in the food and agriculture industries” with the aim of ensuring “a more consistent approach to official controls” throughout the food and agriculture sector. According to the reports on The Crop Site, “the changes are also intended to support more sustainable and effective control systems across European Union (EU) member states.”
The proposed changes “will reduce the legislation from approximately 70 pieces to five”, with risk-based assessments allowing a better targeting of controls. The proposals include “a change to the way official controls are funded”. Under the Commission’s proposals, “member states would be expected to recover the full cost of official controls,” with this resulting in “a major increase in the number of controls subject to mandatory charging”. Current EC proposals “include detailed measures for the calculation of fees”, including a mandatory exemption for micro-businesses (defined as businesses that employ “less than 10 people, with a turnover of less than €2 million”) from fees, but not from controls. This is in recognition of the impact such fees could have on the competitiveness of microenterprises. It forms part of a more general flexibility for microenterprises within the EU.
Significantly, the proposed changes all affect “procedures and management of import controls across the plant, animal, feed and food chains”, with an expectation that these import controls will be “simplified and harmonised under the changes”.
The proposed regulatory changes are at an early stage in the approval process and, due to the complexity of the package of proposed changes, “voting is not expected to take place until late 2014.”
While the nominal aim of the EC proposals is simplification, the cost recovery component cannot be overestimated, given the financial crisis facing many EU governments. There is likely to be strong pressure from the EU farming lobby to ensure that any expansion of mandatory controls, and any moves towards full cost recovery for official food safety and sanitary and phytosanitary (SPS) controls carried out, are applied equally to imported food and animal products. Any such application of full cost recovery for official controls on imports from ACP countries could fall particularly heavily on those ACP exporters with limited overall export volumes and on those ACP countries seeking to develop new exports, where export volumes still need to be built up.
Against this background, it would appear to be important for ACP exporters of plant and animal products to ensure that any exemptions applied to EU micro-businesses from the principle of full cost recovery are extended to ACP exporters, particularly in LDCs, but also in sectors and products where export diversification is in progress.
Given the lengthy process of approval through which the current proposals will need to go, there would appear to be time for a concerted ACP initiative in this area.