Policies and legislation on pesticides: a conversation with experts
In June, we hosted a webinar on the policies and legislation on pesticides together with FAO. Prior to the webinar, we asked registrants to send us any questions they might have about the topic. We asked the presenters, Prof. Parthiba Basu, Tsvetana Georgieva, Dr. Roberta Nocelli, Ivy Saunyama and Kim-Anh Tempelman to answer those questions that had not been covered in the webinar. We received questions in 3 domains. Questions about status, policies, and legislation of pesticides, questions about the scientific background of pesticides admission, and questions about a number of practical issues regarding (the use of) pesticides. This is part 1 of the questions, covering status, policies and legislation. Part 2 covers questions on the scientific background of pesticides admission, and questions on the practical level.
All answers reflect the opinion of the presenters, and not the opinion of the organisation they represent. Did you miss the webinar? You can watch the recording here.
Status, Policies and Legislation
Which new or old pesticides will probably be used to replace products recently forbidden, like neonics and glyphosate? What is the action plan to prevent misuse of pesticides?
Regarding the replacement of pesticides Parthiba Basu states that replacement of the neonics will have to be non-chemical (For example, see this paper). Older ones, he says, are even worse. The European Commission describes the situation for Europe as follows: ‘Authorisation of plant protection products (PPPs) is the responsibility of Member States, following the approval of active substances they contain at European level. Vice versa, non-approval of active substances is followed by withdrawal from the market of PPPs, containing such active substances. Information on the approval or non-approval of active substances is to be found on the EU pesticides database. Similarly, Member States keep registers of authorised PPPs, which are publicly available.
PPP professional users shall use only PPPs authorised for placing on the market and use in their countries. One further obligation for PPP professional users is to use pesticides in accordance with the authorisation conditions, as described on their labels, and to keep records of the uses of pesticides (e.g. crop, rate, timing), as well as to make this information available to the relevant competent authorities. All the above aspects are subject to official controls at farm level, including also aspects related to the sustainable use of pesticides. Selection of PPPs to use is with the professional users, based on pest monitoring data and/or based on recommendations by advisors, where they have to consult the list of authorised PPPs, and the authorised uses (crop/pest combinations).
In the case of any violations of national and/or EU legal requirements, including the use of illegal pesticides or illegal uses of authorised pesticides, sanctions and fines are imposed by the control authorities, and further actions are undertaken by the authorities to make sure that the non-compliant operators remedy the situation (as per the Official Controls Regulation). The sanctions imposed shall be proportionate, effective and dissuasive.’
Roberta Nocelli: ‘In Brazil, neonicotinoids and glyphosate are allowed. We have legislation that proposes sanctions for the use of illegals and the misuse of pesticides, but our inspection is inefficient.’
What is the right relationship with the European Common Agricultural Policy? How can intensive farmers be made aware of the need to look for non-toxic alternatives?
Tsvetana Georgieva: Revision of the Common Agricultural Policy is currently on-going. As part of this process, EU Member States are required to develop National Strategic Plans (NSPs). The NSPs have to reflect on the Farm to Fork (F2F) targets, including: (a) 50 % reduction in use and risk of chemical pesticides by 2030, (b) 50 % reduction in the use of more hazardous pesticides (categorised as candidates for substitution) by 2030, and (c) increase in the area dedicated to organic farming, reaching up to 25 % of the total agricultural utilisable area by 2030. Implementation of IPM is considered as a core action to meet the above mentioned targets, which is also to be reflected in the NSPs. For measures/actions at farm level, going beyond the EU legal requirements, farmers would get financial support.
How can pesticide regulatory agencies lead in the conversation of effects of pesticides on pollinators and work with other multi-sectoral government agencies in pollinator protection.
Kim Anh Tempelman: It should be one of the main responsibilities of pesticide regulatory agencies to take the lead in discussions on the effects of pesticides on pollinators and work with other multi-sectoral government agencies to this end. However, limited access to/lack of information can be a hurdle.
Multistakeholder pollinator protection platforms can be very useful in discussing cases of poisoning, best ways to protect pollinators, etc. In this context, the 5-year review of the All-Ireland Pollinator Plan (and related recording from World Bee Day) could be useful (minute 45’45).
Why have pesticides not been banned already when there is clear evidence against the use of them?
The answer of the European Commission: ‘In the EU, pesticides are not approved or banned, if no safe use could be demonstrated in the process of approval or renewal of approval respectively of active substances and, consequently, in the authorisation of PPPs at national level in individual MSs. Furthermore, the approval of an active substance can be reviewed at any time in the light of new scientific and technical knowledge and monitoring data according to Article 21 of Regulation (EU) No 1107/2009. Articles 69, 70 and 71 provide for emergency measures if necessary.’
Roberta Nocelli: ‘In Brazil there is no systematic review process for records, this only occurs upon evidence that the products cause environmental damage, human health or have lost their effectiveness. The number of products authorized in Brazil has increased significantly in recent years and there is a bill that changes the responsibility for the registration system, excluding the Ministry of Environment and Health from the analysis process.’
A number of questions focused on possible strategies to influence farmers’ decisions to use pesticides or to use alternative protection methods. Eg questioners asked whether a ban on the use of a wide range of pesticides might help, what the role of awareness raising could be and whether price-regulation systems (through taxes) might help.
The decision of a farmer whether to use pesticides, and which specific pesticide, is influenced by many factors. Thus, many different policy strategies may help to change towards a more ‘ecosystems services inclusive’ agricultural system with a lower use of pesticides. Relevant factors are price (in the Netherlands this is often mentioned by farmers), but also risk-perception (‘what happens if I do not apply pesticides?’), knowledge on alternative methods, and even habits (‘this is how I’ve always done it, and my father did it this way as well’). A prerequisite for a farmer not to use pesticides is -obviously- that they have alternative methods to protect their crops. It is therefore important to strengthen extension and advisory services and train farmer groups, including through Farmer Field School programs, and to promote environmental friendly alternatives.
The prohibition of pesticides may induce innovation towards different plant protection measures. Awareness raising on the importance of biodiversity for (climate) resilient agriculture is definitely of relevance. Including and implementing concrete conservation and sustainable use objectives and activities for local genetic resources for food and agriculture in national strategies and action plans.
We are not aware of any research specifically on the impact of tax changes on the purchase decisions of farmers in this respect. There has been quite some research on the effects of tax changes on purchase decisions in general, and sometimes on specific issues. There are also some examples of implementation of taxes to influence purchase behavior of citizens (eg. the ‘sugar-tax’ in the United Kingdom).
What are the latest strategies for upscaling and outscaling pollinator friendly farming systems within the African setting?
The African Union has endorsed regional guidelines to conserve and protect pollinators. Field work is ongoing in several countries, including in Kenya, Rwanda, Tanzania and South Africa. In addition, efforts are being made under the EU funded ACP MEAs 3 programme to strengthen regulatory capacity of pesticides, including for pollinator protection.