On June 22, 2022, the European Commission published a draft regulation on the sustainable use of pesticides: “Sustainable Use Regulation.” It stakes out the goals of the legally binding Farm-to-Fork strategy and makes the measures required. The use of pesticides and risk associated with their application should be halved by 2030. Commissioner Stella Kyriakides said the objective was to reduce the use of pesticides instead of extending the list of banned products. The strategy mirrors the wishes of EU citizens, she said.
The regulation requires all EU member states to equally contribute to reducing pesticide use and is more legally binding than Directive 2009/128/EC, which it replaces. UBA proposes five measures it considers necessary to ensure the strategy is successful:
Financial assistance for farmers: The implementation of the regulation would inflict costs on farmers, who would be allowed to apply synthetic chemical substances only in exceptional circumstances. They would have to rely on alternatives. This could result in both higher costs and reduced agricultural harvests. Both realities are conductive to reducing the incentive among famers to cut pesticide use. The regulation should therefore require EU member states to allocate a budget to compensate farmers for lost harvest and more expensive alternatives to synthetic chemical pesticides. The budget might be based on the size of agricultural production in each EU member state.
Pesticide tax: Revenues from a pesticide tax could be used to finance assistance packages for farmers and discourage the use of synthetic chemicals in agriculture. Progressive taxation system in Denmark where levies increase with the toxic load of pesticides has proven effective in discouraging the use of the most toxic chemicals and fostering the application of less harmful substances as well as alternative methods to protect crops. Revenue from such a tax system should be injected back into agriculture to compensate farmers who adhere to nature-friendly farming. The windfall could also be used to protect water resources from pollution and secure biodiversity.
Better protection sensitive areas: Protecting biodiversity is one of the main goals of the draft regulation. It aims to protect nature reserves and public areas like parks, which offer essential refuge for endangered species. UBA believes the regulation should implement larger buffer zones between those areas and agricultural fields to avoid pesticide exposure. In addition, the regulation should set clear and ambitious goals to raise the share of agricultural fields untreated with pesticides, which would contribute to the protection of endangered birds like skylarks and partridges.
Suitable indicator to measure progress: The Commission should rely on applicable and reasonable indicators to trace progress of measures to halve the use of pesticides across the EU. The current tool applied by the EU is unfit for purpose. The Harmonized Risk Indicator (HRI) relies mainly on volume sales to quantify the risks of pesticides, while taking less notice of their toxicity. A far more suitable indicator is applied in Denmark. The Pesticide Load Indicator (PLI) gauges the health and ecological risks associated with pesticides. The Treatment Frequency Index (TFI) also applied in Denmark and the Number of Dose Unit (NODU) index used in France have helped both countries map out the intensity of pesticides in agriculture and their environmental impact. The proposed regulation should use those indicators as guidelines for measuring progress on reducing pesticide use.
Digital database: The proposed regulation mandates farmers to report their pesticide applications to a central register. UBA believes a digital register is crucial as it would allow the Commission to see if and how fast pesticide use is falling, to identify the challenges farmers are facing, and which alternatives to pesticides are particularly effective. The data should be made available to concerned authorities.
Danish Pesticide Load Indicator: Kudsk, P, Jørgensen LN, Ørum JE (2018): Pesticide load — A new Danish pesticide risk indicator with multiple applications. Land Use Policy 70, 384–393. https://doi.org/10.1016/j.landusepol.2017.11.010
Möhring N, Kudsk P, Jørgensen LN, Ørum JE, Finger F (2021): An R package to calculate potential environmental and human health risks from pesticide applications using the ‘Pesticide Load’ indicator applied in Denmark. Computers and Electronics in Agriculture 191 (2021). https://doi.org/10.1016/j.compag.2021.106498