1. PEST Committee hearing, 6 September Stakeholders' recommendations on the current EU regulation on the approval of plant protection products Franziska Achterberg, Greenpeace

2. Three issues Lack of independent and transparent EU risk assessment
Lack of EU wide action on dangers for the environment
Abuse of emergency authorisations

3. (1) Lack of independent and transparent risk assessment
“The rapporteur Member State shall make an independent, objective and transparent assessment in the light of current scientific and technical knowledge.“ Reg. (EC) No 1107/2009, Article 11.2

4. (1) Lack of independent and transparent risk assessment
Use of unpublished industry studies without independent evaluation of the data
Copy-paste of industry evaluation of published literature studies

5. (2) Lack of EU wide measures
“In order to achieve the same level of protection in all Member States, the decision on acceptability or non- acceptability of such substances should be taken at Community level on the basis of harmonised criteria.”
Reg. (EC) No 1107/2009, Recital 10

6. (2) Lack of EU wide measures
Long-term risk to non-target vertebrates identified by EFSA ...

7. (2) Lack of EU wide measures
... and passed on to EU Member States to deal with.
“… the risk assessment concluded for at least one of the representative uses that the risk was expected to be low.” (Commission response to the PEST Committee)
“Member States shall pay particular attention to (...)
— the risk to terrestrial vertebrates and non-target terrestrial plants.” (EU renewal of glyphosate)

8. (3) Abuse of emergeny authorisations
“(…) in special circumstances a Member State may authorise, for a period not exceeding 120 days, the placing on the market of plant protection products, for limited and controlled use, where such a measure appears necessary because of a danger which cannot be contained by any other reasonable means.”
Reg. (EC) No 1107/2009, Article 53 on Emergency Situations in Plant Protection

9. (3) Abuse of emergeny authorisations
Romania has “systematically issued 120 day emergency authorisations” for
neonicotinoid products each year since 2013.
(PAN Europe et al, 2017)
Use of clothianidin, imidacloprid or thiamethoxam to control Agriotes spp in maize and sunflower is “scientifically supported“.
(EFSA Technical Report, June 2018)

10. Recommendations
The RMS and EFSA should perform a truly independent evaluation and cannot rely on the industry’s interpretation of the data. All studies underpinning scientific evaluations should be publicly available.
The Commission, supported by EU MS, should consistently restrict or ban pesticides which can pose a danger to people or the environment.
EU MS should apply Article 53 on “emergency authorisations” as intended, and the Commission remind them of their obligations.