Communication from the Commission to the Council, the European Parliament and the Economic and Social Committee - Towards a Thematic Strategy on the Sustainable Use of Pesticides
Date: 2002-07-01
Institutions: European Commission
Subjects: EU initiative, EU programme, environmental cooperation, environmental policy, environmental protection, exchange of information, pesticide, statistics, sustainable development

COMMISSION OF THE EUROPEAN COMMUNITIES

Brussels, 1.7.2002
COM(2002) 349 final

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE
EUROPEAN PARLIAMENT AND THE ECONOMIC AND SOCIAL COMMITTEE

TOWARDS A THEMATIC STRATEGY ON THE SUSTAINABLE USE OF
PESTICIDES

EXECUTIVE SUMMARY........................................................................................................ 4

I. Introduction............................................................................................................................. 6

II. Objectives of the Thematic Strategy...................................................................................... 7

III. Background, Review of the Current Situation and Evaluation ............................................ 8

1.

Background and Scope................................................................................................. 8

1.1.

Definitions.................................................................................................................... 8

1.2. Scope of the Communication .............................................................................................. 9

1.3. Use of plant protection products: quantities, benefits, costs and risks of using them....... 10

1.3.1.Quantities of PPPs used in the EU .................................................................................. 10

1.3.2.Benefits of the use of PPPs ............................................................................................. 11

1.3.3.Risks and costs associated with the use of PPPs............................................................. 12

1.3.4.Reducing risks associated with the use of PPPs………………………………………..14

2.

Overview of existing Community legislation and initiatives taken by the Member
States .......................................................................................................................... 14

2.1. Community instruments which directly affect PPP use .................................................... 14

2.1.1. Directives controlling the placing on the market of plant protection products .............. 14

2.1.2. Directives setting Maximum Residue Levels (MRLs)................................................... 16

2.1.3. Directives controlling water quality in the Community................................................. 17

2.2. Other Community policies/instruments which indirectly affect PPP use ......................... 18

2.2.1. Common Agricultural Policy (CAP).............................................................................. 18

2.2.2. Directives on the improvements of safety and health of workers at work ..................... 20

2.2.3. Genetically modified organisms (GMO)........................................................................ 20

2.2.4.Community research……………………………………………………………………20

2.3. Further Community initiatives capable of contributing to sustainable use of pesticides.. 21

2.4. National initiatives contributing to PPP risk reduction..................................................... 22

2.5. Instruments for monitoring progress: statistics on PPP use and indicators....................... 23

3.

Evaluation of the present situation............................................................................. 25

IV. Implications for candidate countries .................................................................................. 26

V. International aspects and regional co-operation.................................................................. 27

VI.

Possible elements of a European Thematic Strategy on the Sustainable Use of
Pesticides.................................................................................................................... 28

2

1. Minimising the hazards and risks to health and environment from the use of pesticides:... 29

2. Improved controls on the use and distribution of pesticides ................................................ 31

3. Reducing the levels of harmful active substances through substituting the most dangerous

with safer (including non chemical) alternatives ....................................................... 32

4. Encouragement of the use of low-input or pesticide-free crop farming, particularly by

raising user’s awareness, promoting the use of codes of good practices and
consideration of the possible application of financial instruments ............................ 33

5. A transparent system for reporting and monitoring the progress made in achieving the

objectives of the strategy including the development of suitable indicators ............. 35

6. Candidate countries .............................................................................................................. 35

7. International aspects ............................................................................................................. 36

VII. Conclusions and further work........................................................................................... 37

Annex 1: Studies carried out in the project Sustainable Use of Plant Protection Products ..... 39

Annex 2: Definitions ................................................................................................................ 40

3

EXECUTIVE SUMMARY

The 6th Environment Action Programme (6EAP) as adopted by the European Parliament and
the Council1 provides for the development of a Thematic Strategy on the Sustainable Use of
Pesticides  with  the  objective  of  reducing  the  impact  of  pesticides  on  human  health  and  the
environment  and  more  generally  of  achieving  more  sustainable  use  of  pesticides  and  a
significant overall reduction in risks, while ensuring necessary crop protection.

The  present  legislative  framework  referred  to  in  the  6EAP,  in  particular  Directive
91/414/EEC and the directives on residues in food, mainly concentrates on the start and end-
of-life  stages  of  pesticides,  i.e.  the  authorisation  of  substances  for  use  in  plant  protection
products  (PPP)  before  they  are  placed  on  the  market  (prevention  at  source)  and  maximum
residue levels (MRLs) on food and feedstuffs. Revision of these Directives is under way. The
thematic  strategy  will  complement  the  existing  legislative  framework  by  targeting  the  use-
phase of plant protection products.

This Communication represents a major step in the preparation of the Thematic Strategy on
the Sustainable Use of Pesticides. The main objectives of the thematic strategy are:

-

-

-

-

-

to minimise the hazards and risks to health and environment from the use of pesticides.

to improve controls on the use and distribution of pesticides.

to  reduce  the  levels  of  harmful  active  substances,  in  particular  by  replacing  the  most
dangerous by safer (including non-chemical) alternatives.

to encourage the use of low-input or pesticide-free crop farming.

to  establish  a  transparent  system  for  reporting  and  monitoring  progress  including  the
development of appropriate indicators.

The current situation in the Community and  the Member  States is presented  on the  basis of
the available preparatory work. This includes quantitative data on  PPP use and the benefits,
costs and risks associated with their use. An overview of the relevant Community legislation
is  also  included  (Directive  91/414/EEC,  the  Directives  on  the  setting  of  maximum  residue
levels (MRLs) in foodstuffs, and Directive 2000/60/EC (Water Framework Directive)).

The  Communication  then  explores  the  numerous  links  between  the  thematic  strategy  and
other  Community  policies,  such  as  the  Common  Agricultural  Policy  (especially  agri-
environmental  measures),  health  and  consumer  protection,  the  new  chemicals  policy  and
other thematic strategies called for in the 6EAP (e.g. soil protection).

There is a short summary of policies and initiatives already in place in some Member States,
which are not yet co-ordinated, and a review of available statistics and indicators. The lack of
agreed and harmonised indicators makes it difficult to monitor quantitative progress towards a
sustainable  use  of  pesticides.  The  implications  for  enlargement  and  the  Community’s
international commitments are also reviewed.

1 

Give reference when available

4

                                                
The  core  chapter  of  the  Communication  suggests  several  possible  measures  addressing  the
five above-mentioned objectives, which could become part of the thematic strategy, and states
the Commission’s preferences as to which measures could be proposed.

The  purpose  of  the  Communication  is  to  launch  a  broad  consultation  involving  all
stakeholders such  as  farmers  and  growers,  NGOs,  industry,  other  social  partners  and  public
authorities.  In  addition  to  a  conference  for  stakeholders  in  the  fourth  quarter  of  2002  (open
participation),  the  general  public  will  be  able  to  participate  in  the  debate  via  the  Internet.
Obviously  the  opinions  of  the  Council  and  the  European  Parliament  will  provide  particular
guidance.

Following  the  consultation  process,  the  Commission  will  develop  the  thematic  strategy
specifying the proposed measures in the course of 2003 and present it for approval to Council
and Parliament at the beginning of 2004.

5

I. INTRODUCTION

Sustainable  use  of  pesticides  is  one  of  the  objectives  of  the  Fifth  Environment  Action
Programme2 (5EAP) as revised3. The chapter on agriculture and the chapter on management
of water resources call for the development of

" further measures in the area of agricultural and non-agricultural pesticides with a view to
ensuring  their  sustainable  use"  and  a  decrease  in  "the  input  of  chemicals  to  the  point  that
none of the basic natural processes are affected".

In mid-1992, the Commission and the Dutch authorities launched a study for the development
and evaluation of future strategies for plant protection products (PPP). The project was directed
by a steering committee with representatives from the relevant Commission departments and the
Dutch  Ministries  of  Housing,  Spatial  Planning  and  the  Environment  and  Agriculture,  Nature
Management and Fisheries.

The  project  was  divided  into  two  phases  with  an  interim  workshop  in  June  1994  and  a  final
workshop in May 1998, involving representatives of all Member States and other stakeholders,
i.e.  farmers,  industry,  environmental  and  consumer  groups.  The  project  yielded  a  number  of
reports  on  pesticide  use  and  policy  options4,  and 
the  workshop  produced  several
recommendations.

There was consensus on “the need for  additional European Community PPP risk reduction
policy instruments. These should have common goals and be tailored to meet the needs at EU,
national and local levels”.

In 1999, the Agricultural Council in Cardiff adopted specific objectives for agrochemicals in
the  “Council  strategy  on  the  environmental  integration  and  sustainable  development  in  the
Common Agricultural Policy”5, where it is stated that

“In  addition  to  EU  rules  to  control  maximum  levels  of  pesticides  in  farm  produce
and  measures  to  reduce  the  environmental  risks  of  pesticide  use  (water
contamination, deterioration of biodiversity, etc.), further measures should be
developed for sensitive areas.”

“PPP  and  biocides  should  only  be  used  when  needed  and  in  accordance  with  the

principle of good plant protection practices.”

“There is a need further to reduce the risks to the environment from the use of PPP
and biocides and to continue to ensure that there are no risks to health in their
use.”

On 24 January 2001 the Commission adopted its Communication on the Sixth Environmental
Action  Programme  (6EAP)  together  with  a  proposal  for  a  Decision  of  the  European
Parliament  and  the  Council  for  its  adoption6.  The  Decision  was  adopted  on  XXX7.  Article
7(1)  provides  that  the  impact  of  pesticides  on  human  health  and  the  environment  must  be

2 
3 
4

5 
6 
7 

OJ C 138 of 17. 5. 1993
OJ L 275 of 10. 10. 1998
References are listed in Annex 1. The full texts are available at:
http://europa.eu.int/comm/environment/ppps/home.htm
Agricultural Council, annex 13078/99/Apri184/Env 398
COM (2001) 31 final
scheduled for adoption in June 2002

6

                                                
reduced and more generally that there is a need to achieve a more sustainable use of pesticides
as well as a significant overall reduction in risks and of the use of pesticides consistent with
the necessary crop protection. Pursuant to Article 7 (2) (c) this is to be achieved through:

– 

– 

full  implementation  and  review  of  the  effectiveness  of  the  applicable  legal
framework in order to ensure a high level of protection, when amended.  This
revision  might  include,  where  appropriate,  comparative  assessment  and  the
development  of  Community  authorisation  procedures  for  placing  on  the
market;
a thematic strategy on the sustainable use of pesticides.

In addition, Article 7 (2) (d) calls for the following measures regarding pesticides:

– 

– 

– 

– 

swift ratification of the Rotterdam Convention on the Prior Informed Consent
Procedure  for  Certain  Hazardous  Chemicals  and  Pesticides  in  International
Trade and of the Stockholm Convention on Persistent Organic Pollutants;
amendment  of  Council  Regulation  (EEC)  No 2455/92  of  23 July 1992
concerning  the  export  and  import  of  certain  dangerous  chemicals 8  with  the
aim  of  bringing  it  into  line  with  the  Rotterdam  Convention,  improving  its
procedural mechanisms and improving information to developing countries;
support for the improvement of the management of chemicals and pesticides in
developing  and  candidate  countries,  including  the  elimination  of  stocks  of
obsolete pesticides inter alia by supporting projects aimed at such elimination;
participation  in  international  efforts  to  elaborate  a  strategic  approach  on
international chemicals management.

According to Article 4, the development of a thematic strategy requires a broad approach and
should be developed and implemented in close consultation with the relevant parties, such as
farmers  and  growers,  NGO’s,  industry,  other  social  partners,  the  scientific  community  and
public  authorities,  while  ensuring,  as  appropriate,  consultation  of  candidate  countries.
Thematic strategies should be presented to the European Parliament and the Council within 3
years of the adoption of the 6 EAP.

This Communication represents a major step in the preparation of the Thematic Strategy on
the Sustainable Use of Pesticides. It contains an analysis of the present situation and of the
measures that could be adopted under the thematic strategy. The purpose is to launch a broad
consultation  involving  all  stakeholders,  and  in  particular  the  European  Parliament  and  the
Council.  At  the  end  of  the  consultation  process,  and  taking  into  account  of  all  comments
received,  the  Commission  will  present  to  the  European  Parliament  and  the  Council  the
thematic strategy specifying the detailed measures to be taken.

II. OBJECTIVES OF THE THEMATIC STRATEGY

Pursuant to Article 7 (1) of the 6EAP, the main objective of the thematic strategy is to reduce
the impacts of pesticides on human health and the environment and more generally to achieve
a more sustainable use of pesticides as well as a significant overall reduction in risks and of
the use of pesticides consistent with the necessary crop protection.

8 

OJ L 251 of 29.8.1992, p. 13, as last amended by Regulation (EC) No 2247/98 (OJ L 282 of 20. 10. 1998,
p.12)

7

                                                
As an element of the 6EAP, the thematic strategy should also contribute to the overall aims
and  be  conform  with  the  principles  of  the  programme,  as  set  up  in  Article  2  of  the  above-
mentioned Decision. This requires, among others, that:

it contributes to ensuring a high level of protection of the environment and human health, in
particular taking into account the specific needs for children and the environment;

it  contributes  to  achieving  a  de-coupling  between  environmental  pressures  and  economic
growth;

it  supports  the  improvement  of  the  management  of  chemicals  and  pesticides  in  developing
and candidate countries, including the elimination of stocks of obsolete pesticides inter alia by
supporting projects  aimed  at  such  elimination and the strengthening of  the pesticides policy
within the context of the EC Development Policy9;

it  takes  account  the  principle  of  subsidiarity  and  the  diversity  of  situations  in  the  various
regions of the Community;

it  contributes  to  the  development  of  a  plant  protection  practise  that  fits  into  the  concept  of
sustainable agriculture including social and economic dimensions.

In particular, the specific objectives of the thematic strategy should be:

(i)

to minimise the hazards and risks to health and environment from the use
of pesticides;

(ii)

to improve controls on the use and distribution of pesticides;

(iii)

(iv)

to  reduce  the  levels  of  harmful  active  substances  including  through
substituting  the  most  dangerous  with  safer  (including  non-chemical)
alternatives;

to  encourage  the  use  of  low-input  or  pesticide-free  crop  farming,  in
particular  by  raising  users'  awareness,  by  promoting  codes  of  good
practices  and  consideration  of  the  possible  application  of  financial
instruments;

(v)

to  establish  a  transparent  system  for  reporting  and  monitoring  the
progress  made  in  the  achievement  of  the  objectives  of  the  strategy
including the development of suitable indicators.

III. BACKGROUND, REVIEW OF THE CURRENT SITUATION AND EVALUATION

1.

Background and Scope

1.1.

Definitions

The term ‘pesticides’ is  a  generic name,  which  encompasses  all  substances  or  products  that
kill pests, whether used in agriculture or for other purposes.

9 

COM (2000) 212

8

                                                
Plant  Protection  Products  (PPP)  are  active  substances  and  preparations  containing  one  or
more  active  substances  that  are  used  to  protect  plants  or  plant  products  against  harmful
organisms (pests) or  prevent the action of such  organisms:  they  can  function  in  many  ways
e.g. by killing pests (and then they are pesticides), but also in other ways such as by creating a
physical barrier, by repelling, by attracting pests away from plants, by regulating the growth
of  the  plants  etc..  PPPs  are  used  in  a  wide  spectrum  of  applications,  such  as  agriculture,
landscape gardening and along transport routes. PPP are also used to some extent in forestry
and domestic gardening.

Biocides are active substances and preparations containing one or more active substances that
are  used  to  destroy,  deter,  render  harmless,  prevent  the  action  of,  or  otherwise  exert  a
controlling  effect  of  unwanted  or  harmful  organisms  (pests)  utilised  in  non-agricultural
sectors,  e.g.  for  purposes  such  as  wood  preservation  or  disinfection,  household  uses,  etc,.
Borderlines between PPP and biocides have recently been clarified and documented10.

Most of the important PPPs and biocides are specifically designed chemical compounds and
have pesticidal effects. But PPPs can also be commodity chemicals (fatty acids, amino acids,
other  common  chemicals),  plant  or  animal  extracts  (plant  or  bone  oils,  gelatine,…),  plant
metabolite derivatives or other substances.

1.2. Scope of the Communication

Because  of  the  particular  circumstances  of  pesticide  use  –  deliberate  release  into  the
environment irrespective of their hazard potential - they have been regulated for a long time in
most Member  States and the Community11. Most of  the Community legislation  has  focused
on the authorisation of substances for use in plant protection products before they are placed
on the market (hence in the spirit of a prevention at source) and on maximum residue levels
(MRLs) in food and feedstuffs (hence at the ‘end-of-life’ stage).

Over the years, a highly elaborate system has been developed for evaluating the risks of PPP
use to human health and the environment, and with the adoption of Directive 91/414/EEC, the
Community embarked in 1993 on a reassessment of all PPPs on the market (see next chapter
for  further  details).  A  similar  system  for  the  evaluation  of  biocides  has  only  recently  been
introduced through Directive 98/8/EC12, which also obliged many Member States to introduce
legislation on biocides for the first time. The effects of this relatively new legislation will not
become visible until well after 2006, when the first evaluations of active substances for use in
biocidal  products  will  be  finalised.  Therefore,  neither  the  Commission  nor  most  Member
States  have  currently  sufficient  knowledge  or  experience  to  propose  further  measures
regarding biocides.

Furthermore,  it  is  clear  from  the  Decision  of  the  European  Parliament  and  the  Council
adopting the 6EAP that, although the term ‘pesticides’ is used, the main concerns are related
to  PPPs.  This  emerges  from  the  fifth  indent  of  Art.  7  (1),  which  calls  for  ‘…  a  significant
overall  reduction  in  risks  and  of  the  use  of  pesticides  consistent  with  the  necessary  crop
protection’, and Art. 7 (2) (c), which specifies Directive 91/414/EEC as the applicable legal
framework that is to be complemented by the thematic strategy.

10 

11 
12 

Guidance  document  agreed  between  the  Commission  services  and  the  competent  authorities  of  the
Member States for the biocidal products Directive 98/8/EC and for the plant protection products Directive
91/414/EC (available at: http://www.europa.eu.int/comm/food/fs/ph_ps/pro/wrkdoc/wrkdoc17_en.html)
Earliest Community Directives regulating plant protection products go back to 1979
OJ L 123, 24. 4. 1998, p 1

9

                                                
Consequently, this Communication will focus on the use of Plant Protection Products (PPPs)
and is an important step in the preparation of the thematic strategy as requested in the 6EAP.
Should, in the future, comparable measures be considered necessary for biocides, they will be
incorporated in the thematic strategy as appropriate.

1.3. Use of plant protection products: quantities, benefits, costs and risks of using them

1.3.1.Quantities of PPPs used in the EU

Agriculture is by far the biggest PPP-using sector13. The European Union currently accounts
with approximately 320 00014 tonnes of active substances sold per year for one quarter of the
world  market  of  PPPs.  The  major  types  of  product  are  fungicides  (ca.  43%  of  the  market),
followed by herbicides (36%), insecticides (12%) and other pesticides (9%).

The crop protection market is estimated to represent more than € 6 billion for the European
Union. PPP sales measured in monetary terms increased annually in the years preceding 1999,
whilst volumes have shown variable trends.

Figure  1  shows15,  that  in  1991  and  during  the  period  1993  to  1995  the  use  (volumes)  of
pesticides fell, partly in response to changes (like set-aside, direct payment,…) introduced in
1992 in the Common Agricultural Policy, but this trend seems to have  reversed in the  years
thereafter with consumption rising again

350

300

250

200

150

100

50

0
1990

1991

1992

1993

1994

1995

1996

Fungicides

Herbicides

Insecticides

1997

Others

1998

Figure 1: Total sales of pesticides in the EU-15 (in kilotonnes of active ingredients))

It should be noted that statistics concerning the total volume (or value) of pesticides sold or
used in the 15 EU Member states are to be interpreted with caution to the extent that they say
little about the nature of the active substances concerned and, consequently, about the risks of
negative  impacts  associated  with  their  use.  Indeed,  an  increase  (or  a  reduction)  in  the  total
volumes of pesticides sold/used is not necessarily equivalent to an increase (or a reduction) in
the risks associated with their use. Thus, for instance, an increase in the volume of pesticides
sold might be due to an increased use of less toxic and persistent and more narrowly targeted
pesticides, which could eventually result in reduced risks of environmental damage.

13 

14 
15 

Non agricultural use (such as in private gardens) is estimated to account for only 2% of total pesticide use
(Environmental Pressure Indicators for the EU, June 2001, Eurostat)
Eurostat and European Crop Protection Association, 1999
Agriculture, Environment, Rural Development: Facts and Figures - A Challenge for Agriculture, 1999

10

                                                
The use (both nature and total volumes applied) of pesticides varies depending on the type of
agricultural  produces  -  the  largest  quantities  of  PPPs  are  used  on  vines,  cereals,  vegetables
and  potatoes  -  and  on  a  range  of  factors,  such  as  outbreaks  of  plant  diseases  or  plagues  of
insects. Moreover, a number of other features affect figures from one year to the next, such as
weather,  seasonal  factors,  prices  of  pesticides  and  land  set-aside  obligations.  Field  research
has  also  shown  that  the  amount  of  active  substance  applied  on  the  same  crop  in  the  same
region during the same growing season can vary considerably.

The  application  of  pesticides  per  hectare  of  agricultural  land  also  varies  widely  between
European  countries.  In  the  eighties  and  nineties,  application  was  lowest  in  the  Nordic
countries, and highest  in  Southern  and Western Europe.  By far the  highest application rates
were observed in the Netherlands. Moreover, in the Northern and Central European countries,
herbicides are predominant, whereas in the Southern and Western countries insecticides and
fungicides dominate.

1.3.2. Benefits of the use of PPPs

There  are  significant  economic  benefits  associated  with  the  use  of  PPPs.  They  are  used  by
farmers  to  improve  or  safeguard  yields  by  eliminating  or  reducing  competition  from  weeds
and  attacks  by  pests,  to  protect  and  preserve  plant  products  against  harmful  organisms,  to
improve  or  protect  quality  of  the  produce,  and  to  minimise  labour  input.  PPPs  also  play  an
essential role in ensuring reliable supplies of agricultural products each year, by contributing
to prevent fluctuations of annual yields. Moreover, the responsible use of PPPs contributes to
ensuring  the  availability  of  low-priced  fruits  and  vegetables  of  good  quality,  which  makes
them affordable for all consumers.

According  to  some  sources,  the  use  of  fungicides  also  helps  to  reduce  mycotoxins  in  food,
such as aflatoxin or ergotamin. However, the Scientific Committee on Plants (SCP) examined
the relationship between the use of PPPs on food plants and the occurrence of mycotoxins in
foods16. It concluded that there is not sufficient evidence that pesticides play a prominent and
consistent role in preventing or inhibiting the production of mycotoxins by toxicogenic fungi.
Data from field studies are equivocal and the SCP recommended further research on the issue.

The use of PPPs reduces demand for land for food production17 and enables the production of
a wider variety of foods regionally, which in turn can reduce transport costs and make more
land available for other uses, e.g. amenity, natural parks, protection of biodiversity.

Conservation  tillage, which  reduces erosion,  and  minimum  tillage  techniques,  which  reduce
the demand for fossil energy in agriculture and decrease the leaching of nutrients, also partly
depend on the use of herbicides.

However, no overall EU figures are available to evaluate these benefits.

The European plant protection industry is a significant economic player on the world market
and  an  important  employer  in  Europe  (about  35.000  people).  Three  of  the  five  largest
companies are based in Europe.

16 

17 

Opinion  of  the  Scientific  Committee  on  Plants  adopted  on  24  September  1999,  available  at:
http://www.europa.eu.int/comm/food/fs/sc/scp/out56_en.html
Oppenheimer,  Wolf  and  Donnelly,  1998.  Possibilities  for  future  EU  environmental  policy  on  plant
protection products, Synthesis report of six sub-reports in PES-A/phase 2

11

                                                
1.3.3. Risks and costs associated with the use of PPPs

Pesticides are chemicals that require particular attention because most of them have inherent
properties  that  make  them  dangerous  to  health  and  environment18.  The  risks  (and  related
costs)  associated  with  their  deliberate  release  into  the  environment  during  application,  in
particular  for  use  in  the  agricultural  sector,  are  accepted  by  society  because  there  is  a
significant economic benefit related to the use of pesticides (see above).

Risks  to  human  health  can  occur  through  direct  exposure  (industrial  workers  producing
pesticides  and  operators  using  them),  and  indirect  exposure  (consumers  and  bystanders).
According  to  a  survey  of  the  European  Federation  of  Agricultural  Workers’  Unions  (EAF),
the  most  common  observed  adverse  effects  of  pesticides  on  workers  and  operators  are
headaches,  vomiting,  stomach-aches,  and  diarrhoea,  caused  by  exposure  during  application
(39% of reported incidents), preparation or mixing (28% of reported incidents), and handling
of containers (6% of reported incidents)19. A survey of the Health and Safety Executive in the
UK for the year 2000/2001 reports 170 pesticide incidents, 71 of which involved allegations
of ill health20.

Consumers and bystanders can be subject to indirect exposure, due to the presence of PPP via
residual amounts in agricultural produce. This exposure is evaluated by the authorities in the
Member  States  and  at  Community  level  and  by  the  WHO/FAO  Codex  alimentarius
Committee on Pesticide Residues. Maximum Residue Levels (MRLs) have been set for many
PPP commodity combinations, and national as well as co-ordinated Community programmes
are in place for monitoring PPP residues in food21.

Particular  attention  must  be  devoted  to  especially  sensitive  population  groups,  such  as
children  (due  to  specific  physiological  and  developmental  factors),  the  elderly  (due  to  their
possibly compromised metabolic  capacity), or other particular  risk  groups (immunologically
compromised  people,  chronically  sick,  etc.),  and  workers  (due  to  their  possible  intensive
exposure). At present, the scientific community sees possible gaps in knowledge for children,
which are probably also the most sensitive group  with regard to  suspected ‘cocktail effects’
(i.e. mixtures of several substances)22.

Exposure via drinking water, although  strictly limited by  the  EU  Drinking  Water  Directive,
requires  constant  efforts  to  monitor  and  –  taking  into  account  the  long  time  scale  of
contamination and remediation – high scrutiny in the regulatory process.

18  Most PPP are dangerous substances. About 500 PPP are included in annex I of Directive 67/548/EEC on

19 

20 

21 

22 

the classification, packaging and labelling of dangerous substances
Summary of the EFA questionnaire on the health and safety linked to pesticides presented in the second
EFA  colloquium  on  pesticides,  6-8/3/1997.  2160  workers  in  all  Member  States  responded.  About  20%
reported adverse incidents.
Health and Safety Executive; Agriculture and Wood Sector. Pesticide Incidents Report 2000/01. Available
on the Internet: www.hse.gov.uk
The  latest  monitoring  programme  was  adopted  in  Commission  Recommendation  2002/1/EC  of  27
December  2001  concerning  a  coordinated  Community  monitoring  programme  for  2002  to  ensure
compliance with maximum levels of pesticide residues in and on cereals and certain other products of plant
origin (OJ L 2, 4.1.2002, p. 8)
Children’s Health and Environment : a review of evidence. A joint report from the European Environment
Agency and the WHO Regional Office for Europe, Tamburlini et al (2002)
(http://org.eea.eu.int/documents/newsreleases/our_childrens_health-en

12

                                                
Potential  exposure  of  bystanders  and  residents  to  pesticides  via  the  air  might  constitute  an
exposure  route,  which  needs  further  attention  by  research  and  possibly  also  regulatory
measures.

Risks to human health and the environment consist of acute and/or chronic adverse effects on
humans and on non-target species. Acute effects are mainly due to the high toxicity of certain
PPPs. Chronic effects which might also affect the fitness of exposed populations include those
due  to  bioaccumulation  and  persistence  of  substances,  irreversible  effects  such  as
carcinogenicity,  mutagenicity  and  genotoxicity,  or  adverse  effects  on  the  immune  or
endocrine  systems  of  mammals,  fishes  or  birds.  It  has  to  be  noted  that  so  far  no  active
substance,  which  is  classified  in  category  I  for  any  of  these  effects,  has  been  included  in
Annex  I  of  Directive  91/414/EEC,  certainly  not  if  such  effects  are  to  be  expected  at
environmental concentrations and exposure conditions.

Spray drift, leaching or run-off are diffuse sources of uncontrolled dissemination of PPPs into
the  environment  leading  to  pollution  of  soil  and  water  compartments  (surface  water  and
ground  water23),  which  can  be  minimised  by  controls  and  respect  of  good  application
practices. Environmental contamination can also occur during and after application, cleaning
of equipment or uncontrolled, illegal disposal of PPPs or their containers (point sources).

PPP  use  may  also  entrain  additional  indirect  effects  on  the  ecosystem,  e.g.  loss  of
biodiversity. If weed control is less systematic, the resulting increase in insect populations is
beneficial  for  the  populations  of  insect-feeding  birds24.  Over-efficient  weed  control  means
that such birds may suffer from shortage of food. Biodiversity, however, is also influenced by
a number of other factors, such as agricultural practices, plot sizes, type of crops, etc.

In recent years, the emergence of a new type of hazard, endocrine disruption, has intensified
the  debate  on  health  and  environment  protection.  Endocrine  disrupters  are  substances
(including several pesticides), which are suspected of interfering with the endocrine systems
of  both  humans  and  wildlife,  and  which  may  cause  adverse  health  effects  such  as  cancer,
behavioural changes and reproductive abnormalities even through exposure to extremely low
doses.  In  a  recent  Communication25  the  Commission  described  the  problem  of  endocrine
disruption,  its  causes  and  consequences  and  identified  appropriate  policy  measures  on  the
basis of the precautionary principle.

In  developing  countries,  the  risks  are  clearly  higher.  This  is  the  consequence  of  various
factors  such  as  the  continued  use  of  older  and  more  toxic  products,  the  far  less  advanced
infrastructures  and  capacity  for  testing  (under  local  conditions),  evaluating,  authorising  and
controlling  the  use  and  disposal  of  pesticides  and  the  unavailability  of  mitigation  measures
such as protective equipment. Many cases of poisoning and even death have been reported26.

In  practice,  it  is  extremely  difficult  to  quantify  many  of  the  actual  adverse  effects  resulting
from  the  use  of  pesticides  and  even  more  difficult  to  attribute  monetary  values  to  them,  in
particular as there are no agreed values for many of the so called ‘externalities’ such as effects

23 

24 
25 
26 

The most commonly found pesticides in groundwater are atrazine and simazine, broad spectrum herbicides
used  in  high  quantities  (Source:  Europe’s  environment:  the  Second  Assessment  (European  Environment
Agency, 1998)
Assessment of the Benefits of Plant Protection Products, Saub-Report, Eyre Associates, 1997
Communication from the Commission on Community Strategy for Endocrine Disrupters, COM (1999) 706
A recent case has been internationally recognised, following an evaluation in the context of the Rotterdam
Convention during the 3rd meeting of the Chemical Review Committee in February 2002.

13

                                                
on  the  environment.  Therefore,  like  for  benefits,  it  is  not  possible  to  give  a  figure  of  the
overall costs of the use of pesticides in the EU.

1.3.4. Reducing risks associated with the use of PPPs

Potential benefits accruing from the PPP use need to be weighted against the risks of negative
impacts  on  human  health  and  environment.  Whereas  the  use  of  pesticides  is  necessary  to
secure crop protection, there is the need to reduce the risks associated with their use.

Also,  there  is  a  widespread  perception  that  those  drawing  the  benefits  from  the  use  of
pesticides  (in  particular  lower  costs  leading  to  higher  competitiveness  of  the  agricultural
sector and industry as well as lower consumer prices) are not necessarily the same incurring
the external costs linked to the adverse effects (in particular the environmental effects).

In practice, different PPP pose different types and levels of risk depending on a whole set of
factors  that  are  the  basis  of  the  risks27.  In  this  context,  it  clearly  appears  that  the  volume
applied  is  only  one  of  the  factors  that  are  at  the  basis  of  risks  associated  with  the  use  of
pesticides. When identifying the best measures for reducing risks, attention has to be paid to
all these factors, as well as to the different phases of the lifecycle of the pesticides, from the
placing on the market to their distribution, application for crop protection purposes, and end-
of-life (waste disposal and residues.

2.

Overview  of  existing  Community  instruments  and  initiatives  taken  by  the
Member States

2.1. Community instruments which directly affect PPP use

2.1.1. Directives controlling the placing on the market of plant protection products

Community  pesticide  legislation  distinguishes  between  “active  substances”  and  “plant
protection products” (PPPs). The active substance is the ingredient that carries the biological
activity. The PPP is the form in which it is put on the market. Other ingredients may improve
adherence to plant surfaces or help to achieve a homogeneous and stable mixture with water
in the spray tank. Combination of several active substances within a PPP and of several PPPs
in a tank mix is frequent.

The  two  key  legal  instruments  at  Community  level  are  Council  Directive  91/414/EEC
concerning  the  placing  on  the  market  of  plant  protection  products  and  Council  Directive
79/117/EEC  prohibiting  the  placing  on  the  market  of  PPPs  containing  certain  active
substances.

The  main  objective  of  Council  Directive  91/414/EEC  is  to  guarantee  that  individual  PPPs,
placed on the market in the Community have no harmful effects on human and animal health
or unacceptable effects on the environment. The Directive came to harmonize the provisions

27 

Risks of individual pesticides are characterised by the adverse effects  which  an  active  substance  has  the
inherent  capacity  to  cause  (so-called  hazards,  which  are  reflected  in  the  toxicological  classification)  and
the  likely  exposure  for  human  populations  or  environmental  spheres,  such  as  water,  soil  and  air,  which
depends on, among others, the pathways and rates of movement of a substance and its transformation or
degradation products after application. More information on risk assessment and its limits can be found for
example  in  the  Communication  from  the  Commission  on  the  Precautionary  Principle  (COM  (2000)  1
final).

14

                                                
already  in  force  in  most  Member  States  concerning  the  conditions  and  procedures  for  the
authorisation of PPPs.

The Directive provides for a two-step process: active substances for which the evaluation has
shown that there are uses which pose no such unacceptable risks are included in Annex I to
the  Directive.  Only  those  active  substances  may  be  used  in  PPPs,  which  have  to  be
individually  authorised  by  the  Member  States.  Active  substances  for  which  there  is  no
evidence  that  their  use  presents  no  unacceptable  risk  for  human  and  animal  health  or  the
environment  must be withdrawn from the  market. The Directive also contains a scheme  for
PPP risk assessment to be used for authorisations in Member States (the Uniform Principles
set out in Annex VI). The Directive further provides for the possibility to restrict authorisation
to certain uses only and to lay down specific application requirements, e.g. related to operator
safety or to water protection28.

The Directive initiated a 12-year programme to review all active substances that were on the
Community  market  at  the  date  of  its  entry  into  force.  However,  the  process  is  slow  and
resource-intensive  because  of  the  complex  scientific  and  administrative  work  involved
(monograph  written  by  a  Rapporteur  Member  State,  scientific  peer  review,  discussions
between experts at the evaluation meetings, consultation of the Scientific Committee of Plants
and vote in the Standing Committee on the Food Chain and Animal Health). The Commission
has recently submitted a report on the functioning of the Directive 10 years after its adoption
to Council and Parliament29. The report suggests, among other things, that it is necessary to
postpone the deadline for completion of the review-process to July 2008.

An  important  shortcoming  of  Directive  91/414/EEC  is  that  it  is  primarily  based  on
assessments of the effects of individual compounds, whereas potential additive or synergistic
effects of mixtures containing several active substances are only  evaluated to a very limited
extent.  Moreover,  the  Directive  does  not  provide  for  explicit  empowerment  at  Community
level  to  check  whether  all  conditions  established  by  the  Directive  are  enforced  by  Member
States30.

The  6EAP  identifies  full  implementation  and  review  of  effectiveness  of  the  Directive  as  an
essential  element  to  ensure  a  high  level  of  protection  of  human/animal  health  and  the
environment. It also urges to improve the overall mechanism of the  authorisation system, in
particular by including, where appropriate, comparative assessment of active substances and
the development of Community authorisation procedures for placing on the market.

In  their  reaction  to  the  10-year  report,  the  Council  and  the  European  Parliament,  while
agreeing  to  a  prolongation  of  the  review-programme,  underline  the  need  for  review  of  the

28 

29 

30 

Directive 91/414/EEC also foresees specific provisions related to the packaging and labelling of PPP. In
particular, concerning labelling, the Directive establishes that it must indicate the uses for which the PPP
has been authorised, the specific conditions under which it may be used, including directions for use and
dose  rates  for  each  use  provided  for  under  the  terms  of  the  authorisation.  Moreover,  Member  States  are
required  to  prescribe  a  proper  use  of  PPP,  including  not  only  the  exclusive  use  of  PPP  authorised,
packaged and labelled in accordance with the Directive, but also compliance with the conditions specified
on the labelling and the application of the principles of good plant protection practice as well as, whenever
possible, the principle of integrated control.
Report from the Commission to the European Parliament and the Council on the evaluation of the active
substances of PPP. COM (2001) 444 final of 25. 7. 2001
Based on provisions of the Directive (Art.17), Member States must also take inspection measures to check
that placing on the market of PPPs, distribution and use comply with the requirement of the Directive, but
this provision stays rather general.

15

                                                
Directive and provide guidance on a number of issues that the Commission should take into
consideration31.

2.1.2. Directives setting Maximum Residue Levels (MRLs)

Several Directives set Maximum Residue Levels (MRLs) in foodstuffs32.  The  Directives fix
the  MRLs  for  commodity/PPP  combinations  based  on  Good  Agricultural  Practices  (GAP)
taking into account the Acceptable Daily Intake (ADI). MRLs are expected to guarantee that
likely  exposure  to  PPP  is  toxicologically  acceptable;  they  are  under  constant  review.
However, one element  for  future  refinement  may  be  the  assessment  of  potential  cumulative
effects  of  different  PPPs,  which  are  currently  not  always  taken  into  account  when  setting
MRLs.

A recent report on the monitoring of residues in plant products on the market33 has shown an
increase in the percentage of samples without any detectable residues (from 60% in 1996 to
64%  in  1999).  MRLs  were  exceeded  in  around  4%  of  the  samples  in  1999,  which  also
represented a slight increase in comparison to the years before (see figure 2). There was also a
slight increase in the number of samples with multiple residues (13.1%-14.1%).

Figure 2: Monitoring Results (1996-1999) for fruit vegetables, and cereals

However, it should be noted that a considerable proportion of the cases in which MRLs were
exceeded were found to be due to intentional or unintentional misuse. Also, actual consumer
exposure to pesticide residues remains well below the acceptable daily intakes, even if MRLs
are exceeded in such a relatively small percentage of products sampled.

31 

32 

Council Conclusions adopted on 12 December 2001. (Annex III to draft minutes of 29 January 2002 (Doc.
15287/01), available at: http://register.consilium.eu.int/pdf/en/01/st15/15287en1.pdf.
European Parliament Resolution on the Commission report – doc P5 (2002)0276 – 30 May 2002
Council Directive 76/895/EEC, 86/362/EEC (as last amended by Directive 2001/48/EC), 86/363/EEC (as
last amended by Directive 2001/39/EC) and 90/642/EEC (as last amended by 2001/48/EC)

33  Monitoring of Pesticide Residues in Products of Plant Origin in the European Union, Norway and Iceland.

1999 Report (SANCO/397/01-final)

16

                                                
Implementation of the Directives on the setting of MRLs has not been as fast as expected and
Community  levels  have  been  established  only  for  a  limited  number  of  substances34.  The
Commission intends to put forward a proposal in the near future to consolidate and amend the
legislation  on  residues.  The  philosophy  underlying  the  new  Regulation  would  be  that  any
unnecessary exposure of consumers to residues through food should be prevented by the best
available  agricultural  methods.  Within  these  strict  limits  guaranteeing  the  highest  level  of
protection for the European consumers, the new Regulation should also ensure that the setting
of  MRLs  does  not  constitute  an  unnecessary  technical  barrier  for  the  international  trade  of
commodities, in particular from developing countries.

2.1.3. Directives controlling water quality in the Community

The new Water  Framework  Directive  (WFD)35 marks  a  change  in  Community  water  policy
towards a coherent and integrated framework for assessment, monitoring, and management of
all surface waters and groundwater based on their ecological and chemical status. The targets
and principles set out in Directive 91/414/EEC for pesticides were translated into objectives
for all waters and will be implemented on a river basin scale. With the adoption of the WFD,
Community  water  policy  is  based  firmly  on  the  precautionary  principle  and  the  sustainable
use of water.

Updated  environmental  requirements  of  the  existing  surface  water  Directive  (75/440/EEC),
the  Directive  on  discharges  of  dangerous  substances  (76/464/EEC)  and  the  groundwater
Directive  (80/68/EEC)  have  been  incorporated  into  the  WFD.  It  is  planned  that,  once  the
WFD is fully operational, these Directives will be repealed in 2013.

For the protection of surface waters, the Directive introduces criteria for establishing a list of
priority  substances  and  priority  hazardous  substances,  for  which  specific  measures  such  as
quality  standards  and  emission  controls  must  be  taken  in  order  to  reduce  or  eliminate
emissions, discharges and losses. A list of 33 priority substances was adopted in 200136; 13 of
these are used in PPPs. Whilst the Community will propose measures for priority substances
by  the  end  of  2003,  Member  States  must  prepare  comprehensive  programmes  of  measures
within river basin management plans by 2009, which include measures against pollution due
to pesticides.

In  order  to  achieve  good  groundwater  status,  the  Commission  will  propose,  by  the  end  of
2002,  criteria  for  assessing  the  chemical  status  of  all  pollutants  and  the  reversal  of  upward
trends in their concentration. As regards  active substances contained in pesticides  (and  their
relevant  metabolites)  the  present  limit  value  (0.1  (cid:1)g/l),  which  is  an  exclusion  criterion  for
authorisation purposes, is considered as the maximum permissible concentration for defining
good groundwater chemical status.

Full implementation of the WFD Directive is expected to make a considerable contribution to
an  overall  reduction  of  risks  from  PPPs  in  the  aquatic  environment.  However,  the
implementation  process  must  be  supported  and  complemented  by  specific  initiatives
regarding pesticides. These should be coherent and closely linked since the sustainable use of

34 

35 

36 

Community  MRLs  have  been  established  for  the  130  most  commonly  used  substances  and  various
agricultural commodities amounting altogether to 17.000 MRLs.
Directive 2000/60/EC of the European Parliament and of the Council of 23  October  2000  establishing  a
framework for Community action in the field of water policy. OJ L 327 of 22. 12. 2000, p. 1.
Decision No 2455/2001/EC of the European Parliament and of the Council. OJ L 331, 15.12.2001, p. 1.

17

                                                
pesticides in European river basins is a prerequisite for the achievement of the objectives of
the Directive.

2.2. Other Community instruments which indirectly affect PPP use

2.2.1. Common Agricultural Policy (CAP)

A  principal  function  of  agriculture  is  production.  Maximising  returns  and  minimising  costs
have given rise to increasing intensification of agriculture  in the last 40  years. The  CAP, in
particular  before  the  introduction  of  the  1992  reforms,  has  certainly  contributed  to
intensification of production, and this is also reflected in the significant increase in PPP use.

First steps to integrate environmental concerns into the CAP date back to the mid-1980s when
the promotion of environmentally friendly farming practices became a policy pursued by the
CAP. In addition, the 1992 reform introduced some elements  having beneficial side-effects.
Cuts  in  institutional  prices  in  combination  with  direct  payments  and  set-aside  have  reduced
incentives  to  intensify  production  and  have  therefore  contributed  to  reduced  use  of  PPPs  in
the  subsequent  years.  Another  important  instrument  to  reduce  intensity  of  production  was
introduced  with  Council  Regulation  (EEC)  No  2078/92  on  agricultural  production  methods
compatible with the requirements of the protection of the environment and the maintenance of
the countryside.

A study37 carried out in 1998 suggested that 20% of the variation of PPP use is attributable to
the effects of the CAP. This percentage may be higher in sectors with heavy pesticide reliance
and large CAP payments such as cotton or tobacco.

In  its  Communication  “Directions  towards  sustainable  agriculture”38,  the  Commission
described  in  detail  the  general  trends  in  European  agriculture  including  intensification,
specialisation, marginalisation and developments in organic farming.

The  latest  reform  of  the  CAP,  as  established  in  the  Agenda  2000,  is  designed  to  achieve
improved  competitiveness  and  further  progress  on  integrating  environmental  requirements
into the CAP. This has been pursued by further cuts in market support and a strengthening of
rural  development  policy.  Ensuring  farming  practices  that  protect  the  environment  and
preserve the countryside is  an integral element of the  agreed package  of measures. Farming
practices to safeguard the environment  have been incorporated in Council  Regulations (EC)
1259/1999  establishing  common  rules  for  direct  support  schemes  under  the  CAP,  and
1257/199939  on  support  for  rural  development  and  amending  and  repealing  certain
regulations, respectively.

Regulation 1259/1999 establishes a link between environmental protection requirements and
direct  support  to  producers  from  the  CAP.  Member  States  must  take  the  environmental
measures they consider appropriate such as:

– 
– 
– 

support in return for agri-environmental commitments,
general mandatory environmental requirements,
specific  environmental  requirements  constituting  a  condition  for  direct
payments.

37 
38 
39 

See footnote 17
COM (1999) 22 final
OJ L 160, 26. 6. 1999, p. 80 and p. 113

18

                                                
With  respect  to  the  latter  two  options,  Member  States  are  authorised  to  use  cuts  in  direct
payments  as  sanction  to  support  the  enforcement  of  environmental  requirements.  The
corresponding  implementation  Regulation  (EC)  963/2001  provides  for  annual  progress
reports on the implementation of measures and penalties by Member States to be submitted to
the Commission40. The first of these reports had to be submitted at the latest in  April 2002.
The Commission is currently evaluating the results of this survey.

Council  Regulation  1257/1999  on  support  for  rural  development 
invites  Member
States/Regions  to  develop  integrated  programmes  at  regional  level  for  the  sustainable
development  of  rural  areas.  For  many  measures  (agri-environment,  less  favoured  areas)
farmers'  eligibility  for  support  has  as  a  minimum  requirement  the  respect  of  Good  Farming
Practice, which is the standard of farming a reasonable farmer would follow in his region in
order  to  avoid  negative  impacts  on  the  environment  and  which  includes  in  any  case  the
respect  of  mandatory  environmental  legislation.  The  national/regional  rural  development
plans contain these Codes of Good Farming Practice. Also relevant for pesticide use are the
agri-environmental measures, through which farmers are paid for environmental services they
provide  beyond  the  level  of  Good  Farming  Practice.  Regarding  pesticide  use,  this  include
reporting  on  actual  use  of  pesticides,  lower  use  of  pesticides  to  protect  soil,  water,  air  and
biodiversity, the use of IPM techniques, or conversion to organic farming.

Further  positive  impacts,  particularly  in  sensitive  areas,  can  be  expected  from  a  specific
provision regarding  "Less  Favoured  Areas"  and  areas  with  environmental  restrictions  in  the
framework of the regional development plans. Payments to farmers in the framework of these
measures are  conditioned on compliance  with the above-mentioned codes of Good  Farming
Practice.

Agri-environmental  measures  have  already  influenced  PPP  use  directly,  for  instance  by
techniques
promoting  Integrated  Pest  Management 
(IPM/ICM),  and  organic  farming.  Despite  the  fact  that  less  than  3.5  %  of  the  total  CAP
spending is devoted to agri-environmental measures, such measures affect more than 20% of
the total agricultural area in the EU. There have been highly successful results in the reduction
of PPP use in individual regions with specific programmes, for instance in Emilia Romagna
(Italy), with reductions of up to 55% for certain types of production41.

/  Integrated  Crop  Management 

Organic  farming,  regulated  by  Council  Regulation  (EEC)  2092/9142  and  supported  by  agri-
environmental  measures,  greatly  reduces  pesticide  use.  However,  some  PPPs,  regarded  as
traditional in organic farming, are still authorised for specific purposes (the most controversial
are  certain  copper  salts,  which  are  toxic  for  the  aquatic  environment).  While  these  are  also
used in conventional agriculture, successful efforts have been undertaken to limit their use in
organic farming.

In the framework of the Common Organisation of the Market in fruit and vegetables, support
is  granted  to  producer  organisations  for  the  implementation  of  operational  programmes  that
must  obligatorily  comprise  environmental  measures  (going  beyond  application  of  good
farming practice), including measures aiming to reduce the use of PPP, for example through
the development of organic or integrated production.

OJ L 136, 18.5.2001, p.4

40 
41  Working Document: State of the application of Regulation (EEC) No 2078/92: Evaluation of Agri-

Environment Programmes (Doc. VI/7655/98), p. 40 ff., available at:
http://www.europa.eu.int/comm/agriculture/envir/programs/index_en.htm
OJ L 198, 22.7.1991, p. 1

42 

19

                                                
Although all the above-mentioned measures helped to achieve a certain de-coupling of yield
development  from  pesticide  use,  there  is  no  sign  of  a  significant  downward  trend  in  the
dependency on PPPs in agriculture in general (see figure 1). However, the midterm review of
the  CAP  reform  under  Agenda  2000  creates  a  new  possibility  for  further  integration  of
environmental concerns, including with regard to the use of PPPs.

2.2.2. Directives on the improvements of safety and health of workers at work

Council Directive 89/391/EEC43 on the introduction of measures to encourage improvements
in  the  safety  and  health  of  workers  at  work,  in  particular  Directive  98/24/EC44on  the
protection  of  the  health  and  safety  of  workers  from  the  risks  related  to  chemical  agents  at
work and Council Directive 89/656/EEC45 on the minimum health and safety requirements for
the use by workers of personal protective equipment at the workplace, have created conditions
for improvements in the safety of workers and operators. Whereas they only define minimum
requirements, leaving scope for higher levels of protection in individual Member States.

Operator  safety is another  very  important element in  the evaluation process  under Directive
91/414/EEC,  and  often  constitutes  a  reason  for  non-inclusion  of  an  active  substance  in  the
Annex to the Directive. Where appropriate, conditions ensuring sufficient operator protection
are to be specified before the inclusion of an active substance in Annex I to the Directive.

2.2.3. Genetically modified organisms (GMO)

A new factor influencing the use of PPPs is the cultivation of genetically modified herbicide
tolerant and pest tolerant plants (GMO). The adverse effects of widespread use of GMOs are
currently  under  discussion  and  are  taken  into  account  in  Directive  2001/18/EC46  on  the
deliberate release into the environment of GMOs.

An evaluation of whether the cultivation of GMOs will lead to a reduced  risk related to the
PPP  use  is  currently  ongoing  :  Member  States  are  engaged  in  substantial  field  trials  on  the
environmental  effects  of  GMO  cultivation.  The  Commission  has  recently  set  up  a  Working
Group  on  Herbicide  Tolerant  Crops  in  the  framework  of  Directive  90/220/EEC47,  which
among  other  tasks  will  consider  the  use  of  herbicides  on  such  crops.  One  of  the  major
problems  is  the  possibility  of  uncontrolled  transfer  of  the  resistance  genes  to  weeds,  which
has  already  been  observed  for  rape  and  beet.  In  its  Communication  on  Life  Sciences  and
Biotechnology48,  the  Commission  has  recently  announced  an  action  plan  including  a.o.  the
reinforcement of the monitoring of potential long term effects of GMOs.

2.2.4. Community research

The  Community  supports  research  efforts  aimed  at  the  reduction  and  sustainable  use  of
pesticides.  Over  200  projects  related  to  pesticides  have  been  funded  under  the  five
Community framework programmes on research and development. Most of these projects fall

43 
44 
45 
46 

47 

48 

OJ L 183 of 29. 6. 1989 p 1
OJ L 131 of 5.5.1998 p 11
OJ L 393 of 30. 12. 1989 p 18
Directive 2001/18/EC of the European Parliament and of the Council of 12 March 2001 on the deliberate
release  into  the  environment  of  GMO  and  repealing  Council  Directive  90/220/EEC.  Commission
Declaration. OJ L 106 of 17. 4. 2001 p 1
OJ  L  117,  8.5.1990,  p.  15.  The  Directive  has  been  repealed  by  Directive  2001/18/EC  with  effect  on
17.10.2002. The first meeting of the Working Group took place on 4 December 2001.
COM (2002) 27 final

20

                                                
under  the  Quality  of  Life  programme  and  the  Energy,  Environment  and  Sustainable
Development programme and relate, in particular, to food, nutrition and health; environment
and health; sustainable agriculture, soil and water resources.

2.3. Further Community initiatives capable of contributing to sustainable use of pesticides

The Commission  has already undertaken or is currently  preparing  several  new  initiatives  or
reviews  of  legislation  in  other  areas  which  could  directly  or  indirectly  contribute  to  a  more
sustainable use of PPPs.

Also within the framework of the 6EAP, the Commission has adopted a Communication on
soil protection49, in which contamination is identified as a threat to soil. Whereas the use of
PPPs  can  contribute  to  such  contamination,  measures  to  reduce  PPP  use  (in  particular
herbicides)  could  increase  the  need  for  mechanical  weed  control,  which  in  its  turn  would
increase the potential for erosion (also identified as a threat to soil)  and  the consumption of
fossil  energy  in  agriculture.  It  is  obvious  that  the  two  thematic  strategies  will  have  to  be
closely co-ordinated.

In addition, the Commission is preparing a Community Strategy on Environment and Health,
which will seek to limit to an acceptable level human exposure to environmental threats, and
in  particular  dangerous  chemicals  from  all  sources.  Particular  attention  will  be  given  to  the
more  vulnerable  groups  of  the  population,  such  as  children,  and  to  the  development  of
appropriate monitoring programs. Exposure of consumers to PPPs occurs mainly through diet,
in  particular  residues  in  food  and  water.  The  Thematic  Strategy  on  the  Sustainable  Use  of
Pesticides will have to take full account of the needs and actions identified in the strategy on
Environment and Health, as well as new scientific evidence.

The Commission is also currently developing all necessary measures for a major overhaul of
the general Community policy on chemicals50. As most pesticides are chemical substances, it
is clear that the provisions and criteria (e.g. regarding persistence) under the new policy will
have  a  direct  influence  on  the  use  of  PPPs.  The  Council  and  European  Parliament  have
repeatedly  called  for  complete  consistency  between  the  Community  policy  on  chemicals  in
general and the policy on pesticides.

On  January  2002,  the  Commission  adopted  a  proposal  for  a  Directive  of  the  European
Parliament and of the Council on environmental liability51. This proposal, currently subject to
the appraisal of the European Parliament and the Council, aims to establish an environmental
liability  regime  for  the  prevention  and  remedying  of  environmental  damage.  It  covers
pollution of water, damage to biodiversity and land contamination. Manufacture, use, storage,
transport or release into the environment of PPP are among activities covered by the proposed
Directive.

49 
50 

51 

COM (2002)179 final
The  preparatory  work  has  been  accomplished  in  the  White  Paper  on  a  Strategy  for  a  future  Chemicals
Policy (COM (2001) 88 final).
COM(2002)17 final.

21

                                                
2.4. National initiatives contributing to PPP risk reduction

A study relating to future EU policy on PPPs52 mandated by the Commission and covering six
Member States, identified the following “Top  Ten” concerns  in  connection  with PPP use in
the Member States :

Contamination of water resources used for human consumption

Possible adverse effects on the ecology, e.g., non-target species

Risks to consumers from food via residues

Effects of exposure to residues in water, soil and air

Contamination of surface water or marine environments

Risks to users of agricultural chemicals

Misuse of PPPs due to lack of knowledge among the users

Specific concern about adverse effects on an ecosystem element

Dependence of agriculture on chemicals for pest control

Frequent and large-scale use of PPPs

These concerns have led to a number of national policy initiatives, the most frequent of which
are:

Protection of watercourses, especially in sensitive zones, by monitoring and prohibition of use
of certain products in water catchment areas.

Training and education programmes for PPP applicators and users.

National use reduction plans which have been developed  and  applied  in  Sweden,  Denmark,
Finland and the Netherlands.

Technical checks and certification of application equipment, implemented in several Member
States with encouraging results.

Efforts  to  increase  Integrated  Pest  Management  (IPM),  pest  forecasting  techniques,  and
biological control methods.

Prohibition  of  aerial  spraying  for  targeted  protection  of  sensitive  species  and  habitats,  and
protection of waters in general.

Mandatory or voluntary collecting of packaging and unused products for safe destruction.

Several Member States (e.g. Sweden, Denmark, Belgium) have introduced taxes on PPPs to
contribute  to  rationalising  their  use.  In  Sweden  the  levy  is  set  at  a  fixed  amount  per  kg  of
active ingredient regardless of the type of PPP. In Denmark, fixed rates have been set for all

52 

See footnote 17

22

                                                
insecticides  (37%  of  retail  price),  fungicides,  herbicides  and  growth  regulators  (25%)  and
microbiological  agents  (3%).  In  both  countries53  pesticide  use  has  fallen,  but  less  than  was
expected  and  it  was  not  possible  to  relate  this  to  the  introduction  of  the  levy  or  to  other
measures taken under the pesticide reduction plans set up in the countries at the same time54.

Some  Member  States  have  developed  strategies  to  promote  organic  farming.  Additionally,
within  the  Codes  of  verifiable  Good  Farming  Practices  in  the  Rural  Development
Programmes  established  under  Regulation  1257/1999,  some  Member  States  have  addressed
the questions of safe use and good practices in regard to pesticides. In some Member States,
producer groups and food retailers are developing accounting systems in relation to PPP use.

2.5. Instruments for monitoring progress: statistics on PPP use and indicators

Statistics on PPP sales broken down into four groups (herbicides, fungicides, insecticides and
other pesticides)  and expressed  in  tonnes of active ingredient  are  gathered  annually  in  most
Member States and transmitted to Eurostat (see Fig. 1). Data are available for the period 1990
to  1999,  but  there  are  gaps  for  some  years  and  some  Member  States.  From  these  data,  the
consumption of pesticides expressed in kg of active ingredient per hectare of agricultural area
has  been  derived  however  with  the  same  type  of  gaps.  Also,  in  some  Member  States,  sales
figures include sales for non-agricultural use.

Unfortunately  only  a  few  Member  States  collect  regular  statistics  on  the  quantities  of
individual active ingredients used on farms. For this reason, the Commission has encouraged
Member States to set up specific PPP use data collection systems and DG Agriculture has via
Eurostat provided financial support to Member States wishing to carry out pilot studies on the
collection of PPP use data55. So far, the only more detailed information comes from industry,
collected under contract to Eurostat56. At the level of active ingredients, parts of the data are
confidential and have to be treated under the provisions of Council Regulation (EEC) 1588/90
on confidentiality.57

Evaluation of the statistics shows that the countries with the largest areas under crops (France,
Italy, Spain and Germany) show the highest consumption of pesticides in absolute values. In
terms  of  pesticide  use  per  hectare,  Italy,  France,  the  Netherlands  and  Belgium  emerge  as
heavy users, reflecting the intensive nature of agriculture in these countries and/or particular
characteristics of the crops necessitating more intensive treatment than others  (e.g.  fruit and
grapes). There is currently no harmonised environmental monitoring of PPPs in all Member
States.  Some  data  exist  in  certain  Member  States,  e.g.  on  water  contamination,  but  neither

53 
54 

55 

56 

57 

The Belgian system as initially conceived exempted all agricultural uses from the levy.
A detailed analysis of both schemes is presented in a study finance by the Commission on the Economic
and  Environmental  Implications  of  the  Use  of  Environmental  Taxes  and  Charges  in  the  EU  and  its
Member  States,  which 
is  available  at:  http://europa.eu.int/comm/environment/enveco/taxation/
environmental_ taxes.htm.
Such support was provided in the Technical Action Plan for Agriculture Statistics (TAPAS) programmes
of 1999 and 2000.
The members of ECPA (European Crop Protection Association) agreed to provide Eurostat with their data
on use of pesticides (by active ingredients), for the major agricultural crop groups in the EU. The data for
1992-1996 have been published in such a way as to respect confidentiality concerning volumes and uses of
individual ingredients while still providing useful information. Similar data for the period 1997-1999 are
currently being processed and will be published by Summer 2002.
Council Regulation (EURATOM, EEC) 1588/90 of  11  June  1990  on  the  transmission  of  data  subject  to
statistical confidentiality to the Statistical Office of the European Communities. OJ L 151 of 15. 6. 1990
p. 1

23

                                                
agricultural  nor  forest  soil  is  subject  to  regular  or  harmonised  monitoring  throughout  the
Community.

The  European  Councils  in  Cardiff  and  Vienna  underlined  the  importance  of  developing
environmental indicators to assess the progress of integration of environmental concerns into
other  policies,  including  agricultural  policy.  The  Communication  “Indicators  for  the
integration  of  environmental  concerns  into  the  CAP”58deals  with  agri-environmental
indicators  and  has  identified  a  core  set  of  indicators  and  areas  where  indicators  need  to  be
developed  further.  Among  those  are  several  related  to  risks  from  PPPs  to  the  environment.
The most important are:

– 

– 

– 

consumption  of  pesticides:  however,  the  risks  posed  by  pesticides  vary
considerably, depending on specific characteristics (i.e. toxicity, persistence) of
active  ingredients  and  use  patterns  (i.e.  volumes  applied,  application  period,
method, type of crop treated, type of soil). Two complementary indicators can
be envisaged: 1) index of pesticide use, weighted to take into account different
types  of  toxicity  and  use  patterns,  2)  pesticide  use,  classified  according  to
intrinsic  characteristics,  e.g.  toxicity  to  non-target  species,  long  term  effects,
persistence in the environment, etc
soil  contamination:  extent 
accumulate in soil.
water  contamination:  the  evolution  of  pesticide  concentrations  in  ground  and
surface water.

to  which  pesticide  residues  or  metabolites

A  second  Communication  has  identified  the  statistical  needs  for  the  elaboration  of  those
indicators59.

Several  indicators  were  considered  as  (partly)  useful  for  evaluating  the  "sustainability"  of
crop protection in the Member States. Sales (kilograms/ hectare) were the  primary indicator
used in the Member States having a national plan for “use” reduction. Other Member States
did  not  accept  this  indicator,  because  it  is  not  directly  related  to  a  reduction  of  "risks",  as
decreases  in  sales  could  be  due  to  increased  use  of  higher-activity  substances  and  possibly
higher  risks.  Frequency  of  application  is  considered  a  better  general  indicator  (mainly  by
NGO’s and the Northern Member States).

Within the OECD specific work has been started recently on risk reduction indicators based
on the intrinsic characteristics of individual PPPs. The work is intended to provide a tool for
users and policy makers to estimate the trend in the risks posed to the environment by the use
of  PPP.  It  is  not  intended  to  give  an  absolute  measurement  of  the  risks  associated  with  an
individual PPP and its effects under specified conditions of use. So far, most of the work has
focused  on  aquatic  risk  indicators,  where  a  pilot  project  involving  six  OECD  member
countries  experimenting  with  three  indicators  developed  in  a  previous  project  as  well  as
several national indicators was completed in 2001. A technical  report on the  project will be
made publicly  available. The OECD Secretariat established early in 2002 a special  web site
on  pesticide  risk  indicators,  which  carries  all  project  documents  and  contains  links  to  other
relevant sites. A project on indicators for the terrestrial environment has recently started.

58 
59 

COM (2000) 20 final
Communication from the Commission to the Council and the European Parliament: Statistical Information
needed for indicators to  monitor  the  Integration  of  Environmental  Concerns  into  the  CAP.  COM  (2001)
144 final of 20. 3. 2001

24

                                                
The Food and Veterinary Office of the European Commission carries out audits and checks in
the Member States, and reports its findings and recommendations, on monitoring of pesticides
residues in foodstuffs, the  application of Article 17  of  Directive  91/414/EEC,  and  Directive
96/23/EC60.  It  also  puts  together  the  data  provided  by  Member  States  on  their  national  and
EU-wide  pesticide  residue  monitoring61.  In  addition,  national  monitoring  programmes  for
pesticide residues  (including  fruit,  vegetables,  cereals  and  food  of  animal  origin)  have  been
developed.

All these initiatives, if developed further and well co-ordinated, should contribute to a more
comprehensive  picture of the  situation, in particular  when  combined  with  actual  monitoring
data on the situation in the Member States, such as:

– 

– 
– 

– 
– 
– 

– 

– 

percentage of agricultural surfaces or farms using integrated pest management
and/or pesticide-free agriculture
percentage using pest forecast systems
quantity of collected empty packages in comparison with quantity (number of
packages) sold
surveys on residues, compliance with MRLs
surveys of soil contamination by pesticides
surveys  of  water  quality,  compliance  with  limits  for  groundwater  and/or
surface water protection
number  of  people  suffering  injuries  from  pesticides  (data  not  generally
available)
efficiency of spraying equipment and its compliance with relevant standards

3.

Evaluation of the present situation

The foregoing overview of the present situation as regards the reduction of risks from PPP use
shows that positive effects can already be seen as a result of national and Community efforts.
The initiatives taken so far are encouraging, but they lack the overall coherence and level of
application required to reduce PPP-related risks even further.

However,  there  is  room  for  improvement  of  existing  instruments,  particularly  concerning
matters  such  as  potential  synergistic  or  cumulative  effects  of  PPP,  long-term  risks  for  the
marine  environment,  incentives  for  substitution  and  an  effective  shift  of  use  from  more
dangerous active substances to safer alternatives, improvement of provisions on enforcement
and controls on distribution or sales of PPP, educational requirements for users and technical
requirements for application equipment.

The co-ordinated and harmonised full implementation of the existing legislative instruments,
including  the  use  of  the  powers  already  conferred  on  Member  States  in  the  CAP,  could
already have a significant downward effect on the risks associated with the use of PPP.

However, there will still be a need for new initiatives, such as those described in chapter VI,
to keep user awareness high and to maintain lasting momentum towards further reducing the
risks associated with PPP use throughout the Community.

60 

61 

Council  Directive  96/23/EC  of  29  April  1996  on  measures  to  monitor  certain  substances  and  residues
thereof in live animals. OJ L 125, 23.5.1996, p.1.
Annual EU-wide Pesticide Residues Monitoring Reports. There are, by now, five  such reports available,
corresponding to the years 1996-2000.

25

                                                
IV. IMPLICATIONS FOR CANDIDATE COUNTRIES

Because of the timeframe of the 6th EAP (2002-2011), any developments regarding pesticides
must  take  account  of  the  implications  of  any  enlargement  of  the  European  Community.
Enlargement  will  have  significant  effects  on  the  candidate  countries  as  they  will  have  to
comply  with  the  policies  in  place  at  the  time  of  accession.  Candidate  countries  should
therefore  be  involved  in  the  process  from  now  on,  in  direct  consultations  and  as  players
concerned by the international aspects of the thematic strategy.

An  important  measure  will  be  to  improve  the  management  of  chemicals  and  pesticides  in
candidate countries, including the elimination of stockpiles of obsolete pesticides waste. The
volume  of  such  stockpiles  is  considerable,  several  hundred  thousand  tonnes62,  and  their
elimination will need to be consistent with future developments in waste policy.

A  number  of  the  governments  in  candidate  countries  need  to  be  supported  on  a  technical,
financial and logistical levels to address the problem, which would best be achieved through
systematic national action plans during the  pre-accession phase.  Development of  such plans
should be given specific support. They would need to include strategies to establish:

– 
– 
– 

nation-wide inventories of stocks of obsolete pesticides
appropriate methods of treatment / disposal
strategies for prevention of accumulation of new stocks

Many international organisations are already working on the problem, as are industry and the
NGOs.  Some  Member  States  are  also  supporting  projects  directly.  Co-operation  among  all
these donors is important, as well as regional co-operation among the countries concerned.

The  SAPARD  Regulation  on  pre-accession  measures  for  agriculture  and  rural  development
((EC)  No  1268/199963)  establishes  the  framework  for  Community  support  for  sustainable
agriculture  and  sustainable  rural  development.  It  provides  for  the  launch  of  agri-
environmental  measures  via  pilot  projects.  Measures  need  to  be  programmed  at  the  most
appropriate  geographical  level.  The  financial  contribution  from  the  Community  for  the
majority of the measures is 75% of total eligible public expenditure.  It should be also noted
that, for the  ten SAPARD  countries,  the  beneficiaries  must  respect  environmental  standards
equivalent  to  that  set  out  in  Community  legislation  and  the  investments  must  comply  with
Community  requirements.  These  obligations  are  an  important  element  of  the  SAPARD
Programme in the framework of the implementation of the acquis communautaire.

In numerous rural areas of the candidate countries, the intensity of agricultural production and
the  use  of  pesticides  are  very  low  and  may  be  expected  to  have  no  significant  effect  on
environment.  However,  the  further  development  and  establishment  of  agri-environmental
schemes in some rural areas of these countries is an important task in reducing environmental
and health impact of pesticides. Research and development efforts to support integrated pest
management and organic production will also be of relevance.

62 

63 

As  reported  by  the  Czech  Research  Centre  for  Environmental  Chemistry  and  Ecotoxicology  at  the  6th
International HCH & Pesticides Forum, Poznan, Poland, 20-22 March 2001. The full report is available at:
http://www.recetox.muni.cz/PBTs/content.htm
OJ L 161, 26.6.1999, p. 87

26

                                                
V. INTERNATIONAL ASPECTS AND REGIONAL CO-OPERATION

Any  Community  action  in  relation  to  pesticides  has  to  take  into  consideration  international
work in  the  area.  Conversely, the Community as  a major player  in international fora is in a
position  to  influence  international  policies  in  accordance  with  its  own  objectives.  The
Intergovernmental Forum on Chemical Safety64, which is responsible for the implementation
of the “chemical chapter” of Agenda 21, has in its programme several activities and some key
operational goals directly relevant for pesticides, in particular capacity building, information
exchange, networking, risk reduction, illicit trafficking, and others.

Persistent  Organic  Pollutants  (POPs)  are  bioaccumulative  organic  chemicals,  which  are
prone to long-range transport and deposition. An international convention to eliminate, where
feasible,  emissions  and  discharges  of  12  specified  POPs,  9  of  which  are  pesticides,  and  to
identify  others,  was  signed  by  more  than  90  countries  in  May  2001  at  Stockholm.  The
Community  and  its  Member  States  are  among  those  and  will  have  to  adopt  all  necessary
measures  to  implement  the  Convention,  which  will  include  production  bans65.  Of  particular
concern  in  this  context  is  DDT,  which  is  one  of  the  pesticides  covered  by  the  Stockholm
(POPs) Convention,  but is still widely  used in developing countries to  combat  malaria.  The
Convention allows this, when the countries concerned request such derogation.

A  key  objective  of  several  Conventions  for  the  protection  of  the  marine  environment
(OSPAR, Helsinki, and Barcelona Conventions66) is the cessation of discharges, emissions
and  losses  of  hazardous  substances  by  2020.  Hazardous  substances  are  defined  through
criteria  on  persistence,  toxicity  and  potential  to  bioaccumulate  (PBT).  The  ‘OSPAR
Chemicals  for  Priority  Action’  and  the  ‘OSPAR  Substances  of  Possible  Concern’  include  a
considerable number of pesticides.

Many  developing  countries  and  New  Independent  States  (NIS)  do  not  have  adequate
legislation or infrastructure to ensure the safe use of chemicals. This problem is addressed by
the  Rotterdam  Convention  on  the  Prior  Informed  Consent  Procedure  (PIC)  for  certain
hazardous  industrial  chemicals  and  pesticides  in  international  trade,  which  was  adopted  in
1998,  and  will  be  implemented  in  the  Community  by  amendments  to  Regulation  2455/92.
Among  other  provisions,  the  Convention  obliges  exporters  of  chemicals  on  the  PIC-list  to
obtain  the  consent  of  the  receiving  country  before  delivery  and  to  guarantee  appropriate
labelling  of  exported  chemicals,  and  establishes  a  system  of  information  exchange  on
chemical risks. The Convention also gives the opportunity to developing countries to propose
the  listing  of  severely  hazardous  pesticides  formulations,  which  cause  problems  under  the
specific conditions of use in the developing country. Of the current 31 PIC substances 26 are
pesticides.

The OECD Pesticide Risk Reduction Project was initiated in 1994 to help OECD countries
reduce risks associated with pesticide use. This project comprises three types of activity:

– 
– 

collection and publication of information about risk reduction activities
organisation  of  workshops  at  which  governments  and  other  pesticide  risk
reduction  "stakeholders"  can  exchange  information  and  identify  issues  that
they would like to work on collectively

64 
65 
66 

http://www.who.int/ifcs/ , in particular the Bahia declaration adopted in IFCS III in October 2000
It should be noted that use of all these pesticides has already been banned in the EU.
Oslo-Paris  Convention  for  the  North-East  Atlantic,  Helsinki  Convention  for  the  Baltic  Sea,  Barcelona
Convention for the Mediterranean Sea

27

                                                
– 

development  of  indicators  that  can  be  used  to  measure  progress  in  risk
reduction.

Sharing experience with the other OECD countries is important for the Community to further
advance the reduction of risks from the use of pesticides, in particular to agree on harmonised
indicators to monitor progress.

The  Codex  Alimentarius  influences  the  use  of  pesticides  around  the  world.  It  includes
recommendations of MRLs for pesticides in foodstuff. The Codex Alimentarius has particular
relevance in international food trade. Codex recommendations have become the benchmarks
against which national food measures and regulations are evaluated within WTO. As Codex
MRLs are not necessarily the most conservative, there is growing pressure within the EU to
set its own MRLs. Unless there is evidence to justify such EU MRLs, this could be perceived
by developing countries as a protectionist barrier to trade, as they do not necessarily have the
technical  means  to  prove  that  their  produce  meets  EU  requirements.  EU  MRLs  for  non-
authorised  pesticides  are  normally  set  at  the  lower  limit  of  analytical  determination,  which
might constitute a problem  for  developing  countries where these pesticides might still be in
use, due to lack of affordable alternatives.

In  November  2000,  the  Council  and  the  Commission  endorsed  a  Development  Policy
Declaration67  that  identified  environment  as  a  crosscutting  issue.  As  a  contribution  to  the
“Cardiff”  process,  the  Commission  presented  a  Staff  Working  Paper  in  April  200168
promoting the search for synergies between environmental protection and poverty eradication
and highlighting opportunities for environment integration into the six priority themes of the
EC  Development  Co-operation  Policy  in  order  to  make  development  sustainable.  Various
projects  related  to  pesticides  use  have  been  and  are  financed  through  Development
Programmes.  They  concern 
implementation  of  Integrated  Pest
Management techniques, the elimination of stocks of obsolete pesticides69, Pest management
and Food security, capacity development for chemicals/pesticides management70, information
concerning MRL set at EC level71 and others.

the  promotion  and 

Many  other  international  activities,  such  as  those  related  to  the  ACP  countries,  EPPO  (the
European and Mediterranean Plant Protection Organisation), or FAO (e.g. FAO International
Code of Conduct for the distribution and use of pesticides) are affected by and influence the
policies developed by the Commission, in particular regarding MRLs and their enforcement.

VI.

POSSIBLE ELEMENTS OF A EUROPEAN THEMATIC STRATEGY ON THE SUSTAINABLE
USE OF PESTICIDES

In  the  preparation  of  this  Communication,  all  existing  instruments  and  initiatives  at
Community  and  Member  States  level,  as  well  as  numerous  background  studies  and
preparatory work already carried out72 have been considered.

67 
68 

69 

70 
71 
72 

Council document 13458/00
Commission  Staff  Working  Paper  “Integrating  the  environment  into  EC  economic  and  development  co-
operation”, 10 April 2001, SEC (2001) 609
Thousands of tons of obsolete pesticides are also stored in Developing countries, particularly in Africa.
http://www.fao.org/ag/AGP/AGPP/Pesticid/Disposal
through the elaboration of National Profiles. http://www.unitar.org/cwm/nationalprofiles/index.htm
Pesticides Initiative Programme. http://www.coleacp.org
For details please refer to: http://europa.eu.int/comm/environment/ppps/home.htm

28

                                                
Given that

– 
– 

– 

many of the risks presented by pesticide use are similar in all Member States;
risks  have  a  cross-border  character,  especially  in  terms  of  water  and  air
pollution;
many Member States have already started risk reduction programmes and such
unilateral  action  can  expose  farmers  in  different  Member  States  to  unfair
competition in the Internal Market and give rise to unequal levels of protection
of health and environment in the Community

it  seems  first  and  foremost  necessary  for  all  existing  instruments  and  initiatives  to  be
harmonised  and  fully  implemented  in  a  co-ordinated  way.  The  direct  benefits  of  any
Community  action  would  be  to  improve  the  possibilities  for  exchange  of  risk  reduction
experiences and to contribute towards a good functioning of the internal market for pesticides
and  plant  products  and  a  fair  competition  between  the  PPP  users,  mainly  farmers,  in  the
Member States.

In  addition,  new  instruments  and  initiatives  to  address  the  risks  associated  with  the  use  of
PPPs will have to be developed. They should have common goals and be tailored to meet the
needs at international, EU, national and local levels.

The  Commission  intends  to  propose  a  thematic  strategy  to  achieve  sustainable  use  of
pesticides. The thematic strategy will complement the revision of the regulatory  framework,
in particular Directive 91/414/EEC, which has already started.

The purpose of this Communication is  to  consult all stakeholders  on  the  potential  measures
set  out  below.  Potential  measures  are  classified  under  the  main  headings  outlined  by  the
Council and Parliament in their Decision xxxx .

1.  Minimising  the  hazards  and  risks  to  health  and  environment  from  the  use  of
pesticides, through:

a.

establishment of national plans to reduce hazards, risks and dependence on chemical
control.

Experience  in  Member  States  has  shown  the  efficacy  of  risk  or  use  reduction  plans.
Programmes  have  to  be  tailored  to  local  conditions.  Different  regions  should  map  out  their
specific needs such as particular pressures and impacts in water catchment areas.

Broad  participation  by  all  parts  of  society,  particularly  farmers,  their  unions,  extension
services  and  the  public  authorities  should  be  encouraged  when  designing  the  specific
programmes,  targets  and  timetables.  The  plans  could  necessitate  preliminary  studies  to
evaluate different scenarios and their consequences. The results of these national plans must
be regularly reported and evaluated.

The Commission proposes that all Member States establish such plans within two years and
report  regularly.  Reduction  measures  for  all  areas  under  the  control  of  public  authorities
should  be  exemplary  parts  of  these  plans.  The  plans  should  be  closely  co-ordinated  or
integrated  with  similar  actions  under  other  Community  legislation  such  as  the  river  basin
management plans under the  Water Framework Directive or rural development plans under
the CAP.

29

b.

reducing particular risks, such as:

1.

2.

3.

pollution  of  watercourses,  ditches,  and  water  catchment  areas  both  through
diffuse and point source pollution
The Commission is fully committed to promoting the successful implementation
of  the  Water  Framework  Directive,  which  will  achieve  a  high  level  of
protection of the aquatic environment from pollution by pesticides. Within the
context  of  the  Common  Implementation  Strategy73  for  the  WFD,  the
Commission  proposes  to  introduce  best  practices  in  river  basin  management
such  as  mandatory  field  margins  or  specific  agreements  between  water
companies and farmers.
chemical control measures in environmental sensitive areas, as defined e.g. in
NATURA  under  Directive  92/43/EEC,  which  requires,  in  Article  6(2),
measures to avoid the deterioration of natural habitats as well as disturbance of
species  and  which  encourages  positive  measures  such  as  environmentally
friendly farming.
The  Commission  proposes  that  the  Member  States  introduce  measures  to
increase the protection of such areas by reducing the overall use of PPP and
defining areas of zero PPP use.
aerial spraying
The Commission proposes a general ban. Specific derogation may be given by
the national authorities of the Member States if aerial spraying presents clear
advantages  and  also  environmental  benefits  compared  to  other  spraying
methods.

c. improving knowledge of risks by

1.

2.

monitoring of the health of users  at particularly high risk  such  as agricultural
workers  and  more  sensitive  consumers  (epidemiological  survey).  Member
States  should  conduct  long-term  research  into  different  high-risk  situations
(including  a  register  of  the  pesticides  used)  and  regularly  publish  reports  on
residues  in  food  including  an  evaluation  of  the  total  diet  of  consumers  with
particular emphasis on the more sensitive types of consumers such as children.
Current residue monitoring programmes need to be re-inforced and enlarged in
scope (to a broader range of food and feedstuff) and better co-ordinated among
the  Member  States  (all  ministries  and  agencies  concerned)  with  enhanced
support  from  the  Food  and  Veterinary  Office  (FVO)  of  the  Commission.
Further  measures  could  be  proposed  in  the  framework  of  the  strategy  on
Environment  and  Health  regarding  monitoring  programmes  and  sharing  of
data.
The Commission proposes that the Member States, including through possible
Commission 
long-term
epidemiological research on PPP users at risk and launch broad investigation
and  monitoring  programmes  on  pesticide  residue  levels  for  consumers,  with
particular  emphasis  on  groups  of  the  population  at  particular  risk.  National
monitoring  efforts  should  be  coordinated  for  better  efficiency  with  enhanced
support by the FVO.
collection of data on incidents having consequences for health and environment
of workers and private users (centralised recording and analysis of incidents)

funded  research  programmes, 

initiate  mid 

to 

73

For 
details 
implemenation.html

please 

refer 

to: 

http://europa.eu.int/comm/environment/water/water-framework/

30

                                                
3.

The  Commission  proposes  that  Member  States  create  new  (where  needed)  or
modify  existing  reporting  systems,  which  should  then  be  coordinated.
Information should be centralised and evaluated for the whole Community.
collection and analysis of  economic data  on PPP use  (benefits and costs)  and
alternatives
Reliable figures for the actual costs of pesticide use (including external costs)
and alternatives could help in the evaluation of the benefits in comparison with
chemical-free methods of control.
The Commission proposes to support together with the Member States further
investigation on this point at national and international level (e.g. OECD).

d. further research and development into:

1.
– 

– 
2.

3.

4.

5.

less hazardous methods of application and handling of PPPs such as
precision  spraying,  improved  coating  and  packaging  technology  (new  soluble
packaging and packaging which retains less residual product when empty)
better adaptation and use of protective clothing
IPM  techniques  as  part  of  ICM,  such  as  early  pest  warning  systems,  disease
forecasting, etc.
improved insurance schemes against potential crop losses in order to minimise
preventive applications
potential  synergistic  and  antagonistic  effects  of  PPPs,  in  particular  in
frequently used combinations of active substances
quantification  of  point  source  pollution  and  practical  solutions  to  address
related hazards

6.improved  methods  to  assess  the  chronic  and  acute  risks  from  residues  to  infants

and children when establishing MRLs to safeguard their health.
The  Commission  proposes  to  support  or  create  together  with  the  Member
States research and development efforts and calls on industry to contribute to
the activities.

2. Improved controls on the use and distribution of pesticides

a.

b.

c.

reporting  of  production  and  import/export  quantities  of  PPPs  by  producers  and
distributors  to  national  authorities.  Under  legal  cover,  national  authorities  would
report  to  the  Community,  which  would  then  prepare  (through  Eurostat)  an  annual
report  with  an  aggregated  data  analysis.  The  necessary  protection  of  data  of
commercial  value  would  have  to  be  respected  when  using,  compiling  or
disseminating  the  data.  These  should  be  as  detailed  as  possible  and  would  also  be
helpful for efficient follow-up of the Rotterdam (PIC) Convention;

reinforcement of ongoing work on the collection  of data  concerning use  (quantities
of  PPPs  applied  per  crop,  product,  area,  time  of  application…).  In  this  respect,
progress  in  keeping  of  logbooks  to  record  spraying  data  and  circumstances  of
treatments, types and amounts of pesticides used could also contribute to enhancing
the  awareness  of  the  users  and  allow  better  controls  of  the  real  patterns  of  use.
Knowledge of actual use patterns would help to better identify unacceptable risks;

reinforcement  of  the  system  based  on  Article  17  of  Directive  91/414/EEC
(inspections  /  monitoring  of  uses  and  distribution  of  PPP  by  wholesalers,  retailers
and farmers) in a co-ordinated way;

31

d.

e.

f.

introduction  of  a  system  of  regular  and  safe  collection,  possible  re-use,  and  finally
controlled destruction of PPP packaging and unused products;

introduction of a system of regular technical inspection of application equipment74;

creation  of  a  system  of  mandatory  education,  awareness  raising,  training  and
certification  for  all  PPP  users  (farmers,  local  authorities,  workers,  distributors,
traders  and  extension  services).  The  training  should  put  emphasis  on  safe  use,
covering both human health and environmental aspects. It would further contribute to
the  free  movement  of  workers 
training
requirements.  Best  practice  guidelines  for  the  most  essential  parts  of  the  training
should  be  developed.  This  could  be  done  against  the  background  of  the  education
programmes  provided  for  in  article  9  of  Chapter  III  of  Council  Regulation  (EC)
1257/99.

through  common  and  recognised 

For all these points, the Commission will propose relevant mandatory requirements
within  two  years  of  the  adoption  of  the  thematic  strategy.  Compliance  needs  to  be
assured  through  adequate  monitoring  measures.  Where  appropriate,  support  to
farmers under the CAP is to be linked to compliance with the required measures.

3. Reducing the levels of harmful active substances by substituting the most dangerous
with safer (including non chemical) alternatives

This goal will be achieved mainly by a quicker implementation of Directive 91/414/EEC and
its amendments in the near future. Preparatory work is already in hand.

In practice this would entail systematic evaluation of the possible substitution75 of a particular
active substance for which certain concerns persist, either by another substance (on the basis
of the inventory of active substances, when an alternative is available for a specific purpose)
or a pesticide-free alternative. Examination of the possibility of introducing  this principle at
Community  level  is  recommended  in  the  10-year  report  on  the  evaluation  of  Directive
91/414/EEC  and  has  been  emphasised  by  the  Council  and  the  European  Parliament  in  their
conclusions on this report.

The Commission proposes to amend Directive 91/414/EEC in order to include among other
modifications  the  substitution  principle.  The  Commission  will  study  feasibility  and  possible
methodologies  for  its  application  in  practice.  Member  State  Rapporteurs  should  then  carry
out comparative assessments under appropriate conditions (which need to be defined) when
evaluating  active  substances,  taking  due  account  of  possible  resistance  problems.  The
revision  of  the  Directive  will  also  take  into  account  several  other  issues  addressed  in  the
Council  Conclusions  and  the  Opinion  of  the  European  Parliament  on  the  10-year  report
evaluating the functioning of Directive 91/414/EEC76.

74

75 
76 

Already in application in several MS. Experience has shown mandatory systems to be more efficient than
voluntary ones.
This concept is already included in the Biocides Directive 98/8/EC
See footnote 31

32

                                                
4. Encouragement of the use of low-input or pesticide-free crop farming particularly by
raising user’s awareness, promoting the use of codes of good practices and consideration
of the possible application of financial instruments

a.

Promotion and development of alternatives to chemical control via IPM agriculture,
organic  farming,  and  biological  control  for  specific  uses,  such  as  glasshouse  crops
and examining the potential of the use of Genetical Modification Technology when
its application is considered as safe for health and environment.

Promoting  good  practices  by  further  developing  Codes  of  Good  Farming  Practice
integrating IPM concepts.

Further  encouraging  the  allocation  of  funds  by  Member  State  and  the  adoption  by
farmers  of  Rural  Development  measures,  in  particular  agri-environmental  schemes
designed to promote low-input farming beyond Good Farming Practice with less use
of pesticides (organic farming, ICM and specific measures to reduce pesticide use),
but also by training and other relevant measures.

b.

Imposing  penalties  on  users  by  reducing  or  cancelling  benefits  under  support
schemes

Member  States  should  make  more  rigorous  use  of  the  possibility  of  applying
penalties  by  cancelling  or  reducing  benefits  covered  by  Council  Regulation
1259/1999  when  environmental  requirements  which  they  have  identified  as
appropriate  in  view  of  the  situation  of  the  agricultural  land  used  or  the  product
concerned  have  not  been  respected.  Where  not  yet  existing,  these  requirements
should be defined.

For  points  a  and  b,  the  Commission  proposes  to  implement  the  current  provisions
more  rigorously  and  exploit  them  fully.  The  upcoming  report  on  Regulation  (EC)
1259/1999  will  unveil  what  Member  States  have  done  on  environmental  protection
requirements and indicate whether further steps will be necessary to reinforce their
implementation. The Commission will include pesticides issues in the discussion on
the future evolution of Good Farming Practices as a policy tool.

c. Special levies on PPPs

Some  Member  States  have  already  introduced  specific  levies,  while  others  are
planning to do so. Introduction of an environmental charge would raise awareness of
the  detrimental  effects  of  over-intensive  PPP  use  and  further  reduce  reliance  on
chemical inputs in  modern agriculture.  Such a  levy  would  also  make  non-chemical
methods  more  competitive  and  could  contribute  to  the  additional  funds,  needed  to
cover  the  external  costs  of  PPPs,  research  and  development  work  into  more
sustainable  alternatives  and  further  protection  of  sensitive  areas  and  population
groups.

The Commission carried out a study of the advantages, disadvantages and feasibility
of an EU wide regulatory framework for levies on pesticides77.

The study concluded that an ‘ideal levy’ would have to respect the following criteria:

77 

Final report by EIM / Haskoning, Zoetermeer, July 1999.

33

                                                
– 

– 
– 
– 
– 

discriminate  effectively  among  the  various  pesticides  (i.e.  the  levy  should  be
proportional to the potential damage to the environment)
be set at the correct rate (i.e. correspond to the marginal external costs)
have an efficient collection and effective reimbursement system
be fraud-proof
provide a permanent incentive to farmers

According  to  the  study,  the  first  two  of  these  criteria  are  confronted  with  major
obstacles: there is inadequate information on the (long-term) negative environmental
effects of pesticides and it is extremely difficult to summate the various effects into
one  single  target  (i.e.  effects  on  the  aquatic  environment  versus  effects  on  the
terrestrial  environment).  Furthermore,  precise  quantification  (and  costing)  of  the
externalities is fairly impossible. Within the scope of the study it was not possible to
propose a solution for an EU wide regulatory framework for levies on pesticides.

Nevertheless, the experience of two real cases of levies applied in practice (Denmark
and Sweden) seems to indicate a certain impact, albeit more limited than originally
expected. Demand for PPPs did decrease, indicating some price elasticity, but it was
unclear whether this could be attributed to the levy alone or was due to a number of
‘accompanying  measures’  taken  at  the  same  time.  Instead,  an  important  aspect  has
been the revenue-raising role of the levy. The funds raised were used (at least in part)
to finance support programmes (such as advisory services) to optimise pesticide use.
In both countries, significant organic agriculture sectors have developed as well.

In the light  of experience to date, the Commission does not propose at  this  time  to
develop  a  fully-fledged  EU-wide  scheme  of  levies  on  PPPs  that  would  reflect  real
marginal  externalities.  Further  research  into  the  full  costs  and  benefits  (including
externalities)  of  using  PPPs  or  alternative  methods  will  be  necessary  first.  The
Commission considers that, if such a levy was to be introduced, Member State should
be encouraged to apply tax differentiation, taking into account the general principles
of the EC Treaty and their specific environmental concerns. Taxation should provide
sufficient  incentive  to  pesticide  users  to  opt  for  pesticides  less  harmful  for  the
environment in the particular context of the Member State concerned and contribute
to internalise at least partly the external effects of the use of PPPs. It could further
contribute  to  the  financing  of  a  number  of  measures  under  the  national  risk
reduction plans and research and development as proposed in various earlier points.

d. Harmonisation of the Value Added Tax for PPPs

The current situation with VAT on PPPs ranging between 3 and 25% puts farmers in
various  Member  States  in  an  unequal  situation.  The  current  Community  legislation
allows  Member  States  to  apply  a  reduced  rate  of  VAT  for  PPPs.  It  distorts  the
internal market and can lead to illegal import with increased uncertainties concerning
potential negative consequences for health and environment resulting from the use of
those illegally imported PPPs, like for example the increased risk from a label which
is in a language unknown to the user.

To ensure the smooth functioning of the internal market, the rate of VAT should be
approximated  in  all  Member  States.  The  Commission  is  currently  preparing  a
revision  of  VAT  legislation  which  could  integrate  this  harmonisation  purpose  and
propose to apply the normal VAT-rate (minimum 15%), excluding thereby all PPPs

34

from the exempted agricultural products, because of their overall harmfulness for the
environment.

The Commission proposes that the harmonisation of VAT at the normal Community
rate should be considered as the necessary first step to respect the requirements of a
single market and to reduce risks of illegal imports.

5.  A  transparent  system  for  reporting  and  monitoring  the  progress  made  in  achieving
the objectives of the strategy including the development of suitable indicators

a. Regular reporting on national risk reduction programmes

Once established, the national PPP Risk Reduction Programmes should be subject to
specific  and  strict  monitoring  by  the  Member  States.  The  result  of  this  monitoring
should be reported to the Commission.

b. Development of suitable indicators for monitoring and definition of quantitative targets

Most  indicators  currently  used  include  quantitative  change  in  volumes  used  and
application  frequency.  But,  because  of  the  different  chemical  characteristics  and
methods of use of different PPPs, such parameters do not necessarily correlate with
the decrease in risk. Therefore other types of  measurement  are  needed,  such  as  the
percentage of certified applicators, of the area treated with PPPs and others still to be
developed or a combination of all these.

Currently there are no generally accepted indicators (see chapter 2.5 for details). The
development  of  such  risk  indicators  is  a  research  priority  indicated  in  two  recent
the  European
Communications  from 
Parliament78.

the  Council  and 

the  Commission 

to 

The Commission proposes that the Member States report regularly on progress with
national  risk  reduction  programmes.  Pending  the  development  of  harmonised
indicators,  they  should  report  on  progress  by  using  the  most  suitable  indicators
currently  available  to  them.  Monitoring  should  include  agricultural  and,  where
appropriate, forest soils, the aquatic environment, and residues in food and feedstuff.
The  Commission  and  the  Member  States  should  actively  contribute  to  the
international  development  of  indicators  (in  particular  within  the  OECD)  and  their
subsequent use.

6. Candidate countries

a.

The enlargement of  the EU will have a  major impact on the  candidate countries as
they will have to comply with the policies in place at the moment of accession.

The  management  of  stockpiles  of  obsolete  pesticides  in  a  number  of  candidate
countries  has  been  mentioned  repeatedly  as  an  important  problem  in  this  context.
Pesticides  become  obsolete  when  they  can  no  longer  be  used  for  their  intended
purpose, and therefore require disposal. The common causes of this situation are:

– 

use of products has been prohibited or severely restricted

78 

See footnotes 43 and 44.

35

                                                
– 

the pesticide has deteriorated because of improper or prolonged storage

Many pesticides still in use in several candidate countries might become obsolete at
the  moment  of  accession.  In  addition,  there  are  already  considerable  stocks  of
obsolete pesticides at the moment. According to Directive 91/689/EEC79, pesticides
are  considered  as  hazardous  waste  requiring  specific  care  during  disposal
(incineration in specific incinerators). If no appropriate measures are taken, candidate
countries might not have adequate incinerators which respect the required emission
limits; this will necessitate upgrading of incineration facilities or require transport to
appropriate incinerators within the current Member States. Eventually other solutions
have  to  be  found.  A  proportion  of  the  obsolete  pesticides  will  be  covered  by  the
Stockholm Convention on POPs and measures for their disposal will be eligible for
the funding provided through the Convention (Proposals from 7 candidate countries
for  inventory  work  for  POPs  related  contamination  have  already  been  accepted).
However, there might be a need for further support to the Candidate Countries.

The  Commission  proposes  that,  in  close  co-operation  with  candidate  countries,
specific  support  programmes  be  developed,  which  target  the  handling  of  stocks  of
obsolete  PPP  and  their  safe  destruction.  Such  programmes  should  start  with  the
identification and quantification of the existing and expected stockpiles (How big is
the problem?80) and then propose appropriate disposal measures (preferably within
the  national  hazardous  waste  management  plans).  Member  States  should  provide
technical  (and if necessary financial) support to  build the  necessary  administrative
capacity to develop and manage such disposal programmes.

The Commission also proposes continued support of candidate countries for the pilot
agri-environmental  schemes,  as  established  under  the  SAPARD  Regulation,  to
develop them further, in particular in view to reducing risks associated with the use
of  pesticide,  so  that  these  schemes  will  be  correctly  established  as  a  part  of  rural
development schemes once accession takes place.

7. International aspects

The  Community  and  the  Member  States  should  contribute  to  the  safe  use  of  PPPs  in
developing countries and NIS by better monitoring and assessing their exports or donation of
chemicals,  training  and  stewardship  of  the  use,  handling  and  storage  of  PPPs  and  the
management of stockpiles of obsolete PPPs, by supporting capacity building and information
exchange.  Full  implementation  of  the  Rotterdam  (PIC)  and  Stockholm  (POPs)  Conventions
will be major steps in that direction. This includes financial support and technical assistance,
both via the mechanisms provided in the Conventions, but also further assistance in capacity
building through specific projects or in the  framework  of  regional  agreements  (in  particular
the  Cotonou  Agreement).  It  also  includes  strenghtening  the  integration  of  environmental
objectives  into  Development  Policy  and  contributing  to  the  goals  of  the  Intergovernmental
Forum on Chemical Safety.

The Commission has already proposed to the Council the necessary legislation to ratify and
implement the Rotterdam Convention on Prior Informed Consent including an amendment of
Regulation 2455/92. The Commission intends to present shortly the necessary proposals  for

79 
80 

OJ L 377, 31.12.1991, p. 20.
The European Parliament sent a letter in July 2001 to all candidate countries requesting the governments
estimates of the range and quantity of stocks of obsolete pesticides and the plans for disposal.

36

                                                
ratification  and  implementation  of  the  Stockholm  Convention  on  Persistent  Organic
Pollutants.

The Commission and the Member States will have to contribute to the technical and financial
assistance provided for in the Conventions, as well as in specific bilateral agreements (such
as  with  the  ACP  countries).  In  addition,  they  should  increase  their  commitments  under
particular  programmes,  such  as  research  on  DDT  alternatives  to  combat  malaria  (in  the
framework of the Community initiative on communicable diseases), capacity building for the
management of chemicals, and support to enable developing countries to substitute pesticides
no  longer  authorised  in  the  EU  and  to  prove  compliance  with  Community  MRLs  on
agricultural  produce.  The  Commission  will  also  seek  to  collaborate  with  the  NIS  on  the
management of chemicals81.

The Commission and the Member States will continue to take part in work under the Codex
Alimentarius  to  ensure  that  Codex  MRLs  provide  for  adequate  protection  of  human  health
and to minimise the risks of challenges of Community measures under the WTO.

VII. CONCLUSIONS AND FURTHER WORK

This Communication has presented a wide range of background information on the applicable
instruments  and  initiatives  directly  or  indirectly  affecting  pesticides  use  in  the  Community
and  further  measures  already  in  place  in  some  Member  States  and  has  identified  remaining
concerns regarding current patterns of pesticide use.

With  a  view  to  minimising  further  the  risks  presented  by  PPPs  for  human  health  and  the
environment, the Communication has identified a range of measures, which could make up a
Community  Thematic  Strategy  on  the  Sustainable  Use  of  Pesticides  which  would  usefully
complement the existing legislative framework.

The  Community  and  the  Member  States,  in  implementing  such  a  strategy,  could  use  many
different instruments: legally binding measures, (economic) incentives, research or voluntary
measures.  Combination  of  all  types  of  instruments  is  also  possible.  Many  measures  could
most effectively be integrated in already existing or currently developing related policy areas,
such as water protection,  health and consumer  protection  (in  particular  food  safety)  and  the
Common Agricultural Policy.

It  is  obvious  that  most  of  the  proposed  measures  fall  currently  within  the  purview  of  the
Member States. This is the case for actions concerning Codes of Good Farming Practices, the
promotion of IPM, training programmes for users, further promotion of organic farming and
low-input  agriculture  and  the  application  of  penalties  including  the  reduction  or  even
cancellation of benefits from the CAP. In order to achieve a higher level of harmonisation and
better  implementation,  it  might,  however,  be  necessary  to  define  minimum  requirements  at
Community  level.  Some  of  the  proposed  measures  could  be  most  efficiently  regulated  at
Community  level  (in  close  co-operation  with  Member  States),  such  as  the  definition  of
adequate  monitoring  requirements,  collection  of  use  data  and  harmonised  systems  to  report
any incidents related to health or the environment.

Public  consultation  on  a  future  thematic  strategy  for  the  sustainable  use  of  pesticides  is
proposed on the basis of these options. The Commission hereby invites all interested parties

81 

Commission Communication-EU-Russia Environmental Co-operation (COM (2001)772 final)

37

                                                
to  discuss  and  comment  on  this  document.  A  public  hearing  will  be  organised  in  the  4th
quarter of 2002.

Comments  may  be  sent  directly  to  the  Commission  not  later  than  30  November  2002.
Submissions should be sent to Ms Hellsten, Head of the Chemicals Unit (DG Environment),
200  Rue  de  la  Loi  /  Wetstraat  200,  B-1049  Bruxelles/Brussel  Belgium.  Comments  may
alternatively  be  sent  by  e-mail  to:  ENV-SustainablePPP@cec.eu.int.  The  various  language
versions of this Communication, the background studies and other related documents used for
its preparation can be found at: http://europa.eu.int/comm/environment/pppshome.htm.

On  the  basis  of  the  analyses  developed  in  this  Communication  and  the  outcome  of  the
consultation  process,  the  Commission  will  propose  at  the  beginning  of  2004  all  necessary
measures setting out a comprehensive Community Thematic Strategy on the Sustainable Use
of  Pesticides.  Because  of  ongoing  developments  in  other  policy  areas,  in  particular  the
revision  of  Directive  91/414/EEC  and  the  CAP  mid-term  review,  some  of  the  measures
envisaged will already be launched before the finalisation of the complete thematic strategy.

38

Annex  1:  Studies  carried  out  in  the  project  Sustainable  Use  of  Plant  Protection
Products82

Phase 1:

Pesticide  use  in  the  EC  (Agricultural  Economics  Research  Institute  (LEI),  The  Netherlands
1994)

Towards a future EC pesticides policy (Centre for Agriculture and Environment (CLM), The
Netherlands, 1994)

Phase 2:

Possible Arguments and Objectives of an Additional EC Policy on Plant Protection Products
(Oppenheimer, Wolff & Donnelly, 1996)

Additional  EU  Policy  Instruments  for  Plant  Protection  Products  (Wageningen  Agricultural
University (Mansholt Institute) 1997)

Analysis of Agricultural Policy in Relation to the Use of Plant Protection products (Produce
Studies Limited, 1996)

Assessment of the Benefits of Plant Protection Products (Eyre Associates, 1997)

Regional Analysis of Use Patterns of Plant Protection Products in Six EU Countries (Landell
Mills Market Research Limited, 1996)

Further Analysis of Presence of Residues and Impact of Plant Protection Products in the EU
(Soil Survey and Land Research Centre and sub-contractors, 1996)

Final workshop documents (May 98)

Possibilities  for  Future  EU  Environmental  Policy  on  Plant  Protection  Products-  Synthesis
Report (Summary Report of all six studies) (Oppenheimer, Wolff & Donnelly, 1998)

Proceedings of the Workshop held in Brussels, May 1998

82 

Internet address: http://europa.eu.int/comm/environment/ppps/home.htm

39

                                                
 Annex 2: Definitions

Good  Farming  Practice  (GFP)  is  mentioned  in  Articles  14(2),  3rd  indent,  and  23(2)  of
Council Regulation (EC) No 1257/1999, on support for rural development from the European
Agricultural Guidance and Guarantee Fund (EAGGF), as well as in article 29 of Commission
Regulation  445/2002  laying  down  detailed  rules  for  the  application  of  Council  Regulation
1257/1999. GFP is  the standard of  farming,  which  a  reasonable  farmer  would  follow  in  the
region concerned. Member States shall set out such standards, which shall, in any case, entail
compliance  with  general  mandatory  environmental  requirements.  In  Particular,  Good
Agricultural Practice (GAP) is frequently used when pesticide use is concerned. Albeit not
defined,  in  Directives  76/895/EEC,  86/362/EEC,  86/363/EEC  and  90/642/EC  relating  to
fixing  of  maximum  levels  for  pesticide  residues  means  the  lowest  amount  of  residues
resulting in sufficient efficacy of the PPPs, making thereby clear that maximum residue levels
are derived from the application point of view.

Good  Plant  Protection  Practice  is  the  terminology  used  in  Directive  91/414/EEC
(concerning  the  placing  of  plant  protection  products  on  the  market)  for  the  proper  use  of
PPPs, but the directive does not provide for a clear definition. Such a definition is developed
by EPPO with the full support of the Commission.

Best  Environmental  Practice  (BEP)  means  the  application  of  the  most  appropriate
combination of environmental measures. Examples for their specific context are described in
Annex  II  to  the  Convention  on  the  Protection  of  the  Marine  Environment  of  the  Baltic  Sea
Area.

Other concepts relating to production methods are also used in this Communication:

Organic  Production  is  defined  and  regulated  in  Council  Regulation  (EEC)  2092/91  of  24
June 1991 on organic production of agricultural products and indications referring thereto on
agricultural products and foodstuffs.

Integrated  Agriculture,  Integrated  Production  (IP),  Integrated  Crop  Management
(ICM)  and  Integrated  Pest  Management  (IPM)  are  all  concepts  relating  to  farming
systems. They include different minimum requirements for the protection of the environment
or  pest  control,  the  use  of  a  combination  of  measures  including  preventive  measures,
measures of  forecasting and diagnosis and the selection of optimum tools for mechanical or
chemical  control.  Different  methods  to  minimise  the  use  of  PPPs,  such  as  warning  systems
and “dosage keys” are also often used.

These  concepts  are  the  result  of  weighing  a  whole  range  of  management  factors:  farm
finances,  pest  and  disease  control,  product  quality,  public  health  and  food  safety,  working
conditions and environmental impact.

“Certified” production schemes in line with IPM, ICM have been established in Europe.

Certification provides better guaranties for the effects of crop protection on the quality of the
environment, public health (increase food safety and food quality) and working conditions. It
makes  farming  practices  visible  as  it  shows  how  growers  meet  the  demands  for  sustainable
crop production.

40