Final EU Proposals on Crop Protection Products

On  Monday 12 January 2009 members of the European Parliament will vote on the final proposals to restrict the use of crop protections products (EU proposals on cut-off and substitution criteria –plant protection products directive 91/414). The final proposals follow agreement by the Council, Commission and Parliament in trialogue meetings and do not include a full impact assessment, which FPC has been calling for.  The proposals will have a significant impact on horticulture, leading to the removal of key products over a period of time.

We are aware that Robert Sturdy MEP will be proposing amendments, which cover:

• an extension of the scope of the five year derogation criteria 
• a reinforcement of the need for an impact assessment, and
• changing the definition of endocrine disruptors.

We are asking MEPs to vote against the compromise and to support the Sturdy amendments should the trialogue compromise be voted down.

We are concerned that the final proposals to introduce cut-off criteria and substitution of crop protection products (Plant Protection Products Directive 91/414) will affect adversely horticulture throughout Europe, as well as the international trade of fresh fruit and vegetables and subsequent availability of food. 

According to an updated agronomic assessment by the UK’s Pesticides Safety Directorate (PSD) the proposals could remove up to 23 per cent of crop protection products which are vital to the production of fruit and vegetables across Europe.  For a number of crops there would be no viable alternatives to control certain prevalent pests and diseases, resulting in significant losses in yield.  Loss of some herbicides would seriously affect weed control for carrots, parsnips and onions, and PSD assesses there is the potential ‘for up to 100 per cent yield loss on carrots’.

Even within the European Parliament the need for a full impact assessment has been recognised.  A recent study [‘The consequences of the ‘cut off’ criteria for pesticides: alternative methods of cultivation’] published by the EU policy department looked at the proposals and investigated alternative methods of cultivation within an integrated pest management (IPM) framework.  The EU study concluded:   ‘Chemical pesticides are a vital part of crop protection and they need to be used more within the framework of IPM. More impact assessments need to be done on the consequences of the ‘cut-off’ criteria’.

The horticulture industry already uses IPM extensively in the UK and has a limited choice of crop protection products approved for use on horticultural crops.  These proposals will axe a number of key substances which are critical to the production of indigenous produce such as peas, carrots, parsnips, onions, and will affect fruits such as strawberries, raspberries, pears and apples.

The European Council has advised that a five-year derogation which will allow the continued use of active substances to control a ‘serious danger to plant health’ is expected to be used only on an exceptional basis.  In reality this will not provide a solution in a day-to-day working environment . The horticulture industry is unlikely to have new alternative products for use over the next ten years, given that most substances awaiting evaluation are variations on existing substances, and the long lead-in times and additional costs for development and approval of products for use on horticultural crops.

The proposals could have severe implications for pest management in Europe and globally with the spread of resistant pests, weeds and diseases, prevalent as a result by default of increasing use of surviving active substances.

The original intention of the proposal was to safeguard health of the consumer, yet there is no evidence that these proposals will achieve this.  What’s more, around 1.9 million less well off people in the UK are eating less than one serving of fruit and vegetables a day.  With increasing levels of obesity across Europe, particularly among young people, we should be encouraging more people to eat fresh fruit and vegetables and ensuring that growers have the necessary tools to provide an affordable and sustainable supply of fresh produce.

The Prime Minister Gordon Brown and Hilary Benn both share the industry’s concerns, with Gordon Brown commenting: “I very much share the concerns you raise about the potential impact of these proposals...we remain concerned that the European Parliament’s Committee is continuing to press for changes which could damage agriculture and food production without securing meaningful benefits for health or the environment.”

In a recent survey (‘Report on research into the social impacts of food prices in food’ carried out by England Marketing - http://www.englandmarketing.co.uk/reports.htm ) consumers have indicated that they will find it difficult to manage an increase of 30 per cent in food prices. Only 10 per cent of consumers said that they would look to reduce their family intake of fruit and vegetables, however they expressed concerns about maintaining a healthy diet if there were significant increases in food prices.   Similarly charities indicated that people with less disposable income will eat less fruit and vegetables, affecting their physical health and well-being, and leading to greater pressure on the health service.  The majority of people (85 per cent), particularly from low income households, said that they would change the way they vote for MEPs if they believed that their current MEP was voting in favour of legislation that would increase the cost of food.

The Fresh Produce Consortium is calling on members of the European Parliament to retain a range of products that allows the horticulture industry to provide good quality healthy produce in an affordable sustainable manner.  We wish to request your support by rejecting the compromise agreement and to call for a comprehensive assessment of the impact of these proposals prior to their implementation. 

Examples of the impact on specific crops

Peas and beans - Few approved herbicides will remain with the loss of pendimethalin and other herbicides are less effective.  No pre-emergence products in green beans.  No reliably effective fungicides available in peas.

Carrots and parsnips - In the long term there will be very significant losses in yields. The potential loss of insecticides (e.g. pyrethroid seed treatment) will lead to reduced yield and quality.  The loss of herbicides, pendimethalin and linuron, will cause increased weed problems, with the potential for 100% crop loss.  Few other herbicides will remain and will give a lower level of weed control.  For example, there will be no products available for post emergence control of potatoes, thistles, docks or volunteer oilseed rape.  There will be significant crop loss and increased production costs without triazole fungicides for prevention of rotting diseases.

Potatoes - The loss of pendimethalin, linuron and potentially metribuzin will greatly reduce herbicide options.  Mancozeb, which is vital to prevent the build up of resistance to blight, will be lost.  There will be potentially greatly reduced insecticide options for control of aphids.  The remaining nematicides are all potentially neurotoxic and could be lost depending on definition.

Leeks - The loss of pendimethalin would make pre-emergence weed control difficult atbest. The loss of ioxynil as post emergence weed control would only increase hand weeding costs as it is the mainstay of all weed control.  If triazoles were to go the rust control in leeks would not be possible with other fungicides, therefore quality and yield would be reduced.

Asparagus - Cypermethrin (and lambda-cyhalothrin – approval pending provide the only means of control of asparagus beetle at present. Poor control during spring and summer may result in asparagus spears being unmarketable and the fern defoliated. The loss of pendimethalin, metribuzin and linuron would seriously limit the ability to control weeds effectively in asparagus. Once the fern is established, inter-row cultivations are difficult, time consuming and therefore expensive.  Hand weeding large areas is prohibitively expensive in the UK. If the above were implemented, the cost of growing asparagus in the UK would rise significantly at a time of increasing pressure on price.

Tree Fruit - The loss of the acaricide bifenthrin and the insecticide deltamethin would not cause major problems but the potential loss of clorpyrifos, cypermethrin and pirimicarb would have a more profound effect.  If thiacloprid was also classified as an endocrine disruptor then aphid control would be further compromised.  The loss of the triazole group would have a major impact as this is the mainstay to control the main diseases scab and mildew on apples and pears, in addition to a range of other diseases on these and other crops.  The loss of mancozeb would reduce the number of alternative actives against scab and mites and the loss of thiram and iprodione would influence storage rot incidence. The further loss of amitrole, 2,4-D, dichlorprop-p, glufosinate,  MCPA, mecoprop-p and pendimethalin would cause major problems with weed control in orchards.

Leafy Salads - Mancozeb is vital for downy mildew control (it’s estimated that 10% of all crop losses in 2008  were due to downy mildew). Thiram is important in ensuring that seeds are free from seed borne diseases which may threaten the establishment of crops. Weed control with baby leaf herb crops such as Flat leaf Parsley and Coriander would be severely affected with the loss of both pendimethalin and linuron for crops grown outdoors.  There would be a big effect from the loss of pyrethroid insecticides.  The control of Bean seed fly in spinach crops with the loss of tefluthrin would become extremely difficult. The control of flea beetles would become unmanageable, with deltamethrin, lambda-cyhalthrin and alpha-cypermethrin all playing a very important role in control.

Herbs - There is an expected loss of about 40% of currently approved substances.   The situation is more grave than the number suggests as the lost actives are often key substances e.g. pyrethroid insecticides (deltamethrin etc); conazole (tebuconazole, prochloraz) and dithiocarbamate (mancozeb etc) fungicides; and several key herbicides (linuron, pendimethalin, ioxynil).