ASTA Priorities in Brazil Ordinance 59 Normative 36 Brazil O-59 - - PowerPoint PPT Presentation

Ordinance 59 Normative 36

ASTA Priorities in Brazil

Brazil O-59

• Applies to importation of small seed lots for

research, breeding, and trials

• Shipments to be subjected to quarantine
• Shipments shall be submitted to phytosanitary

testing

• Shipments of seed not on PVIA list shall be

shipped to approved quarantine station and submitted for quarantine testing

Brazil O-59

• Exempted: regulated articles that fall in

categories 0 or 1 of phytosanitary risk based

• n Brazil legislation
• Special import permits are required

Brazil O-59

• Initially distributed domestically for comment;

informally shared with several other

• rganizations for comment once interest was

made known to DSV

– ASTA/APHIS – Plantum/ESA – ISF

• U.S. companies have recently had difficulty
• btaining import permits and complying with

phytosanitary import requirements

Brazil O-59

• Small quantities do not lend themselves to

phytosanitary testing – sample size may be the entire shipment!

• Many shipments are for destructive testing or

evaluation under confinement and therefore pose little, if any risk

• O-59 needs to conform to new seed ISPM
• Process to obtain import permits is very

bureaucratic, subject to interpretation, and time consuming – could set back variety development and evaluation activities

Brazil O-59

• USDA APHIS is proposing that Brazil DSV use

the U.S. protocol for importing small seed lots

– Conditions customized according to risk – Destructive analysis vs. growth in confinement vs. various forms of post entry quarantine

U.S. System for Importing Small Seed Lots

• Import permit required, phytosanitary certificate not

required

• Import permits good for up to 3 years
• Seed not of any prohibited species, noxious weeds, not

treated, pelleted or coated

– APHIS will still issue special permits for prohibited spp but under conditions of quarantine or post entry quarantine

• Meets certain packaging and shipping requirements
• Up to 50 seeds or 10 grams/packet; up to 50

packets/shipment

• Shipped to designated POE

Brazil N-36: Review of the Latest Version of Proposed Rule

• N-36 applies to importation of commercial

seed

• Article 1: defines quarantine pests associated

with seed species in annexes to the rule

– 1st draft: 35 country-specific annexes; the US annex contained over 120 pests – 2nd draft: annexes reduced to one global annex – 3rd draft: back to country-specific annexes

Brazil N-36

• Article 2:

– DA*1: PC stating that seed is free of Q pests – DA2: shipment treated for arthropods – DA5: (Norm 7), Allow Field Inspection for some species of specific origins – DA15: shipment is free from pests identified in the annex based on a lab test OR field inspection OR if applicable, seed was grown in a PFA (ISPM 4)

• Shipments will likely be re-tested at POE prior to

entry (paid by exporter)

* Additional Declaration

Brazil N-36

• Concern that some of the pests listed in

annexes are not technically justified

• Seed tests are non-existent for many pests
• Frequency of re-testing at the POE (original

version indicated 100%!)

Brazil N-36

• APHIS/Brazil technical bilateral held May 12, 2014

– Luis E.P. Rangel, new DSV director et.al.

• Brazil N-36 still in process; comment period is still

“open” for APHIS

• APHIS resubmitted all information previously

submitted for the record

• APHIS preparing additional analyses (July 2014)
• ABRASEM/ABCSEM organizing a one day

Phytosanitary workshop with MAPA set for September 25. O-59 and N-36

• B-36 continues to be a moving target!