Ref. Ares(2023)4550291 - 30/06/2023
full impact assessment with a view to securing nutrient supply and avoidance of
leakage effects.
3. Adequate and well-founded definition of sensitive areas
For sensitive areas, we feel that excluding the use of any PPP, especially if that includes non-
chemical measures (e.g. biocontrol) is
too extreme and will be very detrimental for
many regions that depend on agricultural production. Besides, without a precise
indication of which areas specifically are concerned and how these provisions should be
interpreted, this may lead to over interpretation and banning of all uses of plant protection
products on areas of land used for agricultural purposes. This
will have a huge negative
impact on agricultural production across the EU.
4. Unrealistic reduction targets in the current socio-economic circumstances
The
reduction targets for the use and risk of chemical pesticides by 2030 are clearly
overambitious considering the current socio-economic and political challenges. We call for a
fundamental readjustment of the EU Commission's proposals in this regard. The reviewing and
setting of new future targets must be based exclusively on sound scientific knowledge. Setting a
minimum reduction target as proposed by the Commission without a sufficient agronomic or
scientific basis is
particularly detrimental to countries that have already significantly
reduced the use of chemical and hazardous plant protection products.
5. A mandatory electronic register is unfeasible and may compromise
confidentiality of data
Copa and Cogeca
also categorically reject the demand for an electronic register for
(almost) all equipment for the application of plant protection products, as the
possible expense far exceeds the expected benefit of this measure and will
only increase the
workload and the economic and administrative burden on farmers. If data collection
pertaining to the application of plant protection methods is required,
any additional
bureaucratic and administrative burden for farmers should be avoided.
Furthermore, should we be required to share all data, we would also
require clarification on
the further use of the required data to avoid compromising the safety of farmers’
private and confidential information.
6. Making CAP voluntary funds mandatory for the transition is not the way
forward
We welcome the inclusion of support measures for farmers during the first five years after entry
into force of the Regulation to facilitate the application and implementation of certain provisions
at farm level
, however we cannot welcome the option for support through the CAP.
We would once again be using CAP funds to support actions/measures that go beyond legislative
requirements and which are not part of existing EU legislation. Going beyond legislative
requirements means
going beyond enhanced conditionality and this would mean that
we would be looking at these measures becoming de facto mandatory for farmers.
This is unacceptable for us.
Following these arguments, you may find our detailed position paper in all Copa and Cogeca
languages in the annex of this letter. Finally, we hope you are able to take our concerns into
consideration and should you have any further questions or remarks, please do not hesitate to
contact us.
Yours sincerely,
Pekka Pesonen
Secretary General
2 | 2