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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 (info Contexte)
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
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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

We urge the Commission, as a first step, and in the short term, to show vision and moral conviction by :

  • Not postponing the much needed reform of the SUD Directive;
  • Ensuring that the reform is sufficiently ambitious and contains strong and legally binding use reduction targets and other provisions, in line with the joint civil society statement on the SUD review;
  • Ensure that all EU food and feed safety standards are met;
  • Fulfil its commitment to the Farm to Fork and Biodiversity strategies, and move away from our current agricultural model and its dependence on external inputs. This is the only way to achieve food sovereignty and preserve long-term food security.

More specifically, we ask the Commission to consider the following elements for its proposal for a new regulation

  1. Set a clear objective of transition to agro-ecological practices and a pesticide-free future.
  2. Set truly ambitious and legally binding reduction targets, both at EU and national level, for the use and risks of synthetic pesticides, and immediately ban the use of the most hazardous pesticides. In addition, the Regulation should reflect civil society’s call for a complete phase-out of the use of synthetic pesticides
  3. Maintain the objective of Member States to reduce dependency on pesticide use, as well as the need to promote the mandatory application of Integrated Pest Management (IPM), organic farming, non-chemical methods, and to designate a sufficient share of the agricultural area under high biodiversity landscape features.
  4. Improving the definition of IPM for unwanted organisms. While current legislation rightly refers to the need to minimise disruption to agro-ecosystems, the way IPM is currently defined leaves too much room for destructive practices. Instead, the regulation should strengthen the definition by making the application of agro-ecological practices mandatory in order to achieve the objectives of reducing pesticide use. The definition should establish a hierarchy from least disruptive to agrosystems – including natural pest control – to most disruptive, with synthetic pesticides used only as a last resort.
  5. Require that National Action Plans drafted by Member States be reviewed and approved by the Commission and an expert panel of independent environmental and civil society scientists, to ensure transparency and independent scientific advice.
  6. Exclude the encouragement of precision farming and genetic engineering techniques, which will only maintain a model of industrial agriculture and a structural dependence on pesticides.
  7. Ban the use of highly damaging practices such as aerial spraying, seed coating, calendar spraying, the use of drones and the use of synthetic pesticides in residential areas and areas frequented by children, without exception. Provide mandatory and appropriately sized buffer zones around homes, schools, offices and waterways.
  8. Ensure public access to adequate statistics on pesticides in order to monitor their use and effectively measure progress against binding targets. The regulation should include environmental indicators, set a short and clear deadline for improving harmonised risk indicators, and develop a comprehensive set of additional indicators.
  9. Ensure that the Common Agricultural Policy budget is used to drive the transition to agro-ecology.
  10. Change the name of the proposal to, for example, “Regulation to reduce dependence on synthetic pesticides”. The name “Regulation on the sustainable use of plant protection products” is a euphemism that uses biased terminology introduced by the pesticide industry. The use of synthetic pesticides is simply not sustainable.

We call on the Commission to urgently address these demands in future legislation in order to ensure policy coherence between the objectives of the EU Green Deal and to pave the way towards a pesticide-free world. The pesticide reduction target of the Farm to Table Strategy and the Biodiversity Strategy must not remain an empty promise.

  • We urge the Commission, as a first step, and in the short term, to show vision and moral conviction by :

    • Not postponing the much needed reform of the SUD Directive;
    • Ensuring that the reform is sufficiently ambitious and contains strong and legally binding use reduction targets and other provisions, in line with the joint civil society statement on the SUD review;
    • Ensure that all EU food and feed safety standards are met;
    • Fulfil its commitment to the Farm to Fork and Biodiversity strategies, and move away from our current agricultural model and its dependence on external inputs. This is the only way to achieve food sovereignty and preserve long-term food security.

    More specifically, we ask the Commission to consider the following elements for its proposal for a new regulation

    1. Set a clear objective of transition to agro-ecological practices and a pesticide-free future.
    2. Set truly ambitious and legally binding reduction targets, both at EU and national level, for the use and risks of synthetic pesticides, and immediately ban the use of the most hazardous pesticides. In addition, the Regulation should reflect civil society’s call for a complete phase-out of the use of synthetic pesticides
    3. Maintain the objective of Member States to reduce dependency on pesticide use, as well as the need to promote the mandatory application of Integrated Pest Management (IPM), organic farming, non-chemical methods, and to designate a sufficient share of the agricultural area under high biodiversity landscape features.
    4. Improving the definition of IPM for unwanted organisms. While current legislation rightly refers to the need to minimise disruption to agro-ecosystems, the way IPM is currently defined leaves too much room for destructive practices. Instead, the regulation should strengthen the definition by making the application of agro-ecological practices mandatory in order to achieve the objectives of reducing pesticide use. The definition should establish a hierarchy from least disruptive to agrosystems – including natural pest control – to most disruptive, with synthetic pesticides used only as a last resort.
    5. Require that National Action Plans drafted by Member States be reviewed and approved by the Commission and an expert panel of independent environmental and civil society scientists, to ensure transparency and independent scientific advice.
    6. Exclude the encouragement of precision farming and genetic engineering techniques, which will only maintain a model of industrial agriculture and a structural dependence on pesticides.
    7. Ban the use of highly damaging practices such as aerial spraying, seed coating, calendar spraying, the use of drones and the use of synthetic pesticides in residential areas and areas frequented by children, without exception. Provide mandatory and appropriately sized buffer zones around homes, schools, offices and waterways.
    8. Ensure public access to adequate statistics on pesticides in order to monitor their use and effectively measure progress against binding targets. The regulation should include environmental indicators, set a short and clear deadline for improving harmonised risk indicators, and develop a comprehensive set of additional indicators.
    9. Ensure that the Common Agricultural Policy budget is used to drive the transition to agro-ecology.
    10. Change the name of the proposal to, for example, “Regulation to reduce dependence on synthetic pesticides”. The name “Regulation on the sustainable use of plant protection products” is a euphemism that uses biased terminology introduced by the pesticide industry. The use of synthetic pesticides is simply not sustainable.

    We call on the Commission to urgently address these demands in future legislation in order to ensure policy coherence between the objectives of the EU Green Deal and to pave the way towards a pesticide-free world. The pesticide reduction target of the Farm to Table Strategy and the Biodiversity Strategy must not remain an empty promise.

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