Despite 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.
The 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.
While 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.
At 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.
Furthermore, 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.
Other 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.
In 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.
There 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.
Furthermore, 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.