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URGENT: an ambitious Pesticides Directive is needed!

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Context

The EU has a regulatory pesticide package: a Regulation on the evaluation and registration of pesticides and a Directive on the use of pesticides, which has been under review for the past two years. This Directive, published in 2009, was supposed to oblige Member States to reduce their dependence on pesticides. Several evaluations, including by the European Commission itself, show that Member States have not set pesticide reduction targets as required by law. Yet the European Commission has not taken legal action against them for failure to implement. In early 2021, the European Commission is launching a public consultation on the revision of this directive. A draft leaked in February 2022 shows a lack of ambition but still sets some targets at EU level that raise the ire of some EU countries and the agrochemical industry. With the Commission's draft due to be presented on 23 March 2022 and war breaking out in Ukraine, agribusiness lobbies want to take advantage of this period of instability to scale back the meagre ambitions of the revision!

Translated with www.DeepL.com/Translator (free version)

Goals

Maintain the publication of the draft Pesticides Directive and make it more ambitious.

EU - A dozen States (mainly from the East) are particularly concerned about the method defined by the Commission for setting national pesticide reduction targets, which would not allow for the different starting points between countries. They also denounce the definition of "sensitive areas" where the use of synthetic pesticides would be banned, which they consider inappropriate and too vague. Pointing to a risk of a drop in production, they ask the executive to review its copy, in the name of food safety. This note will be discussed at the Agriculture Council on 21 March. The date of presentation of the Commission's text, scheduled for 23 March, is uncertain.

Updated on 22 March following yesterday's Council of Agriculture Ministers and the subsequent press conference. Commission postpones presentation of draft regulation on the sustainable use of pesticides

Updated on 16 June: The presentation of the proposal will be made on 22 June
consultation on the pesticides directive
Discussion in the Council on the SUD Directive
Publication of the draft Directive by the Commission (postponed sine die)
Calling on European decision-makers
Publication of the draft Directive by the Commission
Calling on European decision-makers
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What the European Commission proposes

Many NGOs, including Générations Futures, are concerned about the pressure that the agrochemical lobbies are putting on the EU and the Farm to Fork (F2F), Biodiversity and SUD Pesticides Directive strategies, taking advantage of the current instability to revise these texts downwards.

Many NGOs* including Générations Futures were already concerned in February 2022 about the lack of ambition of the proposal on the “sustainable use of plant protection products” that the European Commission plans to launch on 23 March. Given that the Sustainable Use of Pesticides (SUD) Directive has failed to reduce pesticide use in the EU, it is high time that the Commission comes forward with a proposal that will drive the transition to agro-ecological food systems that protect biodiversity and human health.

The current agricultural model, based on the intensive use of machinery, fossil fuels, synthetic fertilisers and pesticides, is now clearly showing its limits. In addition to its devastating effects on the environment and health, this model has trapped European farmers in a vicious circle of increased pesticide expenditure to compensate for declining yields, without guaranteeing an adequate income. The economic benefits of this model are one-sided and rest in the hands of a highly concentrated industry, whose profits in Europe were estimated at €900 million in 2017. In the same year, the societal costs were estimated at €2.3 billion (1).

The urgency of moving away from the use of synthetic pesticides is clear. Since the adoption of the SUD Directive in 2009, scientific evidence of the negative effects of pesticides and chemical cocktails (2) on ecosystems as a whole (3), biodiversity and human health has been mounting. Scientists warn that chemical pollution has exceeded safe limits for humanity, threatening the stability of global ecosystems. These risks are compounded when the effects of chemical pollution on biodiversity and climate change are taken into account (4).

Reducing the use of pesticides and making the transition to a healthy, sustainable and toxic-free food system based on agroecology is both possible and necessary, as many practical experiences, practices and studies demonstrate (5,6). The 2017 INRAE study shows that it is possible to significantly reduce the use of pesticides without affecting the economic (7) and productive performance of farms. Other IDDRI research shows that agroecology can feed Europeans healthily, reduce agricultural greenhouse gas emissions by 40%, help restore biodiversity and protect natural resources. (8)

Recently, 1.2 million Europeans signed the Save Bees and Farmers Citizens’ Initiative, calling for an 80% reduction in synthetic pesticides by 2030, the phasing out of synthetic pesticides in Europe by 2035 and strong support for farmers in their transition to agroecology (9). Massive investment and policy changes are urgently needed to help European farmers break free from the pesticide industry. We also recall that the European Parliament “stresses the need for these reduction targets to be binding and the importance of pursuing them through holistic, preventive and circular approaches such as organic and agroecological practices”. The principles enshrined in Article 191.2 of the Treaty on the Functioning of the EU should guide the revision of the Environment Directive.

The Commission’s draft proposal for a regulation on the sustainable use of plant protection products does not bring the necessary changes to ensure the EU’s transition to agroecology, despite some positive elements.

We welcome the proposal for a Regulation to replace the current Directive, which is essential to achieve effective implementation by Member States. Furthermore, the proposal to ban the use of pesticides in areas used by vulnerable groups and in sensitive areas, such as Natura 2000 sites, is an important step in the right direction.

However, many elements of the proposal are worrying and do not improve the failure of the SUD. Furthermore, some positive aspects of the current SUD legislation, in line with the agro-ecological transition and the objectives of the EU Green Deal, are missing from the draft proposal.

 

  1. Bureau d’Analyse Sociétale d’Intérêt Collectif (Basic), Analyse de la création de valeur et des coûts cachés des pesticides de synthèse (2021): lebasic.com/wp-content/uploads/2021/11/BASIC_Etude-Creation-de-Valeur-et-Couts-Societaux-Pesticides_20211125.pdf
  2.  The EU safety assessments for pesticides are based on models rather than real-life studies and do not consider risks of pesticide cocktails and indirect effects in the food web. https://issuu.com/pan-uk/docs/the_cocktail_effect_-_report?fr=sODM1NzExOTMxNQ
  3.  Persson et al. (2022), Outside the Safe Operating Space of the Planetary Boundary for Novel Entities,Environ. Sci. Technol: 10.1021/acs.est.1c04158
  4.  Groh et al. (2022), Anthropogenic Chemicals As Underestimated Drivers of Biodiversity Loss: Scientific and Societal Implications, Environ. Sci. Technol: 10.1021/acs.est.1c08399
  5.  D’Annolfo et al. (2015), A review of social and economic performance of agroecology, International Journal of Agricultural Sustainability: https://www.researchgate.net/publication/283721380_Social_and_economic_performance_of_Agroecology
  6.  van der Ploeg et al. (2019) The economic potential of agroecology: Empirical evidence from Europe. Journal of Rural Studies: https://hal.archives-ouvertes.fr/hal-02625121/
  7.  Lechenet et al. (2017), Reducing pesticide use while preserving crop productivity and profitability on arable farms, Nature plants: https://www.inrae.fr/en/news/reducing-pesticide-use-agriculture-without-lowering-productivity
  8.  Poux et al.(2018), An agroecological Europe in 2050: multifunctional agriculture for healthy eating. Findings from the Ten Years For Agroecology (TYFA). Iddri-AScA: www.iddri.org/sites/default/files/PDF/Publications/Catalogue%20Iddri/Etude/201809-ST0918EN-tyfa.pdf
  9.  https://www.savebeesandfarmers.eu/eng/

 

What we want

There is an urgent need to quickly publish a pesticide regulation that sets ambitious reduction targets and provides an effective measurement indicator!

The revision of pesticide regulations is an important legislative moment in the context of the “Farm to Fork Strategy”. It aims, among other things, to act on a 50% reduction in the risks and uses of pesticides , with a focus on the most dangerous products (halving in volume) by 2030 both in the States and in the European level. Following a first postponement in March , the proposed revision of the regulations is due to be published on June 22, 2022.

In order to alert to the urgency of the situation, 24 European NGOs are writing to the European Commission concerning the SUD regulation (for Sustainable Use Directive) relating to the framework for the use of pesticides at European level and the law on the restoration of Nature present in the European “nature protection” package. Générations Futures supports this initiative and has written today to the French government to use its full weight in order to obtain ambitious texts in terms of the protection of health and biodiversity.

Our NGOs reaffirm in these letters the need for the publication of the ambitious pesticide package on the scheduled date, while this legislative text is an essential part of putting into practice the objectives of the “From Farm to Fork” strategy.

The various NGOs recall the strong expectations linked to this text, in particular:

  • Set as a clear goal the transition to agroecological practices and a pesticide-free future .
  • use and risk reduction targets , both at EU and Member State level, for synthetic pesticides.

On this question of the measurable objective there is a major subject which will have to be taken into account: the choice of indicator. In its effort to make the minus 50% target measurable and binding, the European Commission has proposed the Harmonized Risk Indicator 1 (HRI 1) to monitor its achievement. However , this indicator currently under discussion is very problematic , as demonstrated by a report published by our colleagues from Global 2000 Austria and which we have translated.

What the report shows is that HRI 1 most strongly discriminates against pesticides used in organic farming. But even within conventional pesticides, there is a systematic bias in favor of the most toxic , whose toxicity is systematically underestimated when the HRI 1 is applied. This is particularly true for highly toxic insecticides such as pyrethroids or neonicotinoid type pesticides, due to an inverse correlation between the toxicity of pesticide active substances and their application rates per hectare. Due to the systematic underestimation of the risks of synthetic pesticides (such as neurotoxins from the chemical group of neonicotinoids, organophosphates or pyrethroids) and at the same time the exorbitant overestimation of the risks of active substances used in organic farming of naturally occurring, the application of HRI 1 jeopardizes other important Green Deal goals in addition to the 50% pesticide reduction target. These include reversing the decline of pollinators and extending organic farming to 25% of EU agricultural area.

Read the report in French and English

Other requests from our NGOs are:

  • Promote mandatory application and improve definition of Integrated Pest Management (IPM), organic farming , alternative non-chemical methods etc.
  • Require that National Action Plans, drafted by Member States, be reviewed and approved by the Commission and a group of independent experts.
  • Exclude incentives for precision farming and genetic engineering techniques.
  • Prohibit the use of highly harmful practices, such as aerial spraying, seed coating , the use of drones , the use of synthetic pesticides in areas near populations.
  • Ensure public access to adequate statistics on pesticides in order to monitor their use and effectively measure progress towards binding targets.
  • Effectively measure the progress achieved through harmonized and effective environmental indicators.
  • Ensure that the Common Agricultural Policy budget is used to drive the transition to agroecology.

During the Agriculture and Fisheries Council on Monday June 13 , 10 countries called for reducing the objectives of the future regulation. The 27 supported this request. France has remained discreet because of the neutrality which falls to it with the French Presidency of the EU. The two European commissioners, Kyriakides and Wojciechowski , insisted on taking into account the realities of each of the Member States by promoting a fair and balanced approach according to the respective situations. Fortunately, Stella Kyriakides , European Commissioner for Health and Consumer Policy, maintained her position on the need to produce a text with rigorous objectives in order to move towards an agricultural and ecological transition. She asserted that ” we must put an end to the excessive use of pesticides “.

During a plenary session in the European Parliament on June 6, 2022 , MEPs had already been able to discuss with Stella Kyriakides on reducing the use of pesticides and strengthening consumer protection . Different deputies like Benoît Biteau , Anja Hazekamp , Claude Gruffat or Maria Arena defended a controlled approach to pesticides and recalled the consequences of their use and the existing alternatives. Sensitive to this discourse, Stella Kyriakides reused these arguments to respond to deputies who were skeptical of moving towards an agricultural transition.

Pesticide reduction targets are currently being strongly attacked by agri-food lobbies . The war in Ukraine is becoming an instrument of their strategy, as recalled by a group of NGOs who denounce the received ideas on production and food sovereignty linked to the Ukrainian context. The agricultural transition must not wait and strong texts must be proposed now to be able to move towards sustainable agriculture. Only this model will make it possible to feed populations healthily, to preserve their health, the environment and biodiversity. There is urgency, and the EU must not give in to the pressure exerted by private and short-termist economic interests .

Find the letter from European NGOs signed by

Agroecology Europe, Beelife, Birdlife, ClientEarth, Corporate Europe Observatory, Euro Coop, European Agroforestry Federation (EURAF), European Coordination La Via Campesina (ECVC), European Environmental Bureau (EEB), European Federation of Trade Unions in the Food, Agriculture and Tourism (EFFAT), Fair Trade Advocacy Office (FTAO), Feedback Europe, Foodwatch, Friends of the Earth Europe, Greenpeace, Health and Environment Alliance (HEAL), IFOAM Organics Europe, Justice Pesticides, Oceana, PAN Europe, Seas at Risk, Slow Food, The Institute for Agriculture and Trade Policy (IATP), Urgenci International Network of Community Supported Agriculture

 

  • There is an urgent need to quickly publish a pesticide regulation that sets ambitious reduction targets and provides an effective measurement indicator!

    The revision of pesticide regulations is an important legislative moment in the context of the “Farm to Fork Strategy”. It aims, among other things, to act on a 50% reduction in the risks and uses of pesticides , with a focus on the most dangerous products (halving in volume) by 2030 both in the States and in the European level. Following a first postponement in March , the proposed revision of the regulations is due to be published on June 22, 2022.

    In order to alert to the urgency of the situation, 24 European NGOs are writing to the European Commission concerning the SUD regulation (for Sustainable Use Directive) relating to the framework for the use of pesticides at European level and the law on the restoration of Nature present in the European “nature protection” package. Générations Futures supports this initiative and has written today to the French government to use its full weight in order to obtain ambitious texts in terms of the protection of health and biodiversity.

    Our NGOs reaffirm in these letters the need for the publication of the ambitious pesticide package on the scheduled date, while this legislative text is an essential part of putting into practice the objectives of the “From Farm to Fork” strategy.

    The various NGOs recall the strong expectations linked to this text, in particular:

    • Set as a clear goal the transition to agroecological practices and a pesticide-free future .
    • use and risk reduction targets , both at EU and Member State level, for synthetic pesticides.

    On this question of the measurable objective there is a major subject which will have to be taken into account: the choice of indicator. In its effort to make the minus 50% target measurable and binding, the European Commission has proposed the Harmonized Risk Indicator 1 (HRI 1) to monitor its achievement. However , this indicator currently under discussion is very problematic , as demonstrated by a report published by our colleagues from Global 2000 Austria and which we have translated.

    What the report shows is that HRI 1 most strongly discriminates against pesticides used in organic farming. But even within conventional pesticides, there is a systematic bias in favor of the most toxic , whose toxicity is systematically underestimated when the HRI 1 is applied. This is particularly true for highly toxic insecticides such as pyrethroids or neonicotinoid type pesticides, due to an inverse correlation between the toxicity of pesticide active substances and their application rates per hectare. Due to the systematic underestimation of the risks of synthetic pesticides (such as neurotoxins from the chemical group of neonicotinoids, organophosphates or pyrethroids) and at the same time the exorbitant overestimation of the risks of active substances used in organic farming of naturally occurring, the application of HRI 1 jeopardizes other important Green Deal goals in addition to the 50% pesticide reduction target. These include reversing the decline of pollinators and extending organic farming to 25% of EU agricultural area.

    Read the report in French and English

    Other requests from our NGOs are:

    • Promote mandatory application and improve definition of Integrated Pest Management (IPM), organic farming , alternative non-chemical methods etc.
    • Require that National Action Plans, drafted by Member States, be reviewed and approved by the Commission and a group of independent experts.
    • Exclude incentives for precision farming and genetic engineering techniques.
    • Prohibit the use of highly harmful practices, such as aerial spraying, seed coating , the use of drones , the use of synthetic pesticides in areas near populations.
    • Ensure public access to adequate statistics on pesticides in order to monitor their use and effectively measure progress towards binding targets.
    • Effectively measure the progress achieved through harmonized and effective environmental indicators.
    • Ensure that the Common Agricultural Policy budget is used to drive the transition to agroecology.

    During the Agriculture and Fisheries Council on Monday June 13 , 10 countries called for reducing the objectives of the future regulation. The 27 supported this request. France has remained discreet because of the neutrality which falls to it with the French Presidency of the EU. The two European commissioners, Kyriakides and Wojciechowski , insisted on taking into account the realities of each of the Member States by promoting a fair and balanced approach according to the respective situations. Fortunately, Stella Kyriakides , European Commissioner for Health and Consumer Policy, maintained her position on the need to produce a text with rigorous objectives in order to move towards an agricultural and ecological transition. She asserted that ” we must put an end to the excessive use of pesticides “.

    During a plenary session in the European Parliament on June 6, 2022 , MEPs had already been able to discuss with Stella Kyriakides on reducing the use of pesticides and strengthening consumer protection . Different deputies like Benoît Biteau , Anja Hazekamp , Claude Gruffat or Maria Arena defended a controlled approach to pesticides and recalled the consequences of their use and the existing alternatives. Sensitive to this discourse, Stella Kyriakides reused these arguments to respond to deputies who were skeptical of moving towards an agricultural transition.

    Pesticide reduction targets are currently being strongly attacked by agri-food lobbies . The war in Ukraine is becoming an instrument of their strategy, as recalled by a group of NGOs who denounce the received ideas on production and food sovereignty linked to the Ukrainian context. The agricultural transition must not wait and strong texts must be proposed now to be able to move towards sustainable agriculture. Only this model will make it possible to feed populations healthily, to preserve their health, the environment and biodiversity. There is urgency, and the EU must not give in to the pressure exerted by private and short-termist economic interests .

    Find the letter from European NGOs signed by

    Agroecology Europe, Beelife, Birdlife, ClientEarth, Corporate Europe Observatory, Euro Coop, European Agroforestry Federation (EURAF), European Coordination La Via Campesina (ECVC), European Environmental Bureau (EEB), European Federation of Trade Unions in the Food, Agriculture and Tourism (EFFAT), Fair Trade Advocacy Office (FTAO), Feedback Europe, Foodwatch, Friends of the Earth Europe, Greenpeace, Health and Environment Alliance (HEAL), IFOAM Organics Europe, Justice Pesticides, Oceana, PAN Europe, Seas at Risk, Slow Food, The Institute for Agriculture and Trade Policy (IATP), Urgenci International Network of Community Supported Agriculture

     

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