Political hotspot June 2022 Newsletter

On 22 June, the European Commission published two important legislative proposals related to the implementation of the Farm to Fork strategy: the Regulation on the Sustainable Use of plant protection products (SUR) and the Nature Restauration Law (NRL), which constitute the so-called “EU Nature Protection Package”.

Through these two legislative proposals, the European Commission sets ambitious key targets to achieve the transition towards a sustainable food system. In the SUR proposal, the European Commission proposes to make the Farm to Fork Strategy’s target of a 50% reduction in the use and risks of chemical pesticides by 2030 legally binding at EU level. The NRL proposal sets binding restoration targets for specific habitats and species (including pollinators and agricultural ecosystems) which should cover at least 20% of the EU’s land and sea areas by 2030, and ultimately all ecosystems in need of restoration by 2050 (in the NRL).

Two proposals that survived the disinformation on food security
IFOAM Organics Europe welcomed the fact that the European Commission presented these two proposals on 22 June and resisted pressure from Member States for further delay. Member States and private sector lobbies have been reluctant to adopt EU legally binding targets for pesticide reduction since the publication of the Farm to Fork Strategy in May 2020. But in the last months, they have strengthened their call for a postponement of the Commission’s Nature Protection Package, using the pretext of the war in Ukraine to falsely argue that it would endanger food security in Europe in an already difficult period.

The Nature Protection Package was initially supposed to be presented on 23 March but the Commission postponed its release to the 22 June. The publication of this package puts an end to  the attempts of the past months to water down the Farm to Fork Strategy’s ambitions and now allows to start the democratic co-decision process within the European Parliament and the Council of the EU.

Towards a strengthened EU policy framework for pesticide reduction…
According to the Commission’s proposal, Member States will have to define national pesticide reduction targets (between 35% and 60%, depending on their starting point) to contribute to the EU-wide target of 50% reduction of chemical pesticide use and risks by 2030. Member States should establish National Action Plans explaining how they intend to achieve their national targets.

A positive point for the organic sector is that the Commission asks Member States to link their National Action Plan for pesticide reduction, with the parts of the CAP Strategic Plans setting out plans to increase organic farming and contribute to the Farm to Fork Strategy’s target for 25% of organic farmland by 2030. This clearly acknowledges the role of organic farming in pesticide reduction and the needs for Member States to provide sufficient support to organic farming.

… severely hindered by biased result indicators

However, the most needed ambition of the Regulation on the Sustainable Use of plant protection products in pesticide reduction will be pointless if the indicator to measure pesticide reduction is not fixed. IFOAM Organics Europe is disappointed that the EU Commission did not fix the indicator to measure progress towards EU and national pesticide reduction targets.

This indicator, based on the methodology of the Harmonised Risk Indicator 1 (HRI-1) adopted in 2019 by Member States, presents two major failings:

1. It indicates a supposed reduction which is mainly due to a decrease in sales of substances that are no longer approved, and not to an actual reduction in pesticide use (according to the European Court of Auditors); and
2. It wrongly establishes causality between the amount of pesticide used and the resulting risk, which unfairly discriminates alternatives to synthetic pesticides based on natural substances. Therefore, with the biased methodology of the HRI-1, any switch from conventional to organic farming would be shown as an increase of the risks from pesticide use, which is absurd as it is wrong.

Relying on a misleading indicator to measure pesticides reduction is ineffective and unfair to organic farmers who strive to find alternatives to toxic synthetic pesticides, as IFOAM Organics Europe and environmental NGOs denounced in a press release two weeks ago. This biased indicator based on the widely criticised HRI-1 will absolutely need to be fixed by the European Parliament during the co-decision process, otherwise the SUR will not support the reduction target of 50% synthetic pesticides by 2030 mentioned in the F2F strategy.

“Take time to develop other indicators,” they say. Really?
Some argue that it is necessary to wait for the EU to collect data on pesticide use (available as of 2028 according to the new EU Regulation on statistics on agricultural inputs and outputs (SAIO)) to propose a better indicator. In the meantime, the HRI-1 methodology would be the best way to calculate an indicator based on sales data.

This is not true. Reliable indicators based on pesticide sales data already exist and are implemented by some Member States. This is the case of the French indicator NODU (Number of Unit Doses) implemented by the French authorities to measure progress towards pesticide reduction. The NODU gives information on the intensity of the use of pesticides, with an indicator in hectares reflecting the total area that would be treated with the active substances sold annually. The advantage of this indicator is that it does not discriminate against natural substances because it considers the doses (in kg/ha) of active substances.

During the co-decision process, IFOAM Organics Europe will continue to propose reliable and implementable alternative indicators to measure pesticide reduction. The progress towards the Farm to Fork pesticide reduction target cannot be monitored on the basis of the HRI-1, otherwise the SUR will fail to achieve a real pesticide reduction, as the previous Directive (SUD) did.