On 12 May the UK Pesticides Safety Directorate (PSD) published an assessment of the Commission’s proposals for ‘cut off’ criteria and substitution provisions, and of the amendments proposed by Parliament.1 The PSD’s analysis is presented both in terms of substances affected and the potential impacts on UK agriculture.
PAN Europe welcomes the PSD study in providing a clear and transparent contribution to the formulation of EU pesticides legislation. We also note that the PSD’s estimates of the proportion of pesticides affected by the Commission’s ‘cut off’ criteria reflect those provided by the Commission and by PAN Europe.
At the same time, the report’s findings must be considered within the parameters of its methodology. The study includes no assessment of the role that new substances not yet included in Annex 1 might play in future crop protection. Nor does it take into account the positive influence that regulatory decisions taken today may have on the development of newer, safer pesticides tomorrow. More problematically, the proposed EU legislation is considered only in terms of agrochemical crop protection; thus giving no consideration to the advantages of protecting insects as pollinators, nor to the human health or environmental benefits derived from eliminating Europe’s most hazardous pesticides from the EU food chain.