Analysis of CMR and Endocrine Disruptors in the EU Food Chain

The Commission’s proposal to amalgamate Member States into three multi-national authorisation zones (Map 1) has no actual basis in terms of agricultural, plant health, and environmental (including climatic) similarities as suggested in Article 3. The authorisation groupings proposed are arbitrary, and bare little resemblance to various scientific attempts at dividing Europe into eco-climatic zones. The Habitats Directive, for example, recognises 9 different bio-geographical regions within the EU; few of which are arranged in accordance with national borders (see Map 2). While the European and Mediterranean Plant Protection Organisation’s (EPPO) recent attempt at identifying regions of ‘comparable climate’ with regards to pesticide authorisations concluded that Sweden and Denmark should be grouped with Germany; Eastern Europe should be a zone in itself; the northern half of France should be grouped with Benelux; and four zones should be created in total – a radically different arrangement to that proposed by the Commission (see Map 3). The Commission’s proposed multinational zones are further undermined by high resolution assessments of European climatic variation made using satellite-based remote sensing technology which show the EU to be a dynamic mosaic of microclimates1 (see Map 4): not a small number of discrete climatic blocks aligned according to 20th century political boundaries.