In the wake of the United States formally acknowledging that citrus fruit is not a pathway to citrus black spot transmission, the South African citrus industry has said that its CBS risk mitigation measures in compliance with EU legislation has been remarkably successful, and yet "still it seems that something is amiss".In a newsletter to the industry, Deon Joubert, Citrus Growers Association special envoy for market access and the EU, writes: “The current EU legislative [Regulation 2016/2031, Article 41, 42 & 70] proposals and push towards “added protection” against “high risk imported plant products”, are now at a stage where consequences are becoming nonsensical. Importantly South Africa is no longer alone in confronting increasing protective EU measures on existing trade. All other plant and plant products from importing third countries are affected and South Africa should get involved.”
In the context of an eroding global free trade environment and looming trade wars, the South African citrus industry is taking issue with the European Union’s expanding quarantine list. New Plant Health legislation, to come into force at the end of 2019, is currently drafted.
According to the current EU stance, import consignments are innocent until proven guilty, or “in” until they are deemed to be damaging to the EU plant health. There could be, the Citrus Growers Association claims, movement away from that stance, beginning with a working paper submitted by France late last year which advocates that all imports to the European Union have to be proven non-damaging à priori before being allowed in.
“In March 2018 the French circulated a more refined version on behalf of eight EU member states [France, Spain, Greece, Malta, Cyprus, Portugal, Italy, Austria], which has developed the “high risk products” into nine, which requires an evaluation or pest risk assessment with possible measures,” Deon Joubert writes. “Then an alternative list of five plant/plant products exists which demand certain requirements to be fulfilled prior to resumption of trade. None of these French position papers are EU Commission draft papers yet, but highly important for South Africa and will be discussed on 10 and 11 July in Brussels.”
He says that such a move could potentially eliminate 12 to 16 billion euros of EU trade.
“Harmonisation of all EU member countries’ plant health policy into a single coherent regime is virtually impossible”
It has been suggested that the large number of non-compliances – of which only 2,500 (a third of the annual number) are phytosanitary non-compliances, the rest relating to packaging and documentation – are evidence that EU legislation is either too restrictive or impractical and officials are unable to enforce its own legislation in a manner that deters repeat non-compliances.The example of protecting the mango production of Malaga in Spain, illustrates the balancing act that will increasingly face the EU when deciding on a high risk fruit like the mango. “Under the new legislative measures considered, it could suggest that in future all imported mangoes must be banned, or treated to address possible risks to these small amount of growers in a far corner of Europe,” he writes. “This by pitting the perceived value and rights of a very small group of mango growers in a corner of Europe against the EU consumers and other world production.”
He continues: “The right of the EU to protect the plant health regime on their borders is not questioned, but unfortunately in the expansion of EU membership, the plant health situation and regimes amongst EU member states are often more diverse than that between EU and non-EU countries. So to harmonise all EU member countries’ plant health policy into a single coherent regime is virtually impossible.”
South African citrus don’t get near European orchards
The Citrus Growers Association points out that after a great year regarding CBS interceptions in 2016, with only four interceptions or 99.977% compliance, last year there were 23 interceptions which, given the volumes sent to Europe, still translated to 99.883% compliance and for a drop of 0.094% South Africa was nevertheless still on the receiving end of “the wrath of the EU”.
“These interceptions happened in Rotterdam [a good 1800 km away from Valencia where the majority of Spanish citrus orchards are] and hopefully all on route to supermarket programmes and shops – nowhere near orchards. The only South African citrus that can get near to Spanish orchards would be if Spanish growers/packers truck South African citrus there from across Europe to repack. The current SA voluntary grower avoidance of Spanish harbours is still in place, although the Spanish industry are pleading that South Africa resumes exports to Spanish ports.”
“The road ahead is clear – South Africa has to further develop and demonstrate through creative closed systems [not open markets] that its citrus supply lines pose a virtual zero risk to any citrus orchards in the EU – perhaps change the narrative from 100 % compliance to a well-managed virtual zero which is practically sustainable.”
He again points out that South African citrus has been exported to Europe for a century without the citrus black spot fungus establishing itself there.