The EU Food and Veterinary Office (FVO) has published the report of its inspection of the Kenyan system of official controls of exports of plants and plant products. The inspection took place in November 2013 and “was undertaken due to the continued interceptions of harmful organisms in consignments of plants exported from Kenya to the EU”. The report covered:
- a review of the overall system of control;
- Kenya’s plant health status;
- export procedures;
- export inspections;
- procedures for issuing phytosanitary certificates; and
- actions taken in response to findings of non-compliance.
This was the third such audit, and it found that the Kenyan Plant Health Inspection Service (KEPHIS) “has taken steps to strengthen the system of export controls for plants and plant produce exported to the EU and to address the shortcomings identified during the previous FVO audit”. The inspection also found “a number of significant shortcomings” in the implementation of official controls regarding “official checks carried out at the main point of exit and at places producing plants for planting for export to the EU”. However, it was considered that “the biosecurity and pest management measures applied by producers of plants for planting and cut flowers should mitigate the risks for these commodities”. Overall, the report found that in view of the shortcomings identified, “the risk of further interceptions of harmful organisms on other commodities remains high”, with no change in the status of the main harmful organisms of concerns since the previous audit.
The FVO found Kenya’s export procedures in line with relevant international standards and “largely unchanged” since the previous audit. It recommended more lengthy pre-export checks at the airport facilities, and that a specific work plan for inspections of plants for planting be drawn up.
In terms of inspections, the FVO considered that the level of resources currently allocated to performing checks was not sufficient to “ensure that the planned checks may be completed, or that appropriate checks can be, and are carried out, for all lots of regulated plants and plant produce”. It was considered that greater priority should be accorded to “a more intensive check on high-risk commodities”, with checks being reduced on low-risk products.
The issuing of phytosanitary certificates was held to be “in line with relevant international standards and EU requirements”, and the report noted that systems had been strengthened since the previous FVO visit.
In responding to non-compliance, the report noted that KEPHIS follows up with producers, and where appropriate remedial actions are not taken, suspends the issuing of phytosanitary certificates.
The FVO report comes at a time when Kenya’s earnings “have remained flat over the years while cost of labour, equipment and inputs continues to soar”. An article in Business Daily Africa reported that earnings from Kenyan horticulture exports have dropped for the third consecutive year, falling by 7.2% in 2013 (from KSh89.9 billion to KSh83.4 billion). Earnings from cut flowers fell by 13.9% (from KSh65 to KSh56 billion) and fruit exports dropped by 4.4% (to Sh4.5 billion). More positively, earnings from vegetables grew by 10.4%, to KSh23.3 billion.
Clearly, efforts need to be intensified to strengthen the ability of producers and other value chain actors, in a cost-effective manner, to comply with required standards. This is an important area for “aid for trade” support, given the financial pressures on Kenyan exporters arising from increased costs of inputs and Kenyan official controls, in a context of prices that have not risen in the past 4 years.
At the same time as Kenya is working to improve its official controls, the EU is moving towards full recovery of inspection costs and is broadening official controls at member state level and proposing to generalise this across the EU (see Agritrade article ‘ New EU food and feed controls to include full cost recovery’, 7 July 2013). These moves could further add to cost challenges in the coming years.
Yet, it is recognised that the biosecurity and pest management measures applied by producers for some products mitigate shortcomings in official control systems. This raises the question of whether greater recognition could not be given to risk mitigation arising from private sector controls when determining the level of official controls – and hence inspection charges – levied on imports into the EU.
There is already a unofficial precedent for this in the UK’s Assured Trader Scheme (ATS), “which recognises the high standards of reputable traders” by reducing the levels of inspection (see Agritrade articles ‘ Call for early action to ease controls on DR banana exports’, 27 September 2010 and ‘ UK government economy measures could raise costs of horticultural imports’, 7 January 2012). A case would appear to exist for exploring the formal incorporation of this approach into pending EU legislative proposals for the revision of EU official food and feed controls. This could form part of a broader package of EU measures (including “aid for trade” support to defray inspection costs of new exporting countries that have no track record for risk assessment), designed to ensure that full recovery of inspection costs and stricter enforcement of import inspection regimes do not undermine the commercial viability of established and emerging ACP horticultural exporters.