Pöördumine

Dear Karmen Joller,

We are writing to draw your attention to a Policy Forum article published in Science (https://www.science.org/doi/10.1126/science.aeg8744), authored by 35 researchers from various research institutions across Europe, in which we assess the proposed amendments to EU pesticide regulation under the Omnibus package X: Food and Feed Safety.

We conclude that many of the proposed changes would weaken protections for human, animal, soil, and environmental health, and stifle rather than foster innovation. We are particularly concerned about the following issues:

•  granting indefinite approval to most active substances would eliminate the successful renewal cycle that has been instrumental in identifying and regulating pesticides with unacceptable risks. Since 2011, this cycle has led to 59 conventional active substances failing renewal on health or environmental grounds, and a further 96 not seeking renewal (likely in part because applicants anticipated non-renewal). By contrast, ad hoc reviews removed only two harmful substances over the same period.
• the integration of new independent knowledge generated after authorisation would be hampered by removing the periodic renewal, as well as by re-defining what “current scientific and technical knowledge” constitutes in plant protection product authorisation. In practice, this risks novel research results generated post-authorisation being systematically disregarded.
• extending grace periods to up to three years for substances that have lost their approval — including those for which identified health or environmental concerns were the reason for non-renewal — risks prolonging the harm to people and the environment, and sending a problematic signal on where the priorities reside.
• removing the requirement for farmers to document their use of biocontrol products would reduce monitoring capacity for a category of substances whose environmental impacts are still poorly understood. Furthermore, the overly broad definition of biocontrol substances proposed by the Omnibus might encompass high-risk synthetic substances.
• Finally, the proposal shifts the effective burden of acting on scientific evidence toward public authorities, without clarifying how or when scientific findings should trigger regulatory review, rather than reinforcing the precautionary and prevention principles enshrined in the Treaty on the Functioning of the European Union.

We fully support the overall aim to achieve greater efficiency in the approval and control process, but this cannot come at the expense of nature and people’s health. We therefore respectfully ask that you consider our concerns and recommendations in your deliberations on the Omnibus proposal. We recommend rejecting the Commission’s proposal. As we outline in our paper, we are convinced that a more robust yet efficient approach to pesticide regulation is achievable — one that can meet the legitimate goals of simplification while maintaining the protections that citizens and ecosystems depend on. Our paper offers a set of recommendations that we believe could serve as a useful starting point for such an approach.

We would be happy to provide additional materials in support of our concerns or recommendations and are open to discussing these issues further with interested policymakers.

Yours sincerely,

Dr. Dimitry Wintermantel
Prof. Ralf B. Schäfer
Prof. Denis Michez
Dr. Lindsey Hendricks-Franco
Prof. Robert Paxton
Dr. Guy Pe’er
Dr. Joachim R. de Miranda
Prof. Simone Tosi
Prof. Mark J F Brown
Dr. Claudia Ituarte-Lima
Dr. Annika Jahnke
Prof. Andreas Schäffer
Dr. Maj Rundlöf
Dr. Daniel Slunge
Prof. Fabio Sgolastra
Prof. Carsten Brühl
Prof. Adam Vanbergen
Prof. Alexandra-Maria Klein
Prof. Dave Goulson
Dr. Julia Osterman

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Dr. Dimitry Wintermantel

University of Freiburg

Chair of Nature Conservation and Landscape Ecology

Stefan-Meier-Str. 76

79104 Freiburg