Summary
In April 2019 the government of Uganda introduced a self-imposed ban on exports of sub-standard vegetables to Europe. This needs to be seen in the context of the stricter application of EU SPS controls. This includes controls for False Codling Moth (FCM) which was designated as a ‘quarantine pest’ by the EU from 1st January 2018. This saw 2/3 of all EU SPS interceptions of Ugandan exports arising from FCM infestations in 2018. Despite the four-fold increase in the value of Ugandan floriculture and horticulture exports to the EU since 2010, serious questions arise as to the commercial sustainability of attaining conformity with EU SPS requirements. Experience in South Africa highlights how costly establishing a comprehensive system based approach to SPS controls can be. Even where export values are more than 10 times those attained by Ugandan exporters this can prove commercially challenging. Critical to enhancing the effectiveness and reducing the unit cost of SPS control measures will be improved organisation of private sector producers and improved public/private sector cooperation in ensuring compliance with EU SPS requirements.
Press reports in December 2018 warned that Uganda’s growing horticultural exports to the EU were coming under an increasing threat of disruption as a result of shortcomings in national systems of pest controls on exported products. It was acknowledged by Paul Mwambu, Commissioner for Crop Inspection and Certification at the Ministry of Agriculture that ‘most of the country’s horticulture products are falling short of the EU recommended standards and thus risk being denied access’ to the EU market. Particular concerns were identified as arising around the ‘presence of pests, poor storage, packaging and high levels of unwanted pesticide residues’ (1).
This followed similar concerns raised in 2016 over shortcomings in Ugandan national SPS control systems. In 2016 it was found that ‘although the inspectors are experienced and well-trained, severe staff shortages prevent the NPPO from running an official export control and certification system fully in line with EU requirements’. This meant the scope and frequency of controls carried out in greenhouses, at pack houses and at the airport was ‘not in line with EU requirements’.
It was highlighted how the reliance on the own inspections of growers and pack houses without adequate official inspections was inadequate. However it was noted that while the inspection system was deemed not to comply with EU requirements, improvements were underway resulting in ‘a low number of EU interceptions of plants for planting and cut roses’, but with continued problems for fruit and vegetables (2). This saw the Minister for Trade ‘ban a section of horticultural products including hot pepper for a month to address the issue’ and the establishment of a ‘technical team to train Ugandan farmers on quality compliance and pest control’. (1).
However, there remains concerns amongst leading Ugandan exporters that the failure of the Ugandan government to ‘enact stringent regulations on who and how to export’ is likely to ensure poor quality and pest infected products continue to enter export supply chains. In addition the high cost of testing for pesticide residues in food crops is also seen as a challenge (1). Collectively these issues are seen as posing a threat to the continued growth of Ugandan floriculture and horticultural exports, which since 2010 have increased 134% in volume and 317% in value.
Evolution Uganda Exports to the EU Cut Flowers, Fruit and Vegetable (Tonnes)
| 2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2016 | 2017 | 2018 | % change 2010-18 | |
| 06 Cut flowers | 5,231 | 5,496 | 5,547 | 15,735 | 14,602 | 13,646 | 15,099 | 14,329 | 13,557 | +159% |
| 07 Vegetables | 2,354 | 2,432 | 2,503 | 2,966 | 3,471 | 3,787 | 4,781 | 5,218 | 5,711 | +143% |
| 08 Fruit | 1,783 | 1,878 | 2,039 | 1,667 | 2,065 | 2,410 | 2,760 | 2,259 | 2,623 | +47% |
| TOTAL | 9,368 | 9,806 | 10,089 | 20,368 | 20,138 | 19,843 | 22,640 | 21,806 | 21,891 | +134% |
Source: EC Market Access Data Base https://madb.europa.eu/madb/statistical_form.htm
Evolution Uganda Exports to the EU Cut Flowers, Fruit and Vegetable (€ ‘000)
| 2010 | 2011 | 2012 | 2013 | 2014 | 2015 | 2016 | 2017 | 2018 | % change 2010-18 | |
| 06 Cut flowers | 8,155 | 40,127 | 43,925 | 46,544 | 45,003 | 47,630 | 47,543 | 50,984 | 50,350 | +517% |
| 07 Vegetables | 4,683 | 4,607 | 4,832 | 6,563 | 7,793 | 10,138 | 10,941 | 10,547 | 11,470 | +145% |
| 08 Fruit | 3,213 | 3,592 | 3,619 | 3,379 | 4,524 | 5,405 | 4,805 | 4,525 | 5,066 | +58% |
| TOTAL | 16,051 | 48,326 | 52,376 | 56,486 | 57,320 | 63,173 | 63,289 | 66,056 | 66,886 | +317% |
Source: EC Market Access Data Base https://madb.europa.eu/madb/statistical_form.htm
What is more following the listing of false codling moth (FCM) as a quarantine pest from the beginning of 2018, the levels of interceptions of non-compliant Ugandan products has increased.
At the January 2019 meeting of the EU Standing Committee on Plants, Animals, Food and Feed growing concern was expressed over the level of interceptions of FCM in 2018. Particular concerns arose around countries using place of production free or effective treatment reporting by growers and packers, with problems in the certification system being seen to exist in such countries (4).
EU Plant Health Interceptions of Ugandan products in 2018
| Product | Pest | Number of Interceptions |
| Capsicum (chilli peppers) | Thaumatotibia leucotreta (FCM) | 40 |
| Annona spp (custard apple) | Fruit Flies | 8 |
| Momordica spp (bitter melon) | Fruit Flies | 10 |
| Rosa spp (roses) | Thaumatotibia leucotreta | 9 |
| Solanum spp (aubergines) | Leucinodes orbonalis | 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
Against this background in April 2019 the government of Uganda announced a ‘self-imposed ban on the export of chillies and substandard vegetables to Europe’, in recognition of the potential threat to the horticulture industry as a whole if no unilateral action was taken. This unilateral action was welcomed by the EU delegate to Uganda who expressed the view that the export of substandard products which did not meet EU standards was ‘killing the market’ for Ugandan exports (5).
| Comment and Analysis There has been considerable growth in Ugandan exports of cut flowers, vegetables and fruits to the EU since 2010, with the overall value of these exports increasing 317% up to 2018. Uganda exports of cut flowers took off in 2013 and showed strong and consistent growth until 2016. However 2017 saw a 5% decline in the volume of exports, with a further 5% decline in 2018. Despite this decline in volume during these last two years export values held up surprisingly well, declining only 1.2% in 2018. Between 2010 and 2018 while the volume of Ugandan cut flower exports increased 159% the value grew 517%. This suggests a progressive improvement in the valorisation of these exports. Ugandan vegetable exports have shown a similar strong and consistent growth in volume (+143%) but with a less dramatic increase in the value of exports (+145%) compared to the cut flower sector, with only a marginal increase in unit value. Ugandan exports of fruit have also increased though at a much slower rate (+47% in volume and +58% in value), but with a slightly better increase in the value of exports than in the vegetable sector. Both in terms of volumes and value exports have been fluctuating since 2015, with 2015 and 2016 marking a high point for the value and volume respectively of Uganda fruit exports. This suggests problems with the quality of Ugandan fruit exports is making itself felt at the commercial level, with lower unit values being obtained. The situation in regard to FCM interceptions is a particular concern in the cut flower sector. Cut flowers accounted for 75% of the combined value of Ugandan cut flower, vegetable and fruit exports to the EU in 2018 (up from 56% in 2010), in a context where roses have consistently accounted for more than 50% of the value of Ugandan cut flower exports to the EU in recent years. Ugandan exports of Roses (060311) to the EU
Source: EC Market Access Data Base https://madb.europa.eu/madb/statistical_form.htm The situation with regard to FCM interceptions of Capsicum (chilli peppers) which accounted for 34% of the volume and 39% of the value of Ugandan vegetable exports is an additional source of concern. Ugandan exports of Capsicum (070960) to the EU
Source: EC Market Access Data Base https://madb.europa.eu/madb/statistical_form.htm Once deliberations on how the EU should respond to rising levels of FCM interception are complete, stricter EU controls could come to constitute a serious setback to the recent growth of Ugandan exports in both the cut flowers and the vegetable sector. As the South African experience in the citrus sector highlights, effectively controlling pest and disease infections in line with increasingly strict EU requirements can require very large financial outlays (see epamonitoring.net article ‘South Africa to Take EU to WTO Dispute Settlement over Citrus Black Spot Controls’, 8 April 2019). In South Africa the development of a multi-product systems approach to pest controls is making it possible to share the costs of controls across different export products, reducing the unit cost of such controls. This is possible in South Africa because of the well-organized nature of the export sectors concerned. The concerned private sector producers’ associations work closely with the government in regulating access to export markets, so as to ensure sub-standard and infected products do not enter into export supply chains. Nevertheless the costs of controls are substantial. This needs to be seen in a context where the value of South African citrus exports to the EU alone is over 10 times larger than the total combined value of Ugandan cut flowers, fruit and vegetable exports to the EU. Against this background the question arises: how commercially sustainable are the necessary controls systems for FCM and other quarantine pests likely to be in a new emergent exporter such as Uganda? This issue will be critically influenced by three factors: · the stringency of EU control measures once the new EU plant health regulation is in place; · the level of private sector organisation in the main export sectors and the ability of sector · the ability of Ugandan exporters to maximise the value on their exports in order to create the In this regard major new initiatives to strengthen the internal organisation of exporting sectors and government/private sector cooperation would appear to be necessary if the expansion of Ugandan exports of cut flowers, vegetables and fruit underway since 2010 is to be sustained. |
Sources
(1) freshplaza.com, ‘Uganda’s horticulture exports risk EU ban’, 18 December 2018
https://www.freshplaza.com/article/9054987/uganda-s-horticulture-exports-risk-eu-ban/
(2) EC, ‘Final report of an audit carried out in Uganda from 06 September 2016 to 15 September 2016 in order to evaluate the system of official controls for the export of plant products to the European
file:///C:/Users/GDC%20Partners/Downloads/2016-8806%20MR%20Final.pdf
(3) 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
(4) EC, ‘Summary report of the EU Standing Committee on Plants, Animals, Food and Fee held in Brussels on 21-22 January 2019’,
https://ec.europa.eu/food/sites/food/files/plant/docs/sc_plant-health_20190121_sum.pdf
(5) allafrica.com, ‘Uganda bans chilli exports to European Union’, 16 April 2019
https://www.hortidaily.com/article/9094507/uganda-bans-chilli-exports-to-european-union/