HomeIdeaReduction of pesticides in the EU, ahead with mockery

Reduction of pesticides in the EU, ahead with mockery

On 24 October 2023, the ENVI (Environment, Public Health and Food Safety) commission of the European Parliament approved with a weak majority (47 votes in favour, 37 against and 2 abstentions) the proposal for a regulation for the reduction of pesticides in agriculture (1,2 ,XNUMX).

However, the troubled reform remains problematic, indeed mocking, in its fundamental flaw already censured by the European Court of Auditors (ECA). The indicator proposed by the Commission to measure the reduction of pesticides is misleading and could even lead to a result opposite to the declared objectives.

1) Sustainable Use and Reduction of Pesticides (SUR), the vote in the ENVI Commission

The October 9 2023 the AGRI Commission of the European Parliament - having a consultative role in examining the proposal for a SUR (Sustainable Use and Reduction of Pesticides) regulation - had tried to water down its objectives. Proposing to contain the reduction of pesticides (-35%, instead of -50%, at national level) and to postpone the deadlines to 2035, rather than by 2030. (3)

The ENVI Commission – responsible for presenting the dossier to the plenary assembly – was able to partially resist (see the following paragraph 3) the agro-industrial lobbies, improving the original text of the proposal in some aspects:

– raising the reduction in use of the most dangerous active substances to 65%, (4)

– monitoring of pesticide residues in the environment, (5)

– ban on operators located in Member States from importing, producing and exporting to third countries active substances and pesticides banned in the EU. (6)

2) Reduction of pesticides, process laws

The text approved by the ENVI Commission of the European Parliament will collect new proposals for amendments, awaiting the vote on the agenda at the plenary session of 20 November 2023.

The text approved by the Assembly will then be discussed by the governments of the member states, in the Council, with a view to a possible compromise agreement with the assent of the European Commission.

Se an agreement will not be reached by the end of the current legislature (May 2024), the examination of the proposed SUR regulation will have to start again from the beginning in the next one.

The strategy 'Farm to Fork' risks failing, once again, due to the connivance between the various European political groups - which have recently also been joined by the 'social(m)ists' - and the governments of member states such as Italy , all under the orders of the large agricultural confederations and global monopolists of pesticides and seeds. (7)

3) Forward with mockery

The mockery is threefold:

– the threat of postponing the examination of the proposed SUR regulation to the next legislature opens the negotiations downwards, since all the political parties have an interest in being able to boast of their miserable 'conquests' in the upcoming electoral campaign,

– the Commission responsible for the European Parliament (ENVI), not surprisingly, has weakened the proposal by bringing forward by a decade (to 2013-2017) the period to which to refer for evaluating the reduction of pesticides, which will therefore be distorted. In addition to having weakened the protection of sensitive areas,

– no one has so far resolved the archetypal flaw, already highlighted by the 'European Court of Auditors'. (8) The European Commission, at the 'suggestion' of the poison lobbies, (9) has introduced a 'pesticide risk indicator' (HRI 1) which, as will be seen, is misleading.

4) Misleading risk indicator

SUR (Sustainable Use of Pesticides Regulation) proposes the objective of reducing the use of dangerous pesticides - a category that includes herbicides, fungicides, bactericides - in EU agriculture by 50% by 2030. (1) The European Commission However, it proposed a measurement tool, the Harmonized Risk Indicator 1 (HRI 1), which is completely misleading.

The HRI 1 divides 'pesticides' into four categories and assigns a different weighting factor (WF) to each of them:

  • 'low risk', WF 1,
  • 'normally authorized', WF 8,
  • 'most dangerous', i.e. pesticides candidates for replacement, WF 16,
  • 'unauthorized', WF 64.


Video above – 'The deceptive harmonized risk indicator 1, and how it can be fixed' – shows the paradox of this indicator. Where:

– the simple replacement of a prohibited pesticide with a similar authorized product leads to an 8-fold reduction in the 'weighting factor' (from WF 64 to WF 8), while

– the 'ban' of a substance can also result from the failure to request renewal of its authorisation, regardless of its riskiness, even if only for commercial reasons,

– 75% of all substances today fall into 'category 2', regardless of their effectiveness against target organisms and the risks for non-target organisms (10,11).

5) Necessary corrections

Scientific opinion published by the German Federal Environment Agency (Umweltbundesamt, UBA, 2022) has already indicated for some time how to correct the HRI 1 indicator. In summary, it is necessary:

  • associate sales volumes with average application rates (existing data published by the Agency, in relation to 255 substances),
  • significantly reduce the risk factor for unapproved pesticides (from 64 to 16),
  • differentiate pesticides within 'category 2', to be re-classified at EU level,
  • include high-risk non-chemical pesticides, currently not included in the indicator,
  • move the reference period from 2015-2017 to 2018-2020. (12)

6) Provisional conclusions

'The use of pesticides must be halved by 2030, according to the draft EU regulation on pesticide reduction. However, this objective must be verified using data on pesticide sales. According to the Federal Environment Agency [as already highlighted by the European Court of Auditors, ed.] this method is misleading. Pesticides that are no longer approved carry too much weight. A decrease in sales figures would indicate a decreasing trend, which does not occur in the field' (Umweltbundesamt, press release 25.10.23). (13)

reduction of pesticides
Figure 1: How the EU calculates the pesticide risk down to a minimum (Umweltbundesamt, UBA). (15)

The Environment Agency of the Federal Republic of Germany also proposes to increase the areas free from pesticides by 10%, in contrast to the exemptions granted by the European Parliament, (14) and to encourage the adoption of the organic method in areas close to protected and particularly sensitive ones. A fundamental need to protect public health from the risks of exposure to toxic chemicals due to the 'drift effect'. (15)

Is critical also remember - in official controls, as in second-party audits (ie retail) and in the certifications of hypothetical 'sustainability' of agricultural practices - the binding provisions already prescribed by the current Reg. (EC) 1107/2009 on integrated pest management and crop-specific rules, according to which farmers are obliged to adopt preventive and non-chemical methods as a priority. (16,17)

Dario Dongo and Alessandra Mei


(1) Dario Dongo. Reduction of pesticides, the proposed EU regulation. GIFT (Great Italian Food Trade).

(2) Pesticide Action Network Europe. ENVI committee vote on pesticides regulation SUR. 24.10.23 https://tinyurl.com/2s36thdw

(3) Dario Dongo. Nature Restoration Law, reduction of pesticides. MEPs at the service of agro-industrial lobbies. GIFT (Great Italian Food Trade).

(4) Marta Strinati. Pesticides used in conventional and bio. Comparison of toxicity. GIFT (Great Italian Food Trade).

(5) Marta Strinati. Pesticides, call for the collection and publication of reliable data. GIFT (Great Italian Food Trade).

(6) Marta Strinati. Stop EU exports of banned pesticides that return to our plates. GIFT (Great Italian Food Trade).

(7) Dario Dongo. Seeds, the 4 masters of the world. GIFT (Great Italian Food Trade). 15.1.19

(8) European Court of Auditors (ECA). Special Report 05/2020: Sustainable use of plant protection products: limited progress in measuring and reducing risks https://tinyurl.com/eaajeznh

(9) HR1 is a «reasonable way to measure the hazard reduction of pesticides» (Crop Life Europe)

(10) IFOAM. Policy brief: correcting the F2F Indicator https://tinyurl.com/mr2m8kcu

(11) IFOAM. Baking soda more dangerous than synthetic pesticides? EU decision-makers on the brink of endorsing deceptive pesticide metrics. 16.10.23 https://tinyurl.com/yrdhd84j

(12) Umweltbundesamt, UBA. (2022). Towards sustainable plant protection. https://tinyurl.com/2vrxpmfs

(13) Umweltbundesamt, UBA. Misleading calculation: EU plans for pesticide reduction at risk. 25.10.23 https://tinyurl.com/32b6pbty

(14) Dario Dongo. Food security, thesis and antithesis of the European Parliament. GIFT (Great Italian Food Trade).

(15) Dario Dongo. The effect derives from pesticides on bees, trees and plants distant from cultivated land. GIFT (Great Italian Food Trade).

(16) Donato Ferrucci, Dario Dongo. Integrated agriculture and use of pesticides, the data do not add up. GIFT (Great Italian Food Trade).

(17) Dario Dongo, Marta Singed. Sustainable use of pesticides, demands for civil society reform. GIFT (Great Italian Food Trade).

Alessandra Mei

Graduated in Law from the University of Bologna, she attended the Master in Food Law at the same University. You participate in the WIISE srl benefit team by dedicating yourself to European and international research and innovation projects.

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