Summary
COLEACP is offering support to ACP producers of chillies and pepper in getting to grips with new EU documentation requirements related to effective treatment against False Codling Moth infestations. While such initiatives are welcome the increasing commercial costs of compliance is likely to progressively squeeze smaller scale producers out of EU market supply chains. This is likely to be compounded by the ongoing EU review of the acceptable minimum residue levels for pesticides applied to a range of fruit and vegetable imports.
In May 2019 COLEACP warned ACP exporters of chillies and pepper of the implications of the new EU implementing directive dealing with treatments applied against False Codling Moth infestations. To secure approval for export to the EU the new directive requires ACP authorities to submit a dossier which not only describes the treatments which are being applied to control False Codling Moth infestations in line with the allowed practices stipulated in the implementing directive but requires evidence of the effectiveness of the treatment programmes being pursued. Submission and approval of these more comprehensive dossiers will need to occur before the 13th December 2019, when the EU’s new Plant Health Regulation comes fully into effect, if access for exports of chillies, peppers and other affected products to the EU market is to continue to be allowed (1).
In the interim the EU is more rigorously enforcing existing rules, with special measures have already been introduced for ‘a number of imported crops where there have been high numbers of notifications due to quarantine pests’ (1). COLEACP highlights how ‘for capsicum, emergency measures were first issued in 2017 under Regulation (EU) 2017/1279’, with ‘a new implementing directive (EU) 2019/523’ being issued in March 2019 with this ‘containing some important amendments to the original measures’ (1).
Under the new rules there are four possible options for dealing with False Codling Moth. Two of these options require the creation of FCM free countries or zones; neither of which is deemed to be practical options for ACP exporters (1).
According to COLEACP ‘Option 3 requires a place of production designated as free from false codling moth (1). Some ACP countries have adopted this option by ‘using screen houses combined with a series of inspections by the NPPO at the production site, conducted according to procedures specified in the directive’. However producers in most of the affected ACP countries have gone for the fourth option in their efforts to maintain access to the EU market. This allows chillies and peppers to be imported into the EU if they have been ‘subjected to an effective treatment to ensure the produce is free from the pest’ (1). It is the effectiveness of measures pursued under this option which ACP exporters now need to provide documentary evidence on.
Under option 4 of the new regulation issued in March 2019 (2019/523) Capsicum imported into the EU must ‘have been subjected to an effective cold treatment to ensure freedom from Thaumatotibia leucotreta (Meyrick) or another effective treatment to ensure freedom from Thaumatotibia leucotreta (Meyrick) and the treatment data should be indicated on the certificates’ referred to in the implementing directive. Evidence of the effectiveness of the treatments applied must be ‘communicated in advance in writing by the national plant protection organisation of the third country concerned to the Commission’ (1).
COLEACP has a programme in place to assist ACP chilli and pepper exporters in developing and resubmitting these more comprehensive dossiers under its Fit for Market programme. Requests for support from ACP national authorities or concerned industry organisations can be sent to: support@coleacp.org (1).
In a not unrelated development, in May 2019 the EU ‘published 5 changes to regulations regarding pesticide residues’, all of which will be actively applied by mid-August 2019. These ‘include reductions and elevations of the Maximum Residue Levels (MRLs) for different products’. The regulations which will come into force are set out below:
- ‘Regulation EU 2019/88 is an amendment to Annex II to Regulation EU 396/2005, and describes a change in the maximum residue levels of acetamipirid …this regulation becomes active on August 13, 2019’.
- Regulation EU 2019/89 is an amendment to Annexes II, III and V of Regulation EU 396/2005, describes a change in the maximum residue levels of bromadiolone, etofenprox, paclobutrazole and penconazole ….this regulation becomes active on August 13, 2019’.
- ‘Regulation EU 2019/90 is an amendment to Annexes II, III and V of Regulation EU 396/2005 and describes a change in the maximum residue levels of bromuconazole, carboxin, fenbutatin oxide, fenpyrazamine and pyridaben….. This regulation becomes active on August 13, 2019’.
- ‘Regulation EU 2019/91 is an amendment to Annexes II, III and V of Regulation EU 396/2005, and describes a change in the maximum residue levels of buprofezin, diflubenzuron, ethoxysulfuron, ioxynil, molinate, picoxystrobin and tepraloxydim….this regulation becomes active on August 13, 2019’.
- ‘Regulation EU 2019/552 is an amendment to Annexes II and III of Regulation EU 396/2005, and describes a change in the maximum residue levels for azoxystrobin, bicyclopyrone, chlormequat, cyprodinil, diphenoconazole, fenpropimorph, fenpyroximate, fluopyram, fosetyl, isothiolone, isopyrazam, oxamyl, prothioconazole, spinetoram, trifloxystrobin, and triflumezopyrim’. This regulation came into effect on 25th April 2019 (2).
| Comment and Analysis
While the issue of the treatment of imported fruit and vegetable products to prevent the introduction of new pest infestations in the EU cannot be divorced from the effects of climate change, equally this issue cannot be divorced from the growing commercial pressure from EU agricultural producers to reduce competition from 3rd country suppliers. These commercial pressures on the EC to apply stricter SPS controls increased following the trade disruptions arising from the August 2014 Russian import embargo and are likely to further increase in the event of a ‘no-deal’ Brexit, given the UK takes far larger volume of Spanish exports than the Russian market ever did (for example Spanish citrus export volumes to the UK in recent years were nearly 5 times the volumes exported to Russia in 2013, the last full year before the import ban) (3 & 4). While the actions of bodies like COLEACP can help ACP exporters meet EU control requirements, as the South African experiences around EU Citrus Black Spot controls highlights, this can be achieved only at considerable expense to the ACP producers concerned (see companion epamonitoring.net article ‘South Africa to Take EU to WTO Dispute Settlement over Citrus Black Spot Controls’, 8 April 2019). This is likely to push smaller scale producers out of export supply chains serving EU markets and increase the role of supply chains controlled by EU agro-food sector multinationals. Such EU agro-food sector multinationals are generally better placed to ensure EU mandated pest control and treatment protocols are respected. This squeezing out of small scale suppliers is more likely to be the case given the on-going nature of the EU pesticides review, which is consistently reducing the minimum detection levels for pesticide residues. Staying abreast of developments in this area can prove particularly difficult for small scale producers. In this context even if small scale producers can eliminate pest infestations and thereby retain access to EU markets, they may find their access to the EU market blocked because of unacceptable levels of pesticide residues on products despatched to the EU market. |
Source:
(1) coleacp.org, ‘Important message to competent authorities and operators in the capsicum sector chillies and peppers’, 22 May 2019
https://www.coleacp.org/en/important-message-to-competent-authorities-and-operators-in-the-capsicum-sector-chillies-and-peppers
(2) agrocontrol.nl, ‘MRL changes in EU legislation on pesticide residues’, 23 May 2019
https://www.hortidaily.com/article/9106577/mrl-changes-in-eu-legislation-on-pesticide-residues/
(3) EC, ‘Market Access Data Base’
https://madb.europa.eu/madb/statistical_form.htm
(4) freshplaza.com, ‘Spain: Citrus exporters, preparing for post-Brexit market’, 6 September 2018
https://www.freshplaza.com/article/2200917/spain-citrus-exporters-preparing-for-post-brexit-market/