Risk Or Benefit?
19 December 2008 The EU directive 91 /414/EU (July 15, 1991) was intended to give guidance on the registration of plant protection products in Europe by providing a better knowledge on the properties of active ingredients present in pesticides, and, the risk assessment for human and the environment associated with the use of pesticides.
This directive included a review of all active ingredients present in the EU market, commencing in 1993 with the aim of completing by 2003. Now, the end of the review is anticipated for December 31, 2009 and, in addition to the review of old actives, new actives are also being reviewed.
New Proposal Under Debate
In 1993, 740 active ingredients were available on the EU market. On August 8, 2008, 394 of these active ingredients were no longer allowed to be included in pesticides (no annex I listing), 113 were approved for use in pesticides (annex I listed) and 233 were still under review.
In recent years, preparations have been made for a new EU regulation to supersede EU directive 91 /414/EU. The first draft regulation was transmitted by the European Commission to European Council (EC) and European Parliament (EP) on July 16, 2006. The first reading was finished on September 22, 2008, with a declaration from the European Commission on the common position of the EC. The same day, an updated draft of the proposed regulation was transmitted.
The proposed new regulation included requirements taking into account new scientific knowledge and benefiting from experiences in risk assessment. In addition, the new proposed regulation included, in contrast with 91/414/EU, (for which the decisions were based on risk assessment and risk/benefit analysis) decision criteria based on labelling and hazard to either ban active ingredients (cut-off criteria) or to classify active ingredients as candidates for substitution.
After the first reading, the cut-off criteria and the criteria for substitution are different depending on whether the proposal from the European Commission or European Parliament is taken into account. Nevertheless both agreed to exclude active ingredients classified as CMR 1&2 or Endocrine Disruptor or vPvB or PBT or POP. Debates are now taking place concerning the active ingredients M3, R3, neurotoxic or acutely toxic to bees (QH > 50).
Ban Will Hurt Farming
The English authorities (PSD) made an estimation of the impact to UK agriculture and also, to European agriculture as a result of the inclusion of some cut-off criteria. Read a detailed analysis.
Currently, the proposal from the European Commission could induce a ban of around 15% of the active ingredients found today in the EU market and, if all proposals from European Parliament are included in the final revision, almost 85% of the molecules could disappear in the next 5 to 10 years. In addition to this global percentage of banned pesticides, some minor uses will also be “unresolved.” This would have a major impact on both farmers and the wider food chain.
In summary, banning pesticides without risk analysis will artificially decrease the options available to farmers in the EU. These solutions will still be available to farmers from other countries, creating a discrepancy in worldwide competition. Also, outside of the EU, some other countries are closely following the EU rules; therefore, the banning of pesticides could occur in these countries. The impact would be huge, maybe bigger than in the EU as the agricultural practices are different, based on agriculture and food availability, independence, and the national economy.
As requested by several associations, it is crucial that an impact review of the proposed new regulation and its stringent criteria is undertaken. This evaluation should take into account a high level of protection to humans and the environment and the consequences for agriculture in all countries, the question of food independence, the impact of increased import/export transport and all other relevant parameters.
The proposed new regulation will now undergo the second reading at EU level. The final text, if an agreement is reached between the European Commission, the EC and EP is expected in the first half of 2009. Therefore, a full risk assessment of the proposed new regulation should be undertaken before any effects appear “in the field” — by which time it could be too late.
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