Civil society intervenes in the debate on the proposed regulation that will replace Directive 2009/128/EC, on the ‘sustainable’ use of pesticides. (1)
This is followed by an analysis of the European Commission’s proposed text, demands for reform from a coalition of environmental and health protection associations, and arguments in support of them.
1) Sustainable use of pesticides, the proposed EU regulation. Foreword
The recommendations made by the ECA in 2020 have actually been taken into account, at least in part, in the proposed EU regulation on the sustainable use of pesticides. (2) Where it is recognized that:
- ‘the application of integrated pest management is mandatory for farmers, but it is not a requirement for receiving payments under the common agricultural policy [CAP, ed.
- the system for enforcing this obligation is weak,
- available EU statistics and new risk indicators do not show the extent to which this policy has succeeded in achieving sustainable use of plant protection products,
- the Court makes recommendations related to the verification of integrated pest management at the farm level, the improvement of statistics on plant protection products and the development of better risk indicators.’
2) European Commission, a weak proposal
The proposed regulation adopted by the European Commission, however, appears weak in addressing the environmental and public health crisis caused by theabuse of pesticides, herbicides and other agrotoxics. As well as the microplastics they contain.
The only solution to out-of-control chemical contamination of ecosystems-involving the most dangerous and toxic active ingredients, the increase of which has also been recorded in Italy, from 2012 to 2020 (see para. 6)-is organic farming. But his support, once again, appears to lack concreteness.
3) EU Farm to Fork Strategy
The EU Farm to Fork strategy, on closer inspection, had emphasized the need to go beyond the goal of reducing pesticide use, precisely by increasing the area of organically farmed land:
- given the ‘urgent need to reduce dependence on pesticides and antimicrobials,’ a willingness was expressed to
- ‘reduce overuse of fertilizers, boost organic farming (which is to reach the target of at least 25 percent of the EU’s agricultural area by 2030),
- Improving animal welfare and reversing biodiversity loss‘. (3)
4) European Parliament, resolution 12.2.19
The European Parliament in turn-in its resolution 12.2.19 on the implementation of Directive 2009/128/EC, referred to in recital 3 in this proposal (recital 3.J), had already:
- highlighted that ‘organic farming plays an important role as a system with reduced pesticide use so it should be further encouraged.’
- called on the Commission to propose a binding and ambitious EU-wide target for pesticide use reduction. However, the lobbies of the agrochemical giants have unfortunately prevailed, as seen in the non-reform of the CAP.
5) Allowable inputs in organic farming, a value ignored
The draft regulation under consideration once again ignores the value of the 60 active substances authorized under Regulation (EC) No. 1107/2009 as inputs for organic farming. Although they, far better than others, can fulfill the goal of reducing the use of the most dangerous pesticides.
These substances have indeed exceeded the most stringent requirements for (substantial absence of) toxicity, persistence, and risk to ecosystems and health. And they were therefore included in Annex I to reg. EU 2021/1165, with the specific aim of increasing the UAA (utilized agricultural area) dedicated to organic in and around all sensitive areas.
5.1) Allowable inputs in organic farming, versatility
It is worth noting that all 60 inputs authorized for organic farming under Reg. EU 2018/848 ‘may be used in organic production, provided their use has also been authorized in non-organic production.’ In addition:
- ‘the Commission has already evaluated the use of certain products and substances in organic production on the basis of the objectives and principles laid down in Regulation (EC) No. 834/2007 of the Council‘,
- ‘The selected products and substances were subsequently authorized under specific conditions by Regulation (EC) No. 889/2008 of the Commission and listed in certain annexes to that regulation‘, and it was deemed
- ‘appropriate to include these products and substances in the restricted lists to be drawn up on the basis of Regulation (EU) 2018/848.’
5.2) Input for organic farming, non-harmful chemistry.
Out of a total of 350 pesticides allowed in Europe today, 26 of the 60 active substances allowed in organic farming contain chemicals, often of natural origin and widely occurring in nature. Unlike the agrotoxics allowed in conventional agriculture, however, these 26 inputs are characterized as non-harmful chemistry. Their list follows:
carbon dioxide
chitosan hydrochloride
sodium chloride
deltamethrin (only in traps)
Ethylene (only on bananas, potatoes and citrus fruits)
diammonium phosphate (only in traps)
Ferric phosphate (among low-risk substances)
fructose
potassium hydrogen carbonate
sodium hydrogen carbonate
calcium hydroxide
copper hydroxide (candidate for substitution)
lambda-cyhalothrin (only in traps)
L-cysteine
lecithins
kerosene oils
copper oxychloride (candidate for replacement)
copper oxide (candidate for replacement)
hydrogen peroxide
calcium polysulfide
Bordeaux mixture (candidate for replacement)
sucrose
alumino silicate (kaolin)
Tribasic copper sulfate (candidate for substitution)
spinosad
sulfur.
6) Failed goals
The objectives stated in this proposed EU regulation are identical to those in Directive 2009/128/EC. Concepts introduced four decades ago, in dir. 91/414/EEC (on the placing of ‘plant protection’ products on the market), taken up first in decision 1600/2002/EC(Thematic Strategy for the Sustainable Use of Pesticides) and reg. EC 396/2005(maximum levels of pesticide residues in or on food and feed of plant and animal origin). Yet:
- pesticide sales have increased, in Italy as elsewhere. According to ISTAT, purchases of active ingredients not allowed in organic farming grew from 29,226 tons in 2012 to 30,994 t in 2020. Goal failed.
- ‘society‘ – as the European Commission itself notes, on page 2 of the proposed regulation – ‘is increasingly questioning the risks associated with the use of pesticides, and this is evident in light of the large number of petitions, two European citizens’ initiatives and parliamentary questions on the subject.’
7) Ten essential principles
A paradigm shift is indispensable and must include ten essential principles:
1) obligation to sell ‘plant protection’ products with electronic invoicing,
2) Allow the purchase and use of plant protection products only with a phytoiatric act drawn up by a licensed professional (as also required by the Council of the Order of Agronomists and Foresters),
3) Prohibit online purchases of plant protection products, the smuggling of which-as has already been denounced-undermines any legislation,
4) protect populations from thedrift effect with appropriate binding rules and deterrent penalties,
5) Introduce mandatory prior warnings to the use of plant protection products on the perimeter of the area to be treated,
6) Always prohibit all aerial spraying,
7) Always ensure suitable distances from waterways and protection of groundwater (which, once polluted, can no longer be cleaned up),
8) Prescribe, for treatments not allowed in organic farming, appropriate distances from organically farmed land. To be qualified as ‘sensitive areas’ in the same way as the ‘non-productive areas’ once managed to keep the land in good agronomic and environmental condition (GAEC),
9) Carry out progress monitoring using statistics on the 290 active ingredients not allowed in organic farming, rather than generically on all 350 active ingredients on the market, in order to overcome the shortcomings of the risk indicators that the European Court of Auditors itself has asked to make functional,
10) Recognize the right of graduate and undergraduate professionals in the field to express themselves and give advice in an area that is first and foremost theirs, even before the ‘licensed consultants’ of licensed retailers.
8) Conclusions
It is necessary to protect the ecosystems and biodiversity that historically characterize European agricultural production, countering the current trend of homologating it to the failed models adopted in other non-EU countries, from the U.S. to Brazil. Therefore, any hypothesis of deregulation of new GMOs, fomented even in Italy, must also be ruled out in the face of the concrete risks already highlighted by independent science.
9) Pesticide regulation, the demands of civil society
The Italian associations and companies mentioned below (see section 9.2) have joined the consultation launched in France by the NGO Générations Futures, with the attached document that aspires to offer useful insights on how to protect the environment, agriculture and the health of citizens in the Old Continent.
9.1) Guide to reading the document
Calls for reform of the proposed ‘pesticide regulation’ are highlighted in yellow, with reduced font of the parts to be deleted. Passages worthy of closer attention are set out in bold type, and the footnote numbering follows that of the original text of the Commission’s proposal (regulation and annexes).
9.2) The signatories
Mario Apicella, AltragricolturaBio technical director.
Marco Bertelli, CREAA president
Matteo Carbone, AltragricolturaBio technical director.
Gianni Cavinato, president of the Consumers Users Association
Michela Del Vecchio, AltragricolturaBio technical director.
Dario Dongo, Égalité
Mauro Falcione president Vitaly Bio
Patrizia Gentilini medical oncologist and hematologist
Francesco Illy, organic farm
Giovanni Malatesta, organic farm
Marco Mameli, president Assotziu Consumadoris Sardigna
Maurizio Mazzariol, president Altragricolura Bio
Giacomo Meloni, Sardinian Trade Union Confederation
Riccardo Piras to Cunfederazione Liberos Massaios e Pastores Sardos
Eugenio Serravalle, Assis president
Marco Tiberti, president European Cosumers Italy
Dario Dongo and Marta Strinati
ANNEX The Italian counterproposal to the new EU Regulation on the sustainable use of pesticides
Notes
(1) Dario Dongo. Pesticide reduction, the proposed EU regulation. GIFT (Great Italian Food Trade). 25.6.22
(2) Dario Dongo, Marina De Nobili. CAP, pesticides and biodiversity. EU Court of Auditors Report. GIFT (Great Italian Food Trade). 29.7.20
(3) Dario Dongo, Marina De Nobili. Farm to Fork special, the strategy presented in Brussels on 5/20/20. GIFT (Great Italian Food Trade). 24.5.20
(4) Pesticide Regulation, public consultation (2022) https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12413-Uso-sostenibile-dei-pesticidi-norme-UE-aggiornate-_it
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
Professional journalist since January 1995, he has worked for newspapers (Il Messaggero, Paese Sera, La Stampa) and periodicals (NumeroUno, Il Salvagente). She is the author of journalistic surveys on food, she has published the book "Reading labels to know what we eat".
