given  the  free  movement  of 
commodities on the single EU internal market after import. Furthermore, plant pests are 
mobile  by  themselves  and  cross-border  effects  will  occur  not  only  through  intra-EU 
movement  of  commodities  but  also  via  natural  spread.  Inevitably  therefore  pests  and 
diseases  of  EU  significance  need  to  be  addressed  jointly.  Inaction  in  one  MS  may 
however result in spread to others. Third country trade partners might also implement 
restrictions on imports from the EU as a whole if an outbreak in one of the MS is not 
properly eradicated. The membership of the EU (not only of the individual MS) to the 
International  Plant  Protection  Convention  and  the  WTO  Sanitary  and  Phytosanitary 
Agreement  further  implies  the  EU  responsibility  to  maintain  an  adequate  legal 
framework ensuring international plant health standards. 

The  specific  added  value  of  the  EU  co-financing  of  the  PHR  is  that  it  provides 
incentives to MS who put in place eradication and surveillance actions which are in the 
long-term interest of the Union as a whole. Large-scale eradication actions by MS for 
outbreaks could be difficult without EU support in view of the large costs incurred by 
the individual MS to the benefit of the EU, even if the overall cost/benefit for the Union 
as a whole would be clearly positive. This requires solidarity between MS in sharing the 
costs  and  burden.  The  current  example  of  the  pine  wood  nematode  outbreaks  in 
Portugal demonstrates that EU plant health co-financing budget is crucial to implement 
the eradication and containment measures which cause damage to Portuguese forestry, 
however are essential to protect forestry in the other 26 MS. 

The  PHR  cannot  be  left  to  the  private  sector  because  of  market  failures  (public  good 
interests,  information  asymmetry,  externalities,  inadequacy  of  market  instruments  to 
transform  the  large  and  diverse  outbreak  risks  into  marketable  risks  due  to  their 
potentially  catastrophic  size,  fragmentation  of  the  sectors  involved  and  non-insurable 
cross-links between sectors).    

While  the  EU  has  the  right  to  act  to  harmonise  intra-EU  trade  and  trade  with  third 
countries, it should be ensured that the measures are proportionate to the objectives, do 
not create undue administrative burden for MS and private sector and do not distort the 
level playing field.  

As concerns subsidiarity, the necessity for the EU to act also relates to the necessity to 
ensure that the regime is adequately resourced. The evaluation underlined that a lack of 
resources  plays  an  important  role  in  the  regime's  shortcomings.  The  costs  of  official 
controls (import controls, controls at the place of production for plant passport issuance, 
the  registration  of  operators  requiring  controls)  are  not  adequately  recovered  in  many 
MS,  resulting  in  shortages  for  competent  authorities  to  implement  the  legislation  and, 
from the operators' perspective, a distortion of trade. This will be further elaborated in 
the review of Regulation 882/2004 on official controls. 

23 

 
Section 3: Objectives 

3.1. General objectives 

The general objectives of the revision are to ensure an EU plant health regime which:  

−  Supports the Union's agricultural policy (TFEU Art. 43) and environment policy 
(TFEU  Art.  191)  by  protective  measures  against  harmful  organisms  of  plants, 
with prevention at the source as important principle; 

−  Allows  a  smooth  functioning  of  the  Union's  internal  market  with  fair 
competition  (TFEU  Art.  114,  while  respecting  the  need  for  a  high  level  of 
protection of health and the environment, based on scientific facts); 

−  Contributes to the harmonious development of world trade (TFEU Art. 206, by 

adopting legislation which complies with the WTO-SPS Agreement). 

3.2 Intermediate objectives 

−  To ensure that the EU territory remains free from harmful organisms that are not 

yet present in the Union 

−  To  ensure  that  the  areas  affected  by  harmful  organisms  with  the  most  severe 

impacts to the Union (priority organisms) do not increase 

−  To modernise the regime in terms of governance and incentives  
−  To ensure adequate support for the regime 

3.3. Specific objectives 

Objective 1: Definition of EU priorities 

−  To  recognise  priority  harmful  organisms  with  large  or  potentially  large  socio-
economic and environmental impact for the Union territory as a whole (versus 
organisms of more restricted impact).  

−  To improve the ability of the regime to smoothly move harmful organisms for 
which  territorial  protection  is  no  longer  justified  to  the  PRM  regime  or 
deregulate them. 

Objective 2: Improved prevention at import  

−  To  increase  the  protection  against  high-risk  trade  imported  into  the  EU  and 

passenger transport associated risks. 

−  To  increase  preparedness  and  surveillance  for  outbreaks  of  harmful  organisms 

not known to occur in the Union and of priority organisms. 
Objective 3: Strengthened eradication and containment capacities 

−  To  upgrade  the  instrumentation  for  eradication  and  containment  (including 

suppression of the presence and natural spread of priority organisms). 

−  To  incentivise  the  notification,  eradication  and  containment  of  outbreaks  of 

priority organisms. 

Objective 4: Restoration and modernisation of the regime for intra-EU movements 

−  To restore the reliability and credibility of plant passports and protected zones. 
−  To  rebalance  competent  authorities'  and  private  operators'  responsibilities  and 

costs, reduce administrative burden and ensure a level playing field. 

Objective 5: Improved support for the regime 

−  To ensure cost recovery from operators for controls by competent authorities as 
these costs relate to private interests, and Union co-financing of costs incurred 
for public interests.  

−  To ensure the availability and quality of diagnostic and scientific support. 
−  To generate public awareness of the relevance of the regime and public support. 

24 

 
 
3.4. Consistency with other EU policies and horizontal objectives 

This initiative was undertaken to improve the regime in terms of effectiveness as well 
as  with  respect  to  the  Commission's  Communication  on  Smart  Regulation  in  the 
European  Union.  It  takes  account  of  the  requests  of  the  private  sector  to  improve  the 
governance model of the regime as concerns consultation on policy development, cost 
and responsibility sharing in policy implementation and reduction of burden. The policy 
should help SMEs (the majority of growers and traders) develop in the market. 

The initiative improves the coherence with three related EU policies: 

− 

− 

It is part of a larger initiative in which Regulation (EC) 882/2004, as 
appropriately amended, becomes the general framework  for official controls on 
food and feed, animal health and welfare, plant health and plant reproductive 
material, allowing simplification and harmonisation of common aspects in the 
food chain legislation; 
It comprises re-arrangements and better linkage with the complementary PRM 
regime as concerns plant health requirements, allowing simplification and 
reduction of burden; 

−  The initiative has been co-ordinated with the Commission's initiative to develop 

a strategy and legislation concerning IAS. 

The initiative helps to transform today’s challenges (such as the effects of globalisation, 
world  demographic  trends  and  the  need  to  substantially  increase  global  food 
production,  resource  depletion,  climate  change,  competition  over  land  use  for 
production of food and non-food, including energy) into opportunities and improve the 
competitive  capacities  of  EU  agriculture.  It  is  coherent  with  other  important  EU 
policies: 

−  Common Agricultural Policy: the Communication "The CAP towards 2020: 
Meeting the food, natural resources and territorial challenges of the future" 
underlines the importance of plant health for agriculture and food security; 
−  Single Market: the regime ensures a high level of protection of health, whilst 

ensuring the effective functioning of the internal market; 

−  Europe 2020 Strategy: the regime helps to deliver a more sustainable, social, 

greener and knowledge-based EU market economy; 

−  Common Strategic Framework (CSF) Horizon 2020: the Union's financial 

instrument for research and innovation; 

−  Trade policy: effective protection of plant health is a prerequisite for 

international trade in plant materials40; 

−  Environment policy: the regime helps to protect natural ecosystems and 

biodiversity; 

−  Climate change: the regime enables mitigating the increasing plant health risks 

from climate change; 

−  Development policy: support for capacity-building activities (existing BTSF 

training programmes) to help inspectors in poor third countries satisfy the PHR 
rules. 

40  The  Council  on  16  September  2010  concluded  that,  for  a  more  integrated  approach,  the  EU  should 
further  enhance  the  coherence  and  complementarity  between  its  internal  and  external  policies 
(EUCO 21/1/10 REV 1). 

25 

 
                                                 
 Section 4: Policy options 

4.1. Policy options included in the analysis 

In light of the problems and objectives outlined above, four options were developed to 
improve the regime (for a description of the elements of each option, see Annex IX). In 
all options, the provisions on official controls in common with other Union food chain 
legislation are transferred to the revised Regulation (882/2004) on official controls. As 
said, the present impact assessment addresses the changes in the existing pillars of the 
PHR,  whether  or  not  specific  provisions  (e.g.  rules  on  import  controls,  certification, 
fees) are absorbed by that Regulation. This is inevitable since the PHR review concerns 
the functioning of the entire regime and its current instrumentation; the present impact 
assessment would otherwise be artificial and meaningless. The introduction to the PHR 
of  new  instruments  from  Regulation  882/2004  (e.g.  creation  of  EU  reference 
laboratories,  accreditation  of  official  laboratories,  use  of  TRACES)  and  modifications 
for setting the level of mandatory fees (plant passports, import controls) will however 
be dealt with in the impact assessment for the revised Regulation 882/2004. 

Option 1: Improve only the legal form and clarity of the regime. The legislation would 
be  converted  from  a  Directive  into  a  Regulation,  and  simplified  and  clarified.  This 
would ensure uniform application. The status quo is maintained in terms of substance.  

Option  2:  Prioritise,  modernise  and  step  up  prevention.  Additional  to  Option  1, 
prioritisation would be improved by transforming the Directive's current Annexes I and 
II, which list regulated pests according to technical features irrespective of their priority 
for the Union, into Annexes41 based on intervention logic and priority:  

−  Future  Annex  I:  all  pests  requiring  territorial  protection  (identical  to  current 
Annex  I  but  expanded  with  the  non-European  pests  listed  today  in  Annex  II, 
Part  A,  Section  I  and  the  pests  listed  today  in  Annex  II,  Part  B  for  which 
protected zones exist); 

−  New Annex / list: "upgraded" Annex I pests that require priority in surveillance, 
contingency  planning and eradication in  view of the large socio-economic and 
environmental risks they pose to the Union as a whole. Priority pests would be 
identified by risk assessment based on transparent criteria;  

−  Future Annex II: all pests that do not require territorial protection but pest-free 
planting material, including "downgraded" pests from the current Annex II, Part 
A,  Section  II  (pests  present  in  the  EU  that  in  practice  only  require  pest-free 
planting  material),  along  with  the  pests  currently  regulated  under  the  PRM 
regime and subject to the certification schemes currently foreseen by the PRM. 

The  plant  passport  and  protected  zone  systems  would  be  modernised  (responsibility 
sharing  with  operators  as  they  have  requested42;  self-certification;  reliance  on  their 
traceability  systems;  use  of  their  barcodes/holograms/chips)  and  upgraded  (plant 

41 The Annexes would be part of future implementing acts, based on an empowerment in the basic act. 
42 Furthermore a permanent consultation platform, also requested by the stakeholders (see Annex X (III), 
eighth indent), will be set up in the form of a permanent Working Group "Plants" under the Advisory 
Group on the Food Chain, Animal and Plant Health. Such a Working Group is currently convened on 
an ad-hoc basis only. Likewise, a permanent Working Group "Animals Health" exists. The costs are 
limited to the use of a Commission meeting room. 

26 

 
 
                                                 
passport scope, format, mandatory cost-recovery based plant passport fees43 as already 
exist  for  import,  rules  for  outbreaks  in  protected  zones).  The  coherence  between  the 
PHR and PRM regimes would be improved44 to increase effectiveness and reduce costs 
for operators. Prevention would be reinforced by introducing a new category of high-
risk plant materials that are not authorised for import until completion of a risk analysis, 
and  by  removing  exemptions  for  passenger  luggage  (to  be  subject  to  low  frequency 
controls only to minimise the cost impacts; see Annex IX).  

Option  3:  Prioritise,  modernise,  step  up  prevention  and  reinforce  actions  against 
outbreaks. Additional to Option 2, obligations would be introduced for surveillance and 
contingency  planning.  In  analogy  with  the  arrangements  in  the  animal  health  regime, 
EU  co-financing  would  be  made  available  for  surveillance  for  new  organisms  and 
priority organisms and for financial compensation of direct losses of operators for those 
organisms.  The  legal  instruments  for  eradication  and  containment  would  be  further 
developed.  The  degressivity  rule  for  EU  co-financing  of  eradication  and  containment 
measures and the exclusion of natural spread related measures would be removed.  

The  Commission  proposal  for  the  Multi-annual  Financial  Framework  2014-2020 
clarifies that "the programme will also fund additional and much-needed action to address 
the  plant  health  pests  and  diseases  which  are  becoming  increasingly  prevalent  across  the 
EU".  Evidently  this  option  can  be  put  in  practice  only  if  the  proposal  is  supported  by 
Parliament and Council. 

Option  4:  Prioritise,  modernise,  step  up  prevention,  reinforce  actions  against 
outbreaks  and  expand  the  scope  to  IAS  plants.  Additional  to  Option  3,  the  regime 
would  also  cover  IAS  plants,  in  terms  of  legal  provisions  for  measures  and  EU  co-
financing. IAS plants (other than parasitic plants) are not covered in Options 1, 2 and 3. 

4.2 Discarded policy options 

The status quo option (no changes at all to the current legislation) was discarded, given 
the outcome of the evaluation and the consultations. 

In  theory,  the  regime  could  be  rescinded  entirely  (deregulation).  This  option  was 
discarded because the EU and its MS are contracting party to the IPPC and have thus 
agreed on a legally binding obligation to regulate plant health. The impact of this option 
on  trade  from  the  EU  to  third  countries  would  over  time  evolve  to  an  unacceptable 
level. MS would impose trade bans on plant material from each other, at the expense of 
the Single Market.  

In  theory,  the  regime  could  also  be  changed  into  a  closed  system,  like  in  many  third 
countries,  thus  prohibiting  all  entry  of  plant  materials  unless  specifically  allowed 
through  an  import  license  system  on  a  case-by-case  basis.  This  option  has  not  been 
recommended  in  the  evaluation  or  during  the  consultations.  It  would  result  in  huge 
impacts on trade to and from the EU, agriculture and the economy at large. This would 
also create a huge administrative burden for third countries' operators and would likely 

43  The  obligation  for  cost  recovery  for  plant  passports  was  presented  as  part  of  Option  2  in  the 
consultations.  Further  elaboration  of  the  logic  and  form  of  the  fee  system  is  part  of  the  impact 
assessment for Regulation 882/2004. 

44  Definitions  and  provisions  of  the  PHR  and  PRM  regimes  would  be  aligned  to  remove  obstacles  to 
combine health inspections under the two regimes. A combined operator register would be required. 
If consignments require a plant passport and a certification label, the authorities would be obliged to 
issue a single document. 

27 

 
                                                 
require  a  significant  increase  of  human  resources  at  EU  level  to  manage  the  system. 
This  option  was  therefore  discarded  as  it  appears  disproportionate.  An  element  of  the 
closed  system  approach  may  be  included  in  the  new  regime  for  new  high-risk  trade 
from third countries, which would not be allowed to enter the EU pending risk analysis 
(see Option 2).  

None of the options considers the exclusion of micro-enterprises (SMEs with less than 
10 employees and a turnover or balance sheet total equal to or less than €2 million). The 
vast majority of enterprises (growers) affected by the PHR are micro-enterprises or, if 
not,  SMEs45.  Micro-enterprises  and  SMEs  trade  plant  material  across  the  Union. 
Exempting them from the regime would fundamentally jeopardise the protection of the 
EU  territory  against  the  introduction  and  spread  of  harmful  organisms.  For  the  same 
reasons,  citizens  are  not  being  exempted  from  the  regime  either.  During  the 
consultations, stakeholders did not request any exemption for micro-enterprises. 

Adapted  solutions  and  lighter  regimes  for  micro-enterprises  have  been  sought  for. 
Where  small  enterprises  sell  their  products  exclusively  on  the  local  market,  strongly 
limiting  the  phytosanitary  risk  of  movements  of  plant  material,  certain  measures  (e.g. 
the  obligation  to  issue  a  plant  passport)  will  not  apply  to  them.  Sales  to  non-
professional final users will also be subject to certain exemptions, in line with current 
legal provisions under Directive 2000/29/EC. An adapted solution for micro-enterprises 
for the mandatory fees for plant health controls, proposed in the revised Regulation on 
Official Controls46, will also apply in relation to plant health controls.  

45 The labour force per enterprise for plant production is on average below 10 employees (EUROSTAT, 

Food: from farm to fork statistics, 2011). 

46 See the impact assessment for the proposal for a revised Regulation on Official Controls. 

28 

 
                                                 
Section 5: Analysis of impacts 

This  section  examines  the  economic,  social  and  environmental  impacts  of  the  policy 
options in Section 4. Each of these comprises a series of amendments of which the costs 
and/or burden for operators (mostly SME)47, MS and the EU is detailed in Annex IX. 
Those amendments cover all areas for which public consultation48 had identified a need 
for impact assessment. 

Each option was assessed against the theoretical baseline of 'do nothing' and therefore 
the  impacts  outlined  are  the  difference  from  the  status  quo  (which  at  long  term  has 
negative impacts on the economy, employment and environment; see Annex VIII). The 
following  criteria  were  used.  For  economic  impacts:  costs  and  burden  (based  on  the 
supplementary  economic  study);  productivity,  profitability  and  competitiveness.  For 
social  impacts:  employment;  food  security  /  safety.  For  environmental  impacts: 
sustainability  (including  impacts  on  use  of  pesticides);  biodiversity  and  ecosystems 
conservation;  health  of  forests,  landscape,  and  public  and  private  green.  To  help 
comparisons  between  options  the  impacts  have  been  rated  (0:  no  impact;  +,  ++,  +++: 
small,  medium  or  large  positive  impact;  -,  --,  ---:  small,  medium  or  large  negative 
impact). Apart from costs and burden, quantitative estimation was not possible since it 
cannot  be  known  in  advance  what  outbreaks  of  which  harmful  organisms  would  be 
prevented. 

According  to  the  evaluation  report,  the  baseline  costs  of  the  PHR  incurred  in  the 
reference year 2008 were as follows (Annex VIII):  

Overall compliance costs 
(including  administrative 
burden and fees) 

Competent 
Authorities 

Operators 

EU budget 

Total 

Baseline scenario:  
-- Prior to levying of fees 
-- After levying of fees 

€ 96 mio 
€ 59 mio 

€ 51 mio 
€ 88 mio 

€ 2 mio 
€ 2 mio 

€ 149 mio 
€ 149 mio 

These  figures  include  the  costs  of  official  controls  (incurred  by  the  competent 
authorities  but  partly  recovered  from  the  operators  through  fees49)  and  the  costs  of 
surveillance, eradication and containment measures. It should be noted that the figure of 
€2  mio  EU  budget  is  based  on  2008  50.  Given  the  claims  for  2010,  2011  and  2012, 
annual MS and EU expenditures will likely be EUR 20 mio higher. 

47 Apart from the seed industry, most operators are small and medium-sized enterprises (SME). 
48  The  public  consultation  in  autumn  2010  allowed  differentiating  between  proposed  amendments  that 
could have major economic impact and should be specifically addressed in the impact  assessment, 
and amendments with minor impact for which impact assessment was not needed. The amendments 
with  perceived  major  impact  were  included  in  the  Terms  of  Reference  for  the  supplementary 
economic study. 

49  The  PHR  obliges  MS  to  levy  fees  for  import  controls.  It  does  not  require  fees  for  plant  passport 

controls and registration of operators, for which fees are levied in some but not all MS. 

50 The figures were taken from the PHR evaluation (2010), which had the year 2008 as the cut-off date. 
Increased expenditures since 2008 relate mainly to outbreaks of pine wood nematode, for which the 
situation in Portugal deteriorated in 2008. Isolated outbreaks in Spain have since been successfully 
eradicated in a very early stage. To if possible avoid such high costs, the new plant health law will 
oblige Member States to carry out intensive surveys for priority organisms. Immediate notification of 
outbreaks will be a condition for eligibility for Union co-financing of eradication measures.    

29 

 
 
 
 
 
                                                 
5.1. Option 1 – Improve only the legal form and clarity of the regime 

In Option 1, the costs and burden of the EU plant health regime would be identical to 
the baseline scenario after levying of fees. The increased clarity of the legal text and the 
form  of  a  Regulation,  avoiding  "noise"  during  transposition,  would  help  to  uniformly 
understand  and  implement  the  legislation,  resulting  in  some  limited  benefits  for 
effective prevention and control of harmful organisms. No economic or social impacts 
are  expected.  None  of  the  stakeholders  or  MS  indicated  that  this  option  (or  the  status 
quo) was their preferred option. 

→ Summary of the key impacts under Option 1: 

Areas 

Impacts 

Economic impacts 
     Reduction of cost/burden to operators 
     Productivity, profitability, competitiveness 

Social impacts 
     Employment 
     Food security and safety 

Environmental impacts 
     Sustainability 
     Biodiversity and ecosystems conservation 
     Health of forests, landscape, public and private green 

0 
0 

0 
0 

+ 
0 
+ 

5.2. Option 2 – Prioritise, modernise and step up prevention 

This option would bring along the following changes (labelled according to Annex IX 
and explained in more detail in that Annex) to the foreseen Regulation:   

(a)  Creation of a list of EU priority pests 
(b) Transformation of current Annex II of Directive 2000/29/EC into an Annex, of 
an implementing act, listing harmful organisms for which thresholds apply 

(i)  Restrictions for new high-risk trade pending risk analysis 
(j)  Dropping the existing exemption to import requirements for passenger luggage 
(l)  Operators fully responsible for intra-EU traceability information 
(m) Extension of plant passport scope to all business-to-business movements of all 

plants 

(n) Simplification and harmonisation of the plant passport format 
(o) Alignments with the certification label issued under the PRM regime 
(p) Obligation  to  MS  to  levy  cost-recovery-based  fees  for  registration  (a 

prerequisite for plant passport inspections) 

(q) Obligation to MS to levy cost-recovery-based fees for plant passport inspections 
(r)  Introduction  of  standardised  rules  for  eradication  of  outbreaks  in  protected 

zones 

5.2.1. Economic impacts 

Overall compliance costs (including administrative burden and fees). According to the 
estimates in Annex IX, no significant impacts are foreseen for changes a, b, l, m, n or r. 
The annual administrative burden / costs would change as follows: 

30 

 
 
 
 
Overall compliance costs 
(including administrative 
burden and fees) 
Baseline scenario:  
-- Prior to levying of fees 
-- After levying of fees 

Option 1 

(i) Temporary restrictions 
new high-risk trade51 
(j) Passenger luggage 
controls 
(o) Alignment with PRM 
certification label  
(p, q) Cost-recovery based 
registration fees and plant 
passport fees 

Competent 
Authorities 

Operators 

EU budget 

Total 

€ 96 mio 
€ 59 mio 

€ 59 mio 

€ 51 mio 
€ 88 mio 

€ 88 mio 

€ 2 mio 
€ 2 mio 

€ 2 mio 

€ 149 mio 
€ 149 mio 

€ 149 mio 

Changes compared to Option 1: 

+ €  1 mio 
(AB) 

+ € 3.5 mio 
(fees) 

+ € 1 mio 
(AB) 

+ €  1 mio 
(of which 5% AB) 

– € 16 mio 
(fees) 

– € 0.7 mio 
(fees) 

+ € 16 mio 
(fees) 

Option 2 total costs 

€ 45 mio 

€ 106.8 mio 

€ 3 mio 

€ 154.8 mio 

Option 2 compared to the  
baseline scenario after 
levying of fees 

− € 14 mio 

+ € 18.8 mio 

+ € 1 mio 

+ € 5.8 mio 

It  should  be  noted  that  the  baseline  figure  of  EUR  2  mio  EU  budget  is  based  on  the 
official figure for 2008. Given the EUR 10-20 mio higher level of claims for 2010 and 
2011,  annual  MS  expenditures  will  rather  be  EUR  55-65  mio,  and  EU  expenditures 
EUR 13-23 mio.  

The impact of this option on the EU budget will depend on the evolution of outbreaks, 
which is unpredictable. While the ceilings set for plant health expenditures in the MFF 
will be respected, a need may arise in extreme cases to have access to the crisis reserve 
for food safety. 

The liberated budget for  competent authorities  from  full  cost-recovery  for  registration 
and inspection activities would be available only in those MS that do not yet have cost-
recovery based fees (budget will not be liberated in all MS). Liberating budget in MS 
where presently no major outbreaks occur could result in budget cuts to the plant health 
services.  

Productivity, profitability, competitiveness (including level playing field). Option 2 will 
provide  better  protection  against  the  entry  of  new  harmful  organisms  thanks  to  better 
use  of  resources  (prioritisation  and  where  appropriate  status  change  of  harmful 
organisms)  and  measures  against  new  high-risk  trade  and  passenger  luggage  related 
impact  on  productivity,  profitability  and 
risks.  This  should  have  a  positive 
competitiveness as regards third countries (an improved EU plant health status results 
in  a  higher  export  potential).  The  benefits  will  be  achieved  only  partially  because 
surveillance and action against outbreaks will also need to be reinforced and this can be 
done  in  this  option  only  in  MS  where  today  no  full  cost  recovery  for  inspection  and 
registration is in place. 

51 The lost value would be the range of EUR 1.5-3.7 million per year and the total administrative costs for 

Member States and EU in the range of EUR 0.8-2.7 million per year. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
The major benefit of Option 2 is that the intra-EU movement system (plant passports) 
will  be  modernised.  Operators  will  be  made  fully  responsible  for  traceability  of 
consignments,  accordingly  the  plant  passport  can  and  will  be  simplified  to  the 
essentials,  and  modern  information  carriers  already  used  by  operators  (barcodes, 
holograms, chips) will be allowed to replace the classical lot number. However, due to 
the  full  cost-recovery  for  registration  and  inspection,  the  costs  for  operators  would 
nevertheless  go  up,  which  would 
impact  negatively  on  profitability  and 
competitiveness. The estimated cost increase per operator is EUR 400 per year for those 
Member  States  that  currently  do  not  levy  fees  at  cost-recovery  level  (Annex  IX). 
Mandatory  cost-recovery  based  fees  across  the  EU  would  reinforce  the  level  playing 
field for operators. Trade distortions due to poorly managed protected zones, providing 
unjustified  benefits  to  operators  within  infested  protected  zones,  would  also  be 
removed.  

The impact of this option on third countries concerns the restrictions on new high-risk 
trade. This would affect in particular countries with emerging trade of plants to the EU. 

5.2.2. Social impacts 

Employment.  The  cost  increase  for  operators  could  have  negative  impact  on 
employment. Sectors with low profit margins (end products: fruits, cut flowers) would 
be impacted more than sectors with a high profit margin (seed industry). MS with many 
small operators (mainly new MS) could be more affected because such operators have 
lower  profit  margins,  although  on  the  other  hand  the  costs  would  be  shared  between 
higher numbers of operators.  

Food  security  and  safety.  The  increased  level  of  protection  against  new  harmful 
organisms  would  impact  positively  on  long-term  food  security.  However,  the  positive 
impact would be minor since the territorial protection would be improved only partially 
in this option. 

5.2.3. Environmental impacts 

Sustainability  (durability;  use  of  pesticides).  The  increased  protection  for  the  EU 
territory against new harmful organisms would impact positively on sustainability and 
would mitigate pesticide use. The positive impact would be minor since the territorial 
protection  would  be  improved  only  partially  in  this  option.  Moreover,  the  increased 
pressure on operators without compensation for losses could be a perverse incentive to 
cover up outbreaks. 

Biodiversity  and  ecosystems  conservation.  The  increased  protection  against  new 
harmful  organisms  would 
impact  positively  on  biodiversity  and  ecosystems 
conservation.  However,  the  positive  impact  would  be  minor  since  the  territorial 
protection  would  be  improved  only  partially  in  this  option  (limited  resources  for 
surveillance and eradication). 

Health status of forests, landscape, public and private green. The partly increased level 
of  protection  for  the  EU  territory  against  new  harmful  organisms  would  impact 
positively  on  the  health  status  of  forests,  landscape,  public  and  private  green.  The 
positive impact would be minor since the territorial protection would be improved only 
partially in this option. 

32 

 
→ Summary of the key impacts under Option 2: 

Areas 

Impacts 

Economic impacts 
     Reduction of cost/burden to operators 
     Productivity, profitability, competitiveness 

Social impacts 
     Employment 
     Food security and safety 

Environmental impacts 
     Sustainability 
     Biodiversity and ecosystems conservation 
     Health of forests, landscape, public and private green 

5.2.4. Views of stakeholders and Member States 

−− 
− 

− 
+ 

+ 
+ 
+ 

One single national stakeholder organisation (PLANTUM NL) was in favour of Option 
2. Another organisation (EUROPATAT) was in favour of Option 2 but found Option 3 
also acceptable. The majority of the stakeholders (including the farmers' EU umbrella 
organisation  COPA-COGECA)  was  in  favour  of  the  options  with  increased  budget 
(Options 3 and 4). Only two of the responding Member States were in favour of Option 
2,  due  to  lack  of  resources  and/or  opposition  to  any  increase  of  the  EU  budget. 
However,  if the increased budget for plant  health  stemmed from a  reallocation within 
the existing EU budget, they were open to this. 

5.3.  Option  3  –  Prioritise,  modernise,  step  up  prevention  and  reinforce  actions 
against outbreaks 

In  this  option,  it  is  assumed  that  the  additional  EU  resources  necessary  to  reinforce 
prevention and actions against outbreaks would indeed be made available. In addition to 
the changes foreseen  in  Options 1 and 2, this option would bring  along the following 
further changes to the Regulation (note that no impact is foreseen for changes (d), (e) 
and (g) in Annex IX):   

(c)  Introduction of mandatory surveillance by the MS (with EU co-financing)  
(d) Introduction of mandatory contingency planning  
(e)  Clarification of measures required for eradication and containment of outbreaks 
(f)  Extension of the scope of the EU co-financing "solidarity regime" to natural 

spread 

(g) Removal of the degressivity rule (mandatory decrease of EU co-financing over 

time) 

(h) EU co-financing to also cover MS expenditures to compensate operator losses 

from measures related to EU priority organisms 

33 

 
 
 
 
5.3.1. Economic impacts 

Overall compliance costs (including administrative burden and fees). According to the 
estimates in Annex IX, the annual burden / costs would change as follows:  

Overall compliance costs 
(including administrative 
burden and fees) 
Baseline scenario:  
-- Prior to levying of fees 
-- After levying of fees 

Option 2 

Competent 
Authorities 

Operators 

EU budget 

Total 

€ 96 mio 
€ 59 mio 

€ 51 mio 
€ 88 mio 

€ 45 mio 

€ 106.8 mio 

€ 2 mio 
€ 2 mio 

€ 3 mio 

€ 149 mio 
€ 149 mio 

€ 154.8 mio 

Changes compared to Option 2: 

(c) Mandatory surveillance 
(with EU co-financing)52 
(f) Coverage natural spread  

(h) Compensation for operator 
losses also covered53 
Option 3 total costs 

− € 4 mio 
(compliance costs) 

− € 3.7 mio 
(compliance costs)
+ € 7 mio 
(compensation) 
€ 44.3 mio 

− € 17 mio 
(compensation) 

€ 89.8 mio 

+ € 10 mio 
(co-financing) 

+ € 3.7 mio 
(co-financing) 
+ €10 mio 
(co-financing) 
€ 26.7 mio 

€ 160.8 mio 

Option 3 compared to the  
baseline scenario after 
levying of fees 

− € 14.7 mio 

+ € 1.8 mio 

+ € 24.7 mio 

+ € 11.8 mio 

In the table above, the figures for mandatory surveillance follow the estimate of FCEC 
(2011) that the current level of surveillance would increase from EUR 14 mio to EUR 
20  mio  per  year  if  it  would  become  an  obligation  and  if  EU  co-financing  would  be 
available.  It  is  assumed  that  the  MS  at  present  already  implement  measures  against 
outbreaks resulting from natural spread in line with the legal obligations, the difference 
being  that  these  measures  would  now  be  co-financed  by  the  EU.  It  is  furthermore 
accounted for that certain MS at present already provide some compensation to growers 
for losses resulting from imposed measures, estimated in Annex IX to be EUR  3 mio 
per year. Assuming that operator losses from official measures would be EUR 20 mio 
per  year,  this  would  imply  that  MS  costs  would  go  up  to  EUR  10  mio  and  operator 
compensation would go up to EUR 20 mio per year, the differences at EU level being 
reflected in the table above.  

It  should  be  noted  that  the  baseline  figure  of  EUR  2  mio  EU  budget  is  based  on  the 
official figure for 2008. Given the EUR 10-20 mio higher level of claims for 2010 and 
2011,  annual  MS  expenditures  will  rather  be  EUR  54-64  mio,  and  EU  expenditures 
EUR 37-47 mio. 

The impact of this option on the EU budget will depend on the evolution of outbreaks, 
which is unpredictable. While the ceilings set for plant health expenditures in the MFF 
will be respected, a need may arise in extreme cases to have access to the crisis reserve 
for food safety. 

52 The surveillance costs are estimated to rise from EUR 14.0 million to EUR 16.8-21.0 million (FCEC, 

2010), here assumed to be EUR 20.0 million.  

53 The estimates for the additional costs to co-finance operator losses vary from EUR 5 million (FCEC, 
2010)  for  five  priority  pests  to  EUR  20.9  million  per  year  if  not  restricted  to  priority  pests  (being 
50% of the average of a range of total compensations between EUR 26.5-57.0 million). Here they are 
assumed to be EUR 20 million per year for a maximum of 20 priority organisms. 

34 

 
 
 
 
 
 
 
 
 
 
                                                 
Productivity,  profitability,  competitiveness  (including  level  playing  field).  Option  3 
would introduce incentives to MS and operators to better support the objectives of the 
regime  through  vigilance,  immediate  notification  and  early  action  (note  that 
compensations  for  losses  would  be  conditional  to  compliance  with  good  bio-security 
practices). Budget would be available in all MS to upgrade surveillance and to reinforce 
eradication  and  containment.  Thus,  the  full  range  of  protective  measures  would  be  in 
place  (prevention  against  high-risk  trade,  enhanced  surveillance,  reinforced  early 
action).  This  would  substantially  limit  the  influx,  establishment  and  spread  of  new 
harmful  organisms  into  and  within  the  EU,  with  a  significant  positive  impact  on 
productivity,  profit  and  competitiveness  with  third  countries  (an  improved,  well-
documented EU plant health status will result in higher export potential). Risks of trade 
restrictions from third countries from EU outbreaks of internationally regulated harmful 
organisms would be substantially mitigated.  

As  in  Option  2,  a  major  benefit  of  Option  3  would  be  that  the  intra-EU  movement 
system  (plant  passports)  will  be  modernised  and  cheaper  for  the  operators.  Operators 
would  be  made  officially  responsible  for  traceability  of  consignments,  as  is  being 
requested.  Due  to  the  full  cost-recovery  for  registration  and  inspection,  the  costs  for 
operators  would  go  up,  but  to  a  same  extent  as  compensation  for  losses  would  be 
foreseen.  Full  cost  recovery  in  all  MS  would  reinforce  the  level  playing  field.  Trade 
distortions  due  to  poorly  managed  protected  zones,  providing  unjustified  benefits  to 
operators within infested protected zones, would be removed in this option.  

5.3.2. Social impacts 

Employment.  The  positive  impact  on  productivity,  profit  and  competitiveness  would 
imply a moderately positive impact on employment too. 

Food security and safety. Achieving full positive impact on EU plant health would have 
a long-term positive impact on food security. As argued previously, food safety would 
not be affected. 

5.3.3. Environmental impacts 

Sustainability  (durability;  use  of  pesticides).  The  positive  impact  on  EU  plant  health 
would imply a positive impact on sustainable agriculture and forestry and a mitigation 
of the needs for pesticide use. 

Biodiversity and ecosystems conservation. The increased level of protection for the EU 
territory  against  new  harmful  organisms  would  impact  positively  on  biodiversity  and 
ecosystems conservation, especially but not exclusively in relation to the health status 
of forests and forest-related biodiversity. 

Health  status  of  forests,  landscape,  public  and  private  green.  The  increased  level  of 
protection  for  the  EU  territory  against  new  harmful  organisms  would  impact  very 
positively on the health status of forests, landscape, public and private green, which are 
particularly  at  risk  in  the  baseline  scenario.  Examples  of  the  success  of  this  approach 
are the eradication of the pine wood nematode outbreak in 2008 in Spain, of red palm 
weevil  in  the  Canary  islands  and  of  the  citrus  longhorned  beetle  in  the  Boskoop  area 
(The Netherlands). 

→ Summary of the key impacts under Option 3:  

35 

 
Areas 

Impacts 

Economic impacts 
     Reduction of cost/burden to operators 
     Productivity, profitability, competitiveness 

Social impacts 
     Employment 
     Food security and safety 

Environmental impacts 
     Sustainability 
     Biodiversity and ecosystems conservation 
     Health of forests, landscape, public and private green 

5.3.4. Views of stakeholders and Member States 

0 
+++ 

++ 
++ 

+++ 
+ 
+++ 

With the two exceptions mentioned under Option 2, all stakeholders and Member States 
are  in  favour  of  Option  3  or  its  variant  including  IAS  plants  (Option  4).  EFNA 
(representing  EU  forest  nurseries),  ENA  (representing  EU  nurserystock  producers), 
UFS (a seeds industry organisation) and the NATIONAL TRUST (a national heritage 
NGO) were in favour  of Option 3. USSE (representing southern EU foresters) was in 
favour of Option 3 or Option 4, depending on the available EU budget. 

5.4. Option 4 – Prioritise, modernise, step up prevention, reinforce actions against 
outbreaks and expand the scope to IAS plants 

In  this  option,  it  is  assumed  that  the  additional  EU  resources  necessary  to  reinforce 
prevention and actions against outbreaks would indeed be made available. In addition to 
the changes foreseen in Options 1, 2 and 3, this option would bring along the following 
further change to the Regulation (labelled according to the list in Annex IX):   

(u) Expansion of the scope of the plant health regime to also cover IAS plants 

5.4.1. Economic impacts 

Overall compliance costs (including administrative burden and fees). According to the 
estimates  in  Annex  IX,  the  annual  administrative  burden  /  costs  would  change  as 
follows: 

Overall compliance costs 
(including administrative 
burden and fees) 
Baseline scenario:  
-- Prior to levying of fees 
-- After levying of fees 

Competent 
Authorities 

Operators 

EU budget 

Total 

€ 96 mio 
€ 59 mio 

€ 51 mio 
€ 88 mio 

€ 2 mio 
€ 2 mio 

€ 149 mio 
€ 149 mio 

Option 3 

€ 44.3 mio 

€ 89.8 mio 

€ 26.7 mio 

€ 160.8 mio 

Changes compared to Option 3: 

(u) Coverage of IAS plants54 

+ € 20.4 mio 
(compliance costs) 

+ € 20.4 mio 
(co-financing) 

Option 4 total costs 

€ 64.7 mio 

€ 89.8 mio 

€ 47.1 mio 

€ 201.6 mio 

Option 4 compared to the  
baseline scenario 

+ € 5.7 mio 

+ € 1.8 mio 

+ € 45.1 mio 

+ € 52.6 mio 

54  The  estimated  costs  for  eradication  measures  would  be  in  the  range  of  EUR  18.5-632.0  million  per 

year, being on average EUR 40.8 million per year. 

36 

 
 
 
 
 
 
 
 
 
 
                                                 
It  should  be  noted  that  the  baseline  figure  of  EUR  2  mio  EU  budget  is  based  on  the 
official figure for 2008. Given the EUR 10-20 mio higher level of claims for 2010 and 
2011,  annual  MS  expenditures  will  rather  be  EUR  75-85  mio,  and  EU  expenditures 
EUR 57-67 mio. 

The  cost  estimate  for  including  IAS  plants  in  the  scope  of  the  PHR  is  an  average 
estimate  (Annex  IX)  for  the  financial  "best  case"  (EUR  18.5  mio)  and  "worst  case" 
(EUR  63  mio)  scenarios,  representing  an  increase  of  the  total  costs  of  the  regime  to 
minimally  EUR  179  mio  and  maximally  EUR  224  mio  (an  increase  of  20%  to  50% 
compared to the baseline and 12% to 39% compared to Option 3). The potential annual 
costs for competent authorities range from EUR 54-76 mio and for the EU expenditures 
from EUR 36-58 mio.   

The impact of this option on the EU budget will depend on the evolution of outbreaks, 
which is unpredictable. While the ceilings set for plant health expenditures in the MFF 
will be respected, a need may arise in extreme cases to have access to the crisis reserve 
for food safety. 

Productivity, profitability, competitiveness (including level playing field). In principle, 
significantly positive impacts are expected as in Option 3. Preventing the entry of future 
IAS  weeds  would  result  in  further  savings  for  the  economy.  The  balance  would  shift 
from plant health proper benefits to wider benefits. However, the positive impacts could 
be  less  to  the  extent  that  the  EU  co-financing  budget  for  plant  health  would  be 
insufficient to cover the needs of the regime in its current scope. If the additional needs 
for  IAS  plants  would  be  met  at  the  expense  of  the  current  needs,  this  could  entail  in 
failure in both areas. 

5.4.2. Social impacts 

Employment. A moderately positive impact on employment would be expected, as for 
Option  3,  however  dependent  on  possible  competition  between  current  needs  of  the 
regime for EU co-financing budget and the needs for IAS plants.  

Food  security  and  safety.  A  positive  long-term  impact  on  food  security  would  be 
expected, as in Option 3. Given the health problems associated with some IAS plants 
(allergies, skin irritation), Option 4 would also favour public health. 

5.4.3. Environmental impacts 

Sustainability  (durability;  use  of  pesticides).  The  positive  impact  on  EU  plant  health 
would imply a positive impact on sustainable agriculture and forestry and a mitigation 
of  the  needs  for  pesticide  use,  however  dependent  on  possible  competition  between 
current  needs  of  the  regime  for  EU  co-financing  budget  and  needs  for  IAS  plants. 
Including  terrestrial  IAS  weeds  in  the  PHR  would  improve  coherence  with  the  PRM 
and plant protection products legislation managed by DG SANCO and could result in 
synergies (better prevention and control with minimal herbicide inputs). 

Biodiversity and ecosystems conservation. The increased level of protection for the EU 
territory  against  new  harmful  organisms  would  impact  positively  on  biodiversity  and 
ecosystems conservation, especially but not exclusively in relation to the health status 
of  forests  and  forest-related  biodiversity.  In  addition,  biodiversity  and  ecosystems 
conservation would greatly profit from protection against IAS plants. 

37 

 
Health  status  of  forests,  landscape,  public  and  private  green.  The  increased  level  of 
protection  for  the  EU  territory  against  new  harmful  organisms  would  impact  very 
positively on the health status of forests, landscape, public and private green, which are 
particularly  at  risk  in  the  baseline  scenario.  However,  the  positive  impact  could  be 
smaller dependent on possible competition between current needs of the regime for EU 
co-financing budget and needs for IAS plants.  

→ Summary of the key impacts under Option 4: 

Areas 

Impacts 

Economic impacts 
     Reduction of cost/burden to operators 
     Productivity, profitability, competitiveness 

Social impacts 
     Employment 
     Food security and safety 

Environmental impacts 
     Sustainability 
     Biodiversity and ecosystems conservation 
     Health of forests, landscape, public and private green 

5.4.4. Views of stakeholders and Member States 

0 
+++ 

++ 
++ 

+++ 
+++ 
+++ 

The  views  of  stakeholders  concerning  the  preferred  option  (3  or  4)  are  mixed.  AIPH 
(representing EU horticulture), COPA-COGECA and its member LTO NEDERLAND 
were in favour of Option 4, on condition that the budget for IAS plants will not come 
from  the  CAP  (COPA-COGECA)  and/or  only  IAS  plants  with  serious  impacts  to 
agriculture would be regulated (AIPH). USSE (representing southern EU foresters) was 
in favour of Option 3 or Option 4, depending on the available EU budget. 

Several MS have indicated that they are not in favour of Option 4 because they do not 
have  the  financial  resources  to  cope  with  IAS  plants.  For  such  MS,  Option  4  will 
anyhow be detrimental to the plant health needs. Other MS have indicated that they are 
in  favour  of  Option  4,  however  arguing  that  the  emphasis  would  be  on  import 
protection  and  that  costs  would  be  limited.  As  shown  by  FCEC  (2011),  this  may  not 
fully reflect reality. 

38 

 
 
 
 
Section 6: Comparing the options  

6.1. Comparing options in terms of economic, social and environmental impacts 

To evaluate the impact of the policy options, the balance of the positive and negative 
scores in the summary tables in Section 5 (excluding the administrative burden / costs) 
were compared: 

−  Positive economic impacts from an improved plant health status would occur in 
Options 3 and 4, more than in Option 2 where protection was partial and where 
the  increased  costs  for  operators  (full  cost-recovery  fees;  no  compensation  for 
outbreak  losses)  would  take  away  the  benefits  in  terms  of  profit  and 
competitiveness.  Although  the  overall  costs  of  the  regime  would  increase  in 
Options 3 and 4, the benefits would increase even more. Option 1 did not have 
any economic impacts;  

−  Positive social impacts followed this pattern as they are derived from the degree 
of improvement of the EU plant health status (food security and safety) and the 
impacts on productivity, profitability and competitiveness (employment);  

−  Positive environmental impacts were limited in Options 1 and 2 but significant 

in Options 3 and 4.  

The  costs  of  the  policy  options  (based  on  the  tables  in  Section  5),  compared  to  the 
baseline scenario, differed substantially: 

Additional annual costs of the four policy options (mio €)

60
50
40
30
20
10
0
-10
-20

M ember States

Operators
EU

Total

Option 1 

Option 2 

Option 3 

Option 4 

Based  on  the  comparisons  of  options  above,  it  appears  that  Option  3  provides  the 
optimal  balance  of  costs  and  benefits  (value  for  money)  in  terms  of  economic,  social 
and environmental impacts:  

−  Option 1 did not involve cost changes but had little impact; 
−  Option  2  resulted  in  21%  higher  costs  for  operators  (EUR  18.8  mio  above 
current  EUR  88  mio),  allowing  MS  to  reduce  costs  and  invest  in  a.o. 
surveillance, but with limited environmental and – due to the cost increase – no 
economic benefits. Total PHR costs in this option increased with 4% from EUR 
149 mio to EUR 154.8 mio; 

−  Option 3 had a slightly higher cost level than Option 2 (+ 8%), however in this 
option the costs for operators remained stable (+2%) compared to the baseline 
scenario,  while  EU  costs  increased  and  MS  costs  decreased.  The  changed 

39 

 
 
 
balance  of  costs 
environmental impacts; 

resulted 

in  significantly  better  socio-economic  and 

−  Option  4  required  a  35%  increase  of  total  expenditures  for  the  regime  (from 
EUR  149  mio  to  EUR  201.6  mio,  an  increase  in  the  range  of  20-50%)  and 
resulted  in  positive  economic,  social  and  environmental  impacts  to  a  similar 
level as Option 3.   

6.2. Comparing the options in light of the objectives 

In order to measure its usefulness, each option was rated against the initial objectives of 
the review to examine which option best met the aims of the review. 

Option 
1 

Option 
2 

Option 
3 

Option 
4 

l
a
r
e
n
e
G

s
e
v
i
t
c
e
j
b
o

s
e
v

j

i
t
c
e
b
o
c

i
f
i
c
e
p
S

Ensuring that the regime effectively 
protects  the  Union  against  harmful 
organisms of EU priority 

the 

regime 

as 
Modernising 
incentives,  costs  and 
concerns 
responsibilities, 
the 
including 
removal  of  competition  distortion 
and the reduction of burden
Definition of EU priorities 
-- Recognition of priority pests 
-- Improved ability to smoothly declassify 
harmful organisms  

Improved prevention at import 
-- Increased protection against high-risk 
trade 
-- Increased preparedness and surveillance 

Strengthened eradication and 
containment capacities 
-- Upgraded instruments 
-- Incentivised notification, eradication and 
containment of outbreaks of priority pests 

Restoration and modernisation of 
the regime for intra-EU movements 
-- Restored credibility of plant passports 
and protected zones 
-- Rebalanced MS/operator responsibilities, 
reduced burden/costs, level playing field 

0 

0 

0 
0 

0 

0 

0 
0 

0 

0 

Improved support for the regime 
-- Full cost recovery for controls of 
operators and Union co-financing for public 
interest 
-- Good diagnostic and scientific support 
-- Public awareness and support 

0 
N.A. 
0 

+ 

+ 

+++ 

+++  
(also 
IAS plants)

+++ 

+++ 

+++ 
+++ 

+++ 
+++ 

+++ 
+++ 

++ 

++ 

+ 
0 

+++ 

+ 

++ 
N.A. 
+ 

++ 

+++ 

+++ 

++ 

+++ 
+++ 

++ 
++ 

+++ 

+++ 

+++ 
N.A. 
++ 

+++ 

+++ 

+++ 
N.A. 
++ 

Magnitude of impact: ++ strongly positive; + positive; −− strongly negative; − negative; 0 none. N.A.: 
not  applicable  (to  be  addressed  by  the  revised  Regulation  882/2004  and  through  the  Horizon  2020 
programme). 

Option 2 ranked lower than Options 3 and 4 for eradication / containment and burden 
reduction  and  thus  also  for  the  general  objectives  of  the  review.  Options  3  and  4 
differed in the extent to which they offered protection at the border (higher for Option 4 
as IAS plants would be covered too) and ensured early detection and eradication (higher 
for Option 3 as limited resources would not be shared with IAS plants).  

40 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The need for scientific support for policy development and for diagnostic laboratories 
was  left  out  of  the  analysis.  Research  on  plant  health  will  be  ensured  through  the 
Horizon  2020  programme55.  Laboratory  support  will  be  provided  by  setting  up  EU 
reference laboratories for plant health under Regulation 882/2004 and will be addressed 
under that review. 

Based on the comparisons of the options above against our initial objectives, it appears 
that Options 3 and 4 are the most effective policy options. Option 4 adds to Option 3 
that  IAS  plants  are  also  covered,  however  this  may  be  at  the  expense  of  the 
effectiveness to eradicate and contain regular pests and the additional costs for the EU 
are high.  

6.3. Highlight the trade-offs and synergies associated with each option 

Option 1 – Improve only the legal form and clarity of the regime 

The  assessment  shows  that  this  option  will  insufficiently  meet  the  objectives  of  the 
review. This option will consolidate the regime's failures, result in avoidable long-term 
costs  and  losses  (estimated  by  the  FCEC  at  up  to  billions  of  EUR  per  year)  and  will 
undermine trust that the regime makes sense at all.  

Option 2 – Prioritise, modernise and step up prevention 

Option 2 improves the regime in so far as possible without additional EU engagement, 
by  responsibilising  operators  but  imposing  full  cost  recovery  and  by  strengthening 
prevention. Given the financial crisis in the EU, Option 2 might be the default candidate 
for the future PHR. The assessment however reveals that its cost-effectiveness is poor.  

Stricter  import  provisions  should  help  to  reduce  the  influx  of  prohibited  regulated 
harmful organisms into the Union. The high volumes of imports from other continents 
where those pests are widespread nevertheless imply that sooner or later some regulated 
organisms  will  slip  through  and  cause  outbreaks,  unless the open approach of the EU 
concerning  import  of  plant  material  is  given  up  (which  option  was  discarded,  also 
politically,  from  the  start  because  of  the  damage  it  would  cause  to  the  Union's 
economy). These outbreaks needs to be timely detected and effectively addressed if the 
open  EU  approach  is  to  be  maintained  (like  in  the  animal  health  regime).  The 
quintessence of Option 2, avoiding further EU engagement, implies that the necessary 
additional expenditures for surveillance and early action against such outbreaks can be 
generated  only  partially,  through  increased  cost  recovery  related  to  intra-EU 
movements of plant material. This will help only in some MS (those with incomplete 
cost  recovery  at  present).  It  will  increase  the  burden  for  operators  (stricter  import 
provisions, temporary  suspension of high-risk trade) without offering reinforced long-
term protection against harmful organisms from third countries, as incentives for early 
notification by operators are not provided and in many MS budget for surveillance and 
early action remains insufficient. This is a risk since harmful organisms do not respect 
MS borders.  

The main advantage of Option 2 is the modernisation and rebalancing of the role and 
responsibilities  of  operators  versus  MS  competent  authorities  (as  well  as  better 

55 The Framework Programmes for research and innovation fund projects aiming to deliver cheaper and 
more versatile diagnostic tools. A combination and coordination of national and European funding 
(under  the  CSF  Horizon  2020  programme)  will  likely  further  strengthen  plant  health  related 
scientific competency. 

41 

 
                                                 
arrangements  between  the  PHR  and  PRM  regimes  and  a  more  level  playing  field). 
While this was one of the general objectives of the review, the other general objective 
(improved  prevention  and  early  action)  would  only  be  partly  met.  The  harmful 
organism  influx  into  the  EU  would  at  best  be  slowed  down  and  the  damage  would 
continue  to  increase,  in  agriculture  and  as  concerns  the  natural  environment,  forests, 
landscape  and  green.  Using  hindsight  to  examine  which  outbreaks  could  have  been 
avoided if this option had been in place a decade ago, it is not clear that the plant health 
status of the Union would have been much better than it is today.  

Option  2  supposes  that  MS  and  operators  are  best  placed  to  deal  with  plant  health 
problems,  which  conflicts  with  the  outcome  of  the  regime's  evaluation  and  with  the 
preference  of  most  stakeholders  and  MS  to  move  to  stronger  EU  engagement  (for 
details see Annex X). It neglects market failure and the existence of significant public 
good  aspects,  and  rather  reflects  the  original  PHR  logic  that  the  regime  is  about 
agriculture and movements in trade. 

Option  3  –  Prioritise,  modernise,  step  up  prevention  and  reinforce  actions  against 
outbreaks 

The  main  difference  of  this  option  compared  to  Option  2  is  the  increased  EU  co-
financing for surveillance and outbreak eradication. This proves to result in a series of 
synergies  which  are  critical  to  ensure  a  better  functioning  of  the  PHR  as  concerns 
prevention and early detection of and action against outbreaks, necessary to achieve the 
desired  socio-economic  and  environmental  benefits  (including  reinforced  export 
potential). 

EU financial support for surveillance for and eradication of new pests and priority pests 
will  help  to  timely  detect  and  eradicate  outbreaks,  more  than  in  Option  2  where  it  is 
questionable whether MS will have the resources to meet new obligations to carry out 
intensified  surveys.  Eradication  actions  are  also  likely  to  be  implemented  more 
robustly.  EU  co-financing  of  compensation  by  MS  to  growers  for  direct  losses  from 
eradication will remove disincentives to hide outbreaks. By making any compensations 
conditional  to  demonstrated  adherence  to  good  biosecurity  practices  and  timely 
notification of outbreaks, an incentive for prevention is introduced that is absent from 
Option 2. Supporting operators as concerns their direct losses from outbreaks of priority 
pests would encourage them to become a partner in the EU plant health regime, as they 
have asked to be. As long as operators do not receive 100% compensation at national 
level  (normally  not  the  case),  it  is  unlikely  that  EU  co-financing  of  operator  losses 
would  act  as  a  perverse  incentive  for  recklessness56.  Moreover,  the  eligibility  for  EU 
co-financing  would  be  restricted  to  the  direct  value  losses,  consequential  losses 
remaining for the grower; these could be insured or covered under mutual funds under 
the  Common  Agricultural  Policy.  Indeed,  the  FCEC  (2011)  reports  that  EU  co-
financing  of  direct  losses  is  likely  to  stimulate  the  development  of  national  mutual 
funds, which would be a welcome development. The legal proposal of the Commission 
of  12  October  2011  on  support  for  rural  development  foresees  support  for  financial 
contributions  to  farmers  for  insurances  and  mutual  funds  providing  compensation  for 
damages, including those caused by outbreaks of regulated organisms of plants. 

Option  3  balances  costs  and  benefits  for  all  parties  involved.  Other  than  in  Option  2, 
costs  for  operators  remain  stable  and  MS  costs  decrease,  while  the  economic  and 

56  Neither  seems  this  to  be  the  case  with  compensations  for  direct  losses  under  the  EU  animal  health 

regime. 

42 

 
                                                 
environmental  benefits  are  much  higher.  This  however  requires  increased  EU 
expenditures. This is justified to address the market failures outlined in Section 2.6.2, in 
particular lack of support for public good objectives. By accepting EU responsibility for 
environmental  protection  also  financially, the entire regime can function better. There 
are moreover economies of scale at EU level. It should be noted that the overall costs of 
Option 3 are just slightly higher than in Option 2, while the benefits are much higher. 
With  limited  investments  in  early  detection  and  eradication57,  large  savings  can  be 
made  as  concerns  eventual  losses  from  outbreaks  and  curative  measures  against 
outbreaks in agriculture and the natural environment. The improved cost/benefit ratio is 
due to a redistribution of costs of operators, MS and the Union. This allows introducing 
incentives  and  creating  synergies.  Option  3  converts  MS  "subsidies"  on  fees  into 
compliance  incentives  (compensation  for  losses  from  eradication  measures).  It  thus 
responsibilises the operators for bio-security and covers part of their risks, but only for 
EU priority organisms and conditional to compliance with the EU legislation.   

Using  hindsight  to  examine  which  outbreaks  of  the  past  decade  could  have  been 
avoided if Option 3 had been in place, it is likely that many outbreaks of forest pests 
could have been detected earlier and successfully eradicated with timely allocation of 
Union  resources.  Indeed,  the  successful  eradication  of  pine  wood  nematode  in  the 
Sierra de Dios Padre, Extremadura (ES) and the on-going one in Galicia would not 
have been possible without EU support. Otherwise, outbreaks are not truly eradicated 
but  suppressed  and  MS  accept  that  the  pests  gradually  spread.  Union  support  to 
competent  authorities  and  farmers  is  critical  to  enable  MS  to  take  the  necessary 
drastic measures, financially and at a political level.  

Option  4  –  Prioritise,  modernise,  step  up  prevention,  reinforce  actions  against 
outbreaks and expand the scope to IAS plants 

The  coverage  of  invasive  plants  results  in  additional  benefits  to  the  environment, 
however with potentially high costs to the MS and the EU. As long as IAS plants are 
not yet present in the EU, the costs of including them in the regime are minimal. Once 
outbreaks occur, the costs for surveys and eradication measures increase significantly, 
to the order of magnitude of forest pest outbreaks. Large-scale outbreaks may lead to a 
higher level of costs than incurred for the plant health regime within its current scope. 
Under the SPS Agreement, it is not allowed to prohibit import of IAS plants from third 
countries without equal domestic measures58. Regulating IAS plants thus brings along 
the risk of unexpected costs for the EU budget. In so far as the budget is limited, the 
coverage of IAS plants would  be detrimental to the needs of the regime in its current 
form,  unless  a  different  intervention  logic  is  applied  for  IAS  plants  (but  then  it  is 
questionable to include them in the PHR). By lifting out IAS plants from the new IAS 
policy,  Option  4  might  in  due  course  result  in  policy  inconsistencies  with  the  overall 
IAS policy objectives, due to inappropriateness  of a  stamping-out approach in natural 
habitats  of  environmental  importance.  Managing  IAS  plants  may  require  accepting 
limited local release for gardening, where release has to be categorically prohibited for 
harmful organisms. The main tools for ensuring safe international movement of plants, 
the  phytosanitary  certificate  and  the  plant  passport,  are  of  no  use  for  regulating  the 
movement  of  IAS  plants.  Aquatic  IAS  plants  are  moreover  not  covered  by  the  IPPC. 
The management of IAS plants thus likely requires a legal instrument of its own.    

57  The  additional  costs  of  Option  3  for  the  regime  as  a  whole  as  EUR  6  million  per  year  (EUR  160.8 

million instead of EUR 154.8 million). 

58  Following  a  liberal  eradication  approach  for  IAS  plants  could  undermine  the  PHR  coherence  and 

credibility. 

43 

 
                                                 
Total annual costs of the four policy options (mio €)

Member States
Operators

EU
Total

250

200

150

100

50

0

Option 1 

Option 2 

Option 3 

Option 4 

Total annual costs for Member States, operators, the European Union and the regime 
as a whole for the four policy options (cost level based on reference year 2008) 

6.4. Preferred option 

In  the  light  of  the  assessment  above,  it  is  considered  that  Option  3  provides  the  best 
way forward to achieve the objectives with the best cost-benefit level59 and an optimal 
balance of inputs from MS, operators and the Union as a whole. Option 3 should have a 
significant  positive  impact  on  profitability  and  economic  growth  of  the  sectors 
involved; it was also the closest reflection of the overall outcome of the stakeholder and 
MS  consultation  (Annex  X).  It  addresses  the  main  concerns  of  the  stakeholders 
expressed in reply to the consultations: the need for a better functioning of the regime, 
the  need  for  partnership  in  the  regime  including  the  use  of  modern  tools  (barcodes, 
chips  etc.)  already  employed  by  them,  and  the  need  for  compensation  of  losses  of 
operators  subject  to  eradication  measures.  The  EU  budget  necessary  to  implement 
Option 3 has been secured in the Commission proposal for the MFF 2014-202060.  

The concerns on IAS can be resolved by creating the possibility in Regulation 882/2004 
for MS to utilise Border Control Posts for official controls on import of IAS plants and 
animals  (similar  to  current  arrangements  for  the  implementation  of  CITES).  This  will 
allow MS to utilise the synergies of plant (and animal) health controls and IAS plants 
controls at the border. Territorial surveillance and eradication provisions will be set up 
in  dedicated  legislation  on  IAS,  in  line  with  the  set-up  for  sectoral  plant  and  animal 
health legislation. 

59 The overall cost increase for the regime would be 8% (€11.8 mio) to avoid future losses of billions of 
Euros  per  year  (FCEC,  2011).  Assuming  that  10%  of  the  250  listed  pests  could  cause  such  huge 
damage, a cost increase of maximally €50 mio for the EU would save some €25 billion, i.e., a return 
factor of 500:1. 

60  The  limits  set  for  plant  health  expenditures  in  the  Multi-Annual  Financial  Framework  will  be 
respected. Legal access will be ensured to the crisis reserve for (animal and) plant health crises, for 
unforeseen  large-scale  outbreaks  requiring  temporarily  high  levels  of  expenditures  exceeding  the 
limits set by the MFF.  

44 

 
 
 
                                                 
Section 7: Monitoring and evaluation  

The  review  of  the  PHR  firstly  aims  to  improve  its  effectiveness.  Most  objectives 
concern improved measures against entry into, and establishment and spread of harmful 
organisms  within  the  EU.  Others  target  the  modernisation  of  the  regime's  functioning 
and governance, by more efficient use of scarce resources, rebalancing responsibilities 
and costs between competent authorities and private operators, reducing administrative 
burden  and  ensuring  a  level  playing  field.  The  following  progress indicators  could  be 
used  as  regards  the  five  specific  objectives  provided  in  Section  3.2  (regardless  of 
whether  the  legal  provisions  are  positioned  in  the  new  plant  health  Regulation  or  the 
future Regulation on official controls):  

Overall indicators 
•  Number of regulated harmful organisms that are present / not present in the Union. 
•  Total areas in the Union affected by priority organisms. 

Definition of EU priorities 
•  To  recognise  priority  harmful  organisms  with 

large  socio-economic  and 
environmental impact for the Union territory as a whole (versus organisms of more 
restricted impact).  

•  To improve the ability of the regime to smoothly deregulate harmful organisms for 

which territorial protection is no longer justified. 

→ 

Indicators: not required (addressed by changing the structure of the legislation) 

Improved prevention at import 
•  To increase the protection against high-risk trade imported into the EU. 
•  To  increase  the  preparedness  and  surveillance  for  outbreaks  of  harmful  organisms 

not known to occur in the EU and of priority organisms. 

→ 

Indicators: 
 -  Numbers  of  import  inspections  and  tests  carried  out  by  the  Member  States  
 -  Numbers of surveillance inspections and tests carried out by the Member States 
for regulated harmful organisms not known to occur in the EU and for organisms 
listed as EU priority 

Enforced eradication, containment and control  
•  To  upgrade  the  instrumentation  for  eradication  and  containment  (including 

suppression of the presence and natural spread of priority organisms). 

•  To  incentivise  notification,  eradication  and  containment  of  priority  organism 

outbreaks. 

→ 

Indicator: 
 -  Numbers  of  eradicated  /  non-eradicated  outbreaks  in  the  EU  territory  of 
regulated harmful organisms listed as EU priority 
-  Elapsed  time  from  the  detection  of  regulated  harmful  organisms  to  their 
notification 
-  Elapsed  time  from  the  detection  of  the  presence  of  priority  organisms  to  their 
eradication 

Restoration and modernisation of the regime for intra-EU movements 
•  To restore the reliability and credibility of the plant passport and protected zones. 

45 

 
 
 
 
 
•  To rebalance competent authorities' and private operators' responsibilities and costs, 

reduce administrative burden and ensure a level playing field. 

→ 

Indicators: 
 - Interceptions by MS of listed harmful organisms in consignments from other MS 
(in absolute numbers and in percentage of the trade volume) 
 -  Numbers  of  eradicated  /  non-eradicated  outbreaks  in  protected  zones 
 - Degree to which operators are satisfied with the regime's functioning and cost 
level 

Improved support for the regime 
•  To ensure cost recovery for competent authorities as concerns controls of operators 

and Union co-financing of costs incurred for public interest.  

•  To ensure the availability and quality of diagnostic and scientific support. 
•  To generate public awareness of the relevance of the regime and public support. 
→ 

Indicators: 
 - Percentages of cost recovery by MS for import and plant passport inspections  
 - Number of national and EU reference laboratories  
- Degree to which citizens are aware of the existence of the regime and support it 

Despite foreseen methodological difficulties, work is foreseen also on development of 
parameters on avoided losses, which may then serve as more direct measure of regime 
efficiency. 

The monitoring of the PHR legislation is currently included in Regulation 882/2004 and 
Directive  2000/29/EC,  which  foresee  that  MS  shall  prepare  integrated  multi-annual 
control  plans  and  report  annually  on,  among  others,  the  results  of  controls  and  audits 
and the type and number of non-compliances identified. Specific reporting obligations 
also  exist  in  the  Control  Directives  for  harmful  organisms  of  potato  and  the  various 
Emergency  Measures.  The  indicators  listed  above  are  a  part  of  the  existing  general 
reporting obligations under Regulation 882/2004, albeit without reference to the above 
specific indicators.  

The plant health Regulation will contain provisions for the Member States to annually 
collect  the  data  pertinent  to  the  above-mentioned  indicators  in  so  far  as  they  relate  to 
concrete  parameters  linked  to  official  activities  carried  out  by  them  (numbers, 
percentages,  elapsed  time,  cost  recovery  rate).  The  Member  States  will  be  asked  to 
provide these data prior to the entry into force of the Regulation so as to determine the 
baseline level of the parameters. 

The  measurements  of  the  degree  to  which  operators  are  content  with  the  functioning 
and cost level of the regime, and the degree to which citizens are aware of the regime 
and  support  it,  are  a  new  element.  These  measurements  should  not  be  carried  out 
annually, but will be a part of the recurrent future evaluation of the regime, along with 
the evolution of the above-mentioned indicators and the EU financial expenditures. The 
first evaluation of the Regulation will take place seven years after the Regulation will 
have become applicable. 

46 

 
 
 
Literature 

Animal  and  Plant  Health  Inspection  Service  (APHIS)  –Plant  Protection  and  Quarantine 
(PPQ),  2011.  Road  Map  to  2015:  A  strategic  plan  for  plant  protection  and  quarantine. 
http://www.aphis.usda.gov/plant_health/downloads/PPQStrategicPlan2015.pdf   

APENET,  2010.  Effects  of  coated  maize  seed  on  honey  bees.  Report  based  on  results 
obtained  from  the  second  year  of  activity  of  the  APENET  project.  CRA-API  (online) 
http://www.reterurale.it/apenet   

BIO  Intelligence  Service,  2011.  Disturbances  of  EU  forests  caused  by  biotic  agents.  Final 

report. http://ec.europa.eu/environment/forests/pdf/FBD_report_2012.pdf  

Brasier, C.M. & Buck, K.W., 2001. Rapid evolutionary changes in a globally invading fungal 

pathogen (Dutch elm disease). Biological Invasions 3: 223-233. 

Breukers,  A.  2007.  Bio-economic  modelling  of  brown  rot  in  the  Dutch  potato  production 

chain. PhD Thesis, Wageningen University. 142 pp. 

Breukers,  A.  et  al.,  2007  Cost-effective  control  of  a  quarantine  disease:  a  quantitative 
exploration  using  'Design  of  Experiments'  methodology  and  bio-economic  modeling, 
Phytopathology Vol. 97, No. 8, 2007 945-957. 

Breukers,  A.  et  al.,  2008.  Costs  and  benefits  of  controlling  quarantine  diseases:  a  bio-

economic modelling approach, Agricultural Economics 38 (2008) 137-149. 

Bruce,  T.J.A.,  2010.  Tackling  the  threat  to  food  security  caused  by  crop  pests  in  the  new 

millennium. Food Security 2: 133-141.  

CABI/EPPO, 1997. Quarantine Pests for Europe, 2nd edition (Ed. by Smith, I.M.; McNamara, 

D.G.; Scott, P.R.; Holderness, M.). CAB International, Wallingford, UK. 

Eiswerth,  M.E.,  Johnson,  W.S.,  Agapoff,  J.,  Darden,  T.D.  &  Harris,  T.R.,  2005.  Economic 
impacts  from  the  effects  of  invasive  weeds  on  outdoor  recreation:  an  input-output  model. 
University of Nevada, Special Publication SP-05-06. 

European  Commission,  2008.  Communication  from  the  Commission  to  the  Council,  the 
European Parliament, the European Economic and Social Committee and the Committee of 
the Regions. Towards an EU strategy on invasive species. SEC(2008) 2887 et SEC(2008) 
2886. 

European  Commission,  2011.  Communication  from  the  Commission  to  the  European 
Parliament,  the  Council,  the  Economic  and  Social  Committee  and  the  Committee  of  the 
Regions.  Our  life  insurance,  our  natural  capital:  an  EU  biodiversity  strategy  to  2020. 
COM(2011) 244 Final. 

European  Commission,  2011.  Communication  from  the  Commission  to  the  European 
Parliament, the Council, the European Economic and Social Committee and the Committee 
of the Regions. A budget for Europe 2020 – Part II: Policy fiches. COM(2011) 500 Final. 

Eurostat, 2007. The use of plant protection products in the European Union. Data 1992-2003. 

FAO,  2006.  World  agriculture:  towards  2030/2050.  Prospects  for  food,  nutrition,  agriculture 
and  major  commodity  groups.  Food  and  Agriculture  Organization  of  the  United  Nations, 
Global Perspective Studies Unit, Rome. 

Food Chain Evaluation Consortium, 2008. Interim evaluation Phytosanitary: harmful organisms 

– Financial aspects. Final report. 

47 

 
 
 
 
Food Chain Evaluation Consortium, 2008. Analysis of the socio-economic and environmental 
impacts  of  banning  or  not  banning  the  movement  of  susceptible  wood  products  from 
Portugal for stopping the spread of pine wood nematode (PWN). Final report. 

Food Chain Evaluation Consortium, 2009. Analysis of the economic, social and environmental 
impacts  of  options  for  the  long-term  EU  strategy  against  Diabrotica  virgifera  (Western 
Corn  Rootworm),  a  regulated  harmful  organism  of  maize,  to  support  the  drafting  of  the 
Commission Impact Assessment. Final report. 

Food Chain Evaluation Consortium, 2010. Evaluation of the Community Plant Health Regime. 

Final report. 

Food Chain Evaluation Consortium, 2011. Quantification of costs and benefits of amendments 

to the EU plant health regime. Final report. 

Fried,  G.,  2010.  Liste  de  plantes  exotiques  envahissantes  à  prendre  en  compte  de  manière 
prioritaire  pour  le  CPHR  révisé.  Ministère  de  l'agriculture  et  de  la  pêche,  laboratoire 
national de la protection des végétaux. 

Hepting, G.H., 1974. Death of the American chestnut. Journal of Forest History 18: 60-67. 

Kimura,  S.  &  Antón,  J.,  2011.  Risk  management  in  agriculture  in  Australia.  OECD  Food. 
(DOI 

Agriculture  and  Fisheries  Working  Papers,  No.  39.  OECD  Publishing 
10.1787/5kgj0d8bj3d1-en). 

Lowe,  D.,  2009.  Current  situation,  management  and  economic  impact  of  citrus  canker  in 
Florida. http://www.calcitrusquality.org/wp-content/uploads/2009/05/current-situation2.pdf  

Marzaro, M., Vivan, L., Targa, A., Mazzon, L., Mori, N., Greatti, M., Petrucco Toffolo, E., Di 
Bernardo,  A.,  Giorio,  C.,  Marton,  D.,  Tapparo,  A.  &  Girolami,  V.,  2011.  Lethal  aerial 
powdering of honey bees with neonicotinoids from fragments of maize seed coat. Bulletin 
of Insectology 64: 119-126. 

Melyukhina,  O.,  2011.  Risk  management  in  agriculture  in  The  Netherlands.  Agriculture  and 
Fisheries Working Papers, No. 41. OECD Publishing (DOI 10.1787/5kgj0d5lqn48-en). 

Nauen,  R.,  2011.  The  development  and  role  of  chemical  solutions:  an  IRAC  perspective. 

Workshop organised by Copa-Cogeca on Tuta absoluta, Brussels, 21 June 2011. 

OECD,  2011.  Managing  Risk  in  Agriculture:  Policy  Assessment  and  Design.  OECD 

Publishing. http://dx.doi.org/10.1787/9789264116146-en 

O'Grada, C., 2002. Ireland's Great Famine: interdisciplinary perspectives. Dublin Press. 

Økland,  B.  &  Skarpaas,  O.,  2008.  Draft  pest  risk  assessment  report  on  the  small  spruce  bark 
beetle, Ips amitinus. Commissioned report from Norwegina Forest and Landscape Institute, 
10/2008. ISBN 978-82-311-0058-4. 

Pimentel,  D.  (editor),  2011.  Biological  invasions:  economic  and  environmental  costs  of  alien 

plant, animal, and microbe species (2nd edition). CRC Press. 

Pimentel, D., Lach, L., Zuniga, R. & Morrison, D., 2000. Environmental and economic costs of 

nonindigenous species in the United States. Bioscience 50: 53-64. 

Pimentel,  D.,  Zuniga,  R.  &  Morrison,  D.,  2005.  Update  on  the  environmental  and  economic 
costs associated with alien-invasive species in the United states. Ecological Economics 52: 
273-288. 

Pluess,  Th.,  Cannon,  R.,  Vojtĕch,  J.,  Pergl,  J.,  Pyšek,  P.  &  Bacher,  S.,  2012.  When  are 
eradication  campaigns  successful?  A  test  of  common  assumptions.  Biological  Invasions, 
Springer Science + Business Media B.V. (DOI 10.1007/s10530-011-0160-2) 

Rafoss,  T.  &  Sletten,  A.,  2004.  Quantitative  pest  risk  assessment  for  the  potato  brown  rot 
bacterium Ralstonia solanacearum (race 3 biovar 2) in fresh potato imports to Norway from 
Egypt. The Norwegian Crop Research Institute, 04/201-15-endelig. 

48 

 
Robinet,  C.,  Van  Opstal,  N.,  Baker,  R.  &  Roques,  A.,  2011.  Applying  a  spread  model  to 
identify  the  entry  points  from  which  the  pine  wood  nematode,  the  vector  of  pine  wilt 
disease, would spread most rapidly across Europe. 

Schrader, G., Unger, J.G. & Starfinger, U., 2010. Invasive alien plants in plant health: a review 

of the past ten years. EPPO Bulletin 40: 239-247. 

Shine, C., Kettunen, M., Genovesi, P., Gollasch, S., Pagad, S. & Starfinger, U. 2008. Technical 
support to EU strategy on invasive species (IAS) – Policy options to control the negative 
impacts of IAS on biodiversity in Europe and the EU (Final module report for the European 
Commission). Institute for European Environmental Policy (IEEP), Brussels, Belgium. 104 
pp. + Annexes. 

Shine,  C.,  Kettunen,  M.,  Genovesi,  P.,  Essl,  F.,  Gollasch,  S.,  Rabitsch,  W.,  Scalera,  R., 
Starfinger, U. & Ten Brink, P., 2010. Assessment to support continued development of the 
EU Strategy to combat invasive alien species. Final Report for the European Commission. 
Institute 
(IEEP),  Brussels,  Belgium. 
(http://ec.europa.eu/environment/nature/invasivealien/docs/IEEP%20report_EU%20IAS%2
0Strategy%20components%20%20costs.pdf) 

for  European  Environmental 

Policy 

Skarpaas,  O.  &  Økland,  B.,  2009.  Timber  import  and  the  risk  of  forest  pest  introductions. 

Journal of Applied Ecology 2009 (46): 55-63. 

Stenlid,  J.,  Oliva,  J.,  Boberg,  J.B.  &  Hopkins,  A.J.M.,  2011.  Emerging  diseases  in  European 

forest ecosystems and responses in society. Forests 2: 486-504.  

Taylor,  B.W.  &  Irwin,  R.E.,  2044.  Linking  economic  activities  to  the  distribution  of  exotic 
plants. Proceedings of the National Academy of Sciences (USA) 101(51): 17725-17730.  

United  States  General  Accounting  Office,  2000.  Invasive  species.  Federal  and  selected  State 
funding  to  address  harmful,  nonnative  species.  Report  to  Congressional  Committees 
GAO/RCED-00-219. 

Van Asseldonk, M.A.P.M., Breukers, M.L.H., Benninga, J., Bremmer, J., Hennen, W.H.G.J. & 
Slobbe, R., 2011. Risicoanalyse Q-organismen in de glastuinbouw. Agricultural Economics 
Research 
2011-054. 
http://www.lei.wur.nl/NL/publicaties+en+producten/LEIpublicaties/?id=1389   

Wageningen, 

LEI-rapport 

Institute, 

Van der Weijden, W., Leewis, R. & Bol, P., 2007. Biological globalisation. Bio-invasions and 

their impacts on nature, the economy and public health. KNNV Publishing, Utrecht. 

Vocke, G., Allen, E.A., & Price, J.M., 2010. The economic impact of karnal bunt phytosanitary 
wheat  export  certificates.  Economic  Research  Service,  United  States  Department  of 
Agriculture, report WHS-10h-01. World Agricultural Outlook, August 2010. 

Waage, J.K., Mumford, J.D., Leach, A.W., Knight, J.D. & Quinlan, M.M., 2007. Responsibility 
and cost sharing options for quarantine plant health. Report to Department for Environment, 
Food  and  Rural  Affairs,  London,  United  Kingdom.  Centre  for  Environmental  Policy, 
Imperial College London, Ascot, United Kingdom. 

Wesseler,  J.  &  Fall,  E.H.,  2010.  Potential  damage  costs  of  Diabrotica  virgifera  virgifera 
infestation in Europe – the 'no control' scenario. Journal of Applied Entomology 134: 385-
394.  

Williams,  F.,  Eschen,  R.,  Harris,  A.,  Djeddour,  D.,  Pratt,  C.,  Shaw,  R.S.,  Varia,  S., 
Lamontagne-Godwin,  J.,  Thomas,  S.E.  &  Murphy,  S.T.,  2010.  The  Economic  Cost  of 
Invasive Non-Native Species on Great Britain. CAB Report 001/09.  

49 

 
 
Annexes 

Annex I: Executive summary of the evaluation report 

For the complete report, see: 
http://ec.europa.eu/food/plant/plant_health_biosafety/rules/docs/final_report_eval_en.p
df 

50 

 
 
 
 
 
European Commission 
Directorate General for Health and Consumers 

EVALUATION OF THE COMMUNITY PLANT HEALTH REGIME 

Framework Contract for evaluation 
and evaluation related services - Lot 3: Food Chain 
(awarded through tender no 2004/S 243-208899) 

Final Report 

Prepared by: 
Food Chain Evaluation Consortium (FCEC) 
Agra CEAS Consulting - Civic Consulting - 
Van Dijk Management Consultants - 
Arcadia International 

Project Leader: Agra CEAS Consulting 

31 May 2010……………………………………

51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Contact for this assignment: 

 Dr Maria Christodoulou  
Agra CEAS Consulting  

20-22 Rue du Commerce 
1000 Brussels  

Phone:      +32 2 736 00 88 
maria.christodoulou@ceasc.com  

EVALUATION OF THE COMMUNITY PLANT HEALTH REGIME 

Final Report 

Prepared by the Food Chain Evaluation Consortium (FCEC) 
Civic Consulting – Bureau van Dijk – 
Arcadia International – Agra CEAS 

Project Leader: Agra CEAS Consulting  

Food Chain Evaluation Consortium 
Civic Consulting – Bureau van Dijk – Arcadia International – Agra CEAS

fcec  

52 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
FCEC Expert Team 

Agra CEAS Consulting: 
Dr. Maria Christodoulou 
Conrad Caspari 
Lucia Russo  
John Nganga 
Prof. 
John  Mumford 
College, London): advisory role 

(Imperial 

Bureau van Dijk: 
Laurence Van Nieuwenhuyse 
Sonia Gonzalo  
Sylvie Barel 
Stephanie Matte 

Arcadia International: 
Daniel Traon 

Acknowledgements 

The evaluation team would like to thank all authorities and stakeholders contacted during the 
project for their contribution to this evaluation. We would also like to thank the members of 
the steering group and the various Commission services as well as international organisations 
involved for their valuable assistance and support throughout the evaluation. 

53 

 
 
 
 
 
 
 
 
 
 
 
 
Key messages of the Evaluation 

•  Over the period covered by this evaluation (from the launch of the single market on 1 January 1993 
until now), the Community Plant Health Regime (CPHR) has contributed significantly to prevent 
the introduction and control the spread of pests affecting plant health in the European Union.  

•  Despite  this  positive  conclusion  overall,  the  objectives  of  the  CPHR,  as  defined  in  the  EU  legal 
basis (Directive 2000/29/EC and legislation on emergency and control measures), are considered to 
have been only partially met. A number of shortcomings and weaknesses have been identified, and 
these point to the need for improvements to the system. 

•  Over  the  period  under  review,  and  particularly  in  more  recent  years,  plant  health  risks  have 
increased  while  the  EU  has  expanded.  New  and  increased  risks  are  due  both  to  globalisation 
(including  the  expansion  of  trade)  and  climate  change.  These  challenges  call  for  a  review  of  the 
current system. 

•  Options  for  the  future  have  been  developed  and  a  preliminary  analysis  of  these  options  was 
undertaken in the course of the evaluation. As a result, key recommendations are made, based on a 
preliminary analysis of the balance between advantages/disadvantages and anticipated impacts. 

•  At the core of the recommendations is the need to modernise the system through: more focus on 
prevention; better risk targeting (prioritisation); and, more solidarity (moving from an MS based to 
EU approach for more joint action to tackle risks of EU significance).  

•  In this context, it is recommended to: 

- 

- 

- 

- 

- 

- 

- 

- 

Include in the scope of the future EU PH regime Invasive Alien Species (IAS) plants with 
wider/environmental  impacts  (on  habitats  and  ecosystems)  and/or  economic  impacts  on  a 
wider range of stakeholders (Recommendation 1). 

Explicitly include natural spread in the regime, and – where deemed necessary on a case by 
case basis – cover by the solidarity regime (Recommendation 2). 

Adopt  a  zero  tolerance  regime  (i.e.  including  Regulated  Non  Quarantine  Pests  with  zero 
tolerance), and further explore potential synergies with S&PM regime (Recommendation 3). 

Take  complementary  measures  on  imports,  in  particular:  for  emerging  risks,  e.g.  on  new 
trade  in  plants  for  planting/propagating  material  (PM):  commodity  pathway  analysis; 
strengthen measures for plants for planting/PM  via official post entry inspections for latent 
harmful  organisms  (HOs)  and,  on  the  basis  of  commodity  pathway  analysis,  proceed  to 
import bans where necessary (Recommendation 4).  

Introduce  mandatory  general  epidemio-surveillance  at  EC  level  for  priority  HOs,  after 
exploring  further  the  process  and  criteria  to  be  used  for  the  identification  and  selection  of 
HOs, and scope and method of surveillance; develop common principles and guidelines for 
harmonized  surveillance/reporting;  and,  introduce  co-financing  to  improve  surveillance 
(Recommendation 5). 

Step up emergency action, via: horizon scanning; compulsory development of contingency 
plans according to a harmonized framework; and speeding up the process for adoption and 
adaptation of both emergency and control/eradication measures (Recommendation 6).  

Improve  the  Plant  Passport  (PP)  system,  in  particular  by  revising  the  scope  of  application 
and harmonising the PP document (Recommendation 7).  

Tighten the system of Protected Zones (PZ), in the short term by improving the status quo, 
and longer term by further examining the implications of applying the IPPC Pest Free Area 
(PFA) concept (ISPM 4) more widely (Recommendation 8).  

52 

 
 
 
- 

- 

- 

- 

- 

Improve  incentives  throughout  the  system  by  extending  the  current  scope  of  solidarity  to: 
cover  the  loss  of  destroyed  material  for  producers/growers;  enable  co-financing  of  new 
measures  e.g.  surveillance,  contingency  planning.  Carry  out  further  analysis  on  the 
possibility  of  introducing  cost-responsibility  sharing  schemes,  in  line  with  the  ongoing 
development of this concept in the animal health field. (Recommendation 9). 

Improve support activities in terms of  R&D  and scientific advice: promote  more sufficient 
and  stable  EU  and  MS  resources  for  funding  and  coordinating  research  (e.g.  structural 
budget  within  the  CPHR  in  addition  to  the  FP7);  continue  EUPHRESCO;  identify  the 
appropriate  structures  to  address  the  economic  impact  of  Pest  Risk  Assessment  (e.g. 
PRATIQUE  follow  up;  SANCO/EFSA  and  EPPO  cooperation)  (Recommendation  10). 
Enhance  diagnostic  capacity  by  completing  the  establishment  of  National  Reference 
Laboratories  in  MS  and  establishing  EU-Reference  Laboratories  for  a  limited  number  of 
priority HOs (Recommendation 11). Continue and strengthen training activity for inspectors 
and extend the training to experts in the diagnostics field (Recommendation 12). 

Improve  organisational  aspects:  establish  an  EU/MS  Emergency  Team  for  Plant  Health 
(within DG SANCO supported by an extended network of MS experts), as is practiced for 
animal  health  (Recommendation  13);  developed  and  implement,  both  at  EU  and  MS  level, 
public awareness campaigns to improve awareness of plant health issues (Recommendation 
14). 

This  evaluation  of  the  CPHR  performance  to  date,  and  in  particular  of  the  financial 
framework  (solidarity  regime)  has  extensively  highlighted  the  mismatch  between  currently 
available  resources  and  targeted  objectives  and  this  underpins  many  of  the  identified 
shortcomings and weaknesses. The analysis of options for the future has in all cases pointed 
to  the  need  to  increase  resources  and/or  prioritise  to  meet  the  objectives  set  out  in  these 
options.  The Commission will have to reflect on the best options to follow. The evaluation 
results have also confirmed the conclusions of the solidarity regime evaluation, according to 
which, a financial instrument is needed to ensure better preparedness in case of emergency.  

In this context, the evaluation recommends that the merits of developing a specific financial 
instrument  in  this  sector,  possibly  in  the  form  of  a  Plant  Health  Fund  (drawing  a  parallel 
from the Animal Health Fund), is examined further (Recommendation 15). 

53 

 
 
 
Executive Summary 

S.1.  Background and scope of the evaluation 

This evaluation1 of the Community Plant Health Regime (CPHR) 2  was launched by DG SANCO with 
the support of the Council3. It covers the period from 1993 to date, i.e. since the introduction of the 
internal market. The basic structure of the current CPHR was established in 1977 (Council Directive 
77/93/EEC); since the 2000 codification, the basic legal framework is Council Directive 2000/29/EC4. 

Since  its  inception  in  1977,  various  major  changes  and  developments  justify  a  comprehensive 
evaluation of the regime. Apart from the introduction of the internal market concept in 1993 and its 
implications in terms of reassessing the balance between intra-Community free trade and prevention of 
the  introduction/spread  of  Harmful  Organisms  (HOs),  other  major  developments  include:  the 
successive  EC  enlargements,  in  particular  the  addition  of  12  new  Member  States  (MS)  in  2004  and 
2007; the establishment of the WTO - SPS Agreement and the EC accession to the International Plant 
Protection Convention (IPPC), and the resulting implications for EU policy in terms of aligning with 
international standards on phytosanitary measures and adjusting to the  globalisation and rise in trade; 
global  warming  (climate  change);  changed  expectations  from  society,  the  changing    balance  of 
interests involved in the agricultural system as a whole; decreasing resources for public services; the 
increasing  role  of  Pest  Risk  Analysis  (PRA)  as  a  foundation  for  phytosanitary  measures  and  the 
availability  of  scientific  expertise  to  develop  PRA;  the  establishment  and  role  of  EFSA;  and,  the 
evolution  of  related  Community  regimes,  in  particular  in  the  field  of  seed  and  plant  propagating 
material (S&PM), and of conceptually parallel EU policy regimes, in particular the new EU Strategy 
for Animal Health (AHS). 

The evaluation had two objectives: a) to analyse the results of the CPHR to date, as compared to the 
acknowledged objectives that were set out by the Community when it was introduced; and b) to clarify 
which  aspects  of  the  current  regime  need  to  be  improved  and  to  suggest  potential  options  for 
improvement. The aim is to feed into the design of future policy in this field and the development by 
the Commission services of an EU plant health strategy. 

The analysis covered all EU 27 MS. MS data, information and views were gathered through a general 
survey of Competent Authorities (CAs) and relevant stakeholders in the 27 MS, supplemented by in 
depth  interviews  with  a  wide  range  of  stakeholders  and  experts  at  EU  and  international  level,  field 
visits  in  12  MS  and  the  review  of  5  third  country  plant  health  policies.  For  the  economic  analysis 
(administrative and other operational costs), a purpose built cost model was developed (on the basis of 
the EC Standard Cost Model) with data collected via a specific cost survey covering the EU-27 (CAs 
and stakeholders). 

S.2.  Evaluation of the performance of the CPHR to date 

Although  the  CPHR’s  scope  and  objectives,  as  they  have  developed  in  the  period  1993  to  date,  are 
considered  to  continue  to  be  both  relevant  and  appropriate,  the  general  view  nonetheless  is  that  the 
regime  has  only  partly  achieved  these  objectives  and  that  it  has  only  partly  been  effective  in 
preventing the entry, establishment and spread of HOs in the EU. 

1  This  evaluation  was  carried  out  by  the  Food  Chain  Evaluation  Consortium  (FCEC)  under  the  leadership  of 
Agra CEAS Consulting with the additional technical expertise of Professor John Mumford (Imperial College), 
and participation of two other FCEC partners Arcadia International and Van Dijk Management Consultants.  
2 The evaluation refers to the Community Plant Health regime (CPHR), for the historical analysis of the policy 
since its establishment in 1977.   
3 ECOFIN Council Conclusions of 21 November 2008. 
4 The evaluation covered the entire CPHR policy area. This includes the entire Community plant health acquis, 
its implementation in the Community and the relevant infrastructural and budgetary support. The evaluation also 
addressed the relationship of the CPHR to related Community regimes. 

54 

 
 
 
                                                 
Several of the CPHR measures and provisions are assessed to have only partly been useful or effective 
and  this  is  attributed  to  certain  key  underlying  factors.  Implementation  by  MS  is  incomplete  or  not 
harmonised,  and  these  gaps  are  often  due  to  variability  in  knowledge,  training,  interests  and 
perspectives,  traditions,  administrative  structures  and  capacities  as  well  as  resources  between  MS  in 
the EU-27, but also a lack of clarity in the provisions of the legal base as such (e.g. on Invasive Alien 
Species  -  IAS  and  natural  spread).  Furthermore,  there  are  significant  and  growing  constraints  in  the 
availability  of  staff  and  resources  devoted  to  plant  health  in  general  (EC,  MS,  research  bodies  and 
diagnostic  facilities  etc.).  Public  awareness  of  plant  health  issues  is  generally  limited,  and 
consequently political support to finance and enact the policy remains relatively weak, thus reducing 
the focus on prevention or on drastic measures at the start of the outbreaks. There is lack of incentives 
and disincentives (including in the form of sanctions/penalties), in the current system, or – where these 
exist - inadequate enforcement. Thus, for example, a lack of incentives to report and notify findings in 
a  timely  manner  constitutes  a  key  reason  for  delays  in  notifications,  which  has  ramifications  on  the 
speed,  and  thus  the  effectiveness  and  efficiency,  of  action  to  address  outbreaks.  In  emergency 
situations, the limited support and lengthy decision-making process results in measures being  taken 
too slowly, too late. In this context, it is argued that a dedicated financial instrument, e.g. in the form 
of a ‘plant health fund’ would contribute to enabling decision-makers to speed up the process. 

In addition, the assessment of the financial framework of the CPHR, which has expanded and updated 
on the independent evaluation of the  Solidarity Fund carried out in 20085, has concluded that a key 
deficiency of the current system is that it only acts a posteriori and does not cover any measures or 
activities  taken  on  a  preventive  basis,  before  or  as  soon  as,  outbreaks  or  new  findings  occur.  This 
results  in  a  loss  of  efficiency,  as  investment  on  prevention  in  the  longer  term  ensures  greater  cost 
effectiveness than measures to address outbreaks, particularly measures taken at more advanced stages 
of  an  outbreak  when  the  targeted  HO  is  established  and  may  be  fairly  widely  spread.  Generally 
speaking, the later action is taken, the more costly and less cost-effective it will be.  

The  above  highlights  that  the  current  CPHR  does  not  sufficiently  address  prevention.  Emergency 
measures  are  generally  adopted  too  late,  and  there  is  no  formal  framework  or  support  to  deal  with 
emergency situations. Contingency plans have not been systematically put in place (either at MS, or at 
EU  level).  Furthermore,  beyond  compulsory  surveillance,  the  efforts  for  more  general  surveillance 
made by MS are relatively limited (with significant variation between MS) and are not systematic or 
coordinated. The current degree of emphasis of the CPHR on prevention and early response, including 
the solidarity regime as such, is therefore judged to be largely inadequate. 

The evaluation has also addressed the question of the deadweight effects of the CPHR (‘What if no 
Community financing was in place’). The analysis of the CPHR costs and benefits during the period 
from  1993  to  date  demonstrates  that:  a)  the  budget  devoted  to  the  CPHR  to  date  remains  relatively 
limited; and b) on a case by case basis, the CPHR has had clear benefits (as discussed in particular in 
the  context  of  5  HOs:  Anoplophora  (chinensis  and  glabripennis),  Ceratocystis  (fagacearum  and 
fimbriata),  Erwinia  amylovora,  Grapevine  flavescence  dorée  and  Phytophthora  ramorum).  In 
conclusion, through the measures adopted in all these cases, the  CPHR has  contributed either to the 
avoidance of the introduction of potentially injurious HOs or to slow down their spread, resulting in 
significant overall benefits. Notwithstanding its successes, the CPHR can nonetheless be improved to 
maximise the effectiveness and efficiency of the measures taken.  

The problems identified are compounded by the changing context within which the policy operates, in 
particular the growing challenges of globalisation and climate change. Moving forward, it is noted that 
these new challenges and new risks arising from them   as evidenced by  increases in solidarity budget 
spending in recent years, will  require the adjustment of the regime for the future. 

5 This evaluation was carried out by the Food Chain Evaluation Consortium (FCEC) under the leadership of Van 
Dijk Management Consultants. 

55 

 
 
 
                                                 
S.3.  Key findings of the evaluation per thematic area 

The results and main findings of the evaluation per thematic area can be reported as follows: 

1.  Scope of the CPHR  

Natural spread  

The extent to which the current CPHR scope includes natural spread was examined with regard to the 
following two aspects: 

Inclusion of natural spread in CPHR scope: the current legislation is not explicit on ‘natural spread’ 
(as  opposed  to  man-assisted  spread),  leading  to  considerable  confusion  and  divergence  in 
interpretation amongst MS and stakeholders. From the review of the CPHR legislation, natural spread 
is  covered  by  Directive  2000/29  Article  16  which  requires  measures  to  deal  with  spread.  Article  23 
however explicitly excludes natural spread from eligibility for solidarity funding, and past experience 
has shown the shortcomings of this approach in terms of effectively targeting pests at the start of an 
outbreak (e.g. Diabrotica virgifera). Technically, the strong interaction between the natural spread and 
movement of plants, and the fact that natural spread is an inherent characteristic of any pest, make the 
distinction  of  causal  effects  on  plant  health  questionable;  ISPM  2  includes  consideration  of  natural 
spread  where  the  pest  risk  is  considered  unacceptable  and  the  phytosanitary  measures  are  feasible. 
Therefore,  there  is  need  for  clarification  of  the  CPHR  rules  on  natural  spread.  The  potential  longer 
term effects  of climate change in terms of altering patterns of natural spread of HOs in the EU also 
need to be taken into account. In view of these conclusions, options for the explicit inclusion of natural 
spread in the CPHR were developed and explored. 

Suitability  of  CPHR  intervention  logic  for  forestry,  public  green  and  natural  habitats:  the 
appropriateness  of  the  CPHR  to  address  the  control  of  HOs  in  these  sectors  is  an  issue  which  goes 
beyond  the  clarification  of  the  provisions  on  natural  spread  as  such.  Principally,  the  CPHR  should 
continue to provide protection against non-EU HOs in these sectors as is currently already the case, 
and as is the practice in the plant health legislation of third countries. Deciding on the best course of 
action in case of outbreaks of regulated non-EU HOs  in EU forests, public green or natural habitats 
(e.g. PWN and Anoplophora), however, requires consideration on a case by case basis of whether the 
potential impact (economic, environmental and social) of the pest in these sectors continues to warrant 
drastic measures under quarantine regulation (= CPHR) when initial eradication fails. Such decisions 
may  ultimately  be  political  (Commission  action  vs  MS  subsidiarity)  and  need  to  involve  close 
coordination between plant health and environment protection policy makers. 

Invasive Alien Species (IAS) 

There  is  currently  a  lack  of  common  understanding,  leading  to  considerable  confusion,  on  both  the 
definition of Invasive Alien Species (IAS) and the extent to which IAS are covered by the scope of the 
Directive.  The  defining  characteristic  of  IAS,  according  to  the  CBD  definition,  is  their  wider 
environmental impact on ecosystems. Historically, this has been considered as an indirect impact for 
the  purposes  of  Directive  2000/29,  but  in  recent  years  there  has  been  a  de  facto  shift  in 
implementation,  due  to  major  pest  incursions  with  significant  indirect,  non-commercial  or  purely 
environmental  impacts.  In  practice,  many  regulated  pests  are  IAS  which  are  already  listed  in  the 
Directive (recent examples include Anoplophora spp., Phytophthora Ramorum). There have also been 
international developments in considering IAS at the level of IPPC and EPPO, and a more general EU 
strategy  on  Invasive  Species  (IS),  following  the  CBD  definition,  has  been  developed.  There  are 
therefore extensive calls for clarification of the CPHR on this issue. The potential effects of climate 
change  in  terms  of  altering  patterns  of  alien  species  invasion  in  the  EU  also  need  to  be  taken  into 

56 

 
 
 
account.  Consequently,  options  for  the  future  regarding  the  inclusion  of  IAS  in  the  CPHR  were 
explored. 

2.  Approach followed for the classification of HOs 

The  current  classification  of  HOs  in  Directive  2000/29/EC  (several  Annexes  with  lists  for  which  a 
range of measures are foreseen, 250 HOs in total) is based on the historical approach taken by EU MS 
and therefore reflects MS and EU historic priorities on risks. Although the number of  HOs listed as 
such is not an issue for effective management at MS CA level in terms of imports from third countries, 
there is need for revision of  the lists (reviewing the approach to Annexes I and II in particular). There 
is  also  a  need  to  consider  prioritisation  of  HOs  that  are  of  EU-wide  concern  (e.g.  in  the  context  of 
pathway  analysis  for  import  inspections,  or  for  intra-EU  surveillance  measures);  especially  as 
concerns HOs occurring on EU territory. If greater prioritisation is needed, then this could be based on 
criteria to be developed, and the general survey has already pointed in the direction these could take. 
The  scope  for  prioritisation  is  explored  further  in  relation  to  options  for  the  future  to  ensure  better 
prevention and to maximise the cost-effectiveness of current measures and resources (in particular for 
import inspections and for intra-EU surveillance). 

Additions  to  the  lists  of  the  Directive,  on  the  basis  of  PRAs,  are  constrained  by  current  data 
availability and methodologies and this delays the process for listing new HOs. Longer term, the EU 
FP7 funded project PRATIQUE is expected to support the development of generic methodologies with 
a  view  to  improving  PRA  availability  on  a  systematic  basis  and  more  proactively  (before  risks 
emerge).  In  the  meantime,  the  use  of  expanded  fast-track  risk  analysis  to  speed  up  the  adoption  of 
measures (particularly in emergency situations), as well as improving cooperation between all bodies 
currently  involved  in  PRAs  (EFSA,  EPPO,  MS  CAs,  stakeholders  where  possible)  should  be 
considered.  

More generally, major limitations of the current approach are found to be the lack of horizon scanning 
and the lack of efficiency in dealing with emerging risks.  Approaches to overcome these issues are 
explored  further  under  the  options  for  the  future  (prevention  at  import  and  emergency  action, 
respectively).  

The  approach  followed  for  the  positioning  of  Regulated  Non  Quarantine  Pests  (RNQPs)  was  also 
examined.  The question is raised because in the EU, two sets of legislation currently cover the range 
of regulated pests: the Plant Health Directive 2000/29/EC and the Marketing Directives for Seeds and 
Plant Propagating Material (S&PM). In conclusion, the results of the evaluation indicate that the major 
issue of concern is the current overlap between the two sets of legislation rather than inconsistencies, 
and that a mechanism should be in place to allow careful consideration for transfer of eligible RNQPs 
between the two sets of Directives. Consequently, options for the appropriate positioning of RNQPs 
were explored.   

3.  Implementation of surveillance provisions 

Surveillance is currently compulsory only in the case of emergency, control measures and Protected 
Zones (PZs); the degree of application is variable by HOs (systematically undertaken only for potato 
diseases).  Procedures  for  surveys  (including  protocols  and  reporting  formats)  are  generally  not 
harmonised at EU level (with the notable exception of PWN), leading to varying implementation. In 
the great majority of cases notification of findings is not done in conformity with legal requirements. 
This  has  hindered  the  possibility  for  early  action  against  HOs,  and  delayed  communication  of 
information to CAs and stakeholders. There is therefore agreement on the need to introduce a quicker 
system  for  notification  of  findings  and  outbreaks  (possibly  to  be  developed  within  current 
EUROPHYT database).  

57 

 
 
 
Other (general) surveillance is carried out by some MS for certain HOs, according to MS priorities and 
following  different  procedures  and  reporting  standards.  This  affects 
to  which 
comprehensive information on the spread of HOs on the EU territory is available, thus leading to less 
effective and efficient eradication measures.  

the  extent 

The  involvement  of  POs  is  generally  limited,  despite  the  importance  of  stakeholder  involvement  in 
early action.  

There is general agreement about the importance and need of more and intensified surveillance, and 
support  for  introduction  of  compulsory  general  surveillance  at  EU  level  for  priority  HOs,  although 
views on the process and criteria to be used for the identification and selection of HOs to be subject to 
such surveillance, as well as the scope and method of surveillance, are divergent. The introduction of 
surveillance  on  a  compulsory  basis  is  associated  with  general  support  for  introduction  of  EU  co-
financing for this measure. Consequently, options for improving surveillance were explored. 

4.  Implementation of import regime 

Overall, the current system of plant health procedures and requirements as applied during the last 15 
years for commercial imports of plants and plants products have been largely effective in preventing 
the introduction of major HO threats into the EU. Nonetheless, the system has some shortcomings as 
demonstrated  by  the  fact  that  it  not  been  effective  in  all  cases.  A  number  of  weaknesses  were 
identified as follows: 

• Effectiveness of plant health border controls is highly variable between MS, and import inspections 
are  focused  on  regional/national  plant  health  issues  rather  than  pests  of  EU-wide  relevance. 
Improving  the  uniformity  of  import  inspections  could  be  addressed  by:  EU  training  (e.g.  BTSF); 
networking between inspectors; development of general guidelines; 

• Significant delays in notifications of interception at import (EUROPHYT): up to 90 days in certain 
cases. This, combined with limited processing of notifications in current system to provide targeted 
information, leads to limitations in use as a risk analysis tool, as evidenced by limited use for risk 
based inspections at MS level; 

• Identification  of  high  risk  pathways  (in  particular  plants  for  planting  including  ornamentals) 

indicates scope for a pathway approach on imports in some cases; 

• For some specific plants on which latent diseases  can be present (particularly plants for planting), 

the need for more extensive post entry inspections has been identified; 

• Current  implementation  of  derogations  is  considered  to  present  a  potential  phytosanitary  risk,  in 
particular those regarding small quantities not used for commercial purposes, and regarding transit 
consignments; 

• Widespread concern for lack of traceability from Point of Destination (PoD) back to Point of Entry 
(PoE)  as  this  could  in  theory  pose  a  problem,  due  to  the  complexity  of  trade  patterns  (including 
consignments in transit); 

• Use  of  reduced  frequency  checks  is  very  mixed  between  MS  and  remains  rather  limited  (18  MS 
have  not  applied  this  possibility),  although  for  the  8  MS  that  apply  this  system  it  is  considered  to 
have been effective. The limited use of reduced frequency is not necessarily a weakness as such, but 
suggests  that  some  MS  may  not  be  prioritising  inspection  according  to  risk  possibly  leading  to 
weaker focus on risk areas; 

• There is scope to improve and strengthen EU emergency measures, with a view to reducing delays 

and enhancing effectiveness and efficiency; 

58 

 
 
 
 
• Third countries have difficulties understanding EU requirements through the reading of legislation 

and perceived lack of uniform interpretation between MS inspection services; 

• Cooperation between plant health and customs authorities needs to be enhanced, inter alia to target 

consistency of nomenclature and to promote IT system interoperability; 

• Lack of sufficient traveller awareness of the phytosanitary risks or private imports poses significant 
risk in the absence of any measures on passenger transport and divergent policies and practices of 
MS in this area (passenger transport controls, passengers’ personal luggage allowance); 

• Underlying  the  above  shortcomings,  there  is  a  lack  of  sufficient  staff  resources  and  training  for 
authorities at all levels, to ensure full and satisfactory implementation, particularly within the current 
economic context. 

Moving  forward,  in  the  context  of  the  significant  expansion  in  trade  volumes  and  change  in  trade 
patterns  (new  products  and  sources  of  supply),  the  EU  is  faced  both  with  increasing  and  emerging 
risks of introduction of HOs. These trends, which have already been witnessed in the last decade, are 
occurring in the context of reduced administrative and financial resources at MS level for inspections. 
In  conclusion,  therefore,  better  risk  targeting  and  maximising  the  effectiveness  and  efficiency  of 
current  resources,  as  well  as  improving  the  availability  of  staff  and  resources,  are  critical  success 
factors  and  should  be  the  basis  for  future  improvements  to  address  the  challenges  ahead. 
Consequently, options for the future import regime were developed and explored. 

5.  Implementation of intra-EU movement regime (plant passport system) 

Overall, while the regime has succeeded in achieving the free circulation of plants and plants products 
within the EU, there are significant concerns on its effectiveness in terms of addressing plant health 
problems  as  such.  Perceived  inadequacies,  related  mainly  to  the  implementation  of  rules,  have 
demonstrated a certain conflict between the two objectives in practice. In particular: 

• The producer registration system is generally perceived to work reasonably well. The concerns are 
mainly related to the issuing of plant passports and the credibility of plant passport documents per 
se; 

• Although  nearly  all  MS  have  implemented  the  option  to  delegate  the  issuing  of  PPs  to  registered 
private  operators  under  official  NPPO  supervision,  the  majority  of  MS  CAS  has  nonetheless 
expressed concerns on the functioning and reliability of the system. This appears to be partly linked 
to the resources available to carry out the appropriate level of inspections and controls and to ensure 
correct  implementation.  On  the  other  hand,  for  stakeholders,  the  delegation  of  responsibilities  to 
issue  PPs  to  private  operators  has  been  a  major  step  forward  in  terms  of  facilitating  trade  and 
introducing flexibility in the current system. 

• Lack of uniformity in the application of the PP system is a particularly significant concern. This is 
associated  with  the  lack  of  a  standardised  format  for  the  plant  passport  document  and  divergent 
practices  on  the  information  contained  in  the  document  and  its  attachment  to  products.  Plant 
passports are difficult to read when too often plant passports information is being mixed with trade 
information.  There  is  an  urgent  need  for  rules/guidelines,  including  possibly  a  harmonised  plant 
passport format;  

• Although the PP document was not intended by the legislation to be a traceability tool, it can offer 
certain  elements  of  traceability.  However,  full  traceability  cannot  be  ensured  by  the  PP  document 
alone, as it is often used jointly with trade documents, and there is considerable difficulty combining 
the plant passport and the physical plant or plant products, particularly with smaller plants such as 
ornamentals. The plant passport only provides information on the previous stage in the supply chain 
and difficulties are being observed when there is a need to further trace back and/or trace forward; 

59 

 
 
 
• Six MS have not implemented exemptions for “small producers serving the local market” and for 
“products  destined  for  final  consumption”  due  mainly  to  potential  phytosanitary  risk,  but  in  those 
MS  that  have  implemented  the  exemptions  the  risk  is  considered  minor  relative  to  the  potential 
burden on these sectors. 

In  conclusion,  by  and  large,  the  implementation  of  the  current  PP  system  does  not  sufficiently  take 
into  account  risk  analysis  nor  does  it  provide  a  sufficient  guarantee  that  products  are  safe  to  move 
within the EU. In many cases, the shortcomings identified in the implementation of the current system 
have undermined the trust of both MS CAs and stakeholders on some of the provisions, and this is a 
critical success factor for restoring overall credibility in the system.  

The above findings confirm that the situation remains as challenging as highlighted in the FVO Report 
of 2005 on this subject. These concerns are particularly acute in the case of protected zones (PZs) and 
call  for  a  significant  review  of  both  systems.  Consequently,  options  for  improving  the  intra-
Community movement regime were explored. 

6.  Implementation of the Protected Zones (PZ) system 

Overall, while the concept of Protected Zones (PZs) is generally considered to be useful and effective 
in slowing down the spread of certain HOs, continued persistent variability in implementation at MS 
level has led to loss of credibility, hence undermining the usefulness of the system as a plant health 
measure.  Despite  significant  progress  in  providing  technical  justification  for  the  current  PZs  at  EU 
level,  the  general  perception  is  that  PZs  were  not  designated  only  on  technical  grounds  but  that 
significant  commercial/political  considerations  are  also  present  The  evaluation  has  found  that  these 
concerns  are  largely  linked  to  an  on-going  debate on  the  cost  and  benefit  distribution  of the  current 
implementation  of  the  PZ  system.  Moreover,  the  distribution  of  costs  and  benefits  is  generally 
assessed  from  the  perspective  of  individual  MS  or  regions,  largely  ignoring  the  cost-benefit 
distribution of the current system of PZs for the EU as a whole.  

Many of the problems of PZs are due to MS failure to apply the agreed measures and not to flaws in 
the  concept  per  se.  There  is  evidence  of  MS  failure  to  carry  out  surveillance  and  report  the  results; 
and, of certain failures in the implementation of the PZ plant passport system (‘ZP’ marking) which is 
considered to create additional administrative and financial burden for traders.  

The  consensus  view  is  therefore  that  controls  should  be  strengthened  and  legislation  fully  enforced 
(e.g. surveillance and reporting obligations) to restore the credibility of the PZ concept. In this context, 
options to pursue further the IPPC PFA concept, which is the approach followed internationally, could 
also be explored (the two concepts could potentially be applied in parallel). It is noted, however, that 
the credibility issue (vis à vis third countries) is not unique to the EU PZ system; in the WTO SPS and 
IPPC context, these are common and relatively frequently occurring problems with the application of 
the  PFA  concept.  Alternative  regionalisation  concepts  could  also  be  considered,  e.g.  Diabrotica 
virgifera may be a good example of the need for a concept using definitions of demarcated infested 
zones  and  pest-free  zones.  However  this  approach  should  be  restricted  to  limited  cases  and  not  be 
widely  applied,  to  avoid  excessive  complexity  in  the  implementation  of  plant  health  measures. 
Consequently, options for the future of the PZ system were explored. 
Ultimately, a critical success factor for the application of any regionalisation concept will be to ensure 
a fair balance between the distribution of costs and benefits at MS level and for the EU as a whole. 
This  will  need  to  be  determined  on  a  case-by-case  basis,  considering  infested  and  non-infested  MS, 
and  the  consequences  of  potential  infestation  for  the  EU  as  a  whole,  taking  into  account  liability 
aspects, incentives, feasibility and proportionality. 

60 

 
 
 
7.  Implementation of control and emergency measures 

Overall,  the  control  and  emergency  measures  have  been  partly  successful  in  preventing  the  entry, 
establishment  and  spread  of  HOs  in  the  EU.  The  effectiveness  of  the  measures  taken  tends  to  be 
specific to the HO being targeted and can vary between regions, and therefore has to be considered on 
a case by case basis.  

Additionally a distinction has to be made between emergency and control measures: while emergency 
measures are largely considered to have been ineffective on the basis that they are generally adopted 
too  late  (despite  the  fact  that  the  legislative  process  as  such  –  comitology  -  is  relatively  less 
cumbersome than for a Council Control Directive), control measures are generally considered to have 
been largely effective (despite the fact that the legislative process in this case – Council approval and 
since Lisbon Treaty (Dec. 1, 2009) co-decision Council and Parliament - is by definition longer and 
less flexible).  

Control measures for ring rot and brown rot in potatoes are considered to have been most effective. 
Critical success factors can be summarised as follows: 

• Adoption  and  implementation  of  very  strict  measures  swiftly  after  the  outbreak,  with  strict 
provisions  in  the  infested  fields  and  refined  methods  for  analysis  procedures,  and  movement 
restrictions (these apply for 4 years);  

• Application of common procedures through control Directives  with detailed obligations restricting 

free interpretation;  

• A commercial crop and therefore producers/growers and industry are concerned and economically 

motivated to act;  

• Potato sector is of high commercial/trade value and is highly integrated. 

Early  prevention  is  considered  to  remain  the  most  effective  and  efficient  approach  for  plant  health 
management.  Consequently,  recommendations  for  improving  emergency  response  were  provided. 
Options to improve the system include speeding the adoption and adaptation of emergency measures 
(based  on  the  evaluation  of  pest  situation  through  PRAs  developed  step  by  step),  and  strengthening 
emergency approach for outbreak measures inter alia via creation of emergency team (SANCO/MS) 
to coordinate EU response to emergencies (as in animal health sector). 

8.  Support activities 

Research and development and scientific advice 

The number of HOs arriving and spreading within the EU is expected to increase in the coming years 
mainly due to globalisation trends and climate change. Against these trends, it is recognised that the 
R&D expertise in plant health is declining in the majority of the most important disciplines required 
for this sector (taxonomy, entomology, diagnosis, etc.), leading to the need to further coordinate R&D 
activities  at  EU  level.  In  this  context,  the  use  of  existing  EU  R&D  programmes  (ERA-networking, 
networks of excellence, etc) is crucial, but currently not perceived to be sufficient.  

DG  RTD  supports  the  coordination  of  plant  health  research  activities  commissioned  under  national 
MS  budgets  (which  roughly  account  for  90%  of  all  such  budgets  available  in  the  EU),  through  the 
ERA-net  EUPHRESCO.  The  establishment  of  this  network  is  perceived  to  be  a  significant  step 
forward in the direction of establishing a coordinated EU R&D approach and there is wide support for 
its continuation in future.  

61 

 
 
 
 
 
EFSA  can  contribute  to  the  harmonisation  of  the  framework  for  PRA  and  the  identification  and 
evaluation of risk management options. However, the role of EFSA does not encompass the economic 
(cost/benefit)  analysis  required  in  full  PRAs  according  to  ISPM  11  and  21  and  WTO-SPS.  It  is 
therefore important to find an appropriate platform to carry out this type of analysis, which at present 
is provided on an ad hoc and exceptional basis through impact assessments. In this context, the outputs 
of the EU FP7-funded project PRATIQUE are expected to provide generic economic and modelling 
techniques to support the development of decision support tools for pest management. Finally there is 
a concern that the PRA process per se is becoming increasingly complex and this can inhibit timely 
decision-making to the detriment of effective and efficient plant health management.   

Moving  forward,  the  need  to  create  a  more  permanent  platform  to  ensure  the  continuity  of  the 
coordination and support of research and development in this field has been identified. 

Diagnostic capacity 

Overall, in the majority of MS the existing capacity is considered to allow only partially the rapid and 
reliable diagnosis of all regulated HOs, and this is mostly due to the relatively limited and decreasing 
financial and human resources. Gaps for the detection (in terms of methods and reference materials) 
are  indicated  by  several  MS,  particularly  with  regards  to  rare  or  new  HOs,  as  well  as  increasing 
difficulties to find experienced experts in specific fields as expertise is generally eroding especially in 
classical subjects (as also noted under previous section). Resources for diagnostics are in many cases 
limited  even  with  regard  to  HOs  for  which  detection  is  possible  and  in  terms  of  activities  that  the 
laboratories would technically be able to carry out.  

The  divergence  in  diagnostic  capacity  across  the  EU  is  largely  due  to  the  inherent  characteristic  of 
research  on  plant  health  which  explains  the  difficulties  of  attracting  financial  support  in  this  field: 
plant  science  is  not  a  high  priority  compared  to  other  scientific  fields  such  as  nanotechnology, 
engineering etc., and commercial interest remains limited. In those MS where plant health is important 
for trade and production, the diagnostic sector is more developed, with significant resources devoted to 
research,  a  clear  structure  and  organisation  in  place,  and  there  is  additional  funding  by  industry. 
However, only a minority of MS are in this situation.  

There  is  lack  of  cooperation  and  networking  among  MS,  although  this  is  considered  crucial  for 
overcoming  current  deficiencies.  The  contribution  of  EU  Projects,  particularly  EUPHRESCO,  is 
generally  recognised  for  having  a  positive  impact  on  networking  between  research  bodies  and 
laboratory experts, but this needs to be further strengthened. Experts stress the fact that coordination 
among activities at MS level remains the main weakness for research and diagnostics at EU level.  

A particularly weak aspect is the development of diagnostic methods, for which funding is not always 
available. There are several EU funded projects to improve diagnostic methods/protocols and update 
with  latest  technology  in  this  field  (including  DIAGPRO  (Diagnostic  Protocols),  QAMP  (whole 
genomic  DNA  amplification  methods),  QBOL  (DNA  bar  coding)  and  Q-DETECT).  At  EU  level, 
binding  protocols  for  diagnostic  methods  do  not  exist  (with  the  exception  of  some  HOs  for  potato 
diseases under control measures), but for a range of HOs, the EPPO and IPPC have issued standards 
for diagnostic methods and procedures (some 97 protocols to date). Many laboratories are currently in 
the  process  of  preparing  for  accreditation,  and  EPPO  is  working  to  share  the  experience  gained 
between laboratories. 

Moving forward, the need to establish  reference laboratories (NRLs and EU-RLs) was identified, in 
order to provide guidance on diagnostic  methods and  training, as  well as to provide maintenance of 
reference collections. 

62 

 
 
 
 
 
 
 
 
Training 

The evaluation highlighted the reduced availability of training and significant variability among MS in 
the level and quality of resources for training activities. Coupled with the lack of communication and 
cooperation  among  inspectors  of  different  MS,  this  contributes  to  the  limited  harmonisation  of 
inspection  practices  and  the  variability  in  the  effectiveness  of  import  inspections  among  MS.  Some 
EU-funded training in the field of plant health to EU NPPO services was provided in 2008 and 2009 
under the BTSF (Better Training for Safer Food) program. Moving forward, it is recommended that 
this  training  is  strengthened  and  continued,  and  that  it  is  provided  both  for  inspectors  and 
diagnosticians. 

9.  Organisational aspects 

Distribution of responsibilities 

The NPPO is the Single Authority and the Responsible Official Body within the meaning of Article 
1.A  of  Directive  2000/29  in  the  majority  of  MS;  the  current  legal  framework  is  considered  to  be 
adequate.  

As  foreseen  in  the  legal  framework,  delegation  of  certain  tasks  is  possible  under  the  authority  and 
supervision of the responsible official bodies. This is currently done by approximately half of the MS 
and mainly concerns the conducting of official checks, control and inspections and the conducting of 
official laboratory analysis; these tasks are delegated mainly to public bodies. Although the majority 
of MS CAs consider that the public resources devoted in their country to the duties and tasks derived 
from the CPHR are insufficient, in the context of  the present evaluation the majority view has been 
that there is limited need or opportunity for further delegation of tasks to other bodies or legal persons. 
However,  in  view  of  the  recent  amendment  of  Dir.  2000/29  with  regard  to  delegation  of  laboratory 
testing,  it  is  recommended  that  further  study  is  undertaken  on  this  issue.  This  would  be  particularly 
relevant  in  view  of  the  resource  constraints  extensively  reported  and  identified  throughout  this 
evaluation,  and  the  need  for  increased  collaboration  and  responsibility  sharing  among  CAs  and 
stakeholders. Delegation should be carefully examined considering the different capacities existing in 
the MS, to ensure a high degree of quality, independence and impartiality. The evaluation highlights 
the  general  lack  of  incentives  as  regards  the  timely  reporting  of  outbreaks  and  the  effective 
implementation of control measures, and the limited current availability of mechanisms that would act 
as  incentives,  both  for  private  operators  and  CAs  (e.g.  compensation  schemes,  solidarity  regime). 
Options to improve these aspects were explored. 

FVO activities 

The  role  and  functions  of  the  FVO  are  considered  highly  useful  and  important  for  monitoring  and 
contributing to harmonising the implementation of the CPHR in the MS and for the improvement of 
compliance  with  EU  import  requirements  from  Third  Countries  (TCs).  It  is  however  noted  that  the 
follow-up  of  missions  is  as  important  as  the  missions,  and  therefore  measures  to  ensure 
implementations of recommendations should be in place. The main constraint to the work of the FVO 
is  the  limited  availability  of  resources;  an  increase  in  FVO  resources  would  enable  some  of  the 
suggestions made for future improvement (e.g. missions to TCs, as these are considered to be highly 
useful). 

EUROPHYT 

EUROPHYT  has  proved  to  be  a  useful  tool  for  the  exchange  of  information  among  MS  on 
interceptions of HOs. However, this mainly applies to imports, as there is no legal obligation in place 

63 

 
 
 
 
for systematic reporting of findings in plant material from other MS. It is recommended therefore that 
the use of EUROPHYT for compulsory notification should be extended from trade with third countries 
to intra-Community movements.  

Another  set  of  improvements  is  suggested  in  order  to  make  the  system  more  user-friendly  (e.g. 
improved  search  engines),  to  increase  readability  and  usability  of  data  for  inspection  targeting  (e.g. 
data elaboration) and to increase the usefulness for signalling upcoming threats (e.g. modification of 
information required).  

Communication and consultation 

The  current  communication  activities  around  the  CPHR  are  generally  perceived  to  be  limited,  and 
confined  mainly  at  public  authority  level  (between  COM  and  MS  authorities).  There  are  significant 
calls  for  more  transparency  in  the  decision-making  process  (based  upon  risk  analysis)  and  the 
communication of actions to stakeholders. 

The current level of consultation in CPHR decision-making is generally perceived by stakeholders to 
be  relatively  limited,  with  traders  seen  as  more  represented  via  their  organisations  than 
producers/growers (in part due to less divergence of interests within the representative organisations). 
It is generally acknowledged that the CPHR has to seek a fine balance between conflicting interests 
(i.e. trade interests versus production interests, divergent interests across MS depending on production 
and  trade  interests).    Furthermore,  it  is  stressed  that  the  interests  of  stakeholders  may  not  fully 
correspond  to  plant  health  protection  objectives.  Plant  health  encompasses  significant  public  good 
components  and,  in  this  context,  plant  health  authorities  consider  that  the  interests  of  stakeholders 
should be taken into account insofar they are in line with plant health objectives, which are considered 
the  overriding  priority  for  policy  making  in  this  field.    On  the  other  hand,  stakeholders  call  for  a 
proportionate and balanced approach in deciding on plant health measures, based on appropriate PRA. 
More generally, the need for raising public awareness on plant health was also identified. 

10.  Costs and benefits of the CPHR 

The impacts of plant diseases can be as devastating as animal diseases. Based on existing studies, past 
cases of HOs introduced and established in the EU, as well as estimates of potential impacts, the costs 
associated with plant diseases can be substantial, and ultimately the scale of the impact can potentially 
reach  those  recorded  in  the  case  of  animal  diseases.  For  example,  in  the  case  of  Bursaphelenchus 
xylophilus (PWN) the control costs of the disease in PT have reached some 40 million € in the period 
1999-2008 (including solidarity funding); the potential economic impact of failure to act could reach 
some 5 billion €/year from the potential destruction of some 10-13 million ha of susceptible coniferous 
trees (50-90% mortality rate). Other cases not specific to the EU, but that have occurred elsewhere, are 
an example of the potential scale of impact that could be reached. Ultimately, in value terms, in the 
EU, the share of production and exports of plants and plant products in the total value of agricultural 
production and exports is comparable to that of animals and animal products.  

The actual and potential scale of impacts also highlights the extent of the benefits where the CPHR has 
effectively contributed both to avoiding the introduction of potentially injurious HOs and to slowing 
down  their  spread.  A  case  study  of  5  HOs  (Anoplophora  (chinensis  and  glabripennis),  Ceratocystis 
(fagacearum  and  fimbriata),  Erwinia  Amylovora,  Grapevine  Flavescence  dorée  and  Phytophthora 
ramorum6) demonstrates substantial benefits.  

6  HOs  selected  out  of  a  total  203  combinations  (MS  x  HO)  for  which  the  benefits  of  the  CPHR  were  widely 
attributed by respondents to the specific cost survey, although not necessarily representing absolute success cases 
across the EU-27. 

64 

 
 
 
                                                 
The overall benefits of avoiding or delaying the introduction and spread of any HO in the EU include 
not only the avoidance or reduction of agricultural losses and gain in competitiveness for which the 
private  sector  is  the  main  beneficiary,  but  extend  to  the  avoidance  or  reduction  of  damage  to 
ecosystems,  biodiversity  and  rural  communities  from  which  the  wider  society  benefits.  The  strong 
public good components of the CPHR are therefore highlighted. 

The CPHR is considered to have been partly successful in preventing the introduction and spread of 
HOs,  with  success  highly  dependent  on  the  targeted  HO.  The  main  lesson  drawn  from  the  cases  of 
failure or partial failure (e.g. PWN; Rhynchophorus ferrugineus - red plam weevil; Tuta Absoluta) is 
the need to act quickly and decisively in case of introduction. Currently, the evaluation of the situation 
before taking measures is, sometimes, too slow or not decisive enough in responding to phytosanitary 
emergencies. A critical factor, in this context, for determining the success or failure of phytosanitary 
measures taken in any sector will be the availability of incentives for action at all levels.   

CPHR provisions have provided the most effective protection as regards the HOs covered by the EU 
Control Directives (e.g. potatoes) for a range of reasons, mainly relating to the focus of the measures 
in a specific sector and the availability of incentives. By contrast the least effective protection appears 
to  be  provided  in  sectors  where  there  is  currently  lack  of  clarity  in  measures  and  which  are  highly 
complex  with  a  broader  spectrum  of  affected  stakeholders  and  potentially  conflicting  interests;  this 
includes both some commercial production sectors and public / private green space.  

The evaluation has confirmed the results of the earlier (2008) evaluation of the solidarity regime, in 
that the incentives provided by the regime remain relatively limited in a number of areas (intervention 
ex-post; exclusion of production losses; difficulty of assigning responsibility, particularly in cases of 
natural spread; lack of disincentives; non effective enforcement of penalties); in all these areas there is 
considerable  room  for  improvement  of  the  solidarity  regime.  A  major  gap  is  considered  to  be  the 
exclusion  of  coverage  of  costs  and  losses  incurred  by  private  operators.  However,  there  is  a  lack  of 
data on the extent and scale of these costs, for which further cooperation with stakeholders is needed, 
as this is a crucial element for examining any revisions to the current system. 

Costs and responsibility sharing schemes are generally considered to be the appropriate tool to provide 
incentives  for  government  and  private  operator  enforcement  and  compliance.  The  choice  of  tools 
(government contributions; private sector based) needs to be pursued on a case by case basis, where 
feasible. The generalised application of private sector schemes is constrained by industry specificities 
and structures and where the plant health threat has an environmental, public good component. In such 
cases, there are strong arguments for government supported compensation schemes. 

The  total  administrative  and  other  operational  costs  of  the  CPHR  were  estimated  on  the  basis  of  a 
purpose-built  cost  model  (applying  the  methodology  of  the  EC  Standard  Cost  Model),  with  data 
provided by MS through the specific cost survey. In total, based on the data provided for 24 MS7, the 
total costs associated with the 13 CPHR obligations selected for the analysis amount to €148,799,204 
on average per year, of which €57,191,859 are administrative costs and €91,607,345 are compliance 
costs. The total average annual costs for the 24 MS CAs amount to €59,218,314 (net of fees), of which 
8.5% are administrative costs). These costs cover the three most important obligations of the CPHR, 
which  are:  import  inspections.  inspections  at  the  place  of  production;  and,  the  compulsory  annual 
surveys of HOs regulated under the emergency measures and the Control Directives. The total amount 
recovered by the 24 MS CAs through fees charged to the private operators pursuant to Article 13d(1) 
of  Directive  2000/29/EC  is  estimated  at  €36,914,993.  In  addition  to  the  above  costs,  based  on  data 
provided by 18 MS CAs, the costs of eradication and control measures amounted to €132,139,696 in 
total during 1993-2008. The total administrative costs for private operators (same 24 MS) amount to 
€51,445,518 on average per year, with the obligation to keep records representing 80.42% of the total.  

7 Of the 25 MS that responded to the specific cost survey, the analysis was only possible for 24 MS, as in the 
case of 1 MS the response was incomplete.  

65 

 
 
 
                                                 
Finally, the total cost on average per year for the European Commission is estimated at €1,881,066, of 
which 38.3% is the administrative cost.  

The  evaluation  has  highlighted  a  number  of  areas  where  opportunities  for  cost  reduction  exist, 
including  the  quicker  adoption  measures,  the  swifter  adaptation  of  measures  taken  to  the  evolving 
situation,  and  the  provision  of  incentives  through  responsibility  sharing  and  the  solidarity  funding. 
More  generally,  enhancing  prevention  and  the  prioritisation  of  measures  present  opportunities  for 
improving the cost effectiveness of the current system. These aspects have been built into the options 
that  have  been  developed  for  the  future  (e.g.  prevention:  options  on  imports  and  on  intra-EU 
surveillance; incentives).  

S.4.  Conclusions and options for the future 

This  evaluation  of  the  various  measures  implemented  under  the  CPHR  indicates  that,  in  the  last  15 
years, the policy has only partially been effective in preventing the entry and establishment, or where 
this  has  already  occurred,  in  containing  the  spread  of  major  pest  incursions  of  significant  potential 
economic, social and environmental impact in the EU.  

The analysis of the regime’s costs and benefits since 1993 demonstrates that the budget devoted to the 
CPHR to date remains relatively limited and, on a case by case basis, the CPHR has had clear benefits 
(e.g. Anoplophora, Ceratocystis, Erwinia amylovora, Grapevine flavescence dorée and Phytophthora 
ramorum,  as  well  as  potato  brown  and  ring  rot).  Through  the  measures  imposed  in  these  cases,  the 
CPHR has contributed either to avoiding the introduction of potentially injurious HOs or to slow down 
their spread, resulting in significant overall benefits and cost prevention.  

Despite success in some cases, the regime overall has not been fully effective in meeting its objectives 
and, in its current form, was found to have both some stronger and some weaker aspects. A number of 
areas were identified where improvements are needed.  

The  identified  weaknesses  and  shortcomings  are  partly  due  to  the  fact  that  the  regime  has  been  in 
place for a long period and the world has changed. The current regime is the product of a series of ad 
hoc,  rather  than  strategic  or  systemic,  adjustments  to  the  various  developments  in  the  context  the 
regime  has  operated  in  (notably:  the  introduction  of  the  Single  Market  in  1993;  successive  EU 
enlargements in 1995, 2004 and 2007; EU international and bilateral relations). This is the first time 
that  an  opportunity  exists  to  develop  this  policy  area  on  the  basis  of  a  more  complete  and  coherent 
strategy.  A  larger  EU  of  27  MS  has  meant  that  there  is  a  more  diverse  range  of  climatic  and  pest 
situations  to  address  than  ever  before,  and  trade  is  now  truly  global  with  new  origins  and  products 
being  continuously  introduced,  often  with  very  short  timescales.    Evidence  of  failure  of  the  current 
regime to respond to new challenges is the fact that it has not prevented some major new pests from 
entering the EU (e.g. Anoplophora sp., Rhynchophorus ferrugineus, PWN), in many cases largely due 
to the fact that new pathways that pose plant health risks have been discovered too late. 

Several measures were assessed to have only partly been useful or effective. This is mostly attributed 
to  a  number  of  underlying  factors  including:  implementation  gaps  and  the  lack  of  a  harmonised 
approach between MS; significant constraints in the availability of staff and resources devoted to plant 
health at all levels (EU, MS, research bodies and diagnostic facilities etc.); the lack of clarity in certain 
legislative provisions (including on IAS and natural spread); lack of risk-based prioritisation of HOs 
and  lack  of  targeted,  risk-based  prioritisation  in  the  use  of  scarce  resources;  limited  visibility  and 
public  awareness  and  thus  political  support  to  finance  and  enact  the  policy;  lack  of  incentives  and 
disincentives  (including  in  the  form  of  sanctions/penalties)  or  –  where  these  exist  –  lack  of 
enforcement; and, the limited support and lengthy decision-making process in emergency situations, 
which  results  in  measures  being  taken  too  slowly  and  too  late.  These  factors  often  lead  to  poor 
implementation. It is noted that the extensive identification of shortcomings in MS enforcement was 
due to a combination of the above factors, in particular insufficient resources/capacity, lack of clarity 

66 

 
 
 
in some provisions of the legal base, but also the fact that infringement provisions are not effectively 
pursued against MS. 

Overall, the current level of emphasis of the CPHR on prevention and early response was found to be 
largely  inadequate.  This  lack  of  a  pro-active  approach  manifest  itself  at  various  levels:  the  CPHR 
financial  framework  (Solidarity  Fund)  only  acts  a  posteriori  and  does  not  cover  any  measures  or 
activities  taken  on  a  preventive  basis,  before  or  as  soon  as,  outbreaks  or  new  findings  occur; 
emergency measures are generally adopted too late, and there is  no formal framework or support to 
deal with emergency situations; contingency plans are not systematically put in place (either at MS, or 
at  EU  level);  efforts  to  undertake  more  general  surveillance  (beyond  compulsory  surveillance)  are 
relatively limited (with significant variation between MS) and are neither systematic or coordinated. In 
conclusion, therefore, the current policy has clearly shown some limitations. 

Moving forward, the more general conclusion that can be drawn from the analysis of future challenges 
points  to  the  evolving  nature  of  risks,  particularly  in  the  context  of  climate  change  and  increasing 
trade, and their potential far reaching impact on both commercial agriculture and forestry but also on 
the society as a whole (ecosystems, biodiversity and rural communities). It is generally acknowledged 
that globalisation is the overriding challenge, with climate change adding to the complexity and range 
of  potential  impacts.  These  challenges  are  not  unique  to  EU  plant  health  policy,  but  exert  a  wider 
impact  on  countries  around  the  world.    At  the  same  time,  MS  CAs  (National  Plant  Protection 
Organizations  -  NPPOs)  are  increasingly  confronted  with  recurrent  obstacles  at  different  levels, 
including the lack of resources and insufficient knowledge on emerging pests.  

In view of the relative success of the regime so far, the majority of MS CAs and stakeholders believe 
that the CPHR scope and objectives, as reflected in the development of the intervention logic in the 
period 1993 to date, are still being met and are still appropriate. At the same time, the majority of MS 
CAs  and  stakeholders  considered  the  current  CPHR  to  be  only  partly  suitable  to  mitigate  risks 
introduced by new challenges, in particular by climate change. On balance, the general view would be 
that  the  plant  health  regime  needs  to  respond  to  the  new  challenges,  by  building  on  those    stronger 
aspects of the regime that have been proven to work well and addressing the weaker areas: evolution 
rather than revolution is needed. A key feature of the new intervention logic developed by the FCEC 
on this basis is that it proposes an adaptation to the current regime rather than a complete change. 

The identified weaknesses and shortcomings, as well as future needs and challenges (opportunities and 
threats), point in the direction of potential options for improvement and these have been developed and 
assessed on the basis of the wide consultation carried out by the FCEC.  

At a conceptual level, the various options aim to respond to the need for: 

(cid:190)  More prevention; 

(cid:190)  Better risk targeting (prioritisation); 

(cid:190)  More solidarity: moving from MS to EU approach for more joint action to tackle risks of 

EU significance.  

S.5.  Recommendations 
The  preliminary  analysis  of  the  options  has  highlighted  those  that  represent  the  best  balance  of 
advantages/disadvantages against anticipated impacts. It is noted that options are complementary (can 
be pursued in parallel) and, in all cases, the assumption is made that the improvements suggested in 
relation to the status-quo (option i) will be taken on board. The options are supplemented by a number 
of  additional recommendations  on possible  improvements  to  the  regime.  As  a  result  of  this  process, 
this evaluation provides a total of 15 recommendations, as follows:  

67 

 
 
 
Recommendation 1: IAS 
Based on an analysis of the scope of the IPPC and the consensus view as it emerged in the process of 
the evaluation and the FCEC analysis, the explicit inclusion of IAS plants with wider/environmental 
impacts  (habitats  and  ecosystems)  and/or  economic  impacts  on  wider  range  of  stakeholders  (option 
iii) is recommended. 

Recommendation 2: Natural spread 
The evaluation results, confirmed by the outcome of the conference of February, indicate that in the 
context  of  increased  demand  for  better  prevention  and  timely  action  against  outbreaks,  but  also  to 
improve the consistency of the current approach, natural spread needs to be explicitly included in the 
regime  (option  ii),  and  covered  by  the  solidarity  regime  (option  iii),  in  order  to  maximise  the 
relevance,  effectiveness  and  efficiency  of  this  approach  (costs  and  benefits  of  the  approach  to  be 
established  on  a  case  by  case  basis).  On  this  basis,  option  ii  is  generally  recommended,  with 
consideration of option iii recommended in certain specific cases. 

Recommendation 3: RNQPs 
From the analysis of the options, the adoption of a zero tolerance approach to the regime covering both 
quarantine and non quarantine pests for which tolerance is zero (PH: RQPs + RNQPs; tolerance = 0) 
(option ii) is the most recommended. It is noted that this includes the improvements suggested in the 
status-quo (option i).  

It  is  also  recommended  that  the  potential  benefits  of  synergies  between  the  CPHR  and  S&PM  are 
further explored. 

Recommendation 4: Prevention strategies at import 
Based on the consensus view as it emerged in the process of the evaluation and the FCEC analysis, it 
is recommended that complementary measures, are taken. These measures include: for emerging risks, 
particularly new trade in plants for planting/ propagating material (PM), commodity pathway analysis 
(option iii); for plants for planting/PM, official post entry inspections for latent HOs (option iv(a)); 
and,  for  plants  for  planting/PM,  on  the  basis  of  commodity  pathway  analysis,  the  introduction  of 
import bans where necessary (option iv(c)).It is noted that this includes the improvements suggested 
in the status-quo (option i).  

Depending on severity of non-compliance or infractions (both at the level of individual traders and at 
the level of the CAs involved), sanctions could be introduced in the system. This issue is more broadly 
considered under the options regarding incentives.   

Recommendation 5: Intra-EU surveillance 
The  evaluation  results,  confirmed  by  the  February  conference,  identified  significant  support  for 
general  epidemio-surveillance  for  priority  HOs,  although  the  process  and  criteria  to  be  used  for  the 
identification and selection of HOs to be subject to such surveillance, as well as the scope and method 
of the surveillance, remain to be discussed.  

Considering  the  views  of  MS  CAs,  stakeholders  and  experts,  and  taking  into  account  the  Council 
conclusions of 2009, the following options are recommended: the development of common principles 
and  guidelines  for  harmonized  surveillance  and  reporting  (option  ii);  the  introduction  of  mandatory 
general surveillance at EC level for priority HOs (option iii); and, the introduction of co-financing for 
surveillance  (option  iv).  It  is  noted  that  this  includes  the  improvements  suggested  in  the  status-quo 
(option i).  

68 

 
 
 
 
 
 
 
 
 
 
 
Recommendation 6: Emergency action  
Based on the analysis of the options for emergency action, the following options are recommended: 
horizon  scanning  (options  ii);  the  compulsory  development  of  contingency  plans  according  to  a 
harmonized framework (option iii); and, speeding up the process for adoption and adaptation of both 
emergency  and  control/eradication  measures  (option  v).  It  is  noted  that  these  options  are 
complementary (i.e. can be adopted in parallel), and that, in all cases, they include the improvements 
suggested in the status-quo (option i). 

Recommendation 7: Plant Passport (PP) system 
From the analysis of options for the future of the PP system, revising the scope of application (option 
ii) and harmonising the PP document (option iii) are the most recommended options. It is noted that 
these options are complementary (i.e. can both be adopted), and that, in both cases, they include the 
improvements suggested in the status-quo (options i). 

Recommendation 8: Tightening the system of Protected Zones (PZ) 
The analysis of options for tightening the PZ system suggests that improving the status quo (option i)) 
is  the  most  recommended  starting  point,  on  the  basis  that  it  represents  the  best  balance  of 
advantages/disadvantages  against anticipated impacts while being the  most acceptable. Longer term, 
there  is  also  a  need  to  further  examine  the  implications  of  applying  more  widely  the  PFA  concept 
(ISPM 4).  

Recommendation 9: Incentives 
On  the  basis  of  the  evaluation  results,  confirmed  by  the  February  conference,  and  the  results  of  the 
evaluation of the solidarity regime, the most recommended options for incentivising the current system 
are  to  extend  the  current  scope  of  solidarity  to:  cover  the  loss  of  destroyed  material  for 
producers/growers  (option  i(a));  and,  co-finance  certain  measures  which  contribute  to  better 
prevention e.g. surveillance, contingency planning (option i(c)).  
It is also recommended to carry out further analysis of the possibility to introduce cost-responsibility 
sharing schemes, in line with the ongoing development of this concept in the animal health field. 

Recommendation 10: Research and development and scientific advice 
The definition of a structural role for EUPHRESCO-like coordination of national research funding is 
recommended, with the establishment of a specific budget for this purpose.  
The evaluation highlighted a strong need for sufficient and stable EU and MS resources for funding 
research  projects;  for  short  term  research  needs,  a  structural  budget  within  the  CPHR  could  be 
established in addition to the FP7.  
It is recommended that discussions and cooperation between SANCO/EFSA and EPPO continue with 
a  view  to  identifying  complementarities  to  cover  the  economic  impact  of  the  EU  PRAs, 
complementing the EFSA role. 

Recommendation 11: Diagnostics  
To  enhance  the  diagnostic  capacity  in  this  sector  in  the  EU,  it  is  recommended  to  complete  the 
establishment  of  NRLs  in  MS  and  to  establish  EU-RLs  for  a  limited  number  of  HOs.  Longer  term, 
EU-RLs  could  be  established  for  each  of  the  disciplines  (nematology,  entomology,  acarology, 
mycology, bacteriology, virology), and subset of disciplines, so that they should be able to detect all 
the 250 HOs. 

Recommendation 12: Training 
It is recommended to continue and strengthen training activity in the plant health sector for inspectors 
and to intensify efforts by extending the training also to experts in the diagnostics field. 

69 

 
 
 
 
 
 
 
 
 
 
Recommendation 13: EU/MS emergency team 
The  establishment  of  an  EU/MS  Emergency  Team  (within  DG  SANCO  and  supported  by  extended 
network  of  MS  experts)  for  Plant  Health  is  recommended,  in  line  with  the  existing  emergency 
preparedness approach in the animal health field.   

Recommendation 14: Communication and transparency 
The need for an increased public and political awareness was a clear outcome of the evaluation. It is 
therefore recommended that both at EU and MS level public awareness campaigns are developed and 
implemented.  

Recommendation 15: Financial Framework 
The  evaluation  of  the  CPHR  performance  to  date,  and  in  particular  of  the  financial  framework 
(solidarity  regime)  has  extensively  highlighted  the  mismatch  of  currently  available  resources  to 
objectives, which underpins many of the identified shortcomings and weaknesses. The above analysis 
of options for the future has in all cases pointed to the need to increase resources and/or prioritise to 
meet the objectives set out in the options.  The Commission will have to reflect on the best option to 
follow.  

The  evaluation  results  have  also  confirmed  the  conclusions  of  the  solidarity  regime  evaluation, 
according to which, a financial instrument is needed for better preparedness in case of emergency.  
In  this  context,  the  evaluation  recommends  that  the  merits  of  developing  a  specific  financial 
instrument  in  this  sector,  possibly  in  the  form  of  a  Plant  Health  Fund  drawing  a  parallel  from  the 
Animal Health Fund, need to be examined further.   

----------------------- 
The contribution of the various options and recommendations towards the various identified needs and 
objectives is depicted in Table 1. The priority assigned to each option and need for further assessments 
are also highlighted. The overarching objective in all cases is to improve prevention. 

70 

 
 
 
 
 
 
 
 
Table 1: Key recommendations for the future and their contribution to achieving the identified needs and objectives  

Early 
detection 

Early 
response 

(cid:57) 

(cid:57) 

Specific objective: better prevention 
Operational objectives: 
of 

Risk 
basis 

Definition 
responsibilities 

Incentives  Clarification68  Public/political 

Priority  Need for further assessment 

awareness 

(cid:57) (a) 

Medium 

Options 
(most recommended) 

1.Explicit inclusion of IAS plants 
with wider environmental impacts 
and/or economic impacts on wider 
range of stakeholders 

2.Inclusion of  natural spread in 
solidarity regime69 

3.Zero tolerance regime 

4. Imports 
For emerging risks: commodity 
pathway analysis 70  

For plants for planting/PM 
strengthen measures: 
a.  Official 71 post entry 

b. 

inspections for latent HOs 
Introduce import bans where 
necessary 
5.Surveillance 
Development of common 
principles and guidelines for 
harmonized surveillance and 
reporting 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

Medium  To enquire feasibility of 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) (b) 

Low 

pursuing implementation of 
sanctions/penalties. 
A separate impact assessment is 
recommended in order to 
examine scope of HOs involved 
and to ensure coherence with 
S&PM legislation 

(cid:57) (a) 

High 

A cost-benefit analysis may be 
required   

Medium  A cost-benefit analysis may be 

required   

High 

Acceptability of ban needs to be 
further assessed 

(cid:57) 

(cid:57) 

High 

68 Where appropriate, clarification is further indicated in terms of: (a) alignment to international standards; (b) better coordination of EU policies 
69 Consideration of solidarity funding for natural spread to be addressed on a case by case basis (e.g. in line with conclusion of 2008 solidarity regime evaluation). 
70 This concerns particularly new trade in plants for planting/ propagating material (PM). 
71 “Official” refers to form of inspection and not agent (the issue of whether the agent would be a CA or licensed private sector inspector is not addressed here). 

71 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Specific objective: better prevention 
Operational objectives: 
of 

Incentives  Clarification68  Public/political 

Options 
(most recommended) 

Early 
detection 

Early 
response 

Risk 
basis 

Definition 
responsibilities 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

General surveillance mandatory 
at EC level for priority HOs72  
Introduction of co-financing for 
surveillance 
6.Emergency actions 

Horizon scanning 

Compulsory development of 
contingency plans according to 
harmonized framework 

Speed up process for adoption and 
adaptation of both emergency and 
control/eradication measures 
7.Plant Passport system 

Clarify the scope and level of  PP  
application, in terms of:  
a. Plants; b. Marketing stage 

Harmonise PP document 

8. Protected zones 

Status quo (with improvements)of 
PZs:  
a. Improve surveillance targets,  
b. Involve stakeholders,  
c. Harmonised eradication 
programmes,  
d. ending status on time 
9.Incentives 

72 Other than Emergency Measures, Control Directives and PZ 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

72 

awareness 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

Priority  Need for further assessment 

High 

High 

High 

High 

High 

Prioritisation criteria to be 
defined.  

Assessment to be conducted 
under solidarity funding scope 

To be analysed whether these 
should be general or pest 
specific; degree of involvement 
of stakeholders 

Medium  Further detailed analysis of 
scope required 

Medium  A separate study is 

recommended in order to 
examine scope for 
harmonisation 

Medium  More detailed analysis needed 

of implications of moving to 
PFA and possible coexistence 
of PZs and PFAs 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Options 
(most recommended) 

Early 
detection 

Early 
response 

Risk 
basis 

Definition 
responsibilities 

Incentives  Clarification68  Public/political 

Priority  Need for further assessment 

Specific objective: better prevention 
Operational objectives: 
of 

awareness 

(cid:57) 

High 

Further detailed analysis of 
scope required 

(cid:57) 

High 

Further detailed analysis of 
scope required 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

High 

High 

High 

High 

Medium 

High 

Extend current scope of solidarity: 
Eradication measures (current 
scope): a. Extend (within current 
scope) to cover loss of destroyed 
material 
Extend current scope of solidarity: 
New measures 
Measures for co-financing 
consideration may include e.g. 
surveillance, contingency 
planning, prevention of emerging 
risks and emergency actions. 
Further recommendations 

10.Research & Development 

11.Diagnostic laboratories  

12.Training 

13.EU/MS Emergency Team 

14.Communication and 
transparency 
15.Financial framework 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

(cid:57) 

High: action recommended within the following year 

Medium: action recommended within 1 to 5 years 

(cid:57) 

(cid:57) 

(cid:57) 

73 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex II: Legal structure of the regime and foreseen changes 

The  plant  health  regime  comprises  a  large  volume  of  legislation.  The  main  legal  acts, 
changes foreseen to those acts and the related impact assessments are outlined below. 

A. Overview of the relevant legislation 

Basic act: Council Directive 2000/29/EC 

• 

• 

• 

The basic act of the plant health acquis – covered by the present IA - is Council 
Directive  2000/29/EC  on  protective  measures  against  the  introduction  into  the 
Community  of  organisms  harmful  to  plants  or  plant  products  and  against  their 
spread within the Community. The Directive has been repeatedly amended since 
its initial adoption in 1977. 
→  
The  current  review  foresees  to  change  the  basic  Directive  into  a 
Regulation  and  to  upgrade  and  expand  the  legal  provisions  (for  details,  see 
Section 4 and Annex IX).  

The proposal will be subject to co-decision of Council and European Parliament. 

The  Directive  contains  numerous  empowerments  for  the  Commission  to  change 
the  Annexes  and  to  adopt  secondary  Commission  acts  (Regulations,  Directives, 
Decisions,  Recommendations).  Large  numbers  of  Commission  acts  have  been 
adopted since the basic Directive entered into force in 1977. 
→  
Certain  secondary  acts,  for  example  Commission  Regulation  (EC)  No 
690/2008 recognising protected zones exposed to particular plant health risks in 
the  Community,  will  be  repealed  following the  entry  into  force  of  the  new  plant 
health  Regulation  as  they  are  absorbed  into  Articles  of  that  Regulation  or 
replaced by secondary acts adopted under that Regulation.  

Most existing Commission acts (in particular emergency measures) will remain in 
force after the review. 

The empowerments have the form of classical Comitology provisions, involving 
the Standing Committee on Plant Health that was established by Article 18 of the 
Directive. They are all subject to the simple regulatory procedure (no regulatory 
procedure with scrutiny). 
→  
In  the  new  plant  health  Regulation,  the  general  empowerments  will  be 
changed into empowerments for delegated and implementing acts. This had to be 
done anyhow due to the entry into force of the Lisbon Treaty.  

Empowerments  to  change  the  new  Annexes  of  the  Regulation  (concerning  for 
example  the  criteria  for  categorisation  of  harmful  organisms  and  for  risk 
assessment and management) will take the form of delegated acts. Empowerments 
to adopt secondary legislation can refer to both delegated and implementing acts, 
depending on their nature.  

Other Council Directives 

• 

Four  additional  Council  Directives  (69/464/EEC,  93/85/EEC,  98/57/EC, 
2007/33/EC) exist concerning the control of specific harmful organisms of potato. 
Part of these are consolidations and amendments of earlier Directives. 

74 

 
 
 
 
These so-called 'Control Directives' will be replaced by implementing acts 

→  
under the new Regulation, with transitional arrangements. 

• 

Two  further  Council  Directives  exist  concerning  the  control  of  carnation  leaf-
rollers  and  of  San  José  scale,  pests  that  have  in  the  meanwhile  become 
widespread in the EU. These two Control Directives are no longer implemented. 
→  These  two  Control  Directives  will  be  repealed  by  the  new  plant  health 
Regulation.  

Council Regulation on Official Controls 

• 

Council Regulation (EC) 882/2004 concerns official controls performed to ensure 
the verification of compliance with feed and food law, animal health and animal 
welfare rules. Currently, only four Articles (41-46) concerning the obligation for 
MS to set up multi-annual control plans and Union inspections within the MS and 
in  third  countries  are  applicable  to  plant  health,  which  was  otherwise  excluded 
from the scope of the Regulation. 
→  
The  scope  of  Regulation  882/2004  will  be  expanded  to  fully  cover  plant 
health. Horizontal principles such as the definition of competent authorities, the 
provisions for delegation of official tasks, the principles for certification, official 
controls and fees will be transferred from the plant health Directive to Regulation 
882/2004.  

Regulation  882/2004  will  be  a  recast,  with  its  own  IA.  The  main  changes  with 
foreseeable  impact  on  plant  health  will  be  the  provision  of  rules  concerning 
official controls, fees, requirements for laboratory accreditation, the setting up of 
EU  reference  laboratories  for  plant  health  and  the  inclusion  of  plant  health 
imports in the TRACES IT tool used for tracing of animals, animal products, food 
and feed that are imported into the EU.  

Commission Decisions concerning accession to international treaties 

• 

Two  Council  Decisions  (94/800/EC  and  2004/597)  concern  the  accession  to  the 
IPPC and WTO-SPS. 
→  

These Council Decisions will remain in force after the review.  

Council Directives on plant reproductive material 

• 

12 Council Directives73 concern the marketing and production of seed and plant 
propagating  material.  As  explained  in  Section  2,  these  currently  also  regulate 
harmful organisms. 

All these will be replaced by a Regulation on plant reproductive material, 
→ 
to  be  accompanied  by  its  own  IA.  However  all  provisions  of  these  Directives 
concerning  plant  health  will  be  transferred  to  the  new  EU  plant  health  regime. 

73  Directives  66/401/EEC,  66/402/EEC,  68/193/EEC,  2002/53/EC,  98/56/EC,  1999/105/EC,  2002/54/EC, 

2002/55/EC, 2002/56/EC, 2002/57/EC, 2008/72/EC, 2008/90/EC 

75 

 
 
 
 
                                                 
Annex III: International Plant Protection Convention74 

The  International  Plant  Protection  Convention  (IPPC)  is  an  international  plant  health 
agreement, established in 1952, that aims to protect plants by preventing the introduction 
and spread of pests of plants and plant products. The convention has been deposited with 
the  Director-General  of  the  Food  and  Agriculture  Organization  of  the  United  Nations 
(FAO)  since  its  adoption  in  1951.  A  new  revised  text75  was  approved  by  the  FAO 
Conference  in  1997.  The  EU  and  all  its  Member  States  are  contracting  parties  to  the 
IPPC.  

The  Convention  extends  beyond  the  protection  of  cultivated  plants  to  the  protection  of 
natural flora (wild plants) and plant products. It takes into consideration both direct and 
indirect  damage  by  pests,  so  it  includes  weeds.  It  also  covers  vehicles,  aircraft  and 
vessels, containers, storage places, soil and other objects or material that can harbour or 
spread pests. 

The  Convention  provides  a  framework  and  a  forum  for  international  cooperation, 
harmonization  and  technical  exchange  between  contracting  parties.  The  IPPC  develops 
so-called  International  Standards  for  Phytosanitary  Measures  (ISPM).  At  present  34  of 
such standards have been published:  

ISPM 01     

ISPM 02 

ISPM 03 

Phytosanitary principles for the protection of plants and the application of 
phytosanitary measures in international trade 
Framework for pest risk analysis 
Guidelines for the export, shipment, import and release of biological control 
agents and other beneficial organisms 

ISPM 04  Requirements for the establishment of pest free areas 
ISPM 05  Glossary of phytosanitary terms 
ISPM 06  Guidelines for surveillance 
ISPM 07 
ISPM 08  Determination of pest status in an area 
ISPM 09  Guidelines for pest eradication programmes 

Phytosanitary certification system 

ISPM 10 

ISPM 11 

Requirements for the establishment of pest free places of production and pest 
free production sites 
Pest risk analysis for quarantine pests including analysis of environmental 
risks and living modified organisms 
Phytosanitary certificates 

ISPM 12 
ISPM 13  Guidelines for the notification of non-compliance and emergency action 

ISPM 14 

The use of integrated measures in a systems approach for pest risk 
management 

ISPM 15  Regulation of wood packaging material in international trade 
ISPM 16  Regulated non-quarantine pests: concept and application 

74 Based on information provided by the IPPC at https://www.ippc.int/  
75 

https://www.ippc.int/file_uploaded//publications/13742.New_Revised_Text_of_the_International_Plant_Protectio
.pdf 

76 

 
 
 
                                                 
Pest reporting 

ISPM 17 
ISPM 18  Guidelines for the use of irradiation as a phytosanitary measure 
ISPM 19  Guidelines on lists of regulated pests 
ISPM 20  Guidelines for a phytosanitary import regulatory system 
ISPM 21 
ISPM 22  Requirements for the establishment of areas of low pest prevalence 
ISPM 23  Guidelines for inspection 

Pest risk analysis for regulated non quarantine pests 

ISPM 24 

Guidelines for the determination and recognition of equivalence of 
phytosanitary measures 
ISPM 25  Consignments in transit 
ISPM 26  Establishment of pest free areas for fruit flies (Tephritidae) 
ISPM 27  Diagnostic protocols for regulated pests 
ISPM 28 
ISPM 29  Recognition of pest free areas and areas of low pest prevalence 
ISPM 30  Establishment of areas of low pest prevalence for fruit flies (Tephritidae) 
ISPM 31  Methodologies for sampling of consignments 
ISPM 32  Categorization of commodities according to their pest risk 

Phytosanitary treatments for regulated pests 

ISPM 33 

Pest free potato (Solanum spp.) micropropagative material and minitubers 
for international trade 

ISPM 34  Design and operation of post-entry quarantine stations for plants 

The  implementation  of  the  Convention  involves  collaboration  by  National  Plant 
Protection Organizations (NPPOs) — the official services established by governments to 
discharge  the  functions  specified  by  the  IPPC  —  and  Regional  Plant  Protection 
Organizations  (RPPOs),  which  can  act  as  coordinating  bodies  at  a  regional  level  to 
achieve the objectives of the IPPC. A Regional Plant Protection Organization (RPPO) is 
an inter-governmental organization functioning as a coordinating body for National Plant 
Protection Organizations (NPPOs) on a regional level. There are currently nine RPPOs; 
one  of  them  is  the  European  and  Mediterranean  Plant  Protection  Organisation  (EPPO). 
Not all contracting  parties  to the IPPC  are members of RPPOs, nor are all  members of 
RPPOs contracting parties to the IPPC. Some contracting parties belong to more than one 
RPPO. 

Countries  that  wish  to  become  contracting  parties  to  the  IPPC  must  deposit  their 
instrument of adherence with the Director General of FAO. At present, the IPPC has 177 
contracting parties. 

The Commission on Phytosanitary Measures (CPM) is the governing body of the IPPC. 
The CPM Bureau is the seven-member elected executive body of the CPM that provides 
guidance to the IPPC Secretariat and CPM on strategic direction, cooperation, financial 
and operational management. The IPPC Secretariat is responsible for the coordination of 
core activities under the IPPC work programme. The Secretariat is provided by the Food 
and Agriculture Organisation of the United Nations.  

77 

 
 
 
 
 
Annex IV: WTO Sanitary and Phytosanitary Agreement76 

The  Agreement  on  the  Application  of  Sanitary  and  Phytosanitary  Measures  (“the  SPS 
Agreement”)  sets  out  the  basic  rules  for  food  safety  and  animal  and  plant  health 
requirements.  It  allows  countries  to  set  their  own  standards.  However,  it  also  specifies 
that  regulations  must  be  based  on  scientific  findings  and  should  be  applied  only  to  the 
extent that they are necessary to protect human, animal or plant life or health; they should 
not unjustifiably discriminate between countries where similar conditions exist.  

WTO  member  countries  are  encouraged  to  use the standards developed by the relevant 
international  bodies  whenever  they  exist.  However,  members  may  use  measures  which 
result  in  higher  levels  of  health  protection,  so  long  as  their  measures  are  based  on  an 
appropriate  assessment  of  risks  and  the  approach  is  consistent,  not  arbitrary.  The 
agreement sets out a framework for what countries can do, but is not prescriptive in how 
countries use health standards and methods of inspecting products. 

Key features 

All countries maintain measures to ensure that food is safe for consumers, and to prevent 
the  spread  of  pests  or  diseases  among  animals  and  plants.  These  sanitary  and 
phytosanitary measures can take many forms, such as requiring products to come from a 
disease-free  area,  inspection  of  products,  specific  treatment  or  processing  of  products, 
setting allowable maximum levels of pesticide residues or limiting the permitted use of 
additives  in  food.  Sanitary  (human  and  animal  health)  and  phytosanitary  (plant  health) 
measures apply to domestically produced food or local animal and plant diseases, as well 
as to products coming from other countries. 

Protection or protectionism? 

Sanitary and  phytosanitary  measures,  by their very nature, may result in restrictions on 
trade. All governments accept the fact that some trade restrictions may be necessary to 
ensure  food  safety  and  animal  and  plant  health  protection.  However,  governments  are 
sometimes pressured to go beyond what is needed for health protection and use sanitary 
and phytosanitary restrictions to shield domestic producers from economic competition. 
A sanitary  or  phytosanitary  restriction  which is not actually required  for  health reasons 
can  be  a  very  effective  protectionist  device  and,  because  of  its  technical  complexity,  it 
can be a particularly deceptive and difﬁcult barrier to challenge. 

The  SPS  Agreement  builds  on  previous  GATT  rules  to  restrict  the  use  of  unjustiﬁed 
sanitary and phytosanitary measures for the purpose of trade protection. The basic aim of 
the SPS Agreement is to maintain the sovereign right of any government to provide the 
level of health protection it deems appropriate, but to ensure that this sovereign right is 
not  misused  for  protectionist  purposes  and  do  not  result  in  unnecessary  barriers  to 
international trade. In other words, it strikes a balance between the right of governments 
to protect health and their desire to see goods flow smoothly in international trade. 

Justification 

The SPS Agreement therefore permits governments to maintain appropriate sanitary and 

76 After http://www.wto.org/English/res_e/booksp_e/agrmntseries4_sps_08_e.pdf  

78 

 
 
 
 
 
                                                 
phytosanitary  protection.  At  the  same  time,  it  reduces  the  possibility  that  decisions  are 
arbitrary  and  encourages  consistent  decision  making.  Sanitary  and  phytosanitary 
measures must be applied for no other purpose than to ensure that food is safe and that 
animals and plants are healthy, or to protect a country’s territory from pests. In particular, 
the  agreement  clariﬁes  which  factors  should  be  taken  into  account  when  risks  are 
assessed. Measures to ensure food safety and to protect the health of animals and plants 
should be based, where possible, on analysis and assessment of objective scientiﬁc data. 

International standards 

The  SPS  Agreement  encourages  governments  to  apply  national  SPS  measures  that  are 
consistent with international standards, guidelines and recommendations. This process is 
often  called  “harmonization”.  The  WTO  itself  does  not  and  will  not  develop  these 
standards.  However,  most  of  the  WTO’s  member  governments  participate  in  the 
development of these standards in other international bodies by leading scientists in the 
ﬁeld  and  governmental  experts  on  health  protection.  These  standards  are  subject  to 
international  scrutiny  and  review.  International  standards  are  often  higher  than  those 
actually  applied  in  many  countries,  including  developed  countries,  but  the  SPS 
Agreement  explicitly  permits  governments  to  choose  their  own  standards.  However,  if 
the national requirement results in a greater restriction of trade, a country may be asked 
by  its  trading  partners  to  provide  scientiﬁc  justiﬁcation  demonstrating  that  the  relevant 
international  standard  would  not  achieve  the  level  of  health  protection  the  country 
considers appropriate. 

Adapting to conditions 

Due to differences in climate, existing pests or diseases, or food safety conditions, it is 
not  always  appropriate  to  impose  the  same  sanitary  and  phytosanitary  requirements  on 
food, animal or plant products coming from different countries. Therefore, sanitary and 
phytosanitary measures sometimes vary, depending on the health situation in the country 
of origin or destination, of the food, animal or plant product concerned. This is taken into 
account in the SPS Agreement. Governments should also recognize pest and disease-free 
areas which may not  correspond to political boundaries, and adapt their requirements so 
that  they  are  appropriate  for  products  from  these  areas,  an  approach  known  as 
“regionalization”.  The  agreement,  however,  prohibits  unjustiﬁed  discrimination  in  the 
use of sanitary and phytosanitary measures, whether in favour of domestic producers or 
among foreign suppliers. 

Alternative measures and “equivalence” 

An  acceptable  level  of  risk  can  often  be  achieved  in  alternative  ways.  Among  the 
alternatives — and on the assumption that they are technically and economically feasible 
and  provide  the  same  level  of  food  safety  or  animal  and  plant  health  protection  — 
governments  should  select  those  that  do  not  restrict  trade  more  than  necessary  to  meet 
their  health  objective.  Furthermore,  if  another  country  can  show  that  the  measures  it 
applies  provide  the  same  level  of  health  protection,  these  should  be  accepted  as 
equivalent. This helps to ensure that protection is maintained while providing the greatest 
quantity and variety of safe foodstuffs for consumers, the best availability of safe inputs 
for  producers,  and  healthy  economic  competition.  “Equivalence”  is  one  of  the  subjects 
regularly discussed in the SPS Committee. 

79 

 
 
 
Risk assessment 

Countries’ SPS measures must be based on an appropriate assessment of the actual risks 
involved. If asked, they must make known what factors they took into consideration, the 
assessment procedures they used and the level of risk they determined to be acceptable. 

Transparency 

The  SPS  Agreement  makes  sanitary  and  phytosanitary  measures  more  transparent. 
Governments are required to notify each other, through the WTO Secretariat, of any new 
or  changed  sanitary  and  phytosanitary  requirements  which  affect  trade.  Each  WTO 
member  must  also  set  up  ofﬁces  (called  “Enquiry  Points”)  to  respond  to  requests  for 
more  information  on  new  or  existing  SPS  measures,  including  how  they  justify  their 
requirements  and  how  they  apply  their  food  safety  and  animal  and  plant  health 
regulations. By systematically communicating information and exchanging experiences, 
WTO  member  governments  can  improve  their  national  standards.  The  increased 
transparency  also  protects  consumers  and  trading  partners  alike  from  protectionism 
hidden in unnecessary technical requirements. This information is now readily available 
in  a  comprehensive  online  database,  the  SPS  Information  Management  System 
(http://spsims.wto.org). 

SPS Committee 

A  special  committee  has  been  established  within  the  WTO  as  a  forum  for  member 
governments  to  exchange  information  on  all  aspects  of  the  SPS  Agreement’s 
implementation.  The  SPS  Committee  reviews  how  countries  are  complying  with  the 
agreement,  discusses  issues  that  may  impact  on  trade  and  maintains  close  cooperation 
with  technical  organizations  in  the  field.  If  a  legal  dispute  arises  on  a  sanitary  or 
phytosanitary  measure,  the  normal  WTO  dispute  settlement  procedures  are  used,  and 
advice from appropriate scientiﬁc experts can be sought. 

80 

 
 
 
Annex V: Convention on Biological Diversity77 

Biological diversity - or biodiversity - is the term given to the variety of life on Earth and 
the natural patterns it forms. The biodiversity we see today is the fruit of billions of years 
of evolution, shaped by natural processes and, increasingly, by the influence of humans. 
It  forms  the  web  of  life  of  which  we  are  an  integral  part  and  upon  which  we  so  fully 
depend.  

This  diversity  is  often  understood  in  terms  of  the  wide  variety  of  plants,  animals  and 
microorganisms.  So  far,  about  1.75  million  species  have  been  identified,  mostly  small 
creatures  such  as  insects.  Scientists  reckon  that  there  are  actually  about  13  million 
species,  though  estimates  range  from  three  to  100  million.  Biodiversity  also  includes 
genetic  differences  within  each  species  -  for  example,  between  varieties  of  crops  and 
breeds  of  livestock.  Chromosomes,  genes,  and  DNA-the  building  blocks  of  life-
determine  the  uniqueness  of  each  individual  and  each  species.  Yet  another  aspect  of 
biodiversity  is  the  variety  of  ecosystems  such  as  those  that  occur  in  deserts,  forests, 
wetlands, mountains, lakes, rivers, and agricultural landscapes. In each ecosystem, living 
creatures,  including  humans,  form  a  community,  interacting  with  one  another  and  with 
the air, water, and soil around them.  

At the 1992 Earth Summit in Rio de Janeiro, world leaders agreed on a comprehensive 
strategy for "sustainable development" -- meeting our needs while ensuring that we leave 
a healthy and viable world for future generations. One of the key agreements adopted at 
Rio  was  the  Convention  on  Biological  Diversity  (CBD).  This  pact  among  the  vast 
majority  of  the  world's  governments  sets  out  commitments  for  maintaining  the  world's 
ecological  underpinnings  as  we  go  about  the  business  of  economic  development.  The 
CBD entered into force on 29 December 1993. It has 3 main objectives:  

−  The conservation of biological diversity;  
−  The sustainable use of the components of biological diversity;  
−  The fair and equitable sharing of the benefits arising out of the utilization of 

genetic resources.  

The EU and all its Member States are parties to the CBD. At present, 193 countries are 
parties to the Convention. 

Thematic programmes 

The  Conference  of  the  Parties  (COP)  has  established  seven  thematic  programmes  of 
work  which  correspond  to  some  of  the  major  biomes  on  the  planet.  Each  programme 
establishes a vision for, and basic principles to guide future work. They also set out key 
issues for consideration, identify potential outputs, and suggest a timetable and means for 
achieving these. Implementation of the work programmes depends on contributions from 
Parties, the Secretariat, relevant intergovernmental and other organizations. Periodically, 
the COP and the SBSTTA review the state of implementation of the work programmes. 

The thematic programmes are: 

−  Agricultural biodiversity 
−  Dry and subhumid lands biodiversity 

77 Based on the information on the CBD website: http://www.cbd.int  

81 

 
 
 
 
 
                                                 
Inland waters biodiversity 
Island biodiversity 

−  Forest biodiversity 
− 
− 
−  Marine and coastal biodiversity 
−  Mountain biodiversity 

Cross-cutting issues 

The COP has also initiated work on key matters of relevance to all thematic areas. These 
cross-cutting  issues  correspond  to  the  issues  addressed  in  the  Convention's  substantive 
provisions  in  Articles  6-20,  and  provide  bridges  and  links  between  the  thematic 
programmes.  Some  cross  cutting  initiatives  directly  support  work  under  thematic 
programmes, for example, the work on indicators provides information on the status and 
trends  of  biodiversity  for  all  biomes.  Others  develop  discrete  products  quite  separate 
from the thematic programmes. The work done for these cross-cutting issues has led to a 
number of principles, guidelines, and other tools to facilitate the implementation of the 
Convention and the achievement of the 2010 biodiversity target. 

The cross-cutting issues are: 

−  Aichi Biodiversity Targets 
−  Access to Genetic Resources and Benefit-sharing  
−  Biodiversity for Development  
−  Climate Change and Biodiversity  
−  Communication, Education and Public Awareness 
−  Economics, Trade and Incentive Measures  
−  Ecosystem Approach  
−  Gender and Biodiversity  
−  Global Strategy for Plant Conservation  
−  Global Taxonomy Initiative 
− 
− 
− 
−  Liability and Redress - Art. 14(2)  
−  Protected Areas  
−  Sustainable Use of Biodiversity  
−  Tourism and Biodiversity  
−  Traditional Knowledge, Innovations and Practices - Article 8(j)  
−  Technology Transfer and Cooperation 

Impact Assessment  
Identification, Monitoring, Indicators and Assessments  
Invasive Alien Species  

Invasive alien species 

Invasive  alien  species  (IAS)  are  species  whose  introduction  and/or  spread  outside  their 
natural  past  or  present  distribution  threatens  biological  diversity.  IAS  occur  in  all 
taxonomic  groups,  including  animals,  plants,  fungi  and  microorganisms,  and  can  affect 
all  types  of  ecosystems.  While  a  small  percentage  of  organisms  transported  to  new 
environments  become  invasive,  the  negative  impacts  can  be  extensive  and  over  time, 
these additions become substantial. A species introduction is usually vectored by human 
transportation and trade. If a species’ new habitat is similar enough to its native range, it 
may survive and reproduce. However, it must first subsist at low densities, when it may 
be  difficult  to  find  mates  to  reproduce.  For  a  species  to  become  invasive,  it  must 

82 

 
 
 
 
successfully out-compete native organisms, spread through its new environment, increase 
in population density and harm ecosystems in its introduced range. To summarize, for an 
alien species to become invasive, it must arrive, survive and thrive.  

Common  characteristics  of  IAS  include  rapid  reproduction  and  growth,  high  dispersal 
ability,  phenotypic  plasticity  (ability  to  adapt  physiologically  to  new  conditions),  and 
ability to survive on various food types and in a wide range of environmental conditions. 
A good predictor of invasiveness is whether a species has successfully or unsuccessfully 
invaded elsewhere.  

Ecosystems that have been invaded by alien species may not have the natural predators 
and  competitors  present  in  its  native  environment  that  would  normally  control  their 
populations.  Native  ecosystems  that  have  undergone  human-induced  disturbance  are 
often more prone to alien invasions because there is less competition from native species. 
For  example,  imported  red  fire  ants  (Solenopsis  invicta  Buren)  are  more  successful  in 
establishing  themselves  in  disturbed  areas  such  as  roadsides  and  agricultural  fields  and 
rarely colonize intact closed forests.  

Islands are especially vulnerable to IAS because they are naturally isolated from strong 
competitors and predators. Islands often have ecological niches that have not been filled 
because  of  the  distance  from  colonizing  populations,  increasing  the  probability  of 
successful invasions. 

Addressing invasive alien species 

The Conference of the Parties (COP) to the CBD has recognized that there is an urgent 
need  to  address  the  impact  of  IAS,  and  established  IAS  as  a  cross-cutting  issue  at  its 
fourth meeting. The decision of COP 6 included adoption of Guiding Principles for the 
Prevention,  Introduction  and  Mitigation  of  Impacts  of  Alien  Species  that  Threaten 
Ecosystems, Habitats or Species. The Guiding Principles are:  

−  Precautionary approach;  
−  Three-stage hierarchical approach;  
−  Ecosystem approach;  
−  The role of States;  
−  Research and monitoring;  
−  Education and public awareness;  
−  Border control and quarantine measures;  
−  Exchange of information;  
−  Cooperation, including capacity-building;  
− 
Intentional introduction;  
−  Unintentional introduction;  
−  Mitigation of impacts;  
−  Eradication;  
−  Containment; and  
−  Control.  

At  COP  7  (2004),  it  was  decided  that  “specific  gaps  in  the  international  regulatory 
frameworks at global, regional and national levels persist, notably in relation to species 
that are invasive, but do not qualify as plant pests under the regulations of international 
agreements”, with regard to the following pathways:  

83 

 
 
 
−  The use of non-native organisms in aquaculture and the restocking of marine and 
inland  water  systems  for  commercial  and  recreational  fisheries  taking  into 
account  contributions  of  national  codes, and  voluntary  international  efforts  such 
as  Codes  of  Practice  on  the  Introductions  and  Transfers  of  Marine  Organisms 
developed  by  the  International  Council  for  the  Exploration  of  the  Seas  and  the 
FAO Code of Conduct on Responsible Fisheries;  

−  Unintentional  or  opportunistic  introductions  (e.g.,  "hitchhiker  organisms"), 
import  consignments, 

through  hull-fouling,  packaging  material, 

including 
vehicular transport and other means;  

−  Unintentional  introductions  of  invasive  alien  species  through  international 
assistance  and  humanitarian  programmes,  tourism,  military,  scientific  research, 
cultural and other activities;  

− 

− 

Intentional introductions of alien species for non-food purposes, including certain 
aspects of horticulture and trade in pets and aquarium species;  

Intentional  introduction  of  alien  species,  as  biocontrol  agents  for  control  or 
eradication of invasive alien species, pests or weeds;  

−  Transnational and national ex situ breeding projects with alien species as sources 

for intentional or unintentional introduction;  

− 

− 

− 

Intentional introduction of invasive alien species through international assistance 
programmes,  including  conservation  and  development  projects  and  other 
activities;  

Intentional introduction of potentially invasive alien species through international 
incentives schemes; and  

Introduction  of  alien  species  through  aquaculture  escapes,  bait  and  pet  releases, 
water transfer schemes.  

The decision of COP 8 identified measures by which Parties, other governments, relevant 
organizations  and  the  Executive  Secretary  should  address  identified  pathways  for 
invasive alien species. 

Collaboration between CBD and IPPC 

The CBD acknowledges the IPPC as covering IAS plants. The COP in 2008 adopted the 
following decision: "The Conference of Parties … encourages parties … to make use of 
the  risk  assessment  guidance  and  other  procedures  and  standards  developed  by  the 
International  Plant  Protection  Convention,  …  and  in  particular,  to  consider  applying, 
where  appropriate,  the  procedures  and  standards  for  quarantine  pests  under  the 
International Plant Protection Convention, to all invasive alien species that have adverse 
impacts  on  plant  biodiversity,  consistent  with  international  obligations;  and  invites  the 
International  Plant  Protection  Convention  to  continue  its  efforts  to  expand,  within  its 
mandate,  its  actual  coverage  of  invasive  alien  species  which  impact  on  biodiversity, 
including in aquatic environments". 

84 

 
 
 
 
 
Annex VI: Overview of the EU agriculture and forestry sector 

The EU plant health regime covers all areas of agriculture, horticulture, forestry, public 
and  private  green  and  the  natural  environment  (wild  plants,  ecosystems).  Some  key 
figures for the main sectors are given below. 

Crop production in the Union 

The  production  of  plants  and  plant  products  accounts  for  an  equal  share  of  EU 
agricultural  output  value  as  that  of  animals  and  animal  products.  The  share  of  plant 
products in EU exports is also comparable to that of animal products; in 2009, each of the 
sub-sectors accounted for around 20% of exports of all food products.  

Value of agricultural production, in billion € (current prices), 2005-2009 

Source: EUROSTAT 

Seeds, propagating material and nursery stock78 

Seeds 

The  European  Seed  Association  (ESA)  estimates  that  the  EU  commercial  seed  market 
has a total estimated production value at over EUR 7 billion, representing more than 20% 
of the total worldwide market for commercial seed. The EU seed markets for cereals and 
pulses are estimated at EUR 2.5 billion, maize at EUR 1.6 billion, seed potatoes at EUR 
0.9 billion, vegetables at about EUR 0.8 billion, while oil and fiber plants, sugar beet and 
grasses are at EUR 0.2 billion to EUR 0.3 billion. The EU is the largest exporter with an 
estimated export value of more than 60% of the total worldwide export value; in 2008, 
the  export  value  was  EUR  3  billion  and  the  import  value  EUR  2.3  billion.  The  EU 

78 Main source: DG SANCO (2011). 

85 

 
 
 
 
 
 
 
 
 
                                                 
became a net exporter of planting seeds in 2002/2003, and its trade surplus has gradually 
increased since then. 

The number of seed companies in the EU is estimated at 6,797 (source: ESA, 2010) and 
includes breeding companies, seed producers and seed traders. About 6,580 out of 6,797 
companies are based in ten Member States. The Member States with the highest number 
of  seed  companies  are  Poland,  Romania  and  Hungary,  however,  the  size  of  seed 
companies in these countries is extremely low with most of them (> 90%) being SMEs. 
The  total  employment  in  the  seed  sector  is  estimated  at  about  50,000  employees, 
concentrated  in  a  limited  number  of  Member  States.  An  important  consolidation  has 
occurred  in  Denmark,  France  and  the  Netherlands,  where  the  number  of  companies  is 
small but the number of employees is rather high.  

to  an 

industry  dominated  by  a  small  number  of 

In  the  last  40  years,  the  commercial  seed  industry  has  transformed  dramatically.  It  has 
shifted from a competitive sector of agribusiness, composed primarily of small, family-
owned  firms, 
transnational 
pharmaceutical/chemical  corporations.  This  transformation  is  nearly  complete  now  for 
key commodity crop seeds but is still ongoing in EU12 MS and in the EU wide vegetable 
sector.  These  corporations  entered  the  industry  by  acquiring  numerous  smaller  seed 
companies, and by merging with large competitors. The hybrid seed corn industry, which 
emerged in the 1930s in the US with the advent of high-yielding hybrid varieties, was the 
first to consolidate in the EU in early 1990’s. This process accelerated in the US due to 
enforcement of Intellectual Protection systems, which attracted the entrance of chemical 
and oil companies to add to their portfolio of agricultural inputs. The decade of the 1990s 
saw numerous mergers between pharmaceutical and chemical companies, in order to take 
advantages  of  potential  synergies.  These  new  conglomerations  were  described  as  life 
science  companies  due  to  their  focus  on biotechnologies.  By  2009,  six  companies  with 
chemical and/or pharmaceutical company roots remained dominant in the seed industry. 
In  the  top-ten  of  the  biggest  seed  companies  at  global  level,  five  are  Europe-based 
companies, four of which are from EU Member States. 

In  parallel  to  this  evolution,  changes  of  ownership  in  original  farmer-owned  supply 
cooperatives have led to the appearance of cooperatively owned global seed companies 
(e.g. Limagrain, Svalof Weibull).  

Vegetable seeds are a special case. They are mainly produced outside the EU in a wide 
range of countries in which labour costs are not as high as in the EU. The produced seeds 
are  shipped  to  the  EU,  especially  to  the  Netherlands,  for  treating,  sampling  and 
packaging  and  re-exported  to  their  final  destination  in  the  EU  or  outside  the  EU.  Main 
producers  are  France,  Italy,  the  Netherlands,  Hungary,  Denmark  and  Poland.    The  five 
biggest companies have 95% of the seed market. 

Propagating material (vine, ornamentals, fruit plants, forest) 

Figures and statistics regarding plant propagating material (other than seed; for example 
cuttings and nursery stock) are fragmentary as no consolidated sources of relevant data 
were  available.  In  most  Member  States,  activities  related  to  certification  of  plant 
propagating  material  is  organised  at  regional  level  or  by  different  organisations,  as  a 
consequence of which the statistics are not consolidated at national level.  

86 

 
 
 
For the ornamentals sector, no figures are available concerning the starting material. The 
total  value  of  the  EU  production  of  potted  plants  and  flowers  however  is  EUR  10.8 
billion (FCEC, 2011). 

For the fruit plants sector, Commission's services consolidated some key figures in 2007-
08  and  concluded  that  more  than  12,000  enterprises  are  involved  in  production  of  fruit 
plants in the EU. About 90% of these are small to medium enterprises frequently based in 
rural  areas  where  alternative  business  is  not  possible.  The  estimated  value  of  this 
business was estimated at about EUR 2.5 billion. 

The tree nursery production is valued at EUR 5.3 billion (FCEC, 2011).  

Arable land crops 

Cereals 

Cereals amount to 14% of agricultural gross output at basic prices. In 2009 the harvested 
production of cereals in the EU was 296 mio tonnes, of which France alone contributed 
close to one quarter (23.6 %); Germany and Poland were the only other Member States 
with a share above 10 %. Wheat was the largest cereal crop in the EU, and France’s share 
of  wheat  production  reached  27.7  %,  ahead  of  Germany  (18.2  %)  and  the  United 
Kingdom (10.2 %); wheat accounted for a relatively high share of total cereal production 
in  the  Netherlands.  France  and  Germany  each  produced  around  one  fifth  of  the  EU’s 
barley  crop,  while  Spain  and  the  United  Kingdom  produced  about  one  tenth  of  the  EU 
total;  barley  accounted  for  a  relatively  high  share  of  total  cereal  production  in  Cyprus, 
Ireland,  Finland  and  Estonia.  France  produced  26.5  %  of  the  EU’s  grain  maize,  while 
Romania,  Italy  and  Hungary  were  also  clearly  specialised  in  this  cereal  product,  each 
contributing between 13 % and 14 % of the EU total; grain maize also accounted for a 
relatively high share of total cereal production in Portugal, Slovenia and Greece (source: 
Eurostat). 

The EU has a considerable trade surplus for cereals, which in 2010 was equal to 23.2 mio 
tonnes. Cereal exports (predominantly wheat and meslin) amounted in 2010 to 22.2 mio 
tonnes while imports were 10.4 mio tonnes. The value of cereal exports to third countries 
in 2010 was EUR 9.5 billion and that of the imports EUR 3.4 billion (net trade surplus of 
EUR 6.1 billion). 

The  directly  employed  labour  force  in  commercial  farms  in  the  EU  for  cereals,  oilseed 
and protein crops in 2007 comprised 2.5 million persons (Eurostat). 

Sugar beet 

The total EU production of sugar from sugar beet is restricted to certain quota. For 2010-
2011,  the  sugar  production  in  the  EU  amounted  to  15  million  tonnes  generated  on  1.5 
mio  ha.  The  value  of  sugar  imports  from  third  countries  was  EUR  1.3  billion  (for  3.1 
million  tonnes)  and  the  value  of  the  exports  to  third  countries  EUR  1.0  billion  (for  2.2 
million tonnes). The value of the intra-EU sugar trade was EUR 2.8 billion (imports) and 
EUR 2.9 billion (exports). 

87 

 
 
 
 
Vegetables 

Vegetable commodity production in the EU has a value of EUR 27 billion. The bulk of 
vegetables production in the EU tends to be concentrated in a few Member States, with 
five  Member  States  (Italy,  Spain,  Romania,  France  and  Poland)  together  representing 
more than 50% of the production. In 2009 Italy and Spain had a combined tomato harvest 
of 11.1 million tonnes – for comparison, the production of tomatoes in Turkey was 10.8 
million tonnes. Portugal and Greece (2008 data) recorded tomato harvests reaching just 
over  1.3  million  tonnes  each.  The  production  of  carrots  was  highest  in  the  United 
Kingdom  (752  000  tonnes)  and  Italy  (624  000  tonnes);  Germany,  the  Netherlands  and 
France  all  had  production  levels  of  around  half  a  million  tonnes.  The  Netherlands  and 
Spain  produced  well  over  1  million  tonnes  of  onions  each,  and  together  with  Poland 
accounted  for  more  than  half  of  the  EU’s  onion  production.  Again,  Turkish  production 
was higher than in any of the EU Member States, reaching 2 million tonnes of onions in 
2009. 

The  directly  employed  labour  force  in  commercial  farms  in  the  EU  for  general  field 
cropping (including field-grown vegetables) in 2007 was 2.5 mio persons. The figure for 
2007 for horticulture, which in part includes vegetables, was 636,000 persons (Eurostat). 

The  quantity  of  EU  vegetable  exports  to  third  countries  in  2010  was  4.2  mio  tonnes 
(including  832,000  tonnes  of  potatoes  and  158,000  tonnes  of  tomatoes).  The  import 
quantities were 3.8 mio tonnes (including 403,000 tonnes of potatoes and 497,000 tonnes 
of tomatoes). The trade surplus thus was 379,000 tonnes (including a surplus of 428,000 
tonnes  for  potatoes  but  a  deficit  of  338,000  tonnes  for  tomatoes).  In  addition,  a  trade 
surplus exists of EUR 1.1 mio tonnes of prepared or preserved vegetables. 

The value of EU vegetable exports to third countries in 2010 was EUR 2.5 billion and for 
imports,  EUR  3.4  billion.  Thus,  a  trade  deficit  exists  for  fresh  vegetables  of  EUR  960 
million. This is balanced by a trade surplus of EUR 911 million for prepared or preserved 
vegetables. 

Potato 

Worldwide  production  of  potatoes  in  2009  was  330  mio  metric  tonnes.  With  63  mio 
metric  tonnes,  the  EU  was  the  second  main  producer,  after  China  (Faostat).  The 
production area in the EU in 2009 was 2.1 mio ha. The production is concentrated mainly 
in 8 Member States (DE, FR, RO, NL, UK, PL, IT, ES). The production value is around 
EUR 9 billion. The number of potato production holdings in the EU in 2007 was 3.2 mio 
(circa 25% of all holdings; of these 2.2 mio holdings in RO and PL).  

On average, total EU potato trade is valued at EUR 4.8 billion, of which EUR 3.9 billion 
is intra-EU trade. This includes fresh and chilled potatoes for a value of EUR 1.7 billion 
and processed potatoes for EUR 3.1 billion. 

The EU is a net exporter of fresh and chilled potatoes to third countries (export value in 
2010  EUR  0.51  billion;  import  value  EUR  0.15  billion).  On  a  world  scale,  the  EU 
production of potatoes is increasingly competitive and valuable, specifically as concerns 
seed potatoes which are mainly concentrated in four Member States representing 68% of 
the  cultivated  area  (32%  in  NL,  15%  in  DE,  13%  in  FR,  12%  in  UK).  Of  the  average 
potato export surplus over 2008-2010 of EUR  413 mio, a large part was attributable to 

88 

 
 
 
exports  of  seed  potatoes  (EUR  266  mio).  Besides  this,  the  EU  is  also  a  significant  net 
exporter of processed potatoes (average trade surplus over 2008-2010: EUR 456 mio). 

In several Member States, potatoes play a very important role, especially in Poland and 
in  the  Baltic  countries,  with  a  high  number  of  small  holdings  cultivating  potatoes: 
whereas  on  average  (EU-27)  the  share  of  direct  labour  force  employed  in  potato 
cultivation amounts to 25%, in some Member States this is significantly higher (85% in 
LT, 80% in LV, 66% in SI, 59% in EE and 55% in PL) (FCEC, 2011). 

Tomato 

In  2009,  total  EU  tomato  production  in  the  EU27  amounted  to  16.9  mio  tonnes  grown 
over ca. 293,000 ha. The total tomato production value is estimated at ca. EUR 9.3 - EUR 
12.7  billion  or  2.8-3.8%  of  the  total  EU27  agricultural  production  value  of  EUR  329 
billion  (source:  EUROSTAT/DG  AGRI).  The  tomato  sector  accounts  for  an  estimated 
20-25%  of  all  fruit  and  vegetable  production  value  in  the  EU.  Tomato  production  is 
concentrated in a few Member States: IT accounts for 43% of production volume, ES for 
28%, and EL for 10% (2007 data). The sector is an important source of employment: for 
example, in ES, one of the key producing MS, the tomato sector gives direct employment 
to more than 100,000 people. Some 66% of total tomato imports in the NL and 38% of 
total tomato imports in the UK come from ES. 

Intra-EU  tomato  trade  is  important,  as  90%  of  tomatoes  consumed  in  the  EU  are 
produced in the EU;  during  2006-09, some 15% of production (2.5 million  tonnes) per 
year were exported intra-EU; this trade is estimated at ca. EUR 2.55 billion (2008).  

A  deficit  exists  in  the  trade  with  third  countries  (net  2010  deficit  EUR  217  mio  for 
338,000 tonnes; value of 2010 exports: EUR 215 mio and imports: EUR 432 mio).    

Other field crops 

Many other arable land crops exist, such as sunflowers, oilseed rape, alfalfa, etcetera, the 
socio-economic value of which is not further elaborated here. 

Fruit production and vineyards 

The directly employed labour force in commercial farms in the EU for fruits (including 
citrus) in 2007 was 1.3 mio persons and that for vineyards 1.1 mio persons, representing 
respectively 5.3% and 5.1% of the agricultural labour force (Eurostat; data for 2007). The 
production figures for citrus and other fruit types are specified below. 

The  value  of  imports  of  fruits  and  nuts  from  third  countries  in  2010  was  EUR  12.3 
billion. With a export value of EUR 2.7 billion, a significant trade deficit exists of EUR 
9.6 billion. This is largely due to citrus, for which a net deficit exists of EUR 1.0 billion 
(import:  EUR  1.5  billion;  export:  EUR  0.5  billion),  and  bananas  (net  deficit  EUR  2.8 
billion). 

Citrus  

Global citrus fruit production in 2009 amounted to 11.1 billion tonnes (Faostat). Citrus 
production in the EU in 2010 amounted to EUR 3.9 billion for a production of around 11 
mio  tonnes  (mainly  oranges)  (Eurostat).  Orange  production  is  concentrated  in  the 

89 

 
 
 
Mediterranean Member States, particularly Spain and Italy. The main importers of EU-
produced citrus fruits are DE, FR, PL, BE and UK.  

As a result of a large deficit in citrus production in the EU compared to the consumption, 
a  significant  trade  flow  exists  from  third  countries  into  the  EU.  Imports  from  third 
countries in 2010 amounted to EUR 1519 mio (for 2.2 mio tonnes), mainly from South 
Africa, Argentina, Brazil, Morocco, Egypt and Turkey. The main importing countries are 
FR,  NL  and  ES.  Consequently,  the  main  intra-EU exporting countries are not only ES, 
GR and IT but also NL. The intra-EU import/export values in 2010 were EUR 3.3-EUR 
3.5  billion  (for  4.3-4.6  mio  tonnes).  Spain  provides  two  thirds  of  the  overall  intra-EU 
exports. 

The  2010  exports  to  third  countries  amounted  to  EUR  473  mio  (for  0.7  mio  tonnes), 
mainly from ES and GR. 

The number of holdings producing citrus in the EU in 2007 was 151,890 and the number 
of  persons  working  there  223,200,  with  the  largest  shares  for  successively  ES,  IT  and 
GR. 

Other fruit trees 

The production of apples, pears, peaches and apricots takes place in the EU on 880,529 
ha (Eurostat data for 2007). The production of apples and pears in the EU in 2009 was 15 
mio  tonnes.  Fruit  production  is  relatively  specialised  across  the  EU  Member  States. 
Poland, Italy and France in 2009 together produced 6.7 mio tonnes of apples, more than 
half  of  the  EU  production.  The  largest  producers  of  pears  were  Italy,  Spain,  the 
Netherlands, Portugal and Belgium, with a combined harvest of just over 2 mio tonnes. 

The value of the export from the EU to third countries in 2010 of apples, pears, quinces, 
apricots, cherries, peaches and plums was EUR 1.2 billion (for 2.0 mio tonnes) and the 
value for imports EUR 1.1 billion (for 1.1 mio tonnes) (Source: Comext).  

Vineyards79 

The  European  Union  is  the  largest  wine-producing  region  in  the  world.  The  total 
vineyard area in the EU-27 in 2009 was 3.7 mio ha, of which 96% for wine production. 
Within the EU-27, Spain has the largest vineyard area (32%), followed by France (23%), 
Italy (21%) and Portugal (6%); 8% of the EU-27 vineyard area is located in Bulgaria and 
Romania.  The  official  production  volume  in  recent  years  was  circa  160-180  mio  hl,  of 
which 70 mio hl quality wines.  

Exports to third countries amounted to 19.6 mio hl and imports from third countries to 
14,0 mio hl (data for 2007). The value in 2010 of exports to third countries was EUR 6.7 
billion  and  the  import  value  EUR  2.3  billion.  Within  the  EU,  the  value  of  exports  and 
imports were EUR 8.2 billion and EUR 7.9 billion, respectively.  

The number of vineyard holdings in the EU-15 was 1.8 mio (data for 1999). 

79 Eurostat database, 2011; Eurostat Agricultural statistics, Main results - 2008-09 

90 

 
 
 
                                                 
Ornamentals80 

The EU is the largest world producer of potted plants and flowers, valued at EUR 10.8 
billion,  accounting  for  41%  of  the  world  production  estimated  at  EUR  26.2  billion.  In 
addition, the tree nursery production is valued at EUR 5.3 billion. The total EU-27 land 
area of flowers, ornamental plants and nursery plants is estimated at 195,000 ha in 2009. 
Production  is  highly  concentrated  in  five  Member  States:  the  Netherlands  (43,200  ha), 
France  (27,200  ha),  Germany  (26,400  ha),  Italy  (24,520  ha)  and  Poland  (15,900  ha), 
which together accounts for 58% of the total area used for ornamentals production. The 
top five producers have a share exceeding 80% of the total EU-27 production of plants 
and  flowers  and  over  90%  by  value.  During  the  last  decade,  the  area  devoted  to 
ornamentals  production  has  been  declining,  except  in  the  case  of  the  Netherlands.  In 
2007, there were ca. 124,000 holdings producing plants and flowers, whereas the number 
was nearly 165,000 in 2003. 

Exports to third countries have been growing steadily in the past decade in volume, with 
518,000 tonnes in 2009 or 19% of total EU export trade. Of this volume, 31% are potted 
plants, 31% are bulbs and corms, 23% conifers and hardy perennial plants, and 16% cut 
flowers and cut foliage. The value of these exports was estimated at EUR 1.5 billion in 
2009.  

Imports from third countries represent 17% of total imports or 430,000 tonnes in 2009. 
Of this total volume of imports, 74% were cut flowers and cut foliage, 20% potted plants, 
4%  bulbs  and  corms,  and  2%  conifers  and  hardy  plants.  The  total  volume  of  these 
imports was estimated at EUR 1.5 billion in 2009. 

The  directly  employed  labour  force  in  commercial  farms  in  the  EU  for  horticulture 
(however including greenhouse vegetables) in 2007 was 636,000 persons (Eurostat; data 
for 2007). 

Forestry, public and private green and natural environment81 

Forests  are  a  multi-functional  resource  offering  landscape  and  amenity  functions,  a 
significant  environmental  role  (including  in  the  context  of  Natura  2000  and  climate 
change  mitigation  targets),  as  well  as  supplying  wood  as  a  raw  material  to  a  range  of 
downstream industries.  

The total forest and wooded land area in the EU is 178 million ha, corresponding to 42% 
of the total land area. About 73% of the total forest area is available for wood supply, and 
of this, only 60-65% of the net annual increment is currently harvested, which is why EU 
forests  are  accumulating  growing  stock  but  also  ageing.  The  estimated  standing  timber 
volume of EU forests is estimated at ca. 27 billion m³ and annual timber growth or net 
annual increment is estimated at ca. 610 million m³ (EUROSTAT, 2009; Forest Europe, 
2011). 

Wood production 

In  recent  years,  total  EU-27  wood  production  has  ranged  at  ca.  400  million  m3  of 
roundwood per year, consistently maintaining its position as one of the main roundwood 

80 FCEC, 2011 (based on Eurostat, DG AGRI, COMEXT, AIPH and Union Fleurs data) 
81 From FCEC (2011). 

91 

 
 
 
                                                 
producers in the world, and ca. 100 million m3 of sawnwood per year, with a labour force 
of 285,000 annual work units (source: EUROSTAT). In 2010, the EU annual roundwood 
production was roughly valued at ca. EUR 16.1 billion (Forest Europe, 2011).  

Non-wood goods 

In addition, non-wood goods (NWGs) are an important source of income and their share 
of the total economic value generated by forests is increasing. In 2010, Christmas trees, 
fruits  and  berries,  and  cork  were  the  most  important  NWGs.  The  total  annual  value  of 
marketed NWGs represents ca. 15% of the roundwood value (or EUR 2.4 billion). The 
annual value of total marketed services82 represents ca. 7% of the roundwood value (or 
EUR  1.1  billion).  In  total,  therefore,  EU  forests  supply  primary  goods  and  services 
valued at nearly EUR 20 billion per year. 

Forest-based industries 

The  EU27  forest-based  industries,  with  a  production  value  of  EUR  365  billion  and  an 
added  value  of  EUR  120  billion  account  for  more  than  3  million  jobs  in  344,000 
enterprises  (DG  ENTR).  In  addition  to  their  economic  weight,  many  parts  of  these 
industries  play  an  essential  role  in  maintaining  sustainable  employment  in  rural  areas, 
and in the woodworking and printing sectors, SMEs are particularly present.  

The availability of wood as a raw material at a competitive price is a determining factor 
for the performance and potential added value generated by many EU industries. Wood is 
the highest cost component in most downstream sectors (in paper making more than 30 
% of total costs are for wood; in the sawmill industry 65 to 70%). The price of wood can 
fluctuate considerably depending on prevailing supply and demand conditions which are 
inter  alia  influenced  by  plant  pests  and  diseases  and  their  impact  on  the  availability  of 
wood at the required quality.  

The  woodworking  industries  (excluding  furniture  sector)  have  a  turnover  of  EUR  134 
billion and generate an added value of EUR 37 billion, employing 1.3 million people in 
197,000  enterprises  (DG  ENTR).  Most  companies are small or medium-sized; the only 
exception  are  the  wood-based  panel  sub-sector  and  a  handful  of  sawmills  having  large 
enterprises.  Together  the  woodworking  and  furniture  industry  has  an  estimated 
production value of ca. EUR 240-260 billion and is dominated by five MS (DE, IT, FR, 
UK, ES), which together account for EUR 170 billion or two thirds of the EU27 output 
value. 

Wood packaging material 

With regards to the wooden pallet and packaging industry, 3 billion pallets circulate and 
450  million  pallets  are  manufactured  annually  in  the  EU;  90  %  of  all  trade  flows  use 
WPM in some form. The WPM is also significant for the wood sector in that 22-25% of 
all sawn timber are used for WPM and the industry is also a major employer (directly and 
indirectly), especially in rural areas (source: FEFPEB).  

82 The reported marketed services are forest-dependent or mainly forest-related and include social services 
(e.g. hunting or fishing, recreation and tourism), ecological services (such as environmental functions 
as well as infrastructure and managed natural resources), biospheric services (e.g. related to functions 
provided by protected and conservation sites). 

92 

 
 
 
                                                 
Trade 

Trade of forest-based products is very important, particularly within the EU27: in recent 
years  imports  (intra-EU  and  extra-EU)  have  reached  circa  EUR  100-110  billion  and 
exports  circa  EUR  110-120  billion.    The  EU  is  a  net  importer  of  forest-based  products 
from third countries (2009: extra-EU imports worth EUR 6.3 billion and exports worth 
EUR 3.2 billion). 

Wider benefits of forests 

On average, 13% of forest areas in the EU-27 have protective functions; however, most 
forests have many functions and may be protective without being officially designated as 
such. Certain stands are protected, e.g. in national parks, where the trees themselves are 
protected  as  well  as  all  the  habitats  they  provide  for  other  plants  and  animals.  Other 
stands  have  protective  functions,  e.g.  for  water  resources  or  to  prevent  erosion  (soil, 
water  and  other  ecosystems  functions)  and  to  prevent  landslides  and  avalanches  in 
mountainous  areas  (infrastructure  and  managed  natural  resources  functions).  Forests 
growing  on  very  steep  slopes  can  thus  protect  other  forests  growing  below  them, 
settlements,  roads  and  railways  in  ways  that  would  be  very  expensive  to  replace  by 
manmade structures. (source: Eurostat 2009).  

From  an  environmental  viewpoint,  forests  and  forest-based  industries  have  a  strategic 
role in climate change mitigation. Forests act as carbon sinks by capturing carbon dioxide 
from the atmosphere and storing it in wood, thus reducing the climate-changing effect of 
this greenhouse gas. Carbon storage in harvested wood products can  extend the carbon 
sequestration  benefits  provided  by  forests;  their  role  in  mitigating  climate  change  is 
therefore important.  The available data (Eurostat, 2009) show that at least 9,580 million 
tonnes  of  carbon  are  stored  in  the  EU27  woody  forest  biomass;  additional  amounts  are 
stored in the forests’ deadwood (in addition, carbon is stored in similar biomass on other 
wooded land, but this has only been estimated in certain MS). 

The  wider  benefits  of  forests  have  been  estimated  in  some  studies.  For  example,  the 
landscape/recreational  value  and  the  biodiversity/carbon  sequestration  value  have  been 
estimated by the UK Forest research (2010) for specific tree species: e.g. oak (Quercus 
spp.):  £240  million  (EUR  270  million)  and  £750  million  (EUR  844  million)  per  year, 
respectively;  Corsican  pine:  £42  million  (EUR  47  million)  and  £28  million  (EUR  32 
million) per year, respectively. The high values of these environmental benefits of forests 
in one MS point to the extensive wider environmental value of forests in the EU27 as a 
whole;  the  total  UK  coniferous  and  broadleaved  area  accounts  for  ca.  2%  of  the  total 
EU27  forestry  area. 
the 
landscape/recreational  value  and  the  biodiversity/carbon  sequestration  value  of  EU27 
forests could therefore be valued at ca. EUR 56 billion.  

  By  simple  extrapolation  on 

these  UK  estimates, 

93 

 
 
 
Annex VII: Relevance of harmful organisms and invasive alien  
plant species to the EU agriculture and forestry, environment, 
landscape and public and private green 

This  Annex  provides  an  overview  of  the  250  harmful  organisms  listed  in  Council 
Directive  2000/29/EC  as  relevant  to  the  various  sectors  (agriculture,  forestry,  natural 
environment) and provides some examples of their importance. 

The plant health Directive (PHD) requires import controls for all plants for planting (also 
called nursery stock) and for some specified seeds: 

−  Planting  material  are  the  commodities  with  the  highest  level  of  risk  as  living 

plants with roots can harbour numerous pests in a invisible (latent) form;  

−  Seeds  are  a  much  lower  risk,  because  the  generation  of  seeds  is  a  biological 

cleaning-up process which few pests can pass.   

The  import  inspections  on  plants  for  planting  require  checks  for  the  compliance  with 
specific  import  requirements  (these  should  have  been  fulfilled  by  the  third  country),  in 
particular the absence of the listed pests in Annexes I and II of the PHD. All sectors start 
with plants for planting, unless they can start with seed83. 

Import  inspections  for  seeds  are  restricted  to  sunflower  seed,  beet  seed,  lucerne  seed, 
bean  seed,  tomato  seed,  and  cereal,  maize  and  rice  seed.  The  inspections  target  12 
specific  virus,  bacteria  and  fungi,  in  addition  to  the  requirement  that  the  seeds  are  free 
from the other harmful organisms listed in Annex I. 

Examples  of  the  relevance  of  plant  health  measures  are  given  below.  For  further 
information, see Pimentel (2011), in particular Chapter 8 (A. Roques, Invasive patterns 
of  terrestrial  invertebrates  in  Europe)  and  Chapter  9  (I.  Sache  et  al.,  Invasive  plant 
pathogens in Europe).  

Cereals 

Tilletia indica (karnal bunt) is a major regulated fungus on wheat, that is not present in 
the EU. It is locally present in the US with a limited distribution. An economic analysis 
for the US Department of Agriculture demonstrated that deregulation would result in an 
average annual loss of 15.1% in export markets for US wheat producers, a reduction in 
wheat prices of 7.5% and a reduction of national net farm income of $8 billion below the 
baseline be cause of the loss in export markets over a time period of eight years (Vocke 
et al., 2010).  

Cereals  amount  to  14%  of  EU  agricultural  gross  output  at  basic  prices.  The  EU  has  a 
considerable trade surplus for cereals, which in 2010 was equal to 23.2 mio tonnes. The 
value  of  cereal  exports  to  third  countries  in  2010  was  EUR  9.5  billion  and  that  of  the 
imports EUR 3.4 billion (net trade surplus of EUR 6.1 billion). 

Diabrotica virgifera virgifera (western corn rootworm) is the most important insect pest 
of  maize  in  North  America,  where  it  causes  US$  1  billion  losses  annually  and  is 
nicknamed  the  "billion  dollar  bug".  WCR  is  probably  the  most  important  maize  pest 

83 This depends on the nature of the crop; some can only start with seeds for biological reasons and others 

only with vegetatively produced cuttings or young plants. 

94 

 
 
 
 
 
                                                 
worldwide and induces the highest insecticide use in the world. Up to 1992, the pest was 
absent  from  Europe.  Since  its  introduction,  it  has  spread  across  most  of  eastern  and 
central  Europe.  The  damage  caused  by  this  new  pest  for  the  EU-27  is  estimated  to 
amount to 5.6 to 6.3 billion euro over the next 25 years (FCEC, 2009). Costs associated 
to the eradication of isolated new WCR outbreaks in Member States that are WCR-free 
vary  from  EUR  240.000  to  EUR  3,610.000.  The  WCR  case  shows  that  effective 
prevention  of  the  entry  of  the  pest  into  Europe  would  have  been  by  far  the  most  cost-
effective measure (billions of euros savings). 

Aphelenchoides besseyi (the rice white tip nematode) has been reported causing serious 
losses  to  rice  in  Japan  and  parts  of  the  USA  (especially  from  1935  to  1945).  Attack 
results in poorly  filled  or unfilled, chaffy grains; the proportion of  the  latter may  be  as 
high  as  40%  in  some  cultivars,  but  early-ripening  cultivars  are  relatively  less  affected. 
Yield  reductions  in  rice  of  17-54%  and  0-24%  have  been  recorded  for  susceptible  and 
resistant cultivars, respectively (CABI/EPPO, 1997). The pest is not known to occur in 
the EU. 

Xanthomonas  campestris  pv.  oryzae  (bacterial  leaf  blight  of  rice)  is  the  most  serious 
disease of rice in South-East Asia. In the Philippines, losses are of the order of 22.5% in 
wet to 7.2% in dry seasons in susceptible crops and 9.5-1.8%, respectively, in resistant 
crops (CABI/EPPO, 2007). The pest is not known to occur in the EU. 

Sugar beet 

Beet necrotic yellow vein virus is the cause of Rhizomania, which is considered the most 
serious  disease  of  sugarbeet  world-wide.  It  was  first  reported  in  northern  Italy  in  1952 
and  has  since  spread  to  nearly  all  areas  of  the  world  where  sugarbeets  are  grown.  
Although the disease will only move a few inches per year through soil without aid, it is 
easily  spread  by  infected  plant  material,  within  soil  adhering  to  non-host  root  crops, 
agricultural equipment carrying contaminated soil, irrigation water, and any other means 
that can move even small amounts of soil. 

For 2010-2011, the sugar production in the EU amounted to 15 million tonnes generated 
on 1.5 mio ha. The value of the intra-EU sugar trade was EUR 2.8 billion (imports) and 
EUR 2.9 billion (exports). 

Vegetables and ornamentals 

Numerous  polyphagous  (i.e.,  non  host  specific)  pests  are  listed  in  the  PHD  that  are 
relevant to vegetables and ornamentals and so far do not occur in the EU.  

Bemisia whiteflies transmit numerous viruses, which can be extremely damaging. Non-
European populations of whiteflies are prohibited from entry into the Union so as to keep 
out  those  foreign  viruses.  With  the  evolution  of  the  highly  polyphagous  B  biotype,  B. 
tabaci  became  a  pest  of  glasshouse  crops  in  many  parts  of  the  world,  especially 
Capsicum,  courgettes  (Cucurbita  pepo),  cucumbers  (Cucumis  sativus),  Hibiscus, 
Gerbera,  Gloxinia,  lettuces  (Lactuca  sativa),  poinsettia  (Euphorbia  pulcherrima)  and 
tomatoes  (Lycopersicon  esculentum).  B.  tabaci  moves  readily  from  one  host  species  to 
another  and  is  estimated  as  having  a  host  range  of  around  600  species  (Asteraceae, 
Brassicaceae,  Convolvulaceae,  Cucurbitaceae,  Euphorbiaceae,  Fabaceae,  Malvaceae, 
Solanaceae,  etc.).  B.  tabaci  is  the  vector  of  over  60  plant  viruses  in  the  genera 
Geminivirus,  Closterovirus,  Nepovirus,  Carlavirus,  Potyvirus  and  a  rod-shaped  DNA 

95 

 
 
 
virus. The geminiviruses are by far the most important agriculturally, causing yield losses 
to crops of between 20 and 100% (CABI/EPPO, 1997).  

Liriomyza sativae (the vegetable leaf miner) is reported as economically damaging on a 
wide range of vegetables including tomatoes, potatoes and Cucurbita. L. sativae has been 
recorded as causing 30% defoliation in an 80-ha field of tomatoes in the USA. Cucurbit 
crops severely attacked in the seedling stage by L. sativae can be totally destroyed. The 
species transmits a number of plant viruses, including celery mosaic potyvirus. Damage 
is  caused  by  larvae  mining  into  leaves  and  petioles.  The  photosynthetic  ability  of  the 
plants  is  often  greatly  reduced  as  the  chlorophyll-containing  cells  are  destroyed 
(CABI/EPPO, 1997). The PHD regulates several Liriomyza species. 

Spodoptera spp. (cotton leafworm) are polyphagous and attack over 40 families. In most 
of  Europe,  outdoor  crops  are  not  likely  to  be  attacked  and  the  principal  hosts  are 
ornamentals  under  glass.  In  the  south  of  Europe,  cotton,  lucerne,  soyabeans,  Trifolium 
and  vegetables  are  hosts  for  Spodoptera  spp.  S.  litura  is  an  extremely  serious  pest,  the 
larvae  of  which  can  defoliate  many  economically  important  crops.  Its  control  requires 
high  pesticide  inputs.  S.  littoralis  is  similarly  one  of  the  most  destructive  agricultural 
lepidopterous  (butterfly)  pests  within  its  subtropical  and  tropical  range.  It  can  attack 
numerous  economically  important  crops  (cotton,  groundnuts,  tomatoes)  all  the  year 
round.  In  Europe,  damage  due  to  S.  littoralis  was  minimal  until  about  1937.  In  1949, 
there was a catastrophic larval population explosion in southern Spain. The main crops 
affected were lucerne, potatoes and other vegetable crops. At present, this noctuid is of 
great  economic  importance  in  Cyprus,  Israel,  Malta,  Morocco  and  Spain.  In  Italy,  it  is 
especially  important  on  protected  crops  of  ornamentals  and  vegetables  (CABI/EPPO, 
1997). 

Thrips palmi (melon thrips) can cause damage to a wide range of glasshouse ornamentals 
and vegetable crops, particularly plants in the cucurbit and tomato families. The pest is 
not established in Europe but several glasshouse outbreaks have occurred which all were 
eradicated.  In  the  UK,  a  study  estimated  the  net  economic  impact  of  T.  palmi  over  10 
years  at  ca.  EUR  20  mio  (FCEC,  2011).  Cost  ratios  for  eradicating  outbreaks  and 
maintaining exclusion of T. palmi ranged from 4:1 to 19:1 excluding the loss of exports 
and from 95:1 to 110:1 including export losses.   

Potato 

A range of internationally regulated pests poses a threat to potato cultivation. Brown rot 
(Ralstonia solanacearum), a bacterium, causes production losses of up to 75% in the 
tropics and the Mediterranean and in northwest Europe up to 40% (Rafoss & Sletten, 
2004). Direct damage from potato ring rot may reach up to 30% of the crop yield (field 
trials show up to 50% loss) (FCEC, 2011). Potato export requires freedom from regulated 
pests such as brown rot, ring rot (Clavibacter michiganensis spp. sepedonicus) and potato 
cyst nematodes (Globodera pallida and G. rostochiensis). Costs for Member States of 
regulated potato pest outbreaks can be high. For example, the impacts of regulated pest 
outbreaks for the Netherlands alone (with an annual production value of potato of EUR 
700 million, of which EUR 300 million seed potatoes) could include export losses up to 
EUR 192 million annually (Breukers, 2007) if no measures would be taken. In 2000-
2001, a small outbreaks of potato wart (Synchytrium endobioticum) on Prince Edward 
Island, the main export seed potato area of Canada, caused a near collapse of the sector 
due to the loss of its main export market, the US.  

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The EU plant health regime lists 16 regulated pests for potato, mainly from South and 
Middle America (the region of origin of potato where the largest diversity of its pests 
exists), most of which today do not occur in Europe (those that do occur in the EU are 
under strict control). Entry of these into the EU and uncontrolled spread would 
immediately impact on trade from the EU (import bans). So far, the EU plant health 
regime has succeeded to keep these exotic regulated pests of potato out. Permanent 
surveillance for them across the EU territory on Solanaceous crops (potato, tomato, 
eggplant, peppers, ornamentals), albeit costly, is essential to ensure that the EU remains 
free from these pests. 

Economic  studies  have  shown  that  intensified  monitoring  for  regulated  potato  pests  is 
highly  cost-effective  (Breukers,  2007;  Breukers  et  al.,  2007,  2008).  In  terms  of  profit 
margin,  the  impact  of  brown  rot  findings  can  be  disastrous.  If  a  potato  lot  is  found 
infected,  the  company  or  industry  sees  the  profit  margin  on  this  lot  reduced  from 
approximately EUR 1,575/ha for seed potatoes to EUR 0 (if found infested) or to EUR 
75/ha  (for  clonally  related  lots  which  are  not  found  infested  themselves).  Short-term 
gains  by  economizing  on  monitoring  and  control  could  easily  result  in  long-term  costs 
that more than outweigh the initial savings. At long term, the whole export market would 
be  lost  because  of  protective  measures  taken  by  the  countries  of  destination.  Optimal 
cost-effectiveness of control requires cooperation of the sector and government, in which 
case brown rot incidence in the Netherlands could be reduced by 75% and the costs of 
control could be reduced by at least 2 million euros per year (Breukers et al., 2007). 

The production value of potatoes in the EU is around EUR 9 billion. On average, total 
EU potato trade is valued at EUR 4.8 billion, of which EUR 3.9 billion is intra-EU trade. 
On a world scale, the EU production of potatoes is increasingly competitive and valuable, 
specifically as concerns seed potatoes. Of the average potato export surplus over 2008-
2010 of EUR 413 mio, a large part was attributable to exports of seed potatoes (EUR 266 
mio).  Besides  this,  the  EU  is  also  a  significant  net  exporter  of  processed  potatoes 
(average  trade  surplus  over  2008-2010:  EUR  456  mio).  In  the  new  Member  States, 
potatoes play a very important role, especially in Poland and in the Baltic countries, with 
a high number of small holdings cultivating potatoes.  

The importance of potato for the EU goes back to the 19th century, when Phytophthora 
infestans,  the  late  blight  fungus,  entered  Europe  from  southern  or  middle  America  and 
caused the Great Famine in Ireland (O'Grada, 2002). 

Tomato 

Tomato is attacked by many of the polyphagous vegetable pests and viruses mentioned 
above.  Protection  against  regulated  pests  is  very  important  to  tomato  production  given 
the tomato production value in the EU is estimated at EUR 9.3-EUR 12.7 billion (FCEC, 
2011). 

The introduction of new non-European pests can be extremely damaging. Recently, the 
south-American  leafminer  Tuta  absoluta  reached  the  EU  and  spread  rapidly  across  the 
EU on tomato fruits. It was not listed in the plant health Directive and was detected too 
late  for  effective  action.  Infestation  is  also  reported  on  potato,  eggplant  and  common 
beans.  Tuta  absoluta  is  a  very  challenging  pest  to  control.  Effectiveness  of  chemical 
control is limited due to the rapid development of insecticide resistant strains.    

97 

 
 
 
Potato spindle tuber viroid, a pest that is absent from the EU (various outbreaks have all 
been eradicated) could cause yield losses in tomato of 20% for an individual grower and 
a  1%  yield  loss  for  the  sector  as  a  whole  (ca.  EUR  100  mio  per  year)  if  allowed  to 
establish and  spread.  In addition, a 30% yield loss could occur in potato (ca.  EUR 567 
mio per year). 

The tomato seed sector is especially sensitive to outbreaks of regulated pests because of 
the extremely high value of tomato seed (one kg of tomato seed at the end of the season 
yields a profit in terms of tomato fruits that is worth more than 1 kg of gold). In the past 
five  years,  outbreaks  occurred  in  the  EU  of  the  regulated  bacterium  Clavibacter 
michinagensis  pv.  michiganense  which  can  cause  up  to  70%  production  losses 
(CABI/EPPO,  1997).  The  tomato  seed  sector  has  gone  far  to  trace  the  source  of  these 
outbreaks and ensure complete eradication. Loss of trust can lead to tremendous damage 
to the seed sector and may cause the collapse of even multinational enterprises. 

Citrus 

The EU plant health Directive lists 36 pests of citrus. Xanthomonas axonopodis pv. citri 
(citrus canker)  and Guignardia citricarpa (citrus black spot) are examples of  pests that 
must be kept out of Europe as they would pose a serious threat to EU citrus production 
and export.  

Citrus  canker  used  to  be  absent  from  the US,  where  it  was  unfortunately  introduced  in 
1999,  after  which  EUR  800  million  were  spent  by  the  competent  authorities  on 
compensation and control costs (Waage et al., 2007). The fight against citrus canker was 
lost due to among others a series of hurricanes in Florida. The US citrus sector is now 
faced with permanently higher production costs and export market losses.   

Citrus production in the EU in 2010 amounted to EUR 3.9 billion. 

Other fruit trees, small fruits 

Rosaceous fruit trees (apple, pear, plum, peach, apricot) and small fruits are susceptible 
to  many  pests.  The  PHD  Annexes  list  37  pests  specifically for this purpose. Fruit trees 
need  to  remain  healthy  for  many  years  and  infestations  generally  cannot  be  eradicated 
(e.g. many viruses and bacteria). This is a vulnerable but important sector for the EU (the 
value  of  the  export  from  the  EU  to  third  countries  in  2010  of  apples,  pears,  quinces, 
apricots, cherries, peaches and plums was EUR 1.2 billion).  

Vine 

The PHD annexes list 6 pests specific for vine. Daktulosphaira vitifoliae (phylloxera) is 
the  most  well-known  pest  of  vine.  In  the  late  19th  century,  the  phylloxera  epidemic 
destroyed  most  of  the  vineyards  for  wine  grapes  in  Europe,  most  notably  in  France. 
Phylloxera was introduced to Europe when avid botanists in Victorian England collected 
specimens  of  American  vines  in  the  1850s.  Because  phylloxera  is  native  to  North 
America,  the  native  grape  species  there  are  at  least  partially  resistant.  By  contrast,  the 
European  wine  grape  (Vitis  vinifera)  is  very  susceptible  to  the  insect.  The  epidemic 
devastated vineyards in Britain and then moved to the mainland, destroying most of the 
European  grape  growing  industry.  In  1863,  the  first  vines  began  to  deteriorate 
inexplicably in the southern Rhône region of France. The problem spread rapidly across 
the continent. In France alone, total wine production fell from 84.5 million hectolitres in 

98 

 
 
 
1875  to  only  23.4  million  hectolitres  in  1889.  Some  estimates  hold  that  between  two-
thirds and nine-tenths of all European vineyards were destroyed84. 

Trees (forests, landscape, public and private green) 

The  PHD  Annexes  list  53  pests  of  trees  (both  broadleaved  and  coniferous).  More  than 
50%  of  invasive  plant  pathogens  attack  woody  plants  (Pimentel,  2011,  p.  229).  Some 
examples of the risk posed by these pests are provided. 

Agrilus  planipennis,  the  emerald  ash  borer,  recently  arrived  in  the  Moscow  region.  In 
North America, this woodborer already killed over 15 million ash trees (Fraxinus spp.) in 
a  few  years.  The  Asian  emerald  ash  borer  expansion  to  the  west  of  Russia  is  seriously 
threatening the European ash forests (Pimentel, 2001, p. 207). 

Anoplophora chinensis and A. glabripennis (citrus longhorned beetle (CLB) and Asiatic 
longhorned beetle (ALB)) have a wide range of potential host species, with Acer being 
especially  susceptible  and  furthermore  Betula,  Salix,  Aesculus,  Fagus,  Carpinus  and 
Populus.  Citrus  is  also  susceptible  to  CLB.  Several  outbreaks  of  ALB  and  CLB  have 
occurred in the EU, probably due to the import of infested live woody plants. Pest risk 
analysis has shown that the potential economic and environmental impact of both CLB 
and  ALB  is  high  to  massive.  In  its  native  range,  ALB  has  killed  millions  of  trees  in 
China,  whereas  the  greatest  losses  from  CLB  in  Asia  (its  natural  homeland)  have 
occurred in fruit tree plantations, especially citrus (FCEC, 2011).  

Bursaphelenchus xylophilus (pine wood nematode). The pine wood nematode (PWN) is a 
serious  pest  of  conifers,  which  is  vectored  by  bark  beetles  of  the  genus  Monochamus. 
PWN is native to north America, where it does little damage to pine trees (co-evolution). 
PWN  spread  to  southeast  Asia  in  the  early  20th  century  where  it  subsequently  caused 
mass mortality of conifer forests in Japan, China, Korea and Taiwan. The main means of 
spread of PWN is with infested wood moved to other areas. To offer protection against 
PWN  and  other  wood-vectored  pests,  the  IPPC  developed  International  Standard  for 
Phytosanitary  Measures  No.  15  concerning  appropriate  treatment  of  wood  packaging 
material. 

PWN outbreaks occurred in Portugal in 1999. The EU put in place emergency measures 
for its eradication. Despite these, the pest spread within Portugal, the continental part of 
which  is  now  a  demarcated  area  for  PWN.  It  spread  also  to  Madeira.  Three  outbreaks 
occurred  in  Spain  which  are  being  eradicated  with  large-scale  felling,  monitoring  and 
testing.  The  area  at  risk  in  the  EU  is  13  mio  hectares  of  coniferous  forest  in  southern 
Europe where 50-90% mortality is predicted (valued at EUR 39-EUR 49 billion) (FCEC, 
2011).  Spread  of  PWN  would  additionally  impact  on  central  European  forests  and  on 
exports from Scandinavian forests. 

Ceratocystis  fagacearum  (oak  wilt)  occurs  in  the  US,  with  considerable  damage 
occurring  in  the  Midwest.  It  was  first  recognized  as  an  important  disease  in  1944  in 
Wisconsin where, in localized areas, over half the oaks have been killed. Surveys in eight 
Wisconsin counties showed that  about 11  percent  of the annual growth increase of  oak 
forests  was  offset  by  mortality  caused  by  oak  wilt.  No  species  of  oak  is  known  to  be 
immune  to  this  vascular  disease.  Experiments  have  demonstrated  that  over  35  oaks  are 

84 Source of historic information: http://en.wikipedia.org/wiki/Phylloxera 

99 

 
 
 
                                                 
susceptible,  as  well  as  American  and  European  chestnuts.  Oak  bark  beetles, 
Pseudopityophihorus spp., transmit the fungus. They breed abundantly beneath the bark 
of oak wilt- infected trees. After egg laying, parents emerge carrying spores and feed on 
healthy oaks. Unfortunately, there is no known way to save an oak tree infected by the 
oak wilt fungus. The only way to maintain healthy trees is through prevention85. 

Cryphonectria  parasitica  (chestnut  canker).  Before  the  turn  of  the  19th-20th  centuries, 
the American chestnut (Castanea dentata) was arguably the most important broadleaved 
tree in the forests of the eastern US, comprising some 25% of the individual trees present 
in these ecosystems which covered some 82 mio hectares. Estimates suggest that over 4 
billion  chestnut  trees  were  present  in  the  eastern  broadleaved  forests  at  the  end  of  the 
19th century. Some of the largest angiosperm trees ever recorded were chestnuts present 
in  these  forests.  The  trees  were  heavily  exploited  and  the  timber  was  in  great  demand. 
The  chestnuts  were  an  important  food  source  for  many  wild  animals.  In  1904,  the  first 
reports of chestnut blight emerged in New York, following shipments of chestnut timber 
from Asia. In 40 years time, chestnuts were largely wiped out from north America (BIO 
Intelligence  Service,  2011).  The  chestnut  blight  case  is  a  textbook  example  of  the 
necessity of effective quarantine legislation.  

Dendroctonus  ponderosae  (mountain  pine  beetle)  is  a  bark  beetle  that  is  not  present  in 
Europe. Expert analysis suggests that, if introduced, conditions would be favourable for 
its  establishment  and  spread.  The  native  European  pine  Pinus  sylvestris  (Scots  pine)  is 
susceptible to the beetle. Scots pine is the most widely distributed conifer in the EU, its 
range extending to large areas of the continent, covering a wide variety of environmental 
conditions  within  this  natural  range.  Scots  pine  forests  exceed  20%  of  the  productive 
forest area of the EU. The total area at risk in the EU is estimated at 30 mio hectare.  

In Canada, the mountain pine beetle has killed 70-80% of the pines on 16 mio hectares of 
pine forest in British Columbia, leading to the closure of 16 major sawmills and the long-
term  decline  of  the  forest  industry.  Experts  anticipate  that  it  would  also  affect  the 
availability of raw material for the construction industry in Canada and the US, while it is 
predicted to result in lumber shortage in the US by 2018 The extent of the damages has 
justified  significant  direct  control  costs:  in  2006,  the  Canada  federal  budget  provided 
$400 mio over two years to combat the infestation, including industry support. Beyond 
the  economic  impacts  as  such,  there  have  been  significant  environmental  impacts.  By 
2020,  the  mountain  pine  beetle  outbreak  will  have  released  270  megatonnes  of  carbon 
dioxide  into  the  atmosphere  from  Canadian  forests,  which  is  the  same  amount  of 
greenhouse gas emissions that Canada is committed to reducing by 2012 under the Kyoto 
Protocol, and more than the total average sink of all of Canada's managed forest over the 
last decade. The beetle has on its own converted the forest from a small net carbon sink 
to a large net carbon source (FCEC, 2011). 

Dryocosmus kuriphilus, the Asian chestnut gallmaker, seriously affects chestnut fruiting, 
causing yield reductions up to 70% (Pimentel, 2011, p. 207) and impacting on chestnut-
dependent  local  economies.  This  invasive  insect  is  spreading  in  Italy,  Slovenia, 
southeastern France, and Hungary. 

Ophiostoma ulmi (Dutch elm disease). Two enormously destructive pandemics of Dutch 
elm disease occurred in the 20th century, resulting in the death of a majority of mature 

85 Source: http://www.na.fs.fed.us/spfo/pubs/fidls/oakwilt/oakwilt.htm 

100 

 
 
 
                                                 
elms across much of the northern hemisphere. Despite the name given to the disease, it 
originated from Asia and not from Europe86. The first pandemic, caused by Ophiostoma 
ulmi,  occurred  as  this  pathogen  spread  across  Europe,  North  America  and  South  and 
Central Asia during the 1920s-1940s. The current pandemic is caused by another species, 
O.  novo-ulmi.  The  initial  pandemic  led  to  the  death  of  approximately  30%  of  infected 
trees,  but  many  individual  recovered  from  infection.  From  the  early  1930s,  a  more 
aggressice  disease  spread  in  the  US,  which  in  the  mid  1960s  reached  Europe  via 
shipments  of  elm  logs  imported  into  the  UK  from  North  America.  By  the  end  of  the 
1970s,  over  75%  of  the  elm  population  in  southern  England  was  dead  or  dying, 
approximately  17.5  mio  trees.  Since  that  time,  most  elms  in  the  UK  and  in  continental 
Europe have been killed, although there are still mature elms in some isolated areas and 
cities  such  as  Amsterdam  (elms  have  always  lined  the  historic  canals)  where  control 
measures  are  taken.  Once  a  very  common  tree  across  Europe,  like  poplar  today,  elms 
have substantially disappeared from Europe and most people would not even know elms 
any more. The disease has had major impacts on landscapes and ecosystems. Populations 
of  any  organisms  dependent  on  mature  elms  for  the  provision  of  food  or  habitat  have 
reduced as a consequence of the enormous losses in elm numbers in Europe over the last 
40 years. (BIO Intelligence Service, 2001; Brasier & Buck, 2011). 

Rhynchophorus ferrugineus (red palm weevil) is an extremely damaging pest of a wide 
range  of  productive  and  ornamental  palm  trees.  The  pest  reached  the  EU  via  Spain, 
probably  with  infested  planting  material  from  third  countries.  Red  palm  weevil  has 
spread  across  most  of  the  Mediterranean  where  it  has  killed  thousands  of  palms.  The 
impact  of  the  pest  in  the  EU  is  estimated  to  have  reached  at  least  EUR  50  mio  in 
containment  and  eradication  costs  for  the  MS  competent  authorities  alone  and  to  have 
involved  the  destruction  of  at  least  65,000  trees,  which  is  only  a  fraction  of  those 
infested. On the basis of the destroyed palms alone, the value of the trees lost is estimated 
at  EUR  65-EUR  195  mio,  on  the  basis  of  the  infested  palms,  EUR  96-EUR  288  mio. 
These  figures  underestimate  the  actual  loss  in  value  as  they  exclude  high-value  trees 
(FCEC, 2011). 

The  red  palm  weevil  and  the  palm  moth  (Paysandisia  archon)  threaten  the  survival  of 
three  endemic,  endangered  palm  species  in  Europe:  Phoenix  theophrasti  in  Crete,  P. 
canariensis in the Canary Islands, and Chamaerops humilis in the western Mediterranean 
region (Pimentel, 2011, p. 207). 

Natural environment and biodiversity 

Invasive alien species (IAS) pose a significant threat to biodiversity in the EU, and this 
threat is likely to increase in the future unless robust action is taken at all levels to control 
the introduction and establishment of these species and address those already introduced. 
IAS  cause  some  EUR  12.5  billion  worth  of  damage  each  year  in  the  EU  (European 
Commission, 2011, Our life insurance, our natural capital: an EU biodiversity strategy 
to 2020). 

The DAISIE project supported under the Sixth EU Research Framework Programme has 
identified 10,822 non-native species present in Europe, 10-15 % of which are expected to 
have a negative economic or ecological impact. Isolated islands with high  biodiversity, 
including  most  of  the  EU’s  overseas  entities,  are  exceptionally  vulnerable  to  invasion, 

86  The  name  "Dutch  elm  disease"  refers  to  its  identification  in  the  Netherlands  in  1921;  the  disease  is 

believed to be originally native to Asia. 

101 

 
 
 
                                                 
which can also have a disproportionate impact on local livelihoods, culture and economic 
opportunities.  As  regards  introduction  pathways,  most  invasive  plants originally  escape 
from gardens or aquaria, while invasive freshwater fauna reach the wild via aquaculture 
escapes or deliberate stocking by anglers. In contrast, most invasive species in the marine 
environment  are  unintentionally  introduced  as  "hitchhikers"  or  contaminants  (e.g.  via 
ballast  water).  With  increasing  volumes  of  plant  and  animal  materials  from  more  and 
more locations being transported across the globe, the potential for introduction of IAS is 
also rising. 

IAS are considered one of the major threats to biodiversity. Ways in which they impact 
on the local ecology include: 

−  Competition with native organisms for food and habitat; 

−  Changing ecosystem structures, for example the seaweed Caulerpa taxifolia has 
changed extensive areas of the Mediterranean coast into Caulerpa monocultures; 

−  Hybridisation with native species; 

−  Direct toxicity;  

−  Being a reservoir for parasites or a vector for pathogens;  

−  Disruption of pollination services due to competition with local bee species. 

IAS  can  reduce  yields  from  agriculture,  forestry  and  fisheries.  IAS  are  also  known  to 
decrease  water  availability  and  to  cause  land  degradation.  Invasive  plants  such  as  the 
Himalayan  balsam  (Impatiens  glandulifera)  outcompete  native  plants  that  play  an 
important  role  in  binding  soil  with  their  roots  and  may  thereby  contribute  to  increased 
soil erosion. IAS can damage infrastructure due to burrowing or via their root systems. 
The  root  system  of  the  Tree  of  heaven  (Ailanthus  altissima)  can  damage  pavements, 
archaeological  remains  and  walls.  IAS  may  also  obstruct  transportation  by  blocking 
waterways. Azolla waterfern (Azolla spp.) and Eastern White pine (Pinus strobus) have 
led  to  a  decline  in  recreational  and  cultural  heritage  values  associated  with  different 
landscapes and water bodies. A number of human health problems, e.g. allergies and skin 
problems, are caused by IAS such as the Giant hogweed (Heracleum  mantegazzianum) 
and the Common hogweed (Ambrosia artemisiifolia). 

The main identified costs in Europe comprise eradication and control costs and damage 
to  agriculture,  forestry,  commercial  fisheries,  infrastructure  and  human  health.  While  it 
may  appear  that  there  are  either  impact  costs  or  eradication  costs,  in  fact  partial 
eradication  and  control  programmes  are  undertaken  in  parallel,  on  an  ongoing  basis  in 
order to try and limit the impact. In 2008, an initial estimate assessed annual IAS-related 
costs  in  Europe  at  between  EUR  9,600  million  and  EUR  12,700  million  per  year.  This 
figure is undoubtedly an underestimate, as it is based on current expenditure to eradicate 
and  control  IAS  plus  the  documented  cost  of  the  economic  impact.  Given  that  many 
countries are only now starting to document and record costs and effects, the real figures 
for  the  financial  costs  involved  will  be  considerably  higher.  (European  Commission, 
2008, Towards an EU strategy on invasive species). 

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Examples of IAS plants and their impacts: 

−  Ambrosia  artemisiifolia:  one  of  the  most  damaging  IAS  weeds  in  Europe 
affecting  human  health  (highly  allergenic),  agriculture  and  biodiversity,  with  a 
total impact on Europe of EUR 225 mio annually (FCEC, 2011); 

−  Eichhornia  crassipes:  during  2005-2008,  Spain  spent  EUR  14.7  mio  to  remove 
nearly  200,000  tonnes  of  water  hyacinth  from  the  Guadiana  River.  In  Florida, 
EUR  30  mio  was  spent  during  1980-1991  to  suppress  water  hyacinth,  while  in 
Louisiana  the  Department  of  Fisheries  treats  about  25,000  acres  of  E.  crassipes 
with herbicides each year, at an annual cost of EUR 1.4 mio;  

−  Fallopia japonica: for the UK alone, annual control costs for Japanese knotweed 

are estimated at EUR 188 mio (Williams et al., 2010); 

−  Hydrocotyle  ranunculoides:  for  the  UK  alone,  annual  control  costs  for 
management of floating pennywort in waterways and aquatic systems (including 
effect on tourism) are estimated at EUR 142 mio (Williams et al., 2010); 
 Pueraria  lobata:  in  the  US,  about  2.8  mio  ha  of  forestry  are  overgrown  by  P. 
lobata,  and  the  losses  in  the  commercial  forestry  sector  from  decrease  of 
productivity are estimated at EUR 235 mio per year (FCEC, 2011). 

− 

103 

 
 
 
 
Annex VIII: Costs and expected impacts of baseline scenario 

This  Annex  describes  the  costs  and  expected  economic,  social  and  environmental 
impacts of the baseline scenario.  

Costs 

The  current  overall  compliance  costs  (including  administrative  burden  and  fees)  of  the 
PHR are as follows (FCEC, 2010):  

− 

Costs before the charging of fees by MS authorities to private operators 

Competent Authorities

Private operators

Commission

Total costs

Administrative Substantive Total

Administrative Substantive Total

Administrative Substantive Total

Administrative Substantive Total

Obligations

Obligation 1: Registration
EU 24

1.359.856

Obligation 2: Authorization to issue Plant Passport
EU 24

138.727

Obligation 3: Issuance of plant passport
EU 24

3.164.606

Obligation 4: Notification of interceptions in trade
EU 24

217.368

Obligation 5: keeping of records
EU 24

0

Obligation 6: Check the correct and uniform application of CPHR
EU 24

277.774

0

0

0

0

0

0

1.359.856

1.490.585

138.727

134.372

3.164.606

8.286.093

217.368

0

0

41.373.782

Obligation 7: Submission and treatment of applications for Solidarity Funding
EU 24

28.322

0

Obligation 8: Import inspection (at border or at place of destination)
EU 24

0

25.983.570

25.983.570

277.774

28.322

Obligation 9: Official inspection of plants, plant products and other objects at the places of production 
EU 24
0

33.320.135

33.320.135

0

Obligation 10: Annual survey of protected zones or buffer zones
EU 8

0

563.557

Obligation 11: Annual surveys of regulated harmful organisms
EU 24

0

27.563.913

563.557

27.563.913

Obligation 12: Overall management of the Plant Health policy
EU 24

0

2.305.769

2.305.769

Obligation 13: Conduct Pest Risk Analysis (PRA)
EU 8
Total costs

0

709.709

709.709

5.186.653

90.446.654

95.633.307

51.284.831

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1.490.585

134.372

8.286.093

0

0

0

0

115.386

41.373.782

0

0

0

0

0

0

0

0

0

553.235

15.924

0

0

0

35.829

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2.850.441

273.099

11.450.699

115.386

332.753

0

41.373.782

553.235

831.010

15.924

44.246

0

0

0

0

0

0

0

2.850.441

273.099

11.450.699

332.753

41.373.782

831.010

44.246

0

0

0

0

0

0

25.983.570

25.983.570

33.320.135

33.320.135

563.557

563.557

35.829

35.829

27.563.913

27.599.743

555.832

555.832

604.860

604859,85

0

0

2.861.600

2.861.600

1.314.569

1.314.569

51.284.831

720.375

1.160.691

1.881.066

57.191.859

91.607.345

148.799.204

− 

Costs after the charging of fees by MS authorities to private operators 

Administrative

Competent Authorities
Substantive

Total

Private operators

Commission

Total costs

Administrative Substantive Total

Administrative Substantive Total

Administrative Substantive Total

Obligations

Obligation 1: Registration
EU 24

Obligation 2: Authorization to issue Plant Passport
EU 24

Obligation 3: Issuance of plant passport
EU 24

Obligation 4: Notification of interceptions in trade
EU 24

Obligation 5: keeping of records
EU 24

1.236.625

101.272

3.164.606

217.368

0

Obligation 6: Check the correct and uniform application of CPHR
EU 24

277.774

Obligation 7: Submission and treatment of applications for Solidarity Funding
EU 24

28.322

277.774

28.322

Obligation 8: Import inspection (at border or at place of destination)
EU 24

0

8.495.711

8.495.711

Obligation 9: Official inspection of plants, plant products and other objects at the places of production 
EU 24

14.553.688

14.553.688

0

1.236.625

1.613.816

101.272

171.827

3.164.606

8.286.093

217.368

0

0

41.373.782

0

0

0

0

0

0

0

0

0

0

0

0

0

0

1.613.816

171.827

8.286.093

0

0

0

0

115.386

41.373.782

0

0

0

553.235

15.924

17.487.859

17.487.859

18.766.448

18.766.448

0

0

0

0

0

0

0

0

0

0

0

35.829

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2.850.441

273.099

11.450.699

115.386

332.753

0

41.373.782

553.235

831.010

15.924

44.246

0

0

0

0

0

0

0

2.850.441

273.099

11.450.699

332.753

41.373.782

831.010

44.246

0

0

0

0

0

0

25.983.570

25.983.570

33.320.135

33.320.135

563.557

563.557

35.829

35.829

27.563.913

27.599.743

555.832

555.832

604.860

604859,85

0

0

2.861.600

2.861.600

1.314.569

1.314.569

0

0

0

0

0

0

0

0

0

0

0

0

563.557

563.557

27.563.913

27.563.913

2.305.769

2.305.769

709.709

709.709

5.025.967

54.192.347

59.218.314

51.445.518

36.254.307

87.699.824

720.375

1.160.691

1.881.066

57.191.859

91.607.345

148.799.204

Obligation 10: Annual survey of protected zones or buffer zones
EU 8

Obligation 11: Annual surveys of regulated harmful organisms
EU 24

Obligation 12: Overall management of the Plant Health policy
EU 24

Obligation 13: Conduct Pest Risk Analysis (PRA)
EU 8
Total costs

Economic impacts 

Productivity, profitability, competitiveness (including level playing field) 

Primary  production.  Due  to  an  ongoing  increased  influx  of  harmful  organisms  that  are 
new  to  the  EU  and  to  an  increased  suitability  of  EU  agriculture,  forests  and  natural 
ecosystems  to  these  organisms  because  of  climate  change,  losses  from  new  plant  pests 
will  increase,  affecting  the  economic  viability  of  agriculture  and  forestry.  Reduced 

104 

 
 
 
 
 
 
 
 
productivity  is  to  be  expected,  profits  and  competitiveness  compared  to  third  countries 
will be under pressure.  

Trade.  With  the  establishment  of  internationally  recognised  regulated  pests  in  the  EU, 
trade restrictions will be put in place by third country trade partners, limiting the export 
of EU produce, with knock-on effects on farmers and growers whose produce cannot be 
sold  any  more  and  whose  investments  cannot  be  paid  back87.  This  is  enhanced  by  the 
current  deficiencies  in  the  surveillance  and  protected  zones  systems,  which  undermine 
trust in the reliability of pest status data for the EU as a whole and for specified protected 
zones. 

Internal market. Large-scale outbreaks in one MS may locally result in higher production 
costs  and  restrictions  to  movement  and  sales  from  demarcated  outbreak  areas  to  other 
MS. Already the current carefully set-up system of protected zones, which brings along 
higher costs for growers outside such zones, can distort the level playing field in the EU 
(FCEC, 2011; present stakeholder consultations). Large-scale outbreaks may have larger 
consequences:  the  impacts  of  phytosanitary  measures  against  expanding  outbreaks  of 
pine  wood  nematode  in  Portugal  were  assessed  by  FCEC  (2008)  to  potentially  have 
serious  consequences  on  the  Portuguese  economy,  depending  on  the  nature  of  the 
measures taken (FCEC, 2008). 

SME. The seed industry excepted, the affected producers in agriculture and forestry are 
mostly Small and Medium-sized Enterprises (SME). 

Industries.  With  large-scale  outbreaks,  supplies  to  agriculture  and  forestry  based 
industries may decline. In general, the economic value of these industries is a manifold of 
the primary production value (Annex VII). In some cases (e.g. citrus), the supplies may 
be obtained from third countries; in other cases (e.g. potato) third country supplies would 
not  be  able  to  meet  EU  demands  because  third  country  production  is  insufficient  or 
because  imports  are  not  allowed  because  of  plant  health  import  restrictions  concerning 
other regulated pests. 

Innovation 

No  action  will  have  negative  impacts  on  innovation  of  agriculture  and  horticulture,  as 
production, sales and profit will be under pressure.  

Social impacts 

Employment  

EU  primary  production  of  crops  in  2007  ensured  employment  for  16.4  mio  persons 
(equalling 9.0 mio annual work units), half of the value of which was attributable to crop 
production  (Eurostat,  2011).  Forestry  and  logging  in  2008  ensured  employment  for  0.3 
mio annual work units, while the wood-based manufacturing activities gave employment 
to  an  additional  2.8  mio  annual  work  units  (Eurostat,  2011).  Decreasing  production, 

87 Examples: the restriction imposed by the US in 2011 on nursery stock from the entire EU because of the 
local incidental outbreaks of Anoplophora chinensis and A. glabripennis; the loss of 15.1% of wheat 
export  marekets  for  the  US  if  the  quarantine  status  of  Tilletia  indica  within  the  US  would  be  lifted 
(Vocke et al., 2010); the EHEC bacterium  crisis in April-June 2011, which did not concern harmful 
organisms of plants but human pathogens vectored by plant food material. A trade ban was imposed by 
Russia on EU vegetable produce; the EU allocated compensations to a level of €210 mio.   

105 

 
 
 
                                                 
sales,  profit  and  export  imply  losses  of  jobs.  With  an  estimate  of  7.6  mio  annual  work 
units at stake (4.5 mio in crop production; 3.1 mio in forestry and forest-based industries) 
a  shrinkage  of  agriculture  and  forestry  with  1%  could  lead  to  a  loss  of  76,000  annual 
work  units  (jobs  for  138,000  persons).  The  average  income  of  EU  farmers  is  currently 
less  than  50%  of  the  average  EU  citizen  income  (COPA-COGECA,  reply  to  the 
stakeholder consultation) and margins in many sectors are small. In the past two decades, 
the  production  of  various  crops  (vegetables,  tomatoes,  cut  flowers)  has  already  been 
moving from the EU to developing countries, were wages are lower. This process will be 
enhanced if no action is taken. 

While the loss of jobs would generally be a gradual process, it may be acute in case of 
major  outbreaks  of  harmful  organisms.  Measures  against  recent  outbreaks  of  the  citrus 
longhorned beetle (Anoplophora chinensis) in the Netherlands in the Boskoop area, the 
major  nursery  stock  production  area  of  the  EU,  questioned  its  very  existence.  Potential 
measures  against  Portuguese  wood  to  stop  the  spread  of  pine  wood  nematode  were 
assessed to threaten 3,300 jobs (FCEC, 2008). An unprecedented outbreak of mountain 
pine beetle (Dendroctonus ponderosae) in Canada eliminated 70-80% of all pine trees in 
the  main  western  forests  of  British  Columbia  and  will  lead  to  the  closure  of  16  major 
sawmills and the long-term decline of the western Canadian forest industry; spread of the 
beetle out of infested British Columbia across the Rocky Mountains to Alberta alone will 
subsequently impact on a further 38,000 people (FCEC, 2011). 

Food security and safety 

At short term, the ongoing influx of new harmful organisms would not impact on food 
security for EU citizens if no action is taken. It is nevertheless questionable whether the 
EU can afford an ongoing influx of new pests and diseases. Global food production will 
need to increase by 40% by 2030 and 70% by 2050 because of increasing demand (FAO, 
2006).  It  should  be  stressed  that,  on  a  global  scale,  losses  from  harmful  organisms  are 
very  considerable.  It  is  estimated  that  these  losses  today  are  40%  (staple  foods)  and 
would  be  even  higher  (50-80%)  in  the  absence  of  control  measures  (estimate  for  all 
crops) (Bruce, 2010). Of those losses, probably 30% are due to newly introduced harmful 
organisms (Pimentel, 2005).  

Food safety is in principle not endangered by harmful organisms of plants, which rarely 
have a direct impact on human health. Certain harmful organisms (in particular fungi, for 
example  Claviceps  purpurea  and  Fusarium  spp.)  produce  metabolites  that  are  toxic  to 
humans,  those  organisms  are  mostly  have  a  worldwide  distribution  and  for  that  reason 
none of them is currently listed under the PHR. Certain human-pathogenic bacteria and 
viruses may be present on the surface of plants, or even invade the tissues of plants, like 
the EHEC bacterium. However, those bacteria and viruses do not cause any harm on the 
plants themselves and therefore are not regulated either under the PHR.  

The introduction and spread of new pests leads to an enhanced use of pesticides88, which 
might indirectly impact on food safety and human health. However, the EU legislation in 

88  According  to  Sache  et  al.  (in  Pimentel,  2011),  downy  mildew  and  powdery  mildew  of  grapevine, 
introduced  from  the  United States  in  the  19th  century,  consume  €180  mio  of fungicides  annually  for 
France alone. In 1991, €163 mio of fungicides were used worldwide against potato diseases, Europe 
accounting  for  59%  of  this  use.  Diseases,  including  potato  late  blight,  accounted  for  a  yield  loss  of 
15%,  which  could  have  reached  35%  if  no  fungicides  had  been  applied.  Since  then,  the  disease  has 
increased  in  aggressivity  and  earliness  in  most  European  countries,  a  shift  linked  to  the  invasion  of 

106 

 
 
 
                                                 
place for plant protection products already ensures that plant protection products can be 
used only when they are safe. 

Environmental impacts 

Sustainability (durability; use of pesticides) 

An  ongoing  influx  of  harmful  organisms  new  to  the  EU  will  impact  negatively  on  the 
sustainability. In agriculture, the introduction and spread of new pests and diseases nearly 
always  leads  to  an  enhanced  use  of  pesticides  so  as  to  maintain  previous  production 
levels. Alternatives (biological control, crop rotation) may be available but are generally 
less  profitable.  The  development  of  biological  control  agents  may  require  substantial 
investments  in  research  and  development  during  many  years  and  a  demanding  and 
expensive registration process at the end of the pipeline, often preventing new products 
from  being  placed  on  the  market  at  all.  Crop  rotation  may  be  effective  to  control  soil-
borne pests, however it implies by definition that crops with high profit margins (potato, 
maize)  cannot  be  grown  permanently,  which  undermines  its  economic  usefulness.  An 
example is the western corn rootworm (Diabroticia virgifera virgifera), a very damaging 
pest that is native to the US where it is known as the billion dollar bug due to its high 
control costs. This pest reached Europe in 1992 and has now spread over a large part of 
the EU. Farmers prefer to drop the current regulated status of this pests as they seem to 
trust that the pest can be controlled by the use of seed pesticide coating (against the soil-
borne larvae) and possibly in future GMO maize lines. Already in 2008, the total volume 
of insecticides used in the EU per year on maize crops amounted to 570 tons of active 
substance, mainly as seed and soil treatment; however, chemical control solutions have a 
limited  to  satisfactory  efficiency,  but  several  toxicity  issues  and  the  implementation  of 
the new Regulation on plant protection products might lead to the conclusion that these 
solutions are not sustainable in the long term (FCEC, 2009). The large scale use of seed 
coatings on maize seed may significantly contribute to bee hive mortality (Marzaro et al., 
2011; Apenet, 2010). 

According  to  Eurostat  (2007)89,  in  2003  some  129,000  tonnes  of  active  substance  of 
fungicides (108,000 tonnes) and insecticides (21,000 tonnes) was applied in the EU-25, 
in particular on potatoes and on cereals. A significant increase in the need for pesticides 
thus may result in substantial additional amounts being applied at EU level.   

Biodiversity and ecosystems conservation 

An  ongoing  influx  of  harmful  organisms  new  to  the  EU  will  also  impact  on  natural 
ecosystems and biodiversity. Those impacts would mostly be due to the introduction of 
new pests and diseases of forest trees, the decline of which would endanger the natural 
ecosystems which depend on them. Many tree species harbour specific lichens, mosses, 
insects and other wildlife. Disappearance of tree species may have serious consequences 
on  biodiversity.  In  addition,  some  new  harmful  organisms  directly  threaten  the 
undergrowth itself. An example is the fungus Phytophthora ramorum, which in the UK 
has spread from infected Rhododendron to Vaccinium species (heather) which appears to 
be  highly  susceptible  to  this  new  fungus.  Massive  decline  of  heath  in  the  UK,  the 

Europe  by  the  A2  mating  type.  In  Finland,  for  example,  sales  of  fungicides  used  against  late  blight 
increased after this introduction fourfold from the 19870s to 2002. 

89  Eurostat,  2007.  The  use  of  plant  protection  products  in  the  European  Union.  Data  1992-2003. 
http://epp.eurostat.ec.europa.eu/cache/ITY_OFFPUB/KS-76-06-669/EN/KS-76-06-669-EN.PDF  

107 

 
 
 
                                                                                                                                                 
Member State with the largest heathlands of the EU, would have very significant impact 
on the natural ecosystems and biodiversity. 

Among  the  harmful  organisms  invading  the  EU,  IAS  plants  are  particularly  harmful  to 
ecosystems  and  biodiversity.  Their  impact  concerns  not  only  terrestrial  ecosystems 
(invasive  weeds)  but  also  equally  aquatic  ecosystems  and  marine  ecosystems  (algae, 
aquatic  weeds).  IAS  plants  may  furthermore  clog  waterways.  Some  IAS  plants  are 
serious  human  allergens.  Several  IAS  plants  have  shown  to  cause  substantial  harm  to 
tourism  by  ruining  natural  ecosystems  and  lakes  and  therefore  require  expensive 
permanent control measures, with costs up to several hundreds of millions of Euros per 
year (FCEC (2011). An ongoing influx of IAS plants in the baseline scenario will cause 
increasing damage to ecosystems and increasing control costs. 

Health status of forests, landscape, public and private green 

An  ongoing  influx  of  harmful  organisms  new  to  the  EU  will  certainly  impact 
significantly  on  EU  forests,  landscape,  public  and  private  green.  Most  of  the  major 
problems experienced in the past decade concern tree pests (pine wood nematode, citrus 
longhorned  beetle,  red  palm  weevil).  The  20th  century  has  witness  the  potential  of 
invasive pests and pathogens to cause large-scale tree mortality, with the disappearance 
of  elm  trees  (Ulmus  spp.)  from  most  of  Europe  and  of  the  native  chestnut  (Castanea 
dentata)  from  the  eastern  US,  where  it  once  constituted  25%  of  the  vast  broadleaved 
forests.  Were  tree  pests  such  as  oak  wilt  (Ceratocystis  fagacearum)  or  mountain  pine 
beetle  (Dendroctonus  ponderosae)  to  reach  the  EU,  oaks  and  pines  could  similarly 
disappear. 

108 

 
 
 
 
 
Annex IX: Outline of the amendments to the regime in options 
1─4 and foreseen impact on costs 

This Annex presents an overview of the main elements of potential changes to the plant 
health regime and an estimate of the expected financial impacts. 

Prioritisation 

Changes under consideration:  

(a) 

(b) 

Creation  of  a  list  of  EU  priority  pests,  to  be  subject  to  enhanced  levels  of 
surveillance,  mandatory  contingency  planning and stricter  procedural rules for 
eradication  and  containment  (no  such  Annex  exists  at  present).  Priority  pests 
will  be  identified,  in  coordination  with  the  Member  States,  on  the  basis  of 
transparent  risk  assessment  criteria  (in  an  Annex  to  the  Regulation), 
demonstrating  that  their  economic,  social  and  environmental  impact  to  the 
Union as a whole is most severe. They will be listed as such in a delegated act, 
if necessary using the three-days urgency procedure. Priority pests may concern 
pests  that  so  far  do  not  occur  in  the  EU  (measures  against  such  pests  will 
anyhow  be  eligible  for  EU  co-financing) as  well  as  pests  already  occurring  in 
the  EU  but  requiring  stringent  EU  measures  (less  Member  State  subsidiarity; 
more EU financial support). The maximum number of priority pests to be listed 
will be set at 10% of all listed Union quarantine pests (10% of 250 = 25). 
Financial impact: see under surveillance, contingency planning and eradication 
and containment. 

Transformation  of  current  Annex  II  of  Directive  2000/29/EC  into  the 
Annex  of  an  implementing  act  concerning  harmful  organisms  for  which 
thresholds  may  apply.  The  current  Annex  II  will  be  amended  to  exclusively 
comprise  pests  that  do  not  require  territorial  protection  but  rather  pest-free 
planting  material.  Organisms  currently  listed  in  Annex  II,  Part  A,  Section  I 
(non-European organisms) and Annex II, Part B (organisms for which protected 
zones exist) require territorial measures and will therefore be transferred to the 
Annex  of  an  implementing  act  concerning  all  organisms  subject  to  territorial 
protection measures. The future "Annex II" will comprise pests from the current 
Annex  II,  Part  A,  Section  II  (pests  present  in  the  EU  that  in  practice  only 
require  pest-free  planting  material),  along  with  the  pests  currently  regulated 
under  the  PRM  regime  and  subject  to  the  certification  schemes  currently 
foreseen by the PRM regime.  
Financial  impact:  the  existing  arrangements  under  the  PRM  for  the  role  of 
operators will continue to apply, ensuring that the cost level is unaltered. Cost 
reductions  are  expected  for  the  pests  currently  in  Annex  II, Part  A,  Section  II 
that  are  transferred  to  the  new  Annex  II,  because  survey,  eradication  and 
containment  measures  will  no  longer  apply  to  them.  This  will  liberate  staff 
resources of the competent authorities for priority plant health tasks.  

At long term, further cost reductions are expected. It will be easier to change the 
status of regulated harmful organisms from territorial (quarantine) to marketing 
(quality), since such a change can be made in one legal Decision instead of by 
deregulation in the plant health regime, with uncertainty about inclusion in the 

109 

 
 
 
 
 
 
 
Annexes  of  the  PRM  regime.  As  the  costs  of  measures  under  the  plant  health 
regime are higher than for the PRM regime, costs for operators will gradually 
decrease  and  further  staff  resources  of  Member  States  for  the  plant  health 
regime will be liberated. 

Surveillance and contingency planning 

Changes under consideration:  

(c) 

Introduction  of  mandatory  surveillance  by  the  Member  States  for 
outbreaks of listed and new harmful organisms. A general survey obligation 
would apply in relation to all listed regulated pests and all pests that are new to 
the EU, while an enhanced level of surveys would be required for EU priority 
pests. EU co-financing for surveys would be put in place. 
Financial impact: the current costs of surveys for the Member States have been 
estimated by FCEC (2011) at EUR 14 mio. An obligation for surveillance, for 
priority  pests  moreover  at  an  enhanced  level,  will  require  additional  resources 
and  would  be  put  in  place  only  when  simultaneously  introducing  EU  co-
financing.  The  financial  costs  in  that  case  would  rise  to  EUR  16.8-EUR  21.0 
mio (FCEC, 2011).  

In this impact assessment, the assumption is made that this measure will lead to 
an increase of the survey costs from EUR 14 mio (borne by the MS) to EUR 20 
mio, half of which would be borne by the EU (co-financing). 

(d) 

Introduction  of  mandatory  contingency  planning  for  priority  harmful 
organisms. 
Financial impact: negligible; this is an activity that would be carried out by the 
MS services, largely as a part of their normal duties. 

Eradication and containment 

Changes under consideration:  

(e) 

Clarification  of  measures  required  for  eradication  and  containment  of 
outbreaks. The current plant health law requires such measures to be taken but 
does not specify these (apart from some potato diseases in the relevant Control 
Directives).  Member  States  are  required,  in  very  general  terms,  to  eradicate 
regulated  harmful  organisms  or  if  that  is  not  possible,  to  contain  them.  This 
allows  Member  States  complete  freedom  about  the  nature  and  the  scale  of 
interventions. The new law would clarify what actions are required, in terms of 
carrying out a delimiting survey to determine the actual extent of the outbreak, 
establishing  a  demarcated  area  and  a  buffer  zone,  implementation  of  specific 
eradication measures and – in the case of priority pests - provision of an action 
plan  containing  all  those  actions  and  measures.  It  would  allow  to  set  up 
permanent measures to eradicate or contain harmful organisms in analogy with 
the  Control  Directives  on  potato  pests,  without  the  need  for  a  co-decided  act. 
Those Control Directives have proven to be successful thanks to such detailed 
requirements.  The  new  PHR  would  thus  acquire  access  to  the  same  useful 
toolbox. 
Financial impact: none. These measures are already good practice and should 
be applied anyway. The measures will however follow a harmonised logic and 

110 

 
 
 
 
 
(f) 

(g) 

(h) 

the action plan will need to be communicated to the Commission and the MS. 
Proper  implementation  of  already  existing  obligations  may  bring  along  new 
costs, but those costs should not be attributed to the new regime. The costs of 
any harmonised Union measures for specific crops / pests cannot be assessed at 
this stage, as they will depend on the crop and pest concerned. 

Extension of the scope of the EU co-financing "solidarity regime" for plant 
health  to  also  cover  costs  of  measures  addressing  outbreaks  that  are  due  to 
natural  spread  within  the  EU.  Costs  from  such  measures  are  explicitly 
excluded from EU co-financing under the current plant health law.  
Financial impact: according to the FCEC (2011), the current level of costs of 
MS for measures related to natural spread is at least EUR 7.3 mio. These costs 
are already incurred at present but they are not co-financed by the EU.  

In  this  impact  assessment,  the  assumption  is  made  that  this  measure  will  not 
lead to additional expenditures but will change the attribution of the costs, from 
today around EUR 7.3 mio (borne by the MS) to in future EUR 3.65 mio for the 
MS and EUR 3.65 mio for the EU.   

Removal  of  the  degressivity  rule.  The  current  plant  health  law  requires 
degressivity  (mandatory  decrease  over  time)  of  EU  co-financing  of  MS 
expenditures  for  eradication  and  containment.  No  level  of  degressivity  is 
specified.  No  such  rule  exists  in  the  animal  health  regime  and  it  would  be 
dropped for plant health too. 
Financial  impact:  the  relevance  of  the  degressivity  provision  has  in  practice 
been limited. In certain cases, degressivity of EU co-financing levels could be 
counter-productive to achieve the objectives of the measures. For such cases, a 
fall-back  exists  in  Directive  2000/29/EC,  Article  23(6)  to  continue  payments 
despite  the  degressivity  rule,  even  at  levels  above  the  standard  50%  level. 
Reversely,  Art.  23  empowers  the  Commission  to  attribute  lower  priority  and 
budget  to  certain  dossiers,  depending  among  others  on  the  availability  of  EU 
budget  for  plant  health.  These  provisions  will  remain  in  the  new  law. 
Altogether, the impact of dropping the degressivity rule is therefore zero.  

Widening  of  the  scope  for  EU  co-financing  of  MS  expenditures  to 
compensate  operators  for  the  lost  value  of  plant  material  subject  to  official 
destruction  measures.  This  would  apply  to  direct  costs  and  losses  only,  since 
consequential losses are very difficult to estimate beforehand (they are not co-
financed  in  the  animal  health  regime  either)90.  The  eligibility  of  MS 
compensation  payments  to  operators  would  be  restricted  to  measures  against 
EU  priority  pests  (for  the  identification  of  priority  pests,  see  change  (a)).  The 
Union financial contribution would be 50%. By exception, a higher percentage 
may  be  set  where  measures  taken  by  a  Member  State  against  certain  priority 
pests  are  primarily  designed  to  protect  Union  territories  other  than  that  of  the 
Member State concerned. 

Article  23  of  Directive  2000/29/EC  already  allows  such  compensations, 
however  an  Implementing  Regulation  has  not  been  put  in  place  and  EU  co-

90 Consequential losses could be co-financed under the current regime if, in accordance with Article 23 (3) 
of  Directive  2000/29/EC,  an  implementing  Regulation  is  adopted.  This  has  not  happened.  Dropping 
the possibility therefore has zero impact. 

111 

 
 
 
                                                 
financing  for  operator  losses  in  practice  has  not  occurred  (a  grey  area 
nevertheless  exists  where  MS  dossiers  included  costs  related  to  operators  that 
were subject to eradication measures). The new plant health Regulation will not 
require such an Implementing Regulation. Compensations to operators paid by 
MS  will  be  part  of  the  dossiers  submitted  by  MS  for  EU  co-financing  (the 
Union itself will not pay any compensation directly to operators).  

Financial  impacts:  the  FCEC  (2011)  estimates  the  additional  EU  budget 
needed to co-finance operator losses at EUR 5 mio per year for the selected 10 
priority  pests.  In  this  impact  assessment,  the  assumption  is  made  that  total 
expenditures  for  this  measure  might  prove  higher.  The  figure  of  EUR  5  mio 
relates to the studied 10 priority pests only and more pests may be listed in due 
course in the priority Annex, up to a maximum of 20 priority pests. In addition, 
availability of EU co-financing for compensating operators might attract further 
requests from operators to MS competent authorities, and from MS to the EU. 

We  assume  that  the  eligible  expenditures  would  be  around  EUR  20  mio  per 
year for a maximum of 20 priority pests. It should be noted that the FCEC study 
shows that current MS compensation payments to operators for costs and losses 
are  around  EUR  6  mio  per  year,  of  which  we  assume  EUR  3  mio  is 
compensation for value loss. The assumed MS expenditures would therefore be 
EUR 10 mio (EUR 7 mio higher than today) and the EU expenditures EUR 10 
mio as well (new). The compensation to operators would go up from the current 
EUR 3 mio to EUR 20 mio. 

By way of comparison, for France alone, the financial impact for operators due 
to  mandatory  destruction,  treatment  or  detention  measures  from  2005  to  2007 
was in the range of EUR 5.3 to EUR 11.4 mio per year. Since France produces 
20% of the EU crop value, the eligible figures could amount to EUR 26.5 mio - 
EUR  57.0  mio  (average:  EUR  41.8  mio)  for  the  Union  as  a  whole,  if  the  EU 
would co-finance operator losses from eradication measures for all listed pests 
(not only priority organisms). In that case, the necessary additional EU budget 
would be EUR 20.9 mio. 

The magnitude of the EU expenditures will be restricted by limiting the number 
of  priority  organisms.  Where  the  annual  ceiling  set  by  the  Multi-annual 
Financial  Framework  (MFF)  for  plant  health  expenditures  would  nevertheless 
be surpassed because of large-scale outbreaks of priority pests, the MFF crisis 
reserve for food safety expenditures will be used. A provision allowing to use 
the crisis reserve mechanism will be included in the legislation. 

Losses  of  operators  resulting  from  eradication  measures  for  pests  other  than 
priority  pests  will  not  be  eligible  for  EU  co-financing.  This  does  not  preclude 
MS compensation for those costs (note that MS will not be obliged anyhow to 
compensate operator losses). For these cases, operators may set up mutual funds 
or rely on dedicated insurances, for which the proposed Common Agricultural 
Policy legislation allows MS financial support and offers Union support. 

Import 

Changes under consideration:  

112 

 
 
 
(i) 

Temporary  restrictions  of  new  high-risk  trade  pending  risk  analysis:  in 
addition to the current Annexes of Directive 2000/29/EC, a new Annex would 
be  created  to  cover  new  trade  in  plants  for  planting  for  which  no  specific 
requirements exist in the plant health regime but that are provisionally seen as a 
high  risk,  based  on  preliminary  technical  and  scientific  evidence.  Such  plants 
for planting would be subject to precautionary measures, allowing time for the 
competent  authorities  and  Commission  to  fill  knowledge  gaps  and  develop  a 
full-fledged PRA (in line with the SPS Agreement). After expiry of a maximum 
period of 4 years, the listed articles would be transferred to regular Annexes or, 
in absence by that time of a PRA, deleted. 
The new Annex would consist of three Parts (A: materials requiring intensified 
inspection  and  mandatory  laboratory  testing;  B:  materials  requiring  post-entry 
quarantine; C: materials of which the entry is refused pending risk analysis). To 
minimise  impacts  on  trade,  high-risk  materials  would  be  subject  to  the  least 
costly  measures,  on  condition  that  the  effectiveness  of  the  measures  is  not 
jeopardised.  
An  exemption  would  be  created  for  scientific  purposes,  trials  and  varietal 
selection, provided that special phytosanitary safeguards are applied.  

Financial  impact:  FCEC  (2011)  estimates  the  costs  of  mandatory  laboratory 
testing for a single ornamental species in the range of EUR 0.3 mio to EUR 1.3 
mio per year, and for all ornamentals EUR 6.8 mio to EUR 23.4 mio. Assuming 
that  the  measures  would  affect  1%  of  the  total  trade,  the  annual  costs  for 
operators would be between EUR 68,000 and EUR 234,000 (on average: EUR 
0.15 mio), at a full cost-recovery basis.  

The  FCEC  furthermore  estimates  the  costs  of  post-entry  quarantine  at  EUR 
1,000 / m2 or up to EUR 1 mio in total for a standard facility (up to 1,000 m2) to 
set  up  such  facilities  and  EUR  2,500  per  year  for  administrative  costs91. 
Assuming that a quarantine facility would be set up in 10 MS and that the life 
span  of  such  a  facility  would  be  20  years,  the  annual  expenditures  would 
amount to EUR 0.5 mio. Assuming maintenance and operational costs of EUR 
0.25 mio per facility per year, the total annual costs at EU level would amount 
to EUR 0.75 mio, to be paid by the operators through fees.  

The  value  of  nursery  stock  imports  into  the  EU  is  EUR  1.5  billion  per  year; 
assuming that new trade amounts to 1% of the total trade, a temporary blocking 
of new trade would impact on a trade value of EUR 15 mio per year. Assuming 
a profit margin of 10% to 25%, the lost value would be in the order of EUR 1.5 
mio  to  EUR  3.7  mio  per  year  (on  average,  EUR  2.6  mio).  As  long  as  the 
measures are strictly confined to new trade, the impact of blocking that trade is 
however formally zero. 

Apart  from  the  costs  for  operators,  additional  burden  would  follow  from  this 
measure for the Commission and for the competent authorities of the Member 
States. For each listed plant or plant product, a PRA would need to be carried 
out  and  that  PRA  would  need  to  be  assessed  by  EFSA.  Assuming  that  the 
development of a PRA requires 0.5 man-year on MS side and 0.5 man-year on 

91 The FCEC argues that in some cases the costs for the operators could however exceed the value of the 

commodities. 

113 

 
 
 
                                                 
(j) 

(k) 

Commission side (EFSA), the costs per PRA would range from EUR 30,000 to 
EUR  100,000  depending  on  the  salary  level  in  the  MS.  With  one  request  per 
year per MS for listing new trade, the annual costs would amount to EUR 0.8 
mio to EUR 2.7 mio.    

In  this  study,  we  assume  that  operator  costs  from  mandatory  testing  of  plant 
material, post-entry quarantine and temporary import restrictions would be EUR 
3.5 mio per year. We assume that costs for MS and the Union would be EUR 1 
mio each per year for PRA.  

Dropping  the  existing  exemption  to  import  requirements  for  passenger 
transport:  the  current  legislation  exempts  plants  and  plant  products  imported 
into the EU by persons intending to use the material for private non-commercial 
purposes.  This  exemption  would  be  dropped,  so  as  to  stop  currently  ongoing 
high-risk imports with passengers and at the same time generate awareness of 
the  public  at  large  of  the  need  to  keep  out  regulated  harmful  organisms  from 
third  countries.  This  would  be  supported  by  random  checks  of  passengers  at 
international airports, carried out incidentally at a low frequency. Additionally, 
information posters would be placed at airports. 
Financial impact: assuming that a single action requires four inspectors for 3 
days (1 day of action, 2 organisational days), and that each MS would carry out 
10  actions  per  year,  the  workload  would  be  0.6  man-year  per  MS  per  year, 
amounting for the entire EU to EUR 18,000 to EUR 60,000 per MS per year. 
The estimated costs for the EU-27 would be EUR 1 mio per year, including the 
costs of posters which are here estimated at 5% of those costs.    

Inclusion  of  plant  and  plant  product  imports  in  the  TRACES  application 
used  today  for  imports  of  animals,  animal  products,  feed  and  food.  An 
obligation  would  be  created  for  operators  and  competent  authorities  to  use 
TRACES  to  submit  prior  notice  of  imports  and  to  keep  track  of  the  status  of 
checks  that  are  being  carried  out.  The  use  of  national  IT  systems  for  these 
purposes would be abandoned.  
Financial  impact:  the  initial  costs  to  expand  the  TRACES  software  to  cover 
plant  health  are  estimated  by  Commission  services  at  EUR  100,000,  together 
with  training  costs  for  national  inspectors  and/or  users  under  the  BTSF 
programme during two years (3 courses for 30 persons per year), estimated at in 
total EUR 400,000. These costs will be fully borne by the Commission, which 
thus  would  have  a  total  one-off  cost  of  EUR  0.5  mio.  Further  maintenance  of 
TRACES  would  be  taken  care  of  by  the  existing  TRACES  team  in  DG 
SANCO. 

The  operator  costs  for  filling  TRACES  with  daily  data  should  be  negligible. 
These costs are currently made as well, but through other systems. In so far as 
MS still allow operators to fax or mail information, the archiving costs for MS 
are  substantial.  Such  information  carriers  have  to  be  individually  scanned  and 
saved,  which  consumes  substantive  memory  space  and  is  known  to  be  highly 
expensive. Those costs can be substantially reduced by using TRACES, which 
stores the factual data and not the template.  Costs will also decrease for MS in 
which the inspectors feed the fax and e-mail data of the operators by hand into 
IT applications. TRACES should thus be anyhow cheaper for the MS. 

114 

 
 
 
MS  however  have  divergent  views  on  the  need  to  include  plant  health  in 
TRACES  and  the  associated  costs.  Some  insist  to  maintain  their  existing 
national systems and believe that the costs of linking these to TRACES would 
be  very  high.  The  issue  will  be  explored  and  addressed  in  the  IA  for  the  new 
Regulation 882/2004 (no provision on TRACES will be incorporated in the new 
plant health Regulation itself). 

Plant passport system 

Changes under consideration:  

(l) 

(m) 

(n) 

(o) 

Attribution  of  the  responsibility  for  the  availability  of  traceability 
information concerning intra-EU movements to the operators: the operators 
would be explicitly responsible for keeping record of the necessary traceability 
information. The current legislation is ambiguous whether such information has 
to be included in the plant passport or can be left to the operators to keep record 
in their own files.  
Financial  impact:  none,  as  operators  already  today  already  have  that 
information in their records and store it for the required minimum period of one 
year. 

Extension  of  the  scope  of  the  plant  passport  to  all  business-to-business 
movements  of  all  plants:  the  scope  of  the  current  plant  passport  provisions 
would  be  expanded  to  cover  all  plants  for  planting  (not  only  specific  ones), 
except seeds, in business-to-business. The same requirement applies already to 
imports  from  third  countries  and,  for  compliance  with  the  SPS  Agreement, 
needs to be mirrored for movements within the Union.  
Financial  impact:  none,  as  argued  by  FCEC  (2011).  The  economic  study  by 
FCEC  (2011)  identified  that  all  transactions  in  the  trade  chain  are  at  present 
already accompanied by documents in various forms. The information required 
for  issuing  a  plant  passport  to  all  plants  for  planting  (except  seeds)  is  thus 
already present in the ICT systems of the operators (e.g. for stock keeping and 
invoicing),  meaning  that  the  cost  of  possible  modifications  to  the  format  of 
labels,  tags  and  the  like  (including  a  plant  passport label  printed  on  them)  are 
one-off  and  can  be  split  over  many  users  of  the  specific  software  packages  in 
use. This is also evidenced by the fact that today many operators already issue 
plant  passports  without  the  obligation,  this  being  easier  (cheaper)  than  issuing 
them for some but not for other species. 

Simplification  and  harmonisation  of  the  plant  passport  format:  the  plant 
passport format would be simplified and harmonised to a mark consisting of a 
logo accompanied by the botanical name of the plant material, the country code, 
the  registration  number  of  the  operator,  and  the  lot  number  (or  a  traceability 
identifier such as a barcode or a chip). 
Financial impact: none, as argued by FCEC (2011). The simplification would 
rather reduce operator costs as less data need to be filled for the plant passport. 

Alignments  with  the  certification  label  issued  under  the  PRM  regime: 
where  possible  definitions  and  provisions  of  the  EU  plant  health  and  PRM 
regimes are aligned to remove obstacles for Member States to combine health 
inspections  under  the  two  regimes  and  reduce  burden.  Where  consignments 

115 

 
 
 
require a plant passport and a certification label, the competent authorities shall 
issue a single document. A combined operator register is foreseen. 
Financial  impact:  cost  reductions  for  operators.  Further  combined  health 
inspections would allow for a reduction of operator costs up to EUR 0.7 mio per 
year (FCEC, 2011). Obliging MS to issue one document in cases both the plant 
health  and  the  PRM  legislation  require  the  issuance  of  a  certification  will 
eliminate double costs for operators. The same is true for the obligation to MS 
to set up a combined plant health and PRM register of operators. 

(p) 

Introduction  of  an  obligation  to  MS  to  levy  cost-recovery-based  fees  for 
registration. Currently MS are free to levy or not fees for plant passport related 
activities such as official inspections at the place of production.  
Financial impact: based on the administrative cost spreadsheets provided with 
the evaluation (FCEC, 2010)92, the impact can be calculated as follows. 

Current situation 

CA costs 

Operator costs 

Total costs 

Before fee charging 

€1.36 mio 

€1.49 mio 

€2.85 mio 

After fee charging 

€1.24 mio 

€1.61 mio 

€2.85 mio 

The  current  costs  of  EU  operators  are  administrative  costs  (EUR  1.49  mio  = 
52% of total costs) and fees (EUR 0.12 mio = 4% of total costs), out of a total 
of  EUR  2.85  mio.  Recoverable  competent  authority  (CA)  costs  for  which  no 
fees are levied amount to EUR 1.24 mio (being 44% of total costs, and 91% of 
the CA costs for registering operators). Registration fees vary between MS from 
EUR 7 to EUR 681 (weighted average: EUR 47). Fees are levied in 11 MS. 

Full  cost  recovery93  will  increase  operator  costs  from  EUR  1.61  mio  to  EUR 
2.85  mio  (+  77%).  The  increase  of  EUR  1.24  mio  will  be  borne  by  24224 
operators  in  MS without full cost recovery (= number of annual renewals and 
new registrations, out of 133144 registered operators), implying an average cost 
increase for those operators of EUR 51 per year. 

(q) 

Introduction  of  an  obligation  to  MS  to  levy  cost-recovery-based  fees  for 
plant passport inspections 
Financial impact: based on the administrative cost spreadsheets provided with 
the evaluation (FCEC, 2010), the impact can be calculated as follows. 

CA costs 

Operator costs 

Total costs 

Before fee charging 

€33.32 mio 

€  0      mio 

€33.32 mio 

After fee charging 

€14.55 mio 

€18.77 mio 

€33.32 mio 

92 Data relate to the EU-27 except BG, GR and LU which had not replied to the cost questionnaires. 
93 Once plant health is included in the scope of Regulation 882/2004, the modalities to set the fee level will 
be governed by that Regulation. This could lead to some limited (probably <20%) deviations from the 
figures used in our study, which are based on full cost recovery. 

116 

 
 
 
 
                                                 
The current costs of EU operators are fees (EUR 18.77 mio = 56% of total costs 
related to plant passport inspections). Recoverable CA costs for which no fees 
are  levied  amount  to  EUR  14.55  mio  (being  44%  of  total  CA  costs  related  to 
plant  passport  inspections).  Fees  are  levied  in  17  MS,  are  not  levied  in  6  MS 
and no data are available for 4 MS. In those MS that levy fees, the cost recovery 
varies from 5% to 100% (reached in 7 MS). The weighted average fee at 100% 
cost recovery is EUR 128. 

Full  cost  recovery  will  increase  operator  costs  from  EUR  18.77  mio  to  EUR 
33.32  mio  (+  78%).  Per  MS,  the  additional  burden  for  operators  would  range 
from  EUR  0  to  EUR  2.9  mio  per  year.  Per  operator,  the  additional  burden 
would  range  from  EUR  0  to  EUR  1278  per  year.  The  weighted  average 
additional  cost  per  operator  in  MS  with  currently  incomplete  cost  recovery 
would be EUR 349 per year. 

The combined impact of mandatory cost-recovery based fees for registration of 
operators  and  for  inspections  at  the  place  of  production  for  plant  passport 
issuance is as follows. 

CA costs 

Operator costs 

Total costs 

Before fee charging 

€96 mio 

€51 mio 

€147 mio 

After fee charging 

€59 mio 

€88 mio 

€147 mio 

100% cost recovery 
for registration and 

€43 mio 

€104 mio 

€147 mio 

The  current  costs  incurred  by  competent  authorities  for  plant  passport 
inspections that are recovered from operators through fees amount to 85% of 
the recoverable costs. The non-levied recoverable costs are 11% of total costs, 
17% of all CA costs and amount to 15% of the total recoverable costs. 

Full cost recovery will increase operator costs from EUR 88 mio to EUR 104 
mio  (+  18%).  Per  MS,  the  additional  burden  for  operators  would  range  from 
EUR  0  to  EUR  2.9  mio  per  year.  Per  operator,  the  additional  burden  would 
range from EUR 0 to EUR 1329 per year, with a weighted average increase in 
MS with currently incomplete cost recovery of EUR 400 per year. 

Protected zones system 

Changes under consideration:  

(r) 

Introduction  of  rules  for  demarcation  and  temporary  or  permanent 
exclusion of outbreak areas: upon an outbreak in a protected zone, MS would 
have  to  apply  the  principles  of  demarcated  areas  and  actively  eradicate  the 
outbreaks. The area under eradication would not be excluded from the protected 
zone, unless no demarcated area is timely established, no measures are taken or 
no eradication is achieved within two years.  
Financial impact:  negligible  for  MS  that  fulfil  their  current  legal  obligations. 
Costs  would  be  incurred  by  MS  that  today  do  not  fulfil  those  obligations, 

117 

 
 
 
 
however,  from  a  formal  impact  assessment  perspective,  the  additional  impact 
compared to the current legislation is zero. 

Laboratories 

Changes under consideration:  

(s) 

Introduction of an obligation to plant health laboratories to be accredited, 
at  least  for  a  single  diagnostic  protocol  (or  a  single  protocol  per  taxonomic 
discipline),  with  a  transitional  period  of  5  years.  The  costs  charged  by  the 
accreditation  body  for  the  initial  accreditation  would  be  borne  by  the  EU,  the 
annual  audit  costs  would  be  for  the  laboratories  themselves  and  should  be 
included in the  cost-recovery  based fees to  the extent that  a laboratory carries 
out official diagnoses. 
Financial impact: accreditation requires laboratories to set up quality assurance 
systems, including the appointment of a quality assurance officer (this may be 
an  additional  task  for  a  staff  member  who  is  not  actively  involved  in  the 
diagnoses).  Quality  assurance  should  be  good  practice  for  any  modern 
laboratory and the associated costs should therefore not be taken into account as 
additional. The transitional period of 5 years should normally be sufficient.  

The additional costs relate to the formal accreditation itself, which consists of 
an initial accreditation, valid for 4-5 years (dependent on the MS in case), and 
the costs of annual audits. Based on a survey of MS laboratories94, the costs of 
the  initial  accreditation  are  assumed  to  range,  depending  on  the  size  of  the 
laboratory  and  the  price  level  in  the  MS,  from  EUR  2,000  to  EUR  20,000 
(rarely EUR 30,000). Since the accreditation would be valid for 4-5 years, the 
annual  costs  would  be  EUR  450  to  EUR  4,500  per  year  per  laboratory.  The 
annual  audit  costs  would  amount  to  EUR  1,300  to  EUR  15,000  (rarely  EUR 
20,000).  

In some MS, the official plant health laboratories have already been accredited 
or largely so. In others, this is not yet the case. The number of laboratories per 
MS presumedly ranges between 1 (for centralised MS)95 and 26 (for MS with 
regional laboratories). In this study, it is assumed that 20 MS still need to apply 
for accreditation, that this would apply to on average 6 laboratories96, and that 
the initial accreditation costs on average would be EUR 2,500 (yearly basis) and 
the annual audit costs on average EUR 8,000. 

Based on these assumptions, the initial costs for the EU would be EUR 0.3 mio. 
The  average  annual  audit  costs  for  the  MS  would  be  27  x  6  x  EUR  8,000  = 
EUR 1.3 mio.  

Assuming that 50% of laboratory activities relate to official diagnoses and the 
remaining  activities  are  commercial,  the  impact  on  operators  from  the 
obligation  would  formally  be  EUR  0.65  mio.  Since  the  need  for  accreditation 
would stem only from the EU plant health legislation, it is more appropriate to 
attribute the full EUR 1.3 mio to the impact of the legislative changes. 

94 Replies were received from AT, BE, CZ, DE, DK, ES, FR, IE, LV, NL, MT, PL, SE, SI, SK.  
95 One MS does not have any such laboratory at all but has contracted out all analyses to other MS. 
96 This is the average number of relevant laboratories in the 15 MS that replied to the consultation. 

118 

 
 
 
                                                 
(t) 

The issue will be further addressed in the IA for the new Regulation 882/2004 
(no provision on laboratory accreditation will be incorporated in the new plant 
health Regulation itself). 

Creation of EU reference laboratories for plant health diagnosis: inclusion 
of  plant  health  in  the  scope  of  Regulation  882/2004  would  legally  create  the 
possibility to set up EU reference laboratories in the plant health area, building 
on  and  reinforcing  existing  laboratories  of  Member  States,  and  support  these 
financially from the EU budget.  
Financial impact: it is estimated that in due course EU reference laboratories 
would be set up for circa 10-12 priority pests. At present, the EU supports 42 
EU reference laboratories in the other areas covered by Regulation 882/2004 for 
a  total  annual  sum  of  EUR  14.2  mio  (figure  for  2010/2011);  the  average  EU 
support  thus  amounts  to  EUR  338,000.  This  implies  that  the  annual  costs  for 
plant  health  reference  laboratories  would  be  EUR  3.4  mio  to  EUR  4.1  mio 
(based on this our assumption is EUR 4 mio). 

The issue will be further addressed in the IA for the new Regulation 882/2004 
(no  provision  on  reference  laboratories  will  be  incorporated  in  the  new  plant 
health Regulation itself). 

Invasive alien plant species 

Changes under consideration:  

(u) 

Expansion  of  the  scope  of  the  plant  health  regime  to  also  cover  invasive 
alien  plant  species:  the  regime  would  explicitly  include  IAS  plants  for  all 
provisions,  including  survey  obligations,  import  and  intra-EU  movement 
measures, eradication and containment measures and the EU co-financing rules 
and levels of Union financial contribution. 
Financial impact: according to the FCEC (2011), listing of IAS plants would 
have  relatively  moderate  financial  impacts  as  long  as  these  plants  are  and 
continue to be absent from the EU. Once outbreaks occur, survey, eradication 
and  control  costs  would  be  significant  (order  of  magnitude  per  IAS  plant 
species: EUR 0.7 mio for surveys; EUR 3 mio for eradication and control). For 
IAS plants that are widely distributed in the EU, costs could be very significant 
(order of magnitude per IAS plant species: EUR 1.5-EUR 3.0 mio for surveys; 
EUR 10-EUR 30 mio per year for eradication and containment). 

Assuming that the EU plant health regime would list 20 IAS plant species, of 
which eventually 5 species have restricted outbreaks and 2 species large-scale 
outbreaks, the total costs would amount to EUR 63 mio per year (5 x EUR 3.7 
mio + 2 x EUR 22.25 mio), of which EUR 31.5 mio would be borne by the MS 
and EUR 31.5 by the EU. If IAS plant species with large-scale outbreaks would 
be rapidly deregulated, the total costs would be EUR 18.5 mio.  

In  this  study  we  assume  reality  will  be  halfway,  i.e.  EUR  40.8  mio,  of  which 
EUR 20.4 mio for the MS and EUR 20.4 mio for the EU. 

119 

 
 
 
Repeal of obsolete Directives  

(v) 

Repeal  of  Council  Directives  74/647EEC  and  2006/91/EC:  these  legal  acts 
would be repealed as the relevant harmful organisms (carnation leaf rollers and 
San  Jose  scale)  are  widespread  across  the  EU  and  are  no  longer  listed  in 
Directive  2000/29/EC  (i.e.,  no  import  restrictions  apply).  They  are  however 
listed  under  the  Marketing  Directives  for  PRM  (Commission  Directives 
93/48/EEC and 93/49/EEC), as quality pests from which commodities in trade 
should be "substantially free". The objectives of the two Council Directives to 
contain the relevant pests and inhibit their spread are obsolete.  
Financial  impact:  in  technical  sense,  the  repeal  will  not  have  any  impact 
because  the  organisms  are  no  longer  controlled  by  plant  health  inspectors, 
despite the PHR legislation (they are only controlled at present in the context of 
the  PRM  legislation).  Formally,  the  PHR  costs  for  operators  and  MS  would 
decrease as a consequence of the repeal, however the net impact is zero since 
the  legal  acts  are  no  longer  implemented  under  that  regime  (while  control 
continues under the PRM regime). 

120 

 
 
 
Annex X: Summary of the opinions of stakeholders and Member States 

This  Annex  presents  an  overview  of  the  positions  taken  by  the  stakeholders  and  the 
competent  authorities  of  the  Member  States  in  reply  to  the  consultations,  either  at 
conferences and consultation meetings or in writing. The Commission has attempted to 
correctly  summarise  and  refer  to  those  positions,  which  however  had  to  be  re-arranged 
and interpreted for the purposes of this Annex. 

I. Opinions concerning proposed measures 

For a description of these measures, see Annex IX. 

Prioritisation 

Changes under consideration:  

(a) 

Measure: introduction of a new Annex for EU priority pests 
Stakeholders:  supported  by  LTO  NEDERLAND,  NATIONAL  TRUST, 
PLANTUM NL. 

(b) 

Member  States:  general  support,  except  for  one MS  that  would  prefer  to  use 
the  emergency  measure  instrument  for  addressing  priority  pests.  Another  MS 
sees  a  need  for  different  prioritisation  for  surveys  compared  to  eradication  / 
containment. 

Measure: transformation of current Annex II into an Annex listing harmful 
organisms for which thresholds apply instead of territorial objectives 
Stakeholders: supported by AIPH, ESA, EUROPATAT, NAO, UFS, VGB (as 
long  as  the  conditions  concerning  the  role  and  responsibilities  of  operators 
would  not  change  for  the  organisms  so  far  listed  under  the  Marketing 
Directives).  COPA-COGECA,  LTO  NEDERLAND  and  PLANTUM  NL 
preferred listing of these organisms under the PRM regime (it should be noted 
that the proposed measure in practice results in the outcome advocated by these 
three  stakeholders,  but  using  a  different  legal  technical  solution,  this  was 
apparently not sufficiently clear in the consultation document). 

Member States: support from all but one MS. 

Surveillance and contingency planning 

Changes under consideration:  

(c) 

Measure: introduction of mandatory surveillance by the Member States for 
outbreaks of listed and new harmful organisms, supported by EU co-financing 
Stakeholders: supported by AIPH, COPA-COGECA, ENA, ESA, HTA, LTO 
NEDERLAND, NATIONAL TRUST, UFS.  

Member States: general support. More stakeholder involvement was requested 
by several MS. 

(d) 

Measure: introduction of mandatory contingency planning for priority harmful 
organisms 

121 

 
 
 
 
Stakeholders: supported by AIPH, COPA-COGECA. 

Member States: general support. 

Eradication and containment 

Changes under consideration:  

(e) 

(f) 

(g) 

(h) 

Measure: clarification of measures required for eradication and containment of 
outbreaks  
Stakeholders:  supported  by  COPA-COGECA,  NATIONAL  TRUST,  UFS, 
VGB.  However,  LTO  NEDERLAND  and  VGB  requested  more  flexibility  to 
adapt to the needs of the local situation. 

Member  States:  variable  support,  ranging  from  support  (4  MS)  to  strong 
reservations (1 MS), and questions how to technically solve specific cases such 
as  outbreaks  in  greenhouses.  The  MS  with  reservations  requested  a  more 
flexible approach to allow for measures tailored to the local situation. 

Measure: extension of the scope of the EU co-financing "solidarity regime" to 
also cover costs of measures addressing outbreaks that are due to natural spread  
Stakeholders:  supported  by  AIPH,  EFNA,  ENA,  ESA,  HTA,  NATIONAL 
TRUST, UFS, restricted to cases where measures would make sense. However, 
COPA-COGECA requested a careful analysis of the potential financial impacts, 
and VGB preferred the status quo. 

Member States: general support. 

Measure: removal of the degressivity rule 
Stakeholders: no consultation was organised as this is a technical issue without 
impact  in  practice  (see  explanation  in  Annex  X).  Nevertheless  noted  and 
supported by UFS. 

Member  States:  no  consultation  was  organised  as  this  is  a  technical  issue 
without  impact  in  practice  (see  explanation  in  Annex  X).  One  MS  however 
itself flagged up that the degressivity rule should be removed. 

Measure: widening of the scope for EU co-financing of MS expenditures to 
compensate operators for the lost value of plant material subject to official 
destruction measures 
Stakeholders: 
supported  by  AIPH,  COPA-COGECA,  ENA,  ESA, 
EUROPATAT,  HTA,  LTO  NEDERLAND,  NAO,  NATIONAL  TRUST97, 
UFS98,  USSE,  VGB.  Their  view  was  that  growers  do  not  always  have  the 
possibilities  to  take  adequate  measures  to  prevent  the  introduction  of  harmful 
organisms  and  that  measures  have  a  mixed  public/private  objective,  implying 
that  MS  and  EU  tax  payer  co-financing  is  justified.  The  share  of  financial 
contribution between grower and tax payer should depend on the extent of the 
public  interest.  A  prudent  approach  was  needed  because  of  the  potentially 

97  Provided  that  payments  are  conditional  to  compliance  by  operators  with  legislation  and  that  perverse 

incentive are not possible, and targeting landowners rather than high-value industries. 

98 Provided that mutual funds cannot be set up and on conditions of good hygiene and prevention practices 

by operators. 

122 

 
 
 
                                                 
significant  impact  at  MS  and  EU  level.  Distortion  of  competition  because  of 
different  national  arrangements  should  be  avoided.  Cost  sharing  should  also 
mean responsibility sharing with private sector. An active role of stakeholders 
in  horizon  scanning  and  preparedness  for  outbreaks  was  proposed.  Prevention 
measures  by  operators  should  be  conditional  to  payments  (incentives). 
Compensation should be open to all sectors, including landowners in the case of 
forests and private green. PAN EUROPE recalled that no preventive measures 
are  in  place  in  the  CAP  at  present.  Without  a  link  to  obligations  concerning 
preventive  economic  measures,  it  was  not  in  favour  of  giving  any  money. 
Greening of the CAP should be conditional to payments. 

Member  States:  diverging  views,  ranging  from  clear  support  to  clear 
opposition.  According  to  the  MS  that  were  in  favour,  compensations  to 
operators  are  important,  restricted  to  priority  organisms  and  conditional  to 
compliance with the legislation and good practices. Priority should be given to 
compensations  relating  to  outbreaks  of  harmful  organism  affecting  public 
goods.  Several  MS  referred  to  positive  experiences  with  national  public 
compensation  funds.  Several  MS  believed  that  compensations  for  suppression 
measures and/or indirect (consequential) losses should also be eligible. MS that 
were  against  believed  that  compensation  could  create  a  perverse  incentive, 
would  be  too  costly,  and/or  should  be  left  to  the  sector  to  organise  through 
mutual funds or insurances (in any case it would require deeper involvement of 
and coordination with the industry). It was also questioned whether MS would 
be able and willing to pay their national part of the compensations, with risks of 
disrupting the level playing field for operators.  

Import 

Changes under consideration:  

(i) 

Measure: temporary restrictions of new high-risk trade pending risk analysis 
Stakeholders: in principle supported by AIPH and LTO NEDERLAND (only 
for  new  trade  and  in  exceptional  cases),  COPA-COGECA,  NATIONAL 
TRUST,  PAN  EUROPE,  PLANTUM  NL  and  UFS  (noting  however  that  an 
import  license  system  would  be  harmful  to  the  EU  agricultural  economic 
activity  as  a  whole).  Concerns  were  expressed  by  AIPH,  COPA-COGECA, 
ENA, ESA, NAO, UNION FLEURS, ZVG about the introduction of post-entry 
quarantine  because  of  the  impacts  on  quality  of  the  quarantined  material, 
impacts  on  trade,  risk  of  cross-contamination  during  quarantine  and  expected 
high costs to operators; in addition, counter-reactions from third countries might 
follow. PLANTUM NL advocated post-entry inspections rather than post-entry 
quarantine.  It  stressed  that  case-by-case  authorisations  (import  licenses)  will 
have a huge impact on the trade of plants for planting and producers in the EU, 
and the process of scientific studies concerning high-risk commodities could be 
too slow and complex to meet the needs of trade. Several stakeholders stressed 
the  need  to  better  support  developing  countries  in  setting  up  proper 
phytosanitary systems.  

123 

 
 
 
Member  States:  general  support  for  introducing restrictions  on  new  high-risk 
trade99.  

(j) 

Measure: dropping the existing exemption to import requirements for 
passenger transport 
Stakeholders:  supported  by  NATIONAL  TRUST.  No  other  comments 
received. 

Member States: general support, to the exception of ca. 3 MS that question the 
feasibility. 

(k) 

Measure: inclusion of plant health imports in the TRACES application  
Stakeholders: not included in the consultation. 

Member  States:  potential  benefits  seen  by  the  MS,  the  general  support 
however  being  conditional  to  careful  consideration  and  elaboration  of  plant 
health  specificities.  Some  believe  that  the  costs  could  be  very  high  and 
disproportionate. 

Plant passport system 

Changes under consideration:  

(l) 

(m) 

(n) 

Measure: attribution of the responsibility for the availability of traceability 
information concerning intra-EU movements to the operators  
Stakeholders: supported by AIPH, COPA-COGECA, LTO NEDERLAND. 

Member States: general support. 

Measure: extension of the scope of the plant passport to all business-to-
business movements of all plants  
Stakeholders:  extension  to  all  plants  (instead  of  the  currently  listed  ones) 
supported by UNPT but not by AIPH, COPA-COGECA, UFS. 

Member  States:  support  by  eight  and  opposition  by  three  MS  to  expand  the 
scope to all plants (however mixed views on excluding or not pot plants). With 
three  exceptions  also  support  to  restrict  the  scope  to  business-to-business 
movements, up to professional final consumers.  

Measure: simplification and harmonisation of the plant passport format 
Stakeholders:  supported  by  AIPH,  COPA-COGECA,  ENA,  ESA,  NAO, 
NATIONAL  TRUST,  PLANTUM  NL,  UNION  FLEURS,  UFS.  However 
EUROPATAT  and  NAO  wished  to  additionally  retain  national  mark  with  a 
view to exports to third countries. 

99 The MS would even prefer stricter ones than here proposed, permanently blocking all plants for 
planting  from  third  countries,  unless  these  are  today  already  allowed  in  via  the  requirements  in 
Annex  IV  of  Council  Directive  2000/29/EC,  pending  risk  analysis  for  each  commodity  /  origin. 
Derogations would be possible on a case-by-case basis after completion of the relevant PRA, or 
for scientific purposes and varietal selections. 

124 

 
 
 
                                                 
 
(o) 

(p) 

(q) 

Member States: general support. 

Measure: alignments with the certification label issued under the PRM regime 
Stakeholders: 
NEDERLAND, NATIONAL TRUST, UFS. 

supported  by  AIPH,  COPA-COGECA,  ENA,  LTO 

Member States: general support. 

Measure: introduction of an obligation to MS to levy cost-recovery-based fees 
for registration  
Stakeholders: discussed as part of measure (q). 

Member States: discussed as part of measure (q). 

Measure: introduction of an obligation to MS to levy cost-recovery-based fees 
for plant passport inspections 
Stakeholders:  supported  by  AIPH,  COPA-COGECA,  ESA,  NATIONAL 
TRUST, UFS, VGB. 

Member  States:  general  support  (14  MS),  although  two  MS  have  concerns 
about the way harmonisation should be achieved and whether this should not be 
left to the individual MS. 

Protected zones system 

Changes under consideration:  

(r) 

Measure: introduction of rules for demarcation and temporary or permanent 
exclusion of outbreak areas  
Stakeholders:  supported  by  AIPH,  COPA-COGECA,  ENA,  ESA,  LTO 
NEDERLAND,  NATIONAL  TRUST,  PLANTUM  NL,  UFS,  VGB,  ZVG  and 
to some extent EUROPATAT (no formal transition to the Pest Free Area as this 
would  endanger  trade  with  third  countries  in  case  of  an  outbreak;  a  concern 
shared by NAO). 

Member States: general support, although five MS question the justification of 
the  foreseen  2-year  grace  period  (they  consider  that  biological  parameters 
should have priority) and one MS does not share the perceived need to set up 
demarcated areas in case of outbreaks. 

Laboratories 

Changes under consideration:  

(s) 

Measure: introduction of an obligation to plant health laboratories to be 
accredited 
Stakeholders: not included in the consultations. 

Member States: all but one MS support to move towards accreditation but with 
a  long  transitional  period  in  view  of  the  costs  and  on  condition  that  the 
specialities  of  plant  health  diagnostics  are  acknowledged  and  the  scope  is 
restricted to a limited number of diagnostic protocols / methods. 

125 

 
 
 
(t) 

Measure: creation of EU reference laboratories for plant health diagnosis  
Stakeholders: not included in the consultations. 

Member States: support by all MS. 

Invasive alien plant species 

Changes under consideration:  

(u) 

Measure: expansion of the scope of the plant health regime to also cover 
invasive alien plant species 
Stakeholders: several stakeholders have expressed fears that inclusion of IAS 
plants will take place at the expense of plant health proper. Seven agricultural 
stakeholders  (EUROPATAT,  EFNA,  ENA,  HTA,  PLANTUM  NL,  UFS, 
UNION  FLEURS)  and  two  NGOs  (NATIONAL  TRUST  and  the  JOINT 
NATURE CONSERVATION COMMITTEE100 of the UK) for this reason are 
not  in  favour  of  including  IAS  plants  (some  stakeholders  because  they  are 
anyhow  against  any  increased  ambitions  requiring  more  financial  resources). 
Four others (the umbrella farmers' organisation COPA-COGECA, AIPH, LTO 
NEDERLAND, VGB-NL) would accept or even favour coverage of IAS plants 
on  the  condition  that  the  necessary  EU  co-financing  budget  comes  from  a 
dedicated  environmental  budget  line  (not  the  CAP)  and/or  on  condition  that 
only agricultural weeds will be covered. 

Member States: the views of Member States diverge considerably, five being 
in favour of including IAS plants and assuming costs would be limited and five 
being  against  because  of  lack  of  resources  and  priority  and/or  because  a 
separate environmental legal framework is being preffered. The Member States 
that are in favour of including IAS plants argue that the costs of including IAS 
plants would pertain mainly to import control, which costs should be relatively 
low.  Other  Member  States  have  requested  careful  analysis  of  the  potential 
impacts prior to any decision. 

Repeal of obsolete Directives  

(v) 

Measure: repeal of Council Directives 74/647EEC and 2006/91/EC 
Stakeholders: not consulted as this is a purely technical issue. 

Member  States:  all  but  one  MS  support  repealing  both  Directives  (the 
exception being due to procedural objections).  

Conclusion:  support  for  most  measures  from  stakeholders  and  Member  States, 
except:  

− 

− 

(e)  Stricter  eradication  /  containment  measures  (one  MS  requires  more 
flexibility) 
(h)  EU  co-financing  of  MS  compensation  to  operator  losses  (wide  support 
from stakeholders, mixed views among MS) 

100 Perhaps to the exception of some IAS plants that had not yet reached Europe. 

126 

 
 
 
                                                 
− 

− 

− 

(i) Measures  addressing high-risk trade  (stakeholders  fear  disproportionate 
impacts) 
(m)  Expansion  of  plant  passporting  obligation  to  all  plants  (disputed  by 
several stakeholders and Member States) 
(u)  Expansion  of  regime  to  include  IAS  plants  (diverging  opinion  among 
stakeholders and Member States) 

II. Opinions concerning the four strategic options 

Replies from stakeholders 

Ten replies were received from the stakeholders to the final consultation: 

−  PLANTUM  NL  (a  seeds  industry  organisation)  was  in  favour101  of  Option  2. 
EUROPATAT  (representing  potato  trade)  was  in  favour  of  Option  2  but  if 
additional funds were available Option 3 would be acceptable as well. 

−  EFNA  (representing  EU  forest  nurseries),  ENA  (representing  EU  nurserystock 
producers), UFS (a seeds industry organisation) and the NATIONAL TRUST (a 
national heritage NGO) were in favour102 of Option 3.  

−  USSE (representing southern EU foresters) was in favour of Option 3 or Option 

4, depending on the available EU budget. 

−  AIPH  (representing  EU  horticulture),  COPA-COGECA  and  its  member  LTO 
NEDERLAND were in favour of Option 4, on condition that the budget for IAS 
plants  will  not  come  from  the  CAP  (COPA-COGECA)  and/or  only  IAS  plants 
with serious impacts to agriculture would be regulated (AIPH). 

Replies from Member States 

From the consultations with the Chief Officers for Plant Health of the Member States on 
individual  technical  issues,  it  was  clear  that  most  MS  seemed  in  favour  of  allocating 
additional  EU  budget  to  the  EU  plant  health regime.  Replies  to  the  consultation  on  the 
strategic options weres however received only from eight MS103: 

−  None of the MS was in favour of Option 1; 
−  Two MS were in favour of Option 2, due to lack of resources and/or opposing any 
increase  to  the  EU  budget,  however,  if  the  increased  budget  for  plant  health 
stemmed  from  a  reallocation  within  the  existing  EU  budget,  they  were  open  to 
this (i.e., in that case options 3 and 4 could be acceptable too; however, one of 
these two respondents anyhow rejected option 4); 

−  Three MS were in favour104 of Option 3; 

101  PLANTUM  NL  considered  this  option  feasible  if  there  would  be  more  focus  on  high  risk  trade  and 
priority  pests,  stakeholders  would  be  better  involved  in  surveillance  and  more  tasks  would  be 
delegated to operators under official supervision. 

102  EFNA  submitted  a  majority  position;  some  of  its  members  preferred  Option  2.  The  NATIONAL 
TRUST  made  the  proviso  that  EU  funding  should  not  be  centered  on  compensation  but  rather  on 
increased  prevention  and  surveillance  actions.  ENA  believed  the  additional  money  should  not  come 
from the CAP but from EU tax payers. For NATIONAL TRUST the fall-back option is Option 2, in 
case no additional EU budget would be available. 

103  It  is  likely  that  the  other  MS  did  not  wish  to  bind  themselves  to  any  position  at  this  stage.  Replies 

received generally pertained to tentative / provisional / informal positions. 

104 One of these specified that additional resources should be taken from the CAP and only be used for EU 

priority pests. 

127 

 
 
 
                                                 
−  Three MS were in favour105 of Option 4. 

Conclusion: Option 3 best reflects the average outcome of the consultation, both for 
the stakeholders and for the Member States.  

III. Other issues 

Aside from the specific issues addressed above, stakeholders requested the following: 

−  An active role for operators in surveys for harmful organisms 
−  More delegation of tasks to operators, to be carried out under official supervision, 
thus saving resources (as also believed possible under Regulation 882/2004), also 
needed for laboratories involved with routine sampling and testing 
In line with Regulation 882/2004, a more risk-based approach (better use of the 
reduced  frequency  checks  instrument;  urgency  required  for  cleaning  up  the 
Annexes and removing outdated organisms) 

− 

−  More  attention  for  the  cost-effectiveness  of  measures  (economic  cost-benefit 

analysis) 

−  A solution for outstanding problems concerning re-export involving multiple MS 
−  Better EU support for scientific research, diagnostics and training to support the 

plant health regime 

−  Partnership  between  private  and  public  sectors  for  the  governance  of  the  health 

regime (cost and responsibility sharing) 

−  Establishment  of  a  permanent  Working  Group  on  Plant  Health  under  the 
Advisory  Group  on  the  Food  Chain,  Animal  and  Plant  Health,  as  a  permanent 
forum for discussing plant health between the Commission and the stakeholders 
(this request was supported by most Member States) 

−  Concerns  were  expressed  about  the  phasing  out  of  active  substances  of  plant 
protection  products,  which  are  indispensable  to  control  outbreaks;  in  case  of 
outbreaks  of  regulated  pests,  eradication  costs  will  be  unnecessarily  high  (for 
PAN EUROPE however, pesticides should be a last resort) 

−  More  support  to  developing  countries  to  set  up  proper  phytosanitary  systems 

(prevention at the source; capacity building) 

105 One of these assumed that the inclusion of IAS plants would not lead to any substantial additional costs. 

128 

 
 
 
 
 
 
                                                 
Annex XI: List of consulted stakeholders 

The European stakeholders' organisations listed below were invited to attend consultation 
meetings and invited to reply to consultation documents106.  

AIPH 

ANTHOS 

AVBS* 

BEUC* 
BLGG AgroXpertus 

CEI-BOIS 

CELCAA 

CEPF 
CIAA 

CIOPORA* 

CLECAT 

COCERAL* 

COPA-COGECA 

DPA 
ECPA 
EEB* 
EFNA 
EISA* 

ELO 
ENA 
ESA 
ESC* 
EUROCHAMBRES* 

the 

for 

International  association  of  horticultural 
producers 
Koninklijke handelsbond voor 
boomkwekerij- en bolprodukten (NL) 
Beroepsvereniging voor bloemisten, 
snijbloementelers, boomtelers, 
tuinaannemers en detailhandelaars (BE)  
European consumers organisation 
Bedrijfslaboratorium voor grond- en 
gewasonderzoek (NL) 
European confederation of woodworking 
industries 
European 
liaison  committee 
agricultural and agri-food trade 
Confederation of European forest owners 
Confederation  of  the  food  and  drinks 
industries 
International  community  of  breeders  of 
asexually  reproduced  ornamental  and  fruit 
varieties 
European  association 
transport, logistics and customs services 
Comité du commerce des cereals, aliments 
du  bétail,  oléagineux,  huile  d'olive,  huiles 
et graisses et agrofournitures 
European 
cooperatives 
Dutch produce association (NL) 
European crop protection association 
European environmental bureau 
European forest nursery association 
European 
initiative 
development in agriculture 
European landowners' organisation 
European nurserystock association 
European seed association 
European shippers council 
Association  of  European  chambres  of 
commerce and industry 

forwarding, 

sustainable 

European 

farmers 

agri-

for 

for 

106  National  stakeholders'  organisations  that  replied  to  the  consultations  (indicated  by  their  country 
acronym)  are  listed  in  so  far  they  participated  in  or  replied  to  the  consultations.  Stakeholders  that 
participated  in  meetings  without  sending  in  position  papers  are  also  listed,  in  many  cases  these 
stakeholders  gave  oral  input  during  the  meetings.  Additional  to  the  listed  stakeholders,  21  other 
stakeholder  organisations  participated  in  the  conferences.  Stakeholders  that  were  formally  invited  to 
participate  in  meetings  and  consultations  but  never  sent  in  any  replies  (mainly  members  of  the 
umbrella Advisory Group) are marked with an asterisk. 
129 

 
 
 
 
                                                 
EUROCOMMERCE* 

EUROCOOP 

EUROPATAT 
EUSTAFOR 
FEDIOL 
FEFPEB 

FERN* 
FOE Europe* 
FRESHFEL Europe  
GLOBALGAP* 

Greenpeace* 
HLB 

HTA 
IFOAM-EU 

IORPIB 

IRU* 
JNCC 
LRF 

LTO Nederland 

MTK 

NAO 
National Trust 
NFU 

NUTFRUIT* 
PAN Europe 
PLANTUM NL 

UFS 
UNION FLEURS 
UNPT 

USSE 
VGB 

WWF* 
ZVG 

in 

of 

of 

for 

and 

organic 

consumer 

federation 

community 

consultancy 

Institute  –  National 

retail,  wholesale  and 

Association 
international trade interests 
European 
cooperatives 
European potato trade association 
European state forest association 
EU oil and proteinmeal industry 
Fédération  européenne  des  fabricants  de 
palettes et emballages en bois 
Forests and the European Union network 
Friends of the earth Europe 
European fresh produce association 
Global partnership for safe and sustainable 
agriculture 
Greenpeace 
HLB 
research 
agriculture (NL) 
Horticultural trades association (UK) 
International 
agriculture movements (EU Group) 
Plant  Protection 
Research Institute (PL) 
International road transport union 
Joint nature conservation committee (UK) 
Lantbrukarnas  riksförbund  (Federation  of 
Swedish farmers) (SE) 
Nederlandse  land-  en  tuinbouworganisatie 
(NL)  
Central union of agricultural producers and 
forest owners (FI) 
Nederlandse aardappelorganisatie (NL) 
National Trust (UK) 
National  farmers'  union  of  England  and 
Wales (UK) 
International nut and dried fruit council 
Pesticide action network Europe 
Branchevereniging  voor  bedrijven  in  de 
sector uitgangsmateriaal (NL) 
Union française des semenciers (FR) 
International floricultural trade association 
Union  nationale  des  producteurs  de 
pommes de terre (FR) 
Union des sylviculteurs du sud de l'Europe 
Vereniging 
in 
bloemkwekerijprodukten (NL) 
World wildlife fund 
Zentralverband Gartenbau (DE) 

groothandelaren 

van 

130 

 
 
 
 
 
Annex XII: Executive summary of the supporting economic 
study 

For the complete report, see: 
http://ec.europa.eu/food/plant/plant_health_biosafety/rules/docs/fcec_final_report_econo
mic_study_plant_health_en.pdf  

131 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
132 

 
 
 
 
(1) 

133 

 
 
 
Key messages 
The aim of this study was to provide supplementary economic data on impacts of amendments to 
the  current  EU  plant  health  regime  and  to  support  the  development  of  the  impact  assessment 
accompanying the legislative proposal of the Commission on the future EU plant health law. The 
key conclusions of the study are as follows: 

•  The total annual costs for the EU and MS of introducing mandatory general intra-EU 

surveillance (Task 1) for ten potential priority Harmful Organisms (HOs) were estimated at 
EUR  €23.4 million  per year if surveillance is carried out at fixed ‘best practice’ levels ("EU 
surveillance requirements" option), of which €9.4 million  are additional to the current 
estimated EU 27 surveillance expenditure. Under the "EU surveillance facilitation" option 
(i.e. without fixed levels) the estimated costs range from €14 million  (current levels of 
expenditure) to €16.8 - €21 million,  of which €2.8 – €7 million 
estimated EU 27 surveillance expenditure. 

are additional to the current 

•  The costs of introducing compulsory post-entry quarantine (PEQ) in the import regime for 
a limited number of high risk ornamental plants for planting (Task 2) would largely fall on 
private operators (POs) and this measure may result in some rationalisation in the sector. The 
highest component are costs of building new facilities at the required biosecurity level 
(implementing the newly adopted ISPM34), which are estimated at ca. €1,000/m 2 or up to €1 
million in total for a standard facility (up to 1,000 m2). Administrative costs for MS 
Competent Authorities (CAs) are to be fully recovered through fees charged to POs 
(inspection costs estimated at ca. €5,000 per facility in total over a PEQ period of 2 years), 
while the expected impact for the COM is likely to be minimal.  

•  The rationale and structure of the animal health financing could be applicable as a model for 
plant health to compensate for direct PO costs and losses, but the model will need to be 
adjusted to the specificities of plant health and the wide diversity of sectors affected, with a 
view to prioritisation and seeking a balance between public and private (commercial) 
interests. The financial impact of expanding the EU solidarity regime to co-finance direct 
costs and losses of POs (at 50% co-financing rate) (Task 3) was estimated at an additional 
expenditure for the EU of ca. €5 million per year  at the current level and number of 
measures imposed by MS CAs on POs. This is very likely to increase the implementation of 
officially imposed measures by POs, and to trigger the implementation of national 
compensation schemes, but it is most unlikely to increase the intensity of measures taken by 
MS CAs.  

•  The financial impact of expanding the EU solidarity regime to also include natural spread 
of plant pests (Task 4) was estimated at additional EU expenditures of min. €3.7 million per 
year (50% co-financing), with a substantial increase in the case of inclusion of natural spread 
for HOs affecting the environment. 

• 

In case of no action, the introduction, spread and establishment in the EU of regulated HOs 
impacting on agriculture, horticulture, forests and the environment (Task 5) has the potential 
to cause multiple billions of Euros of economic damage per year across the EU to sectors 
directly affected and upstream/downstream industries, as well as also potentially adversely 
affecting tourism, retail, and ecosystem values and services. The impact of an outbreak of 
any of the selected HOs reviewed by the study in terms of damage costs may extend to the 
entire value chain of the sector/s affected, with potentially very significant knock on effects 
on employment and the wider economy. 

•  Whatever approach is considered for solving the current lack of coherence in listing HOs 
between the seed or plant propagating material (S&PM107) acquis and the EU plant health 
regime (Task 6), impacts of aligning the two regimes are likely to be negligible. Merging 

107 Indicated in the main text of the impact assessment as the plant reproductive material (PRM) regime.  

134 

 
 
 
 
                                                 
the visual inspection based plant passports (PPs) of the plant health regime with the sampling 
and laboratory testing based health certificates of the S&PM regime would lead to a cost 
reduction of about €1.5 million but, as several MS have already implemented this approach, 
the total benefit would be less. Delegation of tasks would help alignment to the approach of 
Regulation 882/2004/EC which is based on results to be obtained and not on how it should be 
done (current logic of the plant health regime).  

•  The modifications to the plant passport (PP) system (that would be issued in a larger 
number of cases than at present and/or in a more harmonised format; Task 7) have a 
negligible financial impact on POs. The required information is already present in their ICT 
system (used e.g. for stock keeping and invoicing), and the cost of possible modifications to 
formats of reports, labels, tags and the like (hence also PP), can be split over many users of 
the specific software packages in use.  

• 

If mandatory surveillance targets for protected zones (PZs) (Task 8) are introduced, the cost 
of surveillance is increased (in the order of several thousand to millions of Euros, depending 
on PZ); where economic benefits of maintaining a PZ could be estimated, such benefits 
clearly outweigh the costs of surveillance even if this is carried out at an increased ‘best 
practice’ level. The costs of mandatory surveillance do not currently appear to be always 
shared between MS CAs and POs, and there is a need to reinforce the implementation of EU 
plant health regime provisions to collect mandatory fees for cost recovery of the inspections 
and sampling/testing in PZs. Immediate delisting of an infested PZ would no longer allow 
protection, thus possibly reducing the potential to eradicate while increasing the cost; on the 
other hand, immediate benefits may result for non-PZ MS in terms of saving high inspection 
and eradication costs to export to the PZ. Delisting an infested PZ after 2 years allows the 
time that is technically considered necessary for the eradication programme to run its course 
while enhancing the transition towards reinforced measures to maintain the integrity of the 
PZ, more in line with the Pest Free Area concept under the IPPC.  

•  The introduction of mandatory requirements for the prevention and control of IAS plants 

within the EU plant health regime may result in an increase in management costs across the 
EU as a whole. Although the total cost for absent or largely absent IAS plants is currently 
expected to be relatively moderate on the basis of the known level of presence and 
distribution and provided that EPPO guidelines on prohibitions of import/trade/planting are 
effectively introduced, if in future these IAS plants become more widespread, as is 
currently the case of Ambrosia artemisiifolia and Hydrocotyle ranunculoides, then the 
surveillance and control/eradication costs likely to require funding under Directive 
2000/29/EC could become very significant. Given the widespread presence of some of these 
IAS plants and the fact that natural spread is by definition an important factor in their 
distribution, future eligibility for EU co-financing of measures against natural spread related 
outbreaks could have very significant impacts on the EU budget (per IAS plant, potentially 
€1.5-€3.0 million annually for surveillance and €10-€30 million for eradication and 
containment). 

135 

 
 
 
 
(2) Executive summary 
The aim of this study, which was carried out by the Food Chain Evaluation Consortium 
(FCEC) in 2011, is to support the development of the impact assessment accompanying 
the legislative proposal of the European Commission (COM) on the future EU plant 
health regime (EU PH regime). The purpose is to provide supplementary economic data 
on impacts which form part of the analytical and descriptive inputs necessary for COM to 
complete its impact assessment and to fill existing knowledge gaps. The study 
investigates the potential impacts of various options to amend the EU PH regime, based 
on the conclusions and recommendations of the CPHR evaluation (FCEC, 2010). 
− 
− 
methodology developed for each of the 9 Tasks. To allow a more in-depth analysis, each 
Task has focused on a representative selection of HOs of high impact for the range of 
sectors potentially affected. The analysis is based on a range of scenarios and 
assumptions that serve as the working hypothesis for deriving the required quantitative 
and qualitative estimates. The development of these working hypotheses, as well as data 
collection, is based on extensive consultation with the relevant organisations (including 
inputs received from the various COM services; Member States (MS) Competent 
Authorities (CAs) and stakeholders) and four Task Forces (TFs) set up to support the 
COM in the review of the EU PH regime. 

The study has followed a highly targeted analytical approach, with a specific 

Task 1: costs of introducing mandatory general intra-EU surveillance 

The objective of Task 1 has been to estimate the costs of introducing mandatory general 
intra-EU surveillance for 10 potential priority harmful organisms (HOs)108 and the impact 
on the costs of EU co–financing of such surveillance. The selection of HOs includes 
those currently considered to represent the greatest threat for the EU, on the basis of data 
on interceptions, provisional emergency measures, control Directives, and the 
requirements of Council Directive 2000/29/EC. For some of these HOs109 mandatory 
surveillance is currently foreseen by EU legislation. The analysis undertaken was 
required to: 

1.1 Determine an appropriate level of surveillance from best practices among MS and by 
comparison with known surveillance levels for other important HOs, including potato 
pests.  
The appropriate level of surveillance was established on the basis of existing information 
on current surveillance methodologies in use in the MS and best practices were identified 

108Anoplophora  chinensis,  Bursaphelenchus  xylophilus,  Erwinia  amylovora,  Guignardia  citricarpa, 
Phytophthora  ramorum,  Potato  Spindle  Tuber  Viroid,  Rhynchophorus  ferrugineus,  Synchytrium 
endobioticum, Thrips palmi, Xanthomonas axonopodis pv. citri. 

109  For  5  HOs  mandatory  surveillance  is  already  currently  foreseen  under  emergency  measures  for 
Anoplophora chinensis, Bursaphelenchus xylophylus, Phytophthora ramorum, Rhynchophorus ferrugineus, 
Potato  Spindle  Tuber  Viroid  (PSTVd),  and  in  one  case  (Erwinia  amylovora)  under  Protected  Zones  and 
buffer zones in place; although the remaining HOs are not currently subject to mandatory surveillance rules 
(Guignardia  citricarpa,  Synchytrium  endebioticum,  Thrips  palmi,  Xanthomonas  axonopodis  pv.  citri.), 
voluntary plans are in place in some MS. 

136 

 
 
 
 
 
 
 
 
                                                 
in part by means of a comprehensive survey of the EU27 MS CAs (to which 25 MS 
responded). The ‘best practices’ identified in this way were used as the basis for the cost 
calculations and reflect expert views as to what constitutes the most realistic combination 
of science and economic considerations rather than a technical gold standard110. Indeed, 
current National Plant Protection Organisation (NPPO) decision-making when planning 
and prioritising surveillance is a combination of what is practical and possible - given 
resource constraints - and achieving a balance between the need to address a number of  
potentially extensive HO threats and the economic interest in those sectors the NPPO is 
called on to protect. For example, on the basis of the information provided by the MS, 
inspections in nurseries generally tend to be combined for HOs affecting ornamental 
plants. Also in many cases, where data availability allows this, the level of sampling and 
testing is undertaken on the basis of suspected cases only. 

1.2 Estimate total annual costs for the MS and the EU of introducing mandatory 
surveillance at fixed surveillance levels (at 50% co-financing) 

On the basis of the identified ‘best practices’ in terms of surveillance methodology, the 
total costs of introducing mandatory surveillance across the EU-27 at these levels, were 
estimated at €23.4 million  per year for the 10 potential priority HOs. This includes visual 
inspections in production places and the environment (40% and 34% respectively of total 
costs), sampling and testing (24%), and awareness-raising campaigns (2%). On the basis 
of the results of the CPHR evaluation (FCEC, 2010), the current EU 27 expenditure on 
surveillance for the 10 HOs is estimated at €14 million (see also Task 1.3). Therefore, the 
additional costs of introducing compulsory surveillance at fixed levels would be €9.4 
million. The additional costs for the EU, given that currently there is no co-financing of 
these surveillance costs, are estimated at 50% of the global figure of €23.4 million, i.e. at 
€11.7 million. 

HO 

Production places - nurseries 

Visual 
inspections/ 
production 
places 
€ 9.3 million 

Visual 
inspections/ 
environment 

Sampling 

Information 
campaigns 

Total 

€ 2.5 million 

€  81,000 

€ 11.8 
million 
€ 10.2 
million 
€ 1.4 million 

Forestry/open environment 

€ 8.0 million 

€ 1.9 million 

€ 242,000 

Other production places 

€ 1.2 million 

€ 162,000 

Total (10 potential priority HOs) 

€ 9.3 million 

€ 8.0 million 

€ 5.6 

€ 485,000 

€ 23.4 

% of total 

40% 

34% 

million 
24% 

2% 

million 
100% 

(a)  Estimates based on average EU fee rate. Figures rounded. 

Source: FCEC calculations 

1.3 Estimate total annual costs for the MS and the EU of introducing mandatory 
surveillance for the selected HOs without fixed surveillance levels (at 50% co-financing). 

The underlying assumption under this option is that the EU would facilitate surveillance, 
but MS apply those levels of surveillance they consider appropriate. Under this 
assumption, the availability of EU funding could result in: 

110 Defining ‘best practices’ on a scientific basis is an exercise beyond the scope of Task 1. 

137 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
a.  ‘Status quo’: MS continue at current levels of surveillance on the basis of their 

current priorities and budget availability. They therefore use EU funding to match 
the total funding they currently provide for surveillance. In this case the annual 
cost for the EU is estimated at ca. €7 million  (at 50% co-financing); this is new 
expenditure since surveillance costs are not currently co-funded; 

b.  ‘Dynamic scenario’: this assumes that a higher budget would be available if there 
was EU co-financing at 50% as MS may decide to increase surveillance levels, to 
reach what they currently consider to be their needs (i.e. an increase of 20-50%), 
as indicated by MS by means of the MS survey In this case, the total annual cost 
for the EU and the MS is estimated at ca. €8.4-€10.5 million 
each (at 50% co-
financing). For the EU, this is new expenditure since surveillance costs are not 
currently co-funded. 

In summary, therefore, the costs and additional costs of the various options are as 
follows: 

Scenario  
Current expenditure (FCEC, 2010) 

Total (100 %)  
€14.0 million   

EU (50%)  

 -  

At fixed surveillance levels (Task 1.2)  

Additional to current expenditure  

€23.4 million  
€9.4 million   

€11.7 million  
€11.7 million   

Without fixed surveillance levels (Task 1.3)  

a. ‘Status quo’  
Additional to current expenditure  
b. ‘Dynamic scenario’  
Additional to current expenditure  

€14.0 million  

- 
€16.8– €21.0 million  
€2.8– €7.0 million 

€7.0 million  
€7.0 million   
€8.4 – €10.5 million  
€8.4 – €10.5 million 

Task 2: costs of introducing compulsory post-entry quarantine (PEQ) for a limited 
number of plants for planting 

The objective of Task 2 has been to estimate the costs of introducing compulsory post-
entry quarantine (PEQ)111 for non European latent HOs which cannot be immediately 
detected by visual inspection or via appropriate laboratory testing within the timeframe 
of normal import procedures, but which pose a latent risk of infection. This option 
concerns a limited number of high risk ornamental plants for planting, in particular palm 
trees (risk of Rhynchophorus ferrugineus); and, trees of the Acer species and bonsai (all 
species), imported from East Asia (risk of a number of HOs including Anoplophora 
chinensis). 

− 
From our analysis and expert consultation (MS CAs, stakeholders, COM, TF3, 
and European and Mediterranean Plant Protection Organization (EPPO)) the following 
conclusions on the impact of this option can be drawn: 
− 

111  PEQ  is  different  from  post-entry  inspections  which  are  already  possible  today,  after  the  consignment 
has  been  released  for  the  internal  market.  Post-entry  quarantine  (PEQ)  implies  that  the  consignment  is 
released for free movement only after an official quarantine period within which the consignment is held or 
planted under quarantine conditions and subject to official inspections and testing. 

138 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
•  The largest impact will be felt by Private Operators (POs) importers of the 

selected categories of plants; 

•  As PEQ facilities would be based on PO premises, there would be a need to 
build/upgrade current PO facilities, as these are currently considered largely 
inadequate, in terms of biosecurity. In other words there is a need to adjust to the 
requirements arising from the recently adopted ISPM34 – i.e. at least biosecurity 
level 2, and possibly also in terms of capacity (to allow all imports of the selected 
plant categories to be placed into PEQ); 
In terms of costs for MS CAs, the administrative costs of setting up and 
implementing PEQ are to be fully recovered, through fees charged to POs for 
registration, regular inspections and sampling; 

• 

•  The expected impact (in terms of administrative costs) for the European 

Commission is likely to be minimal, although there will be a need to: hold further 
consultations with MS and to steer the process of setting up and reviewing the 
system, e.g. in terms of the appropriate requirements for bio-security 
(implementation of ISPM34); and, to ensure that MS implement the PEQ 
requirements correctly. 

The costs involved in building/upgrading and maintaining facilities to the 

− 
appropriate biosecurity level (i.e. at least level 2) are estimated at ca. €1,000/m 2 or 
in total for a standard 300 m2-1,000 m2 facility. In addition 
€300,000 - €1,000,000 
administrative costs (registration, regular inspections and sampling fees to be paid to MS 
CAs on the basis of full cost-recovery) are estimated at ca. €4,480 – €5,040 per facility 
during a PEQ period of 2 years (on the basis of an estimated 32-36 inspections).  

− 
The above costs are considered to be relatively high, particularly for businesses 
with a high turnover trading small plants and therefore a relatively high number of low 
unit value commodities. It is therefore expected that this measure would result in some 
rationalisation in this sector. Although, in terms of business disruption, the impact is 
expected to be zero to minimal after the first 2 years (i.e. when products are released 
from quarantine), it is nevertheless considered that PEQ may not be a viable economic 
option in those cases where the costs exceed plant value (e.g. small Acer species), as this 
would effectively mean that the costs would outweigh the value of the plants put into 
quarantine. 
− 
− 
It is noted that third country (TC) trading partners, e.g. Australia and New 
Zealand also have PEQ obligations on imports of certain plants into their territory. The 
Australian model, for example foresees specifically dedicated and high bio-security level 
facilities run exclusively in PEQ stations appointed by the Australian Quarantine and 
Inspection Service (AQIS), and importers bear the full cost of the measures for the 
officially imposed minimum quarantine periods and at officially set fees. 
− 
Tasks 3 and 4: financial impact of applying the EU solidarity regime to co-finance 
direct costs and losses of POs; and to include natural spread 

The objective of Task 3 was to analyse the financial impact of applying the EU solidarity 
regime to co-finance not only costs of MS CAs but also direct costs and losses of POs 
pursuant to official measures imposed.  

139 

 
 
 
 
 
 
 
3.1 To clarify the extent to which the rationale and structure of animal health financing 
is applicable, as a model, for establishing a similar structure for plant health to 
compensate for such costs 

The study has found that the rationale and structure of the animal health (AH) financing 
could be applicable as a model for establishing a similar structure for plant health (PH) to 
compensate for direct PO costs and losses, but the model will need to be adjusted to the 
specificities of PH and the diversity of sectors affected, for which a more in-depth 
feasibility study would be recommended. The diversity of HOs and affected sectors 
covered by the PH regime makes it unlikely that it will be possible to find a model 
capable of addressing all scenarios and all sectors. To achieve this there is need for 
prioritisation, based on the significance and impact of plant pests at EU level and for the 
different sectors. It is further noted that the balance between public and private 
(commercial) interests needs to be fully taken into account in any model to be developed 
and in assessing the relative importance of individual HOs for different groups of 
beneficiaries, the purpose of compensation, and the relative weight of the public versus 
private good component of such compensation.  
Regarding the potential for cost-sharing, a key principle of the ongoing cost and 
responsibility sharing schemes (CRSS) being developed in AH, is that direct costs should 
be partly covered by public resources (up to maximum ceilings), while for the 
compensation of non-covered direct losses and consequential losses, POs should assume 
primary responsibility through the development of private insurance schemes/mutual 
funds. PO liability - a key component in relation to Food Law - for helping mitigate risks 
through appropriate action is seen as an important element for future CRSS, as long as 
this does not result in a disproportionate administrative burden. The availability of 
support could be linked to compliance with statutory action, analogous to the “three tier 
approach”112 which is being developed by the COM/MS for contingency 
planning/minimum mandatory action. In practice, for a very limited number of EU 
priority pests, pest-specific contingency plans should be developed, with strong 
involvement of stakeholders. Contingency plans could thus include both preventative 
measures taken by POs and PO response/cooperation in the event of an outbreak. In such 
cases the co-financing of the eradication measures by the EU should be very substantial 
given the high importance of the pests and the fact that the actions are mandatory.  

Stakeholders’ views were found to be quite divergent and generally the need for public 
intervention  with  solidarity  funding  appears  to  correlate  with  the  interests  of  the  more 
fragmented  sectors.  In  broad  terms,  the  arable  sector  appeared  to  favour  reliance  on 
Common  Agricultural  Policy  (CAP)  support  in  relation  to  funding,  arguing  that  the 
funding for plant health solidarity should not affect the overall funding for CAP, while 
the horticultural and forestry sectors were more interested in compensation.  

3.2 To estimate in global terms (order of magnitude) the direct costs of POs associated 
with the officially imposed measures that would be eligible for compensation.  

112 1. Detection of a new listed/non-listed pest in new areas (minimum mandatory action – no contingency 
plan); 

2. Detection of a listed pest of EU importance (generic EU contingency plan); 

3.  Detection  of  a  listed  pest  of  priority  EU  importance  (EU  pest-specific  contingency  template  with 
minimum mandatory actions and national contingency plans). 

140 

 
 
 
 
 
 
                                                 
− 
This analysis was carried out for a representative selection of HOs affecting the 
different sectors113. The FCEC estimates are summarised according to eligibility under 
three headings:  

(i)  Already eligible direct costs and losses: these are currently covered by solidarity 

i.e. costs of removal, destruction, disinfection, sampling and testing. These 
were estimated at the range of €19.3 - €44.8 million per year, reflecting the 
various scenarios used in the calculations. As an average between all 
scenarios, the costs of heading (i) are estimated at €32 million per year ;  

(ii) Currently non eligible direct costs and losses: these are the costs not covered 

currently by solidarity i.e. loss of plant/production value for POs. These were 
estimated at €6.7 - €13.4 million per year, reflecting the various scenarios 
used in the calculations. As an average between all scenarios, the costs of 
heading (ii) are estimated at €10 million per year ; 

(iii)Currently non eligible indirect costs and losses: these are the costs that go beyond 

the scope of Task 3, i.e. consequential losses from movement bans for POs. 
These were estimated at €15.3 - €19.4 million per year, reflecting the various 
scenarios used in the calculations. As an average between all scenarios, the 
costs of heading (iii) are estimated at € 17.4 million per year . 

3.3 To estimate the costs for the EU and MS CAs of expanding the solidarity regime to 
co-finance direct costs of POs, under two different scenarios: at current level of 
checks (scenario 1: static scenario); at increased level of checks (scenario 2: 
dynamic scenario)  

A priori, it is noted that the current legal basis in principle already provides the 
framework for compensation of certain costs/losses of POs when these are directly 
related to the implementation of officially imposed phytosanitary measures; this has 
however not yet been fully implemented. The impact on EU solidarity funding should 
therefore in principle be considered as neutral on this basis, as an increase in the required 
funding would relate to the full implementation of the current provisions. Nonetheless, in 
practice, full implementation of these provisions will carry an additional cost for the 
solidarity funding when compared to the current implementation.  

Under the static scenario, on the assumption that all the MS where outbreaks occur 
introduce solidarity requests and all the dossiers submitted by MS are eligible114, all 
direct costs and losses would be covered by the EU at 50%115. The additional EU 
expenditure required for funding under solidarity if direct losses are made eligible 
(heading (ii)), at 50% co-financing rate, would therefore amount to ca. €5 million per 
year. This expenditure would be additional to the estimated expenditure to cover the 
already eligible direct costs (heading (i): €16 million per year of EU co-financing at 
50%). 

113  Diabrotica  vv,  Ralstonia  solanacearum,  Clavibacter  michiganensis  ssp.  Sepedonicus,  Bemisia  tabaci, 
Erwinia  amylovora,  Potato  Spindle  Tuber  Viroid,  Bursaphelenchus  xylophilus,  Anoplophora  chinensis, 
Anoplophora glapripennis, Rhynchophorus ferrugineus 

115 Compensation rate by MS is 100%. 

141 

 
 
 
 
 
 
 
 
                                                 
 
The inclusion of direct costs and losses under solidarity funding may have an impact of 
the level and intensity of measures imposed on the POs, and therefore impact on the 
overall solidarity funding (dynamic scenario). Over the last five years, a total amount of 
€29 million  was paid in 10 MS to compensate costs and losses of POs following 
outbreaks of HOs, i.e. an average €5.9 million per year.  By extrapolating to the whole 
EU, this would result in potential compensation at EU level of some €11 million per 
year116. In the absence of any further evidence, it is not possible to quantify the impact 
of the introduction of the coverage of costs and losses of POs on the level of measures 
imposed on the POs and co-financed by MS and therefore by the solidarity regime. On a 
qualitative basis, the availability of compensation for direct PO costs and losses incurred 
by the officially imposed measures is likely to trigger the implementation of national 
compensation schemes the legal basis for which currently exists in MS, but which have 
not been so far activated, very likely to increase the implementation of officially imposed 
measures by POs, and mostly unlikely to increase the intensity of measures taken by 
national authorities.  

Task 4: To estimate the impacts for the EU and the MS of expanding the Solidarity 
Regime so as to also cover prevention measures for natural spread. 

Only 7 MS (out of the 25 MS that responded to the FCEC survey) indicated they would 
submit a dossier for outbreaks caused by natural spread. The total cost of these dossiers, 
as indicated by MS (only 5 MS provided figures), would reach at least €7.3 million per 
year.  
On  the  basis  of  50%  co-financing,  the  impact  on  the  EU  solidarity  budget  would 
therefore be at least €3.7 million  per year. 

The  figures  provided  by  MS  indicate  that  the  increase  in  solidarity,  although  not 
significant in most cases, would become substantial in the case of inclusion of natural 
spread for HOs  affecting  the environment, as the case of  Rhynchophorus ferrugineus 
indicates. This is due to the high eradication costs of these HOs, as shown in the analysis 
for  Task  3,  particularly  if  direct  losses  (heading  ii)  are  also  to  be  covered.  It  is  also 
evident that the HOs with the highest potential for natural spread are also those with the 
most significant potential costs from the control measures taken in the case of outbreaks.  

Task 5: economic impact of harmful organisms 

The objective of Task 5 has been to estimate the potential economic impact arising from 
the spread of HOs, by focusing on specific HOs affecting a range of sectors (agriculture, 
horticulture, forestry, public/private green spaces).  

The economic analysis undertaken primarily covers the actual or potential damage to the 
sector/s concerned (damage costs). The assessment of these is conducted drawing on the 
best available evidence from past outbreaks as existing studies and literature including 
pest risk assessments (MS, EU, EPPO Pest Risk Analyses) and cost benefit analysis 
(CBAs) of pest management. It is to be noted in this context that ultimately, the impact of 
an outbreak in terms of damage costs may extend to the entire value chain of the sector/s 

116 It includes all costs and losses. It is noted that this calculation does not take into account specificities in 
MS in terms of current cost sharing arrangements, and focus on particular HOs and sectors of national 
relevance, but it is simply based on the current French compensation model.  

142 

 
 
 
 
 
 
 
 
 
                                                 
directly affected by the introduction, spread and establishment of the HO. This has 
potentially very significant indirect and knock on effects on employment, as well as on 
other dependent sectors and the wider economy.  

The available evidence from past outbreaks and studies indicates that, if no action is 
taken, the introduction, spread and establishment in the EU of the HOs under review has 
the potential to cause multiple billions of Euros worth of economic damage per year 
across the EU to both those sectors directly affected and upstream/downstream sectors 
(including input suppliers, food processing and the wood working industries), as well as 
also potentially adversely affecting tourism, retail and other services, and ecosystem 
values and services.  

The FCEC analysis and findings highlight the need to distinguish between the potential 
impacts of pests affecting the agricultural, horticultural and nursery sectors in terms of 
yield and quality losses, and the impacts of pests affecting forestry and private/public 
green spaces. For the latter, impacts are both more complex and long lasting in effect, 
while there are less possibilities and considerably higher costs involved in replacing 
destroyed or susceptible plants than is the case for agricultural crops. In addition to 
longer term commercial impacts arising from harvest losses, there are significant 
potential adverse impacts on biodiversity, amenity, landscape and other environmental 
values (including broader environmental objectives such as the reduction of CO2 
emissions), which are generally very difficult to monetarise. We particularly note that as 
these functions of forestry and private/public green spaces have yet to be fully identified 
or quantified, the complete value of ecosystem services is always likely to be 
underestimated (European Commission, 2008a). Moreover, since the global impacts of 
pests and diseases are both complex and impossible to capture in their entirety, the 
estimates provided must also be considered to under-represent the entirety of the impacts. 
In the forestry sector, several of the HOs reviewed have the potential to cause severe 
damage to EU forests, in terms of economic and landscape value, as indicated by the 
FCEC estimates below. The range of losses depends on the underlying scenarios and 
assumptions, including the extent of the infestation, anticipated timber harvest and the 
extent of yield losses in the affected area, and producer prices in the various markets. For 
example, the results indicate that in the worst case scenario for a single pest the cost 
could reach somewhere in the range of €42.6-€89.2 billion (Anoplophora) or €39-€49.2 
billion (Bursaphelenchus xylophilus) in terms of the commercial value of the susceptible 
lost timber. Such losses could also have significant effects on employment: extrapolating 
on available evidence in the case of Bursaphelenchus xylophilus, some 11,040 jobs in the 
forestry and wood cutting sectors could be directly affected under the worst case 
scenario. Many more jobs would be at risk in the downstream sectors; the EU27 forestry 
and forest-based industries employ an estimated 2.4-3 million workers. Moreover, it 
would take at least 20-30 years for the lost forests to be replanted and mature to the point 
of generating new income from harvested timber. 

Estimated potential impact of key HOs affecting EU-27 forestry, in case of ‘no 
action’ (a) 

Bursaphelenchus 
xylophilus 
(PWN) 

Anoplophora 
(ALB/CLB) (b) 

Threatened area: 10-13 million ha of coniferous forests (assumed 50-90% mortality 
rate); 
Productive forestry value loss: €0.9-€1.7 billion  (scenario 1: PWN widespread in 
current area: PT) to €39-€49.2 billion  (scenario 4: PWN widespread in EU27); 
Export value loss: €174 million (worst case scenario: TC ban on EU imports). 
Threatened area: loss of 30% hardwood forest in the EU; 
Productive forestry value loss: €19.6-€39.2 billion  (scenario 1: Anoplophora 
widespread in currently infested MS) to €42.6-€85.2 billion  (scenario 2: Anoplophora 

143 

 
 
 
 
 
 
Phytophthora 
ramorum 

widespread in EU27); 
Threatened area: loss of 20% hardwood forest in the EU high risk area (EU PRA); 
Productive forestry value loss: at least €4.2-€9.1 billion , plus threat to EU cork 
industry. 
Threatened area: not yet present in EU; if introduced, 100% of susceptible area in 
medium/ high risk regions (77% mortality rate), or 11.6 million ha coniferous (Pinus 
sylvestris) forest; 
Productive forestry value loss: €31.8-€45.5 billion  
(a)  Impacts on the sectors directly affected by the indicated pests. 
(b)  Anoplophora chinensis (CLB) and Anoplophora glabripennis (ALB) 

Dendroctonus 
ponderosae 
(MPB) 

Source: FCEC estimates 

The potential loss in value indicated above refers to harvested timber only, and excludes 
other forest landscape, recreational and environmental values which, as forestry data 
demonstrates, are much more significant. Based on estimates by UK Forest Research 
(2010) for specific UK tree species, the landscape/ recreational value and the biodiversity 
/carbon sequestration value of EU27 forests could roughly be valued at ca. €56 billion 
(FCEC extrapolation). Other estimates (PRATIQUE) provide a landscape value of trees 
susceptible to Anoplophora glabripennis at €287.6/tree. 

According to data reported by MS to Forest Europe, some 4.4 million ha of the EU27 
forest area (ca. 3% of the total forestry area) is already damaged by insects and 
diseases, which are the most significant damaging agents within EU forests and far more 
significant than the  damage caused by wildlife and forest fires. The total area damaged 
by insects and diseases in the EU27 may affect the production of an estimated annual 
felling volume of 12.3 million m3 of roundwood with an estimated value of €492 million. 
In addition, in the damaged area, such damage may affect the provision of non-wood 
goods (NWGs) (estimated value: €74 million) and of services (estimated value: €34 
million). Taking these factors together therefore, the total loss of value from damage 
caused to date by insects and diseases may have already reached an estimated annual 
loss of ca. €600 million  in terms of income generated from wood, NWGs and services 
provided by the affected forestry resource. 

In the agricultural sector, the HOs under review can cause significant production and 
trade losses, as indicated by the FCEC estimates below (the range of losses depends on 
the underlying scenarios and assumptions, as noted for forestry pests): 

Estimated potential impact of key HOs affecting EU-27 agriculture, in case of ‘no action’ 
(a) 

Maize 

Diabrotica virgifera virgifera:  
Crop value loss: €472 million per year; up to € 6.1 billion over 25 years (FCEC, 2009); 
Export value (under threat): extra-EU exports of €336 million per year (2008-2010 average)  

Potatoes  High risk from a range of HOs (b), for 3 of which EU Control Directives are in place: 

Crop value loss: yield losses can vary from 20%-80% depending on the HO; on this basis, 
PCN could cause losses of up to €8 billion , ring rot up to €3 billion , and brown rot up to €4 
billion; 
Export value (under threat): extra-EU exports of €413 million per year (2008-2010 average) 

Tomatoes  High risk from several HOs (c): 

Crop value loss: €6.6 - €9 million  (scenario 1: PSTVd spreading in previously infested MS) to 
€93-€127 million  (scenario 2: PSTVd spreading throughout the EU27); 
Export value loss: from Tuta absoluta outbreak (US and Canada restrictions on EU imports) 
estimated at ca. €11.5 million per year 

(a)  Impacts on the sectors directly affected by the indicated pests. 

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(b)  Including Clavibacter michiganensis spp. sepedonicus (potato ring rot); Globodera (potato cyst 
nematodes - PCN); Ralstonia solanacearum (potato brown rot); Potato Spindle Tuber Viroid 
(PSTVd). 

(c)  Including Potato Spindle Tuber Viroid (PSTVd); Pepino Mosaic Virus (PepMV); Tuta absoluta 

Source: FCEC estimates 

Even at the level of direct impacts, it is difficult to put a monetary value on the 

− 
production loss due to a plant pest, since a range of factors including pre-outbreak 
agricultural and forestry management practices and other preventive action will affect the 
extent of the damage likely to be caused by a specific pest, while the lost production 
value will depend on the prevailing market prices at the time the commodity concerned 
would have been produced and/or sold. Market prices are difficult to obtain in many 
cases (there is generally significant lack of data on prices, while in most sectors there is 
no ‘EU price’, making it complex to extrapolate at EU level). Furthermore, prices also 
fluctuate considerably depending on a range of factors, including in many cases the 
prevailing supply and demand in international markets. Such effects are compounded by 
the fact that outbreaks themselves may affect the level of market prices if they result in 
significant and drastic losses of production. 
− 
Other costs of ‘no action’, which have not been investigated here, include the impact that 
the spread and establishment of a HO could have on the functioning of the internal 
market if MS are forced to adopt measures which may affect the free circulation of goods 
within the EU.  

By comparison, in the US, it is estimated that plants and plant pathogens cause annual 
damage of the order of $64.1 billion, of which $21 billion consist of crop losses caused 
by plant pathogens, $13.9 billion of crop losses caused by insects and mite pests, $4.2 
billion consist of loss of forest products and $24 billion are estimated to be caused by 
crop weeds; of these figures, 40%-65% is due to introduced pests, pathogens and weeds 
(Pimentel et al., 2005). In the UK, a study carried out in 2010 estimated the total current 
annual cost of invasive non native pests to the British economy at approximately €1.9 
billion.  

The common conclusion that emerges from all available studies and the FCEC estimates 
is that, although the total annual costs (to both industry and government) of prevention 
and current (early response) measures may be significant, the potential benefits to be 
obtained by excluding the pest or containing/eradicating as early as possible are several 
times the order of magnitude of the cost of the measures taken. 

Task 6: improving the coherence between the EU Plant Health Regime (CPHR) and 
the EU Seed and Plant Propagating Material Regime (S&PM) 

The objective of Task 6 has been to address the coherence between the EU Plant Health 
Regime and the EU Seed and Plant Propagating Material (S&PM) acquis. The analysis 
undertaken was required to: 

6.1 Determine the appropriate positioning of HOs in the CPHR and the S&PM regimes 
and estimate the economic impacts (costs and administrative burden for MS and EU 
authorities as well as for POs) of moving regulated HOs from one regime to the other 
according to the following three options: 

145 

 
 
 
 
 
 
 
 
 
  
- 

Status quo (with cleaning up of double listing). Costs for cleaning the different 
legislative texts are considered as marginal. It consists of a desk review of the 
texts, a contact with NPPOs to secure that all HOs are considered and then 
cleaning-up of the texts; 

-  All HOs to be moved from the S&PM regime to a separate Annex in the CPHR 
(but retaining their provisions and requirements). Impacts of moving all HOs 
listed in the S&PM Regime to the CPHR are limited to impacts linked to the 
mandatory import control measures. However as the large majority of host 
species for the HOs to be considered for transfer are plants for planting which 
are already inspected at import, and as all plants for planting entering the EU are 
already controlled by at least a visual control of each consignment, the costs for 
import control will not increase. Costs would however increase significantly if 
laboratory testing would be a mandatory part of the inspection. For illustrative 
purposes, applying one laboratory test to each consignment of ornamental plants 
would cost €6.8 - €23.4 million for EU 27 MS; 

-  All HOs pertinent to seed or plant propagating material to be moved from the 

CPHR to the S&PM regime. As the S&PM regime shall apply “without any 
prejudice to the Plant Health regime”, any S&PM certified material shall 
already comply with the provisions of Directive 2000/29/EC and therefore no 
cost impacts are anticipated. As certain species are not covered under the S&PM 
regime, some host crops (e.g. tobacco) and related HOs will be de-regulated 
under this option but with marginal impacts as these crops are not of high 
European economic value and pest diseases to be considered are not of high 
risks. 

6.2 Assess the impacts of merging the plant passport and certification schemes and more 
particularly: 

The analysis of the costs and benefits for MS CAs and for POs of merging the 
visual  inspection  based  PPs  of  the  CPHR  with  the  sampling  and  laboratory 
testing  based  health  certificates  of  the  S&PM  Regime.  Currently  none  of  the 
current CPHR and S&PM regimes are a barrier to the merger of field inspection 
services.  For  S&PM,  field  inspections  can  be  done  under  official  supervision 
and in the case of CPHR some operational tasks can be delegated to bodies other 
than the official NPPO. Costs can be reduced by asking the S&PM inspectors to 
control holdings in the context of the PP obligations. In case all inspections for 
PP were carried out by S&PM inspectors, total yearly savings can be estimated 
at  less  than  €1  million  per  year.  The  total  benefit  of  moving  from  a  non-
integrated  approach  to  a  coordinated  joint  inspection  would  lead  to  a  cost 
reduction  of  about  €1.5  Million  but  as  several  MS  have  already  implemented 
this approach the total benefit would be less. 

-  The analysis of the economic impacts for POs and for CAs (CPHR and S&PM) of 

upgrading the PP requirements for propagating material to the level of the 
S&PM regime. We consider that upgrading PP requirements to the level of the 
S&PM regime requirements does not lead to any impact as there is no additional 
requirements to be implemented as they already exist. Inconsistency exists only 
in the legislative texts from which they have to be removed. 

-  The analysis of the economic impacts of merging the new PP document (logo) 
and the certificate document. Adding a logo on these labels will have a nearly 

146 

 
 
 
 
 
 
zero cost as the only thing to be done would be to add this logo on the label 
format. 

6.3 Determine the role of the private sector in the CPHR regime and delegation of tasks. 

The different evaluations and other studies that have been performed during the last three 
years  in  the  areas  of  S&PM  and  PH  have  all  highlighted  the  demand  by  a  majority  of 
stakeholders and CAs of delegation of tasks  that  should  be  understood  in  two  different 
ways: 

-  Delegation of tasks from the official NPPO to other official bodies (as already 
implemented in some MS for PP controls carried out by certification bodies); 
-  Delegation of tasks directly to POs (e.g. certification under official supervision in 

S&PM).  

Conclusions of this analysis show a low level of consensus regarding this possibility of 
delegating tasks.  

MS CAs in favour of delegation of tasks (i.e. FR) have highlighted that further delegation 
would help to align to the approach of the Regulation 882/2004/EC which is based on 
results to be obtained and not on how it should be done (current logic of the CPHR 
regime). In that context any tasks related to the monitoring of compliance of businesses 
with CPHR obligations may be delegated e.g. inspections, sampling and analysis etc. 
However, delegation of responsibility for taking action where infringements are found is 
prohibited. The COM retains the possibility to restrict further the types of tasks that may 
be delegated.  

Apart from using private laboratories in the context of CPHR, stakeholders and CAs 
consider that any other controls, and especially visual controls, related to general 
surveillance and implementation of control and emergency measures should remain an 
official task that should not be delegated. 

Task 7: impact of options on possible modifications to the existing plant passport 
system 

The objective of Task 7 has been to evaluate the impact of six different options 
concerning possible modifications to the existing PP system: 

7.1  Obligation  to  have  PP  accompanying  the  smallest  unit  in  trade  in  the  business  to 
business (B2B) chain 
In principle there is no impact, since such an obligation is already in place, through the 
issuance of replacement PPs, as foreseen under the present regulation, especially in the 
case that a large passported consignment is split in several smaller ones. 

7.2  Obligation  to  have  PP  accompanying  the  smallest  unit  in  trade  in  the  business  to 
consumer (B2C) chain, meaning that all plant material (for which at present a passport 
is needed), sold in nurseries and garden centres to a final consumer, would have to be 
passported 

147 

 
 
 
 
 
 
 
 
 
 
 
 
 
With the exception of individually sold bulbs, all other plant material (seeds, seedlings, 
ornamental plants, etc.) already carry some type of tag or label; adding information to 
these can be done either by the garden centres or by their furnishers, at a negligible extra 
cost. Note that final buyers who need large quantities of a given species will not buy 
from garden centres (B2C) but from nurseries (B2B), and thus already receive a PP if this 
is required for the species. 

7.3 Dropping the existing distinction between sales (of passported plant material) inside 
or outside a protected zone (PZ) 
Although such a distinction is foreseen under the present regulation (with sales outside a 
PZ not needing a PP), business practice today is already such that POs do not distinguish, 
and thus issue PP for all their consignments of species needing a PZ passport, even those 
not sold inside a PZ; this is also an indication that the cost of issuing plant PPs in cases 
where this is strictly spoken not compulsory, is not an issue. 

7.4 All plant material (traded in the B2B chain) should carry a passport (this option does 
not extend to the B2C chain) 

The implementation of this option would lead to an increase in the number of passports, 
the gross unit cost of which can be estimated at below 10 eurocent per consignment (the 
average value of a consignment in the B2B chain is not known, but is probably at least 
€100, so the increase is less than 1 ‰); the net unit cost can be still lower, if the 
“passport” information can be added to already existing documents such as invoices or 
transportation document (as is usual business practice, with the consent of the CAs). 

Note that in that case, all operators will have to be authorised to issue PPs; such 
authorisations do not lead to an extra cost in the large majority of the MS, the necessary 
inspections being combined with normal phytosanitary inspections. 

7.5  The  existing  formats,  which  cover  a  wide  variety,  should  be  harmonised,  while 
keeping the existing data fields 

This option would obviously have no impact for POs who fill in the PP by hand. For POs 
using a computer system, the impacts will be limited to minor modifications to the 
existing software packages (adapting the layout of documents to be printed); note that 
most operators use a package developed by specialised software companies, and that 
consequently the cost of its modification can be split over a large number of users (and 
will probably be considered to be part of the normal updating/upgrading that is included 
in the licence, and so will not be invoiced separately by these software companies to their 
users). 

7.6 The existing formats should not only be harmonised but also simplified, so that they 
could take the form of a label 
The impact would be the same as for 7.5: none for POs who still fill in the passports by 
hand; a limited impact (modification of software packages) for the ones who use a 
computer system, since the cost can be split over many users of such packages. 

Task 8: costs and benefits of introducing mandatory surveillance targets and 
mandatory de-listing procedures for infested protected zones 

148 

 
 
 
 
 
 
 
 
 
 
 
 
The objective of Task 8 was to analyse the costs and benefits of introducing mandatory 
surveillance targets and mandatory de-listing procedures for infested PZs, by focusing on 
specific examples of PZs117. The selected PZs provided a balanced representation of the 
various types of HOs and the different situations in MS with regard to the 
implementation of measures for the maintenance of PZ status, and of the challenges, 
added value and the costs for MS to maintain PZs in place.  

8.1 Identify best practices of surveillance targets for each HO for the selected PZs 

The improvement of surveillance targets within the PZs was recommended by the CPHR 
evaluation (FCEC, 2010) as one of the options for improving the current system of PZs 
and reinforcing their credibility, as the concerns with the current system of PZs stem 
from implementation issues. The ongoing work of a dedicated DG SANCO/MS TF also 
highlighted the need to introduce at EU level minimum levels of surveillance within PZs 
in order to provide a degree of harmonisation in the approach followed across the EU. 
For this Task, appropriate surveillance levels were identified on a case by case basis, to 
the extent this was possible, and applied to the selected case studies (PZ/HO).  

8.2 (a) Estimate the costs of introducing mandatory surveillance at identified 

surveillance level versus benefits 

Costs: The current costs of surveillance in PZs are generally lower than in the case of 
Buffer Zones (BZs) established within infested non-PZs. This is due to the fact that in 
PZs, in the absence of infestation, intensified surveillance levels are not generally 
applied. In the case of host plants and sectors with high economic value for the MS, the 
costs of surveillance in BZs could be from 2.5 to up to 10 times higher, as the number of 
controls needed to guarantee the same level of protection would need to be increased 
substantially. If current surveillance levels are considered insufficient to justify/ensure 
freedom from the HO, these would need to be raised and this would result in a higher 
cost. If mandatory surveillance targets are introduced at the level of ‘best practice’ (as 
defined for the purposes of Task 8 and indicated Task 8.1 results), the cost of 
surveillance is increased, as these levels generally result in higher inspection and/or 
sampling intensity. This increase may concern the level of visual inspections, with an 
intensity increase of 100% (e.g. Erwinia amylovora) in certain cases, and/or the level of 
sampling, with 10% additional sampling applied (e.g. Globodera pallida) or even higher 
increases, in the range of 100% or more (e.g. from symptomatic cases only to established 
levels of sample/ha in the case of Erwinia amylovora). 
Benefits: Evidence of the benefit of PZs is generally scarce; in most cases, there are 
currently no CBAs to support already established PZs (with the notable exception of 
Bemisia tabaci). In this regard, it needs to be considered whether carrying out a CBA 
should become a formal requirement in future for the establishment of PZs. In those 
cases where economic benefits could be estimated (i.e. Bemisia tabaci, Erwinia 
amylovora, and Globodera pallida, and in general for HOs affecting plants with a 
commercial value), it can be concluded that such benefits clearly outweigh the costs of 
surveillance even if this is carried out at an increased level. Thus, for example where the 
economic sector is highly important at national level, e.g. apple and pear production in 
IT, where the sector generates some €1.1 billion in terms of annual production value, the 
value of production in those regions where the bulk of production is concentrated will 

117 Erwinia amylovora – IT, LV; Bemisia tabaci (European populations) – UK, FI; Ips amitinus – IE, EL; 
Cryphonectria parasitica – CZ, SE; Globodera pallida – SK. 

149 

 
 
 
 
 
 
                                                 
amount to several hundred million Euros. In other words potential production losses are 
very substantial indeed compared to surveillance costs at increased levels amounting to 
hundreds of thousands of Euros. The same holds true in the case of the potato sector in 
SK, where the costs of the order of thousands of Euros of increased surveillance are far 
outweighed by the benefits of the protection of a sector with a value of €34 million.  

Results of costs and benefits for the PZs selected for the purpose of this exercise are 
presented in the table below: 

HO for which PZ is 
in place 
Globodera pallida 

Surveillance costs at ‘best 
practice’ levels (a) 
SK: € 41,000 

Erwinia amylovora 

Bemisia tabaci 

Ips aminitus 

Cryphonectria 
parasitica 

BZ: 
IT (two 
regions): 
€ 264,960  

PZ:  
IT (two 
regions): 
€54,800 

IT (est.): €4.2 
million 
LV: €85,900 
FI: €331,700 

SE: €4,200 
CZ: €19,000 - €33,400 
EL: €55,010 

IE :€ 5,800 

Benefits (value of protected sector) 

SK: €33.8 million 

IT (two regions): €180 million 

IT: €1.1 billion 

LV: €3.2 million 

€48.9 million (tomatoes only) 
Cost - benefit ratio estimated at 0.93-1.99 over 
30 years (at current levels of surveillance) 
Environmental value (non quantifiable) 

Economic value:  
Export value of coniferous round and sawn wood 
EL: €1.5 million  
IE: €62.6 million  

Environmental value 
 (non quantifiable) 

(a) ‘Best practices’ defined in accordance with methodology followed in the study (Task 8.1). 

(b) Recommendation on the appropriate sharing of the costs of mandatory surveillance 

between MS CAs and POs 

The analysis highlighted several cases where the costs of mandatory surveillance do not 
currently appear to be appropriately shared between MS CAs and POs. In particular, 
although mandatory fees are foreseen by the EU plant health regime for the cost recovery 
of the inspections and sampling/testing carried out by the MS CAs in the PZs, in several 
cases this provision is not being implemented and fees are only partly collected or not 
collected at all. This issue was also identified in the evaluation of the CPHR (FCEC, 
2010). There is therefore a need to reinforce the implementation of these provisions. 

8.3 Estimate the economic impact of mandatory de-listing of the selected PZs (a) 

immediately, or (b) after two years 

Eradication efforts are pursued in PZs for as long as it is economically, as well as 
technically, justified. During the eradication period (i.e. up to 2 years according to EU 
legislation) POs benefit from the continued status of a PZ, but also bear the higher costs 
of intensified inspections and eradication. The balance between these costs and benefits 

150 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
will determine the degree to which MS pursue their efforts to eradicate in order to 
maintain PZ status.  

(a)  In case of immediate revoking of PZ status, it is no longer possible to protect the 
area while engaging in an intensive eradication effort. Free trade immediately 
occurs, thereby potentially placing the area at higher risk and possibly reducing 
the potential to eradicate while increasing the cost of eradication. It can also be 
expected that surveillance will have to be intensified in this case, as the 
requirements on imported material can no longer be imposed. Therefore the 
impact is in all cases the immediate loss of the benefits from the protection that a 
PZ offers (as described above). On the other hand, there could be immediate 
benefits for non-PZ MS which today may have to maintain costly (i.e. intensified) 
inspection and eradication systems to export to the PZ, if these requirements no 
longer need to exist; 

(b) Delisting after 2 years offers certain advantages to an infested PZ under 

eradication, compared to immediate delisting in that: a) it allows the time that is 
technically considered necessary for the eradication programme to achieve its 
objectives; and, b) where the PZ faces difficulty in achieving the objectives of the 
eradication programme, it allows the possibility of a smooth transition of that PZ 
towards alternative measures for maintaining some protection of non-infested 
territories within the PZ, via the establishment of BZs.  

Task 9: costs of including in the EU plant health regime five Invasive Alien Species 
(IAS) plants 

The  objective  of  Task  9  has  been  to  estimate  in  global  terms,  the  costs  for  the  EU  of  
including  in  the  EU  plant  health  regime  five  IAS  plants  (weeds)118.  All  of  the  selected 
IAS  plants  have  a  high  probability  of  entry,  establishment  and  spread  in  the  EU27  and 
very significant potential impacts, as documented in the main literature119. 

By definition, the inclusion of any new HOs in the EU plant health regime will entail 
some costs for the EU and MS associated to the obligation to adopt management 
measures for their prevention, and in the event of introduction, for their control and 
eradication. While the general assumption has been that the IAS plants under review 
would be dealt with in the same way as currently regulated HOs (i.e. under Council 
Directive 2000/29/EC), ultimately the costs would depend on the specific measures to be 
followed. Such measures include control at import, surveillance, eradication and 
containment, as well as, where relevant, movement within the EU (PP system). The 
identification of the measures that would be most suitable for each of the examined IAS 
is an exercise beyond the scope of the study. Thus, in order to estimate costs, the FCEC 
has developed hypotheses on the measures that might be appropriate in each case, based 
on the information currently available in the reviewed literature and by means of expert 
consultation. It is also noted that, a priori, it is not clear at present whether any of the 

118  Polygonum  perfoliatum,  Pueraria  lobata,  Hydrocotyle  ranunculoides,  Eichhornia  crassipes  and 
Ambrosia artemisiifolia. The aim of this particular selection has been to cover the following key criteria: 
geographic  impact  and distribution of IAS plants  across  the  EU27  (north/south;  east/west);  presence and 
distribution  of  the  plants  within  EU,  i.e.  absent/locally  present/established  in  some  MS;  range  of  plants’ 
habitats (land/water); affected sectors (agriculture/environment).  

119  Including,  EPPO  PRAs  (available  for  Polygonum  perfoliatum,  Pueraria  lobata,  Hydrocotyle 
ranunculoides and Eichhornia crassipes) and, in the case of Ambrosia artemisiifolia, EUPHRESCO. 

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reviewed IAS would fulfil the eligibility criteria for co-financing under the EU solidarity 
budget120. 

From this analysis and extrapolations of each of the selected IAS plants, the following 
key conclusions can be drawn. 

For four of the selected IAS plants121, the main pathway appears to be intentional 
introduction through imports of ornamental plants. Consequently, EPPO recommends the 
prohibition of imports, sale, movement and planting (of Pueraria lobata, Hydrocotyle 
ranunculoides; Eichhornia crassipes) or controlled imports only (Polygonum 
perfoliatum). The implementation of the EPPO recommendations on imports would 
appear the simplest and most cost-effective control option that would be available under 
Directive 2000/29/EC; nonetheless, taking account of WTO-SPS obligations, similar 
restrictions would also apply to intra-EU movements and the obligation to eradicate and 
contain outbreaks. 

The absolute scale, as well as relative share, of the costs of prevention, control and 
management measures that could be pursued under Directive 2000/29/EC, will depend 
on the current status and distribution of each of the selected IAS plants. A distinction 
can be made between two groups: 

1.  For IAS plants absent (Polygonum perfoliatum) or largely absent (Pueraria 

lobata, Eichhornia crassipes) from the EU27, the potential costs will be mainly in 
terms of preventive action, including import controls and surveillance. These 
costs are generally expected to be significantly lower in order of magnitude than 
for the second group, as long as no new outbreaks of these IAS plants occur. On 
this basis, for these plants, the additional cost of general (preventive) 
surveillance is expected to be relatively moderate. This cost might become 
more significant if specific intensive surveillance in the context of control and 
eradication plans is to be required, indeed very significant the more infestations 
become widespread and the scale of the surveillance expands, but cannot be 
estimated with the information available. As an indication, the cost for more 
specific intensive surveillance of Pueraria lobata in forestry in the affected and 
high risk areas could be up to the estimated costs for the surveillance of 
Bursaphelenchus xylophilus in forestry (€656,000 ).  

The potential control and eradication costs for these pests in the event of pest 
introduction could be significant, as has been seen in the case of the control and 
eradication costs for Eichhornia crassipes, i.e. ca. €3 million  per year (according 
to documented cases in ES and the US; average annual expenditure over 3 years 
in ES and 10 years in the US). At EU level, therefore, the total cost is expected 
to be lower for this first group of pests (compared to the second group), as long 
as they are absent or largely absent from the EU122.  

120 This is particularly questionable for Ambrosia artemisiifolia, for which ‘natural’ (i.e. not man-assisted) 
spread is a significant risk factor; it could also be questioned for the other IAS as, by definition, all 
IAS plants owe their invasiveness to their intrinsic ability for natural spread. 

121 In particular, those currently absent (Polygonum perfoliatum) or largely absent from the EU (Pueraria 
lobata, Eichhornia crassipes), as well as for the more widely present Hydrocotyle ranunculoides. 
122  As  indicated  above,  it  is  also  noted  that  not  all  of  this  cost  is  expected  to  be  eligible  for  solidarity 
compensation  under  current  rules,  for  example  the  current  restrictions  for  outbreaks  due  to  natural 
spread. 

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2.  For IAS plants that are already widely present/distributed in the EU (Ambrosia 
artemisiifolia, Hydrocotyle ranunculoides), the total potential costs are likely to 
be significantly higher in order of magnitude than for the first group.  

In this case, the available evidence suggests that the cost of surveillance could be 
very significant, as this would certainly be required within control and 
eradication programmes. The cost could therefore approach the order of 
magnitude of HOs affecting the open environment, estimated under Task 1 at ca. 
€1.5 - €3 million  per pest per year123. 

Furthermore, the potential control and eradication costs for these pests could be 
very significant. As an indication, the control and eradication costs in the case of 
Hydrocolyte ranunculoides have been ranging from ca. €1 - €2 million 
per year (according to documented cases in BE, NL and the UK). Given the 
currently already widespread distribution of these IAS plants, this implies that at 
EU level, individual IAS plants may require €10 - €30 million  per year for 
eradication and containment. At EU level, therefore, the total cost is expected 
to be higher for this second group of pests (compared to the first group)124.  

per MS 

In conclusion, the introduction of mandatory requirements for the prevention and control 
of IAS plants within the EU plant health legislation may result in an increase in 
management costs across the EU as a whole. With the exception of Ambrosia 
artemisiifolia and Hydrocotyle ranunculoides, the total cost for the other selected IAS 
plants is expected to be relatively moderate, under the following two conditions: 

i.  This global assessment is made on the basis of the current known level of 

presence and distribution within the EU27 of these IAS plants. If the presence 
and distribution proves to be different than what is currently known from the 
available literature or any of these IAS plants becomes established and spreads, 
this would immediately affect the level of surveillance and control and 
eradication costs that might be incurred; 

ii.  EU-wide prohibitions of import/trade/planting of ornamental plants and/or 

susceptible material are introduced, in accordance with EPPO guidelines and 
recommendations, as this is assessed to be the main pathway for the introduction 
and/or further distribution of  Pueraria lobata, Hydrocotyle ranunculoides, 
Eichhornia crassipes and Polygonum perfoliatum in the EU27. 

In this sense, the estimates made here reflect the impact of known pest risk and action 
taken to avoid introduction or further spread, rather than hazard analysis which is 
effectively the worst case impact. However, if in future the above conditions change, and 
these IAS plants become more widespread, as for example Ambrosia artemisiifolia and 
Hydrocotyle ranunculoides below, then the surveillance and control/eradication costs 
likely to require funding under Directive 2000/29/EC could become very significant. 

123 This order of magnitude corresponds to earlier estimates  provided under the CPHR evaluation on the 
basis of data submitted by MS CAs, which had estimated that for the 10 HOs covered by emergency 
measures annual surveillance costs amounted at ca. €18.6 million i.e. on average ca. €1.86 million per 
HO. 

124  Again,  it  is  also  noted  that  not  all  of  this  cost  is  expected  to  be  eligible  for  solidarity  compensation 
under current rules, for example in the context of the current restrictions for outbreaks due to natural 
spread. 

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The case of Ambrosia artemisiifolia, and to a certain extent also that of Hydrocotyle 
ranunculoides, sets these apart from the other IAS plants examined here. Due to the 
wide distribution of these plants throughout the EU, the introduction of mandatory 
requirements for the control of these IAS plants under Directive 2000/29/EC could result 
in a very significant impact on the plant health budget. In any case, given their 
widespread distribution and the fact that natural spread is an important factor in their 
distribution, it is not clear at present which of the current measures available under the 
Directive would be applicable for the management of these IAS plants. It is therefore 
impossible with the information available to date to make a meaningful estimate of the 
global cost of including these IAS plants in the future EU PH regime125. For Ambrosia 
artemisiifolia, at present, prevention (through early detection and eradication) of new 
populations is considered the best measure for halting further spread, while full 
eradication is currently largely considered impossible126.  

125  The  likely  impact  of  the  various  management  options  for  the  control  of  Ambrosia  artemisiifolia  is 
expected to become clearer after the completion of a study recently launched by DG ENV which aims 
to assess the epidemiology, effects and control costs of this pest in the EU27.  

126  Guidelines  for  management  of  common  ragweed,  Ambrosia  artemisiifolia  -  Results  of  the 
EUPHRESCO  project  Strategies  for  Ambrosia  control  2008-2009.  See  also  EPPO  datasheet  and  PL 
PRA 2001. 

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