Pesticides EU market

According to the Eurostast, pesticide (fungicides, herbicides, insecticides and other pesticides) annual sales in the EU15 increased during the period 1992-2001 from 291.895 to 327.279,90 tonnes, with a peak of 355.537,40 in 1998, despite a Common Agriculture Policy (CAP) reform whose objective was to lower EU agriculture external costs including environmental contamination. France and Italy are, by far, the largest markets in the EU15 accounting for 99.635 and 76.346 tonnes of all pesticide sales respectively.

This increase in pesticide consumption happens despite a clear trend in arable farming towards active ingredients which are effective at lower dosage rates (grammes instead of kilogrammes) than former standard products. However the effect on total pesticide consumption of the increased use of low dose pesticides can, but only partly, be counterbalanced by a slight increase in the use of sulphur and copper products. These high dose pesticides, mainly used as fungicides, are key products in integrated crop protection, for disease control in vineyards, orchards, and on farms dedicated to organic farming practices.

Figure 3 - Insecticide consumption in EU, 1996 EU 15 and 1998 acession countries

The quantity of pesticides consumed does not necessarily reflect the risk presented by using pesticides. The real risks depend on factors such as type of product, toxicity, persistence, climate and soils conditions, water solubility, type of cultivation and application practices, and resulting exposure. New active substances can be applied far less copiously without necessarily resulting in a corresponding reduction of risk for health and environment. High dose pesticides are not necessarily likely to lead to an increase in these risks.

Ideally, a proper pesticide risk indicator would take into account all the above mentioned parameters. However, this would involve complex and contentious calculations. Data availability does not yet allow the calculation of a "scientifically sound" pesticide risk indicator and will much probably never allow this. Moreover, there is a lack of a consensus on a calculation methodology.

From Eurostat consumption data, it appears that there is a trend towards an increased dependency on pesticide products and hence an increase in exposure to pesticides, their "inert ingredients" and metabolites.

In order to avoid any likely further increase in the risk to health and environment from rising exposure to pesticides acting separately or in interaction, precautionary measures for pesticide use/dependency reduction must be implemented without further delay.

Council Directive 91/414/EEC of 15 July 1991 concerning the placing of
plant protection products (PPPs) In the market sets out a Community harmonised framework for authorisation, use and control of plant protection products. It is a dual system where the Community evaluates active substances and Member States evaluate and authorise products containing them. A basic principle of the Directive is the development of a positive list (Annex I) of active substances that are acceptable for the environment, human and animal health. Substances listed in Annex I are eligible for inclusion in plant protection products that Member States may authorise to be placed on the market at national level.

The Directive provided for a 12-year programme of evaluation of the 834 active substances already on the market at the time of its entry into force in July 1993 (the "existing" active substances) and, pending Commission Decisions on their inclusion in Annex I, permitted their remaining on the market until July 2003 under certain conditions. The Commission split the review programme for these substances into four phases, following the division of the 834 substances on the market into four lists:
- First priority list (90 substances), established in 1992, comprised those substances considered at that time to be the most widely used on the market as well as those of clear concern;
- Second list (149 substances), established in 2000, comprised all those organophosphates and carbamates that were not on the first list as well as other substances of concern and substances for which industry had indicated early availability of dossiers;
- Third list (402 remaining chemical substances), introduced in 2000, comprises the pesticides not as widely used as the pesticides in the second list;
- Fourth list (193 remaining substances), established by default, includes substances identified as being of lower concern: (a) microbial pesticides, (b) substances already authorised in foodstuffs, (c) plant extracts, (d) animal products, (e) substances used in organic farming, (f) rodenticides, (g) storage products and (h) commodity chemicals.

All other substances presented since July 1993 are considered as "new" active substances. Both new and existing substances are evaluated in parallel.

In July 2001 the Commission presented to the European Parliament and to the Council a Progress Report on the evaluation programme for existing substances. Although no more than 31 of the 834 existing active substances were evaluated having completed the full procedure, the Commission believed that by July 2003 decisions will have been taken on at least 380 of the 834 substances, mainly decisions withdrawing substances from the market. Furthermore, the Commission proposed to finish the first list by July 2003 with the established system and process. The evaluation of the second list should be complete in 2005 and the third and fourth lists in 2008. The risk assessment per review for the substances on the first phase was completed by the European Commission. For substances on the second phase, this task is performed by the newly created European Food Safety Agency.

Phase	Number of substances (% market share in 1993)	Beign examined	To be examined	Clear that will be withdrawn	In Annex I
First	90 (30%)	61	0	16	13
Second	149 (40%)	0	60	89	0
Third	402 (25%)	0	167	235	0
Fourth	193 (5%	0	166	27	0
Total	834 (100%)	61	393	367	13

The withdrawal of over 300 substances by 2003 is mainly due to the fact that agrochemical companies did not push for re-registration of the older products, sometimes on economic grounds and sometimes because they knew they would not pass the stricter test requirements introduced.

The Commission also recognised in its Progress Report the need to amend Directive 91/414/EEC, but it decided to wait for the reactions of Parliament and Council to the report before bringing forward proposals for amendment in 2002. The European Parliament Resolution was very critical towards the report and called for the revision of the Directive on several grounds:
- unless there is a change in policy, there can be no guarantee of compliance with the timetable proposed by the Commission;
- new knowledge on the problems caused by pesticides;
- existence of several important aspects not covered by evaluation (endocrine disrupters, synergistic additives, the additive and synergistic effects of several pesticides, etc.);
- absence of any decision not to include a pesticide on the list on grounds connected with human health;
- residues in foodstuffs of plant origin have revealed severe shortcomings in the control systems of the Member States.

The EP resolution also calls for specific amendments to the Directive, many of them defended by PAN Europe in our positions.

PAN Europe and its partners called on the Commission to make use of the opportunity to propose a fundamental review of 91/414/EEC, which is aimed at modernising and harmonising the Directive in line with relevant EU legislation (e.g. Water Framework Directive) and international agreements such as the OSPAR Convention.

Future pesticides regulation should be based on the highest protection level available in existing EU legislation or international agreements, in line with the Precautionary Principle. The overall objective of 91/414 should be that avoiding negative impacts on or dangers to “health, groundwater and the environment and human and animal health should take priority over the objective of improving plant production”. EU agricultural policy should aim at sustainable agriculture, and the pesticide authorization process should reconsider the degree of need for each individual pesticide.

As required under the Better Regulation initiative, Commission services have been invited to prepare an Extended Impact Assessment of the economic, social and environmental impacts of the revision on Directive 91/414/EEC. The report is going to be presented in January 2006, followed by a stakeholders meeting and a period of consultation.