- Dear COMAGRI MEP,
- Ahead of the discussion in COMAGRI tomorrow morning on the Commission’s draft proposal for
- Criteria for Endocrine Disruptors (ED), for Plant Protection Products (pesticides) and Biocidal
- Products we would like to provide you with background information on this issue, including the ECPA
- View on ED and infographic in attachment. The Commission published its draft proposal for ED
- criteria on 15 June, along with the results of its impact assessment (executive summary attached)
- What is the issue?
- At a difficult time for the EU agricultural sector, particularly following the Russian embargo, we find it
- surprising that the Commission proposal ignores their own socio-economic impact assessment, and
- proposes measures that will undoubtedly further impact the viability and competitiveness of EU
- agriculture. The EC has proposed an option (option 2) which they acknowledge will have ‘the highest
- impact on sectorial competitiveness, agriculture, and trade’, while offering ‘the same high level of
- protection to human health’ as all other options. In other words there will be maximum impact on
- agricultural competitiveness with no additional benefit for society. Please see for reference our
- letter to DG Sante on 11 July highlighting these points.
- What is the impact?
- EU farms – big and small - are already heavily impacted by a strict hazard based regime for the
- authorisation of pesticides in the EU, and this proposal will only add further complications, removing
- more tools from the EU farmers’ toolbox. This will lead to the loss of EU agricultural jobs. It will also
- result in the development of resistance to an ever narrower range of products. This is outlined in a
- recent report endorsed by Copa Cogeca and ECPA on the ‘Cumulative impact of hazard based
- legislation on crop protection products in Europe’ which shows losses of up to 85% of yields in some
- countries. This report covers 9 EU Member States, 7 staple crops and 24 specialty crops. Please find
- attached a summary sheet.
- What can I do?
- With 46 million EU jobs at stake across the EU Agri food sector, we feel it is important that EU
- Commission consider the socio-economic impact of this proposal for EU agriculture, its
- competitiveness and trade, bearing in mind its large contribution to overall EU GDP. The
- Commission is yet to give a clear rationale for choosing such a demonstrably discriminatory and
- disproportionate policy option. We hope Agriculture MEPs will take this opportunity to question the
- Commission on this point.
- I remain at your disposal should you require any further information, and am available at any time to
- meet if you wish to discuss further.
- Kind regards,
- Graeme Taylor
- Director of Public Affairs