Ref. Ares(2020)1375297 - 05/03/2020

EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR HEALTH AND FOOD SAFETY

Health and food audits and analysis

DG(SANTE) 2019-6741

FINAL REPORT OF AN AUDIT CARRIED OUT IN FROM 05 NOVEMBER 2019 TO 13 NOVEMBER 2019 IN ORDER TO EVALUATE THE PLANT HEALTH CONTROLS APPLIED IN THE POTATO SECTOR Executive Summary

This report describes the outcome of an audit carried out in Montenegro from 5 to 13 November 2019 as part of the published Directorate-General for Health and Food Safety audit programme. The main objective of the audit was to evaluate the system of official plant health controls related to potato production and certification of potatoes for export to the European Union (EU), according to the requirements of Council Directive 2000/29/EC. The audit particularly focused on the surveillance and controls for Clavibacter michiganensis spp. sepedonicus (causing potato ring rot), Ralstonia solanacearum (causing potato brown rot), potato cyst nematodes (Globodera spp.) and Synchytrium endobioticum (causing potato wart disease). The overall situation of the main potato harmful organisms in Montenegro is positive. Long crop rotation schemes and minimal irrigation are applied in the professional seed and ware potato crops whilst the use of certified seed for the production of ware potatoes is subsidised. The system of official controls in the potato sector is comparable to that applied in the EU. Seed potato plots are subject to an official surveillance programme which includes soil sampling prior to planting, visual surveys of the growing crop and sampling of tubers mainly carried out prior to harvest for laboratory analysis. Potato cyst nematodes have not been detected and the findings of potato wart disease that occurred in 1968 have been eradicated. In general, the diagnostic methods applied by the official laboratory for the detection of potato bacteria and potato cyst nematodes are equivalent to those in the EU. However, there were significant weaknesses in quality control procedures, insufficient facilities for storage of samples and inadequate quarantine facilities. The shortcomings affect the reliability of results. Available data indicate that so far there has been no incidence of ring rot and brown rot in Montenegro. However, the surveillance methods applied to confirm this are not fully in line with the EU requirements. Sampling is not representative as samples of potato tubers are mainly taken from the fields of large scale registered producers of certified seed and ware potatoes. A significant proportion of potato growing areas are operated by small-scale non-registered producers whilst potatoes destined for household consumption or the domestic local markets are not or only occasionally surveyed. Montenegro cannot be regarded as free from both potato bacteria as there are problems in the sampling approach and in the number of tuber samples analysed. The report includes recommendations to address the shortcomings.

I Table of Contents

1 Introduction...... 1 2 Objectives...... 1 3 Legal Basis...... 1 3.1 Relevant legislation ...... 2 3.2 Relevant standards...... 2 4 Background ...... 2 4.1 Potato production and trade...... 2 4.1.1 Potato production system-seed multiplication and certification ...... 2 4.1.2 Border inspection posts - Potato imports and exports...... 4 5 Findings and Conclusions ...... 6 5.1 Organisational aspects of plant health controls ...... 6 5.1.1 Designation of Competent Authorities ...... 6 5.1.2 Staffing provisions and resources ...... 7 5.1.3 Training of inspectors, work planning and instructions ...... 8 5.1.4 Legal powers of inspectors and sanctions ...... 9 5.1.5 Cooperation and communication with stakeholders...... 9 5.1.6 Laboratories...... 9 5.1.7 Relevant national legislation and rules...... 10 5.1.8 Registration of establishments ...... 12 5.2 Control of potato harmful organisms ...... 13 5.2.1 Status of harmful organisms of potato in Montenegro...... 13 5.2.2 Cms and Rs surveillance strategy and results...... 14 5.2.3 Potato cyst and other nematodes surveillance strategy and results ...... 17 5.2.4 Potato wart disease and potato flea beetles...... 17 5.2.5 Specific ring rot and brown rot control measures ...... 18 5.2.6 Documentation and traceability of potato consignments...... 19 5.2.7 Export checks and issuance of phytosanitary certificates...... 20 6 Overall conclusions...... 21 7 Closing Meeting...... 21 8 Recommendations ...... 21

II ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT Abbreviation Explanation AFSVPA Administration for Food Safety, Veterinary and Phytosanitary Affairs BtF Biotechnical Faculty of the Brown rot Disease caused by the bacterium Ralstonia solanacearum (Smith) Yabuuchi et al. Cms Clavibacter michiganensis ssp. sepedonicus DPHP Department of Plant Health Protection DSPM Department of Seed and Propagation Materials DPI Department of Phytosanitary Inspection EU European Union ISPM International Standards for Phytosanitary Measures MARD Ministry of Agriculture and Rural Development MONSTAT Statistical Office of Montenegro PCN Potato cyst nematodes PS Phytosanitary Sector Ring rot Disease caused by the bacterium Clavibacter michiganensis (Smith) Davis et al. ssp. sepedonicus (Spieckermann et Kotthoff) Davis et al. Rs Ralstonia solanacearum SPS State Plant Service under the Ministry of Agriculture Surveillance An official process which collects and records data on pest occurrence or absence by survey, monitoring or other procedures Survey An official procedure conducted over a defined period of time to determine the characteristics of a pest population or to determine which species occur in an area

III 1 INTRODUCTION

The audit took place in Montenegro from 5 to 13 November 2019 as part of the Directorate- General for Health and Food Safety’s planned audit programme. The audit team consisted of two auditors from the Directorate-General for Health and Food Safety and an expert from an EU Member State. It was accompanied throughout the audit by representatives of the Phytosanitary Sector of the Administration for Food Safety Veterinary and Phytosanitary Affairs (AFSVPA).

An opening meeting was held on 5 November 2019 at the premises of the Phytosanitary Sector of AFSVPA during which the objectives, scope and itinerary for the audit were confirmed and additional information necessary for the conduct of the audit was requested.

2 OBJECTIVES

The objectives of the audit were to evaluate:  the performance of the various bodies involved in the national plant health system with regard to the potato sector;  the methodology and results of the surveys that are carried out for the relevant harmful organisms;  the phytosanitary situation as regards harmful organisms in potatoes of quarantine relevance for the EU, in particular Clavibacter michiganensis ssp. sepedonicus, Ralstonia solanacearum, Globodera pallida, G. rostochiensis and Synchytrium endobioticum;  the plant health measures applied to the potato production in Montenegro with regard to meeting the requirements of the relevant EU legislation. In pursuit of these objectives, the following competent authorities were met and the following plant health control sites were visited: Competent authorities National Plant Protection Organisation Phytosanitary Sector of the AFSVPA Official Laboratories Biotechnical Faculty, Podgorica Regional Inspectorates Four in Žabljak, Nikšić, Danilovgrad and Kolašin. Plant health control sites Producers and distributors of seed potatoes Three in Nikšić, Danilovgrad and Kolašin Producers of ware / other potatoes Three in Žabljak, Nikšić and . Retail markets of seed or ware potatoes Two in Nikšić (seed) and Zabljak (ware) Border inspection post One in Dobrakovo

3 LEGAL BASIS

The audit was carried out under the general provisions of EU legislation, and in particular Art. 21 and 27a of Council Directive 2000/29/EC and with the agreement of the

1 Phytosanitary Sector - Department for Plant Health Protection (DPHP), the National Plant Protection Organisation of Montenegro under the AFSVPA.

3.1 RELEVANT LEGISLATION

All EU legislation relevant for this audit is listed in Annex 1. Legal acts quoted refer, where applicable, to the latest amended version.

3.2 RELEVANT STANDARDS

International Standards for Phytosanitary Measures (ISPMs) issued by the International Plant Protection Convention of relevance for this audit are listed in Annex 2.

4 BACKGROUND

This was the first audit carried out by the Directorate-General for Health and Food Safety to Montenegro for plant health matters. The import into the EU of ware potatoes from most third countries is prohibited by point 12 of Part A of Annex III to Directive 2000/29/EC. However, in accordance with the same point, such imports may be permitted from European third countries which are either recognised as being free from Clavibacter michiganensis ssp. sepedonicus (Cms, causal agent of potato ring rot), or in which provisions recognised as being equivalent to the EU provisions on combating the disease have been complied with.

There are additional requirements, included in Annex IV, Part A, Section I of the same Directive, relating to other harmful organisms of potato that must be complied with in order for ware potatoes to be imported into the EU. In particular, point 25.1 of the same Annex relates to S. endobioticum (Se, causal agent of potato wart disease, PWD), point 25.4.1 relates to Ralstonia solanacearum (Rs, causal agent of potato brown rot) and point 25.4.2 to Tecia solanivora (Guatemalan potato moth) listed as Scrobipalpopsis solanivora.

The status of these and other harmful organisms of potatoes of concern to the EU is detailed in section 5.2.1 below.

In 2017, the DPHP submitted a request for recognition of the country as being free from all regulated harmful organisms affecting potato. The European Commission requested further technical information on potato production and the phytosanitary situation in Montenegro which was provided in June 2018. Unless otherwise stated, statistical data in the following chapters were provided by the DPHP.

4.1 POTATO PRODUCTION AND TRADE

4.1.1Potato production system-seed multiplication and certification

The domestic production of ware potatoes and certified potato seed is entirely based on the import and multiplication of certified "class A" seed and high grade "basic" material originating from the EU, mainly the Netherlands. Despite the legal possibility to import seed

2 potatoes from a wider range of countries than permitted by the EU (see also section 5.1.7), there have only been very small quantities of seed potatoes imported from Serbia. During the last two growing periods 2017-2018 the area dedicated to the production of certified seed potatoes grown mainly in the central and northern mountainous regions increased from 64 ha to 89 ha giving a production of 630 t (in 2017) and 1,155 t (in 2018) of certified seed (class "A" and "B") and an average yield of seed potatoes of 13 t/ha. Further increase of seed potato producing areas took place in 2019 with average yield of 16t/ha.

There is no breeding programme for the production of pre-basic potato seed in Montenegro. The Plant Gene Bank of the Biotechnical Faculty in Podgorica established in 2004 has 54 accessions of Solanum tuberosum; this material has not been tested and it is not released. A seed certification system is in place. This provides assurance regarding the health status of certified seed potatoes and the ware potato production derived from them. Certified seed is used for further multiplication or commercial ware potato production and in total covers ca. 80-85% of the ware potato production area. The remaining 15-20% is managed by small- scale producers using partly farm saved seed. The main seed potato production takes place in Žabljak and Kolašin but also in other highland areas of Montenegro. More than half (ca. 70%) of the produced potato seed grows above 1,000m from sea level. The production of class "A" certified potato seed below 600m height is prohibited. Altitude thresholds are also in place for the production of "Super elite" and "Elite" classes of potato seed at or above 1,000m and 800m respectively. Figure 1 below provides an overview of the main seed potato growing areas in Montenegro. Figure 1. Main seed potato growing areas in Montenegro (in green)

Ware potato production takes place throughout the country. Depending on the altitude, potatoes are planted from April to early June and harvested from August to mid-October. There is no production or processing of industrial potatoes whilst early ware potato production is limited in the plains of Podgorica region – and in . They are planted early March and harvested from mid-June onwards. Contract potato production is common for large scale commercial distributors and exporting. The area and the number of registered

3 and non-registered farms involved in seed and ware production in 2019 is detailed in table 1 below. Table 1. Size of potato production units in 2019 Crop area Registered1 Non-registered2 in (ha) Certified seed Certified seed Ware & other Ware & other Ware & other Ware & other potato farms potato area (ha) potato farms potato area (ha) potato farms potato area (ha) <1 0 0 289 70.3 30,245 537.5 1 – 4.99 2 3.8 178 366.6 0 0 5 – 19.99 6 70.10 22 175 0 0 20 - 50 1 38.78 6 155.1 0 0 >50 0 0 0 0 0 0 Total 9 112.68 495 767 30,245 537.5 1 Source: AFSVPA 2 Source: MONSTAT Estimates of the Statistical Office of Montenegro (MONSTAT) on the total area where ware potatoes are grown vary significantly and indicate a larger area to that operated by producers registered with the AFSVPA. During the last two growing periods 2017-2018 the ware potato area was estimated to ca. 2,100 ha producing ca. 34,400 t of potatoes and an average yield of ca. 16.5 t/ha. For seed potatoes, a crop rotation scheme of minimum four years with cereals, alfalfa combined with vegetables or bare fallow is obligatory. In ware potato production, crop rotation with cereals and legumes/vegetables lasts two or, in certain cases, three years. Small- scale producers of ware potatoes also apply similar crop rotation schemes. In all cases this had to be followed up by adequate cleaning. A low proportion (15-20%) mainly ware potato crops are occasionally irrigated mainly by commercial producers having access to surface or underground water; seed potatoes are not irrigated. Solanum dulcamara and Solanum nigrum are known to occur in Montenegro. No cutting of farm saved seed for the production of ware potatoes has been reported.

4.1.2Border inspection posts - Potato imports and exports

At the time of the audit there were 12 BIPs of which one is bordering with the EU (Croatia). Table 2 below indicates the names and location of the BIPs in Montenegro. Table 2. Border Inspection Posts (BIPs) in Montenegro BIP, entity Bordering Type BIP, entity Bordering Type country country Božaj Albania Road Dobrakovo Serbia Railway Podgorica Albania Railway Dobrakovo Serbia Road Podgorica international Post/Forwarders Ranče Serbia Road Podgorica international Airport Dračenovac Serbia Road Bar international Sea Port Kula Kosovo Road Debeli Brijeg Croatia /EU Road Ilino Brdo BiH Road

The AFSVPA provided the following data on the quantity and origin of seed ware and early ware potatoes imported to Montenegro in 2017 and 2018:

4 Table 3. Imports of seed ware and early ware potatoes in Montenegro in 2017 and 2018 Country of Quantities (in t) imported to Montenegro in Quantities (in t) imported to Montenegro in origin 2017 2018 seed ware early ware seed ware early ware Albania 0 110.17 0 0 473.98 0 Austria 0 48 0 0 0 0 Belgium 0 0 0 47.5 0 0 Belarus 0 0 0 0 40 0 Bosnia and 0 114 1,001.5 0 610.44 87.71 Herzegovina Denmark 47.5 0 0 23.75 0 0 France 35.25 2,292.72 298.8 46.8 174.7 3,436.88 Greece 0 22.4 0 0 96.37 0 Netherlands 1,086.44 0 0 781.48 31.56 0 Croatia 0 528.2 623.82 0 930.5 46.5 Italy 0 12.99 0 0 0 0 Cyprus 0 0 0 0 20.9 0 Luxembourg 0 0 0 23.75 0 0 Morocco 0 7.2 0 0 0 0 Germany 0 672 48 0 312 1,191.3 Slovenia 10.08 0 0 0 0 0 Serbia 58.31 2531.3 0 46.38 691.28 0 Spain 0 0 0 23.75 0 0 Kosovo 0 162.41 0 0 0 0 UK (Scotland) 0 0 0 0 15,47 0 Total 1,237.58 6,501.39 1,972.12 993.41 3,397.2 4,762.39

Ware potatoes can be imported from all countries included in point 12 of Part A of Annex III to Directive 2000/29/EC, with the exception of Egypt from where imports of ware potatoes are prohibited (Rulebook OG MN 27-2014). The AFSVPA provided the following data on potatoes exported from Montenegro in 2017 and 2018: Table 4. Exports of seed ware and early potatoes from Montenegro in 2017 and 2018 Country of Quantities (in t) exported from Montenegro in Quantities (in t) exported from Montenegro in destination 2017 2018 seed ware early seed ware early Kosovo 0 0 215.5 0 0 0 Bosnia and 0 0 150.5 0 0 0 Herzegovina Serbia 0 0 21.4 0 0 0 Total 0 0 387.4 0 0 0

5 5 FINDINGS AND CONCLUSIONS

5.1 ORGANISATIONAL ASPECTS OF PLANT HEALTH CONTROLS

Legal requirements Articles 1(4), 2(1)(g), 2(1)(i), 6.5, 6.6, 12(2) and 13c(1)(b) of Directive 2000/29/EC. Directives 92/90/EEC and 93/50/EEC. ISPM 7 and ISPM 23.

Findings

5.1.1Designation of Competent Authorities

1. Following the implementation of institutional changes, the AFSVPA established in 2017 is composed of three sectors, Food Safety, Veterinary and Phytosanitary. The Phytosanitary Sector (PS)-Department for Plant Health Protection is the single competent authority for the implementation of plant health legislation, within the meaning of Article 1(4) of Directive 2000/29/EC.

2. Plant health administrative and control activities are carried out at central level by the DPHP and regionally by the Department for Phytosanitary Inspection (DPI). Figure 2 below indicates the structure of the AFSVPA and the links with the Ministry of Agriculture and Rural Development (MARD) and the Customs Administration.

Figure 2. Structure of the AFSVPA and overview of the institutions involved in the plant health controls of the potato sector.

3. In the Phytosanitary Sector, the DPHP retains administrative role for plant health issues including the risk management for harmful organisms and the preparation of the technical basis for the implementation of plant health legislation. The DPHP is also

6 responsible for the management of the registration database for producers and operators and for the organisation of general and specific surveys.

4. The DPI is responsible, inter alia, for the implementation of plant health and food safety checks during the import of plants and plant products in the twelve border inspection posts of Montenegro. Inspectors of the DPI are also in charge of verifying the compliance of producers and operators with registration requirements, carrying out official plant health checks in the domestic production and enforcing plant health legislation. They issue phytosanitary certificates for the exports of plants and plant products. Plant health inspectors take action when corrective measures have to be taken, i.e. compliance of producers with the registration requirements and report to the DPHP and the Department of Seed and Propagation Materials (DSPM).

5. Regarding potato controls, inspectors have general and specific tasks described in the plant health programme of the annual plan of the AFSVPA (see also section 5.1.3). These mainly include inspections for signs and symptoms of harmful organisms, compliance checks with the labelling requirements and sampling of tubers during warehouse storage, import and export of potato consignments. Inspectors take samples of soil for laboratory analysis and detection of potato cyst nematodes (PCN). If necessary, inspectors participate in the specific surveillance for harmful organisms and take samples of potato tubers for testing.

6. The Phytosanitary Laboratory (Centre for Plant Protection of the Biotechnical Faculty, University of Montenegro, hereafter BtF), is the legal entity authorised, inter alia, for the technical control of seed material of crop plants. Since 1983, the BtF is considered to be the founder of the domestic seed potato production in Montenegro. The DPHP has delegated to the bacteriology laboratory of the BtF the tasks of potato surveillance, sampling and testing for Cms and Rs and the control activities necessary for the issuance of plant passports of potato seed (see also section 5.1.6).

5.1.2Staffing provisions and resources

7. There are currently 22 employees in the Phytosanitary Sector. In the DPHP three full time officials are responsible for plant health issues at central level. Two full time officials of the DSPM have been assigned with certification tasks of propagating material including potato seed. At the time of the audit, there were 16 regional inspectors assigned with plant health checks of the domestic production and during import. During the interviews carried out by the audit team, staff resources in the DPI were often mentioned as a limiting factor for carrying out potato surveillance and controls. The DPHP stated that they plan to increase the number of the DPI staff to 24. 8. Fees paid by operators for plant health checks during imports provide a source of funding for the AFSVPA, the other two sources being the national budget and income from laboratory tests of domestically produced propagating material.

7 5.1.3Training of inspectors, work planning and instructions

9. The DPHP provided a list with the most recent general and specific training events on plant health. During the last decade and in preparation of Montenegro's accession to the EU, staff of the DPHP, the DPI and the BtF have attended some 40 national and international training events. These include EU twinning projects, Better Training for Safer Food workshops, study visits for the Technical Assistance and Information Exchange and the Instrument for Pre-Accession Assistance together with regional development programmes addressed to plant health experts, inspectors and producers.

10. General and specific training on plant health focused on the methods of surveillance and sampling of potatoes, the procedures to be followed for the detection of harmful organisms and their control. Specific meetings were arranged to inform inspectors about the legislation on phytosanitary control measures and the plant passport regime. Remote training for both the DPI staff and potato producers/operators is also publicly available in the internet, whilst for some of the training courses access is also provided through video links. All inspectors met by the audit team were aware of the plant health risks, the relevant phytosanitary requirements of potato crops and were well trained to carry out their tasks.

11. The goals for seed and ware potato surveys are explicitly described in the components of the annual programme of phytosanitary measures of the AFSVPA. The programme includes the budgetary funding allocated to fulfil separate targets, it is approved by the MARD and it is published in the Official Gazette. The programme contains the methodology of surveillance that has to be carried out for the EU regulated harmful organisms and serves as the inspectors' manual. In the framework of contingency planning, it includes provisions for specific additional funding to be allocated in case of emerging plant health issues. It has also incorporated general plant health aspects such as monitoring and forecasting for harmful organisms which are established in Montenegro, emergency phytosanitary measures in the framework of contingency plans. The programme has also incorporated a component concerning the management of agricultural inputs including seed, propagating material and genetic resources and refers to the controls necessary to be carried out on seed potatoes for certification purposes.

12. The DPHP in collaboration with the DSPM and the DPI prepare the annual surveys and determine the numbers of samples to be taken each growing period from the different regions. They issue technical guidelines and specific checklists that include the methods, rates and densities of sampling. Operating procedures provide standardised forms to be completed for samples taken for laboratory analysis. Inspection and sampling records are kept in a database. A substantial part of potato surveys, particularly the checks carried out at four different developmental stages of the domestic seed potato crops has been delegated to the Phytosanitary Laboratory of the BtF (see also section 5.1.6).

8 5.1.4Legal powers of inspectors and sanctions

13. Inspectors have general legal powers to access the production, storage and marketing chain of plants, plant products and other objects at all stages. Tasks related to checks of imported seed potatoes at the place of destination may only be carried out in collaboration with the Customs. Sanctions and fines can be imposed in cases of infringement.

5.1.5Cooperation and communication with stakeholders

14. During 2019 the DPHP in collaboration with experts from the Phytosanitary Laboratory of the BtF organised information and training events addressed to potato producers/operators and the regional inspectors of Podgorica, Niksic, Tuzi and Zeta. All events addressed the obligation of producers for their registration in the phytosanitary database and provided scientific information about potato wart disease, ring rot and brown rot. The events also focused on the phytosanitary controls carried out for certification purposes including sampling and laboratory testing.

15. Fliers and brochures contain up-to-date information and warning notes on the signs and symptoms of potato harmful organisms, including the potato psyllid Bactericera cockerelli, the prevention and phytosanitary measures against potato bacteria and contact details of the DPHP. Information material available on the webpage of the AFSVPA includes risk analysis for the introduction of Cms and Rs in Montenegro and instructions to potato producers/operators.

16. During the interviews carried out in the regional plant health services and at producers, the audit team noted that:  Inspectors appeared to have established good cooperation and collaboration with potato producers;  Producers confirmed that they have attended official training events. They have received certificates of attendance and identity cards necessary for the purchase and use of plant protection products;  Extension and/or consultation services are provided occasionally during the controls carried out at import of potato seed and during the surveillance period.

5.1.6Laboratories

17. The analyses of samples for the detection of harmful organisms of potato are carried out in the Phytosanitary Laboratory of the BtF under the authorisation of the AFSVPA. Six higher education chief specialists holding doctorate degrees are in charge of analysis/research and maintenance of the laboratories of mycology, bacteriology, virology, entomology and nematology. The diagnostic needs of the bacteriology and mycology laboratories are currently covered by one expert in phytopathology and one

9 technician for the preparation of samples. No additional staff are employed during peak times. 18. The BtF has participated in numerous projects on agricultural research. The diagnostic laboratories assigned with potato crop surveillance tasks for plant health purposes have not been accredited according to international standards. No internal or external audits or participation in international proficiency testing have been organised. 19. During a visit carried out in the BtF, the audit team noted that:  In general, the methods used for the soil sampling and laboratory detection of PCN are in line with the technical requirements of Directive 2007/33/EC and the corresponding diagnostic protocol of the EPPO. The nematology laboratory has the basic equipment for PCN extraction and identification; so far no presence of Globodera sp. or Meloidogyne sp. has been detected. However, the laboratory lacks quarantine drainage of waste water and facilities for the safe handling of soil residues. This increases the risk of further spread in case of nematode contamination;  The procedures followed during the handling of samples in the laboratory are not documented. The internal organisation for the reception, registration and storage, preparation and analysis of samples and the issuance of test reports does not provide for the anonymity of sample origin;  The microbiology laboratory of the BtF has the capacity for preparing and analysing five samples per day for the detection of Cms and Rs. During the analytic procedure, priority is given to samples of tubers taken for import purposes and for potato seed certification. However, the storage facilities are not sufficient to adequately cover any temporary increased storage needs, especially during the peak periods or following any future event of a ring rot or brown rot outbreak;  The methods used for the detection of both bacteria are in line with the technical requirements of Directives 93/85/EEC and 98/57/EC. Potato ring rot and potato brown rot have not been detected. However, in the event of a potentially positive initial screening immunofluorescence test, pathogenicity bio-tests confirming or refuting suspicion of bacterial presence, can only be carried out in the laboratories of other countries equipped with quarantine glasshouse facilities.

5.1.7Relevant national legislation and rules

20. The AFSVPA informed the audit team that the national legislation in the plant health sector is being aligned with the EU legislation. The following is a list of the legislation of plant health relevance for potatoes that was in force at the time of the audit:

- Law on Plant Health Protection (OG MN 28/2006, 28/2011, 48/2015) partly harmonised with Directive 2000/29/EC;

10 - Rulebook on phytosanitary measures for the prevention of introduction, spreading and control of harmful organisms and lists of harmful organisms for plants, plant products and objects under supervision (OG MN 39/2011, 80/2016, 91/2017, 38/2018), transposing national legislation and the form and content of the phytosanitary certificates and phytosanitary certificates for re-export with the Annexes to the Directive 2000/29/EC;

- Rulebooks on phytosanitary register of producers and professional stakeholders and record keeping (OG MN 15/2013, 19/2013 and 39/2013) transposing Directives 92/90/EEC and 93/50/EEC;

- Rulebook on the manner of carrying out phytosanitary checks and conditions for issuing of plant passports (OG MN 72/2015) transposing Directives 92/105/EEC and 2005/17/EC;

- Rulebook on phytosanitary measures for the detection, prevention of spreading and control of the fungus Synchytrium endobioticum causative agent of the potato wart disease (OG MN 15/2010), transposing Directive 69/464/EEC;

- Rulebooks on phytosanitary measures for the detection, prevention of spreading and control of potato ring rot (OG MN 66/2010) and potato brown rot and bacterial potato and tomato wilt (OG MN 67/2010) transposing Directives 93/85/EEC and 98/57/EEC;

- Rulebook on measures for the detection, prevention of spreading and control of potato cyst nematodes (OG MN 43/2010) transposing Directive 2007/33/EC;

- Rulebook on phytosanitary measures for the prevention of introduction and spreading of potato flea beetles (OG MN 17/2017, 35/2018) transposing Decision (EU) 2012/270/EU.

21. The audit team received copies of the above legislation in English and noted that texts largely transpose the relevant EU legislation except for provisions that are specifically addressed to Member States. The current test methods described in the amended Directives 93/85/EC for ring rot and 98/57/EC for Ralstonia solanacearum have been included in the national legislation. The audit team also noted that:

 Import requirements for potatoes are generally harmonised with the EU requirements, even though potato imports, including seed potatoes, are allowed from all European countries including Belarus, Moldova, Ukraine and the European parts of Russia and Turkey.

 The import of ware potatoes from the non-European countries stated in point 12 of Annex III, A to Directive 2000/29/EC is allowed with the exception of potatoes from Egypt.

11 5.1.8Registration of establishments

22. Producers growing arable crops including potatoes in areas of 0.1ha or more (or crops under cover in greenhouses of 0.02ha or more) are subject to registration in the national phytosanitary database of the DPHP (hereafter "registered" producers). The obligation for registration is also in place for potato retailers, wholesalers, warehouse operators and packers who are obliged to purchase material exclusively from registered entities. In line with the conditions for registration, the DPHP registers importers of plants including seed and ware potatoes that are also subject to administrative controls.

23. There is a legal requirement linking the registration obligations with assistance or state aids provided to producers. In line with a cross-compliance mechanism the application for financial support requires registration of the producer, estimation of the volume of the production and compliance with plant health rules.

24. The DPHP has clearly defined the exemption from registration obligations for small- scale producers growing potatoes in open areas less than 0.1ha. These should not be engaged in any professional plant production or processing and their total produce should be intended for personal use or trade in local markets not exceeding 50km distance from the place of production. In line with the food safety law small-scale producers forwarding their produce in local markets must be registered in the food safety database (see also section 5.2.6).

25. Of the ca. 850 entities registered in the list of agricultural holdings of the MARD which contains operators registered for both food safety and plant health purposes 830 are also registered in the phytosanitary database. This also includes importers of plants and plant products, seeds and propagating material and companies treating and labelling wood packaging material. Registration is a one-off process and currently there are nine entries for seed potato producers and 495 entries for ware potato producers. Table 1 above provides a breakdown of the DPHP registered seed and ware/other potato producing farms and non-registered producers who grow potatoes in 2019. The number of non- registered small-scale growers of ware potatoes in plots of less than 1ha and a total area of ca. 540ha is estimated to be 30,245.

26. The DPHP has issued three general and specific factsheets addressed to producers of ware potatoes and citrus fruits, processors, distributors and other operators providing information for registration into the phytosanitary database. Registered producers have to report annually their plans of intended production and type of crops. The data in the phytosanitary database of the DPHP are accessible by the regional inspectors who have been assigned to control compliance with the registration requirements and by experts of the Phytosanitary Laboratory of the BtF who carry out designated checks of the domestic seed potato crops (see also section 5.1.6).

27. Substantial efforts are in place for further promoting registration of small-scale producers in the phytosanitary database of the DPHP. However by the end of 2019, the areas operated by registered producers corresponded to ca. 40% of the total ware potato

12 producing areas, whilst at the same time the estimates between the data available by AFSVPA and the MONSTAT on the total areas with ware potato production varied significantly (see also section 4.1.1).

Conclusion on organisational aspects of plant health controls

28. The competent authorities have the necessary legal basis and well-trained staff to implement the EU legislation concerning plant health in potato production. Controls are adequately planned. This increases the capacity of the DPHP for a proper overview and control of potato production.

29. Methods applied during the laboratory analysis of samples are generally equivalent to those applied in the EU. However, the sample storage and bioassay quarantine facilities of the Phytosanitary Laboratory of the BtF are not sufficient. The weaknesses in quality control procedures could affect the reliability of results.

30. Campaigns regarding the major harmful organisms of potato and factsheets on the requirements for registration have been addressed to potato operators. The collaboration between the different competent authorities facilitates verifying that producers are respecting the requirements for registration in the phytosanitary database. However, large areas where ware potatoes are produced are still operated by small-scale producers who are not registered, reducing the probability of being subject to adequate plant health checks and early detection of ring rot or brown rot contamination.

5.2 CONTROL OF POTATO HARMFUL ORGANISMS

5.2.1Status of harmful organisms of potato in Montenegro

31. The AFSVPA provided the following information on the status of EU harmful organisms: Table 5. Status of EU-regulated harmful organisms of potatoes in Montenegro Harmful organism Status Harmful organism Status Potato spindle tuber viroid B Septoria lycopersici var. malagutii A Potato stolbur phytoplasma E1 Thecaphora solani A Tomato spotted wilt virus E1 E. papa E. tuberis, E. cucumeris, E. subcrinita B Andean potato latent virus A Clavibacter michiganensis ssp. sepedonicus B Andean potato mottle virus A Ralstonia solanacearum B Arracacha virus B, oca strain A Globodera rostochiensis, G. pallida B Potato black ringspot virus A Meloidogyne chitwoodi, M. fallax B Potato viruses T, A, M, S, V and X A Ditylenchus destructor A Potato virus Y (incl. Yo, Yn, Yc) A Nacobbus aberrans A Potato leafroll virus A Leptinotarsa decemlineata D Premnotrypes spp. A Scrobipalposis (=Tecia) solanivora A Synchytrium endobioticum B Naupactus leucoloma A Phoma andina A Puccinia pittieriana A Where: A=Absent, no reports, B=Absent, confirmed by survey, D=Present widespread E1=Present, limited distribution, under official control

13 5.2.2Cms and Rs surveillance strategy and results

Legal requirements Article 2 of Directive 93/85/EEC and Article 2 of Directive 98/57/EC Findings

32. Montenegro has launched a specific surveillance programme for the inspection of potato and tomato crops (see also section 5.1.3). Annual surveys for the detection of ring rot and brown rot are carried out by experts of the BtF at all registered seed potato producers, mainly through three visual inspections of the growing crop, in parallel with other checks taking place for seed quality and certification purposes.

33. A fourth check is carried out by experts of the BtF in the field during the last stage of the growing period 10-15 days after the desiccation of potato crop foliage by randomly uprooting 200 plants following a w-shape sampling pattern. One tuber is collected per plant and one sample of 200 tubers is taken per ha of potatoes. At the same time 110-120 tubers are sampled per ha for follow up checks carried out for non-quarantine harmful organisms and quality purposes.

34. In general, controls focus on the large-scale commercial seed and ware potato producers and exporters. In seed potato production, controls for certification purposes are carried out following an application of registered producers to AFSVPA and forwarded to the BtF. One application together with evidence indicating the identity of the plot, the origin of the used potato seed and compliance with the soil sampling requirements confirming PCN absence is submitted per plot and per potato variety.

35. The DPHP informed the audit team that small-scale non-registered producers might occasionally be selected for surveillance on the basis of information collected for other purposes, such as the provision of agricultural extension services for the presence of quality pests. In case of suspicion, inspectors of DPI who also have the right of taking samples of potatoes from local markets have been instructed to send foliage and/or tuber samples for laboratory analysis. On average ten samples per year are taken from non- registered producers and analysed by the BtF.

36. Annual surveys of ware potato crops are also based on visual inspections carried out during the vegetative period. Other hosts of R. solanacearum like tomato are visually inspected with instructions for samples to be taken in case of suspicion. Despite the provisions of the specific national surveillance programme, wild hosts of R. solanacearum such as S. dulcamara and S. nigrum, potato waste from warehouses which carry out potato tuber sorting and packaging and surface or waste water are not sampled.

37. Neither ring rot nor brown rot has been detected in Montenegro. The samples of potato tubers taken are also analysed for R. solanacearum, giving the same sampling densities as for ring rot. The laboratory testing carried out for the detection of ring rot and brown rot during 2016-2018 growing periods is presented in table 6 below.

14 38. The available data indicate that the average sampling density in seed (2.42 ha per sample) is somewhat lower than the average densities applied for the detection of ring rot and brown rot in the EU (1.7-1.8 ha per sample). Furthermore, considering the quantities of potato seed produced, at least during the last growing period (1,155 t in 2018) and the numbers of seed potato samples taken for laboratory analysis, it would be safe to conclude that not all seed potato plots or the corresponding lots of seed potatoes produced during 2018 are sampled.

39. The DPHP stated that testing of all seed potato plots and 100% of seed material for Cms and Rs was carried out until 2015. Nowadays controls mainly focus on seed and ware potatoes imported to Montenegro.

Table 6. Laboratory testing in seed and ware potatoes for both Cms and Rs from 2016 to 2018 2016 2017 2018 Potato category Cropping No of Cropping No of Cropping No of Density* Density* Density* area (ha) samples area (ha) samples area (ha) samples Basic seed 2.9 3 2.1 2.0 3.3 Certified seed/Other 70.05 33 57.8 27 82.5 25 Ware/Other 557.5 7 79.6 538.6 51** 10.6 710.2 25 28.5 S. dulcamara/S. nigrum 0 0 0 Tomato 0 0 - 30 - Water 0 0 0 *Sampling density is indicated as total ha/sample, ** samples of seed and ware potatoes taken from warehouses of registered producers 40. The data provided by the MONSTAT and a total ware potato producing area of ca. 2,100 ha indicate that the sampling density of ware potatoes, ca. 80 ha per sample in Montenegro vs. ca. 50 ha per sample in the EU, is low. During the interviews with experts in the Phytosanitary Laboratory of the BtF and regional inspectors of the DPI at the premises of seed and ware potato producers the audit team also noted that:

 Potato surveillance is mainly focused on large-scale producers. Small-scale non- commercial holdings where endemic ring rot or brown rot is more likely to occur are not or less well represented in the surveillance plan;

 The majority of the samples of both seed and ware potatoes sent for laboratory analysis are taken from the fields instead of sampling at storage as recommended by the EU legislation. However, sampling after plant desiccation reduces the probability of spotting late visual symptoms of Cms or Rs in the foliage at the final growth stage, whilst the bacteria have less time to multiply in the tubers before laboratory analysis;

 When samples are taken, the potato tubers are not allowed to be harvested until the sample is tested negative. To reduce dispatch costs the tubers are cut in half or by 1/3 in a way that the top heel end (stolon) part is retained in the cut piece and sent to the Phytosanitary Laboratory of BtF;

41. Sampling and laboratory analysis of seed and ware potatoes is mainly targeting large- scale producers. Tubers are sampled from warehouses only exceptionally where additional funding is available; most recently, this took place in 2017.

15 42. Import requirements for potatoes are generally harmonised with EU requirements, even though potato imports are allowed from more countries including all European countries (see also section 5.2.3). Controls carried out at import are mainly based on visual inspections on seed and ware potatoes of EU and third country origin performed by the DPI.

43. During the last two import periods the BtF carried out laboratory testing for the presence of ring rot and brown rot in 28 lots of seed and ware potatoes imported from the EU and in nine lots of ware potatoes imported from non-EU countries. Emphasis is given to the classes of "super elite" and "elite" material imported from the EU, the experts of the BtF consider that potatoes from neighbouring non-EU Balkan countries represent a high risk pathway for the introduction of harmful organisms due to their limited traceability. For this purpose, priority is given to sampling and checking of imported material instead of laboratory checking all seed potatoes produced domestically by the large-scale registered operators.

44. The audit team visited the BIP of Dobrakovo and noted that the requirements for additional declarations on the phytosanitary certificates accompanying imported potatoes were enforced. During the interviews with DPI inspectors the audit team also noted that:

 Documentary, identity and plant health checks are carried out at the BIP for all consignments with ware potatoes. Plant health checks of ware potatoes are carried out with visual inspection and cutting of 200 tubers;

 In most cases documentary and identity checks of consignments with seed potatoes are carried out at the BIP. Plant health checks with visual inspection and cutting of 200 tubers is usually carried out prior to customs clearance at places of destination approved by the DPHP;

 Samples of imported seed or ware potato material consist of 200 tubers. A sample is always taken for visual inspection from potato consignments arriving from “high risk” non-EU countries for the presence of potato bacteria. In general, 5% of seed and ware potato consignments are sampled and samples of tubers are sent to the BtF for laboratory analysis;

 In case of suspicion, plant health checks carried out on potatoes during import may involve quick testing at the border inspection post using rapid pocket diagnostic kits for the detection of R. solanacearum. If positive, the same sample of cut tubers is sent to BtF for laboratory analysis;

16 5.2.3Potato cyst and other nematodes surveillance strategy and results

Legal requirements Directive 2007/33/EC

Findings

45. Sampling and testing for PCN is obligatory for all seed potato plots prior to participation in the seed certification programme. Seed potato producers are obliged to submit annual seed potato production plans by the end of April. All fields destined for seed potato production are sampled by taking 100 sub-samples of 15ml of soil per ha in June following a rectangular scheme. The audit team noted that PCN surveillance of ware potato fields is carried out by taking a larger number of soil samples than that required by Directive 2007/33/EC for surveying of 0.5% of the total ware potato area.

46. In the framework of the surveillance programme for the inspection of potato crops, ca. 140 soil samples from plots with seed and ware potatoes are examined annually. The capacity of the nematology laboratory is max. 180 soil samples. Occasionally, tubers of seed potatoes are also visually inspected for symptoms of other nematodes such as Meloidogyne chitwoodi; no analysis has been carried out so far for Ditylenchus destructor. Potato cyst nematodes have not been recorded in Montenegro.

5.2.4Potato wart disease and potato flea beetles

Legal requirements Directive 69/464/EEC and Article 4 of Decision 2012/270/EU

Findings

47. S. endobioticum was detected in 1968 in Lijeva Rijeka (municipality of Podgorica) and Uvac (municipality of Kolašin). Visual inspections for the presence of this pathogen are conducted in warehouses in the framework of certification of seed potatoes and the general surveillance carried out in ware potatoes for quarantine harmful organisms. Tubers produced in affected areas since 2010 are negative for the presence of S. endobioticum. None of the plots found to be contaminated in 1968 is used nowadays for producing potatoes.

48. The BtF does not have the technical capacity for identifying resting sporangia of S. endobioticum in samples of soil. In order to definitely determine the current status of the organism in Montenegro, the BtF organised in 2013 and 2014 systematic bio-assay trials using samples of soil taken from affected plots in these areas as substrate for growing in containers an old autochthonous variety susceptible to potato wart disease. The trials provided negative results for the presence of S. endobioticum.

49. Surveys for the presence of potato flea beetles Epitrix sp. are carried out by the BtF during the vegetative stages of potato crops using entomological sweeping nets. As for all potato harmful organisms samples of seed and ware potato tubers taken from

17 warehouses are also examined for the presence of Epitrix sp. and in case of suspicion are sent for laboratory analysis in the BtF. Potato flea beetles have not been detected in Montenegro.

Conclusion on the control of potato harmful organisms

50. Annual surveys are carried out for the detection of Cms and Rs. The two diseases have not been detected. However, the total numbers of samples analysed annually and the sampling approach applied by testing tubers taken mainly from the fields of large-scale producers do not provide sufficient coverage of the potato production. Wild hosts of Rs and surface water are not sampled. The status of the bacteria in Montenegro is therefore not fully known.

51. There is a programme for ensuring that fields used for seed potatoes are free from PCN. Control measures harmonised with those of the EU are laid down in national legislation. Systematic soil sampling and testing of fields intended for the production of seed and ware potatoes proved that there is no incidence of PCN. S. endobioticum and Epitrix sp. are not present in Montenegro.

5.2.5Specific ring rot and brown rot control measures

Legal requirements Articles 1 and 11 of Directive 93/85/EEC and Article 10 of Directive 98/57/EC.

Findings 52. There is no incidence of Cms or Rs to warrant additional measures in Montenegro. Producers are entitled to receive agricultural subsidies only if they are registered and submit evidence that they have used certified seed. Checks carried out for the provision of agricultural subsidies are used by the DPI inspectors to request the registration of producers in the phytosanitary database. The cultivated area thresholds for receiving agricultural subsidies are more than 0.5 ha for seed potatoes and 0.1 ha for ware. During the interviews with regional plant health inspectors and potato producers the audit team also noted that:

 Although there is no agreed hygiene protocol indicating the details of actions to be taken during each stage of potato production there is good and widespread knowledge about the importance of good hygiene practice applied in the places of production;  Training events highlight the importance of good hygiene with the preventive disinfection of tools and agricultural machinery used during seed and ware potato packaging and transport. The producers met by the audit team stated that they do not or only in exceptional circumstances share their machinery and agricultural equipment. Such action would be followed up by adequate cleaning.  Large scale seed and ware potato producers and wholesalers stated that as preventive measure they disinfect agricultural machinery, storage facilities and

18 other farm equipment at least once a year in order to avoid possible future problems of pest and disease transmission. Conclusions on the specific ring rot control programme

53. Montenegro has adopted preventive measures against ring rot and brown rot. Professional potato producers use certified seed and are aware of the positive effects of regular disinfection.

5.2.6Documentation and traceability of potato consignments

Legal requirements Article 10 and point 18.5 of Annex IV, Part A, Section II of Directive 2000/29/EC. Directive 92/105/EEC Article 3 of Directive 2002/56/EC.

Findings 54. All consignments of potatoes destined for domestic circulation must be accompanied by an appropriate plant passport (for seed) or labelling on each packaging unit (for ware). Trade of potatoes in local markets is carried out by producers who are expected to be registered in line with plant health requirements and/or the food safety law and are subject to direct and/or indirect "potato movement compliance" checks. For this purpose the audit team visited the premises of seed and ware potato producers and one retail shop and noted that:

 All operators met were aware of their obligation for registration with the DPHP. Seed and ware potatoes at the premises of producers were clearly marked and labelled indicating the varieties and lot numbers. Ware potatoes in bulk in the retail shop had labels indicating the registration numbers of producers or pack houses;

 The DPHP stated that small-scale producers and/or retailers in local markets trade potatoes only to final consumers. In line with the food safety law they are subject to documentary checks for compliance with the rules for registration by the DPI.

Conclusions on documentation and traceability of potato consignments

55. The documentation and traceability system for potato consignments provides sufficient guarantees on the plant health status of labelled potatoes traded in Montenegro.

19 5.2.7Export checks and issuance of phytosanitary certificates

Legal requirements Points 25.1, 25.2 and 25.4.1 of Annex IV, Part A, Section I, of Directive 2000/29/EC

Findings

56. In order to export ware potato producers must be registered in the phytosanitary database and participate in the surveillance plan for the inspection of potato crops. Producers must submit an application to the DPI which is competent for the area of the place of production at least 24 h prior to export. Upon notification, inspectors proceed with analysis of import requirements of the third country receiving the potato consignment and carry out documentary, identity and plant health checks of the consignment to be exported.

57. Pre-export checks usually take place in the production sites or warehouses owned either by farmers or managed by professional companies. During the documentary and identity checks, inspectors check for evidence of the origin of the consignments and the results of inspections carried out in the framework of the specific potato surveillance plan. In addition, they take a 200 tuber sample for each lot of 25 t for visual inspection and if in doubt they may order a complementary laboratory testing. A phytosanitary certificate is issued at the place of production where the visual inspection is carried out.

58. At the BIP of Dobrakovo, a point of exit from where ware potatoes are exported to Serbia, the audit team carried out an administrative follow up of the export procedure with DPI inspectors who stated that:

 Potatoes destined for export must be loaded at the place of production following a visual inspection or upon documentary verification of laboratory results for the absence of quarantine harmful organisms. Potatoes have to be packed in clean and labelled packaging material. Inspectors have to be present during loading;

 Inspectors have the right to issue phytosanitary certificates only for potatoes produced in the region of their competence. Ware potatoes for export can be traced back to their place of production through lists with registered potato producers notified to the BIPs;

 Customs clearance prior to export generally takes place at the local customs office and the consignment is sealed at the place of production. In case of infringement, inspectors at the points of exit have been instructed to launch an investigation procedure involving trace back and forward actions.

Conclusions on export checks and issuance of phytosanitary certificates

59. There are clear procedures for export controls. Pre-export checks are carried out in warehouses and plant health inspectors have been instructed to be present during

20 loading. Consignments and their certification are traceable as appropriate from production, handling and transport to the point of exit.

6 OVERALL CONCLUSIONS

The overall situation of the main potato harmful organisms in Montenegro is positive. Long crop rotation schemes and minimal irrigation are applied in the professional seed and ware potato crops whilst the use of certified seed for the production of ware potatoes is subsidised. The system of official controls in the potato sector is comparable to that applied in the EU. Seed potato plots are subject to an official surveillance programme which includes soil sampling prior to planting, visual surveys of the growing crop and sampling of tubers mainly carried out prior to harvest for laboratory analysis. Potato cyst nematodes have not been detected and the findings of potato wart disease that occurred in 1968 have been eradicated. In general, the diagnostic methods applied by the official laboratory for the detection of potato bacteria and potato cyst nematodes are equivalent to those in the EU. However, there were significant weaknesses in quality control procedures, insufficient facilities for storage of samples and inadequate quarantine facilities. The shortcomings affect the reliability of results. Available data indicate that so far there has been no incidence of ring rot and brown rot in Montenegro. However, the surveillance methods applied to confirm this are not fully in line with the EU requirements. Sampling is not representative as samples of potato tubers are mainly taken from the fields of large scale registered producers of certified seed and ware potatoes. A significant proportion of potato growing areas are operated by small-scale non-registered producers whilst potatoes destined for household consumption or the domestic local markets are not or only occasionally surveyed. Montenegro cannot be regarded as free from both potato bacteria as there are problems in the sampling approach and in the number of tuber samples analysed.

7 CLOSING MEETING

A closing meeting, where the team presented the main findings and preliminary conclusions of the audit, was held on 13 November at the premises of the Phytosanitary Sector of AFSVPA.

8 RECOMMENDATIONS

No. Recommendation

1. To ensure that the designated laboratory facilities are improved by including dedicated areas for sample reception and storage and quarantine glasshouses facilitating pathogenicity tests meeting the requirements of Directives 93/85/EEC and 98/57/EC. Quality control procedures should be improved to demonstrate that the laboratory generates technically valid

21 results. Recommendation based on conclusion 29. Associated finding 19 2. To ensure that the registration of seed and ware potato producers are continued and include all entities that market potatoes other than small scale growers whose entire production is sold to final consumers on the local market in line with Article 6(6) of Directive 2000/29/EC and Directive 93/50/EEC. Recommendation based on conclusion 30 Associated finding 27 3. To ensure that the surveillance sampling carried out for latent infection of Clavibacter michiganensis ssp. sepedonicus and Ralstonia solanacearum, is improved in line with Article 2 of Directive 93/85/EEC and Article 2 of Directive 98/57/EC and in particular: a. the number of seed and ware potato samples should be increased, b. samples should preferably be taken from potatoes in storage, c. sampling should take into account the potato production system in the country and represent more small scale potato production holdings. Recommendation based on conclusion 50 Associated finding 40 4. To ensure that the surveillance carried out for identifying Ralstonia solanacearum contamination will include annual official targeted surveys in line with Article 2 of Directive 98/57/EC. In particular surveillance should include: a. adequate number of samples of wild solanaceous host plants. b. adequate number of samples of surface water used for irrigation and samples of liquid waste discharged from potato packaging premises. Recommendation based on conclusion 50 Associated finding 36

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

http://ec.europa.eu/food/audits-analysis/rep_details_en.cfm?rep_inspection_ref=2019-6741

22 ANNEX 1 – LEGAL REFERENCES

Legal Reference Official Journal Title Dir. 2000/29/EC OJ L 169, 10.7.2000, Council Directive 2000/29/EC of 8 May p. 1-112 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

Dir. 69/464/EEC OJ L 323, Council Directive 69/464/EEC of 8 24.12.1969, p. 1-2 December 1969 on control of Potato Wart Disease

Dir. 93/85/EEC OJ L 259, Council Directive 93/85/EEC of 4 October 18.10.1993, p. 1-25 1993 on the control of potato ring rot

Dir. 98/57/EC OJ L 235, 21.8.1998, Council Directive 98/57/EC of 20 July 1998 p. 1-39 on the control of Ralstonia solanacearum (Smith) Yabuuchi et al.

Dir. 93/50/EEC OJ L 205, 17.8.1993, Commission Directive 93/50/EEC of 24 June p. 22-23 1993 specifying certain plants not listed in Annex V, part A to Council Directive 77/93/EEC, the producers of which, or the warehouses, dispatching centres in the production zones of such plants, shall be listed in an official register

Dir. 92/90/EEC OJ L 344, Commission Directive 92/90/EEC of 3 26.11.1992, p. 38-39 November 1992 establishing obligations to which producers and importers of plants, plant products or other objects are subject and establishing details for their registration

Dir. 2007/33/EC OJ L 156, 16.6.2007, Council Directive 2007/33/EC of 11 June p. 12-22 2007 on the control of potato cyst nematodes and repealing Directive 69/465/EEC

Dir. 92/105/EEC OJ L 4, 8.1.1993, p. Commission Directive 92/105/EEC of 3 22-25 December 1992 establishing a degree of standardization for plant passports to be used for the movement of certain plants, plant products or other objects within the Community, and establishing the detailed procedures related to the issuing of such plant passports and the conditions and detailed procedures for their replacement Dir. 2004/103/EC OJ L 313, Commission Directive 2004/103/EC of 7 12.10.2004, p. 16-20 October 2004 on identity and plant health checks of plants, plant products or other objects, listed in Part B of Annex V to Council Directive 2000/29/EC, which may be carried out at a place other than the point of entry into the Community or at a place close by and specifying the conditions related to these checks

Dec. 2012/270/EU OJ L 132, 23.5.2012, 2012/270/EU: Commission Implementing p. 18-21 Decision of 16 May 2012 as regards emergency measures to prevent the introduction into and the spread within the Union of Epitrix cucumeris (Harris), Epitrix similaris (Gentner), Epitrix subcrinita (Lec.) and Epitrix tuberis (Gentner)

Dir. 2002/56/EC OJ L 193, 20.7.2002, Council Directive 2002/56/EC of 13 June p. 60–73 2002 on the marketing of seed potatoes ANNEX 2 – INTERNATIONAL STANDARDS QUOTED IN THE REPORT

International Title Standard

ISPM 4 International Standard on Phytosanitary Measures Publication No 4, Requirements for the establishment of pest free areas, Food and Agriculture Organisation, Rome, August 2011 https://www.ippc.int/en/publications/614/

ISPM 23 International Standard on Phytosanitary Measures Publication No 23, Guidelines for Inspection, Food and Agriculture Organisation, Rome, June 2019 https://www.ippc.int/en/publications/598/