Summary
In the mango sector stricter EU phytosanitary controls on non-European fruit fly (Tephritidae) could halt the strong growth in ACP mango exports to the EU market which has been underway since 2008. Stricter EU controls could make it commercially non-viable for smaller scale ACP exporters to continue to enjoy entry to the EU market. In this context the extent to which the UK will apply evolving EU phytosanitary controls under a no-deal Brexit scenario could take on some significance for smaller scale ACP mango exporters. Put simply risk assessments based solely on agro-climatic conditions in the UK may come to quite different conclusions than risk assessments based on the diverse agro-climatic conditions across all EU27 member states. In this context if the UK were to design phytosanitary controls based solely on the threat to agriculture and human health in the UK these may prove to be far less strict than the controls now being introduced by the EU. This is an issue which could usefully be taken up in ongoing Continuity Agreement negotiations with the UK, particularly in the context of the “Annex of Concerns” approach now being canvassed as a mean of ensure forward looking trade arrangements with the UK are set in place. Trade arrangements which take into account the changed economic realities and commercial possibilities which the UK’s withdrawal from the EU customs union and single market will or could bring about.
The EU’s new plant health regulation is due to enter fully into effect on 13th December 2019. However a number of interim measures have already been introduced for plant imports where quarantine pests are present. This is focussed on more rigorous enforcement of the existing framework of import controls. This includes measures against non-European fruit fly (Tephritidae).
There have been a particularly high number of interventions of Tephritidae in imports of mangoes from ACP countries. In October 2018 this saw the introduction of a regulation which would establish special measures related to imports of mangoes. These measures are scheduled to be adopted in March 2019 and published in April 2019. This would provide for a 5 months transition period before the provisions of the new regulation come into force (1).
Under this regulation mangoes will only be allowed entry to the EU market if ‘they have been subjected to an effective treatment to ensure freedom from Tephritidae (non-European)’. Such effective treatment must be fully documented, including the treatment applied being recorded on the ‘plant health certificate that accompanies the consignment’.
In addition before the designated start date for the application of the regulation (i.e. before the end of September 2019) the National Plant Protection Organisation (NPPO) ‘must send a dossier to the EC outlining in detail the treatments that must be applied’ including the ‘post-harvest treatments, and/or a pre-harvest “systems approach” that covers control and management (IPM) of the pest in the field’ (1).
The NPPO must also ensure an action plan is in place which has been agreed and is being implemented across the industry, so that 100% of mangoes are ensured fruit fly free. It is recognised this will require close collaboration between the NPPO and mango producers and exporters (1).
COLEACP has in place a €23.5 million programme to combat fruit fly in West Africa which has been largely funded by the EU (€16.7 million). This programme has been under implementation since 2015 and is scheduled to terminate in 2019 (1). It forms part of a wider Regional Plan to combat and control fruit flies in West Africa, known as the “Fruit Fly Programme” (2). In addition as part of its €25 million ‘Fit for Market’ programme (3) COLEACP is providing funding to support the ‘development of the dossiers to be submitted to the EU before the end of the year’ (1).
In the run up to the entry into force of the new EU regulation dealing with Tephritidae infestation of imports of mangoes COLEACP argue, it is ‘critically important for 2019 exports to be tightly managed so that there are a minimum number of interceptions due to fruit fly’. If fruit fly infestations are not effectively controlled and infestation levels continue as in previous years, then ‘it is possible that the EC will take more drastic action against imports from ACP countries for the 2020 season’ (1).
Main ACP exports of Guavas, mangoes and mangosteens (080450) to the EU (selected years – tonnes)
| 2008 | 2011 | 2014 | 2017 | +% 2008-17 | € Value 2017 | |
| Ivory Coast | 11,249 | 10,180 | 20,469 | 31,219 | +177.5% | 28,433,401 |
| Dominican Republic | 4,308 | 6,357 | 11,152 | 13,045 | +202.8% | 18,087,003 |
| Senegal | 6,038 | 5,341 | 10,330 | 11,895 | +97.0% | 13,563,549 |
| Mali | 4,902 | 1,797 | 3,833 | 5,455 | +11.2% | 4,823,702 |
| Burkina Faso | 2,408 | 2,128 | 3,062 | 4,872 | +102.3% | 12,378,166 |
| Ghana | 1,097 | 226 | 2,384 | 3,532 | +222.0% | 26,710,536 |
| South Africa | 1,781 | 510 | 592 | 2,289 | +28.5% | 9,831,587 |
| Gambia | 686 | 1,502 | 2,193 | 1,755 | +155.8% | 2,709,558 |
| Cameroon | 227 | 328 | 471 | 489 | +115.4% | 1,335,367 |
| Guinea | 544 | 93 | 1,013 | 384 | -29.4% | 388,170 |
| Equatorial Guinea | 0 | 0 | 0 | 138 | – | 133,124 |
| – Sub-Total | 33,250 | 23,121 | 55,499 | 75,073 | +124.2% | €118,394,163 |
| Total EU Imports | 231,727 | 252,738 | 271,737 | 359,989 | +55.4% | €560,699,447 |
| % top 11 ACP | 14.5% | 9.1% | 20.4% | 20.9% | 21.1% |
This needs to be seen in a context where although 24 ACP countries have been involved in exporting Guavas, mangoes and mangosteens (080450) to the EU, in 2017 only 11 ACP countries exported more than 100 tonnes per annum. Since 2008 in volume terms ACP exports of Guavas, mangoes and mangosteens to the EU have increased 124%, compared to only a 55% increase in extra-EU imports from all sources since 2008. The main ACP source of extra-EU imports is West Africa, which accounts for 78% of Guavas, mangoes and mangosteens imported into the EU from the top 11 ACP sources and 16% of total extra-EU imports, with Cote d’Ivoire alone accounting for 9% of extra-EU imports in 2017 in this product category. The second most important ACP source of supply is the Dominican Republic accounting for 17.4% of imports from the top eleven suppliers (3.6% of total extra-EU imports).
In 2017 the value of imports of Guavas, mangoes and mangosteens from the top 11 ACP suppliers reached €118.4 million. By 2017 the top 11 ACP suppliers accounted for almost 21% of extra-EU imports, up from 14.5% in 2008. The category of Guavas, mangoes and mangosteens has thus been a significant growth sector in trade with the EU over the past decade (4). In 2017 around 20% of these exports to the EU were destined for the UK market, with this representing an above average dependence on direct exports to the UK market in trade with the EU in Guavas, mangoes and mangosteens. It is unclear to what extent ACP exports of Guavas, mangoes and mangosteens to the Netherlands which took 42% of EU imports from the top 11 ACP suppliers may be traded onward to the UK.
Main ACP exports of Guavas, mangoes and mangosteens (080450) EU, UK, Netherlands (2017)
| Country | EU (t) | UK (t) | UK % Share | Neth | Neth % share |
| Ivory Coast | 31,219 | 4,407 | 14.1% | 12,324 | 39.5% |
| Dominican Republic | 13,045 | 4,539 | 34.8% | 6,998 | 53.6% |
| Senegal | 11,895 | 476 | 4.0% | 6,319 | 53.1% |
| Mali | 5,455 | 151 | 2.8% | 2,685 | 49.2% |
| Burkina Faso | 4,872 | 300 | 6.2% | 2,068 | 42.4% |
| Ghana | 3,532 | 2,618 | 74.1% | 51 | 1.4% |
| South Africa | 2,289 | 984 | 43.0% | 898 | 39.2% |
| Gambia | 1,755 | 1,517 | 86.4% | 2 | 0.1% |
| Cameroon | 489 | 0 | 0% | 0 | 0% |
| Guinea | 384 | 0 | 0% | 130 | 33.9% |
| Equatorial Guinea | 138 | 138 | 100% | 0 | 0% |
| Top 11 ACP | 75,073 | 14,992 | 20% | 31,475 | 41.9% |
| Imports all sources | 359,989 | 66,814 | 18.6% | 195,689 | 54.4% |
| Comment and Analysis The application of new stricter EU controls on Tephritidae infestations in imports of mangoes could place a significant administrative burden on many smaller scale exporters of Guavas, mangoes and mangosteens. A situation could emerge where the volume of trade involved is insufficient to warrant the level of investment required to maintain access to the EU market under the new stricter EU phytosanitary control regime. It is unclear where this cut off point for commercially viable levels of exports would be, in light of the cost implications of new EU SPS requirements. The unit cost of control measures is very sensitive to the overall volume of production.This is well illustrated by South Africa’s sophisticated electronic compliance database Phytclean. This comprehensive control system not only covers the Rand 20 billion citrus industry but has been extended to the entire horticulture industry and may even be further ‘adopted for agriculture and floriculture as well’ (see companion epamonitoring.net article ‘The Potential Differential Effects of Stricter EU False Coddling Moth Controls on African Export’, 19 March 2018). In the case of South Africa it is possible to carry the huge aggregate costs of compliance with EU SPS requirements because an agricultural systems approach has been adopted to control measures which spreads the financial burden across a number of large export sectors. The economic possibilities for implementing such comprehensive systems of SPS controls for single crops with limited export volumes are extremely limited.Thus in the mango sector if the cut off point for commercially viable levels of exports were an industry wide revenues of €1 million, fully 62% of current ACP countries which have in recent years exported Guavas, mangoes and mangosteens to the EU market, would no longer be likely to engage in this trade. If the commercially viable cut-off point for industry revenues was €5 million fully 88% of current ACP countries which have in recent years exported Guavas, mangoes and mangosteens to the EU market would no longer be likely to engage in this trade.This highlights the importance of the issue of the SPS control regime which the UK plans to implement if it leaves the EU without a Brexit deal by the end of May 2019.Once the UK has left the EU customs union and single market the UK government may wish to pursue an SPS control regime which more accurately reflects the agro-climatic conditions in the UK. This would enable the removal or relaxation of current SPS controls where UK agro-climatic conditions make the application of more rigorous EU controls unnecessary and inappropriate (see companion epamonitoring.net article ‘Stricter Risk Assessments under New EU Plant Health Regulation Could Hinder ACP Exports’, 25 March 2019).This may be particularly relevant for EU regulations which only come fully into force after the UK has formally left the EU customs union and single market under a no deal Brexit outcome to the current negotiations (see companion epamonitoring.net article, ‘Brexit Delayed but No Deal Brexit Still on the Table’, 25 March 2019). If the application of UK SPS controls were to diverse, based on the specific agro-climatic conditions in the UK, rather than pan-EU single market agro-climatic concerns, then this would maintain possibilities for continued mango exports to the UK market for smaller scale ACP producers. This needs to be seen in the context of DEFRA’s current risk assessment of Tephritidae (5). As an integral part of ongoing ‘Continuity Agreement’ negotiations this may require the concerned ACP governments to call for the establishment of a mechanism for the revision of UK SPS import requirements in areas where the specific agro-climatic conditions in the UK make redundant the application of controls currently required or scheduled for implementation under the EU’s new Plant Health Regulation. The proposed conclusion of an “Annex of Concerns” to each Continuity Agreement, which would cover all those areas of concern requiring additional measures and agreements to ensure continuity of export trade flows and continuity in the value of the tariff preferences could offer a vehicle for dialogue around these phytosanitary control related issues Of course such “Annex of Concerns” would also be integrated into Continuity Agreements which ACP governments have already concluded with the UK, with in the mango sector this being particularly important for the Dominican Republic in the context of the recently concluded UK-Caribbean Continuity Agreement. These options for a differentiated approach to phytosanitary control requirements for the UK and EU27 market will however be constrained for ACP exporters who have limited logistical connections to the UK market. Some West Africa exporters, such as those in Mali, only have direct European air freight connections to Charles De Gaulle airport in France for their Mango exports. Such exporters would have to comply with EU requirements even if the final destination were the UK market. This raises a broader issue for the UK, namely how to addressed the concerns of LDCs over the trade implications of increasingly strict EU phytosanitary controls, in a context where no economic partnership agreement with the EU is in place and hence no Continuity Agreement with the UK is under consideration. |
Sources:
(1) COLEACP, Important message to the competent authorities and operators involved in the Mango sector’, 8 March 2019
(2) COLEACP, ‘Fruit Fly’
https://www.coleacp.org/en/nos-programmes/fruit-flies
(3) COLEACP, ‘Fit for Market’
https://www.coleacp.org/en/nos-programmes/fit-for-market
(4) EC, Market Access Data Base
http://madb.europa.eu/madb/statistical_form.htm
(5) DEFRA, ‘UK Plant Health Information Portal – Tephritidae’
https://planthealthportal.defra.gov.uk/data/?q=Tephritidae