EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY

Transcription

1 Ref. Ares(2017) /09/2017 EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY Health and food audits and analysis DG(SANTE) FINAL REPORT OF AN AUDIT CARRIED OUT IN CAMEROON FROM 08 MAY 2017 TO 18 MAY 2017 IN ORDER TO EVALUATE THE SYSTEM OF OFFICIAL CONTROLS FOR THE EXPORT OF PLANTS AND PLANT PRODUCTS TO THE EUROPEAN UNION 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.

2 Executive Summary This report describes the outcome of an audit carried out in Cameroon from 8 to 18 May 2017, as part of the published Directorate-General for Health and Food Safety audit programme. The objectives of the audit were to evaluate the system of official controls and the certification of plants and plant products originating in Cameroon and exported to the European Union (EU). The audit was undertaken in response to a continuing high number of interceptions of harmful organisms in consignments of plants and plant products exported from Cameroon to the EU. The audit team found that the National Plant Protection Organisation (NPPO) has begun to establish an export control system for plant health. However, at present the system does not include many of the elements required by EU and International Standards. There are significant weaknesses in its organisation and implementation which compromise its overall effectiveness. Therefore, preexport checks cannot be considered reliable to ensure compliance with EU import requirements. In October 2016, in response to correspondence from the European Commission, the NPPO developed and implemented an export certification scheme for mango, the main commodity with most interceptions. This scheme has the potential to improve the overall reliability of export checks. The report contains recommendations to Cameroon to address the shortcomings identified. I

3 Table of Contents 1 Introduction Objectives and scope Legal Basis Relevant EU legislation International standards Background Notifications of interception Production and trade Findings and Conclusions Organisational aspects of plant health controls National Plant Protection Organisation Legislation Work planning and resources Guidelines and training Laboratories and technical support Communication with stakeholders Plant health status Export procedures General procedures Registration and traceability of consignments Mango export certification scheme Export inspections Facilities for performing inspections Export inspections Phytosanitary certificates Action taken in response to non-compliances and EU notifications of interception Non-compliances EU notifications of interception Wood packaging material and ISPM 15 certification Overall Conclusions Closing Meeting Recommendations...18 II

4 ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT Abbreviation Consignment DRCQ EC EU EUROPHYT Harmful organism HT IPPC ISPM Lot MB MINADER NPPO Plants PPP t WPM Explanation As defined in Article 2(1)(p) of Council Directive 2000/29/EC as a quantity of goods covered by a single document required for customs formalities or for other formalities, such as a single phytosanitary certificate or a single alternative document or mark; a consignment may be composed of one or more lots. Department of Regulation and Quality Control and Agricultural Inputs and Products European Community European Union The EU s notification system for plant health interceptions As defined in Article 2(1)(e) of Council Directive 2000/29/EC as any species, strain or biotype of plant, animal or pathogenic agent injurious to plants or plant products. Heat treatment International Plant Protection Convention International Standard(s) for Phytosanitary Measures As defined in Article 2(1)(o) of Council Directive 2000/29/EC as a number of units of a single commodity, identifiable by its homogeneity of composition and origin, and forming part of a consignment. Methyl bromide Ministry of Agriculture and Rural Development National Plant Protection Organisation Should be considered to mean 'all living plants and specified parts thereof, including seeds' as defined in Article 2(1)(a) of Council Directive 2000/29/EC. Phytosanitary Police Post Metric ton Wood packaging material III

5 1 INTRODUCTION This audit took place in Cameroon from 8 to 18 May 2017 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). The audit team consisted of two auditors of DG Health and Food Safety and one national expert from a European Union (EU) Member State. Representatives of the National Plant Protection Organisation (NPPO), the Department of Regulation and Quality Control and Agricultural Inputs and Products (DRCQ) of the Ministry of Agriculture and Rural Development (MINADER), accompanied the audit team during the audit. An opening meeting was held on 8 May 2017 at the headquarters of the NPPO in Yaounde, during which the objectives and itinerary for the audit were confirmed, and additional information necessary for the conduct of the audit was requested. Unless otherwise specified, the data quoted in the following sections, and elsewhere in the report, was provided by the DRCQ. 2 OBJECTIVES AND SCOPE The audit was undertaken in response to a continued high number of interceptions of harmful organisms in consignments of plant produce exported from Cameroon to the EU, as detailed in section 4.1 below. The objective of the audit was to evaluate the system of official controls and the certification of plants and plant products regulated by Council Directive 2000/29/EC exported from Cameroon to the EU, and in particular the implementation of an action plan to address the ongoing interceptions. The scope of the audit was to review the organisation and resources of plant health controls for export of plants and plant products, as well as the implementation of controls including export inspections, issuance of phytosanitary certificates, action taken in response to noncompliances and EU interceptions and wood packaging material (WPM) and ISPM 15 certification. To meet this objective, the following meetings and visits were carried out: Meetings/visits No. Comments Competent Authorities Central 2 Department of Regulation and Quality Control and Agricultural Inputs and Products, Yaounde Regional 3 Douala, Limbe, Yaounde Laboratories 2 Quarantine laboratory in Yaounde, Douala University 1

6 Plant health control sites Points of exit 3 Yaounde-Nsimalen Airport, Douala Seaport, Douala Airport Production sites 5 Producers of mango and pineapple Pack houses 3 Handling plant produce intended for the export to the EU Treatment facility 1 WPM heat treatment 3 LEGAL BASIS The audit was carried out under the general provisions of European Union legislation, in particular Articles 21 and 27(a) of Council Directive 2000/29/EC, and in agreement with the NPPO of Cameroon. 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. 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. 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 EU import requirements, for evaluating official export controls in contracting parties. Cameroon is a contracting party to the IPPC. The full text of the IPPC and of all adopted ISPMs is available on the IPPC website ( The ISPMs of particular relevance to this audit are listed in Annex 2. 4 BACKGROUND This audit was carried out in response to the high number of interceptions of harmful organisms in consignments of fruit and vegetables exported from Cameroon, which have been notified by EU Member States since It is the first audit relating to plant health carried out by DG Health and Food Safety to Cameroon. The concerns of the EU on these issues were first conveyed to Cameroon by a letter of 29 July 2016 addressed to the NPPO. The letter included the list of critical commodities, which were those most frequently intercepted by EU Member States due to the presence of harmful organisms, namely: mango (Mangifera spp), custard apple (Annona spp.), mahogany wood (Entandrophragma spp.), peppers (Capsicum spp.), aubergine (Solanum spp.) and citrus 2

7 fruits (Citrus spp.). The letter also requested that an action plan (hereafter 'the action plan') to address the ongoing interceptions be provided to the Commission. In addition a reminder letter was sent to the NPPO on 17 January At the time of the audit, the NPPO had not replied to those letters, nor provided the requested action plan. However, it emerged through this audit that the NPPO had in fact sent a reply via their Brussels embassy in October 2016 outlining their proposed actions addressing shortcomings in their mango export controls (the commodity of main concern). However, for reasons unknown, this communication was not received by DG Health and Food Safety. Irrespective of this miss-communication the NPPO has still not developed an action plan intended to address interceptions in other risky commodities to prevent recurrence. Further information on the the DG Health and Food Safety's Health and food audits and analysis Directorate, including audit reports and its work programme, are available at: Information on the EU's requirements for plant health, including import requirements is published by the DG Health and Food Safety on their website: NOTIFICATIONS OF INTERCEPTION As detailed in table 1 below, EU Member States notified a total of 331 interceptions from Cameroon between 1 January 2013 and 8 May 2017 in EUROPHYT, the EU s notification system for plant health. 175 of these interceptions were due to the presence of harmful organisms. The remaining 156 were due mainly non-compliant or missing phytosanitary certificates. There were no interceptions notified of wood packaging material (WPM) from Cameroon. Table 1: Summary of notifications of interception by EU Member States and Switzerland in consignments exported from Cameroon (source EUROPHYT) Reason Presence of harmful organism * Other reasons, including documentary reasons Total * From 1 January to 8 May 2017 The data shows that there has been a significant increase in the number of interceptions of harmful organisms reported during 2015 and 2016 compared to the previous years. The most commonly intercepted harmful organisms include non-european Tephritidae ('fruit flies') which account for more than half of all interceptions (116 interceptions), followed by Thaumatotobia leucotreta (false codling moth) (9) and Leucinodes orbonalis (eggplant fruit 3

8 borer) (8). Practically all fruit flies were found on mangos (Mangifera spp.) (which alone accounted for 75 interceptions), followed by custard apple (Annona spp.) (24 interceptions) and peppers (Capsicum spp.) (16 interceptions). In addition to that, wood and bark insects of different genera were intercepted on mahogany wood (31 interceptions). Further details on the status of harmful organisms of concern to the EU in Cameroon are provided in section 5.2 below. The European Commission publishes a non-eu trade alert list, which is intended to draw the attention of relevant plant health authorities to the most frequent phytosanitary risks in any 12 month period. The list for the period 1 March February 2017 identified two risk commodities for Cameroon, namely, mango and Citrus spp. and fruit flies as the main harmful organisms intercepted. Further information on EUROPHYT including reports of interceptions, and the non-eu trade alert list are available on the DG Health and Food Safety website: PRODUCTION AND TRADE The NPPO could not provide any data for the production of fruits and vegetables, however, export of plants and plant products from Cameroon is detailed in tables 2 and 3 below: Table 2: Export of fresh fruits and vegetables to the EU from Douala Airport (source NPPO) Common name Botanical name Quantity (t) Pineapple Ananas comosus Papaya Carica papaya Mangos Mangifera indica Passion fruit Passiflora edulis African plum Dacryodes edulis Ndolé Vermonia amygdalina ,0 Eru Gnetum africanum Amarantus Amaranthus Aubergine Solanum melongena Ginger Zingiber officinalis Fresh flowers Douala Airport is the main export point for the export of fresh fruits and vegetables to the EU. Overall, the volume of export has significantly increased in the last three years, and for 4

9 mango it has tripled. The NPPO stated that the volume of export of peppers (Capsicum) is lower than for aubergine. Table 2: Export of fresh fruits and vegetables to the EU from Yaounde-Nsimalen Airport (source NPPO) Common name Botanical name Quantity (t) Pineapple Ananas comosus Cassava Manihot esculenta na 1 na Eru Gnetum africanum na na 52.9 African plum Dacryodes edulis na na na data not available Practically all export of pineapples from Cameroon to the EU takes place from Yaounde- Nsimalen Airport. By comparison, not many other plants and plant products are handled there. Mahogany wood is exported to the EU from the Douala Seaport, fresh fruits and vegetables are also exported through this point of exit. 5 FINDINGS AND CONCLUSIONS 5.1 ORGANISATIONAL ASPECTS OF PLANT HEALTH CONTROLS Legal requirements Article 2(1)(i) of Directive 2000/29/EC. ISPM 7. ISPM 23. Findings 5.1.1National Plant Protection Organisation 1. The NPPO for Cameroon is the Department of Regulation and Quality Control and Agricultural Inputs and Products (DRCQ) of the Ministry of Agriculture and Rural Development (MINADER). Within the DRCQ, the Sub Department of Seed Regulation and Plant Quarantine is in charge of the plant health activities. The DRCQ is responsible for setting policy, drafting legislation and coordinating activities. 5

10 2. Implementation of the plant health controls at regional level is under the responsibility of Regional Services for Quality Control as a decentralised service of the MINADER. Within these Regional Services, there are 48 established Phytosanitary Police Posts (PPP) which are responsible for all official plant health import and export controls. Only 31 PPPs are operational with three involved in export controls to the EU at the three main export points; Yaounde-Nsimalen Airport, Douala Airport and Douala Seaport. 3. Since reorganisation of the MINADER in 2005 the Department of Agricultural Development has also been responsible for plant health matters. Within each of the ten regions in Cameroon, there is a Phytosanitary base ( Bases Phytosanitaires ) which is subdivided at local (department) level into 58 Phytosanitary Brigades ( Brigades Phytosanitares ). Inspectors are responsible for surveillance of pests, for control of outbreaks and provide technical advice and training to farmers. However, they do not undertake any official checks in the export certification process and there is no cooperation nor coordination of activities with the DRCQ Legislation 4. The law on Phytosanitary Protection No 2003/003 of 21 April 2003 establishes the legal basis for the controls and protection of plant pests. Articles 9 and 10 require that export of plants or plant products must be accompanied by a phytosanitary certificate and can take place only at official points of exit. 5. Other relevant implementing legislation is provided for in Governmental and Ministerial Decrees and Orders. Principal amongst these include: Governmental Decree No 2005/0771/PM of 6 April 2005 establishes detailed rules for the execution of plant quarantine operations. It requires that phytosanitary certificates accompanying export consignments are issued at the points of exit after a successful phytosanitary inspection; Order No 029/CAB/PM of 4 April 2014 laying down the procedures for inspection and control of goods by the State technical services at the Douala Seaport; Ministerial Order No 0274/MINADER/CAB of 19 March 2013 concerning approval of phytosanitary certificates layout and procedures for their issuance; Ministerial Order No 003/06/MINADER/SG/DRCQ/SDRSQV/SQV/ of 3 April 2006 establishes the rules for treatment and marking of wood packaging material for external trade Work planning and resources 6. There are eight staff involved in plant health within the DRCQ. There are 11 Phytosanitary inspectors involved with import and export certification at the PPP of Yaounde-Nsimalen Airport, 12 at the PPP of Douala Airport and 34 in the PPP of Douala Seaport. During the meetings and visits the NPPO stated that there was insufficient enough staff to perform all tasks required. 6

11 7. The work of phytosanitary inspectors is coordinated within each PPP based on applications submitted by exporters for export checks. There is a very short advance notification requirement in place for export checks carried out (see also paragraph 23). Inspectors are also involved in import controls and in checking of passenger luggage Guidelines and training 8. The NPPO has drafted an inspection manual for phytosanitary controls, including general guidance for export inspections and sampling in line with international standards. This document was, at the time of the audit, in the final approval phase by the MINADER. Overall the draft manual is comprehensive, however, it is not commodity or harmful organisms specific or detailed enough, with key elements missing (such as detection of harmful organisms and necessary action(s) in case of non-compliance). 9. The NPPO stated that documents used for training on how to conduct export checks were distributed to phytosanitary inspectors. However, the audit team noted that phytosanitary inspectors referred, in some cases, directly to ISPMs in the absence of specific guidance on performing export checks. 10. The NPPO informed the audit team that there was no guidance of import requirements in place. During interviews with Phytosanitary inspectors the audit team noted that the EU import requirements and additional declaration statements are generally provided by exporters and not verified by inspectors (see section 5.5 below). 11. Furthermore, the NPPO does not maintain guidance and work instructions covering all aspects of the procedures of the phytosanitary certification system, which is not in line with Section 4.2 of ISPM 7. Phytosanitary inspectors are not provided with adequate technical information concerning harmful organisms regulated in importing countries, which is not in line with section 3.3 of ISPM 7. Official information regarding the phytosanitary import requirements needed for phytosanitary certification is not provided to inspectors, which is not in line with section 2.2 and 3.2 of ISPM The DRCQ informed the audit team that there were four plant health courses organised in the period from 2015 to May 2017, provided mainly by international organisations. These courses were not directly relevant for export checks. In 2015, a course was organised for phytosanitary inspectors focused on risk (11 participants) and another on strengthening the management of plant health in Africa (15 participants). In 2016, a capacity-building workshop was organised for phytosanitary inspectors (30 participants). A capacity-building workshop on Pest Risk Analysis was organised in 2017 (7 participants). 13. During visits of Yaounde-Nsimalen Airport, Douala Airport and Douala Seaport and various pack houses, the audit team noted that inspectors were aware of the main harmful organisms of EU concern and have general technical knowledge on plant health inspections. However, due to the lack of practical, hands-on training on detection of harmful organisms, inspectors are not fully technically competent and experienced when 7

12 carrying out export checks. This, together with the absence of internal interceptions suggests that training provided is not meeting the needs of phytosanitary inspectors (see sections and below). Inspectors do not have the training or experience required to be considered technically qualified, which is not in line with Article 2(1)(i) of Council Directive 2000/29/EC and section 3.1 of ISPM Laboratories and technical support 14. The DRCQ informed the audit team that the Central Plant Quarantine Laboratory in Yaounde remains non-operational after closing some eight months ago due to lack of resources. The audit team visited the facility which was equipped for basic plant health analysis. 15. The DRCQ stated that there were no local laboratory facilities to support export checks. The audit team visited the Biochemistry Laboratory at University of Douala, which carry out analysis of samples in support of Douala Seaport. They analyse commodities e.g. beans, coffee, cacao for quality traits. However, there is no link with Douala Airport in support of plant health export checks. The absence of quarantine laboratory and lack of diagnostic support for plant health activities is not in line with section 2.2 and 3.4 of ISPM Communication with stakeholders 16. The NPPO publishes information on export certification through their webpage. In the preparation of the new export certification scheme for mango, the PPP of Douala Airport cooperated very closely with stakeholders and organised two meetings with exporters and farmers in autumn Additional meetings with growers and exporters took place after the implementation of the scheme in January The growers and exporters visited by the audit team were aware of the current issues with respect to exports to the EU and of notifications of interceptions. Conclusions on organisational aspects of plant health controls 17. There is no specific guidance on conducting export checks and inspectors lack appropriate training and experience. They cannot therefore be considered to be adequately technically qualified. This means that for exports to the EU, official checks are not reliable. 18. In the absence of official guidance on EU import requirements, it cannot be ensured that export consignments, issued with a phytosanitary certificate, are compliant with EU rules. 19. The absence of quarantine laboratory and diagnostic support compromise the effectiveness of the phytosanitary certification system. 8

13 5.2 PLANT HEALTH STATUS Legal requirements Article VII.2(j) of the International Plant Protection Convention. ISPM 8. Part A of Annexes I, II and IV to Directive 2000/29/EC. Findings 20. The NPPO stated that the status of the majority of harmful organisms of concern to the EU has not been officially established. There is no systematic surveillance in place to establish the status and assess the distribution of these harmful organisms and so no pest free areas have been established. The status of certain harmful organisms has been determined in collaboration with research institutions. 21. The NPPO provided the general information about the status for the following harmful organisms: There are no official data for the presence of non-european Tephritidae, despite numerous EU interceptions. Ceratitis sp. is present in the South West region. There are no official data for the presence of Thrips palmi (one EU interception). Bemisia tabaci is present, based on results of MINADER surveillance from There are no official data for the presence of Phyllosticta citricarpa, however there were five EU interceptions on citrus fruits. Xanthomonas citri subsp. citri and Pseudocercospora angolensis are present, based on data from international plant health databases. Conclusions on plant health status 22. The status of the majority of harmful organisms of concern to the EU is not officially determined or status not known, despite EU interceptions. 5.3 EXPORT PROCEDURES Legal requirements Annex V, Part B and Annex IV, Part A Section I to Directive 2000/29/EC. ISPM 7. 9

14 Findings 5.3.1General procedures 23. The NPPO informed the audit team that exporters must make an application for inspection and certification to the PPP of the point of exit using a standard form ( Request for inspection and phytosanitary certification ). Application is received in the morning of the day of export, indicating the commodities to be exported using the categories for the Customs declaration. Plant health checks are carried out at the point of exit at cargo terminals. The outcome of the inspection is noted down on the application form, and based on this, the phytosanitary certificate is issued Registration and traceability of consignments 24. The NPPO stated that in general, no system of registration is in place for any actors in the export supply chain. However, one of the actions put in place in response to the EU correspondence was registration of mango producers, pack houses and exporters (see chapter 5.3.3). 25. The NPPO informed the audit team that traceability of consignments is possible through commercial documents only for commodities from organised intensive farming e.g. banana and pineapple. However, with the exception of mango, traceability is not possible for other regulated plants and plant products exported to the EU because exporters source these on local markets Mango export certification scheme 26. The NPPO informed the audit team that for mango, an improved export certification scheme was put in place in autumn 2016 and implemented since January 2017 (when the new mango export season started). The scheme is implemented at the level of the PPP of Douala Airport because all mango export from Cameroon to the EU is through this point of exit. The legal basis is the note of the head of the PPP of Douala Airport to exporters, which states that mangos have to be subject to systematic control which includes sourcing from approved places of production and processing in pack houses. 27. The PPP of Douala Airport stated that there were 29 staff from regional PPPs and staff from other regional agricultural services, so called controllers, involved in the implementation of the scheme. They also stated that there was a lack of inspection equipment, means of transport for controllers and a proper inspection area at the Douala Airport cargo terminal. 28. The PPP of Douala Airport and the NPPO described the certification scheme, which was at the time of the audit implemented only in the Littoral and South West regions. They stated that it consists of the following phases: Field inspection at approved places of production and issuance of an attestation. Field controllers are visiting the farms to check and verify the implementation of measures and are present and supervise at the time of harvesting. After the 10

15 harvest, a farm inspection attestation is issued by the field controller indicating the quantity. Phytosanitary controllers are present at pack houses and supervise the entire processing of mangos. They verify that incoming fruits are accompanied by the farm inspection attestation and check the quantity and quality of the fruits. They supervise and check fruits during washing, sorting and packing. Batches are formed after packing and unique batch codes include the code of the farm. Before dispatching to the point of exit the controller issues a Pre-certification attestation. In the last phase at Douala Airport, Phytosanitary inspectors check the documents accompanying the consignment, carry out export inspection and issue the Phytosanitary certificate. 29. The PPP of Douala Airport stated that at the time of the audit there were 16 exporters in the mango export scheme with around 100 approved places of production from 50 farmers. The official services approved only those places of production with lower pressure of fruit flies and each place of production was given a code. Measures had been put in place to reduce the pressure of the harmful organisms (e.g. mass trapping for fruit flies, weeding under the trees, collection and disposal of fallen fruits). 30. The audit team visited three mango farms and three pack houses and noted that: places of production consist of large old (20 to 50 years old) trees of a local variety, planted in the natural environment (forest). All farms are certified for organic production and no chemical plant protection products are used. Pheromone traps for fruit flies were put in place, covering six to 15 trees per trap. Vegetation under the trees was cleared and pits for destroying fallen fruits were noted; farmers confirmed regular visits of field controllers and their presence during the harvest. Logbooks of the activities of the field controllers were checked by the audit team, which confirmed recorded data for the visits during harvests, however not all regular visits to the farms were recorded; controllers confirmed their presence in pack houses during the entire selection process. They check documents and the amount of fruits at arrival and confirm separate processing and certification of fruits from each place of production. In one pack house, the controller stated that he inspected fruits at arrival and would discard the whole lot if the level of infestation is more than 25%. However, no such case ever happened. In all pack houses fruits of lower quality, overripe or damaged are removed and supplied to the local market; controllers supervise workers and also check fruits during the processing until final packing and marking of boxes. Every fruit is visually checked by workers and some fruits were also cut to check for larvae. However cuts were too deep and practically halved the mangos from both sides of the stone, not appropriate for detecting larvae; 11

16 exporters form batches of 500 kg, which is generally 100 boxes. For each batch controllers produced pre-certification attestation documents, which accompany the consignment to the airport. Controllers stated that they would refuse the certification and discard the entire batch if a single infested fruit is found in the formed batch. However, there have been no such cases so far; pack house owners were aware of EU interceptions of their consignments. Conclusions on export procedures 31. The absence of registration of operators and traceability of consignments make it difficult for the NPPO to ensure the phytosanitary compliance of exported consignments other than of mango. However, the mango export certification scheme ensures traceability and, with enhanced implementation, has the potential to improve compliance with EU requirements. 5.4 EXPORT INSPECTIONS Legal requirements Annexes I and II Part A; Annex IV, Part A Section I and Annex V, Part B to Directive 2000/29/EC. ISPM 7. ISPM 23. ISPM 31. Findings 5.4.1Facilities for performing inspections 32. The audit team visited all three main points of exit, namely Yaoude-Nsimalen and Douala airports and Douala Seaport, and noted that there were no facilities for carrying out export checks, such as an inspection table, inspection kit or adequate lighting. In addition, there were no appropriate areas for inspection. At both airports inspections are carried out outside beside the trucks (as the unloading bay is too small and generally used for other goods). In addition to that, there is no adequate space for the office for the Phytosanitary inspectors and they share a desk with other services at the point of exit. This is not in line with section 3.4 of ISPM Export inspections 33. The PPP of both Douala and Yaounde-Nsimalen Airports informed the audit team that applications for export are submitted in the morning for export checks for the late afternoon. The latest deadline for delivery of consignments is by 17:00. However, Phytosanitary inspectors at both airports confirmed that consignments also arrive after 12

17 the deadline and that there is a pressure by exporters on staff performing checks to have their consignments ready for loading onto the aircraft. For instance, when observing mango inspection at Douala Airport the audit team noted that the exporter intervened in the performance of the export check by complaining that the inspectors cut too many fruits whilst not having found any infestation. After the exporter s intervention the inspectors practically stopped the cutting of the fruits. This compromises the quality of the export checks. 34. The audit team noted that Phytosanitary inspectors at the points of exit have no access to official import requirements, guidelines for inspections or technical information of regulated pests. In the absence of a computer at the cargo terminals the inspectors cannot obtain any additional information when needed. This is not in line with sections 3.2 and 3.3 of ISPM The PPP of Douala Airport stated that they sample every fifth box (20%) for inspection, the entire contents of which are inspected. They also stated that so far they have not sent any samples for laboratory analysis. 36. The audit team observed mango inspection at Douala Airport and noted that: phytosanitary inspectors checked the accompanying documents, the field attestation and pre-export certification from the pack house; phytosanitary inspectors worked in close proximity to exporters because the export check was carried out simultaneously with the unloading of boxes from the truck directly to the aircraft pallet; every fifth box was taken aside for inspection. However, the inspection was more of a scan because the majority of fruits were only touched inside the box to check for any soft fruits. Only suspicious soft fruits or those with spots were taken out of the box for detailed visual inspection; furthermore, visual inspection of individual fruits was conducted too quickly and not using proper techniques. Very few fruits were cut, and for those that were, the cuts were too deep and not systematic to examine the entire fruit. In addition to that, inspectors used an inappropriate magnifying glass, of very low magnification. This is not in line with section 3.1 of ISPM 7 which requires that phytosanitary certification activities are conducting by personnel with the technical qualifications and skills appropriate for the duties and responsibilities; only the final outcome of the inspection is recorded at the application for export. However, inspectors did not record any details of the performed export check. This is not in line with section 4.3 of ISPM The PPP of Douala and Yaounde-Nsimalen stated that they refused to accept for export certification some consignments of leafy vegetables, which were not adequately prepared for the export. However, the PPPs further stated that they have not found any infested consignments during the export checks and thus no internal interceptions have been made so far. 13

18 38. Phytosanitary inspectors randomly check departing and arriving passengers at both airports. No fresh fruits and vegetables are allowed in hand luggage on departure and checked in luggage is inspected for proper packing and forbidden goods. Conclusions on export inspections 39. Official checks are carried out in inadequate facilities, without the necessary equipment or appropriate conditions. Consequently, facilities cannot be considered to be sufficient and safe, to allow for efficient and reliable inspections to be carried out. 40. The export checks are carried out inaccurately and inspection techniques are inefficient. Thus export checks do not provide appropriate assurance of the pest status of inspected consignments. 41. The effectiveness of checks is further compromised by the lack of time available to perform them. This is linked to the late presentation of consignments for inspection, as well as pressure by exporters, which interfere with the ability of staff to perform their duties. 42. The absence of any records of export checks is a limitation for an appropriate review of the inspection system and the effective follow-up of EU interceptions. 5.5 PHYTOSANITARY CERTIFICATES Legal requirements Article 2(1)(i); paragraphs 3 and 4 of Article 13a; and Annex IV, Part A Section I of Directive 2000/29/EC. ISPM 12. Findings 43. There are three PPPs issuing phytosanitary certificates for export to the EU (Doaula and Yaounde-Nsimalen Airport, as well as Douala Seaport), which are signed by the head of PPP or other authorised officers. The audit team noted that certificates and attached sheets are in line with the format suggested in ISPM 12. The audit team also noted that there was appropriate traceability system in place in Douala Seaport for processing the export applications and recording export certification work. In the absence of any IT system or computers, phytosanitary certificates are either hand written or completed using a typewriter. Hardcopies of phytosanitary certificates are kept by the issuing PPPs. 44. The NPPO confirmed that the text for additional declaration statements is generally provided by exporters and this was not verified by inspectors. The audit team examined phytosanitary certificates issued by the PPP of Douala Airport and noted that: in one case the statement provided on the phytosanitary certificate, declared the country to be free from Thrips. However, the NPPO stated there are no data 14

19 available regarding the presence of Thrips in Cameroon. It is not, therefore, confirmed that the phytosanitary import requirements to which those additional declarations relate, have been met. Statements provided do not reflect the real plant health status, which is not in line with Article 13a of Council Directive 2000/29/EC and Section 4 of ISPM 12 (see also section above); for consignments containing citrus fruits the statement provided on phytosanitary certificates, declared that no symptoms have been observed during official field (and vicinity) inspection since the beginning of the last cycle of vegetation. However, the NPPO stated that, for citrus fruits, inspections at the place of productions are not carried out and that the Phytosanitary certificates are issued on the basis of export inspection at the point of exit. This is not in line with Article 13a (4) of Council Directive 2000/29/EC. Conclusions on phytosanitary certificates 45. Additional declaration statements are not systematically verified by the official services and in the case of citrus fruits it is not ascertained that EU import requirements have been complied with. 5.6 ACTION TAKEN IN RESPONSE TO NON-COMPLIANCES AND EU NOTIFICATIONS OF INTERCEPTION Legal requirements ISPM 7. ISPM 23. Findings 5.6.1Non-compliances 46. The NPPO stated that there is no established procedure for dealing with internal interceptions and that it is not provided for in any written guidance. The NPPO also stated that there are no procedures in place to review the effectiveness of its export checks in light of internal interceptions. This is not in line with section 2.2 of ISPM The points of exit visited by the audit team stated that no internal interceptions had been made over the last few years (see also paragraph 36 above). During the period since 2013, 175 consignments were intercepted in the EU for the presence of harmful organisms. This suggests that the checks carried out by Phytosanitary inspectors are not reliable EU notifications of interception 48. As for internal interceptions (see section above), the NPPO stated that, except for mango, there is no established procedure in place neither follow up done for individual 15

20 EU notifications of interception. The audit team also noted that in the absence of procedures in place the review of the effectiveness of its export checks in light of individual EU interceptions is not carried out, which is not in line with section 2.2 of ISPM The PPP of Douala informed the audit team that since January 2017 they follow up every EU interception for mango. They inform the exporter and request an investigation of the case and corrective action to be taken. In one case, the exporter replaced the pheromone traps as they were found no longer effective. Conclusions on action taken in response to non-compliances and EU notifications of interception 50. Except for mango, individual EU interceptions are not systematically followed up, this prevents the NPPO from introducing corrective measures to prevent reoccurrence. 5.7 WOOD PACKAGING MATERIAL AND ISPM 15 CERTIFICATION Legal requirements Point 2 of Part A, Section I of Annex IV of Directive 2000/29/EC. ISPM No. 15. Findings 51. The NPPO informed the audit team that Cameroon implements the ISPM 15 standard. The DRCQ is in charge of authorising heat treatment (HT) facilities and providers of Methyl Bromide (MB) treatment. Authorisation is granted after inspection of facilities and is valid for five years. Initial inspection and regular annual inspections of approved facilities are carried out by the staff of the Regional delegations. Individual MB fumigation is supervised by staff of the PPP. Treated WPM is marked with the stamp of the PPP responsible for supervision. In case of HT facilities, each approved facility uses its own mark. The wood used in Cameroon for WPM is domestically sourced low grade of mixed hardwood species. 52. The audit team observed MB fumigation treatment in Douala Seaport and visited one authorised HT facility and noted that: MB treatment was conducted after advance application to the PPP of Douala Seaport and supervised by inspectors. Fumigation took place in a makeshift fumigation chamber comprising a tarpaulin, covering the stack of dunnage to be fumigated and kept in place with weights where the tarpaulin meet the floor. The MB gas was delivered via a pipe from a cylinder and the target concentration was achieved by calculating the weight of gas delivered to the specific volume of dunnage to be treated; 16

21 the treatment generally lasts for two days. Before opening, the concentration of gas is measured. A report of treatment is produced by the PPP of Douala Seaport and treated wood marked is with their appropriate ISPM 15 mark; the HT provider managed a state of the art kiln facility. It was well equipped and maintained. The temperature in chambers is typically set at 65 o C for thin wood, and 95 o C for thicker wood, with the duration of treatment from two to five days, respectively. Even though wood core temperature probes were not used, the HT was considered appropriate because of the temperature and duration of the treatment. In addition, moisture probes were used in the wood (with wood typically dried to 10% moisture); however, in the yard there were stacks of wood with supporters bearing an inappropriate ISPM mark. The HT provider explained that they used this mark because supporters were too narrow for the approved standard. This is not in line with section 4.2 of ISPM 15; the HT facility confirmed visits from the inspectors from the Regional delegation and showed inspection reports as well as their DRCQ renewal decision from However, the recent inspection of the facility has not indicated the use of inappropriate ISM mark for treated wood. Conclusions on wood packaging material and ISPM 15 certification 53. Cameroon has a system in place for implementing ISPM 15 which, despite some exceptions, can ensure compliance with the standard. 6 OVERALL CONCLUSIONS The NPPO has begun to establish an export control system for plant health. However, at present system does not include many of the elements required by EU and International Standards. There are significant weaknesses in its organisation and implementation which compromise its overall effectiveness. Therefore, pre-export checks cannot be considered reliable to ensure compliance with EU import requirements. In October 2016, in response to correspondence from the European Commission, the NPPO developed and implemented an export certification scheme for mango, the main commodity with most interceptions. This scheme has the potential to improve the overall reliability of export checks. 7 CLOSING MEETING A closing meeting was held on 18 May 2017 at the DRCQ headquarter in Yaounde during which the main findings and preliminary conclusions of the audit team were presented. The NPPO accepted the information provided by the audit team and expressed its firm commitment to address the shortcomings identified. 17

22 8 RECOMMENDATIONS No. Recommendation 1. Ensure that all officials responsible for performing inspections of export to the EU have an appropriate level of technical competence in line with Article 2(1)(i) of Council Directive 2000/29/EC and section 3.1 of ISPM 7. The recommendation is based on conclusions No. 17 and 39. Associated findings No. 13 and Ensure that officials responsible for performing export inspections have access to an appropriate level of technical information and guidance in line with sections 3.2, 3.3 and 4.2 of ISPM 7, in particular, ensure access to EU import requirements. The recommendation is based on conclusions No. 17 and 18. Associated findings No. 10, 11 and Ensure that NPPO has appropriate laboratory technical capacity available for testing harmful organisms of concern to the EU, in accordance with sections 2.2 and 3.4 of ISPM 7. The recommendation is based on conclusion No. 19. Associated finding No Ensure that appropriate checks are carried for all consignments of all plants and plant products intended for export to the EU. In particular, that staff performing checks have access to adequate equipment, materials and facilities and a sufficient and safe inspection place are available in line with section 3.4 of ISPM 7 and in order to carry out reliable export checks to ensure that consignments meet EU requirements in line with Article 13 of Council Directive 2000/29/EC. The recommendation is based on conclusions No. 39, 40 and 41. Associated findings No. 32, 33 and Ensure that for each consignment, records are kept on inspection, personnel, timing and results in line with section 4.3 of ISPM 7. The recommendation is based on conclusion No. 42. Associated finding No Ensure that consignments for export to the EU are only issued with a phytosanitary certificate when relevant EU import requirements are met and that additional declaration statements are given only when they are officially verified, in line with Article 13a of Council Directive 2000/29/EC and Section 4 of ISPM 12. The recommendation is based on conclusions No. 18 and

23 No. Recommendation Associated findings No. 10 and Ensure that individual internal and EU interceptions are appropriately followed up to enable corrective measures to be taken to avoid reoccurrence and that the effectiveness of the system of checks is reviewed in light of these interceptions in line with sections 6 of ISPM 7 and 2.6 of ISPM 23. The recommendation is based on conclusion No. 50. Associated findings No. 46 and 48. The competent authority's response to the recommendations can be found at: 19

24 ANNEX 1 LEGAL REFERENCES Legal Reference Official Journal Title Dir. 2000/29/EC OJ L 169, , p 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

25 ANNEX 2 STANDARDS QUOTED IN THE REPORT International Standard Title ISPM No. 5 International Standard on Phytosanitary Measures Publication No 5, Glossary of phytosanitary terms, Food and Agriculture Organisation, Rome, Adopted 2016; published 2016; ISPM No. 7 International Standard on Phytosanitary Measures Publication No 7, Phytosanitary certification system, Food and Agriculture Organisation, Rome; Adopted 2011; published 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 ISPM No. 12 International Standard on Phytosanitary Measures Publication No 12, Phytosanitary certificates, Food and Agriculture Organisation, Rome; Adopted 2014; published ISPM No. 23 International Standard on Phytosanitary Measures Publication No 23, Guidelines for Inspection, Food and Agriculture Organisation, Rome, Adopted 2005; published ISPM No. 31 International Standard on Phytosanitary Measures Publication No 31, Methodologies for sampling of consignments, Food and Agriculture Organisation, Rome, Adopted 2008; published