Ref. Ares(2016)1673821 - 08/04/2016
Ref. Ares(2016)2052846 - 29/04/2016
IMPACT ASSESSMENT, ANNEX II
Alternatives in agriculture for endocrine disrupting
pesticides.
Introduction
This Annex shows the results of the investigation undertaken by PAN Europe on the alternatives available in
agriculture for endocrine disrupting pesticides- the ones under debate in recent years. In 2013, UK Health
and Safety Executive HSE published a report on the costs of the potential ban of pesticides1and evaluated the
pesticides previously listed by CRD/HSE as being potentially banned in the EU2. Many subsequent reports,
such as the ones from the pesticide umbrella organisation ECPA3and UK-farmers organisations4, used the
data collected by CRD/HSE and others in a more or less repeated message. Pesticide producer BASF and
another farmer organisation, ELO, focussed on azoles in cereals5. From this collection of pesticides that the
UK, industry and farmers expect most problems for, we took the most debated 13 pesticide-pest
combinations to look into alternatives and the seriousness of the expected problems and claimed costs. We
also included a pesticide which is part of the endocrine interim criteria, and a pesticide qualified endocrine
disruptor based on independent literature.
Methodology
PAN Europe first collected all the available alternatives for the 13 pest-pesticide combinations from public
available sources in the different EU countries6. We looked at available synthetic alternatives, at non-
chemical alternatives, and especially at the ‘Integrated pest management’ (IPM) system as described in EU
Directive 2009/128, Annex III, a system all farmers in the EU have to apply from January 1, 2014 onwards.
The draft collection was then sent to a panel of independent experts for peer-review. The experts are actively
working as specialists in biological control, integrated pest management and sustainable use of pesticides;
they can be consulted for the IA on request7.
1 Agronomic and economic impact assessment for possible human health and ecotoxicology criteria for endocrine disrupting
substances, Report to Chemicals Regulation Directorate, June 2013,
http://www.pesticides.gov.uk/guidance/industries/pesticides/News/Collected-Updates/Information-Updates-
2014/January/Regulation+_EC_No_1107_2009-progress_on_endocrine_disrupters_and_candidates_for+substitution
2 Extended impact assessment study of the human health and environmental criteria for endocrine disrupting substances proposed by
HSE, CRD, January 2013, http://www.pesticides.gov.uk/guidance/industries/pesticides/News/Collected-Updates/Information-
Updates-2014/January/Regulation+_EC_No_1107_2009-progress_on_endocrine_disrupters_and_candidates_for+substitution
3 ECPA lobby paper on endocrines, March 2013
4 http://www.fwi.co.uk/news/eu-pesticide-review-could-cost-uk-industry-905m.htm, December 2014
5 BASF ELO on azoles, 2012.
6 It concerns the following website with information on alternatives: Swiss, IOBC, http://www.iobc-
wprs.org/pub/index.html, UK HGCA, http://www.hgca.com/ , DE, Julius-Kühn Institut,
http://www.jki.bund.de/en/startseite/home.html, FR, Arvalis, http://www.arvalis-infos.fr/index.html , DK, DAAS,
Arhus, http://www.vfl.dk/system/404.htm#.VJh7IcgU , NL, “Groen Kennisnet”,
http://www.groenkennisnet.nl/plant/Pages/default.aspx, NL, “Kenniscentrum Wageningen”,
http://www.kennisakker.nl/kenniscentrum/kenniscentrum ,
7 Please send a message to xxxx@xxxxxxxxxx.xxxx
PAN Europe - Rue de la Pépinière 1 B-1000, Brussels, Belgium
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Results
Overall, the experts consulted by PAN Europe disagreed that the ban of the indicated pesticides will result in
substantial yield losses, taking into account the availability of synthetic alternatives in every case. In some
difficult cases, such as Septoria in cereals, a lot of attention and knowledge is needed but still available
alternatives are sufficient to control the pest.
The list of alternatives for the 13 pest-crop combinations is given below in Table 1.
Table 1. Alternatives for 13 pest-crop combinations.
Pesticide
Main plant pest
Claimed costs by
Synthetic alternatives
Non-chemical alternatives/IPM,
use
industry in case of
resistant varieties, rotation,
banning (UK Fera,
biological control, etc.
BASF)
Azoles
Septoria tritici in
4,6 billion for Europe
SDHI pesticides: Boscalid,
Bacterial seed treatment (e.g.,
(epoxiconoczaole,
cereals
assumed, yield loss, from
Isopyrazam, Bixafen,
Cerall from Bioagri); less
cyproconazole,
net exporter to net
Fluxapyroxad
vulnerable varieties towards
etc.).
importer (UK); resistance
Cyprodinil and Strobilurimn
Septoria (Bristol, Robigus,
Eight azoles are
problems due to massive
such as Azoxystrobulin
Fortissimo, Tabasco, Lincoln,
banned in
use of chemicals
Tulsa, Carenius), avoid early
DK.(**); Four in
planting
FR (***)
Azoles,
Phoma stem
Many millions, assumed
Fludioxonil, metalaxyl,
Resistant varieties (Escort,
Difenoconazole,
canker in winter
reduction yield 9,8%
thiram, penthiopyrad,
Twister), crop rotation, cultural
Flusilazole,
oil seed rape
(UK); the Agri Chamber
picoxystrobin
control measures (burning
Prothioconazole
in Schleswig-Holstein has
stubble), bacterial seed treatment
shown that there is rarely
a benefit of spraying; in
fact azoles are misused for
stem growth reduction.
Myclobutanil
Grape, powdery
Not considered an
trifloxystrobin, azoxystrobin, Ampelomyces quisqualis
(azole)
mildew
endocrine by UK
spiroxamine
(parasitic fungus), Aureobasidium
pullulans, a yeast, sulphur,
resistant varieties, low spraying
frequency to prevent resistance,
spray forecast model
Mancozeb
Downy mildew in
No yield reduction but
Mandipropamid (Brassica),
Resistant varieties (Brassica);
Brassica/Grapevin
other costs assumed by
Copper, Metalaxyl,
Sulphur, Potassium bicarbonate,
e/Lettuce
UK Fera
Cymoxanil (Grapevine)
cropping density (Lettuce), field
location (lettuce), many
biologicals in development
Mancozeb
Late blight in
Not mentioned as
Cyazofamid, fluazinam
Resistant varieties (Carolus,
potatoes
increasing costs by UK
(preventive), cymoxanil,
Bionica, Sarpo Mira, Vitabella),
Fera; resistance problems
dimethomorph,
planting distance, early
due to massive use of
ametoctradin, fluopicolide,
harvesting,
chemicals.
propamocarb, fenamidone,
potassium phosphite.
Ioxynil
Broad-leaved
Assumed 20-40% yield
Bromoxynil (leek), Pyridate,
Use ‘false’ seed bed, soil
herbs in onions
reduction (UK)
Pendimethalin, Oxyfluorfen,
solarisation, mechanical weeding;
and leeks
Fluazifop-P-butyl,
pyro-weeding
Clethodim
Thiacloprid
Oil seed rape/
No yield reduction; other
Indoxacarb
Beetle resistant to pyrethroid
pollen beetle - seed pesticides are more
Pymetrozine
insecticides, monitoring for
coating
expensive (UK); (this
thresholds necessary (*), use of
claim is questionable,
kaolin, of entomopathogenic
pyrethroids are cheaper)
fungi, parasitic wasps in- and off-
filed (parasitation up to 80% if no
pesticides are used).
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Pesticide
Main plant pest
Claimed costs by
Synthetic alternatives
Non-chemical alternatives/IPM,
use
industry in case of
resistant varieties, rotation,
banning (UK Fera,
biological control, etc.
BASF)
Thiacloprid
Aphids in
No yield reduction (UK);
Pirimicarb, Pymetrozine,
Various types of biological
strawberries
Thiacloprid kills many
control, wasps in greenhouses
beneficial mites and repels
(aphidius ervi), parasitic flies,
beneficial wasps.
lacewings and ladybirds.
Entomopathogenic fungus and
also physical killers like soaps,
polysaccharides, pyrethrin
Pyrethroids
Aphids in grain
No yield reduction, higher
Pirimicarb, Pymetrozine,
Use is not needed; if left
(cypermethrin,
(transmitting virus) price of synthetic
Flonicamid, Rynaxypyr
untreated, natural enemies will
deltamethrin, L-
alternatives (UK); much
develop and balance the pest
cyhalothrin)
resistance against
(virus concerns exaggerated);
pyrethroids
avoid early sowing to escape
main aphid migration period,
natural pyrethrin
Amitrole (part of
Non-selective
Not ranked as an EDC
Chlorotoluron (dismissed
Mechanical weeding, covered
endocrine interim
herbicide in
(UK)
because it’s a C2R2),
soil; pyro-weeding
criteria)
orchards
Clopyralid, glyphosate
(dismissed because it’s a
EDC)
Abamectin
Tarsonemid
Impact expected but
Cyromazin, Spinosad,
Heat treatment of plants,
(Vertimec)
control
unknown (UK); other
Bifenazate, Hexythiazox,
Biological control with a range of
(mite) in
synthetic are more
Spiromesifen
Amblyseius spp. (predatory
strawberries
effective
mites) and Hymenopteran
parasites with very good results
Chlorpyrifos
Apple blossom
Significant yield losses for Thiacloprid (dismissed
Earwigs, Quassia extract,
weevil
some apple varieties (UK)
because it’s a EDC),
pheromones
Spinosad
Dimethoate
Aphids in (seed)
Not considered an EDC
Pymetrozin, Flonicamid,
Encouraging predators and
(endocrine as
potatoes
(UK)
Pirimicarb,
parasitoids like wasps, ladybirds;
determined by
paraffin oils
independent
literature)
(*) Monitoring for thresholds (for all pest organisms) is a prerequisite for IPM and organic production. This can be done by
pheromone traps, colour traps, direct observation (counting), presence of diseases, forecast models, etc. Should be compulsory
in all countries and crops to prevent/reduce resistances of many pest organism.
(**) bromuconazole, cyproconazole, fluquinconazole, flusilazole, flutriafol, ipconazole, prochloraz, tetraconazole
(***) bromuconazole, fluquinconazole, fuberidazole, ipconazole.
All experts stress the need to move to another system, the integrated crop management, to prevent further
resistance against current pesticides used, to make better use of available predators, and to reduce the amount
of toxic agrochemicals that is released into the environment causing environmental pollution and degradation
of ecosystems. The pesticide groups of Azoles and Pyrethroids are almost at the end of their life-stage.
Resistance of pests is at such a level that the use of pesticides- in higher doses and in mixtures (pesticide
cocktails)- has become futile.
It is important to note that the resistance to pests is the result of the current system: too high pesticide
spraying frequency, too narrow crop rotation and vulnerable crop varieties. This system encourages
resistance and creates a continuous loop where stronger and higher pesticide quantities are necessary. To
escape from this loop we need to move towards sustainable agricultural practices.
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The system of IPM is the most developed for changing current practices and it is not only an option but a
legal requirement. IPM is much more knowledge-based (such as monitoring & need to know the lifecycle of
pests, thresholds & timing of intervention, use of mechanical weeding etc) and therefore extension services
should be used to stimulate and encourage farmers. A EU-wide program should be adopted and proper
incentives (such as CAP) should be used.
An element of the current system is the lack of innovation. Substituting one synthetic chemical by another is
no real innovation but just the continuation of 'calendar' spraying. IPM on the other hand is very innovative,
working with predators, ecosystems, sounds, heat, etc and a range of other non-chemical based options to
control pests. Choosing for IPM means profit and jobs for many SMEs in Europe to provide for extension
services. Food quality will increase and this will give Europe a competitive advantage on the market. The
environment will improve and this will protect biodiversity and species extinction and will also have a
positive socioeconomic impact as it will stimulate tourism in agricultural areas. Undoubtedly, the application
of IPM is beneficial for all sectors.
Conclusion
The conclusion drawn by PAN Europe is that the ban of a number of harmful pesticides with endocrine
disrupting properties from the market not only is favourable but also feasible. There are a range of
alternatives available, even synthetic alternatives that there will be hardly any substantial yield loss.
Certainly not the huge yield-losses claimed by UK and industry, who ignore the implementation of IPM by
member states. Many alternatives are readily available and additional alternatives can be introduced with the
use of proper extension services.
PAN Europe - Rue de la Pépinière 1 B-1000, Brussels, Belgium
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Tel: +32 (0)2 503 0837 – Fax. +32 (0)2 402 3042 www.pan-europe.info
“This document has been produced with the financial assistance of the Life+ Programme of the European
Commission DG Environment”