KENYA'S COMMENT TO EU NOTIFICATION ON ADDITIONAL MEASURES BY
EU ON FCM IN ROSE FLOWERS EXPORTS TARGETING FCM IN ROSE
FLOWERS FROM THIRD COUNTRIES
Introduction
1) In a notification to the WTO dated 2nd May 2024, the European Union (EU)
G/SPS/N/EU/759 submitted its intent of introducing enhanced requirements for
imports of cut roses from those origins where the pest is known to be present to
protect its territory form introduction of the pest.
2) The European Union (EU) is Kenya’s major market for a wide range of
horticultural produce including fresh cut flowers, vegetables, fruits and an
assortment of herbs.
3) Kenya has over the years supplied EU member states with high quality flowers
thus contributing to Kenya’s domestic growth and livelihood for over 4 million
people.
4) It is Kenya’s desire to continue growing the flower subsector by fostering
collaboration in safe trade.
Kenya’s Comments on the proposed measure
5) Kenya acknowledges the conclusions of the scientific opinion of European
Food Safety Authority (EFSA) regarding the probability of introduction of
Thaumatotibia leucotreta (Meyrick) into the Union territory through the
imports of cut roses as an introduction pathway.
6) Kenya is also cognizant of the risks posed by Thaumatotibia leucotreta
(Meyrick) to the Union territory as it is listed as a Union quarantine pest not
known to occur in EU territory.
7) Kenya, further notes that EU intents to introduce enhanced requirements for
imports of cut roses from those origins where the pest is known to be present to
protect its territory form introduction of the pest. Specifically, the proposed
enhanced requirements are contained in the Draft Commission Implementing
Regulation amending Implementing Regulation (EU) 2019/2072 as regards the
listing of pests and rules on the introduction into, and movement within, the
Union territory of plants, plant products and other objects.
8) While recognizing that the proposed enhancement of import requirements by
EU under the provisions of IPPC Art. VII. (1), Kenya expresses its concern that
the proposed measures on import requirements will have far reaching impact
on the social economic benefit of flower trade between the two territories.
9) While Kenya acknowledges that its horticultural subsector has been facing
challenges of False Codling Moth (FCM), a quarantine pest in EU; it has been
implementing an integrated approach in managing the pest using recommended
international guidelines, principles and standards.
10) Kenya underscores her commitment to fully comply and protect EU from
introduction of quarantine pests through exports of roses.
11) In view of the above, Kenya requests the EU to reconsider postponing the
timelines for coming into force of the new requirements; and invites the EU to
engage and work together with Kenya’s stakeholders to enhance efforts
towards addressing the pest of concern.
12) Based on the foreseeable effects in the production and phytosanitary
certification, Kenya proposes that adequate time should be given to allow for
the NPPO and producers to implement strategies for compliance.
13) Kenya notes the challenging posed in implementing the proposed changes
abruptly, and fears that the proposed measures are more trade restrictive that
necessary to achieve the EU’s appropriate level of protection.
14) Kenya proposes the consideration for implementing the measures in a phased
manner, under a framework to allow for safe transition.
15) Kenya reiterates its willingness to establish this implementation framework in
collaboration with the European Commission for the mutual benefit of both
territories and without compromising on plant health. Further, Kenya requests
for capacity building support for the NPPO and the industry players.
16) The Delegation of Kenya’s has the honour to reiterate its highest consideration
to the European Union Commission.
Ends
