While the EU Delegation in Ghana has heralded the scheduled lifting of the EU ban on imports of specified vegetable from Ghana on 1st January 2018, the trade benefits of this measure could be undermined by the stricter SPS control requirements on False Coddling Moth scheduled to be introduced by the EU from 1st January 2018. This could potentially place a significant additional administrative burden on the competent authority to verify compliance with EU requirements, with any failure to satisfy stricter EU requirements leading to market closure. This is an issue not only for Ghana but 20 other ACP countries engaged in exporting capsicum and pimento to the EU. How the situation evolves in regard to ACP exports of capsicum and pimento in 2018 will provide a concrete example of the kind of impact which stricter EU Plant Health Regulation requirements are likely to have on a range of ACP fresh plant exports to the EU.
At the end of October 2017 the EC announced the current ban on imports of five plant products from Ghana (chilli pepper, bottle gourds, luffa gourds, bitter gourds and eggplants) would be lifted form the 1st January 2018. This followed an EU inspection visit in September 2017. The lifting of this ban was attributed to the ‘significant corrective measures to improve the inspection and control system for plant health at exit points’ undertaken by the Ghanaian competent authority since the introduction of the ban in October 2015 and the ‘evolution of the numbers of import interceptions with quarantine pests notified by Member States for commodities not subject to the ban’ (1).
Press reports indicate farmers in eastern Ghana have been particular affected by the EU ban, with lower farms earnings and retrenchment of farm labourers since the introduction of the ban. The retrenchments are seen fuelling rural urban migration pressures (5)
Farmers have become frustrated at the slow pace of progress in securing the bans removal, given the earlier profitability of chilli pepper exports. A particular point of concern is the suggestion form some agro-food sector consultants in regard to the ‘inadequate resources for government regulatory agencies that are supposed to help ensure effective monitoring of the food production chain’ (5).
However the EC has also indicated Ghanaian exporters would still ‘have to fulfil the EU phytosanitary legislation to ensure the freedom of quarantine pests’ (1). This latter qualification is important since on 15 July 2017, the European Commission published Implementing Directive 2017/1279, which sets out new control measures for ‘four new quarantine pests, including False Coddling Moth’ (FCM), which affects Ghanaian chilli pepper production.
Chilli pepper was one of the five products where the Ghanaian import ban is scheduled to be lifted on the 1st January 2018; the same data at which stricter control measures for quarantine pests like False Coddling Moth are scheduled to be implemented. As a consequence before the 1st January 2018, the national competent authority will need to ensure effective FCM control measures are in place which fully meets EU requirements (2).
According to COLEACP this will require the competent authority in Ghana to ‘collect pest data to evidence the effectiveness of control methods being used by growers’ and ‘compile a dossier on the methods used, and data on its effectiveness’. This will then need to be submitted to the EU, with an EU committee of experts assessing and approving the measures in place, if exports are to continue to be allowed after 1st January 2018. Should no data be submitted before the 1st January deadline or the data submitted be incomplete, exports of chilli pepper to the EU from Ghana will be banned (2).
According to COLEACP ‘no guidance has been provided by the European authorities on the treatments that are likely to be acceptable’. The only reference made in the EU directive is to the use of cold treatment. However according to COLEACP it is unclear if this is suitable for chilli pepper and what the quality and shelf life consequences would be of such treatments. Against this background COLEACP is organizing trials to investigate the impact of cold treatment on the commercial value of chilli pepper exports (2).
Currently False Coddling Moth control methods in Ghana focus on inspections and identification of infected products and their withdrawal from export supply chains. In Ghana COLEACP has advocated a 6 step programme. This consists of:
- the registering of all growers with the Ministry of Agriculture;
- grower level field monitoring for FCM infestations, with full record keeping of inspections carried out;
- official on-farm inspections with even a single example of infestation leading to the withdrawal of production from EU export supply chains;
- strict segregation of consignments during transportation;
- consignment by consignment inspections for FCM in pack houses and withdrawal of consignments from EU export supply chains should a single example of infestation be detected;
- official inspections at the airport, with SPS certificates only being issued if there are zero infestations in consignments (3).
|Comment and Analysis
The impact of the increasingly strict EU SPS standard and the Oct 2015 EU import ban can be seen in the data on Ghanaian exports of capsicum and pimento (CN 070960) to the EU since 2007. This shows that despite the conclusion of an IEPA between Ghana and the EU which eliminated any residual tariffs applied, Ghanaian exports in both volume and value peaked in 2007. Subsequently export volumes fluctuated between 1,451 tonnes and 2,744 tonnes, on a generally downward trend until 2014, when export volumes increased. In 2015 however export volumes collapsed, with only minimal exports to the EU (11 tonnes) recorded in 2016. This export trade has always been heavily concentrated on the UK, with the UK’s share of imports into the EU from Ghana never falling below 96% prior to the introduction of the ban.
Ghanaian exports to the EU of Capsicum and Pimento under tariff 070960 (tonnes / Euro)
Source: EC Market Access Data Base
In addition to Ghana some 20 other ACP countries export capsicum and pimento to the EU, including 5 Caribbean countries. Of these 20 countries in 2016: 5 exported less than 10 tonnes; 6 exported between 10 and 50 tonnes, 1 exported between 50 and 100 tonnes, 6 exported over 100 tonnes but less than 600 tonnes, while 2 exported between 1000 and 2,000 tonnes (Kenya – 1,025 tonnes and Uganda – 1,771 tonnes). This needs to be seen in a context where the EU imports 232,889 tonnes of capsicum and pimento from beyond its borders, with the main suppliers being Morocco (43%), Turkey (29%), Israel (10%) and Macedonia (7%).
The introduction of the new EU controls on False Coddling Moth highlight how even before the full entry into force of the new EU Plant Health Regulation scheduled for 13 December 2019, more stringent SPS controls are being introduced.
The absence of clear guidance on treatments which would be acceptable to the EU suggest that small scale exporters and small holder growers could find themselves excluded from EU export supply chains, since they have little capacity to invest in additional control measures, and what is potentially more important little capacity to carry the financial losses which the withdrawal from the export market or destruction of even a single consignment could represent.
All but 2 ACP exporting countries can be described as very small scale exporters, while even the largest ACP supplier accounts for only 0.4% and 0.8% of total extra-EU imports, with a value of trade between €3.3 million and €5 million in 2016. Against this background the costs of additional controls and documentation could come constitute an excessive burden for most ACP exporters of capsicum and pimento to the EU.
Controlling False Coddling Moth so that exports to the EU can take place has been complicated by increasingly strict EU minimum pesticide residue levels (4). While FCM infestations may be prevented by the application of pesticides, excessive residue levels on delivery to the EU can also lead to market closure. This is a particular problem for production of capsicum and pimento given the regular harvesting which takes place.
Against this background it should be noted that as part of the EU pesticide review, within the EU, implementation of specific aspects of the regulation have in the past been deferred where there was no viable alternative treatment option available. However given the range of plant matter which FCM infestations can affect, there would appear to be little scope for flexibility in the application of the new stricter EU controls.
Against this background, despite the Ghanaian authorities having ‘taken significant corrective measures to improve the inspection and control system’, this may not prove sufficient for the export trade to resume, given the introduction of new stricter SPS controls on imports of plant products into the EU.
In certain ACP countries awareness programmes for growers in combatting False Codding Moth are being rolled out (e.g. in Ghana and in the South African citrus sector). There is potentially scope for knowledge transfer across ACP countries on the effectiveness of various programmes for combatting FCM (see companion article, ‘Pre-emptive export restrictions introduced on South African citrus exports to EU’, 9 November 2017). This is potentially an area where the ACP Secretariat, COLEACP or CTA could play a role in facilitating information sharing.
(1) muyjoyonline.com, ‘EU removes ban on Ghanaian vegetables’, 8 November 2017
(2) COLEACP, ‘Important amendment to EU Plant Health Regulations affecting exports of chillies and pepper (Capsicum), 26 October 2017
(3) COLEACP/PIP Handbook on ‘Managing False Coddling Moth in Ghana’
(4) COLEACP/PIP, ‘Technical notes for the coaching sessions for pepper growers in Ghana on False Codling Moth, Thaumatotibia leucotreta.’
(5) Myjoyonline.com, ‘Farmers Struggle Over Ban On Vegetable Export’, 11 October 2017
|Key words: SPS, Horticulture, COLEACP
Area for Posting: SPS, Horticulture, West Africa