Summary
The development of a systems based approach to pest and disease control for CBS is yielding benefits in terms of South African controls of False Codling Moth (FCM). EU FCM interceptions on imports from South Africa were down in 2018, with a far lower level of interceptions than other ACP exporters despite South Africa’s far higher volume of exports to the EU of potentially infected products. Calls for a ‘white list’ approach to FCM related import controls if adopted by the EU could free up scarce pest control resources for deployment in the most vulnerable areas. However development assistance support will be required to ensure small scale producers are not commercially disadvantaged by any moves over to a ‘white list’ approach. Given South Africa’s successful experience there would appear to be scope for the sharing of best pest-control practices across ACP exporters of vulnerable products.
Representatives of the Citrus Growers Association (CGA) of South African have suggested that the experience of phytosanitary risk mitigation in response to stricter EU Citrus Black Spot controls has left the sector better placed to respond to the new challenge arising from stricter EU controls on False Codling Moth (FCM). From 1st January 2018 FCM was defined by the EU as a ‘quarantine pest’ requiring stricter SPS compliance for imports to the EU to take place (1).
In 2018 the first year of interception of FCM as a listed quarantine pest saw 204 interceptions of FCM infested imports to the EU from across the globe. For cut flowers over the course of the year interceptions gradually decline while there were growing levels of interceptions for capsicum (bell peppers). This occurred largely in ‘countries using the options of place of production free or effective treatment’ as the basis for claiming FCM free status. The EC took this to suggest serious problems ‘in the certification system of the exporting country’ (see companion epamonitoring.net article, ‘Increased Levels of Pest Interception in Uganda Leads to Pre-Emptive Export Ban, 27 May 2019) (2).
Under the new EU FCM quarantine pest requirements ‘all fruit must either be sourced from an FCM-free area or must be subjected to an effective treatment to ensure that it’s free of FCM’ (4). The EC is launching consultations with the governments of the countries concerned with further EU level discussions being required before any decisions on remedial action (e.g. import restrictions) are taken (2).
EU False Codling Moth Interceptions from ACP Countries 1 January 2018 until 31st December 2018
| Country | Product | Interceptions by Product |
| Uganda | Bell pepper (Capciscum) | 43 |
| Roses (Rosa) | 9 | |
| Kenya | Roses (Rosa) | 40 |
| Bell pepper (Capciscum) | 11 | |
| Baby’s-breath cut flower (Gypsophilia) | 5 | |
| Tanzania | Roses (Rosa) | 34 |
| South Africa | Citrus (citrus) | 12 |
| Ghana | Bell pepper (Capciscum) | 12 |
| Zimbabwe | Roses (Rosa) | 16 |
| Rwanda | Bell pepper (Capciscum) | 6 |
Source: EC, ‘Phytosanitary alert list for commodities entering territory covered by the Common EU Plant Health Regime – based on EUROPHYT – Interceptions data, 1 January 2018-31st December 2018
https://ec.europa.eu/food/sites/food/files/plant/docs/ph_biosec_trade-non-eu_alert-list_201801-201812.pdf
Subsequent to the decision to launch these consultations in February 2019 further reports submitted to the EC revealed a total of 9 interceptions of false codling moth from 10 January to 15 February 2019:
- 3 on Roses, 2 of which came from Kenya and 1 from Tanzania:
- five interceptions on peppers (5) with 2 each originating in Mozambique and Uganda and 1 from Zimbabwe;
- 1 on Annona muricata (Soursop) from Uganda (3).
It is against this background that South Africa has enjoyed major success in controlling FCM infestations in products exported to the EU, with according to the Citrus growers Association of Southern Africa ‘just nine FCM interceptions during the 2018 citrus season’ (4) on an export volume of 750,000 tonnes (EC figures put the number of interceptions for the whole of 2018 at 12 (5)). The number of FCM interceptions on exports from South Africa was down from 61 interceptions recorded by official and unofficial sources in 2017 (4).
The effectiveness of South African pest control measures compares favourably to other ACP exporters, with 34 interceptions reported on exports form Tanzania, 52 on exports from Uganda and 56 interceptions from Kenya, with all of these countries involved in a far lower volume of trade than South Africa (5).
According to Deon Joubert of the CGA, South Africa has ‘virtually disappeared to the back of the queue as a defaulter’ when it comes to FCM infestations. However it was highlighted how the work required to get South African exporters into this position was ‘massive’ (1).
Deon Joubert called on the EU to recognise the achievement of the South African industry by moving over to a ‘white list’ approach which would provide ‘fast track access’ for successful suppliers and importers who have never experienced any interceptions. This it was held would ‘motivate everyone to manage zero interceptions themselves’, while also freeing up resources to ‘manage and assist the few supply lines who do experience challenges and fix those’ (1).
| Comment and Analysis
The lower level of FCM infestations detected in South African citrus exports is largely attributable to the ‘farming systems’ approach adopted to control a variety of pests and infections. Initiatives introduced to control citrus black spot are now yielding rewards in terms of the effectiveness of FCM control measures (see epamonitoring.net article, ‘The Potential Differential Effects of Stricter EU False Coddling Moth Controls on African Exports’, 19 March 2019). Other African fruit and vegetable exporters however face more problems in effectively controlling FCM in line with increasingly strict EU requirements. While lessons can potentially be learnt from this South African experience the issue of the unit cost of effective controls arises for smaller ACP exporters of products vulnerable to FCM infestation. Against this background the proposal of the Citrus Growers Association for the establishment of a ‘white list’ approach to the implementation of FCM controls would provide exporters with an additional commercial incentive to invest in effective FCM controls, since it would reduce costs in the market entry component of the supply chain. Such a ‘white list’ approach would also allow limited national control capacities to be deployed in those areas where effective controls are most needed. However it needs to be recognised that unless targeted support programmes for smaller scale producers are set in place, such a ‘white list’ approach would serve to strengthen the commercial position of large scale producer/exporters. This suggests any moves towards more targeted FCM control arrangements will need to be accompanied by complementary development finance supported capacity building programmes for associations of smaller scale exporters. Ensuring commercial advantages follow on from effective pest controls, linked to reduced levels of inspection and hence market entry inspection costs, would be an important means of incentivising collective initiatives by associations of smaller scale producer/exporters. Based on the South African experience of adopting a systems based approach to pest and infection control there would appear to be scope for the sharing of best pest control practices across ACP exporters of vulnerable products. |
Source:
(1) freshplaza.com, ‘European Commission is not hostile to trade with South Africa’, 4 April 2019
https://www.freshplaza.com/article/9090322/citrus-summit-european-commission-is-not-hostile-to-trade-with-south-africa/
(2) EC, ‘Summary report of the Standing Committee on Plants, Animals, Food and Feed held in Brussels on 21-22 January 2019’
https://ec.europa.eu/food/sites/food/files/plant/docs/sc_plant-health_20190121_sum.pdf
(3) EC, ‘Summary report of the Standing Committee on Plants, Animals, Food and Feed held in Brussels on 21-22 February 2019
https://ec.europa.eu/food/sites/food/files/plant/docs/sc_plant-health_20190221_sum.pd
(4) ftwonline.co.za , ‘South Africa slashes false codling moth occurrences’, 12 December 2018
https://www.freshplaza.com/article/9053187/south-africa-slashes-false-codling-moth-occurrences/
(5) EC, ‘Phytosanitary alert list for commodities entering territory covered by the Common EU Plant Health Regime – based on EUROPHYT – Interceptions data, 1 January 2018-31st December 2018
https://ec.europa.eu/food/sites/food/files/plant/docs/ph_biosec_trade-non-eu_alert-list_201801-201812.pdf