New EU Fruit Fly Rules Cause Concern Amongst West African Mango Exporters

 

Summary
Stricter EU SPS import controls on Tephritidae (fruit flies) infestations due to come into effect on 1st September 2019 could pose challenges for West African mango exports to the EU.  This is particularly the case for smaller scale exporters. In this context a ‘no-deal’ Brexit could offer some relief, if the UK could be persuaded to define the required SPS controls with reference solely to the agro-climatic conditions prevailing in the UK rather than across the whole of the EU. This is an issue which concerned ACP exporters should urge their governments to collectively take up with the UK government, with a  view to establishing clearly defined structures for dialogue around such a review once the UK is no longer subject to the rules of the EU’s customs union and single market.

Concerns are increasing amongst Mango exporters in West Africa over their state of preparedness for the implementation of new stricter EU controls on fruit fly infestations from 1st September 2019. COLEACP has warned that from 1st September 2019 exporters serving the EU market will need to verifiably demonstrate the mango has been subjected to an effective  treatment to ensure it is free from Tephritidae (fruit flies), and the treatment data must be included in the phytosanitary certificate’. (1) The requirement to provide written data on the treatment method applied could prove enormous for smaller scale producers.

In 2018 West African exports of Guavas, Mangoes and Mangosteens amounted to 65,800 tonnes for a total value of € 103,246,575. Since 2012 exports to Europe have increased 119% in volume and 176% in value. The main West African exporters by volume are Ivory Coast, Senegal, followed a long way behind by Mali, Burkina Faso, Ghana, Gambia and Guinea. The ranking of countries by value of exports is somewhat different with Ghana being the leading exporter by value, despite exporting only 1/10th of the volume of Ivory Coast. Burkina Faso also has strong export earnings relative to the volume exported (2).

Main West Africa Exporters of Guavas, Mangoes and Mangosteens (080450) to the EU 2012-2018

Tonnes 2012 2013 2014 2015 2016 2017 2018 %
Total EU 232,447 260,424 271,737 297,956 335,265 359,989 398,369
Ivory Coast 15,267 16,514 20,469 22,938 30,047 31,219 31,246 +105%
Senegal 6,196 8,205 10,330 11,519 10,049 11,895 15,885 +156%
Mali 3,815 4,760 3,833 6,425 7,448 5,455 7,046 +85%
Burkina Faso 2,126 2,934 3,064 4,352 6,385 4,872 5,818 +174%
Ghana 840 1,621 2,384 2,655 3,611 3,532 3,816 +352%
Gambia 981 878 2,193 1,914 1,677 1,755 1,523 +55%
Guinea 856 820 1,013 1,159 459 384 466 -47%
-Sub Total 30,081 35,732 43,286 50,962 59,676 59,112 65,800 +119%
 
Value Euros 2012 2013 2014 2015 2016 2017 2018 %
316,392,408 362,386,422 403,102,192 522,598,921 547,190,904 560,699,447 585,060,494
Ivory Coast 13,364,588 16,755,643 23,135,594 26,622,004 29,828,988 28,433,401 26,475,143 +98%
Senegal 9,496,198 9,463,129 11,089,958 13,100,380 10,779,872 13,563,549 16,881,067 +78%
Mali 4,451,127 6,551,906 4,451,538 8,708,181 8,458,463 4,823,702 7,207,805 62%
Burkina Faso 4,244,405 6,464,818 7,896,971 12,291,267 15,663,949 12,378,166 20,331,916 +379%
Ghana 3,057,830 8,882,893 15,480,768 18,844,402 26,542,501 26,710,536 29,773,457 +874%
Gambia 2,051,791 1,352,096 4,243,551 3,616,499 2,944,833 2,709,558 2,100,877 +2.4%
Guinea 807,346 1,043,751 1,157,747 1,214,947 515,605 388,170 486,310 -40%
 
-Sub Total 37,473,285 42,514,236 63,217,370 67,456,127 94,734,211 89,007,235 103,246,575 176%

Source: EC Market Access Data Base

It is unclear how well placed these West African exporters are to meet the reporting and treatment requirements for the containment of fruit fly infestations before the entry into force of new EU regulations on 1st September 2019.

By 2018 the main West African exporters of Guavas, Mangoes and Mangosteens were accounting for 16.5% of EU imports by volume and 17.6% by value. This contrasts with a situation in 2012 when West African exporters of Guavas, Mangoes and Mangosteens were accounting for 12.9% of EU imports by volume and 11.8% by value. Exports of Guavas, Mangoes and Mangosteens have thus been a growth sector in West Africa’s agro-food sector trade with the EU both in absolute terms and in terms of their share of the EU market.

Beyond West Africa the leading ACP exporter of Guavas, Mangoes and Mangosteens is the Dominican Republic, the 3rd largest ACP exporter by volume and the 4th largest exporter by value. In recent years South Africa has also emerged as an exporter of Guavas, Mangoes and Mangosteens, taking 7th place amongst ACP exporters in 2017.

There are also 17 smaller scale exporters across the ACP whose volumes have never exceeded 75 tonnes (2). These smaller scale exporters are likely to face the most severe challenges in meeting EU reporting requirements. Indeed, with the exception of the Dominican Republic and South Africa, where costs of fruit fly controls can be spread across a multiplicity of sectors in close association with well organised private sector bodies, it is unclear how well placed other ACP exporters are to meet the reporting and treatment requirements for the containment of fruit fly infestations.

Other ACP Exporters of Guavas, Mangoes and Mangosteens (080450) to the EU 2012-2018

Tonnes 2012 2013 2014 2015 2016 2017 2018 12-18%
Central Africa
Cameroon 260 388 471 517 477 489 246 -5%
Equ Gui 90 138 248
Southern Afr
South Africa 681 298 592 1,487 1,513 2,289 1,778 +161%
Caribbean
Dom Rep 6,653 9,640 11,152 13,103 14,791 13,045 14,415 +117%
-Sub Total 7,594 10,326 12,215 15,098 16,971 15,961 16,687 +120%
 
Value Euro 2012 2013 2014 2015 2016 2017 2018 %
Central Africa
Cameroon 687,268 942,969 1,123,561 1,605,018 1,096,727 1,335,367 685,687 -0.2%
Equ Gui 92,492 133,124 250,723
Southern Afri
South Africa 4,524,372 2,206,351 4,779,322 11,614,128 7,066,924 9,831,587 8,331,132 +84%
Caribbean
Dom Rep 8,479,339 13,853,733 16,392,952 19,580,963 22,585,448 18,087,003 18,712,180 +121%
– Sub Total 13,690,978 17,003,053 22,295,835 32,800,109 30,841,591 29,387,081 27,979,722 +104%

Source: EC Market Access Data Base

By 2018 these other main ACP exporters of Guavas, Mangoes and Mangosteens were accounting for 4.2% of EU imports by volume and 4.8% by value (2).

Beyond the ACP Group the leading suppliers of Guavas, Mangoes and Mangosteens to the EU market are Brazil (34.5% of imports in 2018) and Peru (32.0%), at a combined volume of 525,976 tonnes, these two countries together account for 8 times more imports than West African countries.

The Leading Exporters of Guavas, Mangoes and Mangosteens (080450) to the EU 2012-2018

Tonnes 2012 2013 2014 2015 2016 2017 2018 %
Peru 53,348 68,779 71,974 76,718 88,019 98,461 124,607 +134%
Brazil 91,251 90,064 99,312 111,195 114,912 131,025 137,596 +51%

Source: EC Market Access Data Base

While imports of Mangoes face no MFN duties, the conclusion of a trade agreement with the EU appears to influence the environment for trade, with since 2012 (the year before the entry into force of EU FTA with Peru) import volumes of Guavas, Mangoes and Mangosteens from Peru having consistently grown, at a faster rate than from Brazil (+ 134% compared to +51%), with Peruvian export volumes approaching Brazilian levels in 2018 (2).

Comment and Analysis
The application of stricter EU import requirements for fruit fly infestations in consignments of mangoes raises the issue of the UK’s future SPS import controls in areas where the UK’s domestic risk assessment is lower than for the EU as a whole. The lower risk assessment in the UK arises from the assessment being made with reference solely to UK agro-climatic conditions, rather than the various agro-climatic conditions across the EU as a whole (3) (see also companion epamonitoring.net article, ‘Ghanaian Pre-emptive Export Ban on Chilli Peppers, Aubergines and other Leafy Vegetables May Be Just the Beginning’,8 July 2019).

The table below sets out the current trade dependence of the main ACP mango exporters on the UK market as a share of total exports to the EU. In addition to these top 11 suppliers there are an additional 11  ACP countries which export mangoes to the UK to a limited extent, with only four of these ACP exporting countries reaching double figures and none exceeding 45 tonnes (the countries concerned are: Grenada (21 tonnes); Jamaica (1 tonne); Kenya (1 tonne); Malawi (1 tonne); Nigeria (23 tonnes); Rwanda (1 tonne); St Lucia (42 tonnes); St Vincent & Grenadines (1 tonne); Sudan (8 tonnes); Tanzania (3 tonnes); Uganda (23 tonnes)

Importance of the UK market in exports of Mangoes to the EU (2018) – tonnes

EU UK % UK
Ivory Coast 31,246 2,403 7.7%
Senegal 15,885 1,355 8.5%
Mali 7,046 172 2.4%
Burkina Faso 5,818 613 10.5%
Ghana 3,816 2,748 72.0%
Gambia 1,523 1,441 94.6%
Guinea 466 133 28.5%
Cameroon 246 0 0%
Equatorial  Guinea 248 248 100%
Dominican Republic 14,415 4,541 31.5%
South Africa 1,778 929 52.2%
Sub-total 82,487 14,583 17.7%
UK Total 68,546
% share total UK imports 21.3%

Source: EC Market Access Data Base

For those ACP exporters facing difficulties in meeting new EU pest control and pest control documentation requirements for the treatment of Tephritidae (fruit flies) it may be possible to launch a dialogue with the UK on whether these requirements are still necessary in a solely UK agro-climatic context, once the UK is no longer part of the EU customs union and single market.

While currently the UK has committed to applying in full existing EU SPS and food safety regulations in the immediate post ‘no-deal’ Brexit period, trade negotiations with the USA are likely to test this resolve and indeed, lead to a policy review.

This could create an opening for ACP governments to request new UK-specific SPS import requirements for Tephritidae, infestations in mangoes. The concerned ACP governments (particularly small scale exporters and those with an exceptionally high dependence on the UK market) could usefully adopt a joint approach to the dialogue with the UK. The core of such concerted action would appear to be the governments of Ghana, Cote d’Ivoire and Cameroon, all of which are still to conclude Continuity Agreements with the UK.  These SPS dimensions should form an integral part of these Continuity Agreement negotiations, with the focus being on establishing a framework for consultations for changes to UK SPS requirements once the UK is no longer subject to the rules of the EU customs union and single market.  In this context it should be recalled it is the departure of the UK from the customs union and single market is at the heart of the UK’s negotiation of Continuity Agreements with ACP countries.

Sources:
(1) freshplaza.com, ‘West Africa’s mango exporters soon to be confronted by new EU directives’, 8 May 2019
https://www.freshplaza.com/article/9101833/west-africa-s-mango-exporters-soon-to-be-confronted-by-new-eu-directives/
(2) EC, Market Access Data Base
https://madb.europa.eu/madb/statistical_form.htm
(3) DEFRA, ‘UK Plant Health Information Portal: An online hub for plant health information, data and resources’
https://planthealthportal.defra.gov.uk/
(4) CBI, ‘Exporting mangoes to Europe’, 24 October 2018
https://www.cbi.eu/market-information/fresh-fruit-vegetables/mangoes/europe/