EUROPEAN COMMISSIONHEALTH AND CONSUMERS DIRECTORATE-GENERAL

Directorate F - Food and Veterinary Office

FINAL REPORT OF AN AUDIT

CARRIED OUT IN

BANGLADESH

FROM 30 JANUARY TO 07 FEBRUARY 2013

IN ORDER TO EVALUATE THE SYSTEM OF OFFICIAL CONTROLS FOR EXPORT OF PLANTS TO THE EUROPEAN UNION

DG(SANCO) 2013-6815 - MR FINAL

Ref. Ares(2013)1846745 - 07/06/2013

Executive Summary

This report describes the outcome of an audit carried out by the Food and Veterinary Office (FVO) in Bangladesh from 30 January to 7 February 2013.The objective of the audit was to evaluate the system of official controls for export of plants originating in Bangladesh and exported to the EU. In addition, the action taken to address the shortcomings identified in the previous audit DG SANCO/2010-8616 was assessed.

The audit was also undertaken in response to continued interceptions in the European Union (EU) of consignments of plants originating in Bangladesh, in particular for the presence of citrus canker, citrus blackspot, thrips and fruit flies.

The audit team found that:

There is a clear structure and division of responsibilities in the plant health service in Bangladesh. There is also good communication with producers and exporters.

There is a plan in place to address the shortcomings identified during the previous audit and some have been addressed recently. There is also a strong commitment to improve the export system through the implementation of the project ‘Strengthening Phyotosanitary Building in Bangladesh’ and the ‘Special program for production of exportable citrus and vegetables’.Although, the export system now appears to be more in line with the EU requirements, in practice, weakness were noted in each step of the export system, in particular in the pre-export inspection.The number of interceptions of harmful organisms in produce from Bangladesh in 2012 was unacceptably high and it is imperative that action is taken urgently to reduce the interceptions and the potential risk to the EU of the introduction of harmful organisms.Recommendations are made in this report to address the shortcomings found.

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Table of Contents 1 INTRODUCTION ........................................................................................................................1 2 OBJECTIVES ...........................................................................................................................1 3 LEGAL BASIS ..........................................................................................................................1

3.1 RELEVANT EU LEGISLATION ...........................................................................................................2 3.2 INTERNATIONAL STANDARDS ...........................................................................................................2

4 BACKGROUND ..........................................................................................................................2 4.1 NOTIFICATIONS OF INTERCEPTIONS ...................................................................................................2 4.2 PRODUCTION AND TRADE INFORMATION ............................................................................................3

4.2.1 PRODUCTION ........................................................................................................................3 4.2.2 EXPORTS .............................................................................................................................4

5 FINDINGS AND CONCLUSIONS ...................................................................................................5 5.1 ORGANISATIONAL ASPECTS OF PLANT HEALTH CONTROLS .....................................................................5

5.1.1 NATIONAL PLANT PROTECTION ORGANISATION ............................................................................5 5.1.2 LEGISLATION .........................................................................................................................6 5.1.3 RESOURCES ...........................................................................................................................6 5.1.4 GUIDELINES AND TRAINING .......................................................................................................7 5.1.5 LABORATORIES AND TECHNICAL SUPPORT .....................................................................................7 5.1.6 COMMUNICATION WITH STAKEHOLDERS ........................................................................................7

5.2 PLANT HEALTH STATUS ..................................................................................................................8 5.3 EXPORT PROCEDURES ....................................................................................................................9

5.3.1 GENERAL PROCEDURES ............................................................................................................9 5.3.2 SPECIAL PROGRAM FOR PRODUCTION OF EXPORTABLE CITRUS AND VEGETABLES ....................................9 5.3.3 EXPORT OF BETEL LEAVES TO THE EU .....................................................................................10 5.3.4 REGISTRATION AND TRACEABILITY OF CONSIGNMENTS ....................................................................11

5.4 EXPORT INSPECTIONS ...................................................................................................................12 5.4.1 FACILITIES FOR PERFORMING INSPECTIONS ..................................................................................12 5.4.2 PLACE OF PRODUCTION .........................................................................................................12 5.4.3 POINT OF EXIT .....................................................................................................................13

5.5 PHYTOSANITARY CERTIFICATES .......................................................................................................14 5.6 ACTION TAKEN IN RESPONSE TO INTERNAL INTERCEPTIONS AND NOTIFICATION OF INTERCEPTIONS FROM THE EU ..................................................................................................................................................15

5.6.1 INTERNAL INTERCEPTIONS .......................................................................................................15 5.6.2 EU NOTIFICATIONS OF INTERCEPTION .......................................................................................15

6 OVERALL CONCLUSIONS .........................................................................................................16 7 CLOSING MEETING ................................................................................................................16 8 RECOMMENDATIONS ...............................................................................................................16ANNEX 1 - LEGAL REFERENCES .................................................................................................18ANNEX 2 – STANDARDS QUOTED IN THE REPORT ...........................................................................19

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ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT

Abbreviation ExplanationBARI Bangladesh Agriculture Research InstituteBBLEA Bangladesh Betel Leaf Exporters AssociationBFVAPEA Bangladesh Fruits, Vegetables and Allied Products Exporters AssociationConsignment Defined in ISPM 5 as a quantity of plants, plant products and/or other

articles being moved from one country to another and covered, when required, by a single phytosanitary certificate

DAE Department of Agriculture Extension of the Ministry of AgricultureEU European UnionEUROPHYT European Network of Plant Health Information Systems – in this report it

refers only to the component constituting the EU’s notification system for interceptions for plant health reasons

FVO Food and Veterinary OfficeGAP Good Agricultural PracticeHa HectareHarmful organism Defined in Article 2 (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.

HORTEX Horticulture Export Development FoundationIPPC International Plant Protection ConventionISPM International Standards for Phytosanitary MeasuresLot Defined in ISPM 5 as a unit of a single commodity, identifiable by its

homogeneity of composition, origin, etc., forming part of a consignmentNPPO National Plant Protection OrganisationPlants 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

PPW Plant Protection WingPQS Plant Quarantine Section of the PPWRASFF Rapid Alert System for Food and FeedSAAO Sub Assistant Agriculture Officer of the DAESOPP Sodium OphenylphenateT TonneTephritidae Family of insects commonly called “fruit flies”Thysanoptera Order of insect commonly called “thrips”

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1 INTRODUCTION

This audit took place in Bangladesh from 30 January to 7 February 2013 and was undertaken as part of the Food and Veterinary Office's (FVO) planned audit programme.

The audit team consisted of two auditors from the FVO and one National Expert from an European Union (EU) Member State. Representatives from the National Plant Protection Organisation (NPPO), the Plant Protection Wing of the Ministry of Agriculture, accompanied the FVO team during the audit.

An opening meeting was held on 30 January 2013 at the headquarters of the NPPO in Dhaka, during which, the objectives and itinerary for the audit were confirmed and additional information necessary for the conduct of the audit, was requested.

2 OBJECTIVES

The objective of the audit was to evaluate the system of official controls for the export of plants regulated by Council Directive 2000/29/EC to the EU.The audit was undertaken due to the ongoing interceptions of harmful organisms notified by EU Member states in EUROPHYT, the EU rapid alert system for plant health (see section 4.1). Particular emphasis was given to those regulated plants and plant products that are hosts of Thrips palmi and other Thysanoptera, non-European Tephritidae (fruit flies), Xantonomonhas anoxopodis pv. citri and Guignardia citricarpa.In addition, the action taken to address the shortcomings identified in the previous audit (DG SANCO/2010-8616) was assessed. The table below lists sites visited and meetings held in order to achieve these objectives:

Meetings/visits No. CommentsCompetent Authorities

Central 3 Plant Protection Wing, DhakaRegional 2 Department of Agriculture Extension, Norshingdhi and Plant

Quarantine Section at Hazrat Shajalal International Airport, Dhaka.

Laboratories 1 Plant Protection Wing, DhakaPlant health control sitesProduction sites 2 Citrus producersExporter Associations 3 HORTEX

Bangladesh Fruits, Vegetables and Allied Products Exporters Association (BFVAPEA)Bangladesh Betel Leaf Exporters Association

Pack house 1 BFVAPEA Hazrat Shajalal International Airport, Dhaka.

3 LEGAL BASIS

The audit was carried out under the mandate of Articles 21 and 27a of Council Directive 2000/29/EC, and with the agreement of the NPPO of Bangladesh.

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3.1 RELEVANT EU LEGISLATION

Council Directive 2000/29/EC provides for protective measures against the introduction into and spread within the EU organisms harmful to plants or plants products. The legal reference for this Directive is listed in Annex I.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 (ISPM) issued by the IPPC thus provide a basis, in addition to the EU import requirements, for evaluating official export controls in contracting parties. Bangladesh is a contracting party to the IPPC.The full text of all adopted ISPMs is available on the International Phytosanitary Portal of the International Plant Protection Convention (https:// www.ippc.int ). The ISPM that were of particular relevance to this audit are listed in Annex II. 4 BACKGROUND

This was the second audit carried out by the FVO to Bangladesh on plant health issues. The first audit took place in June 2010 (DG(SANCO) 2010-8616), the report of which is available on the FVO´s website: http://ec.europa.eu/fod/fvo/ir_search_en.cfmThis second audit was carried out in response to the continued and increasing number of interceptions of harmful organisms in consignments exported from Bangladesh, that have been notified by EU Member States.

4.1 NOTIFICATIONS OF INTERCEPTIONS

Between 1 June 2010 to 31 December 2012, EU Member States notified a total of 406 interceptions on consignments exported from Bangladesh, in EUROPHYT, the EU's notification system for plant health. As detailed in table 1 below, 158 of these interceptions were due to the presence of a harmful organism. The remaining 248 were due mainly to non-compliant or missing phytosanitary certificates.Table 1: Summary of notifications of interception by EU Member States (source EUROPHYT)

Reason 2010(01/06-31/12) 2011 2012

Presence of harmful organism 20 26 112

Other reasons, includingdocumentary reasons. 37 108 103

Total 57 134 215

The most commonly intercepted harmful organisms include: Thrips palmi and other Thysanoptera (thrips) 45 interceptions in 2012, non-European Tephritidae (“fruit flies”) 30 interceptions in 2012, Xanthomonas anoxopodis pv. citri (cirus canker) 20 interceptions in 2012, Guignardia citricarpa (citrus blackspot) 5 interceptions in 2012, Diaphania indica (cucumber moth) 5 interceptions in 2012 and Leucinodes orbonalis (eggplant fruit borer) 4 interceptions in 2012.

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Thrips were intercepted mainly in eggplant and Momordica sp.. Fruit flies were found mainly on Momordica charantia (bitter gourd), Trichosanthes sp. (serpent gourd) and Psidium sp. (guava); citrus canker and citrus blackspot on fruits of citrus; cucumber moth and eggplant fruit borer were found on bitter gourd and eggplant respectively.Further details on the status of harmful organisms of concern to the EU are provided in section 5.2 below.

4.2 PRODUCTION AND TRADE INFORMATION

Unless specified otherwise, the data quoted in the following sections and elsewhere in the report, was provided by the NPPO.

4.2.1 Production

The total area of Bangladesh is 147,570 km2 and the total population is about 150 million. The average size of places of production is 0.25 hectares. The climate of Bangladesh is very favorable for the production of cereals, vegetables, fruits, oil seeds and grains. Bangladesh has a tropical monsoon type climate and the temperature ranges from 10oC-30oC in winter and 21oC-34oC in summer. The following tables provide details of the production of key vegetables and fruits in Bangladesh.Table 2: Production of vegetables in Bangladesh 2010 – 2012

Local common name

Botanical nameArea (hectare) and production (tonnes)

2010 2011 2012ha t ha t ha t

Sweet gourd Cucurbita maxima 17,336 296,970 15,653 310,166 19,772 388,553White gourd Benincasa cerifera 17,123 193,383 14,348 223,725 14,468 232,068Bottle gourd Lagenaria siceraria 32,122 662,403 32,054 759,525 32,200 765,360Bitter gourd Momordica charantia 14,305 142,351 15,374 189,910 16,236 185,285Spiny gourd Momordica cochinchinensis 8,897 114,267 6,903 101,918 7,572 107,534Pointed gourd Tricosanthes dioica 13,236 185,443 13,337 200,866 13,373 198,391Snake gourd Trichosanthes anguna 12,891 133,196 12,069 138,983 12,340 138,713Ribbed gourd Luffa acutangula 12,231 115,614 10,861 118,409 10,217 106,900Cucumber Cucumis sativus 11,731 133,499 10,581 137,864 14,375 187,944Yard long bean Vigna sinensis 10,052 86,534 8,849 87,127 9,180 90,092Okra Abelmoschus esculentus 19,961 171,870 17,638 169,782 19,165 179,702Brinjal Solanum melongena 30,548 517,069 32,087 520,357 30,676 625,537Beans Dolichos lablab 39,287 411,861 40,249 444,347 40,100 432,000Amaranth Amaranthus tricolor 22,098 273,875 20,478 272,609 19,421 262,528Radish Raphanus sativus 53,083 1,182,236 53,095 1,396,352 51,100 1,203,000Arum Colocasia sp. 17,898 286,099 13,935 259,992 17,432 333,379Chilli Capsicum sp. 179,000 204,900 182,500 256,000 181,560 250,000Others - 29,829 346,233 268,055 482,792 29,030 350,903

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Table 3: Production of fruits in Bangladesh 2010 – 2012

Name Botanical nameArea planted (hectare) and production (tonnes)

2010 2011 2012ha t ha t ha t

Citrus Citrus sp. 13,220 114,409 14,750 120,380 15,370 125,500Papaya Carica papaya 26,839 425,457 25,670 402,340 24,580 39,820Jackfruit Artocarpus heterophyllus 79,280 1,352,084 80,300 1,525,000 80,500 1,582,000Olive Elaeocarpus robustus 3,910 46,573 4,000 47,900 4,050 48,200

4.2.2 Exports

From the total volume of exported vegetables and fruits, more than 54% is exported to the EU, UK being the main market (46%), followed by Italy (5%), Germany (2%) and others (1%) respectively. The second export market is the Middle-East (42%) followed by Asia (3.5%) and North America (0.5%). The export of vegetables and fruit to the EU between 2010 and 2012 is detailed in the following tables:Table 4: Exports of fresh fruits and vegetables exported to the EU between 2010 and 2012

Local common name Botanical name Quantity (tonnes)2010 2011 2012

Okra Abeimoschus esculentus 490 521 821Bottle gourd Lageneria siceraria 523 489 502White gourd Benincasa cerifera 485 365 681Arum Colocasia sp. 383 389 501Snake gourd Trichosanthes anguna 482 400 208Ribbed gourd Lufata acutangula 320 190 205Brinjal Solanum melongena 340 382 84Bitter gourd Momordica charanta 250 269 183Amaranth Amaranthus tricolor 485 493 498Beans Dolichos lablab 360 379 392Spiny gourd Momordica cochinchinensis 175 198 308Pointed gourd Tricosanthes dioica 440 587 488Yard long bean Vigna sinensis 429 367 280Radish Raphanus sativus 223 122 132Kangkong/Swamp Cabbage Ipomea sp. 227 155 80Green chilli Capsicum sp. 124 267 484Indian spinach Spinacea oleracea 230 149 121Sweet gourd Cucurbita maxima 220 389 280Corm Colocasia sp. 887 955 1,030

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Table 5: Exports of fresh fruits to the EU between 2010 and 2012

Local common name Botanical name Quantity (tonnes)2010 2011 2012

Mango Mangifera indica 73 68 69Jack fruit Artocarpus heterophyllus 374 550 537Olive Elaeocarpus robustus 5 68 39Hog plum Spondia sp 30 88 62Citrus Citrus sp 6 - 224

The total volume of export of vegetables has been around 10,000 t per year. Colocasia is the main product exported followed by okra, white gourd and bottle gourd. The quantities of exported fruit to the EU has been increasing every year and the main fruits exported are: jack fruit, citrus and mangos.

All fresh fruit and vegetables exported to the EU are transported by air from Hazrat Shahjalal International Airport in Dhaka. The NPPO and BFVAPEA informed the audit team that the main limitation for increasing export volumes is the lack of air freight capacity.

5 FINDINGS AND CONCLUSIONS

5.1 ORGANISATIONAL ASPECTS OF PLANT HEALTH CONTROLS

Legal requirementsArticle 2(1)(i) of Directive 2000/29/EC establishes the requirements for a measure or statement, to be considered as 'official'. In particular, '…if it is made by representatives of the official national plant protection organisation of a third country, or, under their responsibility, by other public officers who are technically qualified and duly authorised…'

ISPM 7 describes the basic elements of the phytosanitary certification process and the requirements for a certification system to fulfil these functions. Sections 1 (Legal Authority), 2 (Management responsibility), 3 (Resources), 4.3 (Procedures), 5 (Communication) and 6 (Review mechanism) are of particular relevance.

ISPM 23 describes the objectives and requirements for inspections. Of particular relevance here, are sections 1.3 (responsibility for inspection) and 1.4 (requirements for inspectors).

Findings 5.1.1 National Plant Protection Organisation

The NPPO stated that there have been no changes in its organisation since the previous audit. A detailed description is included in the previous audit report. In summary:

• the Plant Protection Wing (PPW) of the Department of Agricultural Extension (DAE) which is part of the Ministry of Agriculture, acts as the NPPO.

• The PPW is sub-divided into four sections, each headed by a Deputy Director: Plant Quarantine, Pesticide Administration and Quality Control, Surveillance and Operations.

• The Plant Quarantine Section (PQS) is responsible for the inspection of imported and exported plants and plant products, and for the issue of phytosanitary certificates. Inspectors are based at 26 border inspection posts. It is responsible for performing the pre-export check

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for plant health (see section 5.4.3 below) and for issuing the phytosanitary certificate (see section 5.5 below).

5.1.2 Legislation

The PPW stated that a new act the “Plant Quarantine Act, 2011” was approved 5 April 2011 but it will effectively enter into force with the adoption of implementing rules, which is foreseen for June 2013.The new Act foresees the establishment of a new National Plant Protection Authority and in case of export of plants or plant products that no exporters shall export plants or plant products without a phytosanitary certificate and all consignments must be checked by a plant quarantine officer to ensure compliance with the phytosanitary requirements of the importing country.Until the entry into force of the implementing rules, the legal basis for the controls carried out by the PPW remains the Destructive Insects and Pests Rule 1966 (Plant Quarantine), as amended July, 1989.

5.1.3 Resources

The PPW informed the FVO team that the number of staff involved in the export programme has increased following the creation of four new border inspection posts. The total number of staff belonging to the PQS is now 190 compared to 119 at the time of the previous audit. There are 73 professional staff (38 graduates and 35 diploma) and 117 support staff.The PPW stated that in response to the previous audit, a capacity building project ‘Strengthening Phyotosanitary Building in Bangladesh’ has been adopted, together with the ‘Special program for production of exportable citrus and vegetables’, hereafter the 'programme' (see section 5.3.2). Substantial state funding was allocated to both programmes.The project for ‘Strengthening Phyotosanitary Building in Bangladesh’, includes training for officials and awareness of farmers, the construction of a new pack house for fresh produce and eight new wood packaging treatment facilities as well as the establishment of seven new border inspection posts and improvement of laboratory facilities. Time frame for the implementation of the plan is detailed in table 6 below.Table 6: Plan of activities of the 'Strengthening Phyotosanitary Building in Bangladesh' project:

Activities No. of events

Starting year of implementation

Year of completion

Construction of central packing house for export of fruits and vegetables ( 6000 m2)

1 2013-14 2014-15

Establishment of post entry quarantine center 7 2013-14 2015-16Workshops 20 2012-13 2014-15Study tour for policy makers 20 2012-13 2013-14Training (Plant Quarantine officials) 40 2012-13 2015-16Training (Exporters, packers and handlers) 150 2012-13 2015-16Training (Laboratory officials) 36 2013-14 2014-15Procurement of Laboratory Equipment (for 10 laboratories)

296 2013-14 2015-16

Establishment of Heat Treatment plant 4 2012-13 2013-14Establishment of Methyl Bromide fumigation plant 4 2012-13 2014-15

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5.1.4 Guidelines and training

The FVO team was informed by the PPW that guidelines and work instructions had been provided to staff performing checks in the export chain. These include the 'Quarantine Handbook' and technical leaflets for farmers and PPW staff. The FVO team noted that the handbook provides general information on import and export procedures (with reference to some EU import requirements and ISPM 15). The leaflets cover 'Directives for Canker free citrus production', 'Directives for Thrips free vegetable production' and 'Directives for White fly free vegetables production'. These cover the management of EU harmful organisms in production sites and have been issued as part of the special programme (see section 5.3.2 below). Training has been provided on the integrated management of these organisms.During the field visits the FVO team noted that neither the PPW inspectors nor the Sub assistant agriculture officers (SAAO) have access to guidelines or working instructions for performing pre-export checks of specific commodities or detection of specific harmful organisms.Although many of the officials performing pre-export checks are qualified in plant pathology, the FVO team noted significant shortcomings in their technical expertise and conduct of the checks (see section 5.4).

5.1.5 Laboratories and technical support

The general structure of the laboratories in Bangladesh has not changed since the last audit.Each point of entry/export is equipped with a laboratory to enable an initial screening of samples to be carried out. The Central Quarantine Laboratory of the PPW acts as the national reference laboratory for plant health. The laboratory may request assistance from research institutes and universities if necessary.The FVO team visited the Central Quarantine Laboratory and met staff. It was noted that the laboratory has adequate equipment for performing visual analysis of samples and limited microbiological analysis for plant health. It was noted that, in the last three years, the laboratory had received 3 samples from imported commodities. The technical specialists in the laboratory do not receive regular training, or on-site experience in other laboratories within Bangladesh, or field visits to maintain their expertise. The FVO team also met with representatives of the Bangladesh Agriculture Research Institute (BARI) who were involved in the surveys for citrus diseases (see section 5.4.2), including the analysis of samples. The representatives confirmed that the Institute is able only to perform visual diagnosis of such diseases.

5.1.6 Communication with stakeholders

Five major initiatives have taken place since the last audit. These included meetings with all the stakeholders involved in the export chain and two research institutions.The main stakeholders related to exports of plant and plant products are Hortex Export Development Foundation (Hortex) and the Bangladesh Fruits, Vegetables and Allied Products Exporters Association (BFVAPEA).Hortex is a non-profit organisation for the development, promotion and marketing of high value agricultural products for export. Its main roles are to provide technical assistance on production, post-harvest management and processing, and cool chain management services. The foundation

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representative informed the FVO team that they actively participated in the initial citrus canker survey and they are discussing with the Ministry of Agriculture to establish a protocol for Good Agricultural Practice (GAP) certification.The objectives of the BFVAPEA are to promote exports and enhance trade and business knowledge for perishable horticultural products as well as to provide a site for exporters to sort and pack their consignments. The BFVAPEA represents exporters of fresh fruit and vegetables and has around 500 members from which 150 are regular exporters of fresh produce to the EU.The FVO team also met with representatives of the Bangladesh Betel Leaf Exporters Association (BBLEA) in connection with the export programme for betel leaves (see section 5.3.3 below).The representatives of these organisations met by the FVO team all stated that they had good cooperation and communication with the NPPO in particular with regards to the establishment and implementation of the export programmes (see section 5.3 below).Conclusions on organisational aspects of plant health controlsThe organisation of the PPW has not changed since the last audit; legislation has been adopted that will allow the establishment of a National Plant Protection Authority. There is a good communication and cooperation with stakeholders as it relates to plant health.Limited guidelines and training has been provided to staff performing checks, however this has not addressed the performance of the checks, or ensured that staff have the specific technical knowledge necessary to ensure that their checks are carried out appropriately. In this respect, the staff performing checks of plants for export to the EU, are not technically qualified, as required by 2(1)(i) of Directive 2000/29/EC. There is also only limited laboratory and diagnostic support available for the NPPO regarding plant health. There are no measures in place to ensure that the technical ability of staff responsible for performing analysis related to export checks of plants exported to the EU is maintained.

5.2 PLANT HEALTH STATUS

Legal requirementsPart A of Annexes I and II to Directive 2000/29/EC lists those harmful organisms whose introduction and movement within the EU is banned. Those of particular relevance to this audit include non-European Tephritidae (“fruit flies”), Thrips palmi and other Thysanoptera (thrips), citrus canker (Xanthomonas anoxopodis pv. citri), citrus blackspot (Guignardia citricarpa) and citrus leaf spot (Cercospora angolensis).

Commission Decision 2006/473/EC recognises Bangladesh as being free from citrus blackspot (Guignardia citricarpa) and citrus leaf spot (Cercospora angolensis). The EU does not recognise any areas of Bangladesh as being free from citrus canker (Xanthamonas axonopodis pv. citri).FindingsThe PPW stated that the status of the harmful organisms of concern to the EU has not changed since the previous audit, with the exception that citrus leaf spot (Cercospora angolensis) is now present in Bangladesh.The PPW stated that following the previous FVO audit, a specific survey for citrus canker, citrus blackspot and citrus leaf spot was undertaken in 2010/2011 by a technical committee formed by PPW, Hortex, BARI and DAE experts. All three organisms were found to be present in Sylhet District. No symptoms were found in Norshingdhi District, and as a result, the PPW stated that this area is considered to be free from these harmful organisms.

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The PPW stated that the Norshingdhi District consists of mainly new plantations, the majority of which are of a local variety 'Jara lebu' of Citrus pennivesiculata. Experts from BARI informed the FVO team that research had been carried out that indicated that Jara lebu is tolerant to the three harmful organisms. The PPW stated that the survey is a continuous process and it will start in 15 April with two main experts from DAE and the SAAO involved in the field inspections. ConclusionA survey for three citrus diseases of concern to the EU has been carried out. Cercospora angolensis Guignardia citricarpa, and Xanthamonas campestris are all confirmed as a result of surveys to be present in Bangladesh.The NPPO claims that, based on research, Citrus pennivesiculata (var. Jara lebu) is tolerant to these three diseases.

5.3 EXPORT PROCEDURES

Legal requirementsAnnex IV, Part A Section I establishes specific requirements for plants and plants products that must be met in order to be exported to the EU. These may vary depending on the status of the relevant harmful organism in the country of origin.

Annex V, Part B to Directive 2000/29/EC lists the plants, plant products and other objects which must be subject to a plant health inspection in the country of origin or the consignor country, if originating outside the EU and accompanied by a phytosanitary certificate.

ISPM 7 describes the basic elements of the phytosanitary certification process and the requirements for a certification system to fulfil these functions.

Findings 5.3.1 General procedures

The general export procedure for the commodities not included in the programme has not changed since the previous audit. All fruit and vegetable consignments intended for export the EU are inspected upon a request from the exporter and the consignment must be present to the PQS in Hazrat Shahjalal International Airport for inspection. Inspectors from PQS inspect a sample from the lot and if no signs of EU harmful organisms are found a phytosanitary certificate is issued by PQS.

5.3.2 Special program for production of exportable citrus and vegetables

The main change in the export system from Bangladesh was the establishment of a general export programme. The programme covers, at the moment, four commodities: citrus fruits (Citrus sp.), bitter gourd (Momordica charantia), teasle gourd (Momordica dioica) and eggplant (Solanum melongena). It is foreseen to extend the programme in the near future to other exported vegetables.The programme includes training and awareness of officials and stakeholders. In 2012, training was provided to 300 farmers and 150 SAAO on pest and disease management of citrus and cucurbit vegetables. The programme also covered training to 50 exporters and 50 quarantine officials. By June 2013 training will be provided to 2,400 farmers, 240 SAAO and 200 exporters and officials.The other component of the programme was the establishment of new citrus orchards and management of old citrus garden in Norshingdhi District. In the current year there is a plan for the establishment of new production sites: 650 citrus, 250 gourds, 250 eggplant, 200 other cucurbits

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and the management of 600 old citrus orchards.The PPW, DAE, with the assistance of BFVAPEA selects the citrus orchards eligible for export. The DAE registers the farmers which are accompanied by an SAAO. The exporters must have a contract with farmers from whom they source produce.

The main tasks of the SAAO is to visit the orchards on a regular basis, to check for the presence of harmful organisms, advise farmers how to prevent the introduction of harmful organisms, when and how to treat and fertilize the soil. It is also requested that farmers maintain a register of all activities done in the orchards including the quantity of fruits harvested and certification of EU regulated pest free harvest.

Fruits to be exported to the EU have to be harvested in the presence of a SAAO and only from orchards free from EU harmful organisms. Following the harvest, a post-harvest certificate is issued by the SAAO to accompany the produce until the point of exit. The audit team was informed that the certificate is now starting being used for the three vegetables also covered by the programme.

For products under the programme, the official export controls are carried out at three stages: field, pack house and prior to export. The initial stage is carried out by SAAO and the last two inspections by plant health inspectors from PPW.

• The field inspection is done by the SAAO. The main aim of this inspection is to confirm the plant health status in the field and issue the pre-export declaration to be forwarded, with the consignment, to the pack house.

• There is a pack house PPW inspection at produce intake. This is followed by washing and a treatment in the case of citrus fruits. If harmful organisms are found or suspected, the lot is rejected.

• The pre-export inspection in the exit point is carried out by PPW plant health inspectors.

The PPW plant health inspection is only made if a post-harvest certificate is presented by the exporter together with the consignment.The FVO team met the Deputy Director of the DAE regional office in Norshingdhi, which is the main area for export of citrus fruits to the EU. The audit team was informed that in the district there are around 1,100 citrus orchards with a total area of 142ha and an average area of 0.14ha. There are around 850 farmers producing citrus fruits and vegetables and the number of SAAO working in the region is 240.The FVO team could confirm that SAAO are DAE staff working in the 64 districts of Bangladesh and their main task is agricultural extension. They are involved in the programme at the local level since they give technical advice to farmers and ensure farm record keeping and traceability. The SAAO were trained on detection of symptoms of the citrus diseases and on the main pest of vegetables of concern to the EU.

5.3.3 Export of Betel leaves to the EU

Bangladesh is a significant exporter of Betel leaves (Piper betle - commonly known as paan leaves). In 2012, the value of such exports was US$ 56 million; the main markets are the UK, Italy and Saudi Arabia. Betel leaves are not regulated by Directive 2000/29/EC.

There have been a significant number of RASFF alerts for the presence of Salmonella and E. coli 0157:H7 on such leaves since 2010. In 2011-2012 there were 77 such notifications. According to the Export Promotion Bureau, Salmonella was found in 44 out of 60 consignments tested by the UK in 2011. The NPPO stated that no betel leaves had been exported to the EU since November 2012.

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The FVO team met with representatives of the Bangladesh Betel Leaf Exporters Association BBLEA), the NPPO and Hortex, who informed the team that the Ministry of Commerce held an initial meeting with stakeholders on 13 December 2011 in order to discuss the RASFF alerts and possible action to address the issue. These included the establishment of an expert committee and the authorisation of the BBLEA to certify betel leaf producers for export. An inter-ministerial meeting on 6 January 2013, chaired by the Ministry of Commerce established a programme to enable the export of pathogen-free betel leaves to the EU. The NPPO and BBLEA informed the FVO team that the programme was still being developed, however it would contain the following key elements, in line with the Decision of the Ministry of Commerce, which was adopted following the above meeting:

• All betel leaves exported to the EU must originate from contract farmers, or other sources, certified for this purpose by the BBLEA.

• The certification will be based on place of production freedom from Salmonella and E. coli, confirmed by laboratory testing of samples taken from the place of production and on a random basis, from individual consignments, and the implementation of good hygiene practice during harvesting and transport.

• The laboratory testing will be carried out by out by the Bangladesh Centre for Scientific and Industrial Research in Dhaka, which will issue a certificate of “freedom from Salmonella” will be issued following the test.

• All betel leaves must be treated with a combination of levulinic acid and sodium dodecyl sulphate prior to export. This has, according to Hortex, been shown to be effective in reducing the levels of Salmonella and coliform bacteria on leaves.

• All betel leaves must be accompanied by a phytosanitary certificate, issued by the DAE. This will require the provision of a certificate of freedom from Salmonella. The phytosanitary certificate must include an additional declaration stating that the consignment is free from Salmonella.

The BBLEA and NPPO stated that the certification of producers had only recently started; the earliest estimate for the start of exports under the programme is April 2013.The NPPO stated that the Export Promotion Bureau had been requested to examine the possibility of creating a specific code to be used on exporters declarations, to enable Customs to identify exports of betel leaves and to verify compliance with the programme, including the issue of a phytosanitary certificate.

5.3.4 Registration and traceability of consignments

There are no major changes on the registration and traceability since last audit.There are 76 exporters registered with PPW. Each exporter contracts in average 10 farmers for supplying produce for export (see section 5.1.6 above). In the Norshingdhi District office there are around 800 registered producers.The main change on traceability was the introduction, under the programme, of the post-harvest declaration issued by the SAAO in charge of the field of production.The PPW indicated that it is possible to trace the field of origin of the exported lots using such documentation and it should allow the trace back to the farmer is case of internal interception of the harmful organism.The audit team noted that a post-harvest certificate must be presented for each consignment for final inspection. During the field visits the audit team was informed that the certificate is not yet in use

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for exports of vegetables.ConclusionThere is register of exporters and contracted farmers. Export programmes and procedures have been developed for citrus fruits, betel leaves and specific vegetables, in response to EU interceptions, which, if fully implemented, should be beneficial in reducing the risk presented by these commodities. Citrus fruit exported in line with the programme is traceable to place of production.

5.4 EXPORT INSPECTIONS

Legal requirementsAnnexes I and II Part A to Directive 2000/29/EC list those harmful organisms whose introduction and movement within the EU is banned. Annex V, Part B lists the plants, plant products and other objects which must be subject to a plant health inspection in the country of origin or the consignor country, if originating outside the EU and accompanied by a phytosanitary certificate.Annex IV, Part A Section I establishes specific requirements for plants and certain plants products, which must be met for exported to the EU. In particular, points 16.1, 16.2, 16.3, 16.4, 16.5 and 36.2 lay down provisions for the export fruits of Citrus L., Momordica L. and Solanum melongena L.ISPM 23 establishes guidelines for inspection. Section 1.4 describes the requirements for inspectors, including access to appropriate inspection facilities, tools and equipment.ISPM 31 provides methodologies for sampling of consignments.Findings

5.4.1 Facilities for performing inspections

The previous report included a recommendation (5) to: ensure that the NPPO has access to adequate equipment and facilities to carry out inspection, testing, consignment verification and phytosanitary certification, in particular to enable an efficient and reliable inspection, in line with Section 3.4 of ISPM 7 and Section 1.4 of ISPM 23.The PPW stated that there have been no changes since the previous audit however a tender process will be launched for the provision of inspection facilities, as detailed in the project ‘Strengthening Phytosanitary Building in Bangladesh’.

The FVO team visited, the main point of exit to the EU. The PQS perform their export checks in a pack house owned by the BFVAPEA, and confirmed that the shortcomings identified during the previous audit still remain.

Equipment for the washing and treatment of citrus fruit with 2.3% Sodium Ophenylphenate (SOPP) has been introduced since the last audit. This has very limited capacity.

5.4.2 Place of production

The previous report included a recommendation (1) to: ensure that phytosanitary certificates are issued for regulated plants, only when it has been ascertained that the additional requirements contained in Annex IV, Part A, Section I to Council Directive 2000/29/EC have been fulfilled. This is particularly important for citrus fruits.The previous report included a recommendation (2) to: ensure that declarations by exporters are

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not considered to be equivalent to the official statements and official control and examination regime for citrus fruits, required by items 16.2(c) and 16.4(c) or (d) of Annex IV, Part A, Section I to Council Directive 2000/29/EC.For the four commodities involved in the programme there is an official field inspection carried out by the SAAO. During the inspection, the SAAO looks for plant health problems and in particular for symptoms of pests of concern for the EU. If no symptoms are found, the SAAO issues a post-harvest certificate that accompanies the consignment until the point of exit. The FVO team visited two producers of citrus fruits for export. The young orchards were of the lemon variety 'Jaba lebu'. The SAAO, that provides technical support to the farmers and performs the official field check, was also present.The SAAO informed the FVO team that he had had, in 2012 two day training on citrus and vegetables pests. He visits the farmers once a week and he has never seen any symptoms or suspect symptoms of citrus diseases. However, when questioned about some leaf spots and twig symptoms the SAAO was unable to tell what could be the cause and what procedure to follow, if any. In addition, he was not able to describe any symptoms of the citrus diseases of concern to the EU.

5.4.3 Point of exit

The previous report included a recommendation (4) to: ensure that the system of official checks at the point of exit is revised to ensure that if a harmful organism is found during the official check, that the remainder of the lot, or if appropriate, consignment, is not considered to be free from the harmful organism, in line with the additional requirements in Annex IV, Part A, Section I of Council Directive 2000/29/EC and the principles of ISPM 5.All plants exported to the EU are subjected to an official check immediately prior to export at Hazrat Shahjalal International Airport in Dhaka. The export check is performed by PQS. The FVO team visited the inspection facility and noted that the PQS inspector makes an initial check looking at the quality of the fruit and pest symptoms. After being sorted and graded and treated with SOPP in case of citrus, before packing an pre-export inspection is carried out for each lot.The audit team observed the treatment and inspection of citrus fruit and noted that:

• The initial plant health inspection is made before fruits were washed and treated. Fruits are treated in 10 litre bins with SOPP in a water solution of 2.3%.

• A second plant health inspection was made before packing. A sample of 5 fruits from every 8 kg box was taken for inspection, in a lot of 500 boxes.

• With the exception of fruit flies, the inspectors were not fully aware of the symptoms of the citrus pests of concern to the EU.

• The lot is rejected when an harmful organism is found or its presence is suspected.Conclusion:The recommendations 1, 2 and 4 from the previous audit have been addressed. Recommendation 5 concerning the facilities for performing pre-export inspections has not been addressed. A plan is in place for the provision of new facilities.The SAAO and PQS inspectors showed shortcomings in their knowledge and awareness of symptoms of EU pests of concern. As concluded in section 5.1 above, the staff performing checks of plants for export to the EU, are therefore not technically qualified to do so, as required by 2(1)(i) of Directive 2000/29/EC.

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5.5 PHYTOSANITARY CERTIFICATES

Legal requirementsArticle 2(1)(i) of Directive 2000/29/EC establishes the requirements for a measure or statement, to be considered as 'official'. In particular, '…if it is made by representatives of the official national plant protection organisation of a third country, or, under their responsibility, by other public officers who are technically qualified and duly authorised…'

Paragraph 3 of Article 13a establishes requirements for the phytosanitary certificate, in particular its format, the information it should contain and its issuance. Paragraph (4) of the same Article contains requirements relating to the use of additional declaration on phytosanitary certificates.

Annex IV, Part A Section I establishes specific requirements which must be met in order to export plants and certain plant products to the EU.

ISPM 12 establishes guidelines for phytosanitary certificates.

FindingsThe previous report included a recommendation (3) to: ensure that the additional declarations entered onto phytosanitary certificates accurately reflect the official checks that have been carried out, and their outcome, as required by Articles 13a(3) and 13a(4) of Council Directive 2000/29/EC and Section 1.1. of ISPM 12.Phytosanitary certificates are issued by one PPW officer based at Hazrat Shahjalal International Airport, in Dhaka.

The FVO team observed phytosanitary certificates being issued at the airport and noted that:• Blank phytosanitary certificates are kept securely by the PPW. All certificates are completed

and endorsed by the Officer in Charge.• For commodities included in the programme, the certificates are completed by the PPW

based on the post-harvest certificate issued by the SAAO.• The FVO team confirmed that no phytosanitary certificates had been issued following

suspension.

In order to minimise the risk of falsification of phytosanitary certificates the PPW stated that they have established a direct link with Customs. From January 2013 onwards, a copy of each phytosanitary certificate and a list of phytosanitary certificates issued every day is sent by the PPW to Customs. Customs confirm if the list and quantities of products are consistent with what is declared on the phytosanitary certificate. Additionally, the reverse page of the phytosanitary certificate is used to state the additional declaration, name of produce and quantities exported which contributes to reduce the falsification of phytosanitary certificates. No phytosanitary certificates are issued for suspended exporters.

The FVO team met with a representative of Customs who confirmed the new procedure put in place in cooperation with the NPPO.

The FVO team examined phytosanitary certificates that had been issued in the airport, and noted that they all had a request for inspection and issuance of phytosanitary certificate, and SAAO declaration for citrus fruits were attached in the dossier.

ConclusionsThe recommendation 3 from the previous audit has been addressedThe system for the issuance of phytosanitary certificates is in line with relevant ISPM and EU

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import requirements. Action has been taken to reduce the risk of fraud related to phytosanitary certificates.

5.6 ACTION TAKEN IN RESPONSE TO INTERNAL INTERCEPTIONS AND NOTIFICATION OF INTERCEPTIONS FROM THE EU

Legal requirementsISPM 7 describes the basic elements of the phytosanitary certification process and the requirements for a certification system to fulfil these functions. Section 6.1 (System review) requires that the NPPO should periodically review the effectiveness of all aspects of its export certification system and implement changes to the system if required. Section 6.2 (incident review) requires that the NPPO establish procedures for investigating reports from importing countries of non-conforming consignments covered by a phytosanitary certificate.

ISPM 23, Section 2.6 (Review of inspection systems) establishes that NPPOs should conduct periodic reviews of import and export inspection systems to validate the appropriateness of their design and to determine any course of adjustments needed to ensure that they are technically sound.Findings

5.6.1 Internal interceptions

The previous report included a recommendation (6) to: ensure that adequate records of official activities related to the export controls are maintained, in line with Section 4.4 of ISPM 7.During the visit to the point of exit, the PQS staff informed the audit team that, in the event that an harmful organism is suspected or found during the pre-export inspection, the lot is rejected. The audit team was informed by the PQS inspector that around 20 consignments were rejected due to the presence of suspect symptoms of harmful organisms. No records or notifications are kept and no follow up is made for such rejections.

5.6.2 EU notifications of interception

The action taken following receipt of an EU notification of interception remains largely unchanged since the previous audit. The PPW stated that exporters are suspended due mainly to non-conformities found on the phytosanitary certificates or exporting with fake phytosanitary certificates. Depending on the gravity of the non-compliance the exporter may be suspended for one, six, 12 or 24 months. The PPW informed the audit team that at the time of the audit, 15 exporters had been suspended for one month, five were suspended for three months, four were suspended for six months and two had been suspended for two years. In addition, four exporters were in the process of being suspended for one month. During the meeting with BFVAPEA, one exporter informed the audit team that following suspension by the PPW, he continues to work as an exporter for another company. The PPW informed the FVO team that, following the notifications of interception of citrus canker and citrus blackspot in 2012, an investigation was carried out in the Moulvibazar area in Sylhet District where the fruit had originated from. The area and places of production concerned had previously been subject to checks by Hortex and BARI and found free from the harmful organisms. The PPW stated that during the investigation both diseases were found in neighbouring fields. The fruit intercepted from the EU was therefore assumed either to come from infected neighbouring plots, or the disease had in fact been present in the field but no symptoms were present at the time of the check.

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As a result of these findings, the PPW stated that in November 2012, they suspended the export of all fruits of Citrus with the exception of Citrus pennivesiculata (var. Jara lebu), which as noted in section 5.3 above, is considered to be tolerant to citrus canker and citrus blackspot, and is also only produced in the Norshindi District, where no signs of these diseases had been found.ConclusionThe recommendations 6 from the previous audit has been partially addressed.Action is taken following an internal interception to exclude the affected lot from export. No action is taken to investigate the cause of the interception. Sanctions are applied in the case of fraud or documentary issues, however the sanction of suspending exporters does not appear to work in practice.Action has been taken following EU notifications of the presence of harmful organisms on citrus fruit. The suspension of the export of fruits of Citrus, with the exception of Citrus pennivesiculata, should help to address the interceptions of harmful organisms on such fruit.

6 OVERALL CONCLUSIONS

There is a clear structure and division of responsibilities in the plant health service in Bangladesh. There is also good communication with producers and exporters.There is a plan in place to address the shortcomings identified during the previous audit and some have been addressed recently. There is also a strong commitment to improve the export system through the implementation of the project ‘Strengthening Phyotosanitary Building in Bangladesh’ and the ‘Special program for production of exportable citrus and vegetables’.Although, the export system now appears to be more in line with the EU requirements, in practice, weakness were noted in each step of the export system, in particular in the pre-export inspection.The number of interceptions of harmful organisms in produce from Bangladesh was in 2012 unacceptably high and it is imperative that action is taken urgently to reduce the interceptions and the potential risk to the EU of the introduction of harmful organisms.

7 CLOSING MEETING

A closing meeting was held on 7 February 2013 at the headquarters of the Plant Protection Wing in Dhaka, during which the main findings and conclusions of the audit team were presented. The NPPO provisionally accepted the findings and conclusions and indicated a commitment to make any necessary changes.

8 RECOMMENDATIONS

The NPPO of Bangladesh should ensure that:

N°. Recommendation

1. Staff performing export inspections of plants and plant produce intended for export to the EU are technically qualified, in line with Article 2(1)(i) of Council Directive

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N°. Recommendation

2000/29/EC.

2. Laboratory technical capacity is available for testing quarantine harmful organisms hosting plants and plant products exported to the EU, in particular citrus diseases, in accordance with points 2.2 and 3.4 of ISPM 7.

3. There are adequate facilities and equipment to enable appropriate inspections to be carried out for regulated plant produce exported to the EU, in line with the relevant additional requirements listed in Annex IV, Part A, Section I to Council Directive 2000/29/EC and Section 3.4 of ISPM 7 and Section 1.4 of ISPM 23.This is an outstanding recommendation since 2010.

4. Action is taken following internal interceptions, in order to review the effectiveness of the export system in accordance with point 6 of ISPM 7.

The competent authority's response to the recommendations can be found at:

http://ec.europa.eu/food/fvo/rep_details_en.cfm?rep_inspection_ref=2013-6815

The NPPO in Bangladesh is requested to provide an action plan addressing all of the above recommendations. It should give details of the action taken and planned, including deadlines for their completion and it should be provided within 25 working days of receipt of this report.

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ANNEX 1 - LEGAL REFERENCES

There are no specific legal references for this inspection.

Legal Reference Official Journal Title

Dir. 2000/29/EC OJ L 169, 10.7.2000, p. 1-112

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

Dec. 2006/473/EC OJ L 187, 8.7.2006, p. 35-36

2006/473/EC: Commission Decision of 5 July 2006 recognising certain third countries and certain areas of third countries as being free from Xanthomonas campestris (all strains pathogenic to Citrus), Cercospora angolensis Carv. et Mendes and Guignardia citricarpa Kiely (all strains pathogenic to Citrus)

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ANNEX 2 – STANDARDS QUOTED IN THE REPORT

International Standard TitleISPM N°5 International Standards for Phytosanitary Measures N°5, Glossary of

phytosanitary terms, Food and Agriculture OrganisationISPM N°7 International Standards for Phytosanitary Measures N°7, Export

certification system, Food and Agriculture OrganisationISPM N°12 International Standards for Phytosanitary Measures N°12, Guidelines for

phytosanitary certificates, Food and Agriculture OrganisationISPM N°15 International Standards for Phytosanitary Measures N°15, Guidelines for

regulating wood packaging material in international trade, Food and Agriculture Organisation

ISPM N°23 International Standards for Phytosanitary Measures N°23, Guidelines for inspection, Food and Agriculture Organisation

ISPM N°31 International Standards for Phytosanitary Measures N°31, Methodologies for sampling of consignments, Food and Agriculture Organisation