On 18 June political leaders from the EU27 will meet to discuss concerns over rapidly rising food prices.

It will be a bitter irony if just a couple of days later the same countries’ agricultural ministers agree to proceed with a piece of legislation that would add significantly to the cost of food.

But that is the scenario Europe is facing as the EU attempts to update existing pesticides approvals legislation.

Two years ago the EU Commission published proposals to update the existing directive (EC 91/414 – PDF format). Among the suggestions was that if a pesticide’s active ingredient was found to pose a particular intrinsic hazard it would automatically be excluded from approval.

That means various “cut-off” criteria will be used to automatically withdraw products from the register of approved products if they exceed certain human health or environmental red flags. Previously those hazards would have been judged on the risk of actual harm being caused in the course of the product being used as recommended.

The cut-off criteria identified by the commission included products that were “Category 1 or 2 carcinogenic, mutagenic or reprotoxic”, unless exposure was negligible, products which were endocrine disruptors, and products which were persistent, bioaccumulating, toxic organic pollutants.

A second proposal suggested identifying pesticides which had properties that were less acceptable than the majority of approved products. For example, products which had significantly lower thresholds for “acceptable daily intake” or “acceptable operator exposure” than the majority of approved products.

These products would be designated “candidates for substitution” which meant they would be replaced when alternatives with better properties became available.

The commission’s proposals were then amended by the EU Parliament, which added further hazard cut-offs and decided that instead of leaving the option of continuing to approve candidates for substitution until suitable alternatives could be found, that these products should be registered for a five-year period only.

After that, regardless of alternatives, they would be taken off the register.

It also, crucially, proposed that candidates for substitution could only be approved once for a period of five years. It means all products that are candidates for substitution would be taken off the register after that point, and would not be re-approved.

Perhaps, unbelievably, neither the commission nor the parliament have carried out an impact assessment for its approvals. Others have, including the pesticides industry. But perhaps the most trustworthy analysis has been done by the UK’s Pesticides Safety Directorate. It has examined most of the existing pesticide products in the UK, and the results don’t make good reading for any proponent of using pesticides on arable farms.

The headline figures suggest under the commission’s proposals about 5-15% of pesticides would be “de-registered”, while 24% of products would be candidates for substitution.

Under the Parliament’s proposals 35-40% of products would be de-registered. A further 71% would lose approval after five years because of the candidates for substitution proposal. In total 82% of pesticides would lose approval by the end of the process, PSD estimates.

Commercial implications

PSD went further with its analysis. It looked at the implications for conventional commercial agriculture in the UK. Its conclusion? “If the full potential impact of the parliament proposals were realised, conventional commercial agriculture in the UK (and much of the EU) as it is currently practised would not be achievable, with major impacts on crop yield and food quality.”

Specific issues it identified if the Parliament cut-off criteria proposals were ratified include blackgrass control in cereals being almost impossible, as would weed control in horticultural crops. Disease control in most crops would be severely handicapped, while there would be a highly significant impact on crops caused by the loss of almost all insecticides.

Most horticultural crops would become uneconomic to grow, particularly if supermarkets were unwilling to compromise on various crop quality requirements, PSD noted.

Current UK arable and horticulture could become unsustainable due to unacceptably high weed infestations if after five years all candidates for substitution products were lost, it added.

Long-term storage of potatoes would result in an unacceptable loss of quality, while the control of most insects and virus vectors would be impossible chemically.

Even the less onerous commission proposals would have a significant impact on crop production. Most worryingly, triazole fungicides could be lost under these proposals, depending how endocrine disruption is defined. Their loss could cause a 20-30% drop in cereal yields. Disease control in oilseed rape would be impossible, too.

A follow up ADAS study, commissioned by the European Crop Protection Association, has quantified the effects on production of three crops – wheat, potatoes and brassica field vegetables – and then attempted to predict the effect on the price of each in an assessment that potentially gives some indications of the effect on food prices.

Again the results make worrying reading. The lowest impact proposals, the Commission’s exclusion criteria only, result in 25% lower production. In the most severe case – the full Parliament proposals – production would fall by at least 53%.

ADAS estimates that under the commission’s proposals a 25% increase in price across the crops would be required to maintain gross margins at current levels, while prices would have to double to compensate under the full parliament proposals.

The messages from the analyses seem straightforward. The proposed legislation would have a massive impact on European conventional agriculture, almost certainly causing production levels to decrease and food prices to increase.

How would the loss in production be made up? Nearly 750,000 extra hectares would be needed, according to the ADAS study, to make up the shortfall in wheat production from the Commission’s proposals alone. It is more than 3m hectares for the parliament’s ideas.

Where is that land going to come from? With the battle raging over food versus fuel production, it is not particularly evident that the EU has that spare capacity available.

Quality of produce would also be adversely affected. UK consumers have grown accustomed to buying vegetables and fruit that have no superficial blemishes or occasional insects in, for example, pre-packed salads. Will consumers accept a lowering of those standards? Unless retailers change their criteria the Parliament’s proposals would almost certainly see rejections increase, and could make those crops uneconomic to grow.

It has been suggested by some commentators that the proposals could lead to some sectors of European agriculture being exported out of the EU. And what will the EU position be regarding imports of food products from countries outside of the EU, who use pesticides banned from use within the EU?


When faced with such overwhelming evidence of the potential damage to EU agriculture it seems unbelievable that common sense will not prevail, and a more sensible compromise found.

Yet, other than the UK and possibly Ireland, no other European government appears opposed to the legislation. Indeed, France scuppered a Slovenian-proposed compromise at the recent Council of Ministers meeting which would have retained cut-off criteria, but defined some of the unknowns, such as negligible exposure and what endocrine effects are, in favour of the original commission proposals.

The reasons behind the dichotomy are not immediately apparent. Undoubtedly the political clout of “greens” is higher in some countries, notably Germany and France, where President Sarkozy has committed to reducing pesticide use.

And maybe the UK is lucky in having an approvals body where agronomists and policy makers work closely together. That’s not the same in other countries, so maybe agronomists haven’t made policy makers fully aware of all the implications.

It could also be because the proposals originated from the EU’s consumer affairs arm, and are seen as a health and environment concern, rather than a food supply and price issue.

Whatever the reason, stakeholders across Europe will need to move quickly to lobby political leaders. Within the UK steps are being taken with the entire food chain, from farmer to food retailers organisations, coming together to lobby Prime Minister Gordon Brown to put the issue on the table at the food price summit.

But it will probably require successful lobbying from within other EU countries to help change the course of legislation that could have a profound effect on the future of EU agriculture.