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copa,~'

cogeca
european
farmefs european
agri-cooperarves

CC(19)8789:1 - PDV/DDJ /r s Director-General Anne Bucher


Directorate General for Health
and Food Safety
Europ ean Commission
Rue de la Loi 200
1049 Brussels

Brussels, 17th October 2019

Re: Chlorpyri fos and chlorpyrifo s-methyl renewal p rocess

Dear Ms Bucher,
Copa and Cogeca would like to draw your attention to the importa nce of chlorpyrifos active
substance s at Europe an level (chlorpyrifos, CHP, and chlorpyrifos -m ethyl, CHP-
methyl) . Withdrawing these substances without an appropriate transit ional period , could
significantly compromise European fruit and vegetable production.
Chlorpyrifos plant protection products are used in agriculture in the chemical defence of crops
(fruit and vegetables in the field, grain storage) because of their effective insecticida l properties.
They adequately and reliably repe l a wide range of insect s that are seriously harmful to various
crops (e.g. Halyomorpha halys, the brown marmorated stink bug from Asia that has been
presen t in Switzerland and Liechtenstein since 2007 and t hat is gradually spreading to many
other regions in the EU).
Unfortunately , to date , t here are no equally efficient alternatives (be they chemical or not) to
ensure safe crop protection . At the same time, non -chemical alternatives (e.g. Trissolcus
japonicu s, a natural predator of H. halys) are still being tested for effectiveness . On the other
hand, the variations in climatic conditions, which have been recorded in many European
countries and marked by an increase in average winter and summer tempe ratures in 2018 and
in 2019, resulted in serious damage to fruit due to attacks by pests such as the brown
marmorated stink bug. The damage has affected large volumes of fruit, between 40% and 100%
of the harvest , leaving them no longer marketable, neither for fresh consumption nor for the
processing industry .
As you may also know, both technical dossiers for these substances will be examined in the
appropriate fora of the European Commission in the coming months . The approval period for
both CHP and CHP-methyl will expire on 31stJanuary 2020 and, as far as we know, the
Commission is planning to go for a non-renewal of both of these substances .
Copa and Cogeca would like to stress that until an adequate alternative is found, EU producer s
must therefore continue to have access to chlorpyrifos -based plant protection products . This is
essentia l in order for them to effectively defend their plants and crops which represent a
fundamental source of income and livelihood. In the event of non- renewal, EU producers must
at least have a sufficient grace period to ensure the protection of their crops and to be able to

Copa - Cogeca I European Farmers European Agr i-Cooperat ives


61, Rue de Treves I B - 1040 Bruxelles I www .copa-cogeca .eu
EU Transparency Registe r Number I Copa 4485688123 1-49 I Cogeca 09586631237 -74
place them on the mark et. The current informa tion that we have regarding a three month period
is still insufficient .
Moreover, we would like to call on the European Commission not to ask Member States for an
opinion on a non-approval of CHP and CHP-methyl before EFSA's peer review is available.
This peer review is scheduled to be released on 31 st October 2019 after the October SCoPAFF
meeting on Phytopharmaceuticals. If the Commission condemns these two substances before
having the final scientific assessment, we believe that this would set a dangerous precedent for
the European evaluation process for active substances. The process would become totally
unpredictable, not to mention the lack of transparency that it would imply from the part of the
European Commission.
More specifically regarding CHP-methyl, we also feel that, for the first time in an EU risk
assessment, an active substance is being condemned mere ly by extrapolating the results
from anothe r substance that stems from the same family but that has differe nt
effects . In this case in particular, the EFSA's most recent dossier published in August 2019
shows that this active substance does not pose problems that could lead to its non -renewal.
At the forthcoming SCoPAFF meetings, in particular those on 21 st and 22 nd October 2019 and 5th
and 6th December 2019, the proposals for regulations on the non -renewal of chlorpyrifos active
substances will be discussed . During these meetings, we also want to urge the European
Commission to recognise the high risk that the lack of effective protection against pathogenic
insects, including the brown marmorated stink bug, would pose to major and speciality fruit and
vegetable crops( pears, apples, peaches, nectarines, kiwis, plums), potatoes, sugar beet, soy bean
and cereals.
By way of conclusion, it is important to note that if agricultural producers are left without any
means of defence against plant pests and diseases, they will suffer significant economic losses,
witness a decline in their competitiveness compared to non-European countries, see
employment impacted and scarcity problems in food supply in the short-term.
Copa and Cogeca call on the Commission, therefore, first to wait for the peer review from EFSA
on both substances before they adopt a position on the renewal of the approval of
chlorpyrifos-based active substances . If this science-based assessment ultimately recommends a
non-renewal of CHP and/or CHP-methyl, we ask that this be on a transitional basis so that
alternative safe and effective overall phytosanitary defence solutions can be found .
Thank you for taking our concerns into consideration. We remain at your disposal should you
have any further questions and look forward to your hearing from you.
A copy of this letter has been sent to Mr J erzy Bogdan Plewa, Director-General of DG AGRI.

of Copa and Cogeca

Cc: Klaus Berend, DG SANTE, Head of Unit, E4 - Pesticides and biocides

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