mr - European Commission

In response to information provided by the competent authority, any factual error noted in the draft report has been corrected; any clarification appears in the form of a footnote.

EUROPEAN COMMISSIONDIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY

Health and food audits and analysis

DG(SANTE) 2016-8806 - MR

FINAL REPORT OF AN AUDIT

CARRIED OUT IN

UGANDA

FROM 06 SEPTEMBER 2016 TO 15 SEPTEMBER 2016

IN ORDER TO

EVALUATE THE SYSTEM OF OFFICIAL CONTROLS FOR THE EXPORT OF PLANTS AND PLANT PRODUCTS TO THE EUROPEAN UNION

Ref. Ares(2017)647054 - 06/02/2017

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Executive Summary

This report describes the outcome of an audit carried out by the Directorate General for Health and Food Safety of the European Commission in Uganda from 6 to 15 September 2016. The objective of the audit was to evaluate the system of official plant health controls for the export of plants, plant products and plants intended for planting to the European Union (EU).

The production system for plants for planting, vegetables, herbs and cut flowers to be exported to the EU is aimed at minimising pest presence. With considerable efforts, the growers of plants for planting and roses are able to keep the risk of presence of harmful organisms in the export consignments very low.

Uganda has an established plant health system with an appropriate legal framework. In recent years, the National Plant Protection Organisation (NPPO) introduced several additional measures, which improved the system of official phytosanitary controls. Although the inspectors are experienced and well-trained, severe staff shortages prevent the NPPO from running an official export control and certification system fully in line with EU requirements.

Official controls are carried out in greenhouses, at pack houses and at the airport, however their scope and frequency are not in line with EU requirements. Phytosanitary certificates are issued for consignments after inadequate or in many cases without official inspections.

The NPPO requires growers and pack houses to operate a system of own phytosanitary inspections during cropping, harvest and packing and considers these private inspections to be part of the official control system. Although the NPPO to some extent audits, supervises and verifies these private activities, they cannot replace official inspections, in particular due to the potential conflict of interest.

As comprehensive information is not available about the absence/distribution of certain harmful organisms of EU concern in Uganda, certain statements included on Ugandan phytosanitary certificates cannot be considered as reliable.

Although the current inspection system is not compliant with EU requirements, the recent efforts for its improvement have resulted in a low number of EU interceptions of plants for planting and cut roses. A similar system, which is being developed and implemented for fruits and vegetables, has not yet provided similar results.

The report contains recommendations to the NPPO of Uganda to address the shortcomings identified.

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Table of Contents1 Introduction ....................................................................................................................................12 Objectives and scope......................................................................................................................13 Legal Basis .....................................................................................................................................1

3.1 Relevant EU Legislation..........................................................................................................13.2 International standards.............................................................................................................2

4 Background ....................................................................................................................................24.1 Audit series ..............................................................................................................................24.2 Production and trade statistics .................................................................................................24.3 EU interceptions ......................................................................................................................3

5 Findings and Conclusions ..............................................................................................................45.1 Production system of plants and plant products ......................................................................45.2 Organisational aspects of the plant health controls .................................................................65.3 Phytosanitary status of harmful organisms relevant for EU export ......................................105.4 Export control system............................................................................................................145.5 Phytosanitary certificates.......................................................................................................205.6 Actions taken in response to internal findings and EU notifications ....................................23

6 Overall Conclusions .....................................................................................................................247 Closing Meeting ...........................................................................................................................258 Recommendations ........................................................................................................................25

III

ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT

Abbreviation Explanation

CA Competent Authority

ConsignmentAs defined by ISPM 5: a quantity of plants, plant products and/or other articles being moved from one country to another and covered, when required, by a single phytosanitary certificate

DG Health and Food Safety European Commission's Directorate-General for Health and Food Safety

EU European Union

EUROPHYT European Union Notification System for Plant Health Interceptions

EUROSTAT EU Statistical Office

HO Organism, harmful to plants or plant products (harmful organism) as defined by Article 2(1)(e) of Council Directive 2000/29/EC

IPPC International Plant Protection Convention

ISPM International Standards for Phytosanitary Measures

MAAIF Ministry of Agriculture Animal Industry and Fisheries

MS Member State of the European Union

NPPO National Plant Protection Organisation

MS Member State of the European Union

PC Phytosanitary certificate, as defined by ISPM 7 and ISPM 12

Plants for plantingPlants, intended for planting, as defined in Article 2(1)(d) of Council Directive 2000/29/EC - plants which are already planted or which are not planted but are intended to be planted

PlantsOther plants and plant products as defined in Article 2(1)(a and b) of Council Directive 2000/29/EC - living plants and parts thereof including leaves and fruit and products of plant origin, unprocessed or having undergone simple preparation.

Regulated (harmful organism/plant/plant product)

As listed in Annex I and II (harmful organisms) and Annex V (plants or plant products) to Council Directive 2000/29/EC.

SOPs Standard Operating Procedures

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1 INTRODUCTION

This audit took place in Uganda from 6 to 15 September 2016 and was undertaken as part of the planned audit programme of the Directorate General for Health and Food Safety of the European Commission (DG Health and Food Safety). This was the first plant health audit by the Commission services in Uganda.

The audit team consisted of two auditors of the DG Health and Food Safety and one national expert from a European Union (EU) Member State (MS). Representatives of the Ministry of Agriculture Animal Industry and Fisheries (MAAIF) accompanied the audit team during the audit.

An opening meeting was held on 6 September 2016 in Kampala, during which the objectives and itinerary for the audit were confirmed and additional information necessary for the conduct of the audit was requested.

Unless specified otherwise, the data quoted in the following sections and elsewhere in the report, was provided by the National Plant Protection Organisation (NPPO) of Uganda.

2 OBJECTIVES AND SCOPE

The objective of the audit was to evaluate the system of official plant health controls for the export of plants, plant products and plants intended for planting (plants for planting) to the EU. To meet the objective the following meetings and visits were carried out:

Meetings, visits No. Comments

Competent Authorities Central 2

MAAIFNPPO

At producers, pack houses 7 Producers of plants for planting, roses, vegetables

and herbs, export pack houses for vegetablesPlant health control sites

At the border 2 Entebbe International Airport - two cargo handling centres

Plant health laboratory 1 Plant Health Laboratory Namelare

3 LEGAL BASIS

The audit was carried out under the general provisions of EU legislation, in particular Articles 21 and 27(a) of Council Directive 2000/29/EC, and in agreement with the NPPO.

3.1 RELEVANT EU LEGISLATION

Council Directive 2000/29/EC provides for protective measures against the introduction into and spread within the EU of organisms harmful to plants or plant products (HOs). The legal reference for this Directive and other relevant EU legislation is listed in Annex 1.

References to EU legislation are to the latest amended version, where applicable.

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3.2 INTERNATIONAL STANDARDS

Article X (4) of the International Plant Protection Convention (IPPC) establishes that contracting parties should take into account, as appropriate, international standards when undertaking activities related to the Convention. The International Standards for Phytosanitary Measures, (ISPMs) issued by the IPPC provide a basis, in addition to the EU import requirements, for evaluating official export controls in contracting parties.

The full text of the IPPC and of all adopted ISPMs is available on the IPPC website (www.ippc.int). The ISPMs of particular relevance to this audit are listed in Annex II.

4 BACKGROUND

4.1 AUDIT SERIES

4.1.1Export controls in non-EU countries

The DG Health and Food Safety carries out continuous assessment of the plant health risk related to the import of plants, plant products and other objects to the EU. The interceptions reported by MS and Switzerland to the EU Notification System for Plant Health Interceptions (EUROPHYT) are analysed together with other available relevant information (e.g. trade statistics). Since 2014 a monthly Alert List is published, which indicates combination of countries, groups of commodities and HOs with interceptions above a defined level in an annual period preceding the date of publication. Audits are planned to those countries, where the interception figures raise doubts that the official export controls carried out by the NPPO of the exporting country ensure full conformity with EU import requirements. The audit to Uganda was carried out due to the total number of interceptions with HOs and especially of chillies since 2014 (see chapter 4.3).

4.1.2 Plants for planting and seeds

In 2015 the DG Health and Food Safety launched an audit series in non-EU countries which export the largest volumes of plants for planting and seeds to the EU, on the export plant health controls of these commodities. This was the sixth audit of the series.

Plants for planting are generally considered as high-risk products from a plant health point of view. They provide a viable pathway for HOs, since they are grown after entry to the EU or serve as propagating material rather than being consumed shortly after they are imported. Council Directive 2000/29/EC requires that each consignment of plants for planting has to be accompanied by a phytosanitary certificate (PC). For many plant species and commodity types specific conditions are set, usually in the form of options, depending on the plant health status of the country, the area, the place of production and the specific HO(s) of concern to the EU. The NPPO of the exporting country shall certify on the PC in the form of an additional declaration the chosen option and that the required conditions are met.

4.2 PRODUCTION AND TRADE STATISTICS

Figures in Table I and Table II indicate production areas, total production volumes and EU export volumes in the period of 2011-2015 of the main Ugandan commodities, which were subject to the audit.

http://www.ippc.int

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Table I. Production areas and volumes (2011-2015),

2011 2012 2013 2014 2015Commodity Area

(ha)Volume (tons)

Area (ha)

Volume (tons)

Area (ha)

Volume (tons)

Area (ha)

Volume (tons)

Area (ha)

Volume (tons)

Plants for planting 95 1,551 95 2,003 95 2,646 95 2,051 98 2,093

Roses 154 4,214 154 4,441 154 4,988 154 4,759 145 4,174Chillies 750 3,000 624 2,469 522 2,088 678 2,712 1,080 4,320Herbs 42 56.5 62.9 75 78Source: MAAIF

Table II. Ugandan export to the EU (2011-2015),

Export volume (tons)Commodity

2011 2012 2013 2014 2015Plants for planting 1,551 2,003 2,646 2,051 2,093Roses 4,214 4,441 4,988 4,759 4,174Chillies 1,895 1,812 1,580 1,477 1,325Eggplants 266 357 878 1,173 1,299Herbs 253 245 80 242 143

Source: MAAIF, UN COMTRADE Mirror statistics)

According to the EU Statistical Office (EUROSTAT) Uganda was the fifth largest exporter in 2015 of live plants (plants for planting) and cut flowers, supplying about 8% and 4% of the plants for planting and roses imported by the EU.

4.3 EU INTERCEPTIONS

In the period of 1 January 2012 – 31 August 2016, 412 interceptions of plants and plant products from Uganda with HO were reported to EUROPHYT. Chillies (Capsicum spp.) with false codling moth (Thaumatotibia leucotreta) and non-European fruit flies (Tephritidae); roses (Rosa spp.) with Spodoptera littoralis and Thaumatotibia leucotreta, bitter gourds (Momordica spp.) with non-European fruit flies and fresh curry leaves (Murraya spp.) with Trioza erytreae were the most intercepted. Although mangoes are not exported to the EU in commercial volumes, there were interceptions with Sternochetus spp. and non-European fruit flies. Although the export volume is high, only three consignments of plants for planting were intercepted with HO since 2012

The number of interceptions of roses with HOs decreased significantly in 2015. This trend continued in 2016. On the other hand, frequent interception of chillies with HOs started in 2014 and the level has been continuously high since. Bitter gourd interceptions started in 2015. Curry leaf consignments were intercepted mainly in 2014.

Since 2012, 121 consignments of plants and plant products were intercepted due to plant health reasons other than the presence of HOs. The majority of the cases related to missing, inadequate or invalid additional declarations on the PC. In the period 2014-2016 fresh curry leaves were also intercepted, as their import is permitted only from countries, which are recognised by the European Commission as free from citrus greening disease. This is not the case for Uganda (see chapter 5.6.2).

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Table III. Interceptions of consignments from Uganda, reported to EUROPHYT

Interception reason 2012 2013 2014 2015 2016 (1/01 - 31/08)

Presence of HOs (total) 24 52 112 130 86 Capsicum spp. 0 8 65 91 65 Rosa spp. 18 37 18 4 3 Murraya spp. 0 0 20 3 6 Momordica spp. 0 3 0 18 4 Mangifera spp. 2 0 2 4 3 Plants for planting 0 1 0 2 0Other than HO presence 29 22 25 20 22 Prohibited plants 2 1 0 6 7 Additional declaration inadequate, invalid, missing 24 18 20 12 17

Further information on EUROPHYT and summaries of interceptions, are available on DG Health and Food Safety website: http://ec.europa.eu/food/plant/plant_health_biosafety/europhyt/index_en.htm

In the period 2014 - 2016, Commission services sent several warning letters to the NPPO, due to the high number of interceptions, mainly roses with Spodoptera littoralis, chillies with Thaumatotibia leucotreta and fresh curry leaves with Trioza spp. Investigation of the reasons for and actions to deal with the issues were requested. Uganda submitted an action plan in response to this request which was updated taking into consideration the new developments. The NPPO introduced specific measures including a temporary ban on the chilli export (see chapter 5.4).

5 FINDINGS AND CONCLUSIONS

5.1 PRODUCTION SYSTEM OF PLANTS AND PLANT PRODUCTS

Legal requirements Annex IV, Part A Section I to Directive 2000/29/EC, Points which are relevant to the products currently exported by Uganda are 18.1, 27.1, 27.2, 28, 28.1, 32.1, 32.2, 32.3, 36.1, 36.2, 41, 42, 44, 45.1, 45.2 and 46.

ISPM 5 and ISPM 36.

Findings

5.1.1 Plants for planting

1. Uganda exports mainly unrooted cuttings to the EU. Some companies deliver limited amounts of rooted bedding plants without growing medium. Many plant genera, species and varieties are produced; the most important genera are Aster, Begonia, Bouvardia, Celosia, Chrysanthemum, Euphorbia, Hedera, Hydrangea, Impatiens, Pelargonium and Vinca.

2. The cuttings are produced and exported by a small number of specialised farms in insect screened greenhouses. However, full insect proofing is achieved only in some greenhouses, which are used for keeping high value, susceptible stocks or for propagating high-grade, non-commercial stocks. Mother plants generally originate from breeders in the EU and arrive in-vitro or as unrooted cuttings. Sometimes high

http://ec.europa.eu/food/plant/plant_health_biosafety/europhyt/index_en.htm

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grade, EU origin breeding stocks are propagated in the neighbouring countries (Kenya, Ethiopia) before they arrive to Uganda as unrooted cuttings for the establishment of mother plant plantations. The imported mother plants are inspected upon arrival by the NPPO according to Ugandan import rules.

3. The audit team visited growers of cuttings and noted that: Certain harmful organisms are common in the vicinity of the production areas, such

as Bemisia tabaci, Liriomyza spp., Spodotera spp. and Helicoverpa spp; The growers apply complex pest management systems with high frequency pesticide

application combining scheduled and pest finding (scouting) based treatments. With this approach the growers can ensure that HOs occur in the crops only occasionally and at low level (see chapter 5.4.2)

5.1.2 Production of vegetables and herbs for EU Export

4. The main EU export item is chillies (Capsicum spp.); different types (e.g. bird eye, habanero) are produced for the EU market. Uganda exports a range of other vegetables and herbs such as eggplants (Solanum melongena and S. aethiopicum), bitter gourds (Momordica spp.) and basils (Ocimum spp.).

5. The vegetables and herbs are generally produced in open fields, by a few large producers and by hundreds of small farmers. The harvested vegetables and herbs are prepared for export and packed by a limited number of pack houses. In some cases independent exporters are also involved. Some pack houses have their own core farms, but generally the produce comes from numerous small and medium size contracted farmers. Sometimes the produce is also collected from non-contracted farmers.

6. Since 2014 the NPPO requests pack houses to introduce specific measures, in order to produce goods which fulfil EU import requirements. Many pack houses have already introduced these measures and in particular they put specific emphasis on tightening relations with the growers. In 2016 the majority of vegetables were supplied by growers to pack houses according to production contracts. The contracted farmers receive advice and training in pest control during the production and about recognising pests in the harvested goods.

7. The audit team visited pack houses and noted that they: Received comprehensive information and training from the NPPO about the EU

import requirements and advise about the best possible ways to meet those requirements;

Had introduced a system, which makes it possible to trace products back to the farm from any stage of the packing. The grower always receives feedback about any pest finding during sorting and inspections carried out by the pack house or NPPO inspectors;

Provide training and technical advice to the farmers. Some of them operate model farms for training purposes. Their efforts concentrate on chillies, false codling moth and fruit flies;

The false codling moth in widespread in the country. Its infestation in chillies generally does not cause clearly visible symptoms in the field because the larvae live hidden inside the fruit. Chillies are harvested continuously providing limited possibilities for chemical control. The presence of eggs and larvae is difficult to detect during the harvest and packing, even for personnel, who are well-trained in the biology of the pest and the symptoms of infestation (see chapter 5.4.2).

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5.1.3 Production of cut flowers for EU export

8. Practically all cut flowers exported to the EU are roses. They are produced and exported by a limited number of specialised, large or medium size farms in greenhouses, which are not insect proof. Growers apply a wide range of measures to minimise the presence of harmful organisms at the production site and concentrate on controlling Spodoptera spp., Helicoverpa spp. and Thaumatotibia spp. moths. In order to control these pests effectively and efficiently the crop is regularly scouted. In addition to the high frequency, programmed and finding based pesticide applications in and around the greenhouses, mechanical control (light trapping, sentinel/trapping plants, destruction of infested plant parts) is also used. Despite these measures the pests are usually present, although with low prevalence in the crop. Therefore strict control during the harvest and packing is necessary (see chapter 5.4.2).

9. The audit team visited rose growers and noted that: Based on an agreement between the NPPO and the Uganda Flower Exporters

Association, each rose farm applies a comprehensive pest control and inspection system;

The farms introduced measures as recommended by the NPPO. The crop is regularly scouted by sufficiently trained personnel of the farm during the growing period and before harvest and based on the findings, chemical and mechanical measures are applied. Any rose bud with insect damage is removed and destroyed. During harvest and packing the companies apply a strict inspection and control system and also mechanical treatment (tapping the bunches) to find and remove hiding larvae.

Conclusions on production system of plants and plant products

10. The production system of plants for planting, vegetables, herbs and cut flowers is aimed at minimising pest presence in the crop. Measures concentrate on HOs of EU concern. The efforts ensure that HOs are only present occasionally and always at a low level in the crops of plants for planting. This is difficult to achieve for the other export crops.1

5.2 ORGANISATIONAL ASPECTS OF THE PLANT HEALTH CONTROLS

Legal requirements Article 2(1)(i) of Directive 2000/29/EC.

Article IV of the IPPC.

ISPM 7, in particular provisions on resources, infrastructure and communication.

1 In their response to the draft report the Competent Authority noted that it is still difficult but achievable to ensure that HOs are only present occasionally and at low level in fruit and vegetables in the crops.

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Findings

5.2.1 National plant protection organisation

11. Uganda is a contracting party to the IPPC since 2007. Pursuant to the Plant Protection and Health Act of 2016, the NPPO is the Department of Crop Protection of MAAIF. It is the Competent Authority (CA) for plant health and headed by a Commissioner. The Commissioner supervises the activities of the Phytosanitary and Quarantine Services, which belong to MAAIF and is headed by an Assistant Commissioner. Export related inspections are carried out by inspectors working for the Phytosanitary and Quarantine Services.

12. The Department of Crop Inspection and Certification of MAAIF has shared responsibility with the Department of Crop Protection in drafting legislation, enforcement of phytosanitary standards and promotion of awareness of regulations, laws and policies governing official controls. Inspectors working for this department also carry out EU export related plant health inspections. The two MAAIF departments belong to the Directorate Crop Resources.

5.2.2 National legislation

13. The Plant Protection and Health Act (Act No 6 of 2016) provides for the legal basis for the phytosanitary controls in Uganda. It defines stakeholder obligations in preventing the introduction and control of pests, weeds and diseases; designates the NPPO; defines duties of the Commissioner for Crop Protection; authorises and empowers NPPO inspectors for implementing and enforcing the Act. Certain provisions of the Seed and Plant Act of 2006, the Agricultural Chemicals Control Act of 2006 also relate to plant health activities.

14. The Minister of MAAIF is empowered to implement the provisions of the Act by statutory instruments (regulations). These describe in detail the powers and tasks of the inspectors, the PC issuance process and plant health responsibilities of growers, pack houses, traders, exporters and forwarders. Statutory instruments deal with enforcement issues such as offences and penalties. The audit team was informed that the statutory instruments also take into consideration plant health requirements and guidelines as laid down in the ISPMs and EU legislation.

15. The audit team noted that NPPO inspectors are duly authorised by the law to carry out EU export related inspections at the production site during the growing period and on the consignment at the stakeholders' premises or at the border. They are empowered to initiate sanctions in the case of identified non-compliances, such as refusing the export or ordering appropriate corrective actions.

5.2.3Resources

16. Border control inspectors, quarantine inspectors and principal inspectors are public servants and work either for the Phytosanitary Service or for the Quarantine Service of the Department of Crop Protection of MAAIF.

17. At the time of the audit there were 25 NPPO phytosanitary inspectors in Uganda. Their official portfolio also includes other, non-plant health tasks. The minimum education requirement is a Bachelor of Science in agriculture or equivalent. The audit team noted

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that the current number of inspectors is not sufficient to carry out official export inspections according to the EU requirements and international rules (see chapters 5.4 and 5.5). The NPPO stated that action is being initiated to eliminate the staffing gap and improvement is expected soon.2

18. The audit team noted that plant health inspectors at the border or working with growers and pack houses are responsible for issues coordinated and supervised by the NPPO as well as by other departments of the MAAIF. Therefore conflicting priorities may influence their export inspection activity.

19. The audit team noted that the plant health inspectors they met: Had appropriate educational and training backgrounds; Were experienced in phytosanitary controls and in particular in visual pest

identification; Had good, sometimes very good knowledge of EU import requirements, however

they were not aware of all recent amendments of the EU legislation (see chapter 5.5.1);

Carried out their activity generally in line with the relevant MAAIF Standard Operating Procedures (SOPs), work instruction and manuals.

5.2.4 Guidelines and training

20. The NPPOs informed the audit team that currently 15 SOPs relate to the official control and more are under preparation. These provide step-by-step guidance for the official plant health activity. SOPs in force deal inter alia with pest diagnosis, pest risk analysis, handling of non-compliances, field inspections for plants for plantings, export inspection and certification, pest reporting, sampling, surveillance and monitoring.

21. Work instructions and manuals for inspectors provide for the detailed implementation of the technical aspects of the SOPs, including the inspection of chillies for fruit flies and false codling moths and the traceability of consignments.

22. The audit team checked some SOPs, work instructions and manuals relevant to EU export controls and noted that they: Were elaborated with assistance of international experts providing advice for

MAAIF; Contain very detailed and comprehensive descriptions including legal requirements,

inspection frequency, description of the pests and their symptoms, equipment, material and tools, documentary check, visual examination, sampling, official reporting and rejection procedure;

Are in line with the relevant ISPMs, in particular with provisions on sampling rates for inspection of a consignment as laid down by ISPM 31;

Take into consideration EU import requirements, in particular concerning the field inspection frequencies for certain types of plants for planting.

23. The NPPO informed the audit team that all staff involved in official plant health controls shall have basic training in pest identification, pest management, pest risk assessment, inspection and certification procedures, national policies, international and

2 In their response to the draft report the Competent Authority noted that coping plans are in place to boost staff levels including recruitment and redeployment of staff to perform official controls.

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bilateral agreements and relevant standards. Training of staff is an ongoing activity to enhance the capacity for improved performance in plant health controls.

5.2.5 Laboratories and technical support

24. The MAAIF Plant Health Laboratory provides analytical services for the NPPO, related to the export, import controls, internal quarantine and surveillance activities as appropriate. The work of the laboratory is supported by scientists of the National Agricultural Research Organisation in the form of training, consultation or validation of certain identification results.

25. The audit team visited the laboratory and noted that: The laboratory possesses basic facilities for morphological identification of harmful

organisms, relevant for EU, including conventional microscopy, sample extraction, insect rearing, bacteria and fungi cultivation;

The staff has experience in the identification of pests, which commonly affect crops in Uganda. They have some reference material or the possibility to contact other experts if specific needs arise;

Currently the laboratory is not capable of serological and molecular tests. Some equipment is lacking and the staff has no experience in this area. The audit team was informed that plans are underway to establish the relevant testing capacities with the support of government funds;

As the majority of the HOs related to the current exports of Uganda to the EU can be identified with morphological methods (except certain viruses in plants for planting) these shortcomings do currently not significantly prevent Uganda from meeting EU phytosanitary requirements (see chapter 5.4.2).

26. The National Agriculture Research Organisation, which is supervised by MAAIF provides support in diagnostics, pest risk analysis and surveillance, development of pest management and control strategies. They are also consulted on the technical aspects during legislative processes.

5.2.6 Communication and collaboration with stakeholders

27. The NPPO stated that communication channels to the relevant stakeholders include training workshops, awareness raising consultations, field visits, face to face meetings, telephone and e-mail contacts. The digital, printed and social media are used for distributing plant health information. Leaflets and bulletins are published with export related information. The MAAIF website covers phytosanitary issues.

28. The NPPO made specific efforts to establish close working relations with associations and professional organisations of producers and exporters of plants and plant products. Currently eight different organisations are involved. MAAIF considers this cooperation as a key element for operating a viable export system of plants and plant products.

29. The NPPO provides assistance in the development and upgrade of pest control and inspection strategies for the different sectors. The relevant associations and professional organisations made commitments to involve their members in the export related plant health activity through coordination, information flow and technical assistance, especially concerning: Pest control in the field;

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Pest monitoring in the crop (scouting); Inspection of plants and products during the packing; Identification of the causes and action against non-compliances; Supervision of the disposal of infested commodities; Establishing channels for up- and downstream information flow; Collection and transmission of relevant records for the NPPO (see chapter 5.4.2).

30. Based on an agreement concluded with the NPPO, the Uganda Flower Exporters Association carries out specific plant health tasks, such as: organising and coordinating farm inspections, collecting information on pest and monitoring traceability at farm level, enforcing phytosanitary measures, informing its members about plant health requirements of destination countries, creating awareness among stakeholders on key phytosanitary issues and conducting pest risk analysis and surveillance for the NPPO. All producers and exporters of plants for planting and roses is member of the organisation. The NPPO informed the audit team that similar agreements are under preparations with associations and organisations in the vegetable sector (see chapter 5.4.2).

31. Plant health inspectors maintain close contacts with the growers of plants for planting and roses and with the main pack houses and exporters of vegetables and herbs. They provide them relevant information and assist them in improving their pest control, inspection and advisory activities.

Conclusions on the organisational aspects of the plant health controls32. NPPO inspectors are duly empowered, work according to detailed written procedures

and have good knowledge of EU import requirements. However, the number of inspectors is not sufficient for official controls for the current level of EU exports and they are not aware of the latest amendments of the EU legislation.

33. The Plant Health Laboratory cannot provide comprehensive diagnostic services but it does not significantly prevent Uganda from meeting EU requirements for current exports.

34. The NPPO works closely with the industry in various sectors; collects and disseminates information and assists in the implementation of controls carried out by the industry. The NPPO largely relies on the industry in the practical implementation of the export controls.

5.3 PHYTOSANITARY STATUS OF HARMFUL ORGANISMS RELEVANT FOR EU EXPORT

Legal requirements Part A of Annex I, Part A of Annex II and Part A Section I of Annex IV of Directive 2000/29/EC.

ISPM 4, ISPM 6, ISPM 8, ISPM 10 and ISPM 17.

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Findings

35. MAAIF provided information on the pest status of HOs subject to EU import requirements. This is summarised in Tables IV and V.

Table IV. HOs listed in Annex I Part A of Council Directive 2000/29/EC, which are relevant for exports from Uganda to the EU

Harmful organism Status in Uganda

Insects, mites and nematodes, at all stages of their developmentAcleris spp. (non-European) AAgrilus anxius Gory AAgrilus planipennis Fairmaire AAnthonomus eugenii AAmauromyza maculosa (Malloch) AAnomala orientalis Waterhouse AAnoplophora chinensis (Thomson) AAnoplophora glabripennis (Motschulsky) AArrhenodes minutus Drury ABemisia tabaci Genn. (non-European populations) vector of viruses such as: Bean golden mosaic virus; Cowpea mild mottle virus; Lettuce infectious yellows virus; Pepper mild tigré virus; Squash leaf curl virus; Euphorbia mosaic virus; Florida tomato virus

D1

Bursaphelenchus xylophilus (Steiner and Bührer) Nickle et al. ACicadellidae (non-European) known to be vector of Pierce's disease (caused by Xylella fastidiosa), such as: Carneocephala fulgida Nottingham Draeculacephala minerva Ball Graphocephala atropunctata (Signoret)

AAAA

Choristoneura spp. (non-European) AConotrachelus nenuphar (Herbst) ADiabrotica barberi Smith and Lawrence ADiabrotica undecimpunctata howardi Barber Diabrotica undecimpunctata undecimpunctata Mannerheim ADiabrotica virgifera zeae Krysan & Smith ADiaphorina citri Kuway AHeliothis zea (Boddie) AGlobodera pallida (Stone) Behrens AGlobodera rostochiensis (Wollenweber) Behrens AHirschmanniella spp., other than Hirschmanniella gracilis (de Man) Luc and Goodey ALiriomyza sativae Blanchard F1Longidorus diadecturus Eveleigh and Allen AMeloidogyne chitwoodi Golden et al. (all populations) AMeloidogyne fallax Karssen AMyndus crudus Van Duzee ANacobbus aberrans (Thorne) Thorne and Allen ANaupactus leucoloma Boheman AOpogona sacchari (Bojer) APopilia japonica Newman APremnotrypes spp. (non-European) APseudopityophthorus minutissimus (Zimmermann) APseudopityophthorus pruinosus (Eichhoff) ARhynchophorus palmarum (L.) ARhizoecus hibisci Kawai and Takagi AScaphoideus luteolus (Van Duzee) ASpodoptera eridania (Cramer) D1Spodoptera frugiperda (Smith) ASpodoptera littoralis (Boisduval) ASpodoptera litura (Fabricus) AThrips palmi Karny ATephritidae (non-European) such as: Anastrepha fraterculus (Wiedemann); Anastrepha ludens (Loew) Anastrepha obliqua Macquart Anastrepha suspensa (Loew) Dacus ciliatus Loew Dacus curcurbitae Coquillet

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Dacus dorsalis Hendel Dacus tryoni (Froggatt) Dacus tsuneonis Miyake Dacus zonatus Saund Epochra canadensis (Loew) Pardalaspis cyanescens Bezzi Pardalaspis quinaria Bezzi Pterandrus rosa (Karsch) Rhacochlaena japonica Ito Rhagoletis cingulata (Loew) Rhagoletis completa Cresson Rhagoletis fausta (Osten-Sacken) Rhagoletis indifferens Curran Rhagoletis mendax Curran Rhagoletis pomonella Walsh Rhagoletis ribicola Doane Rhagoletis suavis (Loew)

D1AAAAAADAAAAAAAAA

Trioza erytreae Del Guercio XXiphinema americanum Cobb AXiphinema californicum Lamberti and Bleve-Zacheo A

BacteriaCandidatus Liberibacter spp., causal agent of Huanglongbing disease of citrus/citrus greening D1Clavibacter michiganensis (Smith) Davis et al. ssp. sepedonicus (Spieckermann and Kotthoff) Davis et al. AXylella fastidiosa (Well and Raju)

FungiCeratocystis fagacearum (Bretz) Hunt AChrysomyxa arctostaphyli Dietel ACronartium spp. (non-European) AEndocronartium spp. (non-European) AGuignardia laricina (Saw.) Yamamoto and Ito AGymnosporangium spp. (non-European) AInonotus weirii (Murril) Kotlaba and Pouzar AMelampsora farlowii (Arthur) Davis AMelampsora medusae Thümen AMycosphaerella larici-leptolepis Ito et al. AMycosphaerella populorum G. E. Thompson APhyloosticta solitaria Ell. and Ev. ATilletia indica Mitra ATrechispora brinkmannii (Bresad.) Rogers A

Viruses and virus-like organismsApple proliferation mycoplasma AApricot chlorotic leafroll mycoplasma AElm phlöem necrosis mycoplasma APear decline mycoplasma APotato viruses and virus-like organisms such as: Andean potato latent virus Andean potato mottle virus Arracacha virus B, oca strain Potato black ringspot virus Potato spindle tuber viroid; Potato virus T non-European isolates of potato viruses A, M, S, V, X and Y (including Y o , Y n and Y c ); Potato leafroll virus

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virus X DF1

Viruses and virus-like organisms of Cydonia Mill., Fragaria L., Malus Mill., Prunus L., Pyrus L., Ribes L.,Rubus L. and Vitis L., such as: Blueberry leaf mottle virus Cherry rasp leaf virus (American) Peach mosaic virus (American) Peach phony rickettsia Peach rosette mosaic virus Peach rosette mycoplasma Peach X-disease mycoplasma Peach yellows mycoplasma Plum line pattern virus (American) Raspberry leaf curl virus (American) Strawberry latent ‘C’ virus

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Strawberry vein banding virus Strawberry witches' broom mycoplasma Non-European viruses and virus-like organisms of Cydonia Mill., Fragaria L., Malus Mill., Prunus L., Pyrus L., Ribes L., Rubus L.

AA

Viruses transmitted by Bemisia tabaci Genn. Such as: Bean golden mosaic virus Cowpea mild mottle virus Lettuce infectious yellows virus Pepper mild tigré virus Squash leaf curl virus Euphorbia mosaic virus Florida tomato virus

Parasitic plantsArceuthobium spp. (non-European) A

Table V. HOs listed in Annex II Part A of Council Directive 2000/29/EC, which are relevant for exports from Uganda to the EU

Harmful organism Subject of contamination Status in Uganda

Insects, mites and nematodes, at all stages of their developmentAculops fuchsiae Keifer Plants of Fuchsia L., intended for planting, other than seedsDitylenchus destructor Thorne Flower bulbs and corms of Crocus L., miniature cultivars and their hybrids

of the genus Gladiolus, Hyacinthus L., Iris L., Trigridia Juss, Tulipa L., intended for planting,

Ditylenchus dipsaci (Kühn) Filipjev Seeds and bulbs of Allium ascalonicum L., Allium cepa L. and Allium schoenoprasum L., intended for planting and plants of Allium porrum L., intended for planting, bulbs and corms of Camassia Lindl., Chionodoxa Boiss., Crocus flavus Weston ‘Golden Yellow’, Galanthus L., Galtonia candicans (Baker) Decne, Hyacinthus L., Ismene Herbert, Muscari Miller, Narcissus L., Ornithogalum L., Puschkinia Adams, Scilla L., Tulipa L., intended for planting, and seeds of Medicago sativa L.

Enarmonia packardi (Zeller) Plants of Crataegus L., Photinia Ldl., L. and Rosa L., intended for planting, other than seeds, and fruit of Malus Mill., originating in non-European countries

Enarmonia prunivora Walsh Plants of Crataegus L., Photinia Ldl.. and Rosa L., intended for planting, other than seeds

Helicoverpa armigera (Hübner) Plants of Dendranthema (DC.) Des Moul, Dianthus L., Pelargonium l'Hérit. ex Ait., intended for planting, other than seeds

Radopholus citrophilus Huettel Dickson and Kaplan

Plants of Araceae, Marantaceae, Musaceae, Persea spp., Strelitziaceae, rooted or with growing medium attached or associated

Liriomyza huidobrensis (Blanchard) Plants of herbaceous species, intended for planting, other than: — bulbs, — corms, — plants of the family Gramineae, — rhizomes, — seeds

Liriomyza trifolii (Burgess) Plants of herbaceous species, intended for planting, other than: — bulbs, — corms, — plants of the family Gramineae, — rhizomes, seeds

Paysandisia archon (Burmeister) Plants of Palmae, intended for planting, having a diameter of the stem at the base of over 5 cm and belonging to the following genera: Brahea Mart., Butia Becc., Chamaerops L., Jubaea Kunth, Livistona R. Br., Phoenix L., Sabal Adans., Syagrus Mart., Trachycarpus H. Wendl., Trithrinax Mart., Washingtonia Raf.

Radopholus similis (Cobb) Thorne Plants of Araceae, Marantaceae, Musaceae, Persea spp., Strelitziaceae, rooted or with growing medium attached or associated

BacteriaErwinia amylovora (Burr.) Winsl. et al.

Plants of Amelanchier Med., Chaenomeles Lindl., Cotoneaster Ehrh., Crataegus L., Eriobotrya Lindl., Mespilus L., Photinia davidiana (Dcne.) Cardot, Pyracantha Roem. and Sorbus L., intended for planting, other than seeds

A

Erwinia chrysanthemi pv. dianthicola (Hellmers) Dickey

Plants of Dianthus L., intended for planting, other than seeds A

Pseudomonas caryophylli (Burkholder) Starr and Burkholder


Xanthomonas campestris pv. vesicatoria (Doidge) Dye

Plants of Solanum lycopersicum L. and Capsicum spp., intended for planting A

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Harmful organism Subject of contamination Status in Uganda

FungiCeratocystis platani (J. M. Walter) Engelbr. & T. C. Harr

Plants of Platanus L., intended for planting, other than seeds A

Diaporthe vaccinii Shaer Plants of Vaccinium spp., intended for planting, other than seeds ADidymella ligulicola (Baker, Dimock and Davis) v. Arx

Plants of Dendranthema (DC.) Des Moul., intended for planting, other than seeds A

Fusarium oxysporum f. sp. albedinis (Kilian and Maire) Gordon

Plants of Phoenix spp., other than fruit and seedsA

Phialophora cinerescens (Wollenweber) van Beyma


Puccinia horiana Hennings Plants of Dendranthema (DC.) Des Moul., intended for planting, other than seeds A

Viruses and virus-like organismsCadang-Cadang viroid Plants of Palmae, intended for planting, other than seeds, originating in

non-European countries A

Chrysanthemum stem necrosis virus Plants of Dendranthema (DC.) Des Moul. and, intended for planting, other than seeds A

Chrysanthemum stunt viroid Plants of Dendranthema (DC.) Des Moul., intended for planting, other than seeds A

Palm lethal yellowing mycoplasma Plants of Palmae, intended for planting, other than seeds, originating in non-European countries A

Tomato spotted wilt virus Plants of Apium graveolens L., Capsicum annuum L., Cucumis melo L., Dendranthema (DC.) Des Moul., all varieties of New Guinea hybrids Impatiens, Lactuca sativa L., intended for planting, other than seeds

A

For both tables: Source: MAAIFCategories: A – absent, no reports; B - Absent, confirmed by surveys;

C - Absent, occasional occurrences, eradicated; D- Present, widespread; D1 - Present, widespread, under official control; E - Present, limitedDistribution; E1- Present, limited distribution, under official control;F- Present, few reports; F1 - Present, few reports, under official control;X- Present, no distribution detailsBlank cells – MAAIF did not provide information

36. The NPPO stated that pests indicated as absent have never been intercepted and notified on any of Uganda’s export commodities. They have never been referred to as being present in Uganda in scientific publications either. Therefore the NPPO declared Uganda as free from them.

37. The NPPO also stated that the following pests, relevant to the EU exports, are subject to mandatory control programmes: Bemisia tabaci, Candidatus Liberibacter spp. Ceratis capitata Dacus ciliatus Dacus cucurbitae Dacus dorsalis, Liriomyza sativae, Spodoptera littoralis and Thaumatotibia leucotreta. When any of these pests are detected at export production sites by official or other controls, the grower is obliged to apply appropriate controls.

38. The NPPO collects pest related information from the growers during official inspections, via the associations or via the network of pest control advisors (mobile plant health clinics). The NPPO considers that production sites for plants for planting are free from pests regulated by the EU as these areas are constantly scouted by the growers and regularly inspected by the NPPO staff.

39. Research institutions, mainly in the framework of pest control programmes carry out general, pest related surveys in the major agricultural crops in the country. They do not focus on the HOs relevant for EU export and usually do not cover the entire territory of the country.

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40. The audit team could not be provided with detailed information concerning general and targeted surveys in Uganda on HOs, relevant for the EU. The team therefore considers that the information currently available for the NPPO cannot provide fully comprehensive information for the determination of the country's pest status.

Conclusions on phytosanitary status of HOs relevant for EU export41. As comprehensive surveillance based information is not available on the presence and

distribution of certain HOs, relevant for EU export, Uganda's declared pest status for these pests cannot be considered as fully reliable.

5.4 EXPORT CONTROL SYSTEM

Legal requirements Annex IV, Part A Section I to Directive 2000/29/EC. Points which are relevant to the products currently exported by Uganda are 18.1, 27.1, 27.2, 28, 28.1, 32.1, 32.2, 32.3, 36.1, 36.2, 41, 42, 44, 45.1, 45.2 and 46. Annex V, Part B to Directive 2000/29/EC.

ISPM 7, ISPM 23, in particular its chapter 1.4, ISPM 27, ISPM 31 and ISPM 36.

Findings

5.4.1 Registration of growers, packing houses and exporters

42. Growers and exporters of plants for planting and flowers and pack houses and exporters of fruit and vegetables are registered. The registration is valid for one year. The companies are obliged to introduce and operate a phytosanitary control system and provide certain information to the authorities (see chapter 5.4.2).

43. Exporters of plants for planting and cut flowers have to communicate information about the species and varieties, the production and packing sites for the registration. Approval is granted after a successful visit of NPPO inspectors to the production sites and packing areas.

44. Since 2014, specific measures were implemented, including a temporary export ban, to identify growers and packing companies involved in fruit and vegetables export. The collection centres and pack houses have already been identified. They are approved for export after a phytosanitary inspection.

45. The audit team noted that: Plants for planting and roses are exported by the growers themselves, therefore

detailed information is available for the CA about the growing and packing areas; The NPPO encourages pack houses of fruit and vegetables to establish production

contracts with their growers and to obtain information about the production areas; The majority of vegetables exported to the EU are produced either by the core farms

of the pack houses or by their contracted farmers. The volume of goods produced by non-contracted farmers is decreasing, for chillies at the time of the audit, this amounted to about 10%.

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5.4.2 Phytosanitary controls by operators

46. MAAIF requires and promotes active participation of the business operators in the phytosanitary controls of goods exported to the EU (see chapter 5.1).

47. Growers of plants for planting and cut roses apply a comprehensive crop inspection system. Some of their workers are specially trained for identifying pest symptoms. They carry out scheduled scouting with a frequency depending on the crop (daily or at least weekly), concentrating on the risky spots. Coloured sticky traps and pheromone traps are also used in the greenhouses. Checking their catch is part of the scouting. The results of the scouting are duly recorded. The general quality control system of the companies during harvest and export packing includes plant health inspections.

48. The audit team noted that: The scouts and are experienced, their work is supported by photographs and

information leaflets about the major HOs (insects) of EU concern and this material was available in the greenhouses;

In the case of pest findings, the common practice is to mark the infested spot and to apply extra local pest control. In certain cases the infested plants are destroyed. Cut roses with identified infestation or insect damage are always destroyed;

Growers of Chrysanthemum (Denranthema) spp. cuttings regularly sample the mother plants to test for viruses and virus like organisms, including Chrysanthemum stunt viroid. The sampling rate depends on the propagation grade. This varied between 1-100% at the companies visited. Test results are made available to the NPPO.

The company's quality control system includes different stages of inspection during harvest and packing. All consignments were inspected by dedicated company personnel. For cuttings the inspections mainly target Bemisia tabaci and Liriomyza spp., while for roses Spodoptera spp. and Thaumatotibia leucotreta. The system ensures with a high probability the absence of harmful insects in the consignment.

49. For "problematic" vegetables pack houses now operate a complex export inspection and quality control system. Its particular aim is to ensure that the export consignments are free from false codling moth and fruit flies. The system was originally introduced for chillies and has now been extended to the main export vegetables, such as eggplants and gourds. The NPPO instructed and trained the companies during the introduction.

50. Pack houses are obliged to apply a system, which makes it possible to trace back the grower at any stage of the process. Some carry out crop supervision of their contracted growers, while they also provide advice on controls. Upon arrival the goods are inspected by a dedicated person of the company, who is trained in visual identification of the major type of insects. The same persons supervise the sorting and packing and carry out random inspection of the consignment to be exported.

51. The audit team visited pack houses and noted that: The company employees, who carry out inspections of the goods are experienced

and possess the basic equipment for visual checks (tables, light, knives, magnifying glass);

The inspection concentrates on chillies. The main aim is to identify symptoms of false codling moth and fruit flies;

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The personnel who sort and pack chillies are aware of the symptoms of the major pests of EU concern. They are instructed to extract any suspicious fruit. The inspection method includes breaking or cutting of suspicious fruits to detect larvae hidden inside;

If the company quality controller detects infestation above a certain level upon arrival the goods are rejected and the grower is notified. In the case of low level infestation a meticulous sorting is carried out. If any infection is detected in the packed consignments the already packed goods from the same grower are resorted and re-inspected;

It seems that the inspection system can detect fruits infested with fruit flies fairly efficiently. However, even persons, who are well-trained in the biology and the symptoms, can easily miss the presence of false codling moth in chillies. The infestation does not always produce clear symptoms therefore the presence of the pest can only be detected efficiently if the fruit is cut.

5.4.3 System of official inspections

52. The NPPO stated that according to the Plant Protection and Health Act of 2016, the exporter shall submit the consignment for examination by an inspector. Production sites of plants for planting are inspected according to SOPs which are in line with the relevant ISPMs. If fully implemented the system would ensure that the relevant requirements of the EU legislation are complied with, including the frequency of the controls and establishment of pest free sites.

53. The audit team noted that: Production sites of plants for planting are inspected regularly by the NPPO. The

frequency varies; on average it is 3-4 times per year. During these visits inspectors check the plant health status of the crops, the company records of scouting, pest findings and pest controls. A report is prepared after each visit;

The inspection frequency at the places of production is not sufficient for conformity of with certain provisions of Annex IV, Part A, Section I, of Directive 2000/29/EC. In particular for the declaration that the place of production is free from Bemisia tabaci or became free from this pest after an infestation, more frequent official inspections are required (see also chapter 5.5.2, Table VI);

Export consignments present at the site during scheduled inspections are also controlled. However, as the companies export continuously, usually several times per week, the majority of the consignments are not checked at the producers;

At the airport the consignments of plants for planting are checked only occasionally. Consequently the majority of the consignments are not inspected by the NPPO. This is not in line with provisions of points 39 and 41 of Annex IV, Part A, Section I, of Directive 2000/29/EC, which require inspections for plants for planting at appropriate times prior to export. For the issuance of the PC, results of company pest scouts are taken into consideration.

54. The NPPO stated that pack houses are regularly checked which includes an assessment of the inspection system they implement. The current NPPO policy is to check every chilli, eggplant and bitter gourd consignment at the packing houses and randomly inspect them at the airport.

55. The audit team noted that:

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As a result of measures implemented since 2014, the NPPO has a clear picture of the exporters and pack houses of vegetables. The pack houses visited by the audit team implemented a comprehensive and efficient system;

The companies notify the inspectors in advance of the exports, therefore inspections at the pack houses can be planned;

Although the share of consignments inspected at the pack house increased significantly, the scope required by the SOPs has not been achieved yet;

The NPPO inspector checks the relevant company inspection records. This includes the identification of growers with positive findings. The inspector pays particular attention to their goods as they are considered as risky;

If the inspector detects any HO the consignment is rejected and the inspection report clearly indicates this. Re-sorting is allowed if the level of infestation is below a certain threshold (2-5% of the boxes). However, the inspector does not always recheck goods after the resorting. This approach does not guarantee that the consignment fulfils EU requirement;

Chilli, eggplant and bitter gourd consignments are randomly inspected at the airport, based on a risk assessment;

Leafy vegetables of basil (Ocimum spp.) are not subject of any official inspection at the pack house or at the airport. This is not in line with provisions of point 45.2 of Annex IV, Part A, Section I, of Directive 2000/29/EC, which requires that the plants have been officially inspected prior to export and have been found free from Bemisia tabaci in the case of countries where the pest is present.

56. The NPPO stated that production sites of roses are officially inspected quarterly. Inspectors check the cropping area, the pack house and the goods prepared for export at the time. They assess the control system applied by the company, which includes checking inspection, pest finding and pest control records. The outcome of each inspection is duly recorded, which may include recommendations to the grower. At the airport about 15% of the consignments are inspected randomly.

57. Each consignment of roses is thus not subject to official inspections at either the pack house or at the airport. This is not in line with provisions of point 45.2 of Annex IV, Part A, Section I, of Directive 2000/29/EC, which requires that the plants have been officially inspected prior to export and have been found free from Bemisia tabaci in the case of countries where the pest is present.

58. The NPPO considers that a combination of official controls and inspections carried out by the companies involved in the production and packing of plants and plant products could ensure that the exported goods are in conformity with the EU and international requirements. Article V of the IPPC states that "inspection and other related activities leading to issuance of PCs shall be carried out only by or under the authority of the official national plant protection organisation". Although inspections carried out by the companies are audited and controlled by the NPPO they cannot be considered as official especially due to the lack of impartiality and due to the possible conflicting interest. EU legislation does not recognise such non-official inspections as a basis for export certification, although they may provide useful support to the official controls.

5.4.4 Integrity and traceability of consignments

59. Producers of plants for planting and roses apply, who are also the exporters, operate traceability systems, which enables the identification the greenhouse or even a part of

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it if any problem is detected in the export consignment. Usually numeric- or barcodes are applied.

60. Each vegetable consignment can be traced back to the pack house which keep detailed records of the deliveries. The origin of the goods is identifiable during the entire sorting and packing process, however it is not always the case after the packing is completed.

61. Plants for planting, roses and vegetables arrive at the airport in closed boxes and are delivered usually by the company/pack house, together with the relevant export documents. If the goods were subject to official inspection during cropping or at the pack house, the inspection report has also to be presented.

62. The audit team noted that in the case of consignments inspected at the pack house, it is not possible for the airport inspector to verify the integrity of the consignment before certifying it because the inspection report does not specify the inspected quantity.

5.4.5 Facilities for performing inspections

63. NPPO inspectors met by the audit team possessed the equipment necessary for inspecting the crop visually and taking laboratory samples if necessary.

64. In the pack houses visited the inspectors could obtain the necessary assistance for the sampling and could use facilities provided by the companies (tables, lighting) which were generally sufficient. The inspectors were equipped with an inspection kit, containing basic tools necessary for the visual identification of the insects of EU concern.

65. The goods subject to this audit are all exported to the EU via Entebbe International Airport. The consignments are handled by two major refrigerated warehouses, which are located in the airport's cargo area. In each warehouse an inspection area is established. The audit team visited these warehouses, witnessed inspections and noted that the conditions at both sites made the meticulous inspection impossible. Due to the general logistic conditions in the warehouses the random selection of boxes for inspection was difficult or in some cases not possible. The inspection area was not sufficiently separated and the ergonomic conditions and the lighting were insufficient. The inspectors possessed all necessary tools for sampling and visual inspection.

66. The audit team checked the administration and data recording system of the NPPO. It was noted that each inspection is duly recorded and a copy of the report is provided to the relevant stakeholder. Currently the administration is largely paper based. Only a limited part of the information is recorded in an electronic database, which is accessible for inspectors. Due to the partial data access and compatibility the current system provides limited possibilities for risk assessment, quality control and coordination purposes.

5.4.6 Implementation of official controls

67. The audit team observed demonstrations of NPPO inspections of crops of plants for planting, chillies and egg plants at the pack houses, chillies, roses and cuttings at the airport and noted that: The inspection of the crop producing unrooted cuttings was carried out according to

the SOP. Inspectors scouted the crop and checked the traps at the production site for

20

detecting the presence of HOs of EU relevance. They also checked scouting and pest control records of the company. The method used ensured the detection of HOs present in the crop at the time of the inspection;

Based on the notification of the pack house, the inspector tries to start the inspection while the sorting/packing procedure of the consignment is ongoing. It enables him to check the entire procedure. The relevant provisions of the SOPs and work instructions were followed. The sample size was in line with ISPM 31. The fruits were meticulously checked including cutting of all suspicious ones and a certain number of ones with no visible symptoms for checking the latent presence of insect larvae;

At the airport the consignment is inspected upon arrival at the cargo centre in their reception areas. The logistics follow a tight schedule and the consignment is intended to spend only a limited time in the reception area. If the schedule dictated by the cargo centre is not observed there is a high possibility that the consignment misses the flight with considerable financial consequences. Therefore there is a continuous pressure on the inspectors to work quickly;

The airport inspector selected fewer boxes of chillies and roses than is required by the SOPs and ISPM 31. Chilli fruits in each box were checked meticulously including visual inspection of the entire content and cutting all suspicious fruit and a 1% of symptomless fruit. From each box of roses, a limited number of bunches were selected, however they were inspected meticulously for the presence of any adult, larvae or egg form of insects.

Conclusions on the export control system68. Nurseries producing plants for planting and cut roses are registered which makes for a

good basis for official controls. The NPPO has made efforts to obtain comprehensive information on the vegetable supply and to have the exporters and pack houses registered and officially controlled.

69. The frequency of official controls at the nurseries does not always fulfil EU requirements. Only some of the export consignments are officially inspected, contrary to EU and international requirements. Inspections carried out by the companies cannot be considered as official.

70. Although the current inspection system is not compliant with EU requirements, it has resulted in allow number of EU interceptions for cuttings and roses. A similar system, which is being implemented for vegetables, does not yet provide similar results.

71. The inspections currently carried out at the airport cannot ensure that the consignments meet EU requirements.

5.5 PHYTOSANITARY CERTIFICATES

Legal requirements Article 2(1)(i) and Article 13a(3) and (4) and Annex IV, Part A Section I of Directive 2000/29/EC.

ISPM 5, ISPM 7 and ISPM 12.

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Findings

5.5.1 Issuance of the phytosanitary certificate

72. Uganda issues PC to all exported plants and plant products, whether the importing country requires this or not. PCs are issued by inspectors located at the phytosanitary border posts, by the headquarters of the NPPO and in the case of raw coffee at the Uganda Coffee Development Authority. As practically all regulated articles are exported to the EU via Entebbe International Airport, the PCs are issued there.

73. The format and information content of the Ugandan PC are in line with IPPC requirements.

74. The audit team noted that: Due to technical issues, the PCs were completed with a typewriter, a computerised

system is expected soon; The PC is issued based on official inspection reports carried out at the growers or

pack houses and on relevant commercial documents which are received in hard copies. The inspectors always check the relevant documents;

Copies of the issued PCs are archived at the border post and certain information about them is uploaded in a simple database, which is accessible to the plant health inspectors. The current system provides limited possibilities for tracing back non-compliant cases or to combat fraud;

During the issuance of the additional declaration on the PC, inspectors take into consideration the information obtained from the exporters. They cross-check this with provisions of Directive 2000/29/EC and a general guidance documents, which was prepared by the Dutch authorities in 2012. Inspectors used the original text of the Directive. As significant amendments are made regularly to the Directive, the system cannot guarantee the appropriateness of the additional declarations.

75. In numerous cases, the PC is issued for consignments of regulated articles, which have not been subject to any official phytosanitary control either at the border or at the packing/preparation site. (see chapter 5.4.3).

76. The audit team noted that this practice is not in line: With Article V.2 of the IPPC which stipulates that "Inspection and other related

activities leading to issuance of phytosanitary certificates shall be carried out only by or under the authority of the official national plant protection organisation" and

With the certifying statement on the PC as referred to by chapter 5 of ISPM 12, which stipulates that the plants, plant products or other regulated articles described in the PC have been inspected and/or tested according to appropriate official procedures.

5.5.2 Additional declarations

77. The audit team analysed examples of additional declarations on Ugandan PCs, issued for exports to the EU. It was noted that: In general the declarations dealt with all points of Annex IV, Part A, Section I of

Directive 2000/29/EC, which were relevant to the exported plant species and type of product;

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There were cases, where the additional declaration did not reflect correctly the plant health status of the place of production or of the consignment.

Table VI. summarises the findings of the audit team.

Table VI. Examples of additional declarations applied by Uganda on PCs for plants for planting of different species destined for the EU.

SpeciesAdditional declaration, given by Uganda in relation to the relevant points of Annex IV, Part A, Section I of Directive 2000/29/EC

Audit team comments

31.1(a) the plants originate in an area, established in the country of export by the NPPO as being free from Liriomyza sativae and Amauromyza maculosa in accordance with relevant ISPMs, and which is mentioned on the PC as an additional declaration

This statement is not correct because Liriomyza sativae is present in Uganda, but MAAIF has not established any areas free from the organism in accordance with provisions of ISPM 8. Furthermore, the area is not mentioned on the PC.

32.3(b) no signs of Liriomyza huidobensis and L. trifolii have been observed at the place of production, on official inspections carried out at least monthly during the three months prior to harvesting.

This statement is not correct because places of production are officially inspected less frequently than at the stipulated interval.

36.1(a) the plants originate in an area, established in the country of export by the NPPO as being free from Thrips palmi in accordance with relevant ISPMs, and which is mentioned on the PC as an additional declaration.

This statement is not correct because MAAIF has not established any areas free from the organism in accordance with provisions of ISPM 8. Furthermore, the area is not mentioned on the PC.

Euphorbia pulcherrima (cuttings)

45.1(b) the plants originate in a place of production, established in the country of export by the NPPO as being free from Bemisia tabaci in accordance with relevant ISPMs, and which is mentioned on the PC as an additional declaration, and declared free from Bemisia tabaci on official inspections carried out at least once each three weeks during the nine weeks prior to export.

This statement is not correct because MAAIF has not established any places of production free from the organism in accordance with provisions of ISPM 10 or mentioned the place on the PC. Furthermore, places of production are officially inspected less frequently than at the stipulated interval.

36.1(b) the plants originate in a place of production, established in the country of export by the NPPO as being free from Thrips palmi in accordance with relevant ISPMs, and which is mentioned on the PC as an additional declaration, and declared free from Thrips palmi on official inspections carried out at least monthly during the three months prior to export.


Hydrangea macrophylla (cuttings)

46(b)(b) the place of production has been found free from Bemisia tabaci and other vectors of the relevant harmful organisms [various listed viruses] on official inspections carried out at appropriate times.

This statement is not fully correct because official inspections are too infrequent for the timing to be "appropriate" for Bemisia tabaci.

28(b)(1) b the cuttings have come from premises, which have been officially inspected at least monthly during the three months prior to dispatch and on which no symptoms of Puccinia horiana have been observed.


28.1(b) the plants have been grown throughout their life in an area established by the NPPO in the country of export as being free from Chrysanthemum stem necrosis virus in accordance with relevant ISPMs.

This statement is not correct because MAAIF has not established any areas free from the organism in accordance with provisions of ISPM 8.

32.3(b) no signs of Liriomyza huidobensis and L. trifolii have been observed at the place of production, on official inspections carried out at least monthly during the three months prior to harvesting.


Chrysanthemum spp. (cuttings)

36.1(b) the plants originate in a place of production, established in the country of export by the NPPO as being free from Thrips palmi in accordance with relevant ISPMs, and which is mentioned on the PC as an additional declaration, and declared free from Thrips palmi on official inspections carried out at least monthly during the three months prior to export.


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SpeciesAdditional declaration, given by Uganda in relation to the relevant points of Annex IV, Part A, Section I of Directive 2000/29/EC

Audit team comments

45.1(b) the plants originate in a place of production, established in the country of export by the NPPO as being free from Bemisia tabaci in accordance with relevant ISPMs, and which is mentioned on the PC as an additional declaration, and declared free from Bemisia tabaci on official inspections carried out at least once each three weeks during the nine weeks prior to export.


Rosa spp. (cut flowers)

45.2(b) the cut flowers have immediately prior to their export been officially inspected and found free from Bemisia tabaci.

This statement is not correct because official inspections of each consignment immediately prior to export are not carried out.

32 There is no point 32 in Annex IV, Part A, Section I of Directive 2000/29/EC. However, there should have been a reference to point 32.2, indicating which of the two options in that point has been complied with.

Ocimum basilicum (leafy vegetable)

45.2(b) the leafy vegetables have immediately prior to their export been officially inspected and found free from Bemisia tabaci.

This statement is not correct because official inspections of each consignment immediately prior to export are not carried out.

Conclusions on phytosanitary certificates78. The Ugandan system does not ensure that PCs are issued only for consignments which

were subject to prior official phytosanitary inspections. In certain cases the additional declaration does not correctly reflect the actual plant health status of the place of production or the plants.

5.6 ACTIONS TAKEN IN RESPONSE TO INTERNAL FINDINGS AND EU NOTIFICATIONS

Legal requirements ISPM 7, ISPM 13 and Section 2.6 of ISPM 23.

Findings

5.6.1 Internal findings

79. If a HO, relevant for EU export is detected during inspections at a production site the official report contains recommendations on appropriate control measures. The export is suspended until corrective measures are applied and their impact is controlled by a repeat official inspection.

80. When a HO is found during the consignment inspection at the pack house or at the airport, the consignment is rejected. Usually re-sorting of the consignment is allowed and this is not verified by a repeated official inspection. This approach does not guarantee that the consignment fulfils EU requirement (see chapter 5.4.3).

5.6.2 EU notifications

81. The assistant commissioner of the Crop Protection Department of MAAIF receives EUROPHYT notification e-mails. Follow-up measures are implemented according to SOPs. For each interception with a HO, the dossier is forwarded to an inspector. The

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relevant grower, pack house or the exporter is visited and an official investigation starts for the identification of the reasons and the possible corrective measures. Until the investigation is concluded, the identified production area is put under quarantine and/or the export authorisation of the pack house is suspended. The interested party receives an official notification, which indicates the results of the investigation and may propose corrective measures. An official inspection is carried out to check the actions taken by the grower/pack house before the quarantine is lifted.

82. Interceptions for reasons other than the presence of HO are also investigated to identify the reason for the non-compliance and in particular to check whether there is any possibility of fraud.

83. The NPPO informed the audit team that recent investigations could identify fraudulent use of PCs for chilli consignments, which did not originate from registered exporters and were not subject to any plant health controls. The UK Plant Health Service provided useful assistance in this issue. If any fraud or forgery is identified the exporter is obliged to re-ship the consignment to Uganda at their costs or meet the costs of destruction at the port of destination.

84. The audit team checked the actions carried out by some chilli consignments recently intercepted by MS and noted that: The consignment was successfully traced back to the pack house; The export from the establishment was suspended until the necessary corrective

measures were implemented.

Conclusions on actions taken in response to internal findings and EU notifications 85. For internal findings the phytosanitary inspectors apply standard procedures with the

aim to ensure that the export consignments are free from HO. However, the applied practice cannot always guarantee this.

86. There is an appropriate procedure to follow-up EUROPHYT notifications, including tracing-back of the intercepted consignments and to eliminate fraudulent cases.

6 OVERALL CONCLUSIONS

The production system for plants for planting, vegetables, herbs and cut flowers to be exported to the EU is aimed at minimising pest presence. With considerable efforts, the growers of plants for planting and roses are able to keep the risk of presence of harmful organisms in the export consignments very low.

Uganda has an established plant health system with an appropriate legal framework. In recent years the NPPO introduced several additional measures, which improved the system of official phytosanitary controls. Although the inspectors are experienced and well-trained, severe staff shortages prevent the NPPO from running an official export control and certification system in line with EU requirements.

Official controls are carried out in greenhouses, at pack houses and at the airport, however their scope and frequency are not in line with EU requirements. Phytosanitary certificates are issued for consignments after inadequate or in many cases without official inspections.

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The NPPO requires growers and pack houses to operate a system of own phytosanitary inspections during cropping, harvest and packing and considers these private inspections to be part of the official control system. Although the NPPO to some extent audits, supervises and verifies these private activities, they cannot replace official inspections, in particular due to the potential conflict of interest.

As comprehensive information is not available about the absence/distribution of certain harmful organisms of EU concern in Uganda, certain statements included on Ugandan phytosanitary certificates cannot be considered as reliable.

Although the current inspection system is not compliant with EU requirements, the recent efforts for its improvement have resulted in a low number of EU interceptions of plants for planting and cut roses. A similar system, which is being developed and implemented for fruits and vegetables, has not yet provided similar results.

7 CLOSING MEETING

A closing meeting was held on 15 September 2016 in Kampala, during which the main findings and preliminary conclusions of the audit team were presented. The CA accepted the information provided by the audit team.

8 RECOMMENDATIONS

The NPPO of Uganda is recommended to:

No. Recommendation

1. Ensure that plant health inspectors' knowledge of EU import requirements is up-to-date, as required by Article 2(i), first indent of Directive 2000/29/EC and by points 3.1, 3.2 and 3.3 of ISPM 7. Particular attention should be paid to provisions listed in the relevant parts of Annex IV, Part A, Section I to the same Directive.The recommendation is based on conclusion No. 32.Associated finding No. 19.

2. Ensure that the plants for planting which are exported to the EU are subject of plant health checks at appropriate times and prior to export, as required by points 39 and 41 of Annex IV, Part A, Section I, of Directive 2000/29/EC and point 5 of ISPM 12.The recommendation is based on conclusions No. 69.Associated finding No. 53.

3. Ensure that the place of production of herbaceous plants for planting is subject to official inspections with a frequency required by Annex IV, Part A, Section I, of Directive 2000/29/EC for certifying that the place of production is free from the relevant harmful organisms.The recommendation is based on conclusion No. 69.Associated findings No. 53.

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No. Recommendation

4. Ensure that cut flowers of roses and leafy vegetables of Ocimum spp. have been officially inspected prior to the export and found free from Bemisia tabaci, as required by point 45.2 of Annex IV, Part A, Section I, of Directive 2000/29/EC.The recommendation is based on conclusions No. 69.Associated findings No. 55.

5. Ensure that appropriate checks are carried out at the airport. In particular that facilities and time available for performing checks are sufficient to enable controls in line with the requirements of ISPM 31 and that staff performing checks are free from interference or pressure from other parties in order to ensure that they can perform appropriate checks in line with section 1.4 of ISPM 23.The recommendation is based on conclusion No. 71.Associated findings No. 65 and 67.

6. Ensure that the sample size selected for inspection of plants and plant products immediately prior to export is sufficient to ensure the appropriate probability of finding any harmful organisms present and that the entire sample is subject to examination, in line with ISPM 31.The recommendation is based on conclusion No. 71.Associated findings No. 67.

7. Ensure that phytosanitary certificates are issued only to those consignments of plants and plant products listed in Annex V. Part B of Directive 2000/29/EC, which had been subject to official phytosanitary inspections as required by Article V of the IPPC and by ISPM 7.The recommendation is based on conclusion No. 78.Associated findings No. 53, 55, 57, 58 and 75.

8. Ensure that additional declarations of the phytosanitary certificates refer correctly to those EU requirements listed in the relevant points of Annex IV, Part A, Section I, of Directive 2000/29/EC, which have actually been met by the relevant consignment. This goes in particular for plants for planting. The recommendation is based on conclusion No. 78.Associated findings No. 77.

The competent authority's response to the recommendations can be found at:

http://ec.europa.eu/food/audits-analysis/rep_details_en.cfm?rep_inspection_ref=2016-8806

http://ec.europa.eu/food/audits-analysis/rep_details_en.cfm?rep_inspection_ref=2016-8806

ANNEX 1 – LEGAL REFERENCES

Legal Reference Official Journal TitleDir. 2000/29/EC OJ L 169, 10.7.2000,

p. 1-112 Council Directive 2000/29/EC of 8 May 2000 on protective measures against the introduction into the Community of organisms harmful to plants or plant products and against their spread within the Community

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ANNEX 2: RELEVANT INTERNATIONAL STANDARDS

International Standard Title

ISPM No. 4 International Standard on Phytosanitary Measures Publication No 4, Requirements for the establishment of pest free areas, Food and Agriculture Organisation, Rome, Adopted 1995; published 2016, https://www.ippc.int/en/publications/614/

ISPM No. 5 International Standard on Phytosanitary Measures Publication No 5, Glossary of phytosanitary terms, Food and Agriculture Organisation, Rome, Adopted 2015; published 2016; https://www.ippc.int/en/publications/622/

ISPM No. 6 International Standard on Phytosanitary Measures Publication No 6, Guidelines for surveillance, Food and Agriculture Organisation, Rome, Rome, Adopted 1997; published 2016, https://www.ippc.int/en/publications/615/

ISPM No. 7 International Standard on Phytosanitary Measures Publication No 7, Phytosanitary certification system, Food and Agriculture Organisation, Rome; Adopted 2011; published 2016 https://www.ippc.int/en/publications/613/

ISPM No. 8 International Standard on Phytosanitary Measures Publication No 8, Determination of pest status in an area, Food and Agriculture Organisation, Rome; Adopted 1998; published 2016 https://www.ippc.int/en/publications/612/

ISPM No 10. International Standard on Phytosanitary Measures Publication No 10, Requirements for the establishment of pest free places of production and pest free production sites, Food and Agriculture Organisation, Rome; Adopted 1999; published 2016https://www.ippc.int/en/publications/610/

ISPM No. 12 International Standard on Phytosanitary Measures Publication No 12, Phytosanitary certificates, Food and Agriculture Organisation, Rome; Adopted 2014; published 2016 https://www.ippc.int/en/publications/609/

ISPM No. 13 International Standard on Phytosanitary Measures Publication No 13, Guidelines for the notification of non-compliance and emergency action, Food and Agriculture Organisation, Rome; Adopted 2001; published 2016 https://www.ippc.int/en/publications/608/

ISPM No. 17 International Standard on Phytosanitary Measures Publication No 17, Pest reporting, Food and Agriculture Organisation, Rome, Rome, Adopted 2002; published 2016, https://www.ippc.int/en/publications/606/

ISPM No. 23 International Standard on Phytosanitary Measures Publication No 23, Guidelines for Inspection, Food and Agriculture Organisation, Rome, Adopted 2005; published 2016 https://www.ippc.int/en/publications/598/

https://www.ippc.int/en/publications/614/










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International Standard Title

ISPM No. 27 International Standard on Phytosanitary Measures Publication No 27, Diagnostic protocols for regulated pests, Food and Agriculture Organisation, Rome, Rome, Adopted 2006; published 2016, https://www.ippc.int/en/publications/593/

ISPM No. 31 International Standard on Phytosanitary Measures Publication No 31, Methodologies for sampling of consignments, Food and Agriculture Organisation, Rome, Adopted 2008; published 2016 https://www.ippc.int/en/publications/588/

ISPM No. 36 International Standard on Phytosanitary Measures Publication No 36, Integrated measures for plants for planting, Food and Agriculture Organisation, Rome, Adopted 2012; published 2016 https://www.ippc.int/en/publications/636/




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