PEST Committee hearing, 6 September 2018 Stakeholders' recommendations on the current EU regulation on the approval of plant protection products Franziska Achterberg, Greenpeace

Three issues (1) Lack of independent and transparent EU risk assessment (2) Lack of EU wide action on dangers for the environment (3) Abuse of emergency authorisations  

(1) Lack of independent and transparent risk assessment The RMS “shall make an independent, objective and transparent assessment in the light of current scientific and technical knowledge.“ Reg. (EC) No 1107/2009, Article 11.2  

(1) Lack of independent and transparent risk assessment Use of unpublished industry studies without independent evaluation of the data Copy-paste of industry evaluation of published literature studies  

(2) Lack of EU wide measures “In order to achieve the same level of protection in all Member States, the decision on acceptability or non-acceptability of such substances should be taken at Community level on the basis of harmonised criteria.” Reg. (EC) No 1107/2009, Recital 10

(2) Lack of EU wide measures   EFSA identified a long-term risk to non-target vertebrates for four out of five representative uses...   EFSA Conclusion on glyphosate, Nov 2015

(2) Lack of EU wide measures ... and passed it on to EU Member States to deal with: “Member States shall pay particular attention to (...) the risk to terrestrial vertebrates and non-target terrestrial plants.” Commission Implementing Regulation (EU) 2017/2324 on glyphosate

(3) Abuse of emergeny authorisations “(…) in special circumstances a Member State may authorise, for a period not exceeding 120 days, the placing on the market of plant protection products, for limited and controlled use, where such a measure appears necessary because of a danger which cannot be contained by any other reasonable means.” Reg. (EC) No 1107/2009, Article 53 on Emergency Situations in Plant Protection  

(3) Abuse of emergeny authorisations Romania has “systematically issued 120 day emergency authorisations” for neonicotinoid products each year since 2013. (PAN Europe et al, 2017) The authorisation of clothianidin, imidacloprid or thiamethoxam to control Agriotes spp in maize and sunflower in 2017 is “scientifically supported“. (EFSA Technical Report, June 2018)

Recommendations The RMS and EFSA should perform a truly independent evaluation and cannot rely on the industry’s interpretation of the data. All studies underpinning scientific evaluations must be publicly available. The Commission, supported by EU MS, should consistently restrict or ban pesticides which can pose a danger to people or the environment. EU MS should apply Article 53 on “emergency authorisations” as intended, and the Commission remind them of their obligations.