The New CAP and Pesticides
A conversation with BirdLife and the European Environmental Bureau (EEB)
BirdLife and the European Environmental Bureau (EEB) co-authored a policy briefing (available here) on pesticides in the new common agricultural policy (CAP). Member States urgently need to reduce the use and risk of pesticides and deliver the reduction targets of the Farm to Fork Strategy: a 50% reduction in the use and risk of chemical pesticides and in the use of more hazardous pesticides by 2030, they argue.
We had a chat with BirdLife’s Tatiana Nemcova and the European Environmental Bureau’s Eva Corral about the report’s main talking points and conclusions. Find our discussion below.
What are the conclusions of the report "Pesticides in the new CAP: business as usual puts nature and human health at risk"?
The report assesses whether the measures proposed in eight draft CAP strategic plans are likely to contribute to a reduction of pesticides use and effectively support farmers to apply integrated pest management during the next CAP programming period (2023-2027).
As our report shows, Member States’ CAP strategic plans will neither contribute to the uptake of IPM principles nor propose strong enough measures to seriously reducing pesticide use dependency, even though it is already required by EU law and has been promised by the Commission since the publication of the Farm to Fork Strategy in May 2020. Overall, the assessed plans demonstrate very low ambition to use CAP funding for interventions related to pesticides use reduction.
On the one hand, the baseline requirements that farmers need to comply with are too lax to reduce the need for pesticides. For instance, only a few Member States combine practices on crop rotation and diversification rules to effectively reduce pesticides inputs. Most plans require the bare minimum with regards to the establishment of buffer strips along watercourses (where no pesticides are allowed), suggesting a width of 3 meters - which is insufficient and not effective to reduce water contamination and biodiversity degradation.
On the other hand, the common instruments under the new CAP which should in theory promote organic farming, IPM and biological pest control – called eco-schemes and AECMs - are often lacking clear targets to reduce pesticides use and might not result in significant improvements. Schemes supporting a genuine shift to agro-ecological practices as a full package are missing and only few schemes supporting the complete elimination of chemical pesticides and/or supporting alternatives were identified.
What is your analysis of the proposal for a regulation on the "sustainable use of plant protection products"?
The SUR proposal needs much improving not to repeat the mistakes of the past. For more information, you can take a look at EEBs position on the revision of the SUR (here).
One of the problems of the current SUD, being a directive, is its insufficient implementation by Member States. The new proposal takes the form of a regulation but still leaves too much flexibility to MS, with the likelihood that implementation problems at national level will persist.
An example of this is the implementation via the CAP strategic plans (see conclusions of EEB/BirdLife thematic briefing and answer to previous question). Another example is the fact that, in a couple of articles in the proposal, Member States are allowed to not follow the Commission’s recommendations.
There is much talking about the reduction targets. While ambitious reduction targets are welcome, setting a reduction target does not mean that the reduction will be achieved. A clear example of this is provided by the failure of French Ecophyto plan, which also contained a 50% reduction target.[1] Additional mesures are also necessary, like a strong commitment to implement low input farming at farm level. Moreover the question of how to measure this reduction is of great importance. Current indicators give grotesque results. Harmonized risk indicator 1 (HRI1) penalizes substances used in organic farming to fight pests and diseases[2]. Unless they are radically improved, they will not be useful to measure progress in achieving the reduction targets, and there is the risk that they will give results that do not correspond to reality.
Integrated pest management (IPM) should be a cornerstone of the legislation (it is mandatory for farmers since 2014) but it is not, and it’s definition remains unclear, opening the door to greenwashing. There is no mention either of the need to promote low-input farming systems (i.e., agroecology, organic farming beyond the 2030 target). Also, as per the phrasing of several articles in the proposal, alternatives to chemical pesticides would not be yet available, which is not the case. There are agronomical practices available[3],[4].
Several relevant provisions included in the current legislation have been removed from the SUR proposal, weakening it, and potentially opening the door to greenwashing and to a weaker text than we have now. For example, the following sentence, included in the SUD definition of IPM, has been removed in the SUR proposal: ”Integrated pest management” emphasises the growth of a healthy crop with the least possible disruption to agro-ecosystems and encourages natural pest control mechanisms”. Another example is that, according to the SUD, the objectives of National action plans (NAPs) include “(…) to encourage the development and introduction of integrated pest management and of alternative approaches or techniques in order to reduce dependency on the use of pesticides”. This paragraph has been removed in the SUR proposal. In this context it is worth reminding that the 2006 Commission’s Thematic Strategy on the Sustainable Use of Pesticides proposed the establishment of National Action Plans by the Member States one of which objectives was to reduce dependence on chemical control for plant protection[5].
Public information campaigns are insufficient in the proposal. Citizens have the right to information. This is why these provisions must be strengthened and available funding should be made available. In the proposal it is unclear whether the campaigns will be limited to having a website. Occupational illness linked to exposure to pesticides is not recognized at EU level nor mentioned in the proposal and it should be.
What would you add to this proposal?
The problems mentioned in the previous question must obviously be solved. For example, Member states should not be allowed to not follow the Commission’s recommendations.
The terms “non-chemical methods”, “preventative measures” and “interventions” need to be clarified to avoid greenwashing, as should be the definition of IPM. Improving the definition of IPM should be done by clarifying that IPM is a holistic system of pest management that follows the principles of agroecology and by including a reference to the Pesticide Action Network (PAN), International Organisation for Biological Control (IOBC-wprs) and the International Biocontrol Manufacturers Association (IBMA) definition (and hierarchy of interventions pyramid) of IPM[6]. The aim of the proposal must be enlarged to promote low-input agricultural systems.
It is also essential that HRI are seriously improved. Member States national targets should not be lower than 40% (calculated with a better indicator), and, to increase their accountability, intermediary targets until 2030 should be set.
In its 2020 report[7], the European Court of Auditors (ECA) recommended that Member states reinforce controls and set adequate penalties for non compliance with IPM. Provisions for controls and sanctions must therefore be strengthened in the SUR proposal.
Pesticides have very negative effects on biodiversity (i.e., pollinators) and the environment, but this is not sufficiently taken into account in the proposal. It should include a legally binding objective of at least 10% of agricultural land being dedicated to high-biodiversity landscape features at farm level, in line with the Biodiversity Strategy for 2030, and environmental indicators. HRI were only adopted in 2019, after lengthy and difficult discussions. To avoid this problem, the proposal should start by including environmental indicators that already exist, or are at an advanced level of development, like the Farmland birds index, LUCAS, Insignia-EU and the Pollinator Index. Essential use derogations should be kept to a very minimum, or be totally removed as for bee killer neonicotinoids. The current liberal approach to derogations hinders achieving the objectives of the legislation. Establishing buffer zones around areas where pesticides cannot be used are important because pesticides do not stop spreading themselves at the border of such areas. Given that it might be difficult to set a harmonized size for mandatory buffer zones the proposal should at least include an adequate minimum size for such zones. Buffer zones of between 3 and 5 meters around superficial water bodies and groundwater for the abstraction of drinking are not appropriately-sized buffer zones (the proposal mention 3 m buffer zones).
Last but not least, the use of synthetic pesticides for non-professional users should be forbidden.
What do you expect from the Czech Presidency of the Council of the European Union on the proposed regulation?
We have had positive exchanges, that we hope to maintain and further develop. We are aware of the importance of achieving a sustainable and resilient food system in the EU. We hope that our exchanges will be fruitful so as to resist adopting false short-term technological solutions. The way forward to achieve a sustainable European food system that is resilient to the global threats we face, like climate change and agricultural soil over-pollution and therefore reduced yields, is to commit to implement ambitiously the Farm to Fork strategy and to support a coherent SUR proposal with strong reduction objectives and promotion of low input farming systems.
[1] https://www.lemonde.fr/planete/article/2022/03/23/reduction-de-l-usage-des-pesticides-les-raisons-d-un-echec_6118856_3244.html
[2] For more information see : https://www.global2000.at/sites/global/files/GLOBAL-2000_Report_HRI-1_220228.pdf
[3] For a list of available non-chemical methods see section 5.1 (pp.56-63) of Food Watch study Locked-In Pesticides. The section includes scientific references on their proven efficacy.
[4] For example according to article 9.d – « for each of the pests referred to in point (c), a list of non-chemical methods used or likely to be available by 2030. » . There are available agronomical practices, not much used (see footnote2)
[6] https://www.pan-europe.info/sites/pan-europe.info/files/ipm-working-with-nature-2019-edition.pdf