Ghanaian Pre-emptive Export Ban on Chilli Peppers, Aubergines and other Leafy Vegetables May Be Just the Beginning
Summary
In the face of increasingly strict EU SPS implementing regulations the Ghanaian government has introduced a pre-emptive export ban on leafy vegetables. A comprehensive system based approach to pest controls is urgently needed in Ghana, with the South African Phytclean electronic compliance database scheme potentially offering a model for private sector initiatives and private/public sector partnership. Initiating a dialogue with the UK authorities in the context of on-going Continuity Agreement negotiations, on future UK SPS controls, could prove of value in the face of increasingly strict EU SPS controls. In a range of areas, given UK agro-climatic conditions and production conditions the UK authorities assess risks far lower than the EU as whole for a range of fruit and vegetable products of export interest to ACP countries. Securing a reduction in these UK-only SPS controls in line with agro-climatic conditions in the UK could open up new market opportunities for Ghanaian exporters.
At the end of May 2019 the Ghanaian authorities announced a pre-emptive ban on exports of all forms of leafy vegetables including chilies, aubergines, solanum, and lufa. This measure was taken in the face of fears that pest infestations (particularly but not exclusively for false codling moth) could give rise to an EU ban (1). This follows ‘the high level of local interceptions at the exit points; the alarming rate of external notifications, and the new EU directives to all countries to re-provide dossiers to the EU on the management of harmful organisms on some of the above vegetables’ (2). Ghana had only recently on the 1st January 2018 escaped an EU imposed import ban (see companion epamonitoring.net article, ‘Lifting of EU Ban May Provide Little Relief for Ghanaian Vegetable Exporters’, 16 November 2017), but was ‘still on the red list and being monitored closely’ (2). With the number of notifications of pest infestations increasing in 2019 (2), it was decided a pre-emptive export ban was necessary. This pre-emptive export ban will last indefinitely (1).
The Vegetable Producers and Exporters Association of Ghana had requested the government to postpone the ban and introduce more selective measures to target specific offenders who failed to comply with EU requirements. It was argued more selective measures would avoid harming most of the 4,000 farmers and associated businesses that would be adversely affected by a blanket export ban (1).
However the Ghanaian government felt unilateral action was essential since this would avert any formal EU import ban, the removal of which would then be beyond the control of the Ghanaian authorities. This needs to be seen in a context where the previous EU ban cost the Ghanaian economy over US$ 30 million in lost exports. The Ghanaian government appears to take the view that it is up to the Ghanaian private sector to work with the government in eliminating ‘unhealthy and unwholesome practices’ (1).
As indicated by the Ghanaian authorities this unilateral initiative follows on EU directives requiring stricter controls on a range of pests from thrips to false codling moth infestations. On 31st May freshplaza.com reported the EU decision ‘set stricter phytosanitary controls for mangoes from third countries’, in the face of an increase in interceptions of harmful organisms over the past years. Mangoes are reportedly ‘the second product (behind peppers) with the most interceptions at the EU border’. In 2017 ‘there were 178 detections of harmful organisms in mangoes from third countries. Of these, 149 were fruit fly detections’, the infestation the EU most wants to keep under control (3).
The EC implementing directive 2019/523 which will come into effect on 1st September 2019 will require all fruit and vegetables entering the EU to be grown in pest free areas where no detections have occurred. This extended regulation stipulates ‘no signs of flies are to be observed at the production site and in its vicinity, since the start of the last complete vegetation cycle’, with official inspections needing to be carried out ‘at least once a month during the three months prior to the harvest’. What is more ‘none of the fruits harvested at the production site must show signs of the organism following an official examination’ (3). In the absence of such assurances all fruit and vegetables will need to be subject to approved treatments to eliminate pest infestations prior to export to the EU (4).
In the case of Ghana this will affect exports of guavas and mangoes which have increased from a mere 883 tonnes (valued at €2.3 million) in 2009 to 3,816 tonnes valued at €29.8 million in 2018. While this represents more than 3-fold increase in the volume of exports, export values increased nearly 13-fold, suggesting a progressive improvement in the quality of Ghanaian Mango exports (5). This strong growth in Ghanaian exports in recent years could come under serious threat from increasingly strict EU import controls.
What is more the recent revision of EU SPS controls may not be the end game. Spanish producer organisation ASAJA continues to demand even stricter EU SPS import requirements to prevent the introduction of new pests in the EU, including:
- ‘prior registration at origin of farms and operators’;
- ‘phytosanitary audits at origin and inspections at the port of departure, funded by the exporting country’;
- the creation of border inspection points ‘specialized in mangoes, especially at the ports receiving the most mangoes’;
- the ‘creation of a body of inspectors, with adequate training, and financed by the producing countries themselves’ (3).
All of these control measures would further increase the costs of production in ACP supplying countries and undermine the competitive position of imports on the EU market.
These demands by Spanish producer organisations need to be seen against the background of increasing Spanish mango production which having grown 16% in the main production region in 2018 (3) is projected to double in the 2019 production season (6). However this would still leave production in the main Spanish production at only 1/6 of the level of total extra-EU imports of mangoes (3).
Stricter controls are also pending on false codling moth infestations (for more specific details on requirements for false codling moth controls see companion epamonitoring.net article ‘COLEACP Warns Highlights New EU Requirements for Retaining Access to EU Market for Chilli and Pepper Exports’, 24 June 2019). The combined effects of these stricter controls could pose serious challenges unless a comprehensive systems approach to SPS controls is adopted.
| Comment and Analysis
Changes in EU SPS control regulations are posing a multiplicity of challenges to Ghanaian fruit and vegetable exporters, with this strongly suggesting the need for the adoption of a comprehensive systems approach to pest controls. If the challenge of maintaining access to the EU market for Ghana’s expanding fruit and vegetable export trade is to be met, this will require: a) better private sector organisation; b) closer government/private sector cooperation; c) a multiple product/pest approach to control systems; d) careful monitoring of the changes in EU minimum residue level requirements In terms of the adoption of a multi-product/multi-pest approach lessons could potentially be drawn from the South Africa experience under its Phytclean electronic compliance database scheme. This system allows officials to immediately identify which farmers are following the required systems of disease and pest controls, with enforcement efforts and export restrictions then being selectively applied. This monitoring system was developed jointly through cooperation between South Africa’s highly organised citrus industry and the Department of Agriculture, Forestry and Fisheries (DAFF), with the operation of the system now being part of the official function of the DAFF. While developed for the citrus sector this scheme is being extended to other sectors. This experience is illustrative of the kind of multi-product/multi-pest control arrangements which public/private sector cooperation should aim at establishing in Ghana. This would then allow for the kind of targeted measures which the Vegetable Producers and Exporters Association of Ghana urged the Ghanaian government to adopt instead of a complete export ban (for more details on the South African Phytclean scheme see companion epamonitoring.net article ‘The Potential Differential Effects of Stricter EU False Coddling Moth Controls on African Exports’, 19 March 2019) Stricter EU SPS requirements also raise the issue of the future basis of UK SPS controls, which, it is acknowledged, may be modified to reflect UK-only agro-climatic conditions, free from any pressure from specific EU27 producer interests. Such a review may be accelerated should a ‘no-deal’ Brexit make imports of affected products from EU27 suppliers more expensive. A review of the UK’s SPS control website (UK Plant Health Information Portal) (7) could well prove useful in this regard. Here the areas where due to agro-climatic conditions and patterns of UK production, the risk assessment for particular pests is lower than at the EU level can be identified. This could prove particularly important in areas where EU controls are becoming increasingly stringent (for specific examples see companion epamonitoring.net article ‘Stricter Risk Assessments under New EU Plant Health Regulation Could Hinder ACP Exports’, 29 April 2019). Entering into targeted dialogues around these issues as part of Continuity Agreement negotiations with the UK could prove of considerable value in the face of increasingly strict EU SPS controls on imports of mangoes and other fruit and vegetable products where Ghana has been expanding its exports to the EU in recent years. This needs to be seen in a context where in 2018 fully 61% of Ghanaian vegetable exports to the EU market went to the UK and 39% of Ghana’s non-banana fruit exports to the EU were destined for the UK market. The individual products the importance of the UK market is even greater, with the UK taking nearly 71% of Ghanaian exports of Guavas, mangoes and mangosteens to the EU in 2018. This has come on the back of an almost 6-fold increase in the value of Ghanaian exports of Guavas, mangoes and mangosteens to the UK since 2013, in light of an almost 4-fold increase in volumes over the same period. By 2018 this export trade to the UK was worth over €21 million up from €3.7 million in 2013 (5). |
Sources
(1) freshplaza.com, ‘Ghana bans chilli pepper exports’, 29 May 2019
https://www.freshplaza.com/article/9109344/ghana-bans-chilli-pepper-exports/
(2) myjoyonline.com, ‘Government places indefinite ban on export of leafy vegetables’, 1 June 2019,
https://www.hortidaily.com/article/9108940/ghana-government-places-indefinite-ban-on-export-of-leafy-vegetables/
(3) agroinformacion.com, ‘Europe sets stricter phytosanitary requirements for imported mangoes’, 31 May 2019
https://www.freshplaza.com/article/9110049/europe-sets-stricter-phytosanitary-requirements-for-imported-mangoes/
(4) freshfruitportal.com, ‘EU to tighten mango import regulations’, May 29 , 2019
https://www.freshfruitportal.com/news/2019/05/29/eu-to-tighten-controls-on-peruvian-mango-imports
(5) EC, Market Access Data Base
https://madb.europa.eu/madb/statistical_form.htm
(6) Freshplaza.com, ‘Spain-s-largest-avocado-and-mango-producer-focused-on-boosting-domestic-consumption’, 31 May 2019
https://www.freshplaza.com/article/9110072/spain-s-largest-avocado-and-mango-producer-focused-on-boosting-domestic-consumption/
(7) DEFRA, ‘UK Plant Health Information Portal: An online hub for plant health information, data and resources’
https://planthealthportal.defra.gov.uk/
(8) EC, ‘European Union – Ghana’, Agro-food trade statistical factsheet
https://ec.europa.eu/agriculture/sites/agriculture/files/trade-analysis/statistics/outside-eu/countries/agrifood-ghana_en.pdf