Sunday, April 7, 2013

Item 40 of the Annex IV, deciduous, dormant plants : differing interpretations

The item 40 of the Annex IV says that deciduous trees and shrubs, intending for planting, other than seeds and plants in tissue culture, originating in third countries other than European and Mediterranean countries need and official statement that the plants are dormant and free from leaves.

But the so called deciduous plants are not identified by the Annex IV and the word " deciduous " gives rise to differing interpretations. A tree in its natural environment can be said non decideous or semi deciduous by a source ( phytosanitary employee, botanical encyclopedia ), and deciduous by an other; or some phytosanitary employees will consider that a distinction is to be made between nursery grown plants ( they won't lose their leaves ) and grown in nature.

The dormancy is also diversely interpreted. ( if a plant is reported to be deciduous but is keeping its leaves during the dry season when it is exported, is it dormant at the time it is exported ? )

When websites maintained by plant protection services exist that inform the public about their specific applications of regulations then differing interpretations are not a big problem; or when an import permit lists the practical conditions in which plants can be imported.

Plant importers in countries known to be linked to problems, such as France, should ask,  before the plants are imported, the phytosanitary office in charge : which items of the Annex IV apply and what are the practical interpretations regarding leaves, rooting etc.

This is how,  below, items were listed on the phytosanitary certificate of a shipment in March to France from Thailand :
FULFILS ITEMS 32.1 ( C ), 32.3 ( C ), 33, 36.1  ( C ) , 45.1 ( C ), AND 46 ( B ) ( C ) OF ANNEX IV AI OF PLANT HEALTH DIRECTIVE
plants were shipped in march, the dry season in which , if deciduous, plants lose their leaves
item 40 is not mentioned as the plants , seen with their leaves on at the time of the control by the phytosanitary office of Thailand the exporting country, were not considered dormant, hence not deciduous ;
Intercepted plants with leaves
In this shipment of 15 species only Aglaia Bauhinia Gardenia and Euclinia were intercepted in March 2013 by the french plant protection bureau while almost all the 11 non intercepted are reported semi deciduous or deciduous by some sources .. and the 4 intercepted are reported semi deciduous ! :

AGLAIA ODORATA, BAUHINIA SPP, BEAUMONTIA GRANDIFLORA, CINNAMOMUM ZEYLANICUM, EUCLINIA LONGIFLORA, GARDENIA SOOTEPENSIS, GARDENIA TUBIFERA, JATROPHA INTEGERRIMA, JATROPHA PODAGRICA, MICHELIA CHAMPACA
ODONTADENIA MACRANTHA, RUSSELIA EQUISETIFORMIS, STROPHANTHUS GRATUS, VALLARIS GLABRA, WRIGHTIA RELIGIOSA  

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