Memorandum submitted by the Crop Protection Association (SFS 22)



Executive Summary


Crop protection plays a vital role in helping to ensure food security.


The use of crop protection products helps farmers to grow a reliable, abundant supply of high quality, safe, affordable food. Without them the UK would become more dependent on imported food.


With the increasing cost of research and development and the demands of the regulatory system it is becoming more and more difficult to discover new crop protection products and bring them to market. Farming and associated industries operate in a global marketplace and unwarranted constraints on the use of pesticides in the EU and UK will put us at a competitive disadvantage and so threaten our ability to maintain local production.


We need to keep as wide a range of crop protection products available as possible to enable farmers to manage pest resistance and to help provide solutions to new pest problems that will develop with climate change. It is important to ensure that regulatory decisions and any further restrictions on the use of pesticides are based on evidence rather than politically motivated.




1. The Crop Protection Association represents companies involved in the manufacture and supply of plant protection products for use in agriculture, horticulture, forestry, amenity areas and gardens. We have 23 member companies, covering more than 90% of the UK pesticide market with sales of 500 million.


2. Technology is key to increasing food production in the UK and elsewhere. Advances in mechanisation, fertilisers, plant breeding, crop protection and potentially biotechnology all play a role.


3. Crop protection is essential to ensure that crop yields are maximised. Without protection we would lose more than 40% of crop yield pre-harvest and a further 10% post-harvest. Currently pesticides (herbicides, insecticides and fungicides) are the main and most effective means of crop protection. They play a vital role therefore in ensuring a reliable, plentiful supply of high quality, affordable food, i.e. food security.






4. Talking about food security, Hilary Benn said on 6 January 2009 at the Oxford Farming Conference:


"I want British agriculture to produce as much food as possible. No ifs, no buts. And the only requirements should be first that consumers want what is produced and, second that the way our food is grown both sustains our environment and safeguards our landscape."


We agree with this. There is an increasing demand for home grown produce. In order to meet this demand, pesticides, used in a responsible way in conjunction with crop rotations and cultural controls in an integrated crop management system, are a key part of sustainable farming in the UK.


5. Mr Benn also said:


"We could produce more fruit and vegetables here in the UK - the market is there, so what is holding us back? If there is a demand then production should follow."


This suggests that, although he has been "arguing against the pesticides regulation which could hit yields by limiting the crops that can successfully be grown in the UK for no recognizable benefit to human health", he does not fully understand the challenges faced by growers in the UK.


6. As a result of the EU review programme for pesticides under directive 91/414/EEC, around 60% of active substances in the EU were lost due to the prohibitively high cost of generating new data required. This led to gaps in the products available for use on so-called minor crops (i.e. virtually anything other than cereals).


7. This situation is likely to be exacerbated by the proposed EU Regulation on the Placing of Plant Protection Products on the Market which is nearing final agreement. At a time when there is so much concern about food security, we believe it is irresponsible to introduce legislation which could make it more difficult to produce food in Europe and whose impact has not been properly assessed.


8. The whole food chain in the UK has been calling for a thorough EU-wide impact assessment of the proposed Regulation. The Prime Minister and Defra ministers have supported this (see attached correspondence[1]) but have been unable so far to obtain support from their counterparts across Europe.


9. In the absence of an EU-wide assessment of the impact of the proposed hazard cut-off criteria in the Regulation, two impact assessments were conducted by the UK Pesticides Safety Directorate (PSD).


10. In its most recent assessment (December 2008), PSD found that up to 14% of the pesticide substances assessed could be removed by the criteria in the common position of the Council adopted in September 2008 but much depends upon the definition of endocrine disruptors which is uncertain. This loss of products could make it difficult to grow certain crops in the UK and so make us more reliant on imports. In addition it reduces the range of substances available for resistance management and limits the potential solutions available to deal with new pest problems arising from climate change.




11. The question has been asked "why doesn't the industry just find more new products?" Unfortunately it's not that simple. Companies commit heavily to research programmes but it takes nine years and 150 million to research, develop and register a new pesticide. This long lead time makes it difficult to respond to changing needs and the high cost means that companies focus on major crops in order to recoup their investment.


12. Companies must also have a predictable regulatory system to give them the confidence to make such major investments. Therefore legislation such as the proposed Regulation which introduces new and undefined regulatory criteria poses a threat to the introduction of new products. Whilst it will not help us in this particular case, we welcome Hilary Benn's statement at Oxford that he is "working hard in Europe to try to get the principles of better regulation recognized and implemented".


13. Once a crop protection product is authorised for sale, it is important that it is used properly. We therefore support measures which reduce risk and promote responsible use. Use reduction targets, which are proposed as an option in the EU Sustainable Use Directive soon to be agreed, achieve neither.


14. Under good agricultural practice, pesticides should only be used when they are needed and in the amount required to do the job effectively. Imposing arbitrary reduction targets just makes it more difficult for farmers to control pests and to avoid the development of resistance. Risk reduction is achieved by focussing on how the products are used not how much.


15. We strongly support the measures under the Voluntary Initiative (VI) to promote responsible use and minimize any impact of pesticides on the environment. Some of these measures will soon be enshrined in EU legislation under the Sustainable Use Directive e.g. sprayer testing, operator training and we hope that the Government will recognize the VI schemes as meeting the Directive's requirements in these areas.


16. There has recently been an increasing emphasis in Defra policy on alternatives to pesticides. Whilst it is important to consider all options to secure our food supply, we feel that there should not be a presumption against pesticides.


17. Synthetic chemistry will remain an important tool for farmers and growers for the foreseeable future and we need to ensure that we have:

a predictable, transparent, science-based regulatory system to encourage innovation;

investment in work to develop suitable solutions to enable continued production of fruit and vegetables in the UK (including the use of existing pesticides); and

responsible use within an integrated farming system.













Crop Protection Association UK Ltd

January 2009

[1] Not printed