CropLife America Discusses EU Cut-Off Criteria
21 February 2013 
Farm Chemicals International recently asked Dr. Clare Thorp, senior director, human health policy, CropLife America (CLA), to discuss the effects of endocrine disruptor “cut-off” criteria in Europe on the crop protection industry. Look for much more on this hot-button topic in the March issue of FCI.
FCI: What specific impact do you see the cut-off criteria having on the crop input industry?
The implications of the hazard based cut-off criteria are relevant to both the crop input industry and growers alike. The EU has established a regulatory system which is out of sync with other countries, including major trading partners such as the U.S., by adopting a non-science based approach to regulation. Basing regulatory decisions on hazard-based cut-off criteria is not in line with internationally accepted OECD guidelines, or the WTO trade rules (to which the EU is a signatory).
If adopted, crop protection products which trigger the cut-off criteria and the crops produced using these compounds will be effectively barred from entering the EU, resulting in a negative impact on global commerce.
FCI: How does CropLife America recommend companies and growers prepare for the regulation?
CLA opposes the EU approach and recommends that companies and growers oppose because the approach is not science-based and will not make people any safer nor protect the environment. It will have serious implications for trade.
FCI: What do you think about the evaluation of the endocrine disruption hazard criteria? Is it too conservative?
It is important that any evaluation of an endocrine disruptor be based on sound science and therefore includes a risk assessment. It is not a question of conservatism, but a question of having an approach which reflects the real risk to people and the environment – not a perceived one.
Hazard-based criteria can prevent beneficial compounds from entering the marketplace, while failing to adequately address compounds which are genuinely of concern.
FCI: Will other countries will follow suit and adopt similar criteria?
CLA supports the approach of the U.S. EPA’s Endocrine Disruptor Screening Program. The EU cut-off criteria fail to reflect the science-based work that is being done by the U.S. EPA.
The U.S. EPA has put in place a comprehensive science-based approach to addressing endocrine disruptors, involving tests to determine whether or not there are real adverse effects in intact animals. They are also incorporating this knowledge into a risk assessment process.
FCI: Thank you, Dr. Thorp. Do you have any further insight you’d like to share?
The benefits of crop protection products are rarely articulated. We depend on these products every day to provide us with an abundant and affordable source of healthy food (fruit and vegetables, for example); to protect us against plant diseases which can be poisonous if we eat them; insect borne diseases; and to protect against invasive species which can take over an indigenous ecosystem.
Crop protection products, through science-based risk assessment, are amongst the most highly regulated, highly tested, and conservatively managed products on the market. Using a hazard-based approach for their regulation as proposed by the EU is neither appropriate nor scientifically sound. It is a crude way of managing compounds which have such a complex and comprehensive range of information available to regulators precisely for this purpose.
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