Ref. Ares(2020)3454525 - 01/07/2020
28/01/2020
ECPA’s position on the up-coming Farm to Fork
initiative
The European Crop Protection Association (ECPA
) welcomes the European Commission’s
Green Deal and supports achieving a climate neutral Europe by 2050. As an industry that
supports farmers and food production, we particularly appreciate the holistic approach proposed to
address the climate crisis. Farmers have been strongly hit by climate change and we have tools that
help them to adapt and the potential to innovate for carbon capture in agriculture. To really improve
sustainability, a careful assessment of trade-offs based on evidence, not rhetoric, is needed. As a
result, all stakeholders, with different viewpoints, must be fully consulted to deliver this agenda and
the transitions that are needed as rapidly as possible.
We understand Plant Protection Products (PPPs) will be one feature of the Green Deal and we hope
for a well-reasoned,
science-based discussion with Commission proposals focused on a
limited
set of policy instruments to avoid a fragmentation of the rules across different legislations.
We also would like to insist on the need to accelerate innovation for the critical challenges
ahead. A fine balance needs to be struck between climate change mitigation measures and ensuring
the continuation of safe food production. Under a changing climate, farmers will require more
innovative tools to control new threats from mycotoxins and invasive alien species, as predicted by
EFSA. ECPA and its members are fully committed to contribute in a constructive way to the
European Green Deal discussion and will make clear commitments to support the Commission’s
agenda, especially in the areas of circular economy, R&D investment for greener ways to protect
crops and training of end-users of our products to ensure they are used properly and only when
necessary.
We welcome the intention of the Farm to Fork strategy covering the whole agri-food chain, from
producers to consumers. The EU law quite rightly ensures that our products may only be sold where
there is no harmful effect on people and no unacceptable impact on the environment, and should
only be used when needed. Despite the existence of these safety measures, we recognise societal
concerns associated with pesticides and we acknowledge the Commission’s willingness to reduce
both
risk and use. While this will be very challenging for us to deliver on,
ECPA views the use of
the harmonised risk indicator 1 (HRI 1) developed and published by the European Commission
as a reasonable way to measure the hazard reduction of pesticides used in both organic and
conventional agriculture. We want to play our part and having already reduced pesticide application
by 97% during the last 60 years, we will re-double our efforts to meet this challenge. Any proposal
for HRI targets should use a
baseline level made from the average index in the period 2014-
2017. We believe that taking an average over 4 years will accurately reflect the intrinsic and real
variability of pesticide use (e.g. changes in use due to climatic conditions, disease and pest
pressure). We would like to encourage the Commission to consider adding an indicator that also
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28/01/2020
measures the consequences that farmers will face if no alternative solutions are brought on time to
the market.
ECPA represents EU market leaders supplying pesticides to the organic, low till, conservation,
agroforestry and conventional agriculture models. As solution providers, we deliver safe products for
all types of production systems; products of natural origin such as microbials, natural substances or
pheromones and products of chemical nature, to adequately control pests, diseases and weeds. We
believe that organic production has a role to play in the mix of agricultural systems that we defend
and therefore
we support the European Commission’s aim to increase organic production in
Europe in order to meet growing consumer demands. However, it is important to note that there
are
ecological trade-offs implied by an increase of organic agriculture, which should be
considered. These include an increased overall volume of pesticide use in Europe as some products
commonly used in organic agriculture need to be applied in much larger quantities than low rate
chemical alternatives, more agricultural land is needed to maintain the same level of productivity and
more greenhouse gas emissions are likely due to more interventions in the fields. We believe that
a truly holistic approach is needed to balance these tensions and achieve the climate action that is
needed whilst preserving Europe’s capacity to produce enough food for an ever-growing population.
In this perspective,
we would welcome the creation of a specific indicator linked to the use of
pesticides in organic agriculture.
Finally, DG SANTE is preparing the final report regarding the
REFIT exercise conducted on the
Regulations 1107/2009 regarding the placing on the market of pesticides and biopesticides and
396/2005 on maximum residue levels of pesticides. We reiterate our view that
the legislation is
fit for purpose and delivers on its goals to protect human health and the environment. We
believe that any
necessary improvements can be achieved by ensuring better implementation
of the current system to enable innovation, rather than by amending the legislation. Targeted
improvements would allow the necessary tools for change to reach European farmers faster, and
continues to ensure that there is no risk to the food supply in Europe. On the latter point, we would
also appreciate a reasonable EU approach on the MRL/IT policy applicable to treated commodities
coming from third countries. Smallholder farmers who produce important crops for Europe such as
tea, coffee, cocoa for chocolate, exotic fruit etc. have different disease and pest pressures to deal
with, especially in tropical environments. In order to achieve the zero hunger and no poverty
Sustainable Development Goals it’s important that these farmers have the right tools, too. We believe
DG AGRI and DG TRADE should be associated to this policy discussion as its impact can be
important and it needs to be compatible with the EU WTO SPS obligations.
Overall, we are concerned that the European regulatory and policy environment is less and less
prone to allow the development and application of innovation in the agricultural sector, and that in a
foreseeable future, European farmers will continue to lose tools faster than new ones can be
introduced.
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