The organisers of the European Citizens’ Initiative Save Bees and Farmers (signed by 1.2 million Europeans demanding a 80% reduction of synthetic pesticides by 2030 and a full phase out by 2035) and the European organic movement are looking forward to the European Commission adopting a proposal for a Regulation for a Sustainable Use of pesticides (SUR) on 22 June. This urgently needed proposal must start the much-needed transition to a health-, climate-, and biodiversity-friendly food system by making the Farm to Fork Strategy’s target for a 50% Union-wide reduction of – both the use and risk of – chemical pesticides by 2030 legally binding.

However, the indicator currently proposed to measure progress towards this target – Harmonised Risk Indicator 1 (HRI-1) – is of great concern to NGOs and the European organic movement, as it seriously undermines the ambition and credibility of pesticides reduction efforts. The HRI-1, which Member States adopted in 2019 to measure the use and risks of pesticides, has been contested by PAN Europe ever since its adoption and was since found to be inappropriate by the European Court of Auditors. The auditors explained that the supposed reduction indicated by the HRI-1 is mainly due to a decrease in sales of substances that are no longer approved, and not to an actual reduction in pesticide use. The Court of Auditors called on the European Commission to improve the HRI-1 already in 2020.

Besides, a paper from GLOBAL 2000 (Friends of the Earth Austria) released today shows that the HRI-1 systematically overestimates the risk of natural substances used in organic farming compared to synthetic substances. For instance, the HRI-1 measures a more than 800% higher risk for a single application of Potassium bicarbonate – a natural fungicide classified by the Commission as low risk active substance and used as baking powder – than for Difenoconazole – a synthetic fungicide classified as candidate for substitution due to its combination of toxic and persistent properties.

Helmut Burtscher-Schaden, GLOBAL 2000: “The HRI-1 indicator is ineffective to measure pesticide reduction and undermines the ambition of the Farm to Fork strategy. A major misconception of the HRI-1 is that it establishes causality between the amount of pesticide used and the resulting risk, while largely ignoring existing differences in toxicity and treated area. Yet these differences amount to a factor between 10 and 1,000 when comparing synthetic active substances with naturally occurring active substances. Despite this, the HRI-1 attributes exactly the same risk to a kilogram of quartz sand – just sufficient to protect five trees from browsing by game – as to a kilogram of a pyrethroid insecticide – enough to kill every living insect over 200 hectares. To largely ignore these differences, as the HRI-1 does, inevitably leads to grotesquely wrong results”.

This is particularly discriminating for organic farming, where synthetic pesticides are prohibited and only substances which already exist in nature can be used for crop protection, as a last resort, after preventive measures. 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.

Eric Gall, Policy Manager at IFOAM Organics Europe, said: “The HRI-1 indicator leads to absurd results and gives the wrong impression that organic farming is the problem, because it is mainly a volume based indicator that discriminates against natural substances. Relying on a misleading indicator to measure pesticides reduction is ineffective and unfair to organic farmers who are the ones who strive to find alternatives to toxic synthetic pesticides. It is also in contradiction with the EU’s target of reaching 25% organic agricultural area by 2030. There are already more suited indicators used at national level in some Member States, that better take into account the area treated and toxicity profiles, that rely on existing data on pesticides sales and that can be readily used to fix the SUR”.

IFOAM Organics Europe published a note explaining that it is possible to build a better indicator on the basis of data on pesticides sales, taking into example the French indicator NODU. 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 with this indicator is that it does not discriminate against natural substances. Finally, the Commission and the Member States already collect the data necessary to calculate the NODU.

Martin Dermine, Policy Officer at PAN Europe added: “The Harmonised Risk Indicators chosen by Member States give a false impression of a reduction trend of the risk posed by pesticides in the EU.  Contrary to the HRI-1, other official data show citizens are more and more exposed to toxic pesticide residues in their food! Member States must stop arranging figures and delaying action to reduce toxic pesticides: the European Commission must fix these Harmonised Risk Indicators when publishing the revised Sustainable Use Regulation proposal”.

To ensure the upcoming SUR provides effective tools to achieve the Farm to Fork ambition, the organisers of the ECI “Save Bees and Farmers”, PAN Europe and IFOAM Organics Europe call on the Commission to include in its proposal on 22 June a new indicator, inspired by reliable national indicators, for monitoring the Farm to Fork pesticide reduction target.

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