Evaluation of the Sustainable Use of Pesticides Directive

1.Introduction 3

1.1The Sustainable Use of Pesticides Directive (hereinafter "the SUD") – the subject of this information report – was adopted in 2009 with the aim of reducing the risk and impact of pesticide use on human health and the environment. Integrated pest management, just like other pest management practices with low pesticide inputs, alongside organic farming, is one of the key elements of the directive, as it includes actions such as crop rotation, pest surveillance and the application of non-chemical pest control methods and other lower-risk pesticides. 3

1.2Bearing in mind the factors listed above, the EESC believes it would be useful to carry out a review of the roadmap contained in the current SUD, including an impact assessment and stakeholder consultation. 3

1.3In particular, we consider it essential to reassess the requirements, targets, conditions and timetables set under national action plans, with the ultimate aim of reducing the risks and effects of pesticide use, both for human and animal health and to ensure the healthy condition and conservation of ecosystems. 3

1.4The evaluation presented by the EESC in this information report is based primarily on the views and opinions of civil society organisations gathered during fact-finding trips to a number of EU Member States (Bulgaria, Croatia, Spain, Ireland and Sweden), and on the responses to the online questionnaire developed for this purpose. In particular, stakeholders were asked to state their views on the effectiveness and relevance of EU legislation on pesticide use, and on the level of their involvement in the development and implementation of the legislation. 3

2.Conclusions and recommendations 3

2.1Effectiveness 3

2.1.1Despite the fact that Member States embarked on the transposition and implementation of the SUD from different starting points and that the progress achieved by Member States varies, implementation of this directive and the National Action Plans (NAPs) has broadly speaking proven to be effective in achieving more rational and sustainable use and in reducing the risk inherent in the use of plant protection products. 3

2.1.2The SUD has helped inform and raise the awareness of all the actors in the chain who are directly involved (industry, distribution and farmers) regarding the importance of Integrated Pest Management (hereinafter "IPM") and the best use of plant protection products. Another improvement observed since the implementation of the sustainable use of pesticides has been to increase – through the introduction of the national plans – end-users' awareness of the importance of making more efficient and rational use of pesticides to protect not only the environment but also themselves. 3

2.1.3While significant progress has been made on the handling and treatment of pesticides since the directive's implementation (worth mentioning in this regard is the issuing of mandatory pesticide handling licences in some Member States), the lack of adequate knowledge remains the main obstacle to the optimal use of pesticides. In particular, and although there are exceptions in certain countries, there remains a widespread failure to comply with the requirement for mandatory end-user training. 3

2.1.4At the same time, there is broad consensus on the lack of alternative solutions and new technologies that are sufficiently cost-effective to deter the use of plant protection products (PPPs) in a more decisive manner. The use of alternative solutions remains low, mainly due to a lack of efficacy and cost-effectiveness to ensure optimal crop maintenance. 4

2.1.5Furthermore, the scarcity of currently available alternative solutions usually results in very high costs that are difficult to bear for farmers, who often sell their products at below production cost. Equally, the elimination of active substances from the market is not keeping pace with the development of alternative solutions, which puts farmers at a competitive disadvantage in the production of their agricultural products. 4

2.1.6Other factors influencing farmers' decisions as to whether or not to use pesticides include political, environmental, social and economic pressures. The latter is undoubtedly the factor that most heavily influences and conditions farmers' use of PPPs. By way of example, 81% of the responses to the EESC survey point to financial pressure as the main factor encouraging farmers to use pesticides. In particular, the lack of a minimum profitability for their products, coupled with high production costs, is a significant driver for farmers to use more PPPs. 4

2.1.7In addition to economic pressure, other factors influencing farmers' choice of plant protection products relate to each country's specific agro-ecological conditions, purchasing habits and consumer behaviour, as well as social and demographic factors. 4

2.1.8There is also no monitoring system that is efficient enough to make it possible to know whether EU rules have promoted greater implementation of IPM systems. Monitoring and enforcement of the law is also considered to be a weakness of the SUD, as well as the absence of effective penalties for those who fail to comply with the regulation. In addition, a better system is needed for recording data with indicators broken down by sector on the quantity of plant protection products used, both at national and EU level. 4

2.1.9Furthermore, where the social and employment-related aspects are concerned, some Member States have on occasion identified poor professional practices by some pesticide users who in practice fail to comply with safety procedures and who have been reported to the relevant authorities. 4

2.2Relevance 4

2.2.1The new EU governance model requires an ever-increasing degree of coordination and cooperation between the various existing public policies. Some of the new policies emerging as part of the new Green Deal will therefore have a significant impact on policies affecting not only the SUD itself but also more comprehensive policies such as the common agricultural policy (CAP). 4

2.2.2In the same vein, the surveys and missions carried out for this report reveal a broad consensus on the importance of the CAP and its ability to create synergies with other policies and actions related to sustainability goals. While the possibility of exploring new avenues and ways of connecting different policies to boost environmental ambition is broadly accepted, the information provided also shows the need to prevent such actions from jeopardising or compromising the funds and resources allocated to meet the targets and goals set out in the CAP. 5

2.2.3Similarly, as they contain actions that have direct effects for regulating the SUD, the measures introduced under the new European Green Deal and the Biodiversity 2030 and Farm to Fork strategies should be thoroughly assessed in order to prevent any negative impact on farmers' incomes. In this respect, the information that has been provided reveals a shared view of the need to carry out sectoral impact assessments quantifying the effects of the implementation of the new objectives in relation to the reduction of plant protection products, under the Farm to Fork strategy. 5

2.2.4Furthermore, the implementation of new measures or actions relating to the revision of the current SUD should take into account the objectives, principles and nature of the CAP (Article 39 TFEU) in such a way that resources aimed at tackling the low profitability of farmers are not put at risk or compromised. The set of actions and policies contained in the Green Deal should also take into account sustainability as is clearly recognised in all of its three aspects: environmental, social and economic 5

2.2.5There are also serious concerns regarding the policy of importing food from third countries which has been treated with plant protection products that are not authorised on the European single market. It is therefore essential that the EU implements the existing rules, applying the principle of reciprocity to agri-food products from third countries. Controls and monitoring should also be strengthened to prevent pesticides which are not permitted under European legislation entering the EU. Both issues need to be specifically taken into account as they prevent EU farmers from competing on a level playing field, particularly in terms of costs and prices and also because of their negative effects on issues related to food safety, fraud and consumer information. In this context, it is important to defend the importance of and continue demonstrating commitment to the model of sustainable European agriculture, without making farmers less competitive. It is worth noting, in this regard, that 68% of respondents believe that, given the trade-off between profitability and sustainability, this tension will result in a significant loss of competitiveness for farmers. 5

2.3Information on pesticides and civil society participation 6

2.3.1There is a widely-held view that organised civil society has not been involved in any meaningful way in the design, implementation, monitoring and evaluation of the SUD. Although there are some examples of active participation in some of the countries analysed in the sampling, the actual impact and ability to influence remain very low overall. While it should be reiterated that this has been the most commonly observed trend, it is worth highlighting different situations such as Sweden's, where a high degree of participation in the design and evaluation of public policies has been recorded, mainly due to the high percentage of civil society participation in the public consultation processes launched for this purpose. 6

2.3.2There is therefore a rather limited influence on decision-making in the area under consideration, which is explained in particular by the complexity and overly technical nature of the matter. This view is held by 86% of respondents, who believe that European citizens and civil society lack sufficient information concerning the rules on the use of pesticides and their management. 6

2.3.3Most of the information gathered suggests that the inherent technical difficulty and the high level of expertise required act as a barrier to greater participation by the organisations involved in the design of pesticide policies. This in turn explains why a large majority believes that the debate is often affected by ideological pressures and that the scientific and academic community should play a much greater role in outreach, communication and information work on pesticide use. 6

2.3.4At the same time, there is some evidence pointing to considerable interest in issues related to pesticide use on the part of civil society organisations as well as the non-specialised public in general. 6

2.3.5In addition, this topic has attracted a lot of media attention lately. This is particularly evident in the high level of interest generated by all issues directly related to food safety and consumer prices due to their interaction with PPP policies. 6

2.3.6In general, despite the differences between countries, there is nevertheless a significant lack of awareness among citizens, and in particular among consumers, about the role and use of pesticides in accordance with both national and European laws. For this reason, some of the suggested recommendations include the launch of awareness-raising and dissemination campaigns in order to better inform the general public and policy-makers alike. Information should be disseminated, for example, on the factors involved in setting food prices, as well as on issues more closely related to product labelling or certification. 6

2.4Outlook 6

2.4.1Farming in the EU is facing a situation marked by the emergence of new challenges and obstacles, but also by new opportunities. Issues such as the sustainability and competitiveness of the food system, farmers' difficulty in covering their production costs, climate change impact and action, the ageing of the population, the lack of generational renewal, the depopulation of rural areas, precision farming and digitalisation will certainly influence the future of agriculture and the way food is produced and consumed. 6

2.4.2A particularly important challenge is that of achieving a balance between the profitability needed to maintain agricultural productivity and life in rural areas and the protection of the environment. Special attention should be paid to EU trade policy with third countries in order to prevent the signing of trade agreements from undermining the European model of family farming and thus safeguarding the European agri-food model, which remains in the vanguard of food safety and quality standards. 7

3.EESC recommendations 7

3.1Effectiveness 7

3.1.1It is essential that this new governance model "leave no one behind": this means ensuring that all Member States can achieve optimal implementation of the SUD despite their differing starting points. 7

3.1.2One key element relates to training in plant protection products and increasing people's knowledge. This will mean: 7

3.1.3Improving the availability and cost-effectiveness of alternative solutions and new technologies for the use of plant protection products: 7

3.1.4Taking into consideration the different influences on and/or pressures faced by farmers: 7

3.1.5Improving the monitoring system and ensuring compliance with the SUD and with National Action Plans: 8

3.1.6Achieving improvements in practices related to the health and safety of users of plant protection products: 8

3.2Relevance 8

3.2.1To ensure that the CAP remains one of the EU's core policies, making it possible to maintain a sustainable European agricultural and livestock model which, based on a model of professional, family and cooperative farming, allows farmers to pursue economically viable activities while supplying the EU with safe, healthy, good quality and affordable food. 8

3.2.2To move towards greater harmonisation and consistency between the different EU policies and legislation: the CAP, the SUD, the Biodiversity strategy, the Green Deal, the Farm to Fork strategy, etc. 8

3.2.3To carry out impact assessments on the possible effects of the reduction targets currently set in the Green Deal and the Farm to Fork strategy; these must always be based on science and avoid confining the debate to ideological stances. 8

3.2.4To promote a fair trade and competition policy in the EU common market, particularly with regard to the potential negative effects of imports from third countries. This means strengthening controls and monitoring imports from third countries, and further European harmonisation in customs matters. 8

3.3Information on pesticides and civil society participation 8

3.3.1Implementation of the new directive should place greater emphasis on investment in training and information for pesticide users. 8

3.3.2Organised civil society, and especially those organisations with expertise in the field of pesticides, should be more closely involved in the design, monitoring and future evaluation of the new directive. 9

3.3.3The quality of information to the general public, and especially to consumers, on the role of pesticides needs to be improved. 9

3.4Outlook 9

3.4.1The medium- to long-term outlook for food policy, agriculture and food safety is characterised by the emergence of new challenges and threats but also of new opportunities. The EU must therefore find a way of adopting a holistic approach to the role of pesticides, involving in a balanced way the entire agri-food system and consumers, with the ultimate aim of continuing to ensure a healthy and safe food supply for an ever-growing world population. 9

1.Introduction 15

4.Data collection 16

5. Sampling 16

5.1Fact-finding meetings 16

5.2Questionnaire 16

5.3Breakdown of respondents 16

6. Primary data: findings and analysis 17

6.1Effectiveness 17

6.1.1Achievements in the implementation of the SUD and the NAPs 17

6.1.2Obstacles to effective implementation of the SUD and the NAPs 19

6.2Relevance 25

6.2.1Role of aid and other public policies in relation to the application of pesticides 26

6.2.2The SUD in relation to the CAP 26

6.2.3The SUD in relation to the Green Deal and the Farm to Fork Strategy 27

6.2.4Competition with third-country imports 30

6.3Information on pesticides and participation of civil society 30

6.3.1Information available on pesticides and public interest 30

6.3.2