The changes to directive 91/414 and other legislative proposals currently in the EU co-decision process could pose a major threat to the viability of EU agriculture according to an analysis by the UK’s Pesticides Safety Directorate (PSD). The document presents an analysis of the potential impact of the Commission proposal on ‘cut-off criteria’ and substitution and an analysis of the amendments proposed by the European Parliament.

The Commission proposals could remove up to 15% of the substances assessed, which are particularly important in the UK for the protection of so-called ‘minor’ crops such as carrots and parsnips. These constitute an important part of a healthy and balanced diet. It is possible that the endocrine disruptor criteria could impact particularly on fungicide availability and might reslt in 20-30% yield losses in cereals.

The European Parliament proposals include a single approval period for candidates for substitution of five years and could result in the loss of up to 85% of conventional chemical substances after that period. The PSD notes, ‘If the full potential impact of the current Parliament proposals were realised, conventional commercial agriculture in the UK (and much of the EC) as it is currently practised would not be achievable, with major impacts on crop yield and food quality.’ The PSD adds, ‘These proposals need to be considered against the background of substantial losses of active substances which have already occurred as a result of the EU review programme under Directive 91/414/EEC.’

The PSD argues that the scale and magnitude of the potential losses, particularly from the Parliament’s proposals, would undermine both resistance management and Integrated Pest Management (IPM). Many analysts see the implementation of IPM strategies as the key to a balanced and appropriate use of pesticides.

Effective resistant management is reliant on having different modes of action (including non-chemical methods) incorporated into strategies to reduce selection pressure and thus minimise the likelihood of resistance development. With reliance on fewer active substances, opportunity for choice is reduced and the risk of resistance substantially increased. Similarly, IPM is reliant on having a range of active substances available.

As far as the Commission proposals are concerned, non-approval of the triazole compounds would remove the foundation stone of control programmes for the major diseases of wheat in the UK, Septoria tritici. Pendimethalin is the mainstay (together with flufenacet) of pre-emergence blackgrass control in cereals. Blackgrass is the major grass weed species in England, and effective blackgrass control strategies rely on pre- and post-weed emergence sequences of a limited range of key herbicides. The non-approval of the pendimethalin pre-emergence option would jeopardise weed control.

The majority of the currently approved herbicides for carrots, parnsips and onions may no longer be available. There is potential for up to 100% yield loss. Loss of warfarin would have significant impact on amenity woodland and forestry, with increased native tree death.

The Parliament proposals would mean effectively no herbicide options for control of weeds in horticultural crops. Many horticultural crops would be uneconomic to grow, particularly if supermarkets were unwilling to compromise on quality standards. Chemical control of blackgrass in cereals would become virtually impossible with severe economic impacts. Seed potato growing would be unlikely and ware potato yields would be severely reduced.

If not substantially modified, these proposals could have a substantial impact on the cost, availability and quality of food in Europe, hitting family budgets hard at a time when inflation is already increasing.

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