The potential impact of proposed changes to EU pesticides regulations in ACP countries
In July 2006, the European Commission issued a proposal to replace Directive 91/414/EEC, the current EU legislation under which pesticides are approved for use. A series of amendments were adopted by the Parliament in January 2009, and the new regulation will probably come into force in late 2010 or early 2011. It introduces a major change: pesticide approvals will be based on “hazard-based cut-off criteria”, which take into account only the intrinsic chemical properties of a pesticide. This is in contrast to the current approvals process, which considers not only hazard (toxicity), but also risk (how a product is used, when, where, how frequently, etc.).
PIP has conducted an impact assessment to consider the potential implications of the new regulation on pesticides that are currently recommended and approved for use on horticultural export crops in ACP countries. The study takes into account the results of earlier studies by EU experts (FMFACCP, KEMI and PSD), which produced assessments of the likely pesticides that could be lost under the new regulation. The full English version of the report can now be seen on the PIP website (and the French version will be available shortly): http://www.coleacp.org/en/pip/14197-impact-assesment.
The PIP study concludes that though several pesticides currently used on export crops may be withdrawn in Europe, the new Regulation is not likely to have a major impact in ACP countries in the short-term. Substances will remain authorized until they come up for review when their Annex I listing expires, and even then the possibility of derogations should allow time to develop alternatives. Moreover, when a pesticide is withdrawn in Europe, continued use on ACP export crops will still be possible provided that the product is registered locally, and EU MRLs and Import Tolerances are complied with. Overall the impact is more likely to be felt over the longer-term, and particularly in the smallholder sector, due to the possible loss of some less expensive, broad spectrum pesticides and consequent increase in production costs.
Certain elements of the new regulation are still to be clarified. For example, the criteria for endocrine disruptors have not been finalised, giving rise to considerable uncertainty. It is also as yet unclear if Import Tolerances of substances that are withdrawn based on public health-related cut-off criteria will be set at the Limit of Quantification. PIP will closely follow the development and implementation of the new regulation, and will anticipate and take action as required.
The report notes that it is vital to begin developing alternative pest management strategies in order to limit the impact when substances are eventually lost. It also highlights the importance of working closely with manufacturers to encourage them to develop new products, and to introduce existing products into ACP countries. Based on the findings of this study, PIP will conduct more detailed evaluations on a crop-by-crop, pest-by-pest basis in order to identify potential problem areas in good time.
