Pathway analysis: aquatic plants imported in 10 EPPO countries S. Brunel EPPO ⁄ OEPP, 1 rue le Nôtre, 7515 Paris, France; e-mail: [email protected] Pathway analyses are regarded by National Plant Protection Organizations as a very efficient way to address the risks posed by invasive alien species. Data on import of aquatic plants was obtained from 10 EPPO countries (Austria, Czech Republic, Estonia, France, Germany, Hungary, the Netherlands, Latvia, Switzerland and Turkey) and aggregated in order to consider whether invasive or potentially invasive alien plants could be introduced in the EPPO region through this pathway. This study highlights that this pathway mainly consists of the import of tropical plants for use in aquaria, and which do not represent a risk due to their climatic requirements. However, a few species require thorough attention owing to the threats they cause. Of the 247 species recorded as imported, only 10 are currently considered to be a threat, representing 4% of the total number of plants imported. These 10 invasive or potentially invasive species continue to be traded in huge quantities in spite of the fact that Crassula helmsii and Eichhornia crassipes are recommended for regulation by EPPO, Azolla filiculoides, Egeria densa, Elodea nuttalli, Lagarosiphon major, Ludwigia grandiflora and Myriophyllum aquaticum should have their entry and spread prevented by countries and Hydrilla verticillata and Pistia stratiotes are recorded on the EPPO Alert List. Six additional species have been identified as representing a moderate to high potential risk: Alternanthera sessilis, Adiantum raddianum, Gymnocoronis spilanthoides, Hygrophila polysperma, Limnophila sessiliflora and Syngonium podophyllum. These species could be subject to further investigation, possibly a pest risk analysis, to evaluate the risk they may represent. Introduction In the framework of the International Plant Protection Convention (IPPC) and the European strategy on invasive alien species (Bern Convention), the European and Mediterranean Plant Protection Organization (EPPO) is developing a strategy to protect the EPPO region against invasive alien plants. In 2002 an ad hoc Panel on Invasive Alien Species was created to identify invasive alien plants which may present a risk to the EPPO region, and to propose management options. EPPO draws up lists of pests which present an unacceptable risk. The process used is as follows: species are first included on the Alert List which is maintained by the EPPO Secretariat; after selection by the relevant Panels, Pest Risk Analysis is carried out. After approval of the results, the species is added to the EPPO A1 list (species not present in the EPPO region) or the A2 list (species present in the EPPO region but not widely distributed), meaning that the species is recommended for regulation. Plants may be considered as quarantine pests, and the same procedures and tools (decision support scheme for quarantine pests and lists) are used as for other pests. The topic of invasive alien plants was first tackled by EPPO in 2002 because many species were invading certain member countries. A list of 39 Invasive Alien Plants for which EPPO ‘strongly recommends countries endangered by these species to take measures to prevent their introduction and spread, or to manage unwanted populations’ was drafted and published in 2004 (see Brunel et al., 2009 for further details). ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 National Plant Protection Organizations (NPPOs) have a major role in preventing the introduction and spread of invasive species, EPPO therefore maintains its free monthly reporting service (http://www.eppo.org/PUBLICATIONS/reporting/reporting_ service.htm) to assist the early warning and identification of new invaders. The EPPO Panel on Invasive Alien Species has also identified the need to work on pathway analyses. In this respect, EPPO published an aggregated list of imported aquatic plants in Orly Airport, France in April 2006 (EPPO Reporting Service 2007, 2007 ⁄ 016). The Panel on Invasive Alien Species recommended that this study should be enlarged to additional Member countries. Data on imported aquatic plants was received from 10 EPPO member countries and aggregated. The aim of such a study is to consider whether the import of aquatic plants represents a risk of introduction of invasive alien plants in the EPPO region. This study will allow trends in the exporting countries to be highlighted and to identify the most traded species. Then, comparing the list of imported aquatic plants with the main lists of invasive alien plants worldwide, allows identification of current and future invaders moving in trade. Methods Sources of Information Copies of Phytosanitary Certificates (PCs) or data on imported aquatic plants were received from Austria, the Czech Republic, Estonia, France, Germany, Hungary, Israel, Netherlands, Latvia, 201 202 S. Brunel Switzerland and Turkey. Species names, origins of consignments, the period covered and quantities were extracted from PCs and are provided in Table 1. Import data were provided from Israel at the genus level and were therefore not included in the study. Taxonomy While aggregating the lists of aquatic plants traded, work on the taxonomy of species was necessary. Because many synonyms were used instead of the currently valid names (e.g. Echinodorus grisebachii was mentioned, whereas the recognized name for this species is E. bleheri), each species name was checked against taxonomic indexes. The following taxonomic indexes were used: (1) The International Plant Names Index (IPNI). (2) Tropicos 3W (Tropicos, 2009). (3) The Germplasm Resources Information Network (GRIN, 2009) was also used when the name(s) could not be found in the 2 previously quoted indexes. The species named in this report as a) currently considered a threat, b) representing a moderate to high risk and c) species for further monitoring are listed in Table 2. The complete table of 247 imported aquatic plants with corrected scientific names is provided on the EPPO website. The following mistakes in the taxonomy were recorded: Incomplete species names In the phytosanitary certificates, species were sometimes only named with the genus and the variety name, without mentioning the species name. For instance, Vallisneria spiralis cv. ‘Torta’ was given as ‘Vallisneria torta’. Spelling mistakes Several mistakes occurred in the spelling of Latin names: Cryptocoryne hodoroi stood for C. hudoroi, Echinodorus palifolius stood for E. palaefolius, etc. Difficult synonyms For some species, the synonymy required deeper investigations. For instance, Mimosa amphibium does not exist and stands for Neptunia natans, and Selaginella braunii was given as S. vogelii according to J van Valkenburg (pers. comm., 2009). Hydrocharis gigantea was used for Vallisneria americana cv. ‘Rubra’, also given as V. gigantea hort; Hydrocharis rubra replaced V. americana cv. ‘Rubra’, and Hydrocharis torta replaced V. spiralis cv. ‘Torta’ according to I Smith (pers. comm., 2009). Limnophila brevipes was called Ludwigia brevipes, Ophiopogon pusillus was used for O. japonicus, and Rotala boschii was called Mayaca sellowiana (I Smith, pers. comm., 2009). Unrecognized names For some names provided, no recognized species could be identified. For instance, Cabomba asiatica is quoted, but does not exist in any flora. The genus Cabomba is endemic to the New World, only C. caroliniana is recorded as present in Asia. Cabomba asiatica could be the incorrect name for C. caroliniana (J.M. Tison, pers. comm., 2007). Another hypothesis is that the English name both for C. asiatica and C. aquatica is ‘yellow cabomba’, in opposition to the English name of C. caroliniana which is ‘green cabomba’. Cabomba asiatica is most probably the incorrect name for C. aquatica (I. Smith, pers. comm., 2009). Aponogeton siamensis, Myriophyllum gigantea, Vallisneria aquatica and Vesicularia fonttonalis are also unrecognized names of species recorded as imported into the Netherlands. Confusion of species and mislabelling Salvinia molesta and some other Salvinia spp. were not recorded in the list of imported plants but it is likely that they have been introduced under the name Salvinia natans. Ludwigia rosefolia is mentioned as imported from Singapore, but this may have been due to a confusion with Alternanthera reineckii cv. ‘Roseafolia’. The plant described as Nelumbo Lu Shan Bai Lian may be Nelumbo nucifera cv. ‘Baiwanlian’. Hydrocotyle ranunculoides is also suspected to be traded under the name H. leucocephala (E. Branquart, pers. comm., 2009). Many consignments labelled as Cabomba aquatica actually consisted of C. caroliniana (pers. comm. J van Valkenburg). Other information compiled In addition to integrating recognized names of imported aquatic plants with the quantities imported and the places of origin, the following information was gathered and added to the table: (1) Plant family. The plant family has been retrieved from the EPPO Plant Protection Thesaurus (EPPT) available at http://eppt.eppo.org/. (2) Intended plant use: ‘A’ means that the species is used in aquarium, ‘O’ means that the plant is used outdoors, as a garden plant (e.g. in ponds), and ‘I’ means that the plant is used indoors as a house plant. All the species have been checked against the aquarists collaborative database ‘Aquabase’ (Aquabase Website, 2009; http:// www.aquabase.org/). This website indicates whether the species is used in aquaria. The species have also been checked against the A-Z Encyclopedia of Garden Plants (Brickell, 1996), providing information on the use of plants outdoors and indoors. When plants were not recorded in these two sources of information, internet searches were used to gather information on their use. The use of plants is quite variable, and these categories provide indicative information only, and it is assumed that many plants that are only recorded for aquarium use could also be used in ponds and gardens. For instance, Crassula helmsii was not reported as being used outdoors while experience shows that it is (EPPO, 2007a). (3) Status of the species. ‘N’ means the species is native in the EPPO region, ‘E’ that it is exotic. (4) Area of origin of the taxon. This information is indicative and has been assembled from the database ‘Aquabase’, as well as from the Germplasm Resources Information Network (GRIN). This information is ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 Whole year 2007 October till November 2006 February till May 2007 Turkey – Izmir Switzerland – Zurich Airport Israel ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 *ISO country codes: ID, Indonesia; IL, Israel; GN, Guinea; ES, Spain, MA, Morocco; MG, Madagascar; MY, Malaysia; SG, Singapore; TH, Thailand. Plant names were only indicated on 14 PCs, and quantities of plants imported from TH were inconsistently indicated The data from the Canary Isles was not interpreted 2 PCs in June, only Anubias spp. 2 GN (Only Anubias spp.) 9 PCs SG 2 from Canary Isles (ES) were not included in the analysis Imports were from the European Union: Information was provided at the genus level Netherlands in majority, Italy and the and was not integrated United Kingdom TH SG 14 SG, 1 GN SG 19 TH, 18 ID, 4 SG, 1 MG, 1 IL 2 ID, 5 MY, 19 SG, 9 TH, 1 Canary Isles (ES) 5 MA, 26 SG, 2 TH ⁄ 33 PCs Exporting countries were not mentioned, as requested by importers. Latvia – Riga Airport January 2005 till April 2007 7 PCs Estonia – Tallinn Airport March 2006 till September 2007 15 PCs, 7 in 2006, 8 in 2007: Czech Republic – Prague Airport May till July 2007 15 PCs Germany – Berlin Flughafen Tegel January till October 2007 ⁄ Hungary – Budapest Airport Whole year 2006 43 PCs Austria – Vienna Airport Whole year 2006 36 PCs April 2006 Whole year 2006 France – Orly Airport Netherlands Period Country Table 1 Information on imported aquatic plants in the countries under study Number of consignments Origins of consignments* Remarks Other airports in Germany did not provide information Pathway analysis for aquatic plants 203 sometimes difficult to trace, as the native area of some plants may be controversial. For instance, Hydrilla verticillata is thought to originate from Asia and Northern Australia, but has been sometimes considered as native in some European countries, such as Poland (Mirek et al., 2002). (5) Presence or absence in the EPPO region. This information has been taken from the EPPO (EPPO PQR, 2007, Version 4.6) and DAISIE databases (DAISIE, 2009). When the species occurs in the EPPO region, countries are indicated with their ISO codes. When the species is widespread, there is no detail of the countries. (6) Invasiveness. Each species has been checked against the Global Compendium of Weeds (GCW) (Randall, 2002), to indicate their invasive behaviour elsewhere in the world. The Global Compendium of Weeds is a list of plant species (over 28 000 names) that have been cited in specific references (approximately 1000) as weeds. An expert has assessed the status of the weed based on its context in each document. The legend for abbreviation of statuses is as follows: W, weed; NW, noxious weed; QW: quarantine weed; SW: sleeper weed; AW, agricultural weed; EW, environmental weed; abs, not quoted in the GCW; ‘ ⁄ ’ no sign of invasiveness. (7) Information on the distribution and invasiveness of species has also been checked against various databases, the main ones being: (a) The ‘Global Biodiversity Information Facility’ (GBIF) portal for worldwide distribution. (b) The ‘United States Department of Agriculture Plants Database on Invasive and Noxious Weeds’. (c) ‘Pacific Islands Ecosystems at Risk’ (PIER). For some species, Risk Assessments have been performed following the Australian Weed Risk Assessment (WRA) system (Pheloung, 2005). For each plant assessed, the WRA system generates a score, assisting policy-makers to determine if a plant can be imported. If the score is higher than 6, the plant is rejected. If the score is lower than 1, the plant is accepted, and in between these 2 thresholds, the plant is placed on a list entitled ‘unable to complete assessment’. For the species quoted in this study for which a WRA has been conducted, the result of the assessment is indicated. (d) ‘Weed Australia’, providing information on Noxious Weed Lists of Australia (Weed Australia, 2009). Limitations of the study This study provides accurate information on the import of aquatic plants in some entry points in the EPPO countries, but the following limitations are to be noted. (1) The periods of import for which the Phytosanitary Certificates have been provided vary for the different countries, which do not allow a simple comparison from country to country. Data provided may not be representative of the whole country (e.g. data was provided from only one airport in Germany). Some phytosanitary certificates were illegible Use E E A, O E A, O A, O E E A, O A E E A, O A, O E A, O Trop. S-Am. N-Am. S-Af. N-Am. Australasia S-Am. W, NW, SW, AW, EW 28150 19030 W, AW, EW W, SW, NW, AW, EW 51 W, QW, NW, EW, CE 425 W, SW, AW, EW 4590 75 10912 50 W, NW, AW, EW W, SW, AW, EW 52 203 238568 884 11 14 2 28 100 28 1 W, NW, EW W, QW, NW, SW, EW 422 W, NW, AW, EW W, AW, EW 17 ID FR 1691135 2548 1310 BE, Corse, W, NW, AW, EW 10860 FR, DE, GB, IE, IT, PT Canary Isles W, SW, NW, AW, EW 601 Widespread IE, LV, LT, PL, RU BE, CH, FR, DE, IT, IE, GB Balearic Isles BE, CH, FR IL, IT, ES, JO Total NL W, NW, SW, AW, EW 6100 Status* GCW BE, DE, DK, W, NW, EW FR, NL, GB Widespread W, QW, NW, EW Widespread (b) 6 species identified in this paper to represent a moderate to high risk Adiantum raddianum (Pteridaceae) I, O E Am. Azores, Madeira (PT), Canary Isles (ES) A, O E Australasia ES Alternanthera sessilis, A. sessilis var. rubra (= A. variegata) (Amaranthaceae) Gymnocoronis spilanthoides A E S-Am. abs (Asteraceae) A E Asia abs Hygrophila polysperma, H. polysperma cv. ‘Rosanervis’ (Acanthaceae) Limnophila sessiliflora A E Asia abs (Plantaginaceae) A, I, O E C & S-Am. abs Syngonium podophyllum, S. podophyllym cv. ‘Albolineatum’, cv. ‘White Butterfly’, cv. ‘Regina red’ (Araceae) Ludwigia grandiflora (given as L. peruensis or L. peruviana) (Oenotheraceae) Myriophyllum aquaticum (= M. proserpinacoides, M. brasiliense) (Haloragaceae) Pistia stratiotes (Araceae) Egeria densa (= Elodea densa) (Hydrocharitaceae) Eichhornia crassipes (also given as Eleocharis crassipes) (Pontederiaceae) Elodea nuttallii (Hydrocharitaceae) Hydrilla verticillata (= H. lithuanica) (Hydrocharitaceae) Lagarosiphon major (= Elodea crispa) (Hydrocharitaceae) N-Am., S-Am. Australia, New Zealand S & C-Am. Status Origin (a) 10 species currently considered to be a threat Azolla filiculoides (= A. caroliniana) A, O E (Azollaceae) Crassula helmsii (Crassulaceae) A, O E Species Distribution EPPO Table 2 Aggregated list of aquatic plants imported in 10 EPPO countries TH SG 50 160 685 1120 120 125 2600 5 170 450 10 650 875 7200 20610 210 26900 MA SG CZ GN 350 5200 500 105 135 20 20 120 100 2 2 1800 70 200 100 CH AU TR EE LV 110 500 5 20 150 x 750 x 2200 1582 6100 Total 250 783 4889 75 3608 10908 29420 24723 10 10 274 11812 15 250 243437 20 50 5 20 51 9891 100 200 1878098 ID SG MG IS SG ID MY TH GN SG TH 122500 11000 545 150 TH DE (Berlin) HU 204 S. Brunel ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 E A, I ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 Australasia Australasia A A Asia N-Am. C & N-Am. A E A, O E A, O E W, EW W, AW, EW Status* GCW IT, PT BE, DE, FR, IT IT ES, FR, GB, IE, IT, NL abs IT abs abs abs 310 635 860 120 Total NL 9576 90 162 6 1 9 31 44 ID FR W, NW, AW, EW 20125 114 W, AW W, NW, EW W, NW, AW, EW W, AW, EW W, NW, AW, EW 10 W, EW W, QW, EW W, SW ES (incl. W, AW, EW Canary Isles, Balearic Isles) GR, IT, PT (incl, Azores, Madcira), FR (corse) IT (Sicilia), W, AW PT (Madeira) abs W, AW Azores, Madeira abs Distribution EPPO 80 80 70 840 10 500 50 50 1800 150 TH SG 180 10 20 250 70 100 MA SG CZ 80 GN 25 ID 2 134 35 50 2300 20 TH DE (Berlin) HU TR EE LV 50 30 50 160 x 10 569 150 833 1800 70 50 3524 120 Total 10 21704 10138 230 150 100 101 10 40 SG MG IS SG ID MY TH GN SG TH CH AU Use: ‘‘A’’ aquarium; ‘‘O’’ outdoors in gardens, ‘‘I’’ indoors as house plants. Situation in EPPO: ‘‘E’’ exotic to the EPPO region ; ‘‘N’’ native to the EPPO region. Origin: ‘‘Am.’’: Americas; ‘‘C-Am’’: Central America; ‘‘N-Am.’’: North-America; ‘‘S-Am.’’: South-America; ‘‘Af’’: Africa; ‘‘S-Af’’: South Africa; ‘‘Trop.’’: tropical; Abs: species is absent. Distribution EPPO: when the species occurs in the EPPO region, countries are indicated with their ISO codes. When the species is widespread, there is no further detail. GCW status: W: weed; QW: quarantine weed; NW: noxious weed; SW: sleeper weed; AW: agricultural weed; EW: environmental weed; abs: not quoted in the GCW; ‘‘ ⁄ ’’: no sign of invasiveness. Importing and exporting countries are indicated with their ISO country codes. ISO codes: AU: Austria; BE: Belgium; CH: Switzerland; CZ: Czech Republic; DE: Germany; DK: Denmark; EE: Estonia; ES: Spain; FR: France; GB: Great Britain; GR: Greece; HU: Hungary; ID: Indonesia; IE: Ireland; IL: Israel; IT: Italy; JO: Jordan; GN: Guinea; ES: Spain, LT: Lithuania; LV: Latvia; MA: Morocco; MG: Madagascar; MY: Malaysia; NL: the Netherlands; PT: Portugal; RO: Romania; RU: Russia; SG: Singapore; TH: Thailand; TR: Turkey. A complete table of all 247 species in this study is available on the EPPO website www.eppo.org Species: species in bold are listed as invasive or potentially invasive in the EPPO region; Am. A, O E E E Am. N & C-Am. A, O E E A N-Am. S-Am. E A Echinodorus berteroi (Alismataceae) Echinodorus cordifolius, E. cordifolius cv. ‘Marble Queen’ (= E. radicans) (Alismataceae) Hydrocleys nymphoides (Limnocharitaceae) Hygrophila costata (= H. lacustris) (Acanthaceae) Marsilea crenata (Marsileaceae) Ottelia alismoides (Hydrocharitaceae) Pontederia cordata (= Hydrocharis dubia) (Pontederiaceae) Rotala indica (Lythraceae) Saururus cernuus (Saururaceae) Sagittaria lancifolia (= S. platyphylla hort.) (Alismataceae) Af. trop. Asia, Sri Lanka Africa S-Af. A, O E A, O E A, O E E Status Origin I, O Use Cyperus papyrus (Cyperaceae) (c) species for further monitoring Chlorophytum comosum (= C. capense) (Anthericaceae) Cryptocoryne beckettii (Araceae) Cyperus alternifolius (Cyperaceae) Species Table 2 Continued Pathway analysis for aquatic plants 205 206 S. Brunel Table 3 Total numbers of imported aquatic plants for the countries which contributed to the study, for the periods for which data was provided. The data have been extrapolated linearily for the periods for which the data were provided to a whole year (e.g. France provided data for April 2006 (1 month), the sum of species have therefore been multiplied by 12). Extrapolated data are rounded up to 100 Country Period Total number of aquatic plants imported Rough extrapolation of plants imported for 1 year Netherlands France Czech Republic Germany Hungary Switzerland Austria Turkey Latvia Estonia Whole year 2006 April 2007 May–June 2007 January–October 2007 Whole year 2006 October–November 2006 Whole year 2006 Whole year 2007 January 2005–April 2007 March 2006–September 2007 4 799 292 98 966 185 015 266 440 140 936 4926 23 620 19 600 5360 2528 4 799 292 1 187 600 740 000 319 700 140 936 29 600 23 620 19 600 2300 2200 because of the poor quality of the document(s), or lists of plant names were not provided. (2) Major importing countries such as Italy, Spain, the United Kingdom, etc. could not contribute to this study. (3) Data on the use of the species (for aquarium, for outdoors or indoors), the origin of the species and the occurrence in EPPO countries should also be taken with caution. (4) Only imported species are captured in this analysis, while many aquatic species are produced directly within the EPPO countries and may be invasive. As an illustration, a Dutch producer has Eichhornia crassipes and Pistia stratiotes in its catalogue (Moering, 2009). Table 4 Total number of aquatic plants exported from the countries which contributed to the study, for the periods for which data was provided. The data have been extrapolated in the same way as for Table 3 Exporting country Number of aquatic plants exported for different periods Rough extrapolation of aquatic plants imported for one year Singapore Indonesia Thailand Guinea Morocco Madagascar Israel Total 261 260 48 787 125 829 22 600 7925 3500 1350 484 571 1 550 800 256 100 191 524 31 600 95 100 3500 1350 2 129 974 Results The study contains 279 entries, of which 32 correspond to information at the genus level, and 247 to imported species. Those at species level have been fully analysed. Importers and exporters Importers From the data obtained, the Netherlands is the major importer, followed by France, the Czech Republic and Germany. Amounts of plants traded have been extrapolated to a whole year in order to allow a rough comparison in between countries in Table 3. Trade within the EPPO region was noted, other than for Morocco, but has not been included in Table 3: (1) Switzerland imported aquatic plants from Canarias (ES). (2) Israel imported aquatic plants mainly from the Netherlands, but also from Italy and the United Kingdom. Major exporters The Netherlands and Germany could only provide aggregated figures without mentioning the countries of export for confidentiality reasons. The other countries were mainly importing aquatic plants from countries outside the EPPO region originating from, by order of extrapolated volume: Singapore, Indonesia, Thailand, Malaysia, Guinea and Madagascar. EPPO countries which are not part of the European Union such as Morocco and Israel are also exporters. Table 4 shows the number of aquatic plants traded by exporting countries. Some exporting countries appear to be specialized in some plant genera: (1) Israel only exports Nymphaea spp. (2) Guinea only exports Anubias spp. and Crinum spp., which are native plants from this area. (3) Madagascar only exports Aponogeton spp., which are native plants from this area. Characteristics of imported aquatic species End use of the plants Among the 247 species for which an end use could be determined (eliminating information provided at the genus level), about 65 % of the imported plants are used in aquaria exclusively, which represents the major end use of these imported aquatic plants. Results are shown in Table 5. ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 Pathway analysis for aquatic plants Table 5 Number of plant species imported according to their end use 207 Table 6 Number of species per family imported (including data provided at the genus level) Use of the plant Number Aquarium Aquarium and outdoors Aquarium and indoors Aquarium, indoors, outdoors Outdoors Outdoors and indoors Indoors Total 163 45 9 1 12 4 13 247 Most imported species Egeria densa (EPPO List of Invasive Alien Plants, 1 878 098 plants imported) and Cabomba aquatica (the main component of this actually consisting of C. caroliniana, J van Valkenburg, pers. comm.) (1 344 915 plants imported) were by far the most imported aquatic plants for aquarium use, and were mainly imported in the Netherlands, although other countries (in order of importance) such as France, Germany, Czech Republic, Hungary, Austria, Latvia, Switzerland and Estonia also imported these species. The other most imported species were Cabomba caroliniana (514 450 plants imported), Hygrophila polysperma (243 437 plants imported), Vallisneria spiralis (145 036 plants imported), Echinodorus bleheri (135 234 plants imported), Vallisneria americana (88 367 plants imported), Najas marina (84 000 plants imported), Hygrophila difformis (66 302 plants imported) and Anubias barteri (48 610 plants imported). Similarly, the largest importer of the above plants was the Netherlands. All of these species, except E. densa and H. difformis, are exclusively used for aquarium purposes. This confirms that the predominance of plants imported for aquarium use does not only concern the number of species, but also their volume. Plant families The greatest number of species imported was from the families Araceae, Alismataceae, Hydrocharitaceae, Acanthaceae and Lytraceae, as shown in Table 6. Origin of plant species On the 240 species for which an origin could be determined, only 17 ( 7%) originate from Europe, highlighting the consumer preference for exotic plants. It is difficult to determine the percentages of origins of the species since some plants originate from a relatively small geographical area (e.g. Cryptocoryne hudoroi originates from Borneo), whereas others have a native distribution which covers several continents (e.g. Bacopa monnieri is pantropical). In general, these species originate from tropical areas, for use in tropical aquaria. While the production of the vast majority of these imported species occurs in Asia (e.g. Singapore, Indonesia), it appears that the origins of these species are diverse: approximately 30% of the species are native to Asia, 30% from the Americas, and 10% from Africa (including Madagascar). This raises questions about the genotypes used in production. ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 Families Number of species Araceae Alismataceae Hydrocharitaceae Acanthaceae Lythraceae Aponogetonaceae Haloragaceae Oenotheraceae Nymphaeaceae Plantaginaceae Scrophulariaceae Cyperaceae Pontederiaceae Apiaceae Asparagaceae Potamogetonaceae Amaranthaceae Cabombaceae Dracaenaceae Pteridaceae Others 41 22 18 13 13 10 10 10 9 9 8 7 7 5 5 5 4 4 4 4 72 Pathway analysis: imported species that represent a phytosanitary risk By combining information on the behaviour of a species where it occurs, its distribution, and its records of invasiveness, it is possible to obtain a subjective indication of the future behaviour of a species. Such rapid assessment has to be taken with care and carries a lot of uncertainties, and only gives suggestions of species that could deserve further attention. Species traded and already naturalized: current invaders The most effective criteria to predict the potential invasiveness of a species is to consider its behaviour in other areas of the world, especially those with the same climatic conditions (Reichard, 2001). In this respect, information has been aggregated in Table 2 from the Global Compendium of Weeds (GCW), providing some clues about the behaviour of species. The species have been ordered according to the risk they might represent, on the basis of the information gathered. It should be noted, that the EPPO Decision-support scheme for quarantine pest remains the dedicated tool to evaluate the risk that a species may represent. High risk species Among naturalized species, 10 are already considered invasive or potentially invasive within the EPPO region: Azolla filiculoides (List of Invasive Alien Plants (IAP)), Crassula helmsii (A2 list), Egeria densa (List of IAP), Eichhornia crassipes (A2 list), Elodea nuttalli (List of IAP), Hydrilla verticillata (Alert List), Lagarosiphon major (List of IAP), Ludwigia grandiflora (List of 208 S. Brunel IAP), Myriophyllum aquaticum (List of IAP) and Pistia stratiotes (Alert List). Datasheets for these species are available on the EPPO website. Cabomba caroliniana has been subject to a Pest Risk Assessment which could not conclude as to whether the species qualifies as a quarantine pest because it only had invasive behaviour in one situation in the Netherlands, while it also escaped in Belgium, France and Hungary where it did not spread (EPPO, 2007b). EPPO suggests that good practices should be set out for this plant (not to be used outdoors, not to be dumped in nature with aquarium wastes, etc.) rather than restriction of trade. Medium risk species Alternanthera sessilis (Amaranthaceae) is used as an aquarium and outdoor plant. The amount of plants imported into the EPPO region is moderate (4 889 plants imported, mainly in the Netherlands). It is only naturalized in Spain so far. The species originates from Asia and Australia, and has extended its range to Southern USA, Central America and the North of South America, as well as to Africa (GBIF, 2009, Global Invasive Species Database, 2009). Alternanthera sessilis is reported by the Global Invasive Species Database (2009) to be a weed of sugarcane, rice, and is associated with banana, cereal crops and disturbed wet areas in tropical and subtropical climates. It appears to have only a low environmental impact. Considering the distribution of this species and the crops impacted, Macaronesia and the Mediterranean Basin would be the area the most at risk in the EPPO region. Adiantum raddianum (Pteridaceae) is a fern which is used indoors and outdoors and was only recorded as imported in the Netherlands in small quantities (75 plants). Its worldwide distribution is mainly restricted to the Americas, where it originates (Global Biodiversity Information Faclity portal, 2009). In the EPPO region, the species is considered invasive in Azores and Madeira (PT), and is naturalized in Canary Isles (ES). It is among the top 25 of the most invasive species in Macaronesia where it competes with native species in specific habitats such as rocky shores, coastal water-falls, cliffs, etc. (Silva et al., 2008). It is also considered an environmental concern in the Pacific Islands (PIER, 2009). Low to medium risk species Some other species might usefully be monitored, although they are considered to pose a moderate risk: Cyperus alternifolius (Cyperaceae) is used outdoors, but trade is minimal (50 plants imported in Hungary). It originates from Western tropical Africa and is present in Southern USA (considered invasive in Florida), New Zealand and Pacific Islands. The species is already naturalized in some countries of the Mediterranean Basin: Italy, Spain (including Canary Isles and Balearic Isles), Greece, Portugal (including Azores, Madeira) and Corsica (FR). In Spain, the species is described as invasive by Sanz-Elorza et al. (2005). PIER (2009) performed a Risk Assessment concluding that the risk posed by this species is high (with a score of 17). In addition, the other traded species Cyperus papyrus is considered a minor weed of rice (Soerjani et al., 1987). Sagittaria lancifolia (Alismataceae) originates from Central and South America. It is imported in moderate quantities (21 704 plants imported mainly in the Netherlands) to be used in aquaria and outdoors. The species is a regulated noxious weed in Australia and in New Zealand where it is reported to restrict water flow and to aggravate flooding, as well as to displace native plants in wetlands (Global Invasive Species Database, 2009). Within the EPPO region, it is only naturalized in Italy, where recent information suggests invasive behaviour. Low risk species Chlorophytum comosum (Anthericaceae) is used as a garden plant as well as a house plant, but is only traded in very low amounts (120 plants imported in the Netherlands). It originates from South Africa and is naturalized in Italy, Azores and Madeira (PT). Worldwide, it is present in Australia, in the USA (only in Florida and Georgia), as well as in Africa and Central and South America. This species has been the object of a Risk Assessment by Pacific Islands Ecosystems at Risk (PIER) (2009) which considers the risk as high (with a score of 8). The University of Florida (Cooperative Extension service, 1999) evaluated this species as a very aggressive and quickly spreading plant. In Europe, however, this species has for many years been a very popular house plant, and may also be grown outdoors in the south. It is available for sale, but is so easily propagated that it is just passed between friends and neighbours. It has not become invasive and there can only be a low risk that it should in the future (I. Smith, pers. comm., 2009). Ottelia alismoides (Hydrocharitaceae) originates from Australasia, and even if only traded in very small quantities and used for aquarium purposes (10 plants imported in the Netherlands), it has naturalized in Italy since 1952 (Piacco, 1952) but is not considered invasive there (G. Galasso, pers. comm., 2009). The species is present in Southern USA (California, Louisiana, Missouri and Texas, and has recently been found in Florida), and it is registered on the Federal List of Noxious Species as well as on the State Noxious Weed List in several States (Alabama, California, Massachusetts, North Carolina, Oregon, South Carolina, Vermont) (USDA Plants Database on Invasive and Noxious Weeds, 2009; Centre for Aquatic and Invasive Plants, 2009). Nevertheless, where introduced to rice fields and agricultural irrigation ditches outside of the United States, O. alismoides is only considered to be a minor weed (Cook, 1996). Pontederia cordata (Pontederiaceae) is native to the Americas and is used in aquaria and outdoors, but is only imported in small quantities (150 plants imported in France and Hungary). It is naturalized in European countries having different climates: France, Ireland, Italy, the Netherlands, Spain and the United Kingdom. So far, the species did not exhibit an invasive behaviour in these countries, but it is prohibited in South Africa as it was regarded as a potential invader (Henderson & Cilliers, 2002). Rotala indica (Lythraceae) originates from Asia and 10 000 plants were imported for aquarium use in 2007, mainly in the Netherlands and in France. The species is recorded as naturalized in Portugal and Italy. It has a very limited distribution worldwide, and is prohibited of entry from Northern Territory in Australia (tropical area), but is only considered a minor weed of rice in Indonesia (Soerjani et al., 1987). ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 Pathway analysis for aquatic plants Saururus cernuus (Saururaceae) is a North-American species which is only used in aquarium and gardens. It is traded in low volumes (230 species imported from Hungary, the Netherlands and France). The species naturalized in Belgium, France, Germany and Italy. Although the species has been present in Italy since 1953 (Stucchi, 1953), it is not considered invasive there (G. Galasso, pers. comm., 2009). In France, this species is considered as potentially invasive by the Conservatoire Botanique de Brest (Lacroix et al., 2008) and has been mechanically removed from Maine et Loire (North-Western France) (Delaunay, 2004). Swatek et al. (2004) also described a small population as naturalized in Germany in 2004. Very low risk to no risk species Although the GCW reports an invasive behaviour for many of these species, the majority of them have naturalized in the EPPO region without being reported as being a threat, or only rarely and in a few specific situations. This is the case for Bacopa monnieri, Blyxa japonica, Ceratopteris thalictroides, Eriocaulon sieboldianum, Hydrocotyle sibthorpioides, Hydrocotyle verticillata, Nelumbo nuciphera, Nymphaea lotus and Sagittaria subulata. Acorus calamus has been introduced during the middle ages, and did not exhibit any invasive potential. Acorus gramineus, Iris japonicus and Nuphar japonica are naturalized in the EPPO region and are not considered to represent a risk. Species traded but not naturalized: future invaders One hundred seventy (170) species which were imported are not recorded to have naturalized in the EPPO region. These species may represent a threat in the future. After reviewing the literature for each of these species, it appears that only a few of them may become invasive. Some of them have been the object of a risk assessment which considers that these plants do not represent a risk by Pacific Islands Ecosystems at Risk (PIER) (2009), as it is the case for Codiaeum variegatum (Euphorbiaceae) and Hemigraphis alternata (Acanthaceae) (scores of -4 and -1 respectively). Eichhornia azurea (Pontederiaceae) has also been the object of an EPPO PRA. Although this plant is listed as a noxious weed in North America and has been recorded as a weed of rice in French Guiana (CIRAD, 2009), impacts are not significant, and the EPPO pest risk analysis concluded that the species does not qualify as a quarantine pest (see ISPM no. 5 in IPPC 2007 for definitions). The potential future invaders are listed below according to the risk they might represent, on the basis of the information gathered. Medium to High risk species Hygrophila polysperma (Acanthaceae) originates from Asia. It is imported for aquarium purposes in large quantities (243 000 plants imported into various countries such as the Netherlands, France, Hungary, Switzerland, Austria, Estonia and Latvia). Outside its native range, the species is only reported as naturalized in the USA. There, it is only present in Texas, Florida and Virginia, but is listed on the Federal Noxious Weed List, as well as in ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 209 several State Noxious Weed Lists (in Alabama, California, Florida, Massachusetts, North Carolina, Oregon, South Carolina and Vermont). The species was the object of a risk assessment by Pacific Islands Ecosystems at Risk (PIER) (2009) which considers that the risk posed by this plant is very high (score of 20). The Global Invasive Species Database (2009) reports that the plant is a fast-growing and spreading invasive that can shade out other submersed plants, clog irrigation and flood-control canals, and interferes with navigation of the waters it invades. It is even able to compete with the very invasive Hydrilla verticillata (Hydrocharitaceae). Considering the current distribution of this species, the area at risk would be the Mediterranean Basin and Macaronesia. Limnophila sessiliflora (Plantaginaceae) originates from Asia and is imported for aquaria in moderate amounts (11 800 plants from the Netherlands, France, Hungary and Estonia). It has only been recorded in thermal waters in Hungary (Lukács et al., 2008). As for Hygrophila polysperma (Acanthaceae), the species is only present in the USA outside its native range and is listed in both the Federal Noxious Weed List and in State Noxious Weed lists (in Alabama, California, Florida, Massachusetts, North Carolina, Oregon, South Carolina and Vermont). Global Invasive Species Database (2009) states that L. sessiliflora is fast-growing and able to shade out and to out-compete totally submersed species. This species also clogs irrigation and flood-control canals, and is a major weed problem in paddy rice fields of India, China, Japan and the Philippines. The areas which appears the most at risk are Macaronesia and the Mediterranean Basin. Syngonium podophyllum (Araceae) originates from Central and South America and is used outdoors, indoors, and in aquaria. Currently it is imported in very small quantities in the studied countries (274 plants in France, the Netherlands, Hungary and Estonia). The species is present in Australia and in Florida (USA), and has been listed as an invasive species by the Florida Exotic Pest Plant Council (FLEPPC, 2003), where it created thick ground cover which was largely impenetrable to other plants, and its extensive root system rendered the plant extremely difficult to remove (Morgan et al., Undated). The species was subject to a risk assessment by Pacific Islands Ecosystems at Risk (PIER) (2009) which considers that the risk posed by this plant is high (score of 15). Macaronesia and the Mediterranean Basin are considered to be the areas most at risk. Gymnocoronis spilanthoides (Asteraceae) originates from South America and is introduced through aquarium trade in small quantities (783 plants imported in the Netherlands, France, Hungary, Austria and Estonia). It is considered invasive in all areas where it has been introduced: Australia, New Zealand and India. The Global Invasive Species Database (2009) reports that this species grows very quickly, and is known to rapidly cover water bodies with a floating mat, excluding other plants and the animals that rely on them. The effects of flooding are exacerbated because infestations block drainage channels. Recreational activities, irrigation and navigation may also be affected. Water quality may decline if large amounts of G. spilanthoides die off and rot under water. The species was the object of a risk assessment by Pacific Islands Ecosystems at Risk (PIER) (2009) which concluded that the species represents a high risk (score of 8). 210 S. Brunel Low risk species Hydrocleys nymphoides (Limnocharitaceae) is imported in low quantities (150 plants in France) for outdoors and aquaria uses. It is native to South America and is considered invasive in New Zealand. Although present in Australia, it is not officially listed as a noxious weed. Hygrophila costata (Acanthaceae) originates from the Americas and is used in aquarium and planted outdoors, but the amounts of imported plants remain small (569 plants in the Netherlands and in France). It has only been introduced in Australia, where it is considered a noxious weed (in New South Wales and Queensland) (New South Wales Department of Industries, 2009). Cryptocoryne beckettii (Araceae) is listed as potentially invasive in Texas (USDA Plants Database on Invasive and Noxious Weeds, 2009). Blyxa aubertii (Hydrocharitaceae) may occur in rice fields, but is not considered to be a serious weed (Aquarium and Pond Plants of the World, 2009). Echinodorus berteroi, Echinodorus cordifolius (Alismataceae) and Marsilea crenata (Marsileaceae) have also been considered as minor weeds in rice (respectively Di Tomasso and Healy, 2003; Aquarium and Pond Plants of the World, 2009; Soerjani et al., 1987). Characteristics of invasive and potentially invasive alien species This study highlights that only a few species imported as aquatic plants represent a risk. Indeed, about 90% of the species traded do not represent a risk. Species currently considered invasive or potentially invasive It can be noted that the major invasive alien plants have already been identified as invasive by EPPO (see A1 and A2 Lists, the List of Invasive Alien Plants, and the Alert List). Crassula helmsii and Eichhornia crassipes have been the object of a Pest Risk Analysis and are recommended for regulation to the 50 EPPO member countries. Hydrilla verticillata and Pistia stratiotes are currently on the EPPO Alert list. The other species are included on the EPPO list of Invasive Alien Plants for which EPPO strongly recommends countries endangered by these species to take measures to prevent their introduction and spread, or to manage unwanted populations. Although these 10 species are having or could have in the future huge detrimental effects on agriculture, the environment and economies, this study shows that many of them are still traded in huge quantities for ornamental purposes. All species which might represent a risk are all traded for outdoor use – except Hydrilla verticillata which is used in aquaria and is considered potentially invasive. In fact, a species used outdoors is assumed to survive climatic conditions occurring in the EPPO region. Using a species outdoors increases its establishment probability as well as its transfer to unintended habitats (the probability of a species escaping from a garden is higher than from an aquarium). This characteristic therefore appears important in determining the success of invasion of a traded aquatic species. Except for E. nuttalli and H. verticillata, all these invasive species are imported in significant amounts, factor which is recognized to increase the introduction pressure and the probability of establishment and spread (Mulvaney, 2003). Hydrilla verticillata has expressed invasive behaviour in many places where it has been introduced (the USA, New Zealand, parts of Australia where it is alien, etc.), but not yet in Europe although it is naturalized in Ireland, Latvia, Lithuania, Poland and Russia (see EPPO Alert List). Only 51 individuals of these species have been reported as imported in the Netherlands in 2007, and the reason why it has not expressed an invasive behaviour in Europe so far might be that it is quite new in trade in the EPPO region. For the majority of these species, the Netherlands is the major importer. Table 2 shows that E. crassipes is mainly imported in Czech Republic. The reason why the plant is not imported in large quantities into the Netherlands is because the plant is directly produced there, as production is more profitable than import. Pistia stratiotes also appears to be mainly imported in France, and for this plant as well, producers in the Netherlands find it more profitable to produce the plant themselves (see Moering, 2009). A few invasive or potentially invasive aquatic species such as H. ranunculoides (A2 List), Althernanthera philoxeroides (Alert List) or Salvinia molesta have not been captured as imported in the available data. This might be because such species are already produced within EPPO countries. Such production has been reported in the Netherlands for Eichhornia crassipes and Pistia stratiotes. Species that could present a risk in the future Among the 247 species for which import data has been provided, only 6 have been identified as representing a moderate-to-high risk for the EPPO region in the future: Alternanthera sessilis, Adiantum raddianum, Gymnocoronis spilanthoides, Hygrophila polysperma, Limnophila sessiliflora and Syngonium podophyllum. All these species – except A. sessilis and A. raddianum which can be planted outdoors – are for aquarium use, which lowers their chances of naturalization. This is particularly true for H. polysperma which is not known as naturalized in the EPPO region, although traded in huge quantities. This reduces the risk of these species becoming invasive. Further investigations should be carried out to determine whether they effectively represent a risk, and which measures should be implemented to prevent risks of invasion. Other impacts Eleocharis parvula, indigenous in Europe and in North America, is recorded as imported from Singapore. This plant is rare and is becoming extinct in Europe. In France, it was declared extinct during the last 20 years but has recently been rediscovered in the wild. This raises the question of the origin of this species found in the wild, and there might be a genetic pollution of the species with the traded taxon (J.M. Tison, pers. comm., 2007). The species not being indigenous in Asia, it would be interesting to know the origin of the plant which was used to initiate the production (coming from Europe or from North America) and how it was multiplied. ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 Pathway analysis for aquatic plants Conclusions This analysis on imported aquatic plants in some EPPO countries highlights that this pathway mainly consists of tropical plants for use in aquaria. Nevertheless, among the few plants used outdoors, 9 out of 51 (about 17%) are invasive or potentially invasive. Only Hydrilla verticillata regarded as potentially invasive, is used for aquarium purposes. Of the 247 species imported, only 10 are currently considered to be a threat, representing 4.2% of the total number of species imported. These 10 invasive or potentially invasive species continue to be traded in huge quantities although they are recommended for regulation by EPPO (Crassula helmsii, Eichhornia crassipes) or countries are encouraged to take action to prevent their entry and spread (Azola filiculoides, Egeria densa, Elodea nuttalli, Lagarosiphon major, Ludwigia grandiflora and Myriophyllum aquaticum). A few additional species considered to represent a lower threat could become invasive, although these assumptions have to be taken with great care: Alternanthera sessilis, Adiantum raddianum, Gymnocoronis spilanthoides, Hygrophila polysperma, Limnophila sessiliflora and Syngonium podophyllum. These species should deserve further attention in the future to determine whether they really represent a risk, and which measures, if any, should be recommended. Other species should be monitored to ensure they do not threaten managed and unmanaged ecosystems: Chlorophytum comosum, Cyperus alternifolius, Cyperus papyrus, Pontederia cordata, Rotala indica, Syngonium podophyllum, Hydrocleys nymphoides, Hygrophila costata, Ottelia alismoides, Sagittaria lancifolia and Saururus cernuus. As these species often originate from tropical areas, the Mediterranean Basin and Macaronesia are the areas of the EPPO region which have the most similar climatic conditions, and are therefore assessed to be the most at risk. Another major finding is that the vast majority (approximately 90%) of the species imported as aquatic plants are not considered to represent a risk. For species which have massive detrimental effects, such as Eichhornia crassipes, for which management costs reached 14 680 000 EUR for a 3 year period (2005–2008) in the Guadiana river to manage the plant along 75 km of river (Cifuentes et al., 2007), and could establish in the whole Mediterranean Basin (EPPO, 2008), regulation appears to be the most appropriate option, after a Pest Risk Analysis is performed and approved by countries. For other species presenting a less immediate risk, a voluntary approach through the implementation of a Code of conduct on horticulture and invasive alien plants could be adopted, as described by Heywood & Brunel (2009). Acknowledgements Mr Smith, Ms McMullen, Ms Petter, and Ms Roy, are warmly acknowledged for their comments. The Members of the EPPO Panel on Invasive Alien Species are acknowledged: Mr van Valkenburg who provided an aggregated list of plants from the ª 2009 OEPP/EPPO, Bulletin OEPP/EPPO Bulletin 39, 201–213 211 Netherlands, Mrs Garkaje provided information for Latvia, Mrs Eek for Estonia, Mr Chromy for Czech Republic, Mr Starfinger for Germany, Dr Dancsa for Hungary, Dr Follack for Austria, Mr Uludag for Turkey, Mr Buholzer for Switzerland, Mr Yacobyi for Israel. Lists of species for France where gathered thanks to Mr Gueudre from the Charles De Gaulle airport inspection services. JM Tison is also acknowledged for his help in compiling the French data. Mr Galasso provided useful data for Italy. Analyse de filière: plantes aquatiques importées dans 10 pays OEPP Les analyses de filière sont considérées par les Organisations Nationales de Protection des Végétaux comme un moyen très efficace pour considérer le risque que représentent les espèces exotiques envahissantes. Des données sur l’import de plantes aquatiques ont été obtenues de 10 pays OEPP (Allemagne, Autriche, Estonie, France, Hongrie, Lettonie, les Pays-Bas, République Tchèque, Suisse et Turquie) et ont été synthétisées pour considérer si des espèces envahissantes ou potentiellement envahissantes pourrait être introduites dans la région OEPP par cette filière. Cette étude met en évidence le fait que cette filière consiste principalement en l’introduction de plantes tropicales pour aquariums qui ne représentent pas de risque, de par leurs exigences climatiques. Quelques espèces méritent cependant une attention particulière en raison des dommages qu’elles occasionnent. En effet, sur les 247 espèces importées, seulement 10 sont actuellement considérées comme des menaces, représentant 4% du nombre total de plantes importées. Ces 10 espèces envahissantes ou potentiellement envahissantes continuent d’être importées en grandes quantités bien qu’elles soient recommandées pour réglementation par l’OEPP (Crassula helmsii, Eichhornia crassipes), que la prévention de leur entrée ou dispersion soit conseillée aux pays OEPP (Azolla filiculoides, Egeria densa, Elodea nuttalli, Lagarosiphon major, Ludwigia grandiflora and Myriophyllum aquaticum), ou qu’elles soient inscrites sur la liste d’alerte de l’OEPP (Hydrilla verticillata, Pistia stratiotes). De plus, 6 espèces ont été identifiées comme représentant un risque potentiel moyen à fort: Alternanthera sessilis, Adiantum raddianum, Gymnocoronis spilanthoides, Hygrophila polysperma, Limnophila sessiliflora and Syngonium podophyllum. Ces dernières espèces pourraient faire l’objet d’une évaluation détaillée, comme une analyse de risque, pour déterminer le risque qu’elles pourraient représenter. 212 S. 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