Flower Auctions International (Vereniging van Bloemenveilingen)
VBN
Serving the interests of the members of Vereniging Bloemenveilingen, which are the cooperatives Royal FloraHolland and Plantion and as such serving the interests of the members of Royal FloraHolland and Plantion which are Dutch and worldwide based ornamental producers.
ID: 60862364841-67
Lobbying Activity
Response to Targeted amendment of the Plant Health Regulation
21 Dec 2023
Response from the Flower Auctions Association (Vereniging van Bloemenveilingen Nederland, VBN) to the Commissions public consultation on the review proposal for the Plant Health Regulation Aalsmeer, 21 December 2023 VBN represents the interface between the producers of ornamental plants and flowers, and the trade therein. The auctions are cooperatives, owned by the producers. A considerable part of ornamental plants and flowers produced within the EU or imported into the EU passes through VBNs auctions. VBN appreciates the possibility offered by the European Commission (EC) to provide input as regards the proposal for amending the Plant Health Regulation (PHR). Our main points are the following: a. VBN supports the ECs view that the PHR in its current form is generally fit for purpose. No major changes should be made to the current logic or legal text. The system functions well as it stands. b. VBN supports the need for a robust protection against the entry into, establishment in and spread within the EU of quarantine pests. The current text offers this. We do not support tightening of the current legal requirements, for example by adding further restrictions on import of (ornamental) plants and flowers from third countries. In this respect, we would like to emphasize that the proposed new empowerment in Art. 42(1) for setting out a procedure to conduct the listing of high-risk plants should not result in additional barriers to trade, but be restricted to the clarification of procedures. The threshold for adding new plant species to the list of high-risk plants should remain high, since this is and should continue to be an exemption to the regular risk-based rules set out in the PHR. Woody plants for planting should continue to be the focus. c. VBN would welcome progress as regards the introduction of digital plant passports. We support the proposal as regards Art. 88 for that reason. We encourage the EC to make progress on this important file. d. VBN accepts the logic of full integration on RNQPs into the PHR, including certification requirements and notification in case of non-compliance (e.g. in Art. 37, Art. 71). We would however like to stress that a substantial transitional period will be required in view of the administrative burden from introduction of the new requirements. It should be recalled that RNQPs do not concern establishment and spread of new pests into the EU territory, but a protection of buyers of propagating material in terms of quality. Therefore, there is no need for a rapid introduction of the new requirements and a transitional period of for example two years should be acceptable. We will be happy to clarify our position if so requested. Contact persons: fritsjonk@royalfloraholland.com robertbaayen@royalfloraholland.com Transparency register number: 60862364841-67
Read full responseResponse to Measures related to Popillia japonica
18 Apr 2023
The Association of Dutch Flower Auctions (VBN) and the Netherlands Vereniging van Groothandelaren in Bloemkwekerijproducten (VGB) would like to thank the European Commission for the opportunity to provide input in response to the draft Commision Implementing Regulation on measures to prevent the establishment and spread of Popillia japonica Newman and on measures for the eradication and containment of that pest within certain demarcated areas of the Union territory. We acknowledge the importance of measures against Popillia japonica in case of outbreaks, given the serious damage that this polyphagous pest could cause in case of establishment and spread. Our main concern as regards the draft measures is the lack of clarity concerning plants moved into, through and out of a demarcated area. The draft measures concern host plants in general present within the infested or demarcated zones and the soil in which they are being grown. It is not clear whether the measures target exclusively those plants that were already present inside the infested or buffer zones at time of the outbreak, or also the plants that are being moved from outside the zones into them and out again in the context of trade. We request the European Commission to clarify the measures applicable to plants and accompanying soil coming from outside and returning to outside the demarcated area in the final text of the measures. It should be clear that the measures against Popillia japonica as currently proposed will not affect the flower auctions or other traders, as long as the plants originate from outside the demarcated area and are handled under appropriate safeguards (closed facilities, where appropriate a plant passport). Another situation which requires clarification is that of flower shops inside the demarcated area. We wonder whether plants with accompanying soil from outside the demarcated area may be sold by florist shops, garden centres and retail outlets inside the demarcated area. We wonder whether any restrictions would apply on those plants and accompanying soil? Can host plants be sold in the demarcated area at all to final consumers? If so, may final consumers move those plants out of the demarcated area without the treatments and safeguards referred to in Art. 9(1)(d) and 9(2), respectively Art. 10(1)(c) and 10(2)? In case of an outbreak of Popillia japonica, we need to have clarity beforehand on the logic that will apply. The Netherlands is a small country, with production and trade of ornamentals being largely concentrated in the west of the country. This is where the auctions and many traders are located. Any outbreak may immediately impact on the auctions and trade companies, not in the least for a priority pest like this, for which buffer zones up to 15 km are foreseen. Our comments and questions are given in full in the attached file. A reply from the Commission Services will be very much appreciated. Thanks for taking our input into consideration. Kind regards, Stefanie Miltenburg (VBN) and Matthijs Mesken (VGB)
Read full responseResponse to Sustainable use of pesticides – revision of the EU rules
18 Sept 2022
The VBN - Dutch Flower Auctions, is an umbrella organization of the Dutch ornamental auctions. The auctions are cooperatives, formed of growers of flowers and plants who have combined forces to organize their sales jointly. The Dutch auctions have 4,000 members (ornamental production companies [of which 700 are international members) and 2,500 customers (trading companies/exporters). At the auctions over 12 bn flowers and plants are traded yearly and the turnover amounts to 5.6 bn Euro (2021). The auctions want to be reliable marketplaces for certified sustainably produced flowers and plants.
The VBN has a couple of important concerns with respect to the SUR proposal
> Specific circumstances of different production practices are not taken into account, which leads to an unfair system especially for frontrunners in sustainable horticulture, high technological production companies which produce in closed agricultural systems.
> The proposal includes a ban on all pesticide use in sensitive areas or within 3 meters of those areas. This might have unwanted outcomes in densely populated regions like in the Netherlands with concentrated greenhouse production in certain areas. The proposal neglects the fact that closed indoor agricultural systems in practice, can ultimately generate no releases of PPPs, fertilizer, or other inputs to the environment.-
> This provision neglects the fact that not all agricultural systems are covered by the CAP. Many innovative agricultural systems are not part of the CAP due to their intensive production on a rather small area. The reference to funding by the CAP in this proposal is thus inapplicable to these innovative agricultural systems and, hence, would result in a negative stimulant.
> In the proposal, no single incentive is presented to stimulate MS to foster the use of alternative measures, such as precision techniques, scouting techniques or natural predators.
Read full responseResponse to Guidelines on the antitrust derogation for sustainability agreements in agriculture
12 May 2022
The Association of Dutch Flower Auctions (VBN) would like to thank the European Commission for its consultation as regards sustainability agreements in agriculture.
The derogation in Art. 210a of Regulation 1308/2013 to Art. 101 TFEU is an important and indispensable means for agricultural and horticultural enterprises to contribute to sustainability. Guidelines on the proper use of the derogation are welcomed.
As for the scope, we note that a very wide range of sustainability domains is included in Art. 210a, from climate and environmental issues to animal health and welfare. What seems to be missing is the domain of plant health in the sense of the phytosanitary rules covered under the Plant Health Law (Regulation 2016/2031), the equivalent of the veterinary rules covered under the Animal Health Law (2016/429). We would be grateful for the Commission to clarify in the future guidelines on Art. 210a that sustainability agreements in practice may also include agreements to improve plant health, in the sense of preventing the entry, establishment and spread of pests of plants regulated under the Plant Health Law. Such a clarification would be in line with the coverage in Art. 210a of landscape, biodiversity and ecosystem protection (point (a) of paragraph 3) and reduction of pesticide use (point (b) of paragraph 3), because new pests may significantly damage the landscape, biodiversity and ecosystems and generally necessitate increased pesticide use. Such a clarification will make a serious difference for growers and traders in plants and flowers. The current omission, even if legally not a problem as explained above, suggests that plant health was deliberately excluded and is therefore not at all eligible for the derogation. It frightens off the companies that would like to participate in plant health sustainability agreements.
For similar reasons, we recommend to clarify in the guidelines that sustainability agreements aimed at preventing the entry, establishment and spread of invasive alien species, covered under Regulation 1143/2014, will be considered compliant with Article 210a in the light of protection of biodiversity and ecosystems.
Such clarifications would be fully in line with the objective under point B in the Call for evidence, which states that the guidelines to be adopted would […] “(iii) provide non-exhaustive examples to stakeholders of the types of objectives they might envisage pursuing”.
The key condition in Art. 210a for eligibility of sustainability agreements, apart from scope issues, is the provision that they shall only impose restrictions of competition that are indispensable to the attainment of that standard. We would like the Guidelines to clarify the methodology to assess whether the elements of the agreements, in particular price aspects, are indispensable or not. In our view, higher prices are indispensable for growers to be able to meet higher sustainability standards, but the price increase should not exceed what is necessary to remunerate the producer for the additional costs and income foregone, plus an incentive for encouraging participation.
We recommend that higher prices for consumers resulting from sustainability agreements shall cover the costs incurred and income foregone of growers, plus an incentive of maximally 20%, in analogy with the incentives permitted in the CAP and proposed by the Commission in the recent consultation on Guidelines for State Aid. Higher incentives than 20% should however be prohibited so as to exclude abuse at the expense of consumers and distortion of competition.
The full text of our contribution is attached in the form of a letter from VBN to the European Commission (DG COMP and DG AGRI).
Read full responseResponse to Updating the list of invasive species threatening biodiversity and ecosystem services across the EU
10 Dec 2021
Position of the Dutch Flower Auctions Association (VBN) concerning the European Commission’s consultation on the list of invasive alien species
See attached paper for our position in full.
General remark
Jointly with other stakeholder organisations in the Netherlands, we are launching an initiative to see how private sector may help implement the objectives of the IAS Regulation 1143/2014 more effectively as regards invasive plants. Our aim is a system of preventive measures that the Dutch growers and traders of ornamental plants are to put in place for ruling out IAS risks as much as possible. We are aware of the special position of our sector, which produces and trades a large array of ornamentals. The concentration of such activities in the Netherlands, a major hub for their production and trade, in our view brings along a special responsibility. Our initiative should help to achieve the objectives of the IAS Regulation as well as help growers and traders of ornamentals to cope with the risks associated with their activities and avoid surprises.
Celastrus orbiculatus
The risk assessment for C. orbiculatus indicates that this species may become invasive. In certain parts of the Union, this seems to be happening; elsewhere, however, no problems seem to occur. The species is not produced at large scale in the Netherlands, mainly for cut branches for the flower industry. This however requires substantive investments, since groves (production fields) of C. orbiculatus become productive only after appr. 7 years and are fully productive only after 10-12 years. For the nurseries involved, often small family businesses, inclusion of C. orbiculatus in the Annex to the Regulation will have serious economic consequences.
We would like to request the Commission to ensure that listing of C. orbiculatus will come with a sufficiently long transitional period (preferably 10 years and as a very minimum 5 years) and compensation for the growers of the value lost, either at EU or at national level.
Pistia stratiotes
The risk assessment for P. stratiotes in our view does not support listing. This aquatic plant species does not survive winter in most of Europe. Exceptional survival in waters with elevated temperatures e.g. due to nearby mining activities should not be taken as evidence that the species could become invasive. The true risk of P. stratiotes lies in the Mediterranean, where winter temperatures permit survival during winter. The endangered Member States, in particular Spain and Portugal, have included the species in their national lists of invasive species. This is exactly the right solution, rather than regulating an overall harmless species at Union level. The production of P. stratiotes is of significant economic interest to the Netherlands’ aquatic plant sector and banning its production and trade is not justified.
We object to the proposed listing of P. stratiotes as an invasive species for the Union as a whole. Such listing is disproportionate and against the Better Regulation rules of the EU. Some years ago, P. stratiotes was also proposed for listing but withdrawn for good reasons. The decision made at that time should be respected.
We would like to request the Commission to withdraw P. stratiotes from the IAS candidate list and leave its prevention and control to national legislation. From our side, we intend to develop a system for restricting trade of P. stratiotes to Member States where the species cannot establish and survive. Such a regionalisation will minimalize risks for Member States with a mild climate, while preventing undue economic impact for private sector in parts of the Union where P. stratiotes cannot survive.
Final remark
We would like to encourage the Commission to focus on IAS that are a real risk but still absent from the Union, rather than on already established species, and to cater for regionalisation where risks are negligible for most of the EU and concern only a few Member States.
Read full responseResponse to Integrated Farm Statistics - List of variables and their description for the reference year 2023
27 Aug 2021
The VBN - Dutch Flower Auctions, is an umbrella organisation of the Dutch ornamental auctions. The auctions are cooperatives, formed of growers who have combined forces to organise their sales jointly. The Dutch auctions have 4,000 members (ornamental production companies of which 700 are international members) and 2,500 customers (trading companies/exporters). At the auctions over 12 bn flowers and plants are traded yearly and the turnover amounts to 4.6 bn Euro. The VBN wants to make an essential remark for the ornamental sector; some plants and all cut flowers are included under the same categories, although the production systems and their market channels are quite different, both in the EU and in the international market. On the other hand, plant production is split in different headings, making it difficult to realise the plant sector relevance because some parts are mixed with cut flowers.
Our request to the Commission, to make a distinction between ornamental plants and cut flowers, is besides these practical reasons, also laid down in two sets of EU Regulations, the Plant Health Regulations (1) and the Regulation on Tariff and Statistical nomenclature (2):
1. Regulation (EU) 2016/2031 of the European Parliament of the Council of 26 October 2016 on protective measures against pests of plants, and all pieces of legislation resulting from it, make a clear distinction between in the requirements for plants for planting and for all other products, amongst which cut flowers.
We believe that the EC, the Council, and the EP must have sound statistics to foresee and prepare legislation and monitor how it affects the farmers, which is currently impossible to do accurately.
2. Council Regulation (EEC) No 2658/87 of 23 July 1987 on the tariff and statistical nomenclature and on the Common Customs Tariff, clearly differentiates plants from cut flowers ( Annex I, Section II, Chapter 6). The EC and MS can know and follow the international market of flowers and plants but cannot obtain reliable data on flowers and plants grown in the EU farms because both productions are mixed in the same section.
In section II. VARIABLES OF LAND of ANNEX I, we propose to segregate ornamental plants from flowers in CLND 046 and 082: see attached document.
Read full responseResponse to Revision of the plant and forest reproductive material legislation
12 Jul 2021
The Association of Dutch Flower Auctions represent over 4000 ornamental production companies. The ornamental sector can only be strong with a broad diversity of products and is therefor dependent on a broad supply of PRM. Every year about 1800 new varieties are being developed. .
The ornamental PRM sector has both a number of large breeding companies as well as a large number of small breeding companies.
There is a wide range of species and varieties (just think of all the different colors and shapes of flowers) with generally a relatively very small volume per variety of trade in PRM. In the current Seed Marketing Directive, only quality and health requirements apply to PRM for ornamental crops.
For many varieties the DUS examination is too expensive and an officially recognized variety description is sufficient. The market largely controls itself in trade flows, where a number of private registration systems have been set up for determining identity. Therefor in ornamental crops, market mechanisms offer sufficient security and the consumer benefits from the widest possible range of products. It is in the interest of the ornamental sector to keep the market easily accessible for as many varieties as are being developed.
Introducing sustainability requirements for market access for PRM would in the ornamental sector practically erode the supply of new varieties as these are being developed for more resilience to pests and diseases but also for commercial features (colors, number of buds, stem length etc.).We strongly believe that sustainability requirements need to be in place at production level and not applied upon PRM market access.
Read full responseResponse to Action plan for the development of EU organic production
23 Oct 2020
The EU Commission must take into account that organic production is a production method only, with certain very specific rules. But it is definitely not the Holy Grail as the most sustainable agricultural production method.
There are other production methods in place which are not taken into consideration in this 25% action plan, although these methods have even better results when looking at impact on climate and the environment and as such contributing to the green deal.
As the green deal (F2F) is about getting towards more sustainable agriculture in the EU, it doesn’t seem sensible to limit this target of 25% to organic production only.
As organic plant production needs to be soil based just for the principle of it, an increase of 25% of organic production means a considerable increase of land use, water use, the use of nutrients and of plant protection products. In that respect organic farming is overall not contributing to a more sustainable agriculture.
Production in greenhouses for example, can be close to completely circular. No emissions to soil, water, air, precision use of nutrients, water, plant protection products and easy use of biological plant protection methods.
However in greenhouses production is often on substrate and as such not considered organic in the EU because the plant is not soil based (by the way, different from other countries in the world where production on substrate is also considered to be 'organic').
IPM and precision farming with digital monitoring tools can as well contribute considerably to more sustainable agriculture. That being the Green Deal (F2F) goal, only focusing on 25% increase of organic production is not a valid tool and disrupts competition.
Besides, consumer demand for EU organic production is hardly growing and is even close to zero with respect to ornamental production. Due to the high level production methods in place and the desire of producers to improve their production methods continuously in this sector, which is also reflected in the certification schemes in place, there is hardly demand for organic products.
In view of the above we would strongly advise to set the 25% goal not only for organic production and to broaden the description. Include in this 25% ecological or sustainable production methods (which can be measured and demonstrated with product life cycle analysis). Then it will also be inviting for producers applying different production methods to cooperate to get best practices in sustainable agriculture instead of polarizing the strictly defined organic method towards other production methods.
Read full responseResponse to Environmental claims based on environmental footprint methods
31 Aug 2020
The Association of Dutch Flower Auctions (VBN) represents cooperatives in the ornamental chain with over 4000 member companies, producers of ornamental products, and 2500 associated buyers/wholesalers. Yearly 12 billion products (flowers and plants) are being traded at the auction market places. These products regard over 30.000 different varieties.
The demand for sustainably produced horticultural products (fruit, vegetables, cut flowers and potted plants) is increasing. Therefore, on a national level in the Netherlands, a consortium of companies developed the 'HortiFootprint Category Rules' (HFCR) calculating an environmental footprint for horticultural products, so for both ornamentals as for fruit and vegetables. The used standardised method is in line with the programme of the European Commission. The next step is to further develop this method at a European level within the 'Product Environmental Category Rules (PEFCR)'. Floriculture has been selected in 2019 by the European Commission as an official trajectory in the European 'transition phase' as the PEFCR “Cut flowers and Potted Plants” (link: https://ec.europa.eu/environment/eussd/smgp/ef_transition.htm )
The ornamental sector demonstrable recognizes the importance of a standardised, objective and scientifically substantiated assessment of the environmental impact of ornamental products throughout the entire chain to have an effective and comparable outcome and further harmonisation of methods.
• However as market demands are already a strong accelerator for businesses to apply more sustainable production methods and as the PEFCR methods and datasets clearly still need further development to become more robust, we strongly recommend option two as set out in the Inception Impact Assessment; a voluntary EU legal framework enabling companies to make green claims in accordance with the Environmental Footprint methods. Taking into account that legal requirements need to be flexible to be sector specific and encourage businesses to take ownership.
• We also like to emphasize that as the PEFCR methods primarily enable to identify continuously where in the chain most effectively improvements can be made for a more sustainable production, it is not a suitable tool for consumer communication. However it can be complementary to existing certification schemes developed by the sector.
• Besides the development of a voluntary legal framework, the Commission could contribute by further improving PEFCR methods and datasets, facilitating the adoption of PEFCR with minimising costs for businesses and to provide funding for front runners as these are being confronted with challenges when PEFCR principles need to be tailor made developed for a specific sector.
Read full responseResponse to Update of measures to control Xylella fastidiosa
7 Jul 2020
VBN (Flower Auctions International) endorses the adjustments of the measures to prevent the introduction and spread of Xylella fastidiosa in the EU. However, as climatic conditions plays an important role in spreading X.f., our opinion is that after a finding of infected plants the prescribed elimination measures, inspections and sampling are sufficient to prevent spreading of X.f. in member states or areas where climatic condition are not favourable for X.f., like Northern European countries. Article 5 (3) gives the MS the possibility by way of derogation from Article 4, the Member State to decide not to establish a demarcated area immediately, when all of the mentioned conditions are fulfilled. It is not always possible to fulfil these conditions.
Read full responseMeeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)
29 Jan 2020 · Sustainable farming and green cities
Response to Rules on plant passports
10 Jan 2020
VBN welcomes the opportunity to give an opinion on the proposal regarding the traceability code for plant passports. VBN represents the flower auctions in the Netherlands that are responsible for the sales of flowers and plants from more than 5500 growers/suppliers to 2500 customers (wholesalers, florists, retailers).
The past two years the ornamental sector and the responsible authorities in the Netherlands have worked very intensively with all the stakeholders to ensure that the several thousand growers and traders were well prepared for the implementation of Regulation (EU) 2016/2031 on 14 December 2019. For many operators, the changes and the obligation to provide all plants, including those intended for sale to consumers, with an EU plant passport were big challenges. For many businesses the implementation of the plant passport system had major consequences for their internal processes and considerable investments were needed in the form of, for example, printers, software and labels. Organizations in the Netherlands, both public and private, have put a lot of energy into explaining the usefulness of an EU plant passport system and raising awareness of the need to achieve a better protection for crops in the EU.
We were particularly surprised that just before the implementation date of 14 December 2019, the European Commission published the proposal that for plants ready for the sale to final users the use of a traceability code should not be restricted to a limited group of high-risk plants in which quarantine organisms were found in the EU (eg Xylella host plants), but for all plants for planting that produce a persistent wood stem, including trees, shrubs, vines and climbing plants. As a result, the traceability code will apply to many plant species as many plants species produce a persistent woody stem. The assumption that plants for planting that produce a persistent woody stem in general are known to be susceptible to Union quarantine pests, and especially to priority pests, is in our opinion not underpinned. Therefore it is not necessary to require a traceability code for such a broad group of plant species. It results in unnecessary administrative and financial burden for many nurseries all over Europe.
A traceability code is not required for rapid traceability or plants. In case of a finding of a quarantine organism, the registration number of the operator on the plant passport is the basis for the traceability. The entire company of the operator will be subjected to an intensive check and through the administration it can be checked which and when product flows has arrived and left the company.
A traceability code leads to considerable additional administrative burdens for companies, is in many cases logistically complex to implement and in turn leads to additional costs as a result of adjustments to investments they made for the current passport. Growers have tried to the do the implementation in a most efficient way possible. They have invested in pre-printed pots, sleeves, labels or stickers. That they have to change it so soon after the date of introduction is hard to explain to them. The additional costs for the ornamental sector are not proportional to the apparent additional biosecurity that is created.
In addition, the fact that the proposal applies for all plants for planting that produce a persistent wood stem causes much uncertainty about which species are involved. There are many species that do not have a persistent wood stem in the sales phase, but they do in a later phase of their life. It will lead to many discussions and undermine the support for the current system.
We therefore believe that there should be no additions to the plant passport system as it was introduced on 14 December 2019 and that adjustments can only be proposed based on experiences in the coming years. These adjustments can be justified when it is proven in practise that they are necessary.
Read full response26 Mar 2019
VBN agrees with art. 3.6 where member states may exempt border control posts, which have been designated for plants and plant products (and other goods etc.), (a) to have a supply of hot and cold running water and facilities etc. and (b) to have rooms with ceilings that are easy to disinfect. For plants and plant products an inspection area with the in articles 4 (2) mentioned equipment, when appropriate for plants and plant products, is sufficient. Inspection rooms with walls, floors and ceilings that are easy to clean and disinfect are for these inspections not necessary and will lead to extra costs.
Read full response26 Jul 2018
The Dutch Flower Auctions, the worlds' biggest trading platform for flowers and plants, plays a crucial role in the ornamental chain in the EU as market place for EU producers and exporters from third countries as members and wholesalers as customers.
Especially in the Netherlands, where most ornamental production and trade in the EU takes place, we are very concerned with plant health risks and even more so in relation to imports.
However, the proposed list of high risk plants as published by the Commission on the 11th of July 2018, lacks a proper technical justification for potential risks of an unacceptable level as required in the regulation (article 42 (3) EU 2016/2031) for the genera FICUS (with the possible exemption of Ficus Carica), CYCAS, LIGUSTRUM, LINOCERA, JASMINUM and ACER.
WE URGENTLY REQUEST YOU TO NOT QUALIFY THESE GENERA
AS HIGH RISK PLANTS and remove these from the list.
Considering the existing large scale, multi-annual trade with only very few import interception records, qualifying these plants as 'high risk' for this regulation is disproportionate and will have an immediate disruptive effect on production, trade flows and therefor businesses in the EU and third countries.
For example, around 4.5 million Ficus plants enter the EU yearly through the Netherlands and on average there are only 5 interceptions.
Secondly, again looking at proportionality it seems unbalanced that in the preliminary risk assessment no distinction is made at species level, as well as a specification of third countries or regions where a certain risk of an unacceptable level occurs.
For example, there are 6 different species of Ficus imported in the Netherlands, which originated over the past 12 years from 21 different third countries.
The listing itself will have an immediate negative effect on businesses in the EU and in all 3rd countries for all species of a genus. And then, will EFSA be able to process all risk assessments filed by all third countries for all species of a genus within a year?
These days it is crucial that EU legislation is balanced and defensible towards citizens and businesses in the EU as well as towards third countries. That EU legislation is proportionate and does not create unnecessary burdens or damages businesses.
We do not need a fake sense of total plant health security looking only at imports as such. We do need effective and high quality, risk based import inspections in the whole of the EU, smart logistics like 'clean corridors' to evade any possibility of contact of trade flows or plant waste material with plant production areas. And, in case a harmful organism is detected, there must be clear protocols for rapid reaction and the immediate execution thereof.
In addition we need to consider it is in all of our interest that especially businesses in third countries, qualified as least developed countries, where some businesses were even built with the help of EU subsidies, will not suffer trade disruptions and business losses when there is no substantial specific plant health risk, clearly demonstrated in a preliminary risk assessment, taking into account species, origin, and occurrence by interceptions.
Read full responseResponse to Commission Delegated Regulation on the methodology for risk assessments of invasive alien species
20 Dec 2017
1. The Commission is not determining which level of protection is appropriate for society and the level of risk unacceptable for the impact on biodiversity. There are no cut-off values for a significant adverse impact on native biodiversity for a. species not yet present in the EU or b. at an early stage of invasion, c. alien species already established in the Union. Therefor the need for listing of species in relation to the risk for biodiversity and ecosystem services in the EU on a species to species level is not demonstrated.
2. The use of non-scientific data (art. 3 delegated act) to justify a listing is contrary to the requirements of the Court of Justice for a risk assessment and not compliant with the principles of excellence, transparency and consistency ensuring that the regulatory measures adopted by the Commission have a proper scientific basis and to ensure the Commission is in a position to examine carefully and impartially all relevant evidence.
3. As plant species are restricted to specific climate conditions, the risk assessment needs to include a precise indication of the climate conditions under which a species is capable to establish a viable population and spread. The bio-geographical region level for an assessment is not taking into account the heterogeneous character of the EU territory. Therefor an assessment of a species on habitat level should take place to determine if the species can enter, form a viable population and spread in a large part of the Union when this is not limited to the isolated characteristics of the habitats concerned. If then the bio-geographical region concerns less than 15% of the EU, the risk is not so significant that it justifies the adoption of measures applicable across the Union.
4. Assessments about known uses and social and economic benefits of species should be included and carried out by experts specialized in social/economic science.
5. Assessments of environmental benefits of the species should be included and completed with a climate change compensation assessment if a species has the ability to prevent negative effects of climate change.
Read full responseResponse to Commission Implementing Regulation laying down rules on plant passports
26 Oct 2017
VBN has the following remark concerning legend 7 of the annex. Include the registration number of the professional operator who issued the initial plant passport in the case of replacement of the plant passport will be impractical when an operator sells a mixture of different plants of varies origins as an arrangement (2 or more different plants in a tray, scale or pot). Each plant also can have numerous operators prior to final sale. In other cases it leads to unnecessary burdens for operators and there is no legal basis for it.
Read full responseResponse to Amendment of the technical Annexes of the Plant Health Directive 2000/29/EC
14 Oct 2016
The Association of Dutch Flower Auctions (VBN) would like to make the following comments.
1. Bemisia tabaci requirements for potted plants destined for protected zones
The proposal that plants of Begonia, Dipladenia, Ficus, Hibiscus, Mendevilla and Nerium oleander intended for sale to the final consumer should originate from pest free production sites is not enforceable for most of the companies. Bemisia tabaci is quite common in many member states and the requirement of no signs of Bemisia in the place of production is hardly feasible. The requirement of pest free production sites conflicts with the efforts of using biological control of pests. Plants intended for sales to the final consumer have a much lower risk than plants intended for the professional grower and should be excluded from the requirement of pest free production site. Only when it is proven that additional measures for plants intended for sales to the final consumer are necessary, an inspection prior to transport to the PZ will be sufficient.
2. Thaumatotibia leucotreta
The addition of Thaumatotibia leucotreta in Annex I at point 25 has a tremendous impact on the export of cut roses from Africa to EU. Central East Africa is the most important area for rose production worldwide and most of the roses are exported to Europe (import value of more than 500 million Euros). Regulation of Thaumatotibia leucotreta for cut roses will have serious consequences for trade and logistics. More inspections at the border and more rejections will lead to severe delay in the logistic process and high costs. In the PRA published in 2013 the Expert Working group considered the risk of Rosa cut flowers as a pathway as minor. Most consignments of Rosa are directly distributed to the market. Transport time is short, and transport conditions are not favourable for the development of larvae. In view of the short life of cut flowers the risk of introduction is much lower than for fruits or plant material.
Read full response