The Potential Differential Effects of Stricter EU False Coddling Moth Controls on African Exports

Summary
Controlling false coddling moth infestations in the face of stricter EU controls will be a major challenge for African fruit and vegetable exporters, with different countries having very different systems in place for controlling infestations in exported product. South Africa’s sophisticated ‘electronic compliance database’ Phytclean could potentially hold important lessons as national SPS authorities across the Africa seek to get to grips with stricter EU controls. This is potentially an important area for pan-African technical cooperation which would supplement existing EU support programmes to strengthen SPS control capacities implemented through such programmes as COLEACP.

Since 1st January 2018 False Coddling Moth (Thaumatotibia leucotreta) has become a regulated pest in the EU.  Inspectors in EU member states are now ‘obliged to report on the pest if it was detected’. Excessive interceptions will lead initially to discussions on the measures necessary to eliminate infestations, with trade being blocked if adequate measures cannot be set in place to halt the export of contaminated consignments.

Across a range of fruit and vegetable products a big issuing facing African exporters in 2018 will be the effects of new stricter EU regulations on the control of False Coddling Moth infestations on imports into the EU (for background information see companion article ‘Lifting of EU Ban May Provide Little Relief for Ghanaian Vegetable Exporters’, 16 November 2017). Not all African fruit and vegetable product exporters will be equally well placed to meet the new regulatory challenge (2).

In the face of progressively stricter EU controls on Citrus Black Spot infections countries such as South Africa have developed ‘an electronic compliance database’ for disease and pest controls called Phytclean. This has been developed jointly through cooperation between South Africa’s highly organised citrus industry and the Department of Agriculture, Forestry and Fisheries (DAFF). The operation of the system has now become part of the official function of the DAFF. After its successful trial in the citrus sector the system has been extended to the entire horticulture industry and may even be ‘adopted for agriculture and floriculture as well’ (2).

This successful electronic compliance database allows officials to immediately identify which farmers are following the required systems of disease and pest controls.  The utilisation of the system is now being extended to controlling infestations of false coddling moth in products destined for export the EU market. A False Coddling Moth management system has been designed and set in place which ‘relies on a range of different activities on the farm, inspections and control sprays’, with in some regions this extending to the use of ‘sterile insect technology’. It was highlighted how South Africa has ‘a whole lot of different mechanisms for eradicating the pest before the fruit even gets into the pack house’ (2).

Individual growers can choose different options but have to prove to the DAFF that they have followed required measures ‘with registered results and evidence stored and updated within the Phytclean system’. Compliance can then be checked by DAFF officials before issuing export authorisations (2).

It is against this background of an effective management system for controlling citrus black spot infections, that the South African industry is confident it is well placed to minimise if not eliminate incidences of FCM infestations in consignments destined for export to the EU (2).

This being noted the effective implementation of pest control management systems hinges around effective enforcement of compliance at all levels, a hard reality revealed by the trend in CBS interceptions on South Africa citrus exports to the EU at the end of the 2017 season (see box) (2).

The Unfortunate Rise in End of Season CBS Interceptions Highlights Need for Constant Effective Enforcement of Controls

2017 saw a record crop in the South African citrus sector as new plantings over the last ten years came on-stream. However despite innovations in growing and post-harvest handling practices aimed at establishing zero tolerance for citrus black spot infections in exported consignments, 2017 saw some slippage in the effectiveness of South African bio-security controls towards the end of the season. This gave rise to an increase in EU interceptions of CBS infected fruit from 4 to 23 (with fully 17 of these interceptions occurring in fruit exported in a 2 to 3 week period at the end of September and the beginning of October).

Justin Chadwick of the Citrus Growers Association of Southern Africa maintained the unfortunate increase was a result of unusual market circumstances, as Brazil exited the EU market early and left market opportunities for end of season exports.  It was this unexpected trade at the end of the season (end of September and the beginning of October) when the incidence of CBS infections is more likely, which gave rise to fully 17 of 23 EU interceptions. However the situation has now been addressed through a strengthening of inspection requirements including ‘additional field inspections for product leaving in September and October’.

This has given rise to a situation where Spain’s Valencian Farmers Association (AVA-ASAJA) has ‘accused Brussels of being “complicit” with South Africa in seriously threatening the interests of European citrus growers’. AVA-ASAJA claimed ‘the attitude of South African exporters and the European Commission is simply unacceptable as a mockery and a total joke’. Cope-Cogeca supported AVA-ASAJA’s claims there had been a ‘deterioration in phytosanitary security’ as a result of the EC’s failure to enforce a cold treatment requirement for imports of South African citrus.

However controlling false coddling moth infestation is seen as being a far more challenging task in other African countries.  These range from Ghana and Senegal in West Africa through Cameroon in Central Africa to Kenya and Uganda in East Africa (1). In countries such as Ghana initiatives are already underway to strengthen national SPS control systems with the support of COLEACP and other programmes financed bilaterally by EU member states (see companion article, ‘Implications of Improving Phytosanitary Control Systems for the Attainment of SDGs’, 25 January 2018).

In January and February 2018 no less than 55 interceptions of FCM infestations were recorded on the Europhyt data base on imports from 7 Eastern and Southern Africa countries, mainly affecting exports of Roses (38 interceptions), carnations (1 interception) soursop (1 interception) and paprika (15 interceptions) (3,4). The corresponding figure for January to February 2017 was 15 interceptions (5,6). No interceptions of FCM were recorded on imports from South Africa or Ghana in 2018.

EU False Coddling Moth Interception on Imports into the EU in January 2018 and for the whole of 2017

January & February 2018 (3,4) Total 2017 (7)
Country Product Total FCM interception Product Total FCM interception
Kenya Roses (10); Carnations (1); Paprika (1) 12 Paprika (17) 17
Tanzania Roses (12); Paprika (1) 13 0
Uganda Roses (7); Paprika (9) soursop (1) 17 Paprika (75) 75
Zimbabwe Roses (7); Paprika (1) 8 Citrus (9); Paprika (10) 19
Mozambique Paprika (1) 1 Paprika (8) 8
South Africa 0 Citrus (10) Paprika (2) 12
Zambia Roses (2) 2 Paprika (3) 3
Ivory Coast 0 Paprika (2) 2
Nigeria 0 Paprika (2) 2
Rwanda Paprika (2) 2 Paprika (2) 2
Cameroon 0 Paprika (1) 1
Ghana 0 Soursop (1) 1
Senegal 0 Soursop (1) 1
Togo 0 Paprika (1) 1
Swaziland 0 Citrus (1) 1
Sub-Total 55   145

Source: Europhyt

Comment and Analysis
The 55 interceptions for false coddling moth in exports from 7 sub-Saharan African countries in January and February 2018 compares to 15 in the corresponding period in 2017 (from 6 sub-Saharan African countries) and 145 interceptions across 15 sub-Saharan African countries in the whole of 2017.As a result of the introduction of compulsory reporting requirements interceptions were over 3 ½ times higher than in January and February 2017.  This heightens the risk of the introduction of EU bans on imports of roses, paprika, carnations and soursop from countries which cannot get FCM infestation under control for products destined for EU markets.

All in all exports from ACP countries of products where FCM interceptions were reported in 2017, had a total value of almost €1,231 million in 2017.  Elements of this trade are potentially at risk, should repeated interceptions and the failure to effectively implement control measures lead to EU bans on imports of the affected products.

However some 57% of these exports originate in South Africa, with these being almost exclusively citrus fruit. Given the progress being made in designing and implementing FCM control programmes in South Africa and the establishment of a computer based data monitoring system to support verification of compliance with the necessary controls, the citrus industry in South Africa is optimistic that it can avoid any trade disruption as a result of stricter EU FCM controls.

Value of Trade in  Exports to the EU in the Main Products Affected by FCM € (2017)

Country Roses (060311) Carnations (060312) Paprika (0709) Citrus (0805
Kenya 379,174,725 13,362,940 24,442,393 18,363
Tanzania 5,261,750 1,354 203,642 58,923
Uganda 26,983,958 12 1,801,749 6,848
Zimbabwe 1,325,287 412,651 28,352,941
Mozambique 3 5,035,598 1,238
South Africa 28,300 1,011 14,477,471 685,715,802
Zambia 11,019,292 412,651 1,234
Ivory Coast 225 23 786,870 274
Nigeria 73 5 51,265 1,198
Rwanda 2,066,731 143,905
Cameroon 39 4 1,006,877 2,687
Ghana 464 47 1,705,142 93,527
Senegal 200 24 20,743,950 526
Togo 18 2 1,801,749 46
Swaziland 25 2 39 4,305,094
Sub-Total 425,861,090 13,366,424 73,025,952 718;558,701

However this still leaves €531 million of trade potentially facing disruption if the countries concerned cannot get FCM infestations on products destined for the EU market under control.

After South Africa, Kenya is the most commercially exposed ACP country with a total trade of €417 million potentially exposed. However given the incidence of interceptions in both 2017 and the first two months of 2018, it is neighbouring Uganda which potentially faces the gravest threat of trade disruption, with Uganda’s trade in products potentially affected totalling €28.8 million potentially being affected. This represents only 6.8% of Uganda’s agri-food exports to the EU, but fully 29.3% of Uganda’s non-coffee agri-food exports to the EU in 2017.

The stricter FCM controls are also a matter of concern in:

· Zimbabwe (potentially affected trade €30 million, equivalent to 14.7% of Zimbabwean agri-food exports in 2017 but fully 33% of Zimbabwe’s non-tobacco agri-food exports to the EU);

· Senegal (potentially affected trade €20.7 million, equivalent to 16.5 of Senegal’s agri-food exports to the EU in 2017);

· Zambia (potentially affected trade €11.4 million, equivalent to 20.1% of Zambia’s agri-food exports to the EU in 2017 but fully 46.3% of Zambia’s non-tobacco agri-food exports to the EU in 2017);

· Rwanda (potentially affected trade €2.2 million, equivalent to 5.7% of Rwandan agri-food exports to the EU in 2017 but fully 96% of Rwanda’s  non-coffee agri-food exports to the EU);

· Swaziland (potentially affected trade €4.3 million, equivalent to 6.3% of Swazi agri-food exports to the EU in 2017 but fully 32.8% of Swazi non-sugar agri-food exports to the EU in 2017.

Stricter EU FCM controls would appear to be a less important area of concern in Tanzania, where potentially only  €5.5 million in exports could be affected, a value equivalent to only 2% of Tanzania’s agri-food exports to the EU in 2017 and 4% of Tanzania’s non-tobacco agri-food exports.

Similarly in Mozambique controlling FCM infestations would appear to be of limited interest, given it would affect only €5 million in exports, the equivalent of only 2.8% of Mozambique’s agri-food exports to the EU in 2017 and some 10% of Mozambique’s non-tobacco agri-food exports to the EU.

In Ghana  a trade valued of products of only €1.8 million would be affected by an import  ban as a result of FCM infestations, with this being  equivalent to a mere 0.14% of Ghana’s agri-food exports to the EU  in 2017 and only 0.87% of Ghana’s non-cocoa agri-food exports to the EU. Nevertheless efforts are being devoted to containing FCM infestation as part of efforts to promote non-cocoa agri-food sectors in Ghana.

Against this background there would appear to be scope in Southern and Eastern Africa for collaboration in establishing ng effective computer based compliance verification systems based on the South African Phytclean scheme. However proprietary fees and technical assistance costs would probably need to be borne by external donors, alongside investment in strengthening national SPS control authorities, so they can effectively run such computerised compliance verification systems.

Source:
(1) producebusinessuk.com, ‘False Codling Moth to become EU regulated pest from 2018’, 22 August 2017
http://www.producebusinessuk.com/insight/insight-stories/2017/08/22/false-codling-moth-to-become-eu-regulated-pest-from-2018
(2) Freshfruitportal.com, ‘South Africa in line for record citrus crop’, 15 February, 2018
https://www.freshfruitportal.com/news/2018/02/15/south-africa-line-record-citrus-crop
(3) Europhyt, ‘Interceptions of commodities imported into the EU or Switzerland with harmful organism(s): January 2018’, 1 February 2018
https://ec.europa.eu/food/sites/food/files/plant/docs/ph_biosec_europhyt-interceptions-2018-01.pdf
(4) Europhyt, ‘Interceptions of commodities imported into the EU or Switzerland with harmful organism(s): February 2018’, 1 March 2018
https://ec.europa.eu/food/sites/food/files/plant/docs/ph_biosec_europhyt-interceptions-2018-02.pdf
(5) Europhyt, ‘Interceptions of commodities imported into the EU or Switzerland with harmful organism(s): January 2017’, 1 February 2017
https://ec.europa.eu/food/sites/food/files/plant/docs/ph_biosec_europhyt-interceptions-2017-02.pdf
(6) Europhyt, ‘Interceptions of commodities imported into the EU or Switzerland with harmful organism(s): February 2017’, 1 March 2017
https://ec.europa.eu/food/sites/food/files/plant/docs/ph_biosec_europhyt-interceptions-2017-01.pdf
(7) Europhyt, ‘Interceptions of harmful organisms in commodities imported into the EU Member States and Switzerland: 2017, 3 January 2018
https://ec.europa.eu/food/sites/food/files/plant/docs/ph_biosec_europhyt-interceptions-2017_summary.pdf