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UNION FLEURS - The International Flower Trade Association

UNION FLEURS

Union Fleurs pursues the following objectives: 1. To safeguard and to promote matters of general interest to the flower trade; 2. To provide sound and loyal competitive conditions in the flower trade; 3. To defend and represent the interests of the international flower trade to international bodies and authorities; 4. To co-operate with associations of producers and retailers of non-edible horticultural products; 5. To promote and to carry out advertising measures for non-edible horticultural products; 6. To exchange, collect and distribute information on the world flower market; 7. To expand the International flower trade Association to as many countries as possible. 8. To stimulate research, marketing and advertisement campaigns in the world market.

Lobbying Activity

Response to Updating the list of invasive species threatening biodiversity and ecosystem services across the EU

24 Mar 2025

Union Fleurs is the international umbrella organisation representing the interests of operators involved in the trade of floricultural products (importers, exporters, wholesalers and distributors of cut flowers and potted plants) in the EU and in 20 countries worldwide. We wish to submit the following comments regarding the proposed inclusion of the flatworm species Obama nungara in the EU list of invasive species: * while we do not dispute the threats to biodiversity posed by this flatworm, we are concerned by the significant operational and economic impacts this proposal will result in for the plant supply chain across the EU. *the extent of the economic impacts (direct and indirect) on the plant supply chain across the EU have not been sufficiently taken into account. The risk assessement carried out prior to the proposed update of the EU IAS list grossly underestimates the amount that will be needed for the surveillance and manageement of Obama nungara by economic operators (less than 100.000 EUR estimated, whereas in reality the amounts might reach millions of EUR per year without any foreseen mechanims for financial compensation of economic operators) * The responsibility of operators in the fight against this invasive organism is well understood, but it must be part of a proportionate and coordinated implementation between EU Member States in order to preserve the integrity of the single market and the free movement of goods. All things considered, we would for the time being support a postponement of the inclusion of Obama nungara in the EU IAS list in order to allow first for proper assessement, risk management and research to develop solutions to control the spread of this flatworm species.
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Response to Amendment of protective measures against pests of plants

28 May 2024

Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide. We wish to submit comments on the draft Commission Implementing Regulation and its Annexes, specifically on the proposed amendments to Annex VII point 62 introducing special requirements for the introduction of cut flowers of Rosa L. from countries of the African continent, Cape Verde, Saint Helena, Madagascar, la Reunion, Mauritius and Israel into the Union territory to prevent against risks related to Thaumatotibia leucotreta for the EU territory. Please see enclosed our detailed feedback and recommendations. In summary: Given the significant socio-economic contribution of rose production in several East African countries, and the reliance of the EU floriculture market on the sourcing of quality roses all-year-round from these origins, we would request EU decision-makers to consider the following recommendations and adjustments to help address the legitimate concerns raised in origin countries and across the rose supply chain: 1) Introduce a transition period for the full implementation of the special requirements longer than the one currently foreseen (6 months after publication in the EU Official Journal): a transition period of minimum 1 year would seem appropriate in order to allow NPPOs and operators in origin countries to prepare adequately and be able to ensure full compliance with the requirements. This could be combined with a phased-in / step-by-step approach with respect to the full implementation of systems approaches. For systems approaches to be fully and efficiently implemented in rose origin countries in Africa in accordance with ISPM14, adjustments to national legislation might e.g. need to be adopted in these countries in addition to technical improvement and infrastructures investments. Such legislative adjustments are likely to require more than 6 months. 2) Ensure that a robust cooperation framework will be established between the EU Commission, NPPOs in the EU Member States and NPPOs in the origin countries in Africa, as recommended by ISPM 14 (even though the development of a systems approach is under the responsibility of the NPPO of the exporting country, ISPM 14 points 8 and 10 clearly require consultation and cooperation between importing and exporting countries). Such a cooperation could possibly include a clear review process of the special requirements after a certain period of implementation and lead to adequate fine-tuning and/or adjustments to the requirements as needed. 3) Provide capacity building and technical assistance where needed in rose origin countries in Africa to support them in their continuous effort to manage the risks posed by Thaumatotibia leucotreta to EU biosecurity and comply with the proposed special requirements. Ensuring the safe trade of plants and plant products is a priority but requires adequate resources and knowledge to be optimal. Support from the EU in terms of training, expertise sharing, and infrastructure improvements will be crucial to successfully address the challenges rose producing countries are faced with when it comes to Thaumatotibia leucotreta. Thanks in advance for taking our comments and recommendations into due consideration. We trust that they will contribute to strike a reasonable balance between the need to protect the EU territory against the risks posed by Thaumatotibia leucotreta and the need to minimize potential disruptive effects on the trade of cut roses and on the socio-economic development in rose producing countries in Africa.We call on EU decision makers to ensure that every effort is made to safeguard existing mutually beneficial rose trade flows between developing countries.
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Response to Measures related to Popillia japonica

29 Apr 2023

Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide. We welcome the opportunity to provide comments on the draft Commission 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. Please find our detailed feedbacks attached. We thank you for taking our comments into due consideration and for clarifying and adjusting the text of the draft Commission Implementing Regulation where requested.
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Response to Integrated Farm Statistics - List of variables and their description for the reference year 2023

31 Aug 2021

Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide. We welcome the opportunity to submit the following important comment for the ornamental sector with respect to Draft Commission Implementing Regulation on the data to be provided for the reference year 2023 pursuant to Regulation (EU) 2018/1091 of the European Parliament and of the Council on integrated farm statistics as regards the list of variables and their description and repealing Commission Regulation (EC) 1200/2009: some plants and all cut flowers are currently 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 currently split in different headings, making it difficult to capture the relevance of the plant sector because some parts are mixed with cut flowers. We would therefore request to introduce a distinction between ornamental plants and cut flowers in section II. VARIABLES OF LAND of ANNEX I of the above -mentioned Draft Implementing Regulation, in line with what is already laid down in e.g. two other sets of EU Regulations, namely 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) makes a clear distinction between the requirements for plants for planting and for all other products, amongst which cut flowers. 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) with specific sub-headings under Chapter 6 for each category. This enables to know and follow more acurately international trade flows both for cut flowers and for ornamental plants. By contrast, it is not possible at the moment to obtain reliable data on flowers and plants grown in EU farms because both productions are mixed in the same section under the current EU Regulation on Integrated Farm Statistics. Please see the attached document which provides more details on the suggestion to split ornamental plants from cut flowers and set new subheadings under CLND 046 and 082 in section II. VARIABLES OF LAND of ANNEX I of the above-mentioned Draft EU Implementing Regulation. This adjustment shall be easy to implement and will make the reporting easier for these products as well as provide helpful statistics to support the monitoring of production of both cut flowers and ornamental plants in the EU.
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Response to Amendment of protective measures against pests of plants

24 Aug 2021

Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide. We welcome the opportunity to provide comments on the draft COMMISSION IMPLEMENTING REGULATION (EU) amending Implementing Regulation (EU) 2019/2072 as regards the listing of pests, prohibitions and requirements for the introduction into, and movement within, the Union of plants, plant products and other objects. Given the extent of the amendments to the listing of pests, and the fact that they impact a large range of commodities and plant products, we would request that sufficient time is given to all interested parties to adjust to the new requirements (operators, in particular in exporting countries, as well as phytosanitary authorities in exporting and importing countries). A reasonable transition period of minimum 6 months should therefore be enforced before implementation of the Regulation and a proper and detailed communication should be carried out by the EU towards their counterparts NPPOs in third countries, NPPOs in the EU and impacted operators to ensure that there is no unnecessary trade disruption when these changes come into force.
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Response to Revision of the plant and forest reproductive material legislation

13 Jul 2021

Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide. We welcome the opportunity to provide comments on the revision of the plant reproductive material (PRM) legislation. . Overall, we support a review of the current legislative framework insofar as it respects the needs of each sector and guarantees the continuation of what has worked well under the current legislation and of the tailor-made approach to the specific charateristics of each sector. For ornamental PRM in particular, the current legislation has worked well to determine the identity of varieties and to assure thresholds to market in terms of quality, integrity and plant health security. The ornamental sector and market offer can only remain strong and innovative with a broad diversity of products and is therefore dependent on a large and diversified supply of PRM. This essential element must be safeguarded by any future legislative framework and shouldnt be undermined. It is estimated that every year about 1800 new ornamental varieties are being developed, both by large breeding companies as well as a significant number of smaller breeding companies. The sector is charaterised by a wide range of species and varieties with a 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 proving sufficient. The preservation of registration based on officially recognized descriptions for ornamentals will be an essential element to maintain for the ornamental sector under any new legislation. The market largely controls itself in trade flows, where a number of private registration systems have been set up for determining identity. Therefore in ornamental crops, market mechanisms offer sufficient security and the consumer benefits from the widest possible range of flowers and plants varieties. It is in the interest of the ornamental sector to keep the market easily accessible for the development of as many varieties as possible. Introducing sustainability requirements for market access for PRM would result in the ornamental sector in the erosion of the supply of new varieties as these are being developed for more resilience to pests and diseases but also for commercial features (flower colors, number of buds, stem length etc.). We believe that sustainability goals are better achieved by stimulating good practice at production level but should not be integrated into the PRM legislation.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide. In response to the stakeholders’ consultation, we wish to submit the following comments: • The floriculture industry (cut flowers & potted plants) has recognised the importance and relevance of developing Product Environmental Footprint Category Rules (PEFCR) and has volunteered and been selected in 2019 by the EU Commission to be one of the very few PECFRs to be developed in the transition phase. Union Fleurs has committed to support the process and participate, together with a representative consortium, in the Technical Secretariat of the PEFCR “Cut flowers and Potted Plants” (https://ec.europa.eu/environment/eussd/smgp/ef_transition.htm ) on behalf of its membership – both in the EU and internationally. • Whilst supportive of the EU objectives set under the Green Deal in terms of circular and green economy, and well aware of the importance of developing a reliable and recognised methodology along well-defined EU Guidelines and on which all tools measuring environmental footprint can align in order to allow comparability across supply-chains and, amongst others, address environmental claims, we strongly favour option 2 as set out in the Inception Impact Assessment as the most sensible way forward as far as the EU policy agenda is concerned ( a voluntary EU legal framework enabling companies to make green claims in accordance with the Environmental Footprint methods as a complement to existing methods.) Our view is as follows: While PEFCRs offer first and foremost highly valuable insights and help identify hotspots and points of continuous improvement for the environmental performance of supply-chains, it is not to say that they should become the one and only reference to substantiate green claims and exclusively guide consumer choice. Before making any further steps, the EU should in any case conduct a full and detailed impact assessment to further analyse the implications of such a policy direction. See attached our further detailed inputs on this matter. Thanks in advance for taking our comments into due consideration. We remain available for any further inputs and details as needed.
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Response to Rules on plant passports

10 Jan 2020

Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide. We welcome the opportunity to provide comments on the draft Commission Implementing Regulation on types and species of plants for planting not exempted from the traceability code requirement for plant passport under Regulation (EU) 2016/2031 of the European Parliament and of the Council and repealing Commission Directive 92/105 EEC. We wish to share the following feedbacks: 1) The timing of this proposed Regulation, submitted for consultation on 13 December 2019 ie a day before the implementation of a major reform of the EU plant health regime, is particularly poor. Operators and supply-chains across the EU have been extensively preparing for the entry into force of the new EU regime for months and have invested heavily in systems and processes to adjust to new requirements laid out under Regulation (EU)2016/2031 and subsequent implementing Regulations - in particular with respect to the new extended provisions for plant passport. This has heavily mobilised resources and capacity across the ornamental supply-chain at a significant level of costs for operators. Integrating now such additional new requirements at such a late stage in the process, even with an additional 12 months to comply, would definitely trigger additional costs, administrative burden and logistical complexities for operators to adjust again their systems. 2) The very generic and broad scope of the list of targeted plants provided in the Annex ("All plants for planting that produce a persistent wood stem, including trees, shrubs, vines and climbing plants") is disproportionate and not risk-specific. If ever justified, requirements for a traceability code up to final users should instead remain limited to a restricted number of specific cases and clearly identified plant species where a risk of pest and pathogens for plants ready for sale to final users has been clearly identified and assessed. We are confident that the existing provisions of Regulation(EU) 2016/2031 and subsequent Implementing Regulations that entered into force on 14 December 2019 already provide the necessary frame, set of rules and adequate tools to protect the EU territory against the risk of pests while ensuring the safe trade and circulation of plants - both for imports and movement within the EU through the reinforced requirements for plant passport. The proposed new requirements on traceability codes will not bring any added value to further strengthen the protection of the EU territory but are likely instead to create an additional unjustified administrative burden and costly pressure on operators dealing with the plants listed in the Annex. We therefore strongly question the lack of proportionality, necessity and scientific justification of this proposal and would urge the European Commission and EU Member States to reconsider. Throughout the reform process of the EU plant health regime and the official controls Regulation, Union Fleurs has steadily promoted the importance of favouring risk-based approaches, risk-targeted measures and a level playing field for operators, in line with the general principles of the WTO SPS Agreement wich requires for any phytosanitary rules and regulations to be scientifically justified and proportionate to the assessment of risks. We fail to see how the broad and generalised scope of this proposal would fit with these principles. Thanks for taking these comments into due consideration.
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Response to The Information Management System for Official Controls regulation (IMSOC)

17 Jun 2019

Union Fleurs - International Flower Trade Association is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide. We welcome the opportunity to provide comments on behalf of our membership on the above-mentioned draft Commission Implementing Regulation ‘IMSOC Regulation’ and the template for CHED-PP displayed in Annex II. Our detailed contribution is herewith attached. Thanks in advance for taking our comments into due consideration. Union Fleurs remains available for any further inputs and details as needed.
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Response to Listing high risk plants & plants for which a phytosanitary certificate is not required for introduction into the Union

15 Aug 2018

Union Fleurs is the international umbrella organisation for national associations and companies active in the floricultural trade (cut flowers and potted plants) and represents the interests of operators involved in the trade of these products (importers, exporters, wholesalers and distributors) in the EU and in 20 countries worldwide. We welcome the opportunity to provide comments on behalf of our membership on the draft Commission Implementing Regulation provisionally listing high risks plants, plant products and other objects within the meaning of Article 42 of Regulation (EU) 2016/2031. As an introduction to our detailed comments, we wish to stress the following points: • The extent of the draft list currently put forward under Annex 1 is raising serious concerns for operators, traders and distributors from the ornamental sector across the EU and in supplying countries. • Among the 39 genera and species of ‘plants for planting’ on the current draft list for which a temporary import ban from all third countries can be anticipated pending a further risk assessment, it is to be noted that some of them have been imported in large volumes into the EU for decades without triggering an unacceptable level of phytosanitary interceptions at the EU borders over the years or presenting an unmanageable level of phytosanitary risks. It is definitely the case for Ficus, one of the most largely traded ornamental plant for indoor / consumer use which is listed as a genera without any further specification of species (the genera ‘Ficus’ alone covers 850 species), but also other genera such as Cycas, Ligustrum, Jasminum, Lonicera and Acer. •The listing of these genera as a full and their subsequent import prohibition, at least during a period of time, under Article 42 as of 14 December 2019 is expected to have a direct and highly disruptive impact on business involved in the production, trade and distribution of these products, both operators in the EU as well as suppliers and producers in third countries. At this stage, and in the absence of any further clarifications and technical justification, we therefore strongly question the proportionality and scientific basis of such measures and raise strong objections in view of the disruption that they are expected to trigger for our membership and operators in the ornamental sector at large. Please find enclosed in attachment the detailed response from Union Fleurs providing further inputs. Amongst others, we specifically request that a number of clarifications and guarantees be provided as early as possible by EU decision -makers, both at the stage of the ‘provisional listing to be adopted on the basis of preliminary risk assessments pending the risk assessment referred to under Article 42(4)’ as well as for the future management of the overall process provided for under Article 42 (within the implementing phase until 14 December 2019 as well as afterwards). We thank you for taking our detailed comments into due consideration and remain available for any further inputs and details as needed.
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Response to Amendment of the technical Annexes of the Plant Health Directive 2000/29/EC

14 Oct 2016

UNION FLEURS , the International Flower Trade Association, which represents operators in the global supply-chain for cut flowers and potted plants (importers, exporters, wholesalers and distributors) would like to submit the following comments on the proposed amendments to the technical annexes of the EU Plant Health Directive 2000/29/EC: 1. Proposed new regulated pest Thaumatotibia leucotreta (False Codling Moth) under Annex I, Part A, Section 1 of Directive 2000/29/EC (‘Harmful Organisms whose introduction and spread within all EU Member States shall be banned’) – new point 25.1 : we wish to express serious concerns as to the possible large impact, including various indirect ramifications, that the regulation of this pest for Rosa sp. cut flowers will have on the whole supply-chain and the controlling capacity of EU NPPOs for imports of cut roses from Africa, given the large volumes exported to the EU market from major East African origins (Kenya, Ethiopia, Uganda in particular, for which exports of cut Roses to the EU market are of a huge socio-economic importance). The Pest risk analysis carried out by EPPO in 2013 clearly concluded that given the low risk of transfer to a suitable host, the risk of Rosa sp. cut flowers as a pathway was considered as minor and therefore not considered for identification of management measures. As highlighted in the PRA, transport conditions of cut roses from East Africa to the EU market and short transport times are not favourable for the development of larvae of T. Leucotreta, while the intended use of the commodity (indoors), it short shelf-life and the quick and direct distribution flows to end consumers shortly after cut roses reach the European market strongly restrict the possibility of direct contact with suitable hosts in Europe and associated risks of transfer. We therefore would like to particularly stress that every effort should be made to ensure that the enforcement of the proposed new measure, and assessment of interceptions in the future, will remain proportionate to the actual risks posed by Rosa sp. cut flowers, so as to ensure consistency with the conclusions of the EPPO PRA. We would also urge the European Commission to appropriately and timely inform the NPPOs of the countries concerned in East Africa of the entry into force of this new measure to ensure that every effort is made, in cooperation with operators in the private sector along the supply-chain, to put in place adequate prevention and control measures can be efficiently implemented and managed before cut roses are exported to the EU. 2. New requirements on Bemisia Tabaci for several potted plants destined for protected zones (UK, IRL, S, FI, P) – new point 24.3 : it is proposed that specific host plants should originate in pest-free production places , also for those plants ready for sale to final consumers, requiring the place of production to be totally free from Bemisia Tabaci for at least three weeks prior to any movement. This will prove extremely difficult to implement in practice due to continuous Bemisia Tabaci population outside greenhouses and places of production, thereby de facto disproportionately restricting movement of those potted plants destined to final consumers. We would strongly require that the requirement be re-formulated so as to specify that ‘inspection of those potted plants destined for final consumers should take place prior to movement and delivery’. Such a requirement would prove much more efficient in practice and proportionate than the requirement for each production place to be totally free from Bemisia Tabaci, which should be removed from the proposed text.
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