Opinion of the European Economic and Social Committee on the Proposal for a Regulation of the European Parliament and of the Council concerning statistics on plant protection products COM(2006) 778 final — 2006/0258 (COD)
Date: 2007-07-11
Institutions: European Economic and Social Committee
Subjects: EU statistics, pesticide, pharmaceutical product, plant health product, statistics

C 256/86

EN

Official Journal of the European Union

27.10.2007

Opinion of the European Economic and Social Committee on the ‘Proposal for a Regulation of the
European Parliament and of the Council concerning statistics on plant protection products’

COM(2006) 778 final — 2006/0258 (COD)

(2007/C 256/16)

On 16 May 2007 the Council decided to consult the European Economic and Social Committee, under
Article 285(1) of the Treaty establishing the European Community, on the abovementioned proposal.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 8 June 2007. The rapporteur was
Mr van Oorschot.

At its 437th plenary session, held on 11 and 12 July 2007 (meeting of 11 July), the European Economic
and Social Committee adopted the following opinion by 138 votes to 1 with 3 abstentions.

1. Summary of the EESC's conclusions and recommenda-

tions

1.1
The EESC welcomes the proposed regulation as a means
of measuring the progress made in the Member States towards
the objectives of the framework directive (1) on the sustainable
use of pesticides.

1.2
The EESC regrets that this regulation covers only the
professional use of plant protection products in agriculture and
does not include their potentially environmentally damaging use
on hard surfaces.

1.3
The EESC would stress that, when linking data on use
with data on the maximum residue level (MRL), it is not only
the quantity of the substances used and the area of crop treated
that are important, but also the crop yield. In order to ensure
that data on use are linked to existing EU crop statistics, and in
particular crop yields, explicit mention must be made of these
crop statistics in the regulation.

2. The Commission proposal

2.1
The objective of the proposed regulation is to establish a
framework for the production of Community statistics on the
placing on the market and use of plant protection products by
imposing an obligation on all the Member States to produce
detailed statistics on a regular basis. To ensure the comparability
of these statistics between Member States and at Community
level, the regulation defines the coverage of the statistics, which
will be limited to professional use in agriculture, and establishes
harmonised rules for data collection and compilation.

2.2
These statistics will be essential for estimating the risk to
human health and the environment linked to the use of plant
protection products, and for measuring the progress made
towards the objectives of
the framework directive on the
sustainable use of pesticides.

(1) COM(2006) 373 final ‘Proposal for a Directive establishing a framework for

Community action to achieve a sustainable use of pesticides’.

2.3
The benefits from this measure should be considered in
the light of the overall framework directive. The general objec-
tive for the implementation of the measures of the framework
directive is to achieve environment and health improvements or
other societal benefits, such as the reduction of external costs
due to the use of plant protection products, by means of a more
sustainable use of pesticides. Measurement of the progress can
only be based on reliable data and relevant indicators. Direct
benefits of this regulation can be expected at national or Com-
munity level from a better knowledge of pesticide use, such as
improved monitoring schemes and better targeted and more
effective policies. Furthermore, the availability of official statis-
tics all over Europe will create a more transparent market that
should improve the competitiveness of the pesticide industry.

3. Existing legal framework

Regulation (EC) No 396/2005 of

European
3.1
Parliament and of
the Council of 23 February 2005 on
maximum residue levels of pesticides in or on food and feed of
plant and animal origin and amending Council Directive
91/414/EEC.

the

Regulation (EC) No 852/2004 of

European
3.2
Parliament and of the Council of 29 April 2004 on the hygiene
of foodstuffs, in particular Annex I, part A, point 9 establishing
an obligation for
food business operators producing or
harvesting plant products to keep records on any use of plant
protection products or biocides.

the

Directive 2000/60/EC of the European Parliament and of
3.3
the Council of 23 October 2000 establishing a framework for
Community action in the field of water policy.

3.4
Council Directive 91/414/EEC of 15 July 1991
concerning the placing of plant protection products on the
market, which is currently under revision.

27.10.2007

EN

Official Journal of the European Union

C 256/87

4. Gist of the proposal

4.1
The proposed regulation creates a legal framework and
lays down harmonised rules for the collection and dissemination
of data concerning the placing on the market and use of plant
protection products.
instructs the Member
States:

In particular,

it

— to collect data regularly (annually as regards placing on the

market, every five years as regards use);

— on how to collect data, whether by representative surveys,
statistical estimation procedures on the basis of expert judge-
ments or models, reporting obligations imposed on the
distribution chain for plant protection products, reporting
obligations imposed on professional users, from administra-
tive sources or by a combination of these means;

— on how to transmit data to the Commission.

The proposal also entrusts the Commission with the
4.2
tasks of adapting some technical aspects and defining the
quality evaluation criteria and the data transmission format.

5. General comments

5.1
The EESC welcomes the proposed regulation as a means
of measuring the progress made in the Member States towards
the objectives of the framework directive on the sustainable use
of pesticides.

6. Specific comments

6.1 Professional non-agricultural use

Data from the Dutch drinking water industry show
6.1.1
that, in more than 50 % of cases, non-compliance with drinking
water standards is the result of the non-agricultural use of plant
protection products on hard surfaces.

The statistics regulation makes it possible to estimate
6.1.2
roughly the total non-agricultural use. This can be done by

Brussels, 11 July 2007.

deducting from the total quantity of a product brought onto the
market in a given year the total amount of professional agri-
cultural use of the product concerned.

6.1.3
The EESC thinks that this indirect calculation of non-a-
gricultural use is too inaccurate for a sound evaluation of the
policy arising from the framework directive.

Besides the collection of data on professional agri-
6.1.4
cultural use, the EESC therefore urges that the statistics regu-
lation also be used for collecting data on the professional use of
plant protection products in the forestry sector, professional use
on hard surfaces and non-professional use.

6.2 Statistics regulations and MRL data

6.2.1
The EESC would stress that, when linking data on use
with data on the maximum residue level (MRL), it is not only
the quantity of the substances used and the area of crop treated
that are important, but also the crop yield. The same quantity of
substances used over the same area is less eco-efficient if there
is a lower yield,
increasing the risk of non-compliance with
the MRL.

In Annex II of

6.2.2
the proposal, reference is made to
Council Regulation (EEC) No 571/88 on the organisation of
Community surveys on the structure of agricultural holdings.
The purpose of this reference is to use the same crop classifica-
tion for both the farm structure surveys and the statistics on
plant protection products. Statistics on the use of plant protec-
tion products can thus be linked effectively to the crop yield
statistics.

that

The EESC acknowledges

reference to Council
6.2.3
Regulation 571/88 offers the possibility of linking the data on
use of plant protection products with the yield statistics of the
crops concerned. In order to ensure that this possibility is actu-
ally used, the regulation should state explicitly that the crop
statistics — and more specifically the crop yields — are to be
used in the analysis of the data on these products.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS