COLEACP response to public consultation regarding the EU Sustainable Use Directive

COLEACP is contributing to the public consultation on the revision of the EU Sustainable Use Directive (SUD). The European Commission (EC) is launching an evaluation of the SUD and assessing the impacts of possible future measures intended to significantly reduce the use and risk of chemical pesticides. The SUD covers the use of pesticides, complementing EU legislation governing the placing of plant protection products (PPPs) on the market (Regulation (EC) 1107/2009), and pesticide residues (Regulation (EC) 396/2005).
The SUD primarily concerns the use of pesticides within EU Member States, but will also have an impact on the use of pesticides in third countries. COLEACP’s response considers the evaluation in the context of impact on ACP countries. It addresses, in particular, potential impact on trade through changes to the setting of pesticide residue Import Tolerances, as well as the drive to influence trading partners, especially developing countries, to transition towards the more sustainable use of pesticides. COLEACP highlights the need for these potential impacts in developing countries to be specifically addressed in the terms of reference for the evaluation.

Any potentially negative impacts of new policies must be understood, avoided, mitigated, or (according to Article 9 of the SPS Agreement) accompanied by technical assistance that ensures there is capacity to meet any new demands on exporting countries.Special and differential treatment may be taken into account for developing countries to reduce the economic impact of regulatory changes (Article 10).

If the intention is for pesticide policy under the SUD to extend to third countries, especially developing countries, the evaluation must similarly be extended to assess the costs and benefits, unnecessary burdens and complexity, and likely impacts. In addition, it must align with EU development policy and assess any impacts on progress towards achievement of the Sustainable Development Goals.

COLEACP activities are oriented towards supporting sustainable agriculture in ACP countries. We promote integrated pest management (IPM) and help producers to control pests while minimising any negative impacts on people or the environment. PPPs are recognised to be an important element of an IPM system, and COLEACP works to ensure that producers can access appropriate and less harmful PPPs, and can use them safely.

Contributing to the Minor Use Foundation/IR-4 prioritisation exercise

COLEACP will be working closely over the coming months with the Minor Use Foundation (MUF) and the IR-4 Project (IR-4), contributing to a major prioritisation exercise to identify global minor use priorities for plant protection products in speciality crops. In particular, Edouard Lehman of COLEACP will lead one expert panel and take part in a further two.

This month, all the collaborators selected the top 10 global crop–pest priorities in each of three sectors – tropical, temperate and greenhouse. Expert panels will conduct Merit Analyses for these 30 crop–pest priorities in July/August. The results of the prioritisation exercise will then be discussed at the Global Minor Use Priority Setting Workshop in September 2020 to make decisions on the top 10 projects to progress between October 2020 and September 2021.

COLEACP represents the interests of the ACP countries by contributing to all stages of this exercise, and will lead the panel of experts conducting the Merit Analysis for the Aubergine–Thrips combination, as well as taking part in the panels assessing the Tomato–Tuta absoluta and Mango–Anthracnose combinations.

MUF works to harmonise global residue tolerances through developing and implementing research priorities. It plays the role of facilitator by enhancing< cooperation among stakeholders globally, and hosting Global Minor Use Priority Setting meetings and the Global Minor Use Summit. IR-4 has been the primary entity in the USA facilitating registrations of conventional pesticides and biopesticides on speciality food crops (fruits, vegetables, nuts, herbs, spices) and non-food environmental horticulture crops. While it focuses on providing support to farmer/growers, food processors and consumers of speciality crops/speciality uses by facilitating US regulatory approval, it also works on international acceptance of chemical and biologically-based pest management technologies, mainly via projects funded by the Standards and Trade Development Facility (STDF).

Brexit

UK–EU negotiations on Brexit are ongoing; COLEACP is following the discussions but the likely outcomes are still quite unclear. We are particularly concerned by the potential for divergence between EU and UK SPS regulations, and EU/UK customs procedures (delays, infrastructure, etc.), specifically for triangular supply chains. COLEACP is liaising with other professional associations on these matters and will continue to follow any new developments very closely. We will be updating the Brexit section on our website during the summer period. COLEACP continue to inform ACP embassies and the OACPS on any specific developments in this area.