The Pesticide Action Network (PAN) Europe and the European Environmental Bureau (EEB) take the opportunity to comment on the Commission Communication “Towards a Thematic Strategy on the Sustainable Use of Pesticides”.
PAN Europe and the EEB in general welcome the initiative of the Commission, but believe that the Commission’s approach falls short of introducing strong and immediate European action.
PAN Europe and the EEB have drafted a detailed pesticides use strategy in the text for a Directive on Pesticides Use Reduction in Europe (the PURE directive). We believe that such a Directive will be crucial to effectively meet the challenge of ever growing pesticides use and better protect Europe’s citizens and environment from the connected risks. We are disappointed that the Commission’s approach fails to propose such a European approach and delays action into the future, as it provides almost no targets or timetables for the actions it proposes.
In May 2002, the European Parliament requested the Commission to publish a proposal for a Directive establishing a programme for a reduction in the use of pesticides, before July 2003. PAN Europe and the EEB also support this timeframe for a new proposal for a Directive. The Directive should constitute an important part of the Thematic Strategy and focus on pesticide use reduction as an essential element of risk reduction.
New European legislation to reduce pesticide use is needed inter alia because of the building evidence that pesticide use poses threats to children’s health and is causing increased contamination of groundwater, Europe’s primary source of drinking water.
These problems require immediate and European action. As highlighted in the PURE Directive, there should be, at a minimum:
- Mandatory reduction plans for all Member States with targets and timetables for use reduction and increased percentage of land in organic farming, including, for each Member State, a target reduction of 50% of the treatment frequency index within 10 years from a baseline year;
- IPM/ICM as a minimum for all EU non-agriculture and agriculture PPP uses
- Cross-compliance with ICM4 4 as a condition for CAP subsidies; more agrienvironmental support under CAP to go beyond ICM, e.g. to promote organic farming;
- Full access to information on pesticides held by authorities, including information supporting specific regulatory decisions in due time to allow for response from the general public, and participation of public interest groups, as observers, in all meetings where decisions are taken related to pesticides and their use.
Our specific comments (see next pages) are set forth under each of the elements for a Thematic Strategy in the Commission Communication, in the text contained within the boxes. Where appropriate, we have referred to relevant provisions in the PURE Directive.