This week, the European Union’s (EU) Standing Committee on Plant, Animal, Food and Feed (SCOPAFF) will discuss and, possibly vote on, new and arguably misinformed regulations on False Coddling Moth (FCM) which pose a major threat to Southern African orange exports.
If agreed to by member countries, these new regulations will have a devastating impact on orange exports from South Africa to the region. This could lead to large gaps in the supply chain and higher prices for European consumers, at a time when the region faces the real risk of food insecurity due to the ongoing Ukraine-Russian conflict. In South Africa, these new regulations will put the sustainability of the industry at risk and the 140 000, mostly rural, jobs it sustains.
The proposed legislation requires exporting African countries to implement a drastic mandatory cold treatment (0°C to -1°C for at least 16 days) for oranges headed to the region. This is despite South Africa enforcing a rigorous risk management system, which has been highly effective in protecting European production from the threat of pests or disease, including FCM, over the past few years.
In this regard, when it comes to the 800 000 tonnes of citrus imports to the EU annually, FCM interceptions have been consistently low over the past three years – 19 (2019), 14 (2020) and 15 (2021) interceptions respectively. South Africa has also disputed six of its reported EU interceptions during last year’s season, as the overwhelming expert scientific reviewed evidence indicates the larvae reported was dead, which means it posed no risk.
This is in stark contrast to FCM interceptions from other 3rd importing countries, which have been much higher - with 53, 129 and 58 interceptions over the same period. Yet no measures have been proposed against these countries, which makes the new regulations proposed against South Africa even more inexplicable.
These proposed new regulations are also disproportionate and unfeasible for the following reasons:
When it comes to South African conventional oranges, only a portion of the crop will be able to withstand the new prescribed cold treatment temperatures. Furthermore, new provisions on the regulations which require “data loggers” from containers and a “measured pulp temperature threshold” are totally different to the current EU accepted FCM risk management system. These will require specialised and severely short supplied container equipment which will not be able to accommodate the huge volumes of fruit exported from South Africa to the EU.
The mandatory cold treatment will also put a stop to all exports of organic and “chem-free” [non-treated] oranges to the EU including several popular varieties such as blood oranges, Turkey, Salustiana, Benny and Midknights. This is due to these products simply not being able to withstand the suggested cold treatment. Yet, these environmentally friendly and sustainable orange types have never recorded a FCM interception.
Furthermore, no consultation took place with the South African National Plant Protection Organisation (NPPO) prior to these new regulations being filed at the World Trade Organisation on 10 February 2022. This is in stark contrast to the EU’s normal operation where issues or concerns on plant health mitigation would be bilaterally discussed and practical options or procedures to mitigate risk considered and agreed for inclusion.
The fact that this proposed legislation was put forward, despite alternative and equally effective cold treatment options being available and which have already been provided for in the South African FCM Risk Management System, indicates that this it is being driven by a political agenda
It is for these reasons that interest groups, including growers in Southern Africa and importers from a number of EU countries such as the Netherlands, Germany, Belgium and France, lodged objections to the proposed regulations during the recent EU “Have your Say” public participation process. In total, a record 164 submissions were made, with 90% of these objecting the proposed regulations.
The CGA has also been meeting with member countries to highlight the threat these unwarranted regulations pose to the continuity of orange imports from South Africa, the year-round availability for EU consumers and the 140 000 jobs the local industry sustains. We hope sanity will prevail during SCOPAFF deliberations this week and these new regulations are rejected.
For more information:
Nicole Mirkin
Tel: +27 84 552 3122