The last pesticide committee meeting of 2024 will set the lines for the future of a toxic mix of topics. Among the highlights there is a proposed ban on two PFAS pesticides. Two ‘toxic 12’ pesticides are also on the table for discussion. For one of these extremely toxic pesticides, a dangerous concept is applied for the first time: negligible exposure. This piece of ‘magic’ would allow continued use of the substance on the unproven ground that people or the environment will not be in contact at all. To complete the toxic mix, two active substances recently identified as endocrine disruptors for humans will be discussed. One of them was the most often detected ‘candidate for substitution’ in European fruit between 2009 and 2019.
Much is at stake in the SCoPAFF meeting of December 4th and 5th. The two PFAS pesticides on the agenda degrade into trifluoroacetic acid (TFA), a highly persistent ultra-short PFAS that contaminates water sources all over Europe. The two endocrine disruptors are members of a toxic family that should have been removed from our environment and our food long ago. The same is the case for the toxic 12, whose authorisation has been stretched for far too long while there is compelling scientific evidence about their harmful effects. During this meeting, the Commission and Member States will also look into an update to pesticide data requirements, a missed opportunity to strengthen protection from neurotoxicity and immunotoxicity.
A Step forward against PFAS Pesticides
After multiple meetings and discussions on PFAS pesticides and TFA, the Commission is finally moving forward with proposals for banning two PFAS active substances. The first substance concerned is flufenacet. Earlier this month, 48 environmental and health organizations supported PAN Europe’s call for a swift ban [1]. Flufenacet is a top-selling PFAS pesticide produced by Bayer, BASF and other companies. It has been found by the European Food Safety Authority (EFSA) to be an endocrine disruptor for humans and non-target organisms. It may impact the brain development of babies and young children and is putting pregnant women at risk. According to the Pesticide Regulation, endocrine disruptors shall be banned. Moreover, the commission acknowledges that flufenacet breaks down into TFA, a suspected reprotoxic substance, which largely contaminates groundwater and our drinking water.
The Commission is also proposing to ban flutolanil, another PFAS pesticide which breaks down into TFA.
More Endocrine-disrupting Pesticides
In November 2024, EFSA formally identified fludioxonil and fenoxaprop-P-ethyl as endocrine disruptors, adding to the growing list of pesticide substances that are acknowledged to interfere with our hormonal systems [2].
Fludioxonil has been linked to delayed sexual maturation, changes in reproductive health, and altered hormone cycles, affecting both humans and wildlife. Worryingly, the substance was the most often detected ‘candidate for substitution’ in European fruit between 2009 and 2019 according to data from the EU Multiannual Control Programme analysed by PAN Europe [3].
Fenoxaprop-P-ethyl was found to induce changes in the weights of the prostate, epididymis, and testes, alongside alterations in testicular weight. In this case, the applicant dataset was so incomplete that no conclusions could be drawn on whether these conclusions that the substance is an endocrine disruptor for humans also apply to non-target organisms.
The Pesticide Regulation clearly states that substances with endocrine-disrupting properties should be banned. PAN Europe calls for immediate action to ensure these two substances are swiftly removed from the market and our food.
A next step in PAN Europe’s Toxic 12 Campaign
The Toxic 12 campaign, led by PAN Europe, raises alarm over the ‘more hazardous’ pesticides that should be banned immediately. At the December meeting, two of these Toxic12 are on the agenda.
First, discussions engaged in July 2024 about the renewal of 8-hydroxyquinoline will continue [3]. Since 2015, the substance has been identified as toxic to reproduction, which means it no longer meets the approval criteria of the Pesticide Regulation. Yet, it remained approved as a ‘candidate for substitution’ until its approval ends. This is why it is on PAN Europe's list of Toxic12 to be banned immediately. Worryingly, the European Commission now proposes to the Member States to renew its approval on the grounds that human exposure would be negligible in the context of drip irrigation in permanent greenhouses [4]. This exceptional clause of "negligible exposure" foreseen by the Regulation allows for the approval of "cut-off" pesticides if it can be convincingly proven that there will be no contact with humans and no residues in food. Worryingly, such a robust demonstration was not provided for 8-hydroxyquinoline. Therefore, a proposal to renew the substance does not comply with the requirement of the Pesticide Regulation. While some Member States have clearly expressed themselves in favour or against the proposals, others have no position yet. PAN Europe reiterated its request for Member States to reject the proposal.
The Commission and Member States will for the first time discuss the EFSA’s recent scientific opinion on Pirimicarb, another one of our Toxic 12. The substance was identified as a ‘candidate for substitution’ because of its persistence and toxicity. Moreover, it is classified as suspected of being carcinogenic. EFSA’s recent opinion concludes that the toxicity of the substance for some (aquatic) organisms is so high that no safe use can be identified, even when applying maximum risk mitigation measures. The substances also raised neurotoxicity concerns. Other important aspects of the risk assessment were not finalised due to data gaps. Taking all of this into account, the substance cannot be considered to meet the requirements to be renewed.
Renewing the approval of these Toxic 12 pesticides would be a failure to protect public health and the environment. PAN Europe urges the European Commission to take a firm stance against these chemicals and reject any proposals to extend their approval.
The Growing Problem of Prolongations
What all these substances have in common is that their approval period has repeatedly been extended due to delays in their risk assessment. For instance, flufenacet's approval was prolonged for 11.5 years after the original authorisation expired, pirimicarb for 8 years, fludioxonil and fenoxaprop-P-ethyl for 7 years, and flutolanil for 6. For all these years the substances remained on the market, while there was ample evidence of their harmfulness. After all those years of use their peer reviews now finally completed indicate that they are too harmful to remain approved in the EU. For some, important uncertainties remain because the producers did not supply the necessary data.
This situation starkly contradicts the purpose of the Pesticide Regulation, which aims to ensure a high level of protection for human health and the environment. Prolonged delays in risk assessments and repeated approval extensions result in continued exposure to substances with harmful and unacceptable environmental effects. Numerous cases highlight the urgent need for stricter enforcement of regulatory deadlines to prevent similar situations in the future. The unlimited use of prolongations is the subject of a court case launched in 2022 by PAN Europe. [5]
Data requirements
As the Commission and Member States are discussing updating the data requirements for microorganisms and bees, PAN Europe argues the current regulatory framework does not sufficiently address key toxicity concerns, particularly in the areas of neurotoxicity and immunotoxicity. Despite mounting evidence linking pesticide exposure to developmental and neurological damage, current pesticide risk assessments do not require studies on these critical areas for all synthetic pesticides. PAN Europe calls for the inclusion of mandatory neurotoxicity and immunotoxicity studies in all pesticide evaluations.
Moreover, pesticide products are still not assessed for long-term toxicity, cancer potential and endocrine disruption, despite the requirements of the EU law that active substances nor products should cause immediate or delayed harmful effects. In a recent ruling from two court cases by PAN Europe, the European Court of Justice, emphasised that pesticide products should be assessed for their endocrine-disrupting properties. PAN Europe sees the revision of the data requirements for pesticide products as a missed opportunity to include the relevant available tests to assess their long-term toxicity, carcinogenicity and endocrine disrupting properties.
Our letter to the Standing Committee on Plants, Animals, Food and Feed
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Notes:
[2] Hormone disrupting pesticides (EDCs) | PAN Europe
[3] Forbidden Fruit
[4] Don’t worry, you will not be exposed to this very harmful pesticide' | PAN Europe
[5] PAN Europe court case against the systematic use of prolongations
