Draft Commission Directive amending Annexes II, III, IV and V to Council Directive 2000/29/EC on protective measures against the introduction into the Community of organisms harmful to plants or plant products and against their spread within the Community

Orgalime welcomes the Commission’s commitment to better protect Europe from organisms harmful to plants or plant products. We fully agree that pallets and other wood packaging used for importation should be treated in a way to prevent spread of harmful organisms in the EU.

Many companies do however use their packaging (pallets, boxes etc) for both imports and exports and this for many years.

Our main concern is about pallets currently in use that already fulfil the new requirements but are not marked in accordance with the requests of the new proposal.  We believe that, as a consequence of the proposed directive, all pallets in use, would have to be collected in order to re-mark and re-certify them.  This would create unnecessary road traffic and unnecessary costs for companies in general.  An other consequence would be a waste of natural resources.

Orgalime believes that ideally the directive should be applicable to new products and the transition period (2004-2006) should be extended.