PAN Europe’s Position Paper on the EU proposal for a Regulation on Sustainable Use of Plant Protection Products

On 22 June 2022, the European Commission published its proposal for a Regulation on Sustainable Use of Plant Protection Products (SUR1 ) and repeal the current EU Directive (128/2009/EC) on the Sustainable Use of Pesticides (SUD2 ). PAN Europe’s main demands: 

1. The name of the SUR needs to be updated to the "Regulation for the reduction of the use of chemical pesticides".
2. The subject and the scope of the SUR must at least be in line with, and improve upon, the SUD. The precautionary principle must remain key and the aim should be to establish a longterm vision - also beyond 2030 - with clear pathways on how to get there, banning synthetic chemical pesticides in the EU by 2035.
3. The EU objective must be increased in ambition to a reduction of 80% of synthetic chemical pesticides used in the EU by 2030, and this percentage must stay applicable to each member state, by removing the idea of intensity and historical reference.
4. To start with, 100% of the more toxic pesticides should be completely phased out by 2030, not just 50%. Pesticides from the so-called "Candidates for Substitution list" should have already been phased out since 2015, from when Member States were required to substitute them. Alternatives already exist and Member States have not implemented the rules since 2015.
5. The main purpose of each of the member states’ National Action Plans (NAPs) must be to define reduction targets, timelines and measures to reduce dependency, not only for the five most used pesticides, but for all chemical pesticides. The NAPs need to give a clear overview of the current situation in Member States and how they aim at moving towards a pesticide-free agricultural model with clear milestones.
6. Quantifying pesticide applications: decade-old measuring and record-keeping obligations must be properly implemented, ensuring effective and easy-to-use digitised recording and transfer of pesticide use and IPM data from the farm to the member state to the commission, in line with SAIO regulation
7. Agroecological practices, including organic farming practices, need to be put at the heart of IPM rather than precision farming adapted to pesticide use, as is promoted by the chemical industry, but which can shift but maintain farmer input dependency. For this to happen there is a need to define and classify what these agroecological practices are, while at the same time better define the agronomic practices being defined as Integrated Pest Management (IPM). It is also time to define what is not IPM, and update the crop-specific guidelines accordingly. Finally, it is crucial that farmers apply all appropriate monitoring before deciding to intervene, including with the help from independent farm advisers.
8. Ban chemical pesticides in all sensitive areas (including railways and roads) as well as for private uses.
9. Introduce an EU-wide pesticide tax to start applying the polluter pays principle.
10. Integrate pesticide reductions and IPM into the CAP, in objectives and indicators, and use mutual funds to cover risk while using pesticide-reducing techniques as a tool to reduce input dependency.
11. Encourage front-running political actions towards a pesticide-free future.