False codling moth: the pest behind how Kenyan roses are inspected

Why roses, and not the rest of the range

In 2023 the European Food Safety Authority assessed the probability of Thaumatotibia leucotreta — false codling moth — being introduced into the European Union through imports of cut roses. It concluded that cut flowers of Rosa provide an introduction pathway for the pest.

The regulation that followed says why it was acted on, and the wording is worth quoting because it is the part that explains the inspection rates:

"Given the continued non-compliances of cut flower Rosa L. consignments due to the presence of that pest, established as a result of border controls in the Union territory, it is justified to introduce special requirements…"

That is the answer to a question this site has stated elsewhere without answering. Great Britain physically inspects Kenyan roses at 25% and Kenyan carnations and gypsophila at 5%. The gap is not about Kenya, and it is not about roses being more valuable. It is about one pest, found repeatedly in rose consignments at the border, on a pathway a regulator has formally assessed. The full inspection table is on the UK market page.

Two regimes, and they must not be read across

Great Britain and the European Union introduced closely parallel requirements, both applying from 26 April 2025. They are not the same instrument and a buyer should never cite one for the other.

Why both belong on a page about Kenyan flowers. A very large share of Kenyan roses moves through the Netherlands, whether sold at auction or in transit to another buyer. A consignment can therefore meet the EU requirement, the GB requirement, or both on the same journey. Which one governs depends on where the flowers are entered, not where they were grown.

The EU instrument was read in full for this page. The GB position is set out on the UK market page with its own source.

Re-read in the consolidated text on 25 September 2026. Point 62 as it stands in the consolidated Regulation 2019/2072 of 6 July 2026, and as it stands in the version dated 15 October 2026, is word-for-word the same. The requirement described below is not changing this autumn.

The four routes, and what each one puts on your certificate

The additional declaration across every destination on this site, with the IPPC's model wordings →

This is the practically useful part. The requirement is not "be free of the pest". It is that the phytosanitary certificate carries an official statement under one of four alternatives — and each alternative leaves a different mark on the paperwork.

Route (a) — the whole country is recognised as free of the pest

The country of origin is recognised as free from Thaumatotibia leucotreta, and that freedom status has been communicated in advance in writing to the Commission by the national plant protection organisation.

Route (b) — a pest free area

A defined area established as free from the pest under ISPM 4. The area is named on the certificate under the rubric "place of origin", and again the status must have been communicated in advance in writing.

Route (c) — a pest free place of production

A place of production established as free under ISPM 10, included in a list of place-of-production codes communicated in advance in writing to the Commission. It requires official inspections at the place of production at appropriate times during the growing season and again prior to export, including visual examination:

"with an intensity to enable at least the detection of a 2 % level of infestation, with a level of confidence of 95 %" — ISPM 31

The certificate must indicate the place of production codes.

Route (d) — an approved site, plus a systems approach or a treatment

An approved site of production on a communicated code list, plus either an effective systems approach under ISPM 14 or an effective stand-alone post-harvest treatment — with the approach or treatment, and documentary evidence of its effectiveness, communicated in advance in writing, and, under the EU instrument, the post-harvest treatment assessed by the European Food Safety Authority. The same 2% / 95% pre-export inspection applies.

The certificate must indicate the production site codes and state the details of the post-harvest treatment used, or the use of the systems approach.

What this means when you are holding the document. Under routes (c) and (d) there are codes on the certificate, and under (d) there is either a named treatment or a statement that a systems approach was used. Under route (b) there is a named area in the "place of origin" field. The same check, alongside the other documents a consignment travels on, is here. If you are buying roses from an African origin and the certificate carries none of these, that is a question to ask — not an accusation, but the one field on the document that this rule actually changes.

Scope: it is wider than Kenya and wider than flowers

Geographic: "Countries of the African continent, Cape Verde, Saint Helena, Madagascar, La Reunion, Mauritius and Israel". This is not a Kenya-specific measure — it applies to every African origin, so it is not a reason to prefer one African supplier over another.

Commodity: cut flowers of Rosa (CN 0603 11 00) plus fruits of Capsicum, Citrus (with named exceptions), Prunus persica and Punica granatum. Only the roses concern a flower buyer — but it is worth knowing the pest is regulated on a fruit pathway too, because that is where most of the published enforcement writing about it sits.

And it does not touch the rest of the Kenyan range. Gypsophila, alstroemeria, statice and the summer flowers are not in scope of this requirement at all, which is consistent with the lighter inspection rates they meet. The summer-flower range is set out here.

Why the rule was delayed nine months, and why that matters

The regulation was made on 23 July 2024 and published in the Official Journal on 26 July 2024 — but the rose provision was given until 26 April 2025 to apply. The regulation states the reason: the period was necessary to allow the competent authorities time, following consultation including under the WTO SPS Agreement.

The commercial reading of that delay is the useful one. Routes (a) through (d) all require something to have been communicated in advance in writing by a national plant protection authority — a freedom status, a list of place-of-production codes, a list of site codes, a treatment dossier. None of that can be arranged on the day of shipment, which is precisely why nine months were allowed. Compliance here is a standing arrangement between an exporter and their plant health authority, not a document produced per consignment.

What we cannot tell you

• Whether any particular Kenyan site appears on a communicated code list. That is a matter between the exporter and the Kenyan plant health authority. We do not hold those lists, we publish no supplier directory, and we will not assert any producer's status on their behalf.
• Which route Kenyan exporters predominantly use. We found no published breakdown.
• What the treatment is, where route (d) is used with a stand-alone treatment. The regulation requires it to be communicated and, in the EU, EFSA-assessed; it does not publish a list on the face of the instrument.
• Whether a given consignment was inspected. What the border charges and how often it opens a box is covered separately.

What to ask

• Which of the four routes does this production qualify under? A supplier close to their own compliance will know without checking.
• Will the certificate carry place-of-production or site codes? Routes (c) and (d) require them.
• Has the arrangement been communicated to the destination authority, and when? The advance-communication step is the one that cannot be done retrospectively.
• Is the position the same for a consignment entered in the EU as for one entered in Great Britain? Two instruments, one of which adds an EFSA assessment.