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Stakeholders' recommendations on the current EU regulation regarding plant protection products, focusing on lack of transparency in risk assessment, need for EU-wide measures, and abuse of emergency authorizations.
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PEST Committee hearing, 6 September 2018Stakeholders' recommendations on the current EU regulation on the approval of plant protection productsFranziska Achterberg, Greenpeace
Three issues • Lack of independent and transparent EU risk assessment • Lack of EU wide action on dangers for the environment • Abuse of emergency authorisations
(1) Lack of independent and transparent risk assessment • “The rapporteur Member State shall make an independent, objective and transparent assessment in the light of current scientific and technical knowledge.“ Reg. (EC) No 1107/2009, Article 11.2
(1) Lack of independent and transparent risk assessment • Use of unpublished industry studies without independent evaluation of the data • Copy-paste of industry evaluation of published literature studies
(2) Lack of EU wide measures • “In order to achieve the same level of protection in all Member States, the decision on acceptability or non-acceptability of such substances should be taken at Community level on the basis of harmonised criteria.” • Reg. (EC) No 1107/2009, Recital 10
(2) Lack of EU wide measures • Long-term risk to non-target vertebrates identified by EFSA ...
(2) Lack of EU wide measures • ... and passed on to EU Member States to deal with. • “… the risk assessment concluded for at least one of the representative uses that the risk was expected to be low.” (Commission response to the PEST Committee) • “Member States shall pay particular attention to (...) • — the risk to terrestrial vertebrates and non-target terrestrial plants.” (EU renewal of glyphosate)
(3) Abuse of emergeny authorisations • “(…) in special circumstances a Member State may authorise, for a period not exceeding 120 days, the placing on the market of plant protection products, for limited and controlled use, where such a measure appears necessary because of a danger which cannot be contained by any other reasonable means.” • Reg. (EC) No 1107/2009, Article 53 on Emergency Situations in Plant Protection
(3) Abuse of emergeny authorisations • Romania has “systematicallyissued 120 day emergency authorisations” for • neonicotinoid products each year since 2013. • (PAN Europe et al, 2017) Use of clothianidin, imidacloprid or thiamethoxam to control Agriotes spp in maize and sunflower is “scientifically supported“. (EFSA Technical Report, June 2018)
Recommendations • The RMS and EFSA should perform a truly independent evaluation and cannot rely on the industry’s interpretation of the data. All studies underpinning scientific evaluations should be publicly available. • The Commission, supported by EU MS, should consistently restrict or ban pesticides which can pose a danger to people or the environment. • EU MS should apply Article 53 on “emergency authorisations” as intended, and the Commission remind them of their obligations.