Art. 24 of Regulation 1107/2009 creates a list of “candidates of substitution”. Commission needs to put pesticides on a list by December 14, 2013 based on the criteria mentioned in Annex II, point 4.

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 which is safer for human 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. 

Sweden has been most active on substitution and applied this already for many years nationally. Sweden also stimulated a discussion in EPPO on comparative risk assessment.

Useful information

• Regulation 1107/2009 (legal text)
• Directive 2009/126/EU on the sustainable use of pesticides
• EPPO on comparative risk assessment (2009)