Ministry of Commerce And Supplies - Enhanced Integrated ...
Ministry of Commerce And Supplies - Enhanced Integrated ... Ministry of Commerce And Supplies - Enhanced Integrated ...
N T I S20102. The DoA has the personnel and expertise to carry out PRAs for traded plants and plant products;3. While there is no certified laboratory operational in Nepal, significant efforts are underway to upgradefacilities and build human resource capacity at the NBSM and the DFTQC to test for agrochemicalresidues and food-borne human pathogens. A similar, though more modest, programme is underwayat the DoLS laboratories. This type of testing is requested and carried out by the Indian Government inthe absence of credible certification being available to Nepalese exporters to produce with their exportdocumentation.Weaknesses:1. The Nepalese government has found it difficult to retain staff in the past, most especially those who arethe recipients of in-service capacity-building training programmes. There is a danger that the currentbeneficiaries of the EU-funded UNIDO capacity-building programme may well be similarly lured awayby better opportunities once the programme comes to a conclusion;2. The primary need for SPS support for exports is in the field of TCP. The type of training/expertiserequired in this field is gained primarily via implementation, i.e. putting these systems in place in aworking (private sector) situation. Therefore, the necessary expertise generally does not reside in thepublic sector;3. The private sector is reluctant to use public services (such as laboratories) because of a perception thatthese are weak and below standard.WTO Sanitary and Phytosanitary (SPS) Enquiry PointsNepal’s WTO SPS enquiry points were reviewed in detail earlier in this chapter. These have been set up andare functional. However, a higher degree of professionalism is necessary, including updating websites/contactdetails and dealing promptly with queries. Currently, the SPS/CODEX enquiry points are the beneficiaries ofan extensive EU-financed/UNIDO-led infrastructural and capacity-building exercise and it is important that itsmomentum be maintained during and after this programme.Infrastructure of Government and Private Sector LaboratoriesCurrently, there are no laboratories in Nepal that carry out internationally recognized testing in foodcomposition and food safety. The need for accredited laboratories for animal and plant health testing isnot so pressing (animals and animal products are not really traded and plant pest/disease taxonomy can beverified using alternatives to accredited laboratories). Outside of the laboratories at the DFTQC and the NBSMthere are a handful of private sector laboratories that only have Nepal Laboratory Accreditation Scheme(NEPLAS) accreditation, which is not internationally recognized and, therefore, currently of no value for tradepurposes.Capacity of Existing Infrastructure in Plant Health, Animal Health, Food SafetyThe most significant weakness in Nepalese export certification infrastructure at present is the lack of acceptablepesticide residue testing (and therefore certification) for the range of plant exports, including those listed inTable 8.4. In effect, this lack of capacity has a number of implications which ‘cascade’ down to the harshregime being imposed by Indian officials at the border posts of compulsory consignment testing for pesticides.Since India has ratcheted up its compliance with CODEX (or even EU) agrochemical MRLs, by extension thismust apply to importers of foods into India, including Nepal.As discussed in more detail earlier, as a first step the pesticide approvals, active ingredients, formulations,application rates, and withholding periods need to be reviewed in light of the changing MRLs, which have inmany cases moved to the LoD in the EU. Following this is the need for the long-term goal of developing a ‘duediligence’ approach by Nepalese exporters which would reduce the required intensity of testing (discussedbelow). This absence affects all exports of plant based food exports from Nepal.NEPAL TRADE INTEGRATION STRATEGY 2010BACKGROUND REPORT203
N T I S2010Simpler requirements such as the necessity for fumigation of lentil exports are currently well addressed,though it would be prudent to ensure that any necessary research and protocols on alternatives to methylbromide fumigation be put in place as a contingency (Indian import protocols allow for substitutes).Accreditation of Nepal-based Laboratory FacilitiesThis topic is effectively covered in Chapter 7.Traceability CapabilityIn SPS terms, Nepal has carried out only one exercise in producing an internationally acceptable traceabilitysystem--with negative results. This was the DFTQC plan for honey monitoring and surveillance to EU Directive92/118/EEC standard. While the production of such a plan is an expensive and difficult exercise, it can andhas been done successfully by countries with limited resources (see footnote 15, Greiling, J., 2008 in relationto the examples of Ethiopia and Zambia). The case studies indicate the necessity of:1. Starting the process as a full partnership of both public and private sectors;2. Bringing in appropriate expertise early on;3. Realizing at the outset that an accredited national testing laboratory is not a prerequisite to runninga national monitoring and surveillance plan (Ethiopia used an EU-accredited laboratory in Ugandafor their initial testing) and that implementation of the plan does not need to follow the building oflaboratory capacity.In terms of tea exports, the current lack of demonstrable traceability in terms of GAP certification requiresexporters to have every consignment tested for pesticide residues. For ginger, lentils, and cardamom whereexports are even weaker, traceability systems would appear to remain an aspiration for the foreseeable future,which, as discussed, had led to compulsory consignment testing for pesticide residues by India.The impediments to developing traceability in Nepalese exports are largely a function of the structure of thenational agriculture and landholding system and are beyond the remit of this report. However, there areexamples of how traceability, generally via TPC, can be achieved in other countries through the developmentof strong cooperatives and marketing associations. Therefore, the SPS export certification needs to workthrough with the public, private and NGO sectors that are involved in institution-building among smallholderfarmers.Assistance to Nepalese Producers to Implement ‘Process’ StandardsCurrently, this remains a future activity in the EU-funded UNIDO programme for upgrading and capacity buildingat the DFTQC and NBSM. The plan is to bring in suitable TPC agencies to give hands-on training to DFTQCpersonnel via the HACCP auditing/certification of participating private sector companies. This aspiration isquite vague and largely ignores the necessity for appropriate PRPs, including traceability (see the precedingsection). The certification of a business is an interactive process involving two types of input: putting in placePRPs, including a complementary infrastructure and a separate certification audit. Since the necessary PRPsinclude supplier traceability with accompanying GAPs, the possibility of full HACCP auditor training for theDFTQC with successful certification of the participating companies seems, from this perspective, to be anunrealistic aspiration. At best, the exercise will build awareness and some capacity within the DFTQC. Thediscussions at the DFTQC seem to indicate that this issue is understood to some extent in that their ultimateintention is to set Nepalese standards for the TCP.204NEPAL TRADE INTEGRATION STRATEGY 2010BACKGROUND REPORT
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N T I S20102. The DoA has the personnel and expertise to carry out PRAs for traded plants and plant products;3. While there is no certified laboratory operational in Nepal, significant efforts are underway to upgradefacilities and build human resource capacity at the NBSM and the DFTQC to test for agrochemicalresidues and food-borne human pathogens. A similar, though more modest, programme is underwayat the DoLS laboratories. This type <strong>of</strong> testing is requested and carried out by the Indian Government inthe absence <strong>of</strong> credible certification being available to Nepalese exporters to produce with their exportdocumentation.Weaknesses:1. The Nepalese government has found it difficult to retain staff in the past, most especially those who arethe recipients <strong>of</strong> in-service capacity-building training programmes. There is a danger that the currentbeneficiaries <strong>of</strong> the EU-funded UNIDO capacity-building programme may well be similarly lured awayby better opportunities once the programme comes to a conclusion;2. The primary need for SPS support for exports is in the field <strong>of</strong> TCP. The type <strong>of</strong> training/expertiserequired in this field is gained primarily via implementation, i.e. putting these systems in place in aworking (private sector) situation. Therefore, the necessary expertise generally does not reside in thepublic sector;3. The private sector is reluctant to use public services (such as laboratories) because <strong>of</strong> a perception thatthese are weak and below standard.WTO Sanitary and Phytosanitary (SPS) Enquiry PointsNepal’s WTO SPS enquiry points were reviewed in detail earlier in this chapter. These have been set up andare functional. However, a higher degree <strong>of</strong> pr<strong>of</strong>essionalism is necessary, including updating websites/contactdetails and dealing promptly with queries. Currently, the SPS/CODEX enquiry points are the beneficiaries <strong>of</strong>an extensive EU-financed/UNIDO-led infrastructural and capacity-building exercise and it is important that itsmomentum be maintained during and after this programme.Infrastructure <strong>of</strong> Government and Private Sector LaboratoriesCurrently, there are no laboratories in Nepal that carry out internationally recognized testing in foodcomposition and food safety. The need for accredited laboratories for animal and plant health testing isnot so pressing (animals and animal products are not really traded and plant pest/disease taxonomy can beverified using alternatives to accredited laboratories). Outside <strong>of</strong> the laboratories at the DFTQC and the NBSMthere are a handful <strong>of</strong> private sector laboratories that only have Nepal Laboratory Accreditation Scheme(NEPLAS) accreditation, which is not internationally recognized and, therefore, currently <strong>of</strong> no value for tradepurposes.Capacity <strong>of</strong> Existing Infrastructure in Plant Health, Animal Health, Food SafetyThe most significant weakness in Nepalese export certification infrastructure at present is the lack <strong>of</strong> acceptablepesticide residue testing (and therefore certification) for the range <strong>of</strong> plant exports, including those listed inTable 8.4. In effect, this lack <strong>of</strong> capacity has a number <strong>of</strong> implications which ‘cascade’ down to the harshregime being imposed by Indian <strong>of</strong>ficials at the border posts <strong>of</strong> compulsory consignment testing for pesticides.Since India has ratcheted up its compliance with CODEX (or even EU) agrochemical MRLs, by extension thismust apply to importers <strong>of</strong> foods into India, including Nepal.As discussed in more detail earlier, as a first step the pesticide approvals, active ingredients, formulations,application rates, and withholding periods need to be reviewed in light <strong>of</strong> the changing MRLs, which have inmany cases moved to the LoD in the EU. Following this is the need for the long-term goal <strong>of</strong> developing a ‘duediligence’ approach by Nepalese exporters which would reduce the required intensity <strong>of</strong> testing (discussedbelow). This absence affects all exports <strong>of</strong> plant based food exports from Nepal.NEPAL TRADE INTEGRATION STRATEGY 2010BACKGROUND REPORT203