October 2010 Implementing Regulations on pesticide statistics Johan Selenius

October History of the regulation Proposal drafted by Eurostat Pesticide expert group Adopted by Commission in December 2006 Part of the package for the Community Thematic Strategy on the sustainable use of pesticides: –Framework Directive on sustainable use of pesticides –New Regulation for the placing of PPP on the market –Machinery Directive 1st Reading: nd Reading: 2009 Adoption: 25 November 2009 Publication: 10 December 2009 Entry into force: 30 December 2009

October Timetable for data collection-delivery Sales data: –1 st reference year = Y2 (2011) –1 st delivery: Y3 (before the end of 2012) Use data: –1 st reference period = Y1-Y5 ( ) –1 st complete delivery = Y6 (before the end of 2015) Main Deliverables2017- Adoption of the Regulation  PPP sales statistics Reference periods Data from MS  Data publication  PPP use statistics Reference periods Data from MS  Data publication  Report and publications Report to EP  RP6RP5RP4RP3 RP1RP2 RP1

October Implementing regulations The appropriate technical format for the transmission of data shall be adopted in accordance with the regulatory procedure; Modifications to the quality reports, the adoption of the definition of the "area treated and the adaptation of the list of substances to be covered and their classification in categories of products and chemical classes shall be adopted in accordance with the regulatory procedure with scrutiny  Two different procedures and implementing regulations! European Statistical System Committee (ESSC), not the CPSA, gives its opinion

October Commission Regulation on Transmission format Two sets of data with delivery dates years apart –Data on placing on the market annually, starting from 2012 –Use data every 5 years, with first compulsory transmission 2015 Eurostat considers it premature to define the transmission format for both sets at this stage. In the draft regulation, only the transmission formats for the data on placing on the market have therefore been included Too much technical details in a regulation gives too much rigidity to a topic where it can be expected that the technical developments might be rapid

October Transmission format The statistical data on the placing on the market of pesticides should be transmitted using the Statistical Data and Metadata eXchange (SDMX) format. The data shall be transmitted or uploaded by electronic means to the single entry point for data at Eurostat (e-Damis). The data flow has not yet been defined. Member States shall transmit the required data conforming to the technical specifications provided by the Commission (Eurostat). FAO data requirements can be also covered with the statistics collected

October Task force discussion 6 May 2010 Some TF members questioned the use of the SDMX format, but according to Eurostat services, the format should not cause problems in data transmission. The issue of confidentiality was discussed at length, with the conclusion that not only the substances, but also the aggregated data per chemical classes and categories should be flagged for confidentiality. This issue has now been incorporated in the draft

October To be discussed Can the draft legislation on the transmission format be accepted?

October Definition of area treated Eurostat considers that the definition should be straightforward and not difficult to implement A first proposal was discussed in the Task Force, but was considered too long. The TF agreed on a new suggestion as follows: "the basic area treated defined as "the physical area of the crop treated at least once with a given active substance, independently of the number of applications“ The draft regulation has been adapted accordingly Commission Regulation on definitions and list of active substances

October List of active substances The list of active substances on the website of DG SANCO ( is constantly updatedhttp://ec.europa.eu/sanco_pesticides/public/index.cfm The updated annex III is based on the situation in August this year The supporting information (CAS-numbers, CIPAC numbers) on new substances is not always available It is not always fully clear to which product categories or chemical class an active substance should be allocated

October Classification Several different sources have been used for the classification: –the information in SANCO database ( –EFSA fact sheets ( –CIPAC website ( –Compendium of Pesticide Common Names ( – The PPDB Pesticide Properties Database (

October Situation in May (not updated) 64 of the substances in Annex III had been deleted from the SANCO list of active substances but had been resubmitted for inclusion. If they would be excluded from the statistics, there is a risk that information on important pesticides will be lost 80 of the substances had been deleted but had not been resubmitted for inclusion, and should pose no problems 58 new applications were pending, many of them potentially important new substances that could have a great impact on sales and use data. 93 substances ADI *, ARfD * and AOEL * were all “non applicable”, meaning no risk? *(For pesticide laymen: Acceptable Daily Intake, Acute Reference Dose, Acceptable Operator Exposure Level)

October Task Force discussion Even though substances are not authorised on EU level, they might still be used, due to certain rules CIPAC and CAS-numbers should be kept, as they are important for identifying the substances “Non-risk” substances received both support and criticism. It was considered that extended use of these products would show a “greener” agriculture Annual updates of the list was suggested, as new substances are introduced and the statistics would not be useful without also these new, emerging trends visible. This is even more importing considering the 5-year period for collecting sales data Substances only sold nationally could be collected under the class “others” Deleted substances might be resubmitted, so they should not be removed too quickly

October Task Force conclusions Annex III will be revised this year based on the situation end October so that the new list that should be used when starting data collection in 2011 will be as complete as possible Substances removed from the SANCO list and not resubmitted for authorisation will be deleted There will be an annual update for adding new (authorised) substances The substances which are presently not authorised, but that are resubmitted for authorisation will not be deleted from the list; During the 5-year period for use of pesticides, no further deletions will be made

October Task Force conclusions (cont.) The pending substances which are authorised at the time of the revision will be included There will be no changes to the major groups and categories of products Eurostat creates a new code for every substance but will also keep the CIPAC code Countries were asked to validate the active substance list Stakeholders would be asked for their opinion on updates

October Stakeholder suggestions Substances that have been resubmitted for inclusion should be kept, as many of them are likely to be reintroduced, and some of them have large markets All pending substances where the dossier is complete should be kept Eurostat’s new, unique code to be used for transmitting and processing the data was accepted

October Suggestions and comments from Member States NL, DE, BE sent comments after the TF meeting on the outcome and Eurostat’s proposals Most of the suggestions have been taken into account in the new legislation DE made some additional comments on Annex III that have not yet been introduced: –The CIPAC codes for copper compounds should be corrected to take into account the ions and ester radicals –Suggests changed classification of laminarin to F06_01, sodium hypochlorite and disodium phosphonate to F01_99 –To perhaps add a new chemical class “Botanical insecticides” and move pyrethrins and azadirachtin there

October Harmonised classification

October Harmonised classification

October Coding: a suggestion MAJOR GROUPS and Categories of productsNew Code Old Cod eChemical ClassActive substancesCASCIPAC Fungicides and BactericidesF00F0 Inorganic fungicidesF01.F1 F01_01 COPPER COMPOUNDS F01_01_01F1.1 ALL COPPER COMPOUNDS 44 F01_01_02F1.1 BORDEAUX MIXTURE F01_01_06F1.1 TRIBASIC COPPER SULPHATE F01_01_07F1.1 OTHER COPPER SALTS 44 F01_02 INORGANIC SULFUR F01_02_01F1.2 SULFUR F01_99 OTHER INORGANIC FUNGICIDES F01_99_1 Sodium hypochlorite None F01_99_99F1.3 OTHER INORGANIC FUNGICIDES To be changed to letter only?

October To be discussed Can the draft implementing regulation be accepted?

October Gentlemen’s Agreement Eurostat’s legal unit considers that annual updates of Annex III to Regulation 1185/2009 is not possible, as the legal procedures are too demanding Regulation 1185/2209 neither gives the possibility of allowing the Commission the right to update the Annex with an article in the implementing regulation Instead it is considered that a Gentlemen’s Agreement would be the best tool as it is more flexible In this case the text of the Agreement is very short, as it only says that the Commission will update Annex III annually in autumn and send the list to the Member States for updating the substances collected

October To be discussed Can the draft Gentlemen’s agreement be accepted?