Current crop yields and quality in the UK and much of the EU will be unachievable if European Commission and European Parliament proposals to change EU agrochemical rules are fully realised, warns the UK. It’s predictions are based on proposals to introduce hazard-based cut-off criteria as a basis for banning ais or substituting them for alternative products. The UK's impact assessment, which has already been presented to EU Ministers discussing the proposals, was issued by the UK Pesticides Safety Directorate (PSD) this month.
The Commission's proposals envisage the introduction of hazard-based criteria as part of the revision of the EU agrochemical registration Directive (91/414). In its first reading, the Parliament sought to extend the range of hazard criteria used. Its amendments were rejected by the Commission but the proposals will still have to return for a second parliamentary reading later this year. In the meantime, the ongoing dispute between EU member states and the Commission over the use of hazard criteria meant that EU Agriculture Ministers were unable to reach an agreement on the proposals in May.
The PSD report assessed the impact of the original Commission proposals and the Parliament's amendments on 286 active ingredients. The ais include ones that have already received EU approval and been added to Annex I of Directive 91/414 and existing ais that are going through the EU review process. The impact assessment excludes: ais that are unlikely to be included in Annex I; ais in the fourth round of the EU review, which includes micro-organisms, plant and animal extracts, attractants and repellents, rodenticides and commodity substances; and new ais not yet included in Annex I.
The assessment concludes that the Commission's original proposals for cut-off criteria could remove from 5% to 15% of all the ais studied. The higher figure includes possible endocrine disrupters. For insecticides, 6-10% of ais would not be approved (5-10% in the UK). For fungicides, the loss is 8-32% (7-35% in the UK), while for herbicides, it is 4-10% (5-12% in the UK). If it is assumed that the lower figure applies through non-approval, the remaining percentage that would become candidates for substitution are 38% for insecticides, 20% for fungicides and 24% for herbicides. Overall, on an EU basis, 24% of the ais would become candidates for substitution, the report estimates.
Some of the affected ais are important in the UK for minor crops such as carrots, parsnips and onions, the PSD points out. Crop sensitivity to herbicides means that many ais are unsuitable for weed control. There is potential for up to 100% yield loss, it warns. The proposed endocrine disruptor criteria could impact particularly on fungicide availability and might result in 20-30% yield losses in cereals, it estimates. If potential endocrine disruptors are banned, there would be no fully effective ais for any of the major diseases of oilseed rape.
The Parliament's proposed amendments extend the range of criteria and shorten approval periods for ais that are deemed "candidates for substitution". The amendments on cut-off criteria could result in the loss of 35-40% of all ais in the EU, with the higher figure including possible endocrine disruptors. The percentage of ais that would not be approved is 65% for insecticides (66% in the UK), 31-43% for fungicides (35-49% in the UK) and 25-31% for herbicides (27-33% in the UK).
The Parliament's amendments on substitution would make 71% of the ais studied candidates for substitution on an EU basis. In terms of product categories, this would apply to 77% of insecticides, 64% of fungicides and 86% of herbicides. The Parliament wants approval periods cut to five years for such ais. This could lead to the loss of up to 85% of conventional ais after the five-year period, the PSD report estimates.
The combined effect of the Parliament's cut-off criteria and substitution proposals would be a loss of 82% of the ais studied, or 92% of 62 insecticides, 80% of 83 fungicides and 91% of 113 herbicides, the report concludes. Other forecasts point to up to 86% of ais, or 90% of sales, in the EU being affected by the proposals.
The Parliament's proposals would effectively leave no herbicide options for weed control in horticultural crops, while chemical control of blackgrass (Alopecurus myosuroides) in cereals would become "virtually impossible", the PSD says. The removal of various fungicides and insecticides would make seed potato growing "unlikely" and many horticultural crops "uneconomic".
If the full potential impact of the parliamentary proposals were realised, conventional agriculture as it is currently practised in much of the EU would not be achievable, the report concludes. In addition to major impacts on crop yield and food quality, there would be a very significant impact in amenity and industrial situations where weed control is important, it notes. There is also a potentially severe impact on resistance management, it adds.
The PSD report points out that the Commission's impact assessment for its original proposals on Directive 91/414 did not address the issue of hazard-based criteria. The Parliament also did not provide an impact assessment of its amendments, it notes.