The pesticides authorization process has been harmonised at the European level through the Council Directive 91/414/EEC of 15 July 1991 concerning the placing of plant protection products on the market. During this time, it has sometimes served as a progressive example for the assessment of the impacts of chemicals on health and environment. But the risks connected with the use of pesticides prevail – including the contamination of groundwater, upon which 65% of the European drinking water production depends. The average use of pesticides per unit of land has risen, in spite of the increasing adoption of active ingredients with a higher activity per weight of active ingredient (source: EEA).
More advanced and progressive policy concepts and assessment tools for chemical substances have been introduced, such as the elimination of certain hazardous substances and the assessment based on intrinsic properties (OSPAR1 1998, introduced into the Water Framework Directive WFD; Swedish “New Guidelines on Chemical Policy” 2000) or the substitution principle leading to a comparative assessment of chemicals (Biocides Directive 98/8/EC). Moreover, many chemical policy processes have opened up for public interest groups (OSPAR, WFD Priority Setting, Risk Assessment of industrial chemicals) and gained from this increased transparency. The current pesticides authorization process is not only intransparent, but also suffers from a severe lack of democracy. Pesticides legislation in general should ensure full participation of the European Parliament in the same way as this is granted by legislation based on Art. 95 of the Treaty.
The “Commission Report to Parliament and Council on Progress in the evaluation of the active substances of plant production products, submitted in accordance with article 8(2) of Council Directive 91/414/EEC” now offers the opportunity to initiate the inclusion of these principles and tools -in line with the precautionary principle- also in the pesticides evaluation.
In this paper, PAN Europe and its partners call on the Commission to make use of the opportunity to propose a fundamental review of 91/414/EEC, which is aimed at modernising and harmonising the Directive in line with relevant EU legislation (e.g. WFD) and international agreements such as the OSPAR Convention.
Future pesticides regulation should be based on the highest protection level available in existing EU legislation or international agreements, in line with the Precautionary Principle. The overall objective of 91/414 should be that avoiding negative impacts on or dangers to “health, groundwater and the environment and human and animal health should take priority over the objective of improving plant production.” EU agricultural policy should aim at sustainable agriculture, and the pesticide authorization process should reconsider the degree of need for each individual pesticide.
PAN Europe does not believe that even carefully tested and assessed pesticides are safe. PAN Europe is committed to “fight for local, national and international agreements to restrict, reduce and eliminate pesticide dependence and to phase out and ban synthetic chemical pesticides, especially those that cause acute, chronic and endocrine disrupting effects” (PAN International Dakar Declaration). PAN Europe stresses that comments made here have to be understood in this context. For the pesticides authorization process we suggest a two-step procedure: I. Exclusion of non-acceptable active ingredients based on hazard criteria (cutoffs). II. Careful evaluation and control of other active ingredients not meeting these cut-offs.