Art. 24 of the EU pesticide Regulation 1107/2009 provides that DG SANTE publishes a list of “candidates of substitution”. This should have been done by December 2013 but it took till 2015, with a list of 77 candidates. In 2023 there are still 50 on the list. Some were banned (not substituted) because they are too toxic. Others were withdrawn by the producers. None were substituted.
Art.50 of Regulation 1107/2009 makes Member States responsible for doing a “comparative risk assessment” to see if the candidate cannot be replaced by an alternative that is safer for humans and the environment. Important for this provision is to know what the present methods and practices in agriculture are in doing such an assessment and not to limit it to a comparison between two or more chemicals. Very relevant is to implement Directive 2009/128/EU adequately through so-called national action Plans and define Integrated Pest Management (IPM) for every crop. IPM is a minimum requirement for agriculture from 2014 on and should be at the basis of the comparative risk assessment in the different countries and different crops.
From September 2015 on for new authorisations on the national/zonal level, the first comparative risk assessments will have to be performed.
So far this substitution does not work. Guidelines are written by the pesticide industry and the regulatory authorities do not do their job. The result is 0 substitutions so far.
We don't agree. These very toxic chemicals are a threat to our health and our environment.
They need to be banned or substituted by safer alternatives as soon as possible : see our Toxic 12 campaign.
