Select Committee on Science and Technology Written Evidence


Memorandum from the Crop Protection Association

  The Crop Protection Association represents companies in the UK engaged in the manufacture, formulation and supply of crop protection products for use in agriculture, horticulture, forestry, home gardening, industrial and local authority outlets.

  Crop protection products are some of the most heavily tested and regulated chemicals in the EU. No pesticide can be marketed unless its safety to consumers including adults, children and the unborn child can be established. I attach a set of Briefing Documents describing how pesticides are developed, tested and regulated in the UK, (not printed).

  To a large extent, plant protection products are not subject to the registration requirements and authorisation procedures of the REACH proposals, as most active ingredients will be considered as "already registered". This is set out in Article 8 (in Title II, Chapter 2) of the proposal, which states that:

    ". . . active substances manufactured or imported for use in plant protection products only . . . shall be regarded as registered . . . for the uses covered by such an inclusion . . ."

  Alun Michael, Minister for Defra reinforced this message in answer to a parliamentary question on 13 January:

    "To ensure compatibility of regulation, the REACH proposal allows for certain substances to be exempt or considered as automatically registered where environmental or human health protection is already adequately covered by existing regimes such as for pesticides, biocides and veterinary medicines".

  Active ingredients will therefore be exempt from the general obligation to register within REACH, as they will be treated as already being registered. They will also be exempt from the requirement to perform chemical safety assessments and produce chemical safety. Additionally Article 53, states that their specific use in plant protection products will be exempt from the authorisation procedures set out in Title VII.

  However, the crop protection industry is still concerned that the Commission proposal as it stands will increase the production costs of plant protection products. For example, adjuvants, co-formulants and intermediates used in plant protection products will need to be registered under the provisions set out in the proposal. While the crop protection industry accepts that they should be covered by the REACH proposals, any new measures should not be over-burdensome and costly.

  In addition, the European Commission proposal appears to be too ambitious with regard to the amount of time it will take to register and authorise all relevant chemicals. Their belief that all the work can be carried out in 11 years would seem unrealistic when the experience in the Plant Protection products and biocides sectors shows that the evaluation works takes much longer than was originally expected.

January 2004

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