BioResources and Horticulture Groups have added their voices to growing concerns about proposed European Union (EU) changes to pesticide regulations
The registration of pesticides within the European Union (EU) is governed by directive 91/414. Apart from showing that products are effective, manufacturers must show that there is no unacceptable risk to human health, to non-target organisms and to the environment from the dose rates intended for product use. Limits to dose rates, and the total amount of an individual active ingredient that can be applied in a crop season is governed in member states by a statutory legal framework. As part of review of directive 91/414, the European Commission has proposed that registration should not only be based on risk assessment, but also whether or not products present a hazard to human health. This hazard-based approach lacks legitimacy since it takes no account of exposure levels. This major change has been promoted as a Health issue, although it is the Agriculture directorate which must implement these changes with, as yet, no input from the European Food Safety Authority (EFSA) despite the request from the European Crop Protection Association for its independent and comprehensive impact assessment. This is a clear oversight, given the fact that a key role of EFSA is to ‘provide scientific advice and technical support for the Community's legislation on issues which have an impact on food safety’.
As yet there is no clear definition of ‘hazard criteria’, but they involve effects on a number of metabolic pathways, including endocrine disruption. It has been estimated that around 20% of active ingredients will have to be withdrawn within the next three years, whilst others will be withdrawn if suitable alternatives can be found. A typical concern would be the loss of azole (DMI) fungicides which are the cornerstone of measures to control key diseases in major crops. (Interestingly, there is no suggestion that azoles be removed from medicine where many are used as front line drugs to treat human fungal infections). These proposals have already been agreed by EU agriculture ministers, but now must be approved by the European Parliament. Unfortunately, amendments tabled in the Parliament seek more stringent registration criteria which, if approved, could lead to the withdrawal of at least 30% of active ingredients and the substitution of a further 50%.1
This would make agricultural and horticultural production within the EU, inefficient, uneconomic, and uncompetitive. Failure to optimise yields inevitably leads to putting more land under the plough, with consequent negative effects on biodiversity. It has been shown that productivity always decreases with organic farming and that it is more nutrient polluting and land hungry with a similar global warming potential per tonne to conventional farming.2
The impact of this proposed legislation will be considerable throughout the EU.
Effects on yields
Commission has not undertaken any assessment of the impact these changes will have on food production within the European Union. A study funded by the UK Pesticides Safety Directorate (PSD) predicts that the Commission’s proposals will cause UK production of arable crops to fall by up to 30%, and require a further 3.29m Ha to be brought into production to make good the shortfall. Should Parliament’s amendments be approved, it would not be cost effective to grow many crops in Europe.
Managing pesticide resistance
Ensuring that valuable active ingredients are not lost or wasted because of the development of resistance is a major objective behind the way crop protection products are used. The cornerstone of anti-resistance strategies is the use of mixtures or alternations in which biologically active partners have different modes of action. By reducing the numbers of modes of actions available, the Commission’s proposals will increase the risk of resistance developing to the few remaining modes of action. As a result, control of many pests, diseases and weeds will become very difficult, and yields will decline further.
Effects on food production outside Europe
Any shortfall in European production could be made good by importing food from outside the EU, even though crops would be produced using deregistered pesticides in Europe. However, European food importers, and especially UK supermarkets, already exert considerable control over how foreign producers grow their crops. Consumers may well demand that pesticides considered too hazardous to use in Europe are not used by these foreign producers. So the impact of the Commission’s proposals could extend well outside Europe, although it is possible that foreign growers may decide to no longer produce for the European market. The Commission’s actions may well contravene World Trade Organisation (WTO) rules, and would certainly contravene the Phytosanitary Agreement, whereby countries agree not to implement measures which are likely to affect crop health in other States.
Research and development
If implemented, the Commission’s changes will present many new challenges for growers, and will require a great deal of research into alternative production strategies. If new crop protection products which meet the new registration requirements are to be found and developed, considerable investment will be needed in both agrochemical and public sector research. The Commission, and some members of the European Parliament, erroneously believe that new products can be discovered, developed and commercialised within five years. The reality is that even more than a decade is optimistic because these compounds are not in the pipeline and it is very doubtful that compounds exist that are benign for environment and human health, but target and kill the target pests accurately. Almost none of this research has started, and it will require considerable changes in direction and new resources, since research into production agriculture has been allowed to decline in many EU member states.3
We ask that MEPs think seriously about the consequences of this legislation on the health of consumers, food production, land use, food prices and sustainability and environmental biodiversity. We must always seek to safeguard our consumers and the environment based on best science (risk assessment) – there is a real chance that hazard criteria will have unintended consequences including the restriction of hazardous materials which leads to increased use of less hazardous materials which may actually present a greater risk.
BioResources Group committee
Horticulture Group committee
1 Pesticides Safety Directorate(www.pesticides.gov.uk)
2 The British Crop Production Council (www.bcpc.org/Events/FoodChainForum/index.asp) (Jim Orson 2008)
3 World Trade Organisation (www.wto.org/english/tratop_e/sps_e/spsagr_e.htm)