‘Possibilities for future EU Environmental Policy on Plant Protection Products’
1.1 Background
This Report is a consolidation of six sub-Reports forming part of PES - A / Phase 2 of a joint project addressing the development and evaluation of strategies for future plant protection policy in the EU. The project has been conducted under the aegis of Environment DG of the European Commission, and the Dutch Ministry of the Environment (VROM). The total project has been divided into several phases, and into two sections addressing respectively agricultural uses (plant protection products) and non-agricultural uses (biocides) and has been directed by a Steering Committee.
The first Phase of the project on agricultural uses was concluded early in 1994, and resulted in two reports: ‘Towards a future E.U. Plant Protection Product Policy’, and ‘Pesticide Use in the E.U.’1 A Workshop on a ‘Framework for the Sustainable Use of Plan Protection Products in the European Union’ was also held, in June 1994, the results of which were embodied in a Report by DHV/Environment and Infrastructure.
Following the Workshop and the DHV Report it was decided that more specialised investigations were required into the different problem areas identified from Phase 1. These Phase 2 sub-Reports draw expertise from Member States, research institutions, the European Commission itself and from parties involved in the plant protection sector.
The starting point for the project (both Phase 1 and 2) was the hypothesis that intensive agricultural production in a large part of the EU has resulted in pollution from, inter alia, plant protection products ("PPP"), with resulting threats to groundwater, surface water, soil and air quality.
Although different types of regulation have been introduced at EU level to combat these problems, 2 there remains a growing concern whether the current regulatory framework is sufficient to produce desired reductions in environmental pollution caused by the use of PPPs. The Terms of Reference for the sub-Reports forming the basis of Phase 2 of the project, and of this Synthesis Report, are therefore related to the issue whether there is a need for an additional plant protection policy, defined as ‘additional to the current EU regulatory framework’ and in particular Directive 91/414’s admission policy for PPPs.
Phase 2 was designed to take into account at least the following aspects:
- That an improvement was required in both the PPPs used (‘chemical innovation’) and in actual pest control practised at farm level (‘agricultural innovation’).
- Current EU policy focuses on possible effects of PPPs themselves and less on use reduction or similar objectives. Present incentives directed towards stimulating farmers to re-evaluate use of PPPs are expected to have limited effect;
- There is at present little data available clarity as to how the three elements in a plant protection policy interact (use of PPPs, the presence of residues in the environment, and the environmental impact) in impacting either the environment or human health;
- The precautionary principle alone appears to be an insufficient device for a general reduction in use of PPPs. Although the principle of reduction in chemical inputs (to the point that none of the basic natural processes indispensable for a sustainable agricultural sector be affected), is identified in the Fifth Environmental Action Program (‘FEAP’) of 1992, no actual methods, goals or limits were defined. Nevertheless, the FEAP includes as one of its priority actions, the development of ‘Proposals for progressive replacement of harmful pesticides and progressive use limitations’;
- Significant disagreement on the environmental impact of PPPs in the EU hampers a common understanding on possible objectives of an additional EU policy;
- Definition of the environmental problems associated with use of PPPs is difficult at present due to differing parameters used by different parties, and different Member States. There are a number of possible objectives which an additional EU PPP policy might seek to achieve, for example, reduction in environmental impact, in use, in concentration, in emission, in residue, in application frequency, in area treated;
- Notwithstanding the wide agreement at the 1994 workshop that environmental considerations should be factored in to any modification of EU agriculture policy, it is not clear what influence the Common Agricultural Policy (‘CAP’) exercises on PPP use in the EU.
In the light of the above observations, it was determined to divide Phase 2 into six sub-projects, as follows:
Sub-Report 1 (Summarised at Section 2 in this Synthesis report)
Possible Arguments and Objectives of an Additional EC Policy on Plant Protection Products - See Section 2 below for Report prepared by Oppenheimer Wolff & Donnelly. This sub-Report presents the strategic assessment of possible developments in EU PPP policy in the future. Unlike previous assessments of policy options, which had focused on a more de facto approach, this Report is intended to consider the underlying motivations for different policy options. Experiences to date in three Member States with PPP reduction strategies in place are compared to three Member States without such policies.
Sub-Report 2 (Summarised at Section 3 of this Synthesis Report)
Additional EU Policy Instruments for Plant Protection Products - Report prepared by Wageningen Agricultural University (Mansholt Institute). This sub-Report takes as its starting point the conclusions from the Oppenheimer Wolff & Donnelly study on possible arguments and objectives of an additional PPP policy for the EU. This Report is particularly intended to take a comparative approach to measures with a local, national or European character, and assess the cost and enforcement implications of policy alternatives. Suggested starting points proposed during the workshop therefore included instruments directed at more effective training and education, registration of PPP trade and use, consideration of economic instruments, and an examination of the possible impact of the EU Eco-labelling scheme.
Sub-Report 3(Summarised at Section 4 of this Synthesis Report)
Analysis of Agricultural Policy in Relation to the Use of Plant Protection products - Report prepared by Produce Studies Limited. It was concluded at the Workshop in 1994 that the relationship between current EU agricultural policy and PPP use was insufficiently developed to allow informed discussion on the possible role of the CAP in an additional EU PPP policy. This Report was therefore commissioned to conduct a medium and long term analysis of agricultural policy and its environmental impact of PPP use, to include an assessment of the effectiveness of EU measures such as price policy and use of structural funds, agri-environmental measures and relevant EU PPP legislation (such as Directive 91/414). The Report examines the potential impact of additional measures such as the set asides established under Regulation 92/2078.
Sub-Report 4 (Summarised at Section 6 of this Synthesis Report)
Further analysis on use patterns of PPPs in EU farming - Report prepared by Landell Mills Market Research Limited, entitled ‘Regional Analysis of Use Patterns of Plant Protection Products in Six EU Countries’. Phase 1 of the project had identified the need for greater examination of differing PPP use at farm-level and crop-level. This sub-Report examines in particular whether further reduction in PPP use is possible, and how such an objective might be achieved at farm level.
Sub-Report 5 (Summarised at Section 7 of this Synthesis Report)
Further analysis of presence of residues and environment impact of PPPs in the EU - Report prepared by Soil Survey and Land Research Centre (SSLRC) (and sub-contractors). It was concluded that Phase 1 results, which had addressed this issue from the perspective of monitoring on the one hand, and science and modeling on the other, were insufficient for the purposes of clarifying the relationship between use, presence and impact of PPPs necessary for an examination of the need for an additional EU policy.
Sub-Report 6 (Summarised at Section 5 of this Synthesis Report)
Assessment of the Benefits of Plant Protection Products - Report prepared by Eyre Associates. This sub-Report is intended primarily to address the economic benefits occurring from PPP use, most particularly by consideration of the theoretical impact of fully non-PPP using farming throughout the Member States.
1.2 Structure of Consolidated Report
1.2.1 Introduction
The present Synthesis Report is intended to provide a starting point for discussions to take place in a Workshop on additional EU policy on Plant Protection Products to be held in mid 1998. Following a summary of the primary conclusions of the six sub-Reports, the Synthesis Report proceeds to examine the OWD Report into possible arguments and objectives of EU PPP policy, and the Wageningen Agricultural University Report into additional policy instruments first.
The study of the impact of current CAP on PPP use is examined third. In this way, it is hoped that a policy framework will be in place before the reader proceeds to an examination of the factual or information-based Reports concerning, respectively, benefits of PPPs, a regional analysis of use patterns of PPPs in Six EU Member States, and an analysis of the presence of residues and environmental impact of PPPs.
The six sub-Reports cover approximately 3,000 pages, as a result of which there are severe restrictions on the space available in a Synthesis Report of around 100 pages. Accordingly, as a general remark, only the primary findings and conclusions of each individual sub-Report have been distilled into this Report. Readers must therefore refer to the full texts for wider discussion of the conclusions and recommendations produced by the authors of each sub-Report. Where appropriate, references are made in this Synthesis Report to the section(s) of individual sub-Reports where further consultation is recommended. Any developments which have occurred since the preparation of the industrial sub-reports are not examined in this synthesis report, but will be addressed in the Workshop to be held in 1998.
1.2.2 Methodology
As an initial task, sub-Reports were read through individually. As a subsequent task, corresponding sections of each Report (but notably the policy driven Reports of OWD, WAU and Produce Studies) were compared.
Each sub-Report was summarised in two stages. Firstly, information not required for an understanding of the conclusions and/or recommendations made in the sub-Report were omitted.3 As a second step, the text remaining was synthesised, leaving only those elements which (a) space allowed; and (b) lead the reader to a better understanding of the policy strategies and policy instruments elaborated by the sub-Reports.
In this Synthesis Report it will be seen that greater attention is paid to the policy-driven sub-Reports of OWD, WAU and Produce Studies, for a number of reasons:
- the areas and/or regions compared in the last two more technical sub-Reports do not completely correspond. As a result, the findings of one sub-Report are not fully supported by the other, as might have been desirable;
- the scope of each of these more technical sub-Reports is stated to have been affected by considerations of time and space, although ultimately budgetary considerations appear to have reduced the intended scope of these sub-Reports;
As a result of the above, the more technical or ‘factual’ sub-Reports prepared by Eyre Associates, Landell Mills Market Research, and by the Soil Survey and Land Research Centre are not considered to provide strong numerical or statistical support for the policy conclusions and recommendations produced by the other sub-Reports. It is for the readership of the Synthesis Report and/or the full text of the sub-Report on Benefits of PPPs to assess whether sufficient data and statistical support exists for findings of the sixth sub-Report (summarised at Section 5 of the present Report).
The need for further study of PPP use is largely unchallenged, and the, by necessity partial, coverage in the relevant sub-Reports in Phase 2 of this Project reflects this fact. However, their findings nevertheless remain relevant at this stage of the Project. As indicated above, the intention of this Synthesis Report is not to provide definitive answers either regarding current PPP use levels or practices, any more than its conclusions reflect the only policy choices, or instrument mixes available to policy makers.
The Synthesis Report is rather intended to provide the policy drivers for future discussion. It provides the background, and the starting point for the Workshop. Where conclusions in the OWD or WAU sub-Reports can be supported by the results of the other Phase 2 studies, this appears in the text. Where they can not, this may be due to a number of factors, not necessarily the result of the limited scope of the Landell Mills and SSLRC sub-Reports.
By way of example, only some of the six Member States examined in the OWD sub-Report have data available for analysis. Even where data is available, it often exists in an uncoordinated and haphazard fashion. While improving the flow of information does not directly affect the level of PPP use in the EU, but rather assists in recording it, it is apparent from the outset that great strides need to be taken in the near term to resolve the different approaches taken by Member States to the tasks involved.
1.3 Primary Conclusions of Sub-Reports
1.3.1 Oppenheimer Wolff & Donnelly
Oppenheimer Wolff & Donnelly studied motives, objectives and parameters from 6 Member States’ policies (Denmark, France, Germany, Italy, the Netherlands, Sweden and Finland) selecting States both with, and without a PPP-Use reduction programme in operation, in addition to authorisation policy. A study on the impact of Directive 91/414 on PPP use is also included in the sub-Report.
The sub-Report concludes with the proposal of six options for an additional EU PPP policy. These six options are not, however, pure alternatives, but to be considered along a continuum of unrestricted use at one end, to prohibition of PPP use at the other. It is accepted that neither end of the spectrum is viable.
The sub-Report notes that almost all Member States have some form of ‘additional’ policy in place, intended to reduce risk from PPPs. Measurable objectives were identified, largely to assist farmers and the general public. It is felt that Directive 91/414 alone is insufficient to meet the goals of an EU PPP policy, and that there is further scope for risk reduction.
Of the six options set out in the sub-Report (found at Section 2 of this Synthesis Report) four may be considered shorter term measures, while two are directed at reduction of agricultural dependency, and therefore represent a more long term view of PPP policy. One option (Option 2 - controls over risks in distribution/use of PPPs) is presented as a minimum requirement for EU policy.
1.3.2 Wageningen Agricultural University
The WAU sub-Report concentrated primarily on the risks arising to the environment, although it is accepted that because of the large range of active substances and the variety of conditions in applying PPPs it is difficult to define even one broadly accepted measure of degree of risk posed by PPP-use.
The sub-Report proposes a re-animation of the examination procedure under Directive 91/414, and recommends a significant increase in the resources allocated to the task. The insufficiency of current data is highlighted also in this sub-Report. A number of policy instruments receive an overall negative assessment. These include both green labelling as well as recording of trade and abolition of short-term set aside.
Other instruments achieve mixed conclusions following their examination in terms of their (a) acceptability, (b) efficiency, (c) effectiveness, (d) enforceability, (e) homogeneity and (f) in relation to the degree of disturbance to income or property rights which occurs.
EU stimulation of Member States’ use reduction plans is considered, although favoured at a regional level, and requiring significant changes in current infrastructure and adequate monitoring. Integrated environmental programmes at farm level also achieve a positive assessment, although dependent on high management skills of farmers. Integrated farming will also require important adjustments by farmers to be effective. Similarly, a programme on resistant cultivars is also considered to make a significant contribution to use/risk reduction.
The following mix of policy instruments is proposed:
- Stimulation of research and policy of generating resistant cultivars / removal of sensitive cultivars
- High uniform VAT
- Encouragement to Member States to develop PPP use/risk reduction programmes
- Speeding review programme under Directive 91/414
Three layers of cumulative policy instruments are further summarised at Section 3 of this Synthesis Report.
1.3.3 Produce Studies
This sub-Report examined the agricultural policy of the EU in so far as it impacts PPP use and risks, and includes a statistical analysis for a limited selection of Member States (Denmark, France, Germany, Italy, the Netherlands, Spain and the United Kingdom) on aggregate PPP use. It should be noted, however, that the Landell Mills, SSLRC and Produce Studies sub-Reports examined different farmers and/or regions. The data collected are not, therefore, fully comparable.
Produce Studies were also invited to conduct a desk study on the relationship between structural policy in relation to environment issues. Research also relied on a series of farmer interviews in which the effect of price on PPP-use was examined. The sub-Report provides the primary conclusions that (a) the impact of Regulation 2078/92 on total PPP-use is minimal, and (b) that CAP has only a limited effect on PPP-use.
1.3.4 Eyre Associates
This sub-Report is intended to address the benefits from PPP-use. The methodology adopted involves examination of the consequences on full non-use of PPPs across European Farming. Environmental and social benefits of PPP use are considered in lesser detail. Four case studies were produced involving apples (Trentino-Adige, Italy), ware potatoes (Flevoland, The Netherlands), wheat (Schleswig-Holstein, Germany) and wine (Bordeaux, France). The main findings are that PPP use allows significant economic savings over farming using reduced PPPs. The additional benefits of land conservation, improved food security, employment savings are also measured favourably against deficits in PPP use identified in this and other sub-Reports.
1.3.5 Landell Mills
This sub-Report made a study of selected regions (some different from those in other sub-Reports, however) where above-average PPP doses are found. Use data (including seed treatment, fungicides, herbicides, insecticides, and so on) were analysed for four crops (wheat, potato, vines and apples).
The sub-Report found that chemical loads differ widely from farm to farm, and from region to region, although explanation for these differences is not always currently known. Wheat herbicides provided the highest chemical load in all regions, although fungicides were also found to be substantial contributors in the Northern regions studied. In potatoes, vines and apples fungicides were found to dominate the chemical load.
1.3.6 Soil Survey and Land Research Centre/Cranfield University
This sub-Report studies the relationship between use and concentrations of PPPs in groundwater and surface water. Insufficient data was frequently a problem in drawing reliable or widely applicable conclusions. Information was gathered on usage and cropping as well as PPP presence in the environment. Twelve broadly representative pesticides were studied in detail (two herbicides, five fungicides and five insecticides/acaricides). The impact on non-target organisms was assessed with available ecotoxicological data.
Some regions did not monitor PPPs, while in others data was classified as confidential. Current administrative structures in a number of Member States makes full achievement of the terms of reference for this study (and therefore proper examination of PPP use/concentrations) impossible at the present time.
Improvements which are minimum requirements for this type of study are identified as: examination of usage over a period of years and information gathering on non-agricultural usage. As Member States continue to study older, more persistent AS, a transfer of resources is considered likely to achieve more efficient goals. A database of health and environmental water quality standards was compiled. Lastly, the sub-Report did find that significant incidences of contamination do occur.
Footnotes:
1.Prepared by the Centre for Agriculture and Environment ('CLM'), and the Agricultural Economics Research Institute ('LEI - DLO') respectively.
2. See in particular Council Regulation 2078/92 of 30 June, 1992, on agricultural production methods compatible with the requirements of the protection of the environment and the maintenance of the countryside, OJ L 215/85; Council Directive 79/117 of 21 December 1978 prohibiting the placing on the market and use of plant protection products containing certain active substances (as amended) OJ L 33/36; Council Directive 91/414 of 15 July concerning the placing of plant protection products on the market, OJ L 230/1 (as amended); Council Directive 76/895 of 23 November 1976 relating to the fixing of maximum levels for pesticide residues in and on fruit and vegetables, OJ L 340/26; Council Directive 86/362 of 24 July 1986 on the fixing of maximum levels for pesticide residues in and on cereals, OJ L 221/37; Council Directive 90/642 of 27 November 1990 on the fixing of maximum levels for pesticide residues in and on certain products of plant origin, including fruit and vegetables, OJ L 350/71; Council Directive 80/68 of 17 December 1979 on the protection of groundwater against pollution caused by certain dangerous substances, OJ L 20/43; Council Directive 80/778 of 15 July 1980 relating to the quality of water intended for human consumption, OJ L 229/11; Council Directive 67/548 of 27 June 1967 on the approximation of laws, regulations, and administrative provisions relating to the classification, packaging and labelling of dangerous substances, OJ L 196/1 (as amended); Council Directive 77/93 of 21 December 1976 on protective measures against the introduction into the Member States of harmful organisms of plants on plant products (as amended by Decision 91/683, OJ L 376 (29), OJ L 26/20.
3. This task is of course subjective in nature. It is accepted that the authors of the individual sub-Reports may disagree with the selection of information included or omitted. As a result, this Interim Synthesis Report will be distributed also to authors of all other sub-Reports for their remarks.
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