Dear Ms. Health Commissioner Kyriakides,
We are writing to you concerning the issue of substitution of the most dangerous pesticides authorised in the EU, the candidates of substitution (CfS). More specifically, we would like to bring to your attention new research from Wageningen University (attached), which concluded that numerous alternative pesticide products containing candidates of substitution (CfS) are available in The Netherlands. The study’s outcome is in flagrant contradiction with what many Member States including the Dutch authorities (Ctgb and Ministry of Agriculture) replied in the context of the REFIT program and in the most recent survey on comparative assessment by the Commission (also attached). Indeed, on page 5 of the survey’s questionnaire, the Dutch ministry claims that the biggest difficulty in substituting candidates for substitution is the “Lack of (sufficient) alternatives under all conditions”. Apparently, the ministry sent you this information based on pure speculation, while it had no data to support its claim.