OpenLobby.EU
Explore

European Forest Nurseries Association

EFNA

The Association is constituted from the professional forest nursery associations or other properly constituted Trade bodies representing the forest nursery and seed trades of European Countries The role of the Association is to represent and to defend the interests of the private producers of forest seed and plants and of all other activities relevant to the profession and to attempt to mediate between member states when disputes arise. The Association shall be responsible particularly for giving the official views of the private seed and nursery sector on all matters concerning Forest Reproductive Material to the Commission of the European Union.

Lobbying Activity

Response to Commission Implementing Regulation laying down rules on plant passports

26 Oct 2017

European Forest Nursery Association, EFNA represents the forest nurseries and traders - at the European level and welcomes the opportunity to share its views about this initiative. EFNA does not believe that Implementing Regulations can be used to change the adopted EU Regulation 2106/2013. The legend item #7 of the Annex requires, in the case of replacement of the plant passport, to include the registration number of the professional operator who issued the initial plant passport. EFNA refers to Article 93 and Annex VII of Regulation 2106/2013 as they relate to Replacement Plant Passports. Regulation 2106/2013 does not require that the unique identification code of the original issuer of the Plant Passport should be included on a replacement Plant Passport. EFNA does agree that traceability must be maintained and be visible to competent authorities. The issuer of any replacement Plant Passport must be able to demonstrate this to Inspectors of the Competent Authority through their own systems. In fact, the use of the traceability code is already planned (legend item #5). Having to openly show the registration number of a previous professional operator would compromise the Commercial Confidentiality. EFNA accepts that the size of a Plant Passport is not regulated, but wishes to stress the importance that the models allowed must enable those issuing plant passports be allowed to use the same layout and size labels for Plant Passports for general movement as for Plant Passports for movement into Protected Zones. If this is not allowed, it could add significant extra costs for those issuing Plant Passports because most nurseries must issue both types. ENA refers to Annex VII Part A of Regulation 2106/2013 regarding the Format of Plant Passports. Plant passports for movement within the Union territory as referred to in the first subparagraph of Article 83(2) (1) The plant passport for movement within the Union territory shall contain the following elements: (a) the words ‘Plant Passport’ in its upper right-hand corner, in one of the official languages of the Union and in English, if different, separated by a slash; The wording in the draft Implementing Regulation (legend item #1 of the Annex) is significantly different. EFNA asks that the Implementing Regulation uses the same clear wording as contained in Regulation 2106/2013.
Read full response