Table of contents

1. Introduction: Political and legal context

2. Problem definition

3. Why should the EU act?

4. Objectives: What is to be achieved?

5. What are the available policy options?

6. What are the impacts of the policy options?

7. How do the options compare?

8. Preferred option

9. How will actual impacts be monitored and evaluated?

Annex 1: Procedural information

Annex 2: Stakeholder consultation

Annex 3: Who is affected and how?

Annex 4: Analytical methods

Annex 5: Relevant background analysis and other relevant policy initiatives of the commission

Annex 6: Marketing authorisation of active substances

Annex 7: Detailed overview of policy measures subject to impact assessment

Glossary

1. Introduction: Political and legal context

1.1. Overall context

The European Green Deal I  announced that all EU policies should contribute to preserving and restoring Europe’s natural capital II , and that the Farm to Fork Strategy III  would reduce the environmental and climate footprint of the EU food system and lead a global transition to competitive sustainability of the food production system. Biodiversity IV loss and ecosystem collapse are one of the biggest threats facing humanity in the next decades. The world lost an estimated €3.5-18.5 trillion per year in ecosystem services 1 from 1997 to 2011 owing to land-cover change V , and an estimated €5.5-10.5 trillion per year from land degradation 2 . Biodiversity is crucial for safeguarding EU and global food security, underpins healthy and nutritious diets and improves rural livelihoods and agricultural productivity VI . Biodiversity loss threatens food systems, putting food security and nutrition at risk 3 . The long-term trends observe a major decline in biodiversity in Europe. Agricultural intensification, intensive forest management and land abandonment or urban sprawl 4 lead to a loss, fragmentation and degradation of natural and semi-natural ecosystems. In a recent survey 65% of EU citizens identified the destruction of natural habitats or the loss of animals or plant species as an immediate and urgent problem for rural areas. 5

Environmental (e.g. pollinator decline, biodiversity loss) and health (potential exposure to pesticides) problems identified at the time of adopting the Sustainable Use of Pesticides Directive (SUD) VII  in 2009 have remained unchanged or even been aggravated VIII . The SUD aimed to address these problems, by promoting a more sustainable use of pesticides in Europe. While pesticides are often considered a quick, easy, and inexpensive solution for controlling weeds and pests in both rural and urban landscapes, pesticide use comes at a significant cost. Pesticides have contaminated many parts of the environment with residues found in soil and air, in surface and ground water IX . The use of pesticides is a matter of strong concern for society and among European citizens X XI . A 2017 European Citizens Initiative 6  with more than one million signatures called on the Commission to propose to Member States a ban on glyphosate (a herbicide XII ), to reform the pesticide approval procedure, and to set EU-wide mandatory reduction targets for pesticide use. While there will be cases where resort to the use of pesticides is necessary, EU policies are directed at protecting human and animal health, protecting the environment and ensuring a sustainable use of pesticides if they are needed XIII . The foresight study XIV  accompanying this impact assessment highlighted the complex landscape surrounding pesticide use and confirmed the diverse and polarised views among stakeholders on this topic. The European Citizens Initiative “Save Bees and Farmers” XV 7 calls on the Commission and European Parliament to act for the use of synthetic XVI  pesticides to be gradually reduced by 80% in EU agriculture by 2030 and completely phased out by 2035. Not using any pesticides, such as fungicides 8 , can jeopardise plant health and human health due to the development and effects of plant toxins and mycotoxins 9 . However, numerous experiences XVII show that it is possible to phase out chemical pesticides, or to reduce very considerably their use, without negative impacts on the economy. Moreover, a large amount of additional research is ongoing to find alternatives to chemical pesticides, which will facilitate the switch to non-chemical alternatives, and new legislation, announced under the Farm to Fork Action Plan, is also being produced to make the authorisation procedure for these products easier. In organic farming systems pesticide input can be reduced by 97% and enhanced soil fertility and higher biodiversity may render these systems less dependent on external inputs XVIII . The European Commission target to have at least 25% of the EU’s agricultural land under organic farming and a significant increase in organic aquaculture by 2030 XIX  is relevant in this context. 

The European Green Deal announced the aim of reducing the use and risk of chemical pesticides in general, and the use of more hazardous pesticides in particular. In the Farm to Fork Strategy XX , Biodiversity Strategy XXI , the Zero Pollution XXII Action Plan, and the Soil Strategy XXIII  the Commission committed to take action to reduce by 50% the overall use of and risk from chemical pesticides by 2030 and reduce by 50% the use of more hazardous pesticides by 2030. The Biodiversity Strategy aims to protect nature and reverse the degradation of ecosystems. Biodiversity is suffering from inputs of nutrients, chemical pesticides, pharmaceuticals, hazardous chemicals, urban and industrial wastewater, and other waste including litter and plastics into the environment and all of these pressures must be reduced. The pesticide reduction targets are also relevant for meeting the objectives of the EU Pollinators initiative XXIV . 

As outlined in the Commission’s Zero Pollution Action Plan for water, air and soil, pollution must be better prevented, remediated, monitored and reported. The EU Chemicals Strategy XXV  for sustainability is a central element of the EU’s zero pollution ambition. It aims to better protect citizens and the environment and boost innovation for safe and sustainable chemicals as well as better accounting for the cocktail and combined effect of chemicals when assessing their risks 10 . Council conclusions on the Farm to Fork Strategy XXVI  called for the prudent and responsible use of pesticides. A European Parliament Resolution XXVII of February 2019 stated that the EU “must act without delay to transition to a more sustainable use of pesticides” and called on the Commission to propose an ambitious EU-wide binding target for the reduction of pesticide use. The European Parliament re-affirmed its call for binding reduction targets in its resolution of 20 October 2021 on a Farm to Fork Strategy for a fair, healthy and environmentally-friendly food system XXVIII .

The foresight study accompanying this impact assessment explored possible future scenarios on the use of pesticides considered to represent plausible scenarios. Key insights included that policy strategies need to be equipped with adequate incentives as well as implementation and monitoring strategies. Pesticide use needs to be managed in the longer term, considering innovation, public understanding and consumer demands. Regulations should support a level playing field for farmers across the EU aiming to build a consensus among stakeholders concerning the use of pesticides in the future.

1.2. Specific context

Plant protection products are pesticides that are used to protect crops against pests, diseases, or competing plants with the aim of optimising food production in conventional or organic farming XXIX . Pesticides are also used to maintain food quality (e.g. during storage) or to maintain certain areas in the condition needed for their proper functioning (e.g. railways, golf courses). Pesticides can be of chemical or non-chemical origin (e.g. micro-organisms) and their residues in food and feed can be harmful to consumers.

Sales and use of pesticides across Europe vary greatly depending on the type and level of agriculture, with France, Germany, Italy and Spain being the highest users with 68% of the total EU sales market for pesticides. A breakdown of pesticide sales by Member State is presented in Annex 5 (Table 21). The European crop protection market is also highly consolidated, with the major companies accounting for more than 50% of the market share XXX . It is estimated to have an annual growth rate of 4.1% during a forecast period of 2021-2026 XXXI . Industry is expecting a higher demand for biopesticides due to an increasing demand for organic and sustainable foods. The market in biocontrol agents is growing rapidly. Between 2016 and 2019 the EU market for macroorganisms increased by 70%, for microbials by 228% and other substances 3-400% XXXII . Between 2020 and 2025 an annual growth rate of 11.3% is predicted XXXIII  and between 2011 and 2017 this category represented around 50% of new applications for approvals of active substances received by the European Commission (see also Annex 5, Figures 16-18). Evidence is accumulating that in many cases such alternative products can effectively substitute the use of chemical pesticides. Data from Spain XXXIV show that the use of chemical pesticides in vegetable production in Almeria has been reduced by approximately 55% and that over 80% of crops grown in winter now depend on biological control to solve pest problems Almeria has more than 30,000 hectares of vegetable production and since 2005, the area of crops using biological methods against pests has increased from around 120 ha to 26,500 ha in 2021.

Due to their potentially harmful effects, plant protection products are strictly regulated in the EU to provide a high level of protection to the environment and to the health of everyone in the EU. The SUD forms together with legislation on pesticide authorisation XXXV , residues XXXVI  and statistics XXXVII a framework which is considered to be amongst the most stringent systems in the world XXXVIII .

Pesticide authorisation

Pesticides are authorised in a two-step system that reflects the principle of subsidiarity (see Annex 6). In the first step, the active substance of a pesticide is approved at EU level, provided it is demonstrated that at least one use with a formulated product is safe. In the second step, Member States authorise plant protection products containing the active substance for specific uses, according to specific standards (the so-called uniform principles XXXIX ) and good agricultural practices (GAP). The Member States consider local agricultural and geographical/climatic differences when authorising PPPs.

Pesticide use

The SUD provides the framework rules on the use of pesticides. It aims to reduce the risks and impacts of pesticide use on human health and the environment. It also aims to promote the use of integrated pest management (IPM) and alternative approaches or techniques, such as non-chemical alternatives to pesticides. The use of pesticides at farm level should be recorded in line with Article 67 of Regulation (EC) No 1107/2009 XL .

The application of IPM is a legal requirement under the current SUD but is not systematically recorded nor required to be recorded in most Member States. The level of official controls on pesticide use in Member States is limited. Even though the use of pesticides is legally required to be recorded at farm level, these data are not systematically collected or analysed leading to the lack of available comparable data on the use of specific plant protection products (e.g. how, when, where, why they are used, and the exact products used).

Pesticide statistics

Statistics on the placing on the market of pesticides based on data collected at Member State level are transmitted to ESTAT which validates those data and produces annual statistics on pesticide sales, and every five years on pesticide use, in agriculture in accordance with Regulation (EC) 1185/2009 XLI . In February 2021 the Commission adopted a proposal for a Regulation on statistics on agricultural inputs and outputs (SAIO) of the agricultural sector to inter alia replace the existing Regulation (EC) 1185/2009 . The proposal is pending adoption by the legislators. The main changes, if compared to Regulation (EC) No 1185/2009, are the annual collection of the data on pesticide use in agriculture and removal of the obligatory aggregation of active substances into major groups, categories of products and chemical classes before publication. SAIO would allow the Commission to publish data on the sale and use of pesticides, at the level of individual active substances provided that regular statistical confidentialty allows this.

Consequently, the Commission would have accurate data on:

•Annual sales of pesticides, broken down by active substance,

•Annual use of pesticides in agriculture, broken down by active substance.

Pesticide residues

Finally, the Regulation on pesticide residues regulates the residues that are left on crops. It does this by setting maximum residue levels (MRLs) at EU level to protect all consumers, including vulnerable groups. MRLs apply to all products placed on the EU market, including imports.

Pesticide enforcement and control

Member States enforce compliance with the legislation in line with the Official Controls Regulation XLII . Illegal import and use of EU-banned pesticides from abroad and residues of EU-banned pesticides in imported foodstuffs are addressed via the legislation on pesticide authorisation and legislation on residues. The European Commission performs audits in Member States to check implementation and national control systems 11 .

Specific requirements of SUD

The SUD XLIII  sets out requirements to reduce the use and risks of pesticides, introducing specific provisions such as:

·Establishment of Member State national action plans (NAPs) to set objectives to reduce hazards, risks and dependence on chemical control for plant protection;

·Union-wide principles on IPM, and establishment of necessary conditions for implementation of IPM 12 ;

·Specific measures to protect the aquatic environment from pollution by pesticides and defining areas of significantly reduced or zero pesticide use and to protect sensitive groups;

·Measuring progress in risk reduction through appropriate harmonised indicators;

·Creating a system of training and awareness-raising for distributors and professional users of pesticides;

·Appropriate handling and storage of pesticides and their packaging and remnants;

·Regular inspection of pesticide application equipment (PAE) in order to reduce adverse impacts of pesticides on human health (in particular as regards operator exposure) and the environment during application; 

·Prohibition of aerial spraying of pesticides, with derogations being possible, aiming to limit the risks of adverse impacts on human health and the environment, in particular from spray drift.

·Distributors selling pesticides to non-professional users need to provide general information to such users regarding the risks for human health and the environment of pesticide use.

Domestic use of pesticides by non-professional users is covered by the current SUD.

1.3. SUD’s interaction with other EU policies and instruments

This impact assessment takes place in the context of several parallel strategies at EU level. Concerning coherence, the evaluation accompanying this impact assessment found that the internal and external coherence of the SUD with other EU policies and instruments is generally strong with no major inconsistencies or overlaps. The evaluation found that the objectives of the SUD were, and still are, highly relevant to address the risks posed by pesticide use to the environment and human health. A large number of current or upcoming Commission initiatives link to the objectives of the SUD (see Annex 5 and in particular Table 25).

Common Agricultural Policy (CAP)

The evaluation found that the link between the SUD and the CAP is strong in theory, but weak in practice. Measures under the CAP could incentivise farmers to use pesticides more sustainably but have only been used to a limited extent. Under the new CAP (due to be implemented from 1 January 2023) Member States will set out National Strategic Plans (NSPs) which shall contribute to achieve the ambitions from the Green Deal and the linked strategies on Farm to Fork and Biodiversity. Member States will be able to fund actions in line with the Farm to Fork Strategy pesticide reduction targets, for example, on IPM. Member States can provide financial support to sustainable farming practices 13 . All CAP payments received by the farmer are linked to complying with basic EU legal requirements including the SUD, with 90% of farmers and agricultural area, and thus the majority of professional pesticide users, being covered under the CAP. Non-compliance leads to possible reductions of CAP payments in case of infringement. Eco-schemes of voluntary support to be offered by Member States to farmers will represent 25% of the total CAP direct payments budget. The level of support will be decided by the Member States. Such eco-schemes can be used to better achieve the objectives of the SUD. Financial incentives are also possible with rural development instruments and market measures, e.g. for practices, investments and risk management. The CAP also foresees technical support to farmers through knowledge exchange (e.g. European Innovation Partnerships) and advice (Farm Advisory Services). The Commission aims to facilitate the identification of farming practices which must or may be implemented by farmers to comply with IPM principles. This will also facilitate making the link with the CAP and in particular Good Agricultural and Environmental Condition (GAEC) 8, which provides for farming practices relevant to IPM, such as biodiversity areas. The CAP is implemented by NSPs, which must describe the implementation of GAECs, the support schemes and their baseline.

Environmental and chemicals policy

The SUD interacts with a number of environmental policies and legislative acts, for example planned nature restoration targets 14 , pollinators initiative XLIV  to address the decline of pollinators in the EU and contribute to global conservation efforts, the lists of pollutants and regulatory standards in the Environmental Quality Standards XLV , Groundwater XLVI and Water Framework Directives XLVII . Possible contamination of water by pesticides is also a relevant issue for the planned revision of the Urban Waste Water Treatment Directive XLVIII . Associated objectives are also furthered by EU rules dealing with the health and safety of workers, pesticide users and bystanders, protection of the environment, habitats, birds and water etc. (see Figure 1).

Figure 1. Interaction of the SUD with other EU legislation and policies relevant to plant protection products (under the responsibility of various Commission DGs)

1.4. Link with the UN Sustainable Development Goals

The objectives of reducing the use and risk of pesticides, to protect health 15 and the environment, are relevant to the Commission’s ambition XLIX  to deliver on the UN Sustainable Development Goals 16 (SDGs). With cross-cutting policy areas related to the sustainable use of pesticides, direct links to SDG goals 3 (health and wellbeing), 6 (clean water), 8 (decent work and economic growth), 11 (sustainable cities) 12 (sustainable consumption and production), 14 (life below water) and 15 (life on land) can be demonstrated. At a global level, the Food and Agriculture Organization of the United Nations (FAO) published the first global assessment of biodiversity for food and agriculture in 2019, which stresses the international level of concern for biodiversity loss. FAO also support a vision of sustainable agriculture supported by the IPM approach 17 . 

2. Problem definition

2.1. What are the problems

The evaluation L of the SUD found that the SUD has not achieved its overall objectives to the extent envisaged in the impact assessment accompanying the Commission proposal LI in 2006. Reports from the Commission to the European Parliament and Council in 2017 LII and 2020 LIII  identified significant shortcomings in the implementation, application and enforcement of the SUD in Member States. While the objectives of the SUD were, and still are, highly relevant to address the risks posed by pesticide use to the environment and human health, its relevance is hampered by its uneven implementation and limited effectiveness. A study LIV by the European Parliament Research Service (EPRS) found progress in many Member States but a limited overall achievement of the SUD’s objectives. A recent special report LV  from the European Court of Auditors (ECA) on the sustainable use of plant protection products found that there is limited evidence of risks from the use of pesticides being reduced. The European Green Deal, Farm to Fork Strategy, Biodiversity Strategy and Zero Pollution Action Plan have all acted to highlight and even increase the relevance of the SUD to reduce the impacts of pesticides across air, water and soil that lead to harm to both health and biodiversity. These strategies also highlight the need to transition to a sustainable food system with resulting environmental, health and social benefits, while offering economic gains and ensuring a sustainable livelihood for primary producers. Consumers primarily see ‘sustainable’ as a synonym for environmentally friendly, without genetically modified organisms (GMOs) and pesticides, and produced locally, with some specificities across countries LVI . 

As described in Annex 5, the negative impacts of using chemical pesticides include;

1.Environmental contamination of air LVII , water (including coastal water LVIII ) and soil LIX LX , 

2.Negative impacts on a range of non-target organisms, including in soil and water, with corresponding biodiversity loss.

3.Possible negative health impacts caused by exposure of operators, residents, bystanders and consumers,

Environmental impacts

Water pollution

Pesticides can get into water due to spillages, application at or near watercourses, or through surface runoff or seepage into groundwater. Studies have shown an increase in the toxicity of applied insecticides to aquatic invertebrates LXI (see also Annex 5). Effects can be on watercourses or in groundwater potentially used for human consumption. In European countries, for rivers and lakes, one or more pesticides were detected above their effect threshold at 13 to 30% of all surface water monitoring sites each year between 2013 and 2019 LXII . Exceedances of one or more pesticides were detected between 3 to 7% of groundwater monitoring sites. A study across 101 sites of small lowland streams in Germany revealed that 83% of agricultural streams did not meet pesticide-related ecological targets and that agricultural non-point-source pesticide pollution was the major driver in reducing vulnerable insect populations in aquatic invertebrate communities LXIII . Water industry case studies refer to examples of additional activated carbon filtration and ozonation due to pesticides in drinking water resources costing a water processing company EUR 50 M in the period 2018-2020 LXIV . Another case study LXV  examined the case of a UK water operator which found the pesticide metaldehyde in its treated drinking water and failed to meet the drinking water Directive limit value for the indicated pesticide threshold. Treating the water for metaldehyde would have cost €612.4M, entailing a 21% increase in consumer water bills. As an alternative to treating the water, the company used financial incentives to address the cost barriers to farmers to use an alternative to metaldehyde. This alternative cost €16.6M, 3% of the alternative cost of treating the water. A recent paper LXVI claims that various infrastructural, institutional and behavioural “pesticide lock-ins” hamper more effective actions being taken in this area.

Air pollution

Airborne levels of pesticides are also a concern LXVII . A recent study LXVIII has shown for example that airborne pesticide mixtures are ubiquitous in Germany. Samples were collected in 2019 and analysed for over 500 substances, 109 substances were detected, including 28 that are not authorised for use in Germany. There is evidence that pesticides and their related substances can travel through the air at least in the medium and possibly also in the long range (see further details in Annex 5).

Soil pollution

Soil hosts more than 25% of all biodiversity on the planet LXIX  and is the foundation of the food chains nourishing humanity and above ground biodiversity. An estimated 60 to 70% of soils in the EU are not healthy LXX . Land and soil continue to be subject to severe degradation processes LXXI  mainly due to unsustainable land use and management, overexploitation and emissions of pollutants including pesticides LXXII . Pesticide levels in EU soil samples are significant LXXIII  and of concern.

In a 2015 study LXXIV , the distribution of 76 pesticide residues was evaluated in 317 agricultural topsoil samples from across 11 EU Member States and 6 main cropping systems. Over 80% of the tested soils contained pesticide residues (25% of samples had 1 residue, 58% of samples had mixtures of two or more residues), in a total of 166 different pesticide combinations. Glyphosate and its metabolite AMPA, DDTs (DDT and its metabolites) and the broad-spectrum fungicides boscalid, epoxiconazole and tebuconazole were the compounds most frequently found in soil samples and the compounds found at the highest concentrations. The need for strategies to reduce the load of pesticides on agricultural soils, as well as for systematic pesticide monitoring, is the conclusion of another study LXXV  carried out in 2015 in the Czech Republic, where arable soils were found to frequently contain multiple residues of pesticides at noticeable levels several months following the last possible application. A recent study LXXVI concludes that the occurrence of currently used pesticides in the soil of agricultural regions is alarming in many countries.

Biodiversity

The evaluation of SUD concluded that, while it has contributed to reducing the risks of using pesticides to human health and the environment, there is a continuing trend of a decline in biodiversity. Biodiversity is declining across the EU LXXVII , LXXVIII and chemical pesticides contribute to this biodiversity decline LXXIX . In the EU, a reduction of species, in particular insects and pollinators has been observed LXXX (see also Annex 5). It is estimated that 75% of global food crop types rely on animal pollination and 50% of land in the EU cultivated with crops dependent on pollinators faces a pollination deficit LXXXI   LXXXII . A study LXXXIII on the effects of agricultural intensification on biodiversity carried out in eight European countries concluded that out of the 13 studied components of agricultural intensification, use of pesticides, especially insecticides and fungicides, had the most consistent negative effects on the species diversity of plants, ground beetles and ground-nesting farmland birds, and on the potential for biological pest control. In agricultural areas, there is a negative relationship between pesticide use and pollinator abundance, group richness, and diversity LXXXIV . Certain pesticides not only affect pollinators but ultimately crops that depend on them for pollination. Pesticides were found to affect their productivity, the abundance of floral visitors, and the mass of fruits; seed quantity and quality were significantly lower after treatment with pesticides. Exposure to such pesticides can be lethal or sublethal with chronic detrimental effect on the individual pollinator and the colony. What pesticides do to pollinators not only impacts their health and life span but also their abilities to function and live together due to several impairments resulting ultimately in colony collapse. Biodiversity enables farmers to produce safe, sustainable, nutritious and affordable food, providing them with the income they need to thrive. The ongoing decline in biodiversity and the degradation of ecosystems in the EU in the last ten years, poses threats to food production systems, and ultimately to food security.

Health effects

Pesticides can cause both acute and long-term health impacts. Chemical pesticides can have dermatological, gastrointestinal, neurological, carcinogenic LXXXV , respiratory, reproductive, and endocrine effects. LXXXVI LXXXVII High occupational, accidental, or intentional exposure to pesticides can result in hospitalisation and death. Already in 1990, the World Health Organization (WHO) estimated that about one million cases of unintentional pesticide poisonings occur annually, leading to approximately 20,000 deaths LXXXVIII . Occupational exposure is likely to be the most common source of exposure that results in unintentional acute intoxication. A recent review estimates that about 385 million cases of unintentional acute pesticide poisonings occur annually world-wide including around 11,000 fatalities LXXXIX . As described in Annex 5, there are a number of cases in which chemicals, initially believed to be safe, ultimately proved to be harmful for human health and / or the environment and their use had to be restricted or forbidden XC XCI . As an example, a recent decree in France has now classified prostate cancer after exposure to chlordecone as a professional/occupational disease 18 .

The problem tree

The problem tree (Figure 2) provides the graphical representation of the problem analysis, focussing mainly on the risks from pesticides used in agriculture. The SUD regulates the use of pesticides, while the current monitoring framework does not collect, at EU level, data on the use of pesticides. Therefore, the exact proportion of total pesticide use at EU level within agricultural production, as opposed to other uses, is not known XCII . However, based on stakeholder consultations XCIII , it is assumed that approximately 90% of total pesticide use in the EU is in agriculture, with the rest in other areas such as forestry, urban green areas, sports grounds, and along roads and railways. 

Figure 2. Problem tree

The evaluation of the SUD identified four main problems

1) The SUD does not reflect the ambition of the European Green Deal, Farm to Fork Strategy, Chemicals Strategy and the Zero Pollution Action Plan

The SUD did not include an overall pesticide use and/or risk reduction target. In 2017 the Commission XCIV encouraged Member States to review and improve the quality of their NAPs, by establishing specific and measurable targets and indicators at national level, which they had been required to do in the SUD. These targets would then allow Member States to monitor progress in the implementation of the SUD, and to adjust their strategy where necessary. The Commission’s 2020 report found that only three Member States identified useful targets based on a review of their initial NAPs. It is clear that the SUD does not reflect the strengthened ambitions in the Farm to Fork Strategy to achieve specific pesticide use and risk reduction targets by 2030, as well as to accompany farmers in the transition towards a more sustainable production system. Similarly, it does not do enough to support the long-term objective for a zero pollution ambition for a non-toxic environment. It is therefore unlikely, as confirmed by stakeholder views,, that the ambition of the European Green Deal can be achieved with the current provisions of the SUD XCV . 

2) Monitoring and data availability are limited

Limitations on pesticide use data arise in part from the lack of (1) systematic data transfer between professional pesticide users required to record such use and Member States, and subsequently between Member States and the EU level; (2) harmonisation in the aggregated dataset that would allow an analysis of trends overtime at the EU level. While professional users are required to keep records on pesticide application under the legislation on pesticide authorisation XCVI , these records are not collected in most Member States. Currently pesticide use statistics collected at EU level are based on statistical surveys. Pesticide sales and use statistics available at EU level XCVII  are aggregated by chemical classes, categories of products and major groups and confidentiality and aggregation requirements prevent disaggregating them at EU level to the level of individual active substances. The usefulness of the survey-based pesticide use statistics is limited also by a lack of harmonisation of the reference year and crops for which data are collected XCVIII . The pesticide use statistics are collected only once in a 5-year period. Analysis of the data XCIX  showed that the currently available pesticide statistics are not sufficient to effectively monitor the progress on the sustainable use of pesticides. Improved data related to use is seen as necessary to develop meaningful indicators related to the environmental impact of pesticide use, to facilitate the identification of specific sectors, substances and practices that may need specific measures at Member State and EU level and to enhance monitoring of implementation at both Member State and EU levels.

3) Uneven and incomplete implementation of the SUD provisions in Member States

Deficiencies persist in the implementation of numerous key aspects of the SUD such as national action plans (NAPs), integrated pest management (IPM) and pesticide application equipment (PAE) C . IPM is not implemented comprehensively by most farmers, even though in many cases it offers not only environmental, but also economic advantages. This may be due to a lack of sufficient incentives, training and advice offered to farmers in some Member States CI , or potentially because of a lack of available alternatives in some crop-pest combinations. The Commission’s compliance-monitoring index CII  to quantify progress in the implementation by, and between, Member States revealed a particularly poor implementation of the SUD provisions with regard to IPM enforcement (34 % implementation by 2019), PAE (41 %) and NAPs (53 %). Qualitative assessments from stakeholders pointed to agreement with the Commission assessments of the deficiencies in implementation of the SUD CIII . The conclusions of the EPRS report CIV  concurred with this view. 

Figure 3. Overview of implementation status of the provisions of the SUD

Source: European Commission (2020). COM(2020) 204 final, Annex. Available at: https://ec.europa.eu/food/sites/food/files/plant/docs/pesticides_sud_report-act_2020_annex_en.pdf

This lack of implementation of the SUD was also raised in public feedback CV  on the evaluation roadmap/inception impact assessment and interviews with stakeholders CVI . However, as shown in Figure 12 in Annex 2, cross-targeted surveys illustrate very contrasting views among different stakeholders on the extent to which they consider that different elements of the SUD are currently implemented.

4) New technologies are not sufficiently taken up by pesticide users

Since the adoption of the SUD in 2009, various advances on precision farming techniques offer the potential to better achieve the objectives of the SUD and reduce the use and risk of pesticides. As described in Annex 5, precision farming or precision agriculture refers to agricultural management systems carefully tailoring soil and crop management to fit the different conditions found in each field CVII . Many technologies are now available for assessing and managing the spatial and temporal variability of the physical, biological, and chemical properties of soils. Global positioning systems, geographic information systems, yield monitors, and remote and proximal sensors can be used to identify crop variability possibly linked to pests, while automatic guidance of farm machinery and variable rate pesticide application technologies are used to target application and reduce the amount of inputs, including pesticides. The application of existing technology is seen as having the potential to significantly reduce pesticide usage. A consensus exists among stakeholders that new technologies that could help to reduce the use and risk of pesticides should be promoted CVIII . A recent paper CIX concluded that decision support systems could halve fungicide use, compared to calendar-based strategies, without increasing disease risk. According to pesticide users and industry the SUD acts as an impediment to the use of such new technologies. Stakeholders 19 see a need for promotion of the uptake of technological developments in the area of digitalisation and precision agriculture CX , as this market is expected to grow and provide new ways of detecting and controlling pests. These developments are predicted to assist in the reduced risk and use of pesticides, providing farmers with the tools to prevent and control pests in a more sustainable way. 

2.2. What are the problem drivers?

The continued use of chemical pesticides to control pests is linked to multiple factors, including the well-established effectiveness and ease of use of chemical pesticides versus less hazardous and non-chemical alternatives and the overall economic pressures in the farming sector which may lead to an overreliance on pesticides as a pest control tool. Furthermore, EU farmers are subject to competition from other farmers and crop growers outside the EU who might use pesticides which are not or no longer authorised or used in the EU. While contested by environmental organisations, the prevalent perception among pesticide users appears to be that there is a lack of viable or equally efficient less hazardous and non-chemical alternatives and that chemical pesticides are cheaper and more effective or reliable than alternative methods CXI . This may act as a brake on the ambitions of individual Member States to pursue more strict and ambitious policies on the sustainable use of pesticides, in particular as regards alternative plant protection practices. Farmers consider that they could be exposed to risks of crop damage or pest control failures and associated financial losses if they switched to an alternative control tool which might or might not be as effective as the more hazardous pesticides that they are accustomed to using. There are 33 low-risk active substances approved for use in pesticides, and pesticides containing 23 of these substances are authorised in at least one Member State. The Commission does not currently have data on the total number of pesticides containing low-risk substances authorised in the Member States, the crops on which they are approved for use, or the proportion of pests against which pesticides containing low-risk active substances provide effective control, which is a significant limitation for monitoring implementation and progress. While financial support is available (e.g. through the CAP), there is a perceived absence of financial or other mitigation incentives to promote the sustainable use of pesticides CXII . Public feedback on the evaluation roadmap and inception impact assessment CXIII pointed to serious deficiencies in the implementation of the SUD in some Member States and urged the Commission to introduce stricter rules, for example in the form of a regulation at EU level to increase coherence and have more binding effects on policies in individual Member States. An apparent lack of ambition is illustrated by the delays of numerous Member States to prepare and subsequently review CXIV and update their NAPs CXV and the absence of quantitative targets or objective progress indicators for the reduction of risk in these NAPs CXVI , as required under Article 4 of the SUD. This is exacerbated by the limited human and financial resources allocated by some Member State authorities to implement the SUD nationally CXVII . Member States show differences with respect to the level of cooperation at different governance levels CXVIII , which is a significant issue on a cross-cutting topic such as the sustainable use of pesticides.

Although IPM is seen as a key element in the sustainable use of pesticides, and many local examples of good practice can be seen CXIX , the assessment of the actual implementation of IPM through Member State controls and corresponding enforcement has been weak CXX . This results in limited evidence on the effective implementation of IPM across the EU. A number of drivers could be contributing to this, for example a need for more incentives, training and advice to pesticide users on how to successfully and effectively apply IPM, a lack of clear tools to monitor the implementation and enforcement of IPM, a view among mainly pesticide users and industry stakeholders that pesticides on the market are safe and effective and that no specific actions are required to reduce their use and/or that no equally effective alternatives to chemical pesticides exist, or a wish not to disadvantage pesticide users in an individual Member State compared to other Member States or non-EU countries which have potentially less restrictive policies on pesticide use. One of the reasons cited by Member States for a poor implementation of IPM is that they have not converted the IPM general principles into prescriptive and assessable criteria to be applied by users. It should be noted that pesticide user respondents to the public consultation CXXI  stated that, following participation to a training course, their knowledge improved considerably. Additional training could therefore also be a viable tool to improve the implementation of IPM by pesticide users.

Many of the problems which were identified with the SUD are also impacted by other pieces of EU legislation. For many stakeholders, especially researchers, the seed industry and farmers, the choice of crop varieties is important, including conventional selection, but New Genomic Techniques (NGTs) are also perceived by some farmers and industry as potential tools to create new crop varieties relatively quickly that would be resistant to certain pests. However, the development of such technologies is equally opposed by others including farmers, civil society and environmental NGOs. Stakeholders such as pesticide users and the pesticide industry consider that the SUD generally acts as a barrier to the use of new technologies such as precision farming and more targeted application of pesticides as part of precision agriculture (e.g. using drones, as they are considered to fall under the current general prohibition of aerial spraying under the SUD unless derogations are issued at a Member State level) CXXII .

2.3. How will the problem evolve?

Most of the environmental and health issues identified at the time of adopting the SUD have remained unchanged or even been aggravated. A stronger awareness among consumers and society at large may act as a driver for change, although these aspects vary considerably among Member States CXXIII . Increasing concerns about the negative consequences of hazardous chemicals on the environment and health, and an awareness of chemical residues in food have increased the demand for products with higher environmental and health standards CXXIV . Future food production in the EU will be influenced by climate change, extreme weather events and altering pest pressures CXXV ., which in turn may influence pesticide risks and use, and the SUD will likely only be moderately relevant to address such future issues and needs

Without an improved monitoring framework, supported by appropriate and timely data availability, it will be difficult to assess the effectiveness of policies to reduce the use and risk of pesticides (and adapt planned actions accordingly). Moreover, the objectives of better protecting health and the environment from the risks of pesticide use and meeting the specific pesticide targets included in the Farm to Fork and Biodiversity Strategies and the Zero Pollution Action Plan will likely not be achieved in the absence of any changes to the current policy framework. If the SUD was left unchanged, the current differences between Member States would be expected to remain or intensify, driven by such factors as political will and governance, market drivers, uneven effects from climate change and public opinion/consumer attitudes. These are expected to continue to differ between Member States leading to varying levels of pesticide use and risk, different levels of protection of human health and the environment and uneven competition on the internal market. As the situation currently stands, following 10 years since the deadline given to Member States for transposing the SUD, there is no indication that the identified problems would not persist in case of a “no-change” policy decision CXXVI .

3. Why should the EU act?

3.1. Legal basis

The legal basis for action in this area is Article 192(1) of the Treaty on the Functioning of the European Union (TFEU), which empowers the European Union to take action in order to preserve, protect and improve the quality of the environment and to protect human health. EU action in this area is justified by the environmental, public health and Single Market issues at stake. If some Member States do not take action to reduce the use and risk of pesticides, this could negatively affect biodiversity, water and soil quality and human health in the whole EU. In addition, different rules on pesticide use across Member States might create unfair competition and undermine the proper functioning of the Single Market for food commodities, while recognising that Article 193 of the TFEU allows Member States to adopt more stringent provisions than the SUD. The variation in efforts across Member States to achieve the sustainable use of pesticides in practice underlines a need for more coordinated and uniform measures at EU level to drive progress in this area and respond to long-standing societal concerns concerning the use of pesticides.

3.2. Subsidiarity: Necessity of EU action

The SUD established a framework to achieve a sustainable use of pesticides by reducing the risks and impacts of pesticide use on human health and the environment and improving the uptake of IPM. A continued divergence of measures taken in Member States would lead to different levels of protection of health and environment and diverging conditions for the main users of pesticides which would be against one of the fundamental objectives of the Treaties CXXVII . The threat to biodiversity and ecosystems crosses boundaries and necessitates a strong and EU-level action. A level playing field across the internal market, for example for pesticide users, is hampered by current varying levels of action in different Member States to reduce the risks for health and the environment linked to pesticide use. Moreover, pesticides pollution is transboundary and affects waters and the marine environment downstream in one Member State whilst the pesticide use may have taken place upstream in another Member State. Stakeholders’ views differ, but tend to call overall for a stronger EU action on the sustainable use of pesticides CXXVIII . Several Member State authorities point out that the effectiveness of a subsidiarity approach depends on the national transposition and implementation, which can differ substantially between Member States CXXIX . This variation means that the potential for harmonisation of rules is not fully realised and varying competitiveness in the single market continue to exist. The deficiencies in implementing the SUD in some Member States suggest that the previous approach of leaving the detailed rules to national transposition under a Directive has not worked. For example, the European Court of Auditors found a need for clearer criteria and more specific requirements in relation to IPM to help ensure enforcement and assess compliance CXXX . With so many complex agricultural variables in pest management, clear, uniform rules should reduce the compliance burden and improve enforcement. 

3.3. Subsidiarity: Added value of EU action

Coordinated EU action can effectively supplement and reinforce national and local actions on the sustainable use of pesticides. Coordination of action at EU level and, where possible, at global level, can contribute to achieving the relevant UN SDGs. EU action is compatible with the principle of subsidiarity. Consequences of more effective policies in this area could ultimately lead to improvements in biodiversity, water and soil quality, other environmental parameters and human health. Moreover, because of the cross-border and transboundary dimension of pollution, coordinated actions between upstream and downstream Member States are needed. The EU also possesses other key instruments in agricultural and food policies with which synergies exist and can be further improved, including by increasing legal and policy clarity and coherence, especially the CAP CXXXI . Linked to incentives and possible mitigation measures, it is expected that stronger action at EU level, including in association with related policies such as the CAP, can help to reduce currently varying national approaches and contribute to a more homogenous approach in the future. Other initiatives foreseen under the Farm to Fork Strategy are complementary, for example the organic farming action plan, research and innovation policies and planned Commission implementing acts revising the data requirements and assessment rules for pesticides containing active substances that are micro-organisms (as alternatives to chemical pesticides), specifying the approval criteria applying to them and updating uniform principles to assess and authorise plant protection products containing micro-organisms. These initiatives aim at facilitating the placing on the market of these products and increasing their availability to farmers (see Annex 5, Table 25 for further details of these initiatives).

Several stakeholders in various consultations expressed the view that the legal instrument of a Regulation rather than the current Directive might contribute to a more harmonised and binding approach in this policy area in the future CXXXII . The reduction of current national differences in pesticide use policies could contribute to a better functioning of the internal market and a reduction of competitiveness differences which are exacerbated by pesticide use policies varying at Member State levels. The SUD is also relevant to the development of organic farming and achieving the Farm to Fork Strategy target of at least 25% of the EU’s agricultural land under organic farming by 2030

4. Objectives: What is to be achieved?

In May 2020 the Farm to Fork Strategy and Biodiversity Strategy announced that the Commission will take action to reduce by 50% the overall use of and risk from chemical pesticides by 2030 and reduce by 50% the use of more hazardous pesticides by 2030. This commitment was re-stated by the Zero Pollution Action Plan in May 2021. The planned revision of the SUD announced in the Farm to Fork Strategy intends to make a substantial contribution to achieving these targets and to EU efforts to continue to reduce the use and risk of chemical pesticides as well as addressing the various problems identified as part of the evaluation concerning current policies and the present implementation of the SUD. A revised SUD should also aim to increase availability of alternatives to chemical pesticides and encourage use of these, therefore supporting farmers in the transition towards a more sustainable food production system.

The levels of these targets were chosen to be both technically feasible and economically viable. The planned 50% targets allow substantial progress towards greater environmental and human health protection against the trade-off of increased challenges in political feasibility and economic viability. These challenges can be mitigated by additional actions while still addressing the negative impacts of pesticides on the environment and human health. While comparatively a lower ambition would make the targets more politically feasible with Member States and indeed be likely achieved as part of the baseline scenario without additional policy measures, they would likely fail to protect the environment and human health in a meaningful way. It is nevertheless acknowledged that, due to limitations in the quantity and quality of pesticide use and risk data currently available at EU level, the level of ambition of these targets can be objectively criticised as being of either an insufficient CXXXIII or excessive CXXXIV level of ambition. Limitations of available data and modelling and assessment tools CXXXV also make it difficult to comprehensively and holistically assess the impacts that a transition to more sustainable food systems (including reduced use and risk of pesticides) will have on the agricultural sector in particular and overall society more generally. The chosen reference period for the targets of 2015-2017 can also be challenged as regards Member States who may have made specific national progress in reducing the use and risk of pesticides either before, during or after this period CXXXVI . The reference period of 2015-2017 was chosen in order to take account of the most recent data available when the targets were announced in the Farm to Fork Strategy in 2020 and to provide for an average figure over a three year period, recognising the annual variation in pesticide use due to factors such as weather, pest and crop conditions. This is further expanded on in chapter 8 as regards the preferred option.

4.1. General objectives

The SUD contributes to the overall EU goals of preserving, protecting and improving the quality of the environment as well as protecting human health and contributing to the completion and proper functioning of the internal market.

4.2. Specific objectives

In line with the European Green Deal, the Zero Pollution Action Plan CXXXVII  and the Farm to Fork Strategy to ensure a fair, healthy and environmentally-friendly food system, and Biodiversity Strategy for 2030, this policy intervention aims to significantly reduce the use and risk of chemical pesticides. This initiative will address the following specific objectives:

1.ensuring that current and future policies reflect the zero pollution ambition of the European Green Deal, Farm to Fork Strategy, Biodiversity Strategy and the Zero Pollution Action Plan, in particular to reduce the use and risk of chemical pesticides, in particular those containing more hazardous active substances, increase the application and enforcement of IPM and less hazardous and non-chemical alternatives to chemical pesticides for pest control;

2.improving the availability of monitoring data, e.g. on the implementation and application of the SUD, use and risk of pesticides and health and environmental monitoring, to ensure a better framework to implement, monitor and adjust, where appropriate, future policies;

3.improving the implementation, application and enforcement of the provisions of the SUD across all Member States with a view to improving the effectiveness and efficiency of current policies, including possible simplification and reduction of administrative burden where possible;

4.promoting the application of new technologies such as precision farming by pesticide users with the aim of reducing the overall use and risk of pesticides 20 .

5. What are the available policy options?

5.1. What is the baseline from which options are assessed?

The baseline describes the likely development where the SUD remains unchanged and is projected to the year 2030, i.e. the year by which the two pesticide-related Farm to Fork Strategy targets should be achieved. This scenario includes the main drivers that may impact the sustainable use of pesticides until 2030 and beyond. The development will be influenced by other parts of the EU pesticide legislation CXXXVIII , EU legislation on agricultural statistics CXXXIX  and the CAP post-2020 21 . These have been taken into account in the baseline assessment, apart from the Commission’s proposal for a nature restoration law which is not yet adopted.

How will the use of chemical pesticides evolve in a no-change scenario?

The evolution is discussed for each target separately. For the F2F target 1, (first Farm to Fork Strategy pesticide use and risk reduction target to reduce the use and risk of chemical pesticides by 50% by 2030) an extrapolation of the current trendline taking into account the historical data, shows that further reductions can be expected in a no-change scenario, in the range of 1 and 5% 22 per year, at an EU level. As an example of current trends, consumption of pesticides in the Czech Republic is reported to have already declined by 32% in the last 10 years CXL . Figure 4 presents the available data and trend line for F2F target 1 for EU27 CXLI .

Figure 4 Data and trends for F2F target 1 for EU27 from 2011 to 2019

It is expected that Member States will continue to make efforts in line with the current SUD. These efforts include funding research into alternative pest control techniques and funding systems to disseminate these alternative techniques to farmers, such as demonstration farms. The CAP provides a range of incentives to reduce the use of chemical pesticides and these will be reinforced in the new CAP applying from 2023. These measures include area-based payments for participating in voluntary schemes to switch to organic agriculture, devoting a share of farm area to biodiversity and making support schemes conditional to those, to protect water courses, to establish wildlife refuges etc., grants towards the purchase of specialist equipment e.g. precision spraying and mechanical weeding equipment and the Farm Advisory System. This system, which all Member States must establish, helps farmers to meet EU requirements in a range of areas, including the safe use of pesticides and IPM. The development of cultivars resistant to pests, disease and environmental variations would also reduce need for pesticide use, and the possible use of NGTs could expand this potential. The share of improved, lower-risk plant protection products is anticipated to increase gradually in the baseline scenario thanks to investments in research and development to meet productivity gains and environmental standards and amendments to rules supporting their approval-authorisation before their placing on the market. Switching to organic agriculture and devoting area to biodiversity will reduce the use of pesticides in these areas. Some precision farming techniques continue, and will continue, to be adopted by an increasing number of farmers each year. Advances in the uptake of additional precision agriculture techniques will continue to contribute to reducing the use and risk of pesticides. These measures, while perhaps not leading to sudden or dramatically large changes in pesticide use, such as when existing substances are not re-approved, are cumulative over time and help users to transition away from chemical pesticide use. Finally, it is expected that under Regulation (EC) No 1107/2009 CXLII  some substances classified as candidates for substitution 23  will not be (re)approved and may be replaced by low risk alternatives.

Figure 5. Estimated trends in the F2F target 1

The baseline annual level of reduction is considered to be attributed to, and mainly driven by, some substances losing their approval and therefore no longer being sold/used and an expanded portfolio of, and hence increased sales/use of, low-risk substances and products. For the F2F target 1 it is expected that the positive reduction trend at the EU level would continue. Still, at a medium reduction rate of 3% per year, this would leave a “gap” of 12 index points, towards reaching by 2030 the 50% reduction target expressed in the Farm to Fork strategy.

The F2F target 2 (second Farm to Fork Strategy pesticide use and risk reduction target to reduce the use of the most hazardous pesticides by 50% by 2030) will be influenced by the same mechanisms, actions and initiatives as the F2F target 1. The sales and use of these substances were broadly stable in the 2011-2018 period. Under the ongoing renewal programme, some substances classified as candidates for substitution 24  will not be (re)approved and will thus not be available for use. The impact of this process first manifested itself in the reduced use of these pesticides in 2019, and it is likely to result in further declines in the sale and use of these products over time. Consequently, pesticide users will be forced to shift to alternative substances or methods. While in the short term, some professional users may switch to another candidate for substitution product rather than a low-risk alternative, the diminishing pool of these substances (due to further non-renewals) should lead to the continuation of the trend starting from 2019 of a steady reduction in the use of more hazardous substances over time. Substitution rate until now was based on “easy wins” leading to a decline rate of 5% between 2015-2017. This process is expected to slow down as further substitutions will be more difficult to achieve and is expected to be between 2 and 3% annually.

The efforts made by Member States to restrict use of more hazardous substances (for example restricted to only professional use and/or banning of their use in public areas) will likely continue, leading to further reduction. Based on current and historic trendlines, it can be expected that use of more hazardous substances would reduce by between 0.05 and 2% 25 per year until 2030. As illustrated by the estimation, the F2F target 2 of reducing the use of more hazardous substances by 50% in 2030 will likely not be met in a no-change scenario. Only limited progress can be expected towards this target if the situation remains unchanged, and thus an accelerated reduction in F2F target 2 is needed.

Figure 6. Estimated trends in the F2F target 2

The gains manifested at EU level towards reaching the F2F target 1 in the baseline scenario, would risk being offset by a continued high variation at Member State level. As shown in the evaluation of the current SUD, the ambition and progress on reducing the risk of pesticides use varies strongly between Member States. The available evidence on trends illustrates the uneven progress in Member States up to the present day which would likely continue in a no-change scenario. This could impede the even playing field for professional users, and in particular farmers, if some Member States restrict access to pesticides (in particular more hazardous pesticides), thereby leading to a situation where farmers compete on the internal market under different conditions (costs of production, risk of yield losses). The magnitude of these impacts is not possible to quantify.

How will environmental, economic and social/health impacts of pesticide use evolve in a no-change scenario?

In a no change scenario it is expected that environmental status and eco-system services will further decline. While the current negative trends are not solely attributable to use of pesticides for plant protection, it is one of the environmental pressures contributing to a decline in biodiversity, soil quality, pollinators, and water quality CXLIII . The baseline scenario estimates that the use of more hazardous substances will decrease at a slower rate than the uptake of low-risk substances, thereby posing a continued risk to the environment.

Use of pesticides is also an enabler of intensive mono-culture practices which further limits habitats and opportunities for nature to flourish. While a (quantified) causal link cannot be established between pesticide use and deteriorating environmental status, intensive farming prioritises food (and biofuel) production over environmental considerations. Intensification of agriculture has a range of negative consequences for the health and quality of natural ecosystems. Partly, this arises from the use of intensive inputs such as pesticides and chemical fertilisers, and partly it is a function of the prevalence of ‘monocultural landscapes’ in which there is little opportunity for nature. In turn, the loss of biodiversity leads to a need to intensify agriculture further CXLIV , as natural predators decline. The planned nature restoration law may address these issues through mandatory targets for nature restoration, however the legislative proposal has not yet been adopted and therefore its potential impacts are not estimated or quantified here.

The economic impact in terms of agricultural income in the baseline is uncertain, with variable decrease percentages by crop category anticipated in the various policy reviews and impact assessments. According to the latest EU Agricultural Market Outlook (EC, 2021) CXLV , total farm income at constant (2010) prices is projected to decrease by 1.2% per year during the period 2021-2031, compared to the previous decade. Overall use of chemical pesticide is expected to decrease in the baseline scenario, which could lead to input savings, however these may be offset by the need to invest in IPM and alternative methods, including precision agriculture. The economic impact of the (continued) decline in eco-systems services and biodiversity is not possible to quantify but would be very high if the lack of progress to reverse the development leads to system collapse. In this respect the continued use of more hazardous substances, classified as Persistent, Bioaccumulative and Toxic (PBT) is likely to pose higher risks than more low risk chemical pesticides in the long term. Other uncertainties in the baseline relate to climate change and the impact of adverse weather events on food production.

In the no-change scenario health impacts are difficult to assess precisely and with certainty. Harmful effects on human health from pesticides have been established, such as acute and chronic poisoning, links to certain types of cancer and Parkinson’s disease. However, across these identified diseases, evidence from academic studies CXLVI  and EFSA annual reports conclude that it is difficult to categorically link specific pesticides with increased risk to human health. Currently available data from meta-analysis by Inserm (2021) points to greater links between risk of diseases and the use of herbicides and insecticides compared to other categories. Among the 57 active substances that are currently classified as candidates for substitution there are 8 substances that are identified on human health grounds, based on their carcinogenic, repro-toxic and endocrine disrupting properties, 10 substances are identified based on their low acceptable daily intake (ADI) and 38 substances are identified based on the PBT criteria (4 active substances are classified as candidates of substitution on several of the criteria). Due to limits in the current state of knowledge, it is not possible to estimate the impact on human health of a no-change scenario where the use of the candidates for substitution remains on the current trend-line (see Annex 5), but it is apparent that there would be no improvement over the current situation.

5.2. The pesticide reduction targets

As described in the Farm to Fork Strategy, the EU Biodiversity Strategy and the Zero Pollution Action Plan, the European Commission announced two pesticide reduction targets:

·Target 1: to reduce by 50% the use and risk of chemical pesticides by 2030

·Target 2: to reduce by 50% the use of more hazardous pesticides by 2030

An important issue to be considered is whether the setting of targets of a lower or higher ambition than 50% would be appropriate. Currently, in the absence of pesticide use data at EU level, the F2F target 1 for the use and risk of chemical pesticides is calculated using a modified version of the current harmonised risk indicator 1 (HRI 1) methodology, based on sales of different hazard categories of pesticides (see Annex 4 for a detailed description of the harmonised risk indicators and methodology for their calculation). F2F target 2 was chosen to specifically reduce the use of these more hazardous pesticides, given that their use increased by 9% in the six year period from the 2011-2013 period to 2018, whereas it was expected they would have reduced. 57 of the approximately 450 active substances approved for use in the EU, approximately one seventh of active substances, fall into this category and because of their inherent hazard characteristics they are given a high hazard weighting of 16. Achieving the second target would correspond to reducing the F2F target 1 by only around 8-10%, according to ESTAT estimates and thus is seen as complementary to F2F target 1, but, given the specific hazard of this group of pesticides, it is considered fully justified to set a separate reduction target for these more hazardous products.

The Commission does not have robust use data on the crops and pests on which these pesticides are used. However, for each of the main product types (herbicides, fungicides and insecticides), there are some active substances that fall into the more hazardous group and some less hazardous, meaning that in some situations the possibility to switch to lower risk alternatives already exists. For some others there are not currently available alternatives and thus the gradual trajectory towards achieving this 50% target for F2F target 2 by 2030 allows time to bring such alternatives to the market.

The Commission intends to monitor the progress in each of the targets annually. This will enable the progress and relationship/articulation between the two targets to be more specifically assessed over time. Along with the new data provided for by the proposed policy options, it will allow for the consideration of setting further and possibly more differentiated targets for different groups of substances (and hazard categories) beyond 2030.

The setting of any EU level targets in the field of the environment involves the trade-off between three interconnected factors: environmental and human health protection, political feasibility and economic viability. This is particularly true for the setting of the Farm to Fork Strategy pesticide targets which operates at the intersection between these three interlinking factors (as demonstrated in figure 7 below). The demonstrated effect of pesticide use on health and the environment necessitates a change in approach and means no-change is not seen as an option. This has to be offset against consideration for actions being proportionate and viable, and for mitigating actions to reduce the economic impact at both a micro (farm) and macro (global) level. The potential negative economic effects of further biodiversity decline must also be considered. Political feasibility has to consider this trade off with additional considerations of context, implementability and enforcement.

Figure 7. Intersection of factors influencing the setting of the farm to fork pesticide targets

To provide further context, the graph below presents the Farm to Fork Strategy first and second pesticide use and risk reduction targets and the estimated decreases based on the baseline.

Figure 8. Farm to Fork 1&2 Indicators and plotted estimated annual decreases in a no-change scenario

As the above diagram shows a 20-30% reduction would be expected to occur with the existing projected reduction rate, without significant changes to the SUD. This can be seen as easily achieved and without significant additional economic cost, thus having little economic impact. It would not have the required positive impact on human health and the environment, thus not achieving the overall policy objective. 

A 40-60% reduction target would represent a medium level of ambition compared to the no-change scenario. Given the current no-change estimates, the baseline assumes that this target would not be met without significant changes in the SUD legislation. A reduction ranking between 40-60% is likely to be challenging yet achievable, requiring in the region of a 10-30% reduction beyond the baseline scenario. It would require additional actions by professional users and Member States and is thus seen as having a positive impact on human health and the environment, and particularly so in the reduction of the more hazardous substances under F2F target 2. Politically, this should allow those Member States with existing ambitions to still achieve these, while allowing those Member States with lower ambitions to improve. Whilst there would be some likely economic impact, this is seen at a level at which support such as the CAP, changes in support through advisors and availability of alternatives would mean the effect is lessened to one which is politically acceptable.

The uptake of precision agriculture and organic farming is also seen to have a quantifiable positive impact with an estimated 20% reduction in pesticide use by 2030 due to these changes if predicted expansion is achieved (see also analysis in Annex 5). Additional factors can also be considered such as changes in consumption patterns, reduction in food waste and increased demand for sustainable foodstuffs that will also mitigate the current foreseen impacts, but these are uncertain and difficult to quantify.

Whilst the impact cannot currently be quantified, the potential for NGT to provide varieties resistant to pests is also considered to offer potential for pesticide use reduction, alongside reducing other agricultural inputs. The JRC supported the European Commission Study in Light of the Court of Justice’s Judgment in Case C-528/16 regarding the Status of New Genomic Techniques under Union Law  CXLVII through reports on the scientific and technological state-of-the-art as well as on current and future market applications of NGTs CXLVIII . In the context of the latter study, a database was compiled to provide a general overview of NGT products under development globally. The database currently has 113 entries of a broad range of crops with an improved pest and disease tolerance. Of these 37 are already in an advanced development stage and at least two have been reviewed by regulatory bodies in other countries. An impact asessement is ongoing to decide on the appropriate regulatory oversight for the concerned plant products, ensuring a high level of protection of human and animal health and the environment.

Taking a higher scenario of 70-80% reduction in pesticide use and risk presents the most ambitious range of reduction, and would require a significant annual decrease in pesticide use and risk. It would have the greatest effect on human health and environmental protection but, as it would require rapid and drastic changes to farming practices before alternatives are available, it is likely to have a greater effect on crop yield, and subsequently the greatest economic cost both for farmers and for the whole economy. It would be politically difficult to accept therefore for Member States. Given the trade-offs between each of the scenarios, the 40-60% target range presents the most balanced and realistic option in working towards increased protection of the environment and human health while balancing the political and economic challenges that would likely occur, within the given timescale. If criteria influencing this rationale, such as developments in IPM uptake supported by CAP and technology, trends in organic farming uptake and development of precision agriculture become clearer and more certain closer to 2030 then consideration should be given to reassessing the targets beyond that timeline.

5.3. Description of the policy options

The policy options considered include a variety of regulatory and non-regulatory approaches of varying levels of ambition. Annex 7 outlines in detail the various policy options which have been subject to impact assessment. These have been classified as being of either least/lowest ambition (Policy option 1), moderate ambition (Policy option 2) or highest/most ambition (Policy option 3) in addressing the identified problems and objectives. Where compatible, the more ambitious policy options build on those of a lower ambition. Pesticide reduction targets of either a lower or higher ambition than those specified in the Farm to Fork Strategy and Biodiversity Strategy have been analysed in section 5.2 above and in Annex 5. Potential costs, benefits and changes in administrative burden for affected stakeholders have been specifically taken into account in the impact assessment CXLIX . 

5.3.1. Specific objective (SO1): Pesticide reduction targets reflected in SUD

The operational objective pursued is to establish a roadmap for reaching by 2030 the F2F targets. In option 1 (least ambitious) the targets would remain non-legally binding, the Commission would monitor progress towards reaching the targets at EU and Member State levels annually, supported by mandatory reporting of corrective measures taken in each Member State in case of underperformance towards reaching the targets. It also includes prohibiting the purchase and use of more hazardous pesticides by non-professional pesticide users, as is already the case in several Member States 26 .

Option 2 (moderately ambitious) would set the 50% reduction targets in legislation as mandatory targets to be achieved at EU level, with Member States setting their own national reduction targets where they can justify a reduction from the 50% target taking into account a formula considering their existing national situation and level of progress in reducing the use and risk of pesticides. There would be a limit on the reduction in ambition permitted and the Commission would make recommendations on any targets not meeting the required ambition and would identify corrective measures to be taken in case of underperformance towards reaching the EU targets with regular monitoring. Once established, these national targets would become legally binding. To reduce the use and risk of pesticides, the use of more hazardous pesticides in sensitive areas such as urban green areas would be prohibited.

Option 3 (most ambitious) would establish the 50% reduction targets as mandatory legally binding targets to be achieved both at EU and Member State levels, with the Commission identifying corrective measures in case of underperformance towards reaching the targets and taking account of the different starting points of Member States. The use of all chemical pesticides would be prohibited in sensitive areas such as urban green areas.

5.3.2. Specific objective (SO2): Monitoring and data are widely available

The operational objectives pursued are to ensure that pesticide use data is sufficient to monitor risks from pesticide use and that knowledge on pesticide use and risk is improved and available data used to the full.

In option 1, Member States would share with the Commission detailed information on existing health and environment monitoring indicators which are already used at a national level concerning the use of and/ or risks from pesticides, with a view to examining if it would be appropriate to apply such indicators at EU level.

In option 2, records of pesticide use already required to be kept by pesticide users under Regulation (EC) 1107/2009 27  would be required to be kept in electronic form 28  and in a more granular format to facilitate the collection and analysis of these data. This information could support the development of future monitoring and risk indicators and allow realistic use and exposure assessments. This would be combined with an obligation for Member States to analyse these pesticide use data and to report annually to the Commission on trends in such data. Building on option 1 and based on the additional data available, the Commission would propose in the future possible new additional harmonised risk indicators concerning pesticide use and risk at EU level. 

Option 3 would be identical to option 2.

5.3.3. Specific objective (SO3): Strong implementation of clearer SUD provisions in Member States

Operational objectives here included to improve technical advisory services to train and advise farmers and other professional pesticide users on IPM practices, promote crop-specific IPM rules, improve the implementation of IPM, strengthen the effectiveness of Member State NAPs and also address identified deficiencies in the current testing of PAE.

Option 1 would require additional training for advisors on IPM, clarification of SUD text on IPM principles including by highlighting the potential role of new practices and technologies, request Member States to develop or approve (including at regional levels) mandatory crop-specific IPM rules covering at least 90% of utilised agricultural area (UAA) nationally. These changes would be reflected in the CAP as regards the better implementation and enforcement of IPM through obligations on, and potential financial incentives for, pesticide users. This could be complemented by the Commission taking action (including through available financial support and/or training) to support the development of any necessary guidelines, standards and promotion of knowledge-sharing for the testing of PAE. The registration of PAE in registers (already implemented in some Member States) could be introduced as a recording, monitoring and enforcement tool 29 and a mandatory training certificate could be required for PAE operators and not just for purchasers of pesticides as under the current SUD. The Commission would also outline clearer specifications concerning expected mandatory content of Member State NAPs, especially as regards steps to progressing towards indicators and targets, with a view to making NAPs more effective tools to achieve the reduced use and risk of pesticides.

Option 2 would require an obligatory independent advisory service to professional pesticide users (decoupled from an economic interest of selling pesticides and PAE) to ensure the promotion of increased use of alternatives to chemical pesticides as they are available 30 . A compulsory electronic IPM record-keeping by professional pesticide users would also be considered, with possible links to the electronic record-keeping of pesticide use data mentioned under SO2. The Commission would take further action to promote the application of best available technologies (BATs) and support the development of any currently missing standards for PAE. The more detailed Commission guidance for Member State NAPs under option 1 would be supplemented by annual reporting to the Commission by Member States on progress in implementing their NAPs, rather than the current requirement of a review of NAPs by Member State competent authorities only every 5 years. Member States would also set their own targets of specific actions such as percentage sales of biocontrol agents, to contribute towards the targets. This would create a direct link between the NAPs and the progress to achieving the targets, and allow greater accountability for Member State actions. Annual reporting would relate to progress towards achieving all national targets and other quantitative data relating to implementation of the revised legislation. An additional element would be an increased emphasis on the existing framework of Member State risk based controls, enforcement and penalties (where relevant), and control systems such as internal audits, making full and detailed use of the various existing mechanisms already offered under the Official Controls Regulation CL  with the aim of improving overall implementation of the SUD in general, and IPM in particular.

Option 3 would be identical to option 2.

5.3.4. Specific objective (SO4): new and more efficient techniques are taken up by pesticide users

Operational objectives under this heading would be to promote the implementation of precision farming and new technologies, including monitoring technologies, big data supporting the decision-making process to apply pesticides only when strictly necessary, such as more targeted pesticide application as part of precision agriculture (e.g. by sensor-assisted sprayers), smart machinery and robotics, pesticide applications in limited areas of fields and ensure that the potential of such technologies to reduce the overall use and risk of pesticides would be properly reflected in the IPM principles currently outlined in the SUD and implemented through the activities foreseen under SO3 regarding IPM (e.g. training, IPM record-keeping).

Option 1 would make these changes to the SUD to emphasise the potentially important role of these technologies to reduce the use and risk of pesticides. The current SUD definition of “aerial spraying” in Article 3 of the SUD would be amended to make clear whether spraying by drones falls under the SUD general prohibition of aerial spraying, given the uncertainty among stakeholders linked to fact that this Article refers in general to “aircraft (plane or helicopter)” and the term drones is not mentioned in the SUD provision currently in force CLI . This would be combined with the Commission, together with Member States, promoting targeted training and advice measures for precision farming to professional pesticide users, promote the use of pest forecasting tools and prediction models which could potentially reduce the overall use and risk of pesticides and continue to support the development of alternative methods to chemical pesticides.

Option 2 would build on option 1 and foresee to amend the SUD to allow more targeted pesticide application as part of precision agriculture within certain parameters, to be defined in a future annex to a legislative EU act based on advances in the underlying scientific data concerning associated pesticide use and risk.

Under option 3 any type of more targeted pesticide application as part of precision agriculture, for example spraying by drones, under certain specifications would be allowed and the Commission would propose additional relevant delegated acts to amend or supplement the legislation, as required, to account for future technological progress.

5.4. Legal instrument

Given the complex variety of factors influencing the sustainable use of pesticides under different national and regional agronomic and climatic conditions, it might be thought that a Directive better satisfies the principle of subsidiarity. However, as confirmed by the evaluation, the approach of leaving detailed rules to national transposition of the SUD has yielded inadequate results in many cases. As more extensively described in the evaluation CLII , audits, fact-finding missions and implementation reports by the Commission, the EPRS study on the implementation of the SUD, and a recent report of the European Court of Auditors on plant protection products all point to weaknesses in the implementation, application and enforcement of the SUD and a failure to sufficiently achieve its overall objective.  The generally looser language of a Directive has been insufficiently precise to ensure an adequate level of compliance. Thus, a Regulation is considered to be a better instrument in order to provide for more binding and uniform rules. 

5.5. Options discarded at an early stage

Policy options considered by the Commission but discarded at an early stage included:

·Colour-coded labelling of pesticides to reflect their hazard profile, e.g. as in a traffic light system (green, amber, red).

Based on consultation with Member State competent authorities and stakeholders, this option was considered to have limited effectiveness potential, as well as being considered difficult to establish objective risk criteria for the categorisation of all pesticides into three simple hazard categories. Feedback received stated that such a colour-coded categorisation could be misleading and that, if it was the objective to reduce or prevent the use of certain pesticides, other more effective tools are available for that purpose.

·Strengthened provisions on the collection and recycling of empty pesticide containers or packaging, in line with objectives of the Circular Economy Action Plan

Feedback from Member State competent authorities and stakeholders was that this issue should be best left to Member States to address nationally and that in many Member States official or industry schemes are already in place and operating quite effectively on this issue.

·Require the testing of new PAE prior to being placed on the market to identify and address any defects before the PAE enters into use, with the objective to better protect health and the environment

The Commission considered that such a provision would be legally incompatible with the provisions of the EU Machinery Directive CLIII (and proposed Regulation CLIV ) that no extra barriers shall be placed to such new PAE being placed on the market. Feedback from Member States and stakeholders indicated that any defects in new PAE occur at quite a low frequency and would be identified subsequently when PAE is subject to a regular routine test in any case.

·Include PAE within the scope of Official Controls Regulation (EU) 2017/625 with the aim to make use of relevant enforcement and reporting tools and potentially improve implementation of SUD provisions related to PAE

Member States specifically opposed and insisted on the exclusion of PAE from the scope of the Official Controls Regulation when it was originally agreed, based on concerns concerning subsidiarity and potential conflict of interest related to control of private sector bodies involved in the testing of PAE in some Member States. The Commission considered that such a policy option could offer the potential to improve controls, enforcement and reporting tools, but consultation with Member State competent authorities demonstrated that the views prevailing at the time of the adoption of the Official Controls Regulation persist. Member States continue to oppose such a provision and therefore it was discarded as a policy option.

·Delete the requirement for Member States to develop SUD NAPs, in an effort to reduce potential administrative burden, especially if these are seen as being not very effective tools in any case and potentially duplicating the obligation on Member States to prepare CAP National Strategic Plans (NSPs)

Member States and stakeholders generally consider that NAPs are not overly burdensome to prepare and update and provide a useful opportunity for relevant stakeholders to input to national policies on the sustainable use of pesticides. Furthermore, not all pesticide use would be captured in CAP NSPs which would only cover the agricultural use of pesticides linked to specific CAP provisions.

·Adapt the taxation of pesticides at EU level, whether through value-added tax (VAT) or excise taxes to discourage the use of all or more hazardous pesticides

Several Member States 31 have introduced specific national taxes on pesticides. Member State competent authorities and pesticide users and industry expressed opposition to such an idea, while environmental NGOs supported it. Given that agreement on taxation at EU level requires unanimity among Member States and is based on a separate Treaty legal base compared to the environmental legal base of the SUD, it was concluded that it would not be legally or practically possible to include this element in a potential revision of the SUD. A proposal to phase out currently applied reduced VAT rates for pesticides has been discussed in Council and agreed in April 2022 CLV (see Table 25 in Annex 5).

·Prescription system for the purchase by professional users of more hazardous pesticides

A national prescription system for pesticides has been introduced in countries such as Hungary, Greece and Switzerland CLVI . However such prescription systems impose high costs and administrative burden both on pesticide users, prescribers and competent authorities and have a generally low efficiency and effectiveness in changing pesticide use and risk patterns CLVII . Introducing a prescription system in each Member State was therefore discarded as a policy option 

6. What are the impacts of the policy options?

This section will discuss and assess the social, environmental and economic impacts of the proposed policy options.

For each type of impact, the assessment discusses who (or what) will be affected and how, what magnitude of effects can be expected and what conditions or mitigating actions may be necessary to offset undue negative effects of the policy options. A transversal assessment across social, economic and environmental impacts needs to consider the inherent tradeoffs of the initiative for different stakeholder groups.

It should be noted that small and medium enterprises (SMEs) would be specifically affected by several potential changes to the SUD. These SMEs would include agricultural advisers, handlers of agricultural produce and pesticides, food processors and intermediaries, agricultural contractors, farmers and other SMEs using pesticides.

6.1. Social impacts

Social impacts include the direct effects from pesticide use on people, including those operators and workers in direct contact with pesticides or pesticide treated areas, bystanders indirectly exposed to them and the public including vulnerable groups, as consumers of food/water containing residues of pesticides. More indirect effects include access to affordable and nutritious food and raw materials as well as access to recreational space and nature and other ecosystem services.

6.1.1. Health impacts

Reductions in the use and risk of chemical pesticides in line with the targets announced in the Farm to Fork Strategy would have a direct impact on the level of exposure to pesticides. It is important to separate the risks to human health for 1) the users of pesticides (professional and non-professional) and 2) citizens living close to areas where pesticides are applied as well as 3) consumers of food products. Reaching both Farm to Fork targets would lead to a reduction in exposure, in particular for professional pesticide users (handling and applying less pesticides) and by-standers (through reduced spray-drift from treatments) CLVIII . There are no clear aggregated data at the EU level on the level of risk related to current exposure, but meta-analysis of academic and scientific literature point to similar and recurring conclusions on the risks and possible impacts and strong presumed links for several exposure–disease combinations  CLIX  (see also Annex 5).

A 2016 review CLX  suggested that the economic costs of pesticide use have been underestimated and that the benefit-cost ratio of pesticide use may have fallen below 1 if the cost of illnesses and deaths triggered and favoured by chronic exposure to pesticides was taken into account. An assessment focussing primarily on the US, estimated the total losses from pesticides use for public health at $1.1 billion per year in the US (2009) CLXI . 

In relation to health impacts from exposure through consumption of food, the current limits on allowed maximum pesticide residues on food are set for single substances CLXII CLXIII  and the current measures to protect human health do not adequately address potential for mixture effects. Studies on consumer risks from the combined exposure to multiple chemicals have been performed focusing on prioritised toxicological effects (neurotoxicity and thyroid mediated toxicity). EFSA has concluded that cumulative dietary exposure is, with various degrees of uncertainty, below the threshold that triggers regulatory action for all population groups CLXIV . Overall, most epidemiological studies point to evidence of presumed links (or statistical associations), but so far regulatory risk assessment approaches, including some on mixtures, point to low risk. This is a significant scientific challenge which makes it difficult to conclude on the causality of observed links (or statistical associations) and the potentially differing conclusions of risk assessment methodologies and epidemiological studies. However, if confirmed as causal relationships, the observed links carry major societal and health costs which support the case for reducing exposure and risk. It has been shown that combinations of chemicals present at even low levels may contribute to the overall risk of adverse health effects such as cancer and reproductive toxicity CLXV and the majority of epidemiological studies point to several statistically significant associations or presumed links.

There are no studies available linking exposure and health effects to specific currently approved substances and it is not feasible to differentiate the impact between the two Farm to Fork Strategy pesticide reduction targets. It could be that achieving the second Farm to Fork Strategy pesticide target on the reduction of more hazardous substances by 50% would yield higher health benefits, but current evidence does not allow for this to be established. More hazardous substances generally have a broader spectrum of action (different types of pests, types of crops), hence replacing a more hazardous substance with low-risk substances may require higher dosages and multiple substances, thus potentially leading to an increase in pesticide use (albeit with lower risk). In the way the Farm to Fork Strategy targets are measured, these aspects would only be captured by the first Farm to Fork Strategy reduction target.

Impacts on human health are considered greater for vulnerable groups, and some specific actions are linked to these. Studies have shown that pesticide residues are present in children’s playgrounds and other public spaces in areas surrounded by intensively managed agriculture, including pesticides that are classified as potential endocrine-active substances, considered to be of particular concern for children (see Annex 5 for further details).

The expected reduction of exposure to pesticides as compared to the baseline will be limited in Option 1 due to the high uncertainty of reaching the 50% reduction targets, in particular for the target on more hazardous substances. Thus, health impacts are not expected to differ substantially from the baseline and affordability of food would likely remain unchanged. It can be expected that the continued decline in biodiversity may influence affordable food and access to nature in a long-term perspective, due to unsustainable practices.

In Option 2 a 50% EU target, to be adapted at Member State level, will likely increase the ambition in national actions compared to the baseline, in particular for the second target on more hazardous pesticides. Under this option the positive impacts on the general public and vulnerable groups such as children are expected to be higher through prohibiting the use of the more hazardous pesticides in urban areas, in particular playgrounds, schoolyards or other recreational areas, including sensitive natural areas.

Option 3 would be expected to have the highest certainty to reach the 50% reduction targets, however the option may lead to adverse effects in terms of higher food prices which could lead to inequalities in access to nutritious and affordable food, affecting more vulnerable groups in society. The positive impacts on the general public and vulnerable groups such as children would be increased by prohibiting the use of all chemical pesticides in urban areas in particular playgrounds, schoolyards or other recreational area, including sensitive natural areas.

6.2. Environmental impact

Environmental impacts include the effect of policy options on biodiversity and in particular impact on pollinators, soil, water and marine species through environmental pollution caused by pesticides. Preventing negative environmental impacts is in line with EU ambitions to restore ecosystems and fully address the biodiversity decline. Reducing the use and risk of pesticides should protect pollinators, soil and water quality in particular. There are challenges to attribute unwanted environmental impacts directly to the use of pesticides because of the interaction of multiple substances and their possible accumulation in organisms which creates a time lag between their use and impact.

All targets and actions in the European Green Deal will need to work together to reverse the expected declines on biodiversity and related ecosystem services CLXVI  (see also Annex 5), in particular, in addition to the SUD, those on pesticides (e.g. removal of more harmful substances from the market through non-renewal of approval, Member States refusing authorisations for products containing candidates for substitution after a comparative assessment, facilitating availability of pesticides containing micro-organisms etc.). The environmental impact of the two pesticide targets, therefore, has to be seen in combination with the existing policy instruments and also other initiatives that will improve soil quality, such as the EU Soil Strategy, considering a range of biological and physico-chemical indicators. Studies CLXVII  have shown that making both pesticide targets legally-binding would reduce an important pressure for biodiversity decline. Even if measures on reducing land use intensity and increasing habitat diversity are just as urgently needed to protect biodiversity, pesticide use reduction would be beneficial for pollinators and other farmland and aquatic species CLXVIII , CLXIX .

Additional environmental benefits can be achieved in relation to reduced risks to water quality through the reduction in use of pesticides. Water industry and environmental NGOs are specifically concerned on the impact on water courses CLXX , both recreational and for drinking, and the potential impact of chemical pesticides on pollinators (see also Annex 5).

Moreover, a stronger role of organic farming and IPM solutions can be expected, strengthening the resilience of ecosystems and agricultural production CLXXI  (see also Annex 5).

In particular the target to reduce by 50% the use of more hazardous pesticides by 2030 would create environmental benefits as it limits the use of substances that are highly toxic, persistent and bioaccumulating 32 , which result in the most important negative impacts on the environment. Additionally, similar to social impacts, mixture effects may cause impacts beyond the characteristics of any specific substance. These impacts are mitigated by the target to reduce the risk and use of all pesticides by 50% by 2030. Therefore, both targets are relevant to realise the environmental impacts.

The ability to quantify the impact of the prescribed options is limited as they are also likely impacted by other policy actions (such as the update of the list of priority substances in surface and groundwaters under the EU Water Framework Directive). The revised SUD will, however, be essential to achieve the environmental quality standards set under the Water Framework Directive which will significantly reduce costs for drinking water treatment (see section 1.1) and protect aquatic ecosystem services. This is in line with the polluter pays and prevention principles which need to be emphasised, linking to the costs of remediation where water treatment (e.g. for drinking water) has to be treated with high costs or when groundwater or surface waters used for drinking water are polluted. Reducing pesticide use, in particular of key insecticides and herbicides is also found to reduce risks to aquatic ecosystems, such as freshwater or marine water ecosystems, and species which are particularly vulnerable to toxic chemicals CLXXII   (see also Annex 5).

Environmental impacts of Option 1 would result mainly from the extent to which the reduction targets are being achieved. The relevant specific measure under SO1 would be to limit the purchase and use of more hazardous substances, which represent only a small change towards achiving the second pesticide target. Therefore, similar considerations as for the health impacts apply on the high uncertainty of reaching the targets. From the specific measures under SO3, training requirements for the use of more hazardous pesticides can be expected to improve conditions of use but also puts a barrier to non-professional use of such products and thus leads to a shift in attitude towards alternative pest and weed control in non-professionally used areas with the resulting effects on the environment. The obligation for all operators to hold a certificate of training, instead of only the purchaser of pesticides, is expected to increase knowledge and better adherence to restrictions with a resulting reduction in risk to the environment. Both environmental NGOs and civil society organisations (18 out of 22) CLXXIII considered this element would be effective to a major/moderate extent in reducing the use and risk of chemical pesticides. This view was also shared by pesticide users and industry (108 out of 151) CLXXIV . This option contains several mechanisms through which the IPM uptake by professional users is expected to increase. Both more clarity on IPM principles and the strengthening of advisory services could remove barriers to the uptake of IPM practices by professional pesticide users. More tailored IPM guidance was viewed as positive by pesticide users and industry (110 out of 151) as well as NGOs and civil society organisations (21 out of 22) considering it would have an impact to a major/moderate extent on reducing the use and risk of pesticides in line with the farm to fork targets. Testing and inspections as specific measures under S04 can ensure that pesticide application equipment are well functioning and have minimal spray drift, thus limiting effects on the environment CLXXV . NGOs, environmental organisations and consumer organisations (14 out 22 organisations) found general agreement that the implementation of this option could help to lead to a reduced use and risk of chemical pesticides to a major/ moderate extent CLXXVI .

Environmental impacts of Option 2 would be related to the additional measures taken to reach the pesticide targets. Further restrictions on the use of more hazardous pesticides would protect sensitive natural areas from the effect of those substances. Possible mixture effects from other pesticides not classified as more hazardous would be reduced to a lower extent.

Among the specific measures under SO3, recording their IPM practices would increase the farmers’ awareness of the IPM principles and in the long term the uptake of IPM because farmers would more easily see the benefits of IPM and evaluate their IPM strategy 33 . Member States were largely of the view that the introduction of electronic IPM record-keeping would help to improve measurability and monitoring of implementation of IPM (11 out 27) CLXXVII . Users and pesticide industry also see the benefits of increased data availability. An independent advisory service is expected to lead to higher quality advice to professional users of pesticides. Environmental impacts from pesticide use recording and collection by Member States are indirect as they would lead to strengthening the evidence base and thus taking better informed decisions ultimately having a positive effect on the environment.

Additionally, specific measures under SO4 create environmental impacts in the long run. Divergent views are held on the environmental effect from using drones for more precise pesticide application. According to an OECD study, the use of drones has the potential to produce benefits for sustainable pesticide use, but these potential benefits cannot be realised without further improving knowledge and data on application of pesticides with drones CLXXVIII . Some respondents to the Commission’s supporting external study survey argued it could lead to a reduction in quantity of pesticide applied through targeted and early or more timely spot treatment of pests, as well as other benefits such as less compacted soil by engines or intervention after severe climatic conditions preventing the use of ground-operating machinery. Other stakeholders argued that it may lead to an increase in spray drift, depending on what type of sprayer the drone replaces and consider the risk of misuse high. Allowing the use of drones without any further specification is expected to lead to negative environmental effects.

Additonal environmental impacts of Option 3, compared to options 1 and 2 would result mainly from the increased obligation to achieve the pesticide targets. Also, banning all chemical pesticides from sensitive areas and therefore also mitigating the mixture effects would see higher impacts than previously described for the other two options. From the specific measures under SO1, a complete ban of chemical pesticides in sensitive areas including urban green areas would amplify the environmental benefits. In the urban context, it would avoid the risk of accidental chemical contamination from pesticides for the public and in particular vulnerable groups such as children. NGO respondents to the targeted survey expect this option to lead to a major reduction in risk 34 , which is largely supported by user respondents 35 . However, three Member State respondents express concerns about the control of invasive species and new pests, if no control substances are available.

For the specific measures under SO3 and SO4, environmental impacts stemming from IPM implementation and improved monitoring would be identical to option 2. Allowing aerial spraying only under defined parameters would only change the environmental impacts once defined conditions are established in a delegated act.

6.3. Economic impact

The quantification of economic impacts is complex and diverse given the breadth and intricacies of agriculture in Europe. This is exemplified in the assessment of implementation of the existing Directive which outlined a wide range of differences between Member States. In order to mitigate against these inherent complexities, a mixed qualitative and quantitative assessment has been carried out, with those policy elements which have potentially direct economic costs (such as administrative costs) being quantitatively assessed as far as possible. Similarly, the baseline is also affected by a large number of drivers (such as the CAP, changes in technology, changes in availability of lower risk pesticides). Many of the problems defined are also affected by a range of different policy actions, many complementary to the SUD, making it challenging to directly attribute the effect of the SUD directly.

6.3.1. Overarching economic impacts

As described in Annex 5, several recent publications have tried to provide estimates of the economic impacts of achieving the Farm to Fork Strategy targets, including the pesticide reduction targets which are within the scope of this Impact Assessment. None of these publications can be considered a fully-fledged impact assessment of the policy, but their results provide some insights into the economic impacts of policy decisions limiting the use of pesticides. The range of impacts reported is large, but in general the impact of reducing pesticide use is that of a reduction in production in the EU with associated reductions in net exports (i.e. higher imports and lower exports). Most of the studies do not consider how the impacts could be readily mitigated by additional actions on the demand side such as food waste reduction or added value chains for sustainable food. Nor do they consider the support actions, such as breeding of resistant cultivars and biopesticides, which can reduce the dependence on plant protection products thus limiting the negative productivity impacts of achieving the pesticide-related targets announced in the Farm to Fork Strategy. Moreover, the simultaneous achievement of different policy targets shows that some of these (e.g. increased land under high-diversity landscape features and organic farming) will contribute to the achievement of the reduction in pesticide use and risk.

As the mentioned studies do not consider positive changes that are likely to occur (even as part of the baseline) to mitigate the economic cost, such as availability of alternatives to chemical pesticides and application of precision farming techniques, they qualify their results as an upper-bound of the expected production impacts of meeting this target on the agricultural sector. The positive effect that support through the CAP can have in reducing the economic impact is in particular demonstrated by the JRC study.

In most cases these studies are limited to economic modelling that do not assess either qualitatively or quantifiably the significant positive environmental impact expected from a more sustainable agriculture. A paper CLXXIX published in January 2022 argues that the narrow focus of the analysis undertaken in such studies is the main driver of the reported reduction in agricultural production in the EU, its deteriorating trade balance and increased prices. However policies such as the Farm to Fork Strategy, encompassing the planned SUD revision initiative associated with this impact assessment, include a much broader set of interventions that are not fully accounted for in these analyses and the tools used have limitations preventing them from capturing the full scope of potential impacts. The afore-mentioned paper concludes that reported impacts from such economic analyses are a higher bound of the potential impact of the input reduction targets, compounded by the limited evidence available on the co-benefits of improved environmental quality the strategies aim to attain. The paper highlights the challenges of comprehensively assessing the impacts that a transition to more sustainable food systems, including reductions in the use and risk of pesticides, will have on the agricultural sector.

Using the methodology of the JRC study it is possible to demonstrate that the economic impact would be significantly less considering the current trend in pesticide reduction forecast as part of the baseline and when considering the contribution that organic farming and improved precision agriculture application can make. Assuming application of existing precision agriculture methods can provide on average a reduction of pesticide use of around 20%, the adoption of precision farming techniques on 35% more land by 2030 (as presumed in the JRC model) would deliver an additional 7% reduction of pesticide use without impacts on yields. An increase of organic farming area to 25%, assuming a cross-section of agriculture, could achieve a further 13% in pesticide reduction. When incorporated into the model this equates to a 6% rather than a 10% yield loss and a significantly lower economic cost to farmers. The interaction and articulation between the two targets should also be considered. A 50% reduction in F2F target 2 is expected to lead to a reduction of approximately 8-10% in F2F target 1, based on assumptions concerning changes in grower practices, and whether the higher risk substances are substituted with less hazardous chemical pesticides or with non pesticide controls.

The target on reducing more hazardous pesticides implemented individually would leave more options on alternatives to users and therefore overall result in lower economic impacts on farms, value chains and trade. However, for some more hazardous pesticides low-risk alternatives are not yet available, which represents economic risks from pests that cannot be controlled without these more hazardous pesticides. Nevertheless, a 50% reduction target would still allow these more hazardous pesticides to be used in many cases under emergency authorisations granted by Member States and where specifically required in the possible absence of effective alternatives.

6.3.2. Specific Economic Impacts

Changes in farm income driven by a reduction in pesticide use and risk are complex and highly dependent on a range of interconnected variables (i.e. crop allocation choices, productive orientation and farm management practices). Moreover, other external drivers such as climatic variability, incidence of pest and diseases, the evolution of oil prices, together with the extent and pace of adoption of IPM and the application of ecological principles in diversified systems, will influence pesticide dependence and the economic performance of farms. As highlighted in a March 2020 opinion of the EU Group of Chief Scientific Advisors, although intensive farming to produce high yields is synergistic with economic competitiveness, leading to low prices, there are relevant trade-offs to be made between overall competitiveness goals and other social and economic considerations, including low environmental sustainability and resilience CLXXX .

Looking at the impact to plant protection products and the plant protection product application value chain, economic operators involved in the distribution and use of pesticides comprise agricultural inputs, machinery and services (e.g. agricultural contractors, extension services and crop marketing). Overall, the EC (2020) 36 projects nominal farm intermediate input costs to increase by 16%, reaching EUR 251 billion in 2030. Following current inflationary pressure, the increase in intermediate costs is expected to slow down, from 1.8% per year in 2011-2021 to 0.7% per year in 2021-2031. The share of improved, lower-risk plant protection products is anticipated to increase in the baseline thanks to continuous investments in R&D to meet productivity gains and environmental standards. The demand for and production of biopesticides is also projected to increase in the baseline. Overall use of pesticides is expected to slow down, thanks to better targeting and improved management through digital technologies, together with the projected increase in organic farming.

For the Agri-Food value chain however, the food supply chain is highly consolidated, characterised by a power imbalance between strong agents operating in concentrated sectors in the downstream stages (i.e. industrial and retailing) and weaker agents in highly disaggregated sectors such as small farmers and consumers. Whilst farmers are more exposed to supply and demand shocks of agricultural products given that both are highly inelastic 37 , increasingly, the impacts of climatic events, environmental disturbances, technological developments and price volatility are not limited to local producers but spread through longer supply chains.

With regards to the impacts on trade, research carried out in this field is often inconclusive, however it points to potential impacts on the trade balance from increased dependency on imports (e.g. cereals, oilseeds) and a decline in exports (e.g. wheat, and specialised crops such as olives and wine) brought about by reduced yields due to a reduction in pesticide use. However other analysis CLXXXI , based on a biomass equilibrium model (and not a market equilibrium model), shows that a food system scenario that is even more ambitious than the Farm to Fork Strategy would enable the EU to move from being a net importer of calories and proteins– which it is today– to being a net exporter, despite a reduction in production. Any changes in food prices could have impacts on food availability and nutrition, with disproportionate effects on developing economies.

Total import of agricultural products in the EU, in physical terms, is greater than that of total export (Eurostat, 2021). Achieving the pesticide targets announced in the Farm to Fork Strategy is anticipated to lead to positive human health and environmental outcomes from a reduced environmental presence of pesticides and lower pesticide exposure for plant protection product users and food consumers. However wider environmental, social and economic trade-offs in the export countries may occur due to possibly resulting changes in production and trade-flows, with developing economies being most at risk of disproportionate effects. On the other hand, a continued reduction in the number of pollinators linked to the use of pesticides could also have a detrimental effect on food security and nutrition. Environmental impacts through land use changes and biodiversity degradation may follow if additional agricultural land is required to compensate for a reduced productivity or to address an increase in EU demand for certain crops.

Potential off-setting and mitigation measures would be needed to counter any undesired negative consequences for such non-EU countries, especially developing countries, while also recognising that such EU policies could support the FAO’s work towards achieving pesticide risk reduction through a sound lifecycle management approach CLXXXII . There is also an ambition to create a bigger market for sustainably produced goods, thus leading to better environmental and health protection in third countries as well as higher returns due to higher prices. With EU support and in collaboration with the UN Environment Programme and the Secretariat of the Organization of African, Caribbean and Pacific States, FAO is working to build capacities to adopt ecosystem-based practices and improve the management of pesticides in agriculture globally CLXXXIII . The Commission offers a range of technical assistance programmes in the sanitary and phytosantitary (SPS) area, recognising that protecting human, animal and plant health is fundamental to any agri-food value chain, but that SPS measures may also have a direct or indirect impact on domestic, regional and international trade. The Commission’s SPS activities aim to ensure that evolving EU SPS measures do not have a negative impact on trade from third countries. Private voluntary standards required by global buyers such as GLOBAL G.A.P. (Good Agricultural Practices) are also evolving and extending to target the environment and sustainable production in a far more comprehensive way, for example including a new module on environmental sustainability including requirements covering biodiversity, ecological upgrading, water management, soil management and conservation, integrated pest management (IPM), and managing pesticides to protect the environment.

6.4. Economic impacts of the proposed policy options

6.4.1. Specific objective 1 (SO1): Pesticide reduction targets reflected in SUD

Baseline: Achievement of the targets under the baseline scenario, primarily driven by the renewal programme for active substances under Regulation No. 1107/2009 and other policies, is not considered probable. Costs for farmers are assumed to be increasing and the decrease in pesticide costs (through reduced purchase and use of pesticides) not sufficiently mitigated by the availability and price of alternatives.

Option 1 will not differ substantially from the baseline. Overall the economic impact on the farmer would be limited. Administrative costs would mainly increase for national and EU authorities stemming from an increased frequency of reporting. Only for Member States that do not have training obligations for the purchase of pesticides containing more hazardous substances would more substantial impacts be expected.

In Option 2, targets would be set within the parameters of a formula. Member States could deviate by set amounts where they have made historical progress prior to the adoption of the Farm to Fork Strategy. They could further deviate where they provide data showing changes in climatic, agronomic and pesticide market conditions compared to when the harmonised risk indicators were first set 38 . To avoid large variations in ambition, there would also be a minimum percentage of reduction for both targets that all Member States would have to achieve regardless of the historical and other factors.

The targets set by Member States would become binding after Member States have had time to consider any Commission recommendations to increase their level of ambition. Member States would report annually on progress towards their achievement and the Commission would publish an analysis every two years, which could include recommendations to the Member State for additional actions.

Tensions among environmental and economic objectives in the EU policy are already one of the drivers of evolution in the EU agricultural sector towards outsourcing of commodity production through trade. EU agriculture has been able to develop its activities on high-value product chains. Achieving the pesticide reduction targets could accelerate such an already existing trend in EU agriculture. Any higher costs for EU producers resulting from the implementation of the targets could erode the competitiveness of EU-farming and the agri-food sector. This has driven calls for the application of the reciprocity principle to agri-food products from third countries, to ensure they have not been treated with pesticides that are not authorised in the EU CLXXXIV . Possible mitigating financial support under the reformed CAP to apply from 2023 could take the form of many actions going beyond conditionality and other relevant obligations, such as longer multiannual crop rotation and diversified crops, payments for investments for pesticides management and localized spraying, payments for training and advice, conversion to organic farming, investments for precision spraying equipment, financing risk management and contributing to advice, cooperation and monitoring systems, etc.

More frequent reporting on data would be considered key to the success of legally binding targets, with annual reporting in an adapted format with national progress reports to the European Commission likely playing an important role in ensuring successful achievement of the targets. It is not possible to foresee how Member States would work to achieve the targets set, since this would likely depend on the national context, capacity, economic situation etc. and thus direct costs cannot be estimated. Additional direct costs for Member States would result from putting in place data collection and regular reporting on progress, a pre-requisite to enable effective monitoring and enforcement. As most Member States prohibit use of more hazardous pesticides in sensitive area, there could be minimal addition cost for the user. Additional administrative costs would be incurred by the Commission in assessing reporting and monitoring progress to the targets but not substantially greater than the baseline.

For Option 3, with uniform legally binding targets at Member State level in addition to policy options under Option 2 the economic costs described above would be repeated and to some extent greater in certain Member States. There would be the clarity of each Member State applying a consistent 50% reduction target based on their individual national starting points with the objective of ensuring that effective actions are taken in each Member State to reduce the use and risk of pesticides in order to protect health and the environment.

Considering prohibition of all chemical pesticides in sensitive areas, the main determining factor for the impacts of this option is the definition of sensitive areas as well as urban green areas. In addition to sensitive natural areas, urban green spaces could include all publicly owned green spaces open to frequent public visit. This could include playgrounds, parks, school yards and urban roadside greenery.

Depending on the actions taken by individual farmers and other pesticide users, such a prohibition on the use of chemical pesticides can lead to higher costs for pest and weed management for the users maintaining or cultivating these areas, the extent of which is highly uncertain, and is mitigated by reduced chemical pesticide expenditure. CLXXXV The ban on use of pesticides in urban public areas mainly affects public bodies in their practices and spending on managing these areas. Six Member States CLXXXVI  report in the Ramboll supporting study targeted survey that they would see no impact as more hazardous substances are not used in parks, sport, school and recreational grounds. The other Member States expect increased costs of pest and weed management by other available means. Several Member States also report that the use of pesticides in public urban areas is minor, resulting in limited costs. A study on a selection of French municipalities CLXXXVII  found that costs for the management of green spaces increase in the first phase of a zero-pesticide management, but fall after adjustments to the management approach have been made.

6.4.2. Specific objective 2 (SO2): Monitoring and data are widely available

Baseline: In the current situation, electronic record-keeping for the collection of data from professional pesticide users regarding pesticide use was found to be in place in six Member States. A further six Member States were found to have record-keeping systems under implementation. CLXXXVIII  The transition towards electronic record-keeping was seen to bring about compliance cost for farmers, estimated to be between 27 and 74 Euro per farmer per year on average. It should be noted however that this cost could be offset by the development of systems for data capture and electronic transfer by Member States and industry, thus reducing administrative costs in the long term. If electronic IPM record-keeping was also introduced there could be some commonality or synergies between the electronic record-keeping systems to limit overall compliance costs.

There are also additional compliance costs for the Member States which vary depending on the existing level of implementation. The cost for Member States without an existing system is estimated at 500,000 EUR for the development of an electronic system with annual monitoring costs estimated as two full time employees or 100,000 EUR. Costs for Member States to share with the Commission information on monitoring data already collected and indicators developed nationally are considered to be limited. Costs for the Commission in collating and reporting on the data are currently considered to be feasible. The potential electronic record-keeping for pesticide use and IPM implementation data requirements are not seen as directly affecting the achievement of the Farm to Fork targets but would provide a means for the development of future targets or indicators and provide data for Member States to take specific and targeted actions towards the existing Farm to Fork targets.

Considering that Option 1 simply provides a greater mandate for Member States to provide existing data, it is foreseen that there would be no additional impacts compared to the baseline.

For Option 2, taking into account that almost half of Member States have in place or are implementing an electronic record system, it is foreseen that possible impacts to plant protection product users would be comparable to the baseline. This is also assuming that electronic data recording under Regulation 1107/2009 is implemented. For Member States without an electronic record system the cost to users of plant protection products would be limited with some increase in administrative burden. This additional burden could be mitigated with the support of advisory services, however, in uploading data onto electronic systems as is already happening in countries with existing systems (e.g. in Denmark). Implementation of electronic record-keeping techniques should in the longer term promote innovation, competitiveness and added value and reduce comparable administrative burdens of alternative non-electronic systems CLXXXIX .

The main additional costs would be administrative and compliance costs in the analysis of data and indicators by Member States and the European Commission. Given that comparable systems have been implemented in the region of EUR 500,000, this one-off implementation cost would be borne by Member States with no comparable systems. Administrative costs need to be balanced against the potential environmental and health benefits expected from better data and monitoring helping to reduce the overall use and risk of pesticides. There could be economic benefits of a better knowledge of pesticide use as regards more efficient risk management and decision-making for placing on the market and use of pesticide, with less effects on health in the long-term as indirect long-term consequence. The increased application over time of precision agriculture techniques and digital technologies, including for data collection and monitoring, could also help to limit or reduce the administrative burden on individual professional pesticide users and/or businesses.

Option 3 is the same as Option 2.

6.4.3. Specific objective 3 (SO3): Strong implementation of clearer SUD provisions in Member States

Baseline: The assessment of impact is based on current evidence concerning the state of implementation of the SUD, which is variable between Member States who have failed to reach the ambitions of the SUD, in particular with delays in production and reviewing of NAPS. It is expected that implementation of the existing IPM requirements would improve piecemeal, based on engagement of farmers and the agricultural support industry, but be supported by the provisions of the newly reformed CAP, another important contextual factor for the baseline. Enhanced implementation of IPM is seen as a cornerstone of the legislation, a stated intention of the Farm to Fork actions, and a core driver in achieving the Farm to Fork targets.

Option 1 would result in further clarifications and guidance on the SUD provisions (on e.g. IPM principles, NAPs, standards for testing of PAE). The impact of these elements would lead to low costs to users and the Member States as they are close to the baseline and continue to leave Member States high flexibility in their approach to implementing their local policies on the sustainable use of pesticides. The greatest cost would be incurred by Member States in developing or approving crop-specific IPM rules. The cost would vary greatly between Member States depending on the level of practical implementation of IPM principles as a local baseline. IPM crop-specific guidelines already exist in some Member States for many crops (see Annex 4). There would only be minimal additional administrative costs for the Commission, for example in clarifying the mandatory content of NAPs. However, these least ambitious policy elements would not represent an effective response to the overall identified problems or in achieving the pesticide targets.

Option 2 would significantly enhance the role of independent advisors, particularly in IPM. This would incur a significant cost for farmers (between 180-540 EUR per farm annually) CXC , as would a requirement for electronic IPM record-keeping (estimated at 74 euro per farmer annually). These costs may be supported by the CAP, should the Member States decide so. This is offset partially by a decrease in costs for chemical pesticides, and an increase in business for consultancies and agronomic advisors. Member States would see increased administrative costs in annual updating and reporting of their NAPs, and an estimated 800,000 EUR to establish an electronic IPM record system. The cost of using these standards as a basis for controls and enforcement is estimated at 1.3 M EUR a year. The Commission would, in general, face limited costs and mostly related to providing guidance and assessment of data.

To link the NAPS to the achievement of targets, it is intended they be more structured and linked to annual progress and implementation reports to the Commission, linking the NAPs to actions to achieve Farm to Fork targets. It is also proposed to require Member States to include positive indicative targets for increasing the percentage of biological pesticides on the three most widely-grown field crops and the percentage of non-chemical methods that can be used on pests on key crops on which the active substances most responsible for the change in index value in relation to both of the national Farm to Fork targets are used. This would help to make the analysis of efforts to encourage non-chemical alternatives in National Action Plans more detailed and uniform.

Option 3 does not add significant policy elements to option 2.

6.4.4. Specific objective 4 (SO4): new and more efficient techniques are taken up by pesticide users

Baseline: The baseline scenario operates on the basis that the reference to precision farming and the development of alternatives to chemical pesticides are not defined in the SUD. In particular, one area that is seen as inhibiting more efficient techniques is the lack of clarity on the legal status of drone use for pesticide application.

For Option 1, the main elements would include to clarify the status of more targeted pesticide application as part of precision agriculture (see Annex 5). Given that this option simply adapts the wording of known techniques, it is foreseen that no cost to professional users and very minor costs for Member States would occur. Under Option 2, building upon option 1, it would entail allowing more targeted pesticide application as part of precision agriculture, for example spraying by drones. Similar to option 1, this would not occur any required cost on users and could conversely provide potential economic benefits to both users, equipment manufacturers and specialist service providers. There would be minor costs for the Member States to include new technological aspects in controls and develop specific methodologies for conducting risk assessments, and for the Commission in developing a set of criteria. Automation would result in potentially reduced labour costs.

7. How do the options compare?

The comparison of proposed policy options is structured around the groups of policy elements being assessed, i.e. the following:

•Policy elements strengthening current SUD provisions;

•Policy elements addressing data availability and monitoring;

•Policy elements addressing alignment with pesticide-related targets announced in the Farm to Fork Strategy; and

•Policy elements addressing new technologies.

An overview is presented below summarising the rating of the impacts of each of the policy options against a series of assessment criteria covering effectiveness, coherence, efficiency, subsidiarity and proportionality CXCI . 

For the specific objective “achievement of the pesticide targets”, Policy Option 3 including fixed uniform 50% legally-binding Member State targets is indicated as being the most effective, with stronger actions reducing the sales and use of more hazardous pesticides having the highest and most certain effectiveness. However, while this higher ambition would be expected to be more effective in realising the Farm to Fork targets, due attention would need to be given to subsidiarity aspects if setting fixed 50% reduction targets as standard for all Member States.

It should be noted, however, that in related policy areas Member States have failed to take sufficient measures at national level to comply with existing EU environmental law (e.g. Water Framework Directive) and hence setting EU obligations will help making implementation more effective CXCII . Policy Option 2 where Member States set their own legally-binding national targets to contribute to achieving an overall EU legally-binding target will be more effective than Policy Option 1. For the other specific objectives, there are also differences in effectiveness between the different policy options; however, the difference is less pronounced than for the first specific objectives. The specific measures summarised under Policy Option 1 mainly provide guidance, clarification and steps to improve implementation of existing SUD provisions. They continue to leave Member States high flexibility in their approach and thus are likely to result in greatly varying effectiveness.

A range of effectiveness is indicated for actions to strengthen the SUD provisions, which is again variable depending on the combination with other actions and the current variable level of application across Member States. The effectiveness of all actions is nevertheless assessed positively and the record-keeping for IPM, in conjunction with the use of these records and crop-specific rules is seen as having the potential to be highly effective, as is the register of PAE.

These elements can be expected to lead to higher levels of implementation and therefore better achievement of the objectives. For monitoring of use of pesticides the effectiveness of all policy options is assessed positively. These policy options would clearly improve measurability and coherence across Member States. In other cases, however, assessing the impact on effectiveness is not always possible, and effectiveness may vary according to the existing national ambitions and actions. For example, concerning new technologies, the assessment is difficult due to the uncertainty of the development and use of technology in the future, this particularly in relation to the potential use of drones for aerial spraying if future scientific evidence and consensus confirms their potential to reduce the use and risk of pesticides CXCIII .

In terms of coherence, almost all of the proposed measures under the different policy options are assessed to be coherent with other objectives of EU policy. The generally high rating is due to the fact that the measures, in short, aim at reducing the health and environmental risks from the use of pesticides. Exceptions include the different policy measures proposed for the specific objective “clarifying use of drones”, given that they suggest future legislative action once relevant scientific evidence and consensus are more fully developed which cannot be assessed yet; however, it is assumed that a potential legislative act or parameters would be designed to not lead to any negative health and environment impacts. Another instance where coherence is less pronounced is for policy option 1 under specific objective “Alignment of the SUD with the pesticide targets”; given that the effectiveness of this option is expected to be low this could lead to limited alignment with health and environmental objectives of the EU legislative framework. The more ambitious options are designed to harmonise actions, to align the SUD with recent policy actions such as the Farm to Fork Strategy, Biodiversity Strategy, the Zero Pollution Action Plan and CAP, and to harness the benefit of synergies with other policies. They also provide for a more coherent action across Member States and remove some of the variations in implementation resulting in better coherence at national level. This is seen as contributing to the single market and reducing variations in production costs that vary significantly at present across Member States.

Concerning efficiency, for the measures under the different policy options there is more certainty in the assessment for the more ambitious options, while overall there is less variation in the difference in assessment between lower and more ambitious options as compared to effectiveness. For the proposed measures to align the SUD with the announced Farm to Fork Strategy pesticide reduction targets, the clearest efficiency gain is seen in limiting the use and risk of more hazardous pesticides. For the consideration of making the pesticide targets mandatory, it is considered that the setting of fixed 50% mandatory targets at Member State levels would have a negative effect on efficiency and proportionality, based on the targets requiring the same reduction for each Member State. The medium option is described as better reflecting past achievements, national circumstances and a more proportionate response based on ‘effort sharing’.

For the strengthening of SUD provisions there is little difference presented between the level of ambition of the actions described, and a positive assessment for the efficiency of the options. The large range in the issues around IPM application link to a described uncertainty of the economic support (including potentially via the CAP) for the implementation particularly at farm level but are seen as having the potential to be highly efficient. For monitoring, the efficiency is based on Member States already having some systems in place. The slightly lower rating for policy option 2 is based on the upfront investment needed for the farmer, but the recurring burden is seen as minimal. As with the assessment of effectiveness the assessment of efficiency for technology is limited by a described uncertainty as to the range, availability and cost of technological advances.

Concerning proportionality, the majority of single measures under all policy options for the different specific objectives are seen as being highly proportional. This is due to the fact that in most cases only limited effort is expected for different stakeholder groups on implementation of the proposed measures towards reaching the specific obejctives. There is one notable exception, concerning the proportionality of policy option 3 of fixed 50% legally-binding Member State targets for the specific objective of achievement of pesticide targets. In this case, there might be proportionality issues given that the baseline of current use of pesticides varies widely between Member States. Also, in order to ensure proportionality, the differences between the agricultural sectors in the Member States would need to be taken into account.

The table below shows summarises the assessment of all criteria.

Table 1. Evaluation of the policy options per specific objective against all criterion

Concerning subsidiarity, the actions are seen as retaining the flexibility to allow Member State-specific and regional circumstances and the variability of agriculture and pesticide use to be taken into account, apart from the most ambitious Policy Option 3 as regards targets of the Commission defining fixed 50% pesticide use and risk reduction targets to be made legally binding in each Member State based on the average for each Member State of the same fixed baseline period of 2015-2017.

Overall Comparison

The comparisons made of effectiveness and coherence, efficiency and proportionality and of subsidiarity of the policy options provides support for the preferred options, although with variation in scoring in some areas because of the variable baseline among Member States. The preferred option for most objectives is Policy Option 3, with notable exceptions on targets (in particular fixed legally-binding 50% Member State targets) and aerial spraying by drones where Policy Option 2 is most adequate.

8. Preferred option

The preferred option is a combination of elements from the options described above that are expected to be most effective and efficient to achieve the objectives, while being coherent with the overall policy objectives and respecting proportionality and subsidiarity. These individual elements forming part of the preferred option are indicated in Tables 30-33 in Annex 7 (under the respective headings of least, medium and most ambitious options). The proposed Regulation accompanying this impact assessment contains very detailed rules relating to the setting of targets and binding, directly applicable obligations on economic operators in support of Specific Objectives 2 and 3. Where Member States have some flexibility to derogate, this is subject to strict binding conditions. All of these measures are most appropriately provided for in a Regulation that can provide greater precision for uniform binding rules.

Specific objective 1: Pesticide reduction targets reflected in SUD

As already applied in other EU policy fields such as renewable energy CXCIV , climate action CXCV  and planned nature restoration targets CXCVI , targets are considered to be an objective, clear and transparent tool to measure progress in reducing the use and risk of chemical pesticides and use of more hazardous pesticides. The options of aspirational EU-level targets, legally binding EU-level targets and legally binding Member State targets have been considered. As a non-legally binding EU-level 50% pesticide target would likely be ineffective CXCVII , mandatory targets will be better suited to achieve agreed EU policy and legally-binding objectives. However, for the Commission to define a fixed and inflexible 50% legally-binding target for each Member State (Policy Option 3) is considered not to fully respect the subsidiarity principle and to be of low political viability based on feedback received from Member States and stakeholders and is, therefore, not preferred. Option 2 involves targets which are legally-binding and to be achieved at EU level, with Member States setting national binding targets to contribute to achieving the overall EU target. Once the Member States define the level of those national targets (after considering any recommendations from the Commission), those national targets become binding. In order to ensure a fair burden sharing, Member States will be allowed to take account of historical progress and changes in national circumstances since when the baseline period was set 39 . Member States will be permitted to set national targets that are lower than 50%, but not lower than 40%, on the basis of such changes. A Member State that has made historical progress through above-average reductions in pesticide usage can propose national targets below the EU 50% target in the range of 40-50%. Conversely, a Member State with poor historical performance will be asked to set proportionately higher targets for use and risk reduction.

Assuming that Member States will avail of the derogations under the Regulation to set targets below 50%, achievement of the twin EU binding targets cannot be guaranteed by the achievement of Member State targets alone, except in the unlikely event that targets set below 50% are balanced by those set above 50% (either due to poor historical performance or because Member States opt for this higher level of ambition on a voluntary basis and taking into account possible societal demands to further reduce the use and risk of pesticides). However, this takes no account of the impacts of removing active substances currently approved for use in pesticides from the market which may occur at an accelerated rate, which will be an additional contributing factor in helping to meet the twin EU binding targets. Quite apart from the formal national reduction target set by each Member State, it should be noted that other separate initiatives either by competent authorities or stakeholders (such as the food industry) may also account for supplementary progress towards achieving the overall EU targets, for example by the promotion of sustainable food systems CXCVIII CXCIX , organic farming, urban greening initiatives under the Biodiversity Strategy CC  etc. The upcoming legislative initiative on a horizontal EU framework for sustainable food systems will help anchor the Farm to Fork Strategy and integrate sustainability into all food related policies. As a lex generalis it will lay down general definitions, principles and objectives, together with the requirements and responsibilities of all actors in the EU food system, which are expected to be complementary and supportive to achieving the targets set by the Farm to Fork Strategy. It is, however, difficult to precisely quantify at this time the contributions and impacts these ongoing and future initiatives will make to achieving the overall EU binding targets. It is also clear that the targets set by those Member States accounting for a high proportion of total EU sales (use) of pesticides will have a strong influence on expected progress towards reaching the overall EU targets (e.g. Germany, Spain, France and Italy accounting for over two thirds of the total EU pesticide sales CCI ). 

A Regulation is the preferred legal instrument to provide sufficiently precise and binding obligations in relation to targets given the need to provide very clear parameters for how targets should be adapted to national circumstances.

Flanking policies will also be an effective means of fostering and guaranteeing compliance at EU level. For example, more specific IPM requirements in crop-specific rules will facilitate rewarding farmers who go beyond compliance with IPM requirements through incentives under the CAP that provide for farming practices relevant to IPM, such as biodiversity areas. Financial support is available in the CAP to help farmers adapt their practices to the transition to less dependency on chemical pesticides. The available financial means are within the national envelopes that Member States have in the CAP budget and these Member States are free to target the priorities in the framework defined at EU level. However these national envelopes are set at the beginning of the programming period and Member States are limited to the available funds in these envelopes.

The mandatory EU-level targets will be combined with annual monitoring of progress at both EU and Member State levels and Commission recommendations of possible additional measures if the level of progress of individual Member States in reducing the use and risk of pesticides is considered as not being sufficient. It should also be noted that trends in the use and risk of pesticides will be influenced by many factors outside the scope of this initiative, for example trends in organic farming production in the EU and whether candidate for substitution pesticides are renewed under Regulation (EC) No 1107/2009 in the period up to 2030 covered by these targets.

In order to achieve the necessary pesticide use and risk reductions the following measures would accompany the targets; (1) The purchase and use of more hazardous pesticides by non-professional users would be prohibited, unless these users were trained as professional users. Such a requirement already applies in some Member States and is considered a preferred option based on the greater risks to health and the environment posed by the use of more hazardous pesticides. This approach is preferred over a potential prescription system given that such a prescription system would be very costly and impose a high administrative burden on pesticide users, advisers and Member States to implement without resulting in a significant reduction in pesticide use and risk CCII . (2) In sensitive areas, including in urban green areas the use of all chemical pesticides would be prohibited. This responds to stakeholder concerns on the need to reduce pesticide use in sensitive areas and for vulnerable groups CCIII and links to relevant specific ambitions under the Biodiversity Strategy to protect nature and reverse the degradation of ecosystems CCIV . Professional pesticide users 40 would face costs and an administrative burden to submit derogation applications if they needed to use chemical pesticides in such sensitive areas. 41

Specific objective 2: Monitoring and ensuring that relevant data are widely available

To strengthen data availability 42  on pesticide use, Member States should systematically collect, in an electronic form, information on pesticide use that professional pesticide users are already required to keep recorded in line with the plant protection products Regulation 43 . Member States should report to the Commission annually on this data in order to identify trends in the use and risk of pesticides. Combining data on actual use of pesticides 44 , with other data collected via relevant research projects 45 monitoring the presence of pesticides and metabolites in human and environmental samples would allow the Commission to develop more precise harmonised risk indicators in the future. Experiences concerning the development of other indicators would also be taken into account, for example water quality indicators developed by the EEA CCV .To improve enforcement, monitoring and control of PAE, a better overview on PAE in use in Member States should be ensured through a preferred option of establishing national PAE registers 46 in each Member State. Data indicates that, depending on the PAE type, an inspection reduces 6 to 12% of the technical risk involved using a single PAE machine of the overall risk of plant protection products for the environment and human health CCVI . It is therefore preferred and considered appropriate and justified to have better overview data available on the inspection of PAE across all Member States, also taking into account the PAE inspection implementation shortcomings identified in the evaluation accompanying this impact assessment. A Regulation is the best legal instrument to address this policy option given that it requires detailed obligations that are directly enforceable on individuals (for example in relation to records on pesticide use or notify sales of application equipment). This is more appropriately dealt with in a uniform manner in a Regulation.

Specific objective 3: strong implementation of clearer SUD provisions in Member States

Given that the CAP is expected to create a strong link between NAPs and CAP payments, the content, development and review of the NAPs would be further specified in detail in the SUD and should be linked to the future NSPs to be prepared under the CAP. Conditionality under the CAP will be an important flanking measure to achieve this specific objective. Even though deleting the requirement for NAPs would reduce potential administrative burden for Member State competent authorities, this current requirement is kept as Member States and stakeholders feedback confirm that NAPs still represent a useful tool to direct and engage on national policies to promote the sustainable use of pesticides, also considering that not all national pesticide use would be covered under the CAP or NSPs. Member States should make better use of the existing provisions under the  Official Controls Regulation  on controls, enforcement and penalties relevant to the SUD. National and/or regional crop-specific IPM rules should assist pesticide users. Together with electronic IPM record-keeping 47 this would also facilitate controls and enforcement. This should be accompanied by an independent advisory systems, for professional pesticide users responding to specific stakeholder demands CCVII . The advisory systems are expected not only to reduce the use and risk of pesticides but also help to reduce costs for pesticide users CCVIII , by reducing amounts spent on pesticides. The promotion of the use of harmonised standards on PAE where they exist and support their development where they currently do not exist should lead to improved controls and reduced pesticide use CCIX .

Implementation is greatly strengthened by providing more detailed rules in the form of a Regulation. For example, in relation to integrated pest management, while it is impossible to provide for sufficiently specific rules for each local crop and region in one text given the numerous geographic, climatic and crop-specific variables, the Regulation can provide for the Commission to object to crop-specific rules that do not follow legal requirements as to contents and subject the method of development and implementation of crop-specific rules to audits. In addition, a Regulation is the most appropriate legal instrument to ensure uniform, streamlined NAPs, which have often lacked quantitative data or adequate levels of detail under the SUD.

Specific objective 4: new and more efficient techniques are taken up by pesticide users

Possible measures to be taken under the CAP will be a most relevant flanking measure to promote that new and more efficient techniques are taken up by pesticide users. Nevertheless, it should be noted that not all pesticide (or even agricultural) use would be covered under the CAP. Given that the SUD does not impede, in principle, the application of precision farming techniques CCX , changes would be limited to providing provisions to describe and encourage the role of precision agriculture as a tool to achieve the objective of pesticide use and risk reduction, encouraging the availability of alternatives to chemical pesticides and in clarifying on aerial spraying and the use of more targeted pesticide application as part of precision agriculture, for example spraying by drones, since drones are not currently explicitly mentioned in the definition of aerial spraying in the SUD CCXI . In line with the SUD’s current prohibition on aerial spraying and the Commission’s over-arching ambition to reduce the use and risk of pesticides, more targeted application of pesticides as part of precision agriculture should be encouraged within clearly defined parameters. However, concerning aerial spraying by drones, due to current limitations and consensus on available scientific data CCXII , those parameters should be defined in a future annex of the legislation based on advances in the underlying science and where demonstrated to reduce the overall use and risk of pesticide. Concerning drones the preferred option is therefore to explicitly include drones in the legal definition of aerial spraying of pesticides, maintain the current general legal prohibition of all forms of aerial spraying, including by drones, except under strict conditions (no feasible alternative and less negative impact on human health and the environment than any alternative) and technical requirements. The Commission will plan to adopt more detailed future rules on aerial spraying via drones once the scientific evidence and consensus on the benefits or risks of this practice are more advanced.

The impacts of this preferred option are mainly shaped by the impacts of the various elements it combines.

Achieving the pesticide targets would generate environmental and social/health benefits, and contribute to a sustainable and safe food production in the EU. Professional users would face additional costs compared to the status quo from the time spent for data recording. A ban of chemical pesticides in sensitive areas could result in a reduction of relevant crop yields from those areas. Professional users being obliged to use independent advisory services better promoting IPM would have a direct additional cost, but could be offset by the savings of using less pesticides as a result. Member State authorities would mainly be impacted by planning and reporting requirements on the elements. The main costs would arise from revising the NAPs to reflect the specifications, setting up electronic data collection systems, analysing the data recorded by pesticide users, and preparing annual reports to the Commission on progress towards reaching the Farm to Fork Stratgey pesticide targets. The additional costs depend on the current level of implementation and can overall be expected to be at a medium level.

Non-professional pesticide users would face costs in order to be trained as professional users if they wished to purchase and use more hazardous pesticides. The overall extent of these costs is unknown as statistics on the number of non-professional pesticide users do not exist and their user profiles differ substantially. Pesticide producers would likely see a change in demand for their products because of the ban of use of chemical pesticides in sensitive areas. There could be a change from the use of chemical pesticides to alternative techniques, including microbial pesticides, with a consequent impact on the product portfolio of pesticide producers. There could also be impacts on the level of international trade CCXIII  of particular pesticides into, or out, of the EU, in line with adjustments in pesticide use rules and policies within the EU. EU consumers could see increasing food prices because of the higher production costs and reduced yields of agricultural production. There could be an impact on the EU trade balance from increased imports (e.g. of oilseeds, cereals) and decline in EU exports of agri-food products to third countries, although, as described earlier and in Annex 5, economic analyses of these aspects differ on the overall impacts and their scale.

The costs are contrasted by benefits for different groups. For society in general, benefits arise from reduced risk for human health and for the environment. The main contribution to this benefit is achieved from the ban of chemical pesticides in sensitive areas, which includes green urban areas close to a large number of people and to vulnerable groups such as children. In addition, a training requirement for non-professional users if they wished to purchase and use more hazardous pesticides and a better implementation of harmonised testing of PAE can be expected to reduce the exposure of pesticide users and bystanders. The impact assessment also found that environmental benefits from legally binding pesticide targets, supported by mechanisms such as the ban of chemical pesticides in sensitive areas, would increase soil and water quality, particularly in such areas that have high environmental value as habitats or for ecosystem services. There would be benefits to biodiversity, and the ecosystem services it underpins such as pollination services, but quantifying these benefits or monetising them is not possible. In the longer term, there could be positive impacts on businesses that directly depend on biodiversity and healthy ecosystems such as in the agriculture, water and food sectors, as well as the tourism industry. Policies to reduce pesticide use and risk in the EU could lead to a promotion of such policies in non-EU countries, with training and knowledge-sharing activities potentially contributing to such positive spill-over effects and the promotion of positive practices to reduce the use and risk of pesticides globally. Professional pesticide users can potentially reduce expenses for pesticides through better implementation of IPM principles. Member State authorities would benefit from improved clarity on requirements towards their NAPs and reporting obligations. Other industries and some specific parts of the food production value chain would benefit from the efforts to achieve the pesticide targets. This applies to farmers practising agroecology, beekeepers, agricultural machinery producers, the biocontrol industry and advisors but also to drinking water suppliers for example (less costs from pesticide pollution).

The potential impacts on production costs and higher risks of loss of yields remain. The benefits of the option relate to the reduction of risk for human health and protection and restoration of biodiversity, natural compartments and ecosystem services.

REFIT (simplification and improved efficiency)

Based on consultations with stakeholders CCXIV , including Member State competent authorities and other stakeholders via the Advisory Group on the Food Chain and Animal and Plant Health CCXV , no legislative simplifications or reductions of administrative burden have been identified that would not jeopardise the objectives of the SUD to protect health and the environment or the ambition of the European Green Deal, Farm to Fork Strategy, Biodiversity Strategy and Zero Pollution Action Plan to reduce the use and risk of chemical pesticides. 

9. How will actual impacts be monitored and evaluated?

The existing indicator to measure the achievement of the two pesticide targets CCXVI  will form the basis of the annual central monitoring of the progress towards the two Farm to Fork pesticide targets at the EU and at Member State levels. Furthermore, the indicator will be used to evaluate and measure the success of this initiative. The importance of this initiative, and the need to ensure that all Member States stay on track to achieve the two pesticide targets, coupled with the availability of the necessary data to measure progress towards the two targets each year, justifies and explains the annual monitoring cycle.

The assessment of progress towards the targets will, in particular, be supported by the availability of annual, harmonised, aggregated data on the sales and use of pesticides under the Commission’s proposed Regulation on Statistics on Agricultural Inputs and Outputs. The resultant data will provide an annual national level overview of sales by active substance and use in agriculture for representative crops by active substance. A planned Implementing Regulation under Article 67 of Regulation (EC) No 1107/2009 will better define the content and format of records that professional users must maintain, which will facilitate the collection of this detailed data by Member State competent authorities. Furthermore, data on pesticides in water (reported by Members States to the European Environment Agency under Directive 2000/60/EC), data on pesticides in soil (under the LUCAS project), and data on farm practices collected under the Farm Sustainability Data Network (FSDN) will also support the evaluation of the success of this initiative.

Additionally, relevant indicators for the operational objectives under each specific objective are proposed and presented in Table 2 below. To supplement this annual monitoring, and making use of all relevant data that will be available, the initiative is proposed to be formally evaluated at the earliest 7 years after the planned legal proposal becomes applicable. This is considered appropriate in view of the time that will be needed for the monitoring data and indicators in below-mentioned Table 2 and for comparative years to become available and to avoid that the evaluation takes place prematurely before sufficient data and monitoring information are available on the implementation, application and enforcement of the expected legal provisions. It should also be noted that data on whether the 2030 pesticide use and risk reduction targets have been achieved will likely only become available in 2032. As part of its monitoring and evaluation activities and making use of the more granular pesticide use data expected to be available, the Commission will consider whether new pesticide use and risk reduction targets will be appropriate for the period beyond 2030, which could also be more specifically differentiated and targeted towards individual and more hazardous categories of plant protection products.

Moreover, these monitoring data can also be used directly in the monitoring of the overall policy objectives set out under the European Green Deal and the 8th Environment Action Programme, including the Farm to Fork Strategy, the Biodiversity Strategy and the Zero Pollution Monitoring and Outlook.

Table 2. Relevant indicators for monitoring of operational objectives CCXVII

Annex 1: Procedural information

Annex 1.1. Lead DG, Decide Planning/CWP references

DG SANTE, PLAN/2020/6975

Annex 1.2. Organisation and timing    

A combined evaluation roadmap and inception impact assessment (ERM-IIA) for this back-to-back assessment was published in May 2020, remaining open for feedback until August 2020. Three Commission public remote stakeholder events took place in January, June and October 2021. An online public consultation/ Have your say took place from January to April 2021.

An external study CCXVIII supporting the evaluation and impact assessment was contracted in December 2020 and concluded in October 2021. A supplementary foresight-on-demand study CCXIX  on future vision scenarios on the sustainable use of pesticides was contracted, commencing in March 2021 and concluding in October 2021.

Within the Commission, an inter-service steering group (ISSG) was set up, including DG SANTE, DG AGRI, DG CLIMA, DG DEFIS, DG EMPL, DG ENV, ESTAT, DG GROW, DG INTPA, DG JUST, JRC, DG MARE, DG MOVE, DG REGIO, DG RTD, SG, SJ, DG TAXUD, DG TRADE.

Five remote ISSG meetings were held between June 2020 and January 2022 to update on the planned work and discuss progress with the supporting external study and to discuss ISSG comments on the evaluation and impact assessment Commission staff working documents.

Annex 1.3. Consultation of the RSB

An upstream RSB meeting took place on 2 July 2021. The draft impact assessment staff working document was discussed at an RSB meeting of 24 November 2021 and a negative first RSB opinion issued on 26 November 2021. A revised draft impact assessment staff working document was submitted to the RSB and, by written procedure, a positive with reservations second RSB opinion was issued on 26 January 2022. Table 3 below outlines how the first RSB opinion comments on improvements needed to the impact assessment staff working document have been addressed.

Table 3. Amendments in response to the first 26 November 2021 RSB opinion comments

Table 4 below outlines how the second opinion RSB reservations have been addressed in the revised impact assessment staff working document.

Table 4. Amendments in response to the second 26 January 2022 RSB positive with reservations opinion

Annex 1.4. Evidence, sources and quality

The evaluation and impact assessment rely significantly on the following sources:

Literature review

Directive 2009/128/EC on the sustainable use of pesticides - European Implementation Assessment, study , European Parliamentary Research Service, ISBN: 978-92-846-3330-2, October 2018. 

Sustainable use of plant protection products: limited progress in measuring and reducing risks , Special Report European Court of Auditors, ISBN:978-92-847-4206-6, Publications Office of the European Union, Luxembourg, 5 February 2020.

Rand Europe, Development of future scenarios for the sustainable use of pesticides and, in particular, achieving by 2030 the pesticide use and risk reduction targets announced in the Farm to Fork and Biodiversity Strategies, RR-A1501-1 October 2021

Ramboll Arcadia International, Study supporting the Evaluation of Directive 2009/128/EC on the sustainable use of pesticides and impact assessment of its possible revision Rand Europe, October 2021.

Public feedback on combined evaluation roadmap and inception impact assessment May-August 2020, published on the Have Your Say Portal of the European Commission

 Online public consultation  published on the “Have your say” portal in January-April 2021, Factual Summary Report (Ref. Ares (2021)3138340 – 11 May 2021),

Better Training for Safer Food (BTSF) Workshop on the Sustainable Use of Pesticides Directive (SUD) 2009/128/EC - Experiences on its current implementation and possible future policy options. 17-19 November 2020.  

Commission public stakeholder events held in 2021 on:  19 January ,  25 June ,  5 October . 

Evaluation on Directive on the Sustainable Use of Pesticides, Information report, European Economic and Social Committee, NAT/805-EESC-2020, 27 April 2021.

Annex 2: Stakeholder consultation

Annex 2.1. Introduction

This synopsis report presents the stakeholder consultation activities performed within the back-to-back evaluation of the sustainable use of pesticides Directive and the impact assessment of its possible revision. It contains a discussion and comparison of results of the different consultation activities, looking, inter alia, into interdependencies and in/consistencies, as well as a summary of how results have been integrated into the analysis for the responses to the evaluation questions and as part of the impact assessment process.

Annex 2.2. Consultation strategy

The stakeholder consultation activities cover the public feedback on a combined evaluation roadmap-inception impact assessment, a public consultation, three public stakeholder events, and interviews, targeted online surveys, focus groups, and stakeholder workshops undertaken by the consultant. The aim of the consultations were:

·to inform stakeholders on the ongoing evaluation and impact assessment mainly via the public stakeholder events and the combined roadmap/inception impact assessment;

·to get the views of the public on the sustainable use of pesticides and possible future options via the public consultation;

·to collect feedback from the authorities on the implementation of the sustainable use of pesticides Directive (what has worked well and not so well) and perspectives on possible changes to the legislative framework via a ‘Better Training for Safer Food’ workshop with Member States national competent authorities; 

·to collect views on implementation and views and data on impacts from stakeholders through targeted interviews and surveys.

As an illustration, main stakeholders identified and addressed are shown in Table 5 below.

Table 5. Main stakeholder groups

Feedback to the roadmap

The roadmap was open for public feedback from 29 May to 7 August 2020. In total, 360 responses were received, originating from 26 countries, with the greatest number of responses originating from France (118 out of 360). As shown below, the main identified stakeholders which provided feedback were EU citizens and business associations.

Figure 9. Overview of respondents responding to the inception impact assessment (N=360)

European Commission (2021). Feedback and statistics: Inception impact assessment.

Feedback received represented a wide spectrum of views ranging from ‘pesticides are all dangerous and must be banned’ to ‘pesticides are assessed as being safe for health and the environment before being placed on the market and their use is essential for food security and production’. Consensus among respondents existed on the view that increasingly strict rules in the EU concerning the use of pesticides will disadvantage EU producers and expose them to unfair competition from third countries. Companies/farmers and many citizens suggested that either EU farmers should be specifically compensated or food and agricultural product imports should respect our rules concerning the use of pesticides or otherwise be prohibited or heavily taxed. While some citizens and NGOs commented that more precise pesticide technology is not the answer to reducing associated risks and new technologies and innovation need to be avoided (including novel breeding and genomic techniques), other stakeholders such as pesticide users and industry considered that new technologies should be promoted.

Citizens and NGOs were mainly concerned about the risks of pesticides to health and environment, including links with the United Nations Sustainable Development Goals. Mainly farmers and industry considered pesticides safe and that not using them jeopardises human health (due to plant toxins and mycotoxins) and plant health. The machinery sector considered that harmonised rules and reinforced testing and inspections of pesticide application equipment are needed.

In general, all proponents and opponents of pesticides, including Member State authorities, agree that the current sustainable use of pesticides Directive is inconsistently and unevenly applied. Stakeholders from various groups see a need for harmonised implementation of the rules to level the playing field for all EU farmers but also enforce the existing instruments to reduce the risk of pesticide use for humans and the environment. Many stakeholders call for a stronger role of the Commission in this process.

Public consultation

The public consultation ran from 18 January to 12 April 2021 and received a total of 1699 responses. Two separate campaigns were identified. 30 identical responses from mainly NGOs linked to an online post 50 and 29 identical responses from Italian agricultural cooperatives. These responses were segregated from the original dataset and were analysed separately. The final pool of respondents’ totalled 1640.

The large majority of responses were received from EU 27 (plus UK) countries (N=1570), especially Italy (N=480) followed by Germany (N=262).

The public consultation covered two areas (1) current use and attitude towards pesticides (2) views on options to improve the sustainable use of pesticides.

For professional users of pesticides the protection of crop yield (301 out of 373) and crop quality (298/373) are the most important factors in their use of pesticides. Similarly, private users mainly use pesticides to protect plants, fruits or vegetables that they grow (76/89). The majority of both private (64/79) and professional users (291/362) use pesticides instead of other control techniques, because pesticides are more effective (offer better/more reliable control) than other control techniques.

45% of respondents stated that they do not think there is a need to reduce the use of pesticides in the EU. This view was predominantly held by professional users of pesticides in agricultural setting, forestry or horticulture and pesticides manufacturers. The option that gathered the most support in all stakeholder groups was to introduce economic incentives and stimuli for the application of integrated pest management by pesticide users and other alternative methods for pest management. The option of ‘increasing the price of more hazardous chemical pesticides to discourage and reduce their use’ gathered the least support from respondents in all stakeholder groups.

In total 162 respondents submitted position papers. Following an initial screening identical (17), irrelevant and inappropriate (6) were removed resulting in 139 position papers analysed covering professional users (34), other industry impacted (26), NGOs (20), individuals not using pesticides (15), pesticide industry (8), pesticide advisors (8), public authorities (7) academia and research (7), trade unions (4), worker organisations (3), beekeeper/honey industry (2), international organisations (2).

The three main themes covered in the position papers were:

(1) The need for there to be more available alternatives to chemical pesticides on the market. This theme mainly originated from professional users of pesticides; however, it was a view that broadly shared across almost all stakeholder groups.

(2) The use of chemical pesticides. From the professional users’ and advisors’ point of view, many highlighted that there can often be implicit assumptions that are made that biological pesticides are innately safer than chemical pesticides. In particular, examples were provided where biological pesticides can sometimes contain similar toxicity and/or ecotoxicity profiles to other synthetic chemical pesticides. On the other hand, many NGOs, EU citizens and academia were of the view that regardless of whether they are chemical or biological pesticides, there is a clear need to reduce the use of pesticides across Europe. The main reason behind this view was for the growing concerns that pesticide use have on human and animal health, biodiversity and the environment and the development of resistance by pests/ weeds. Interestingly, one line of agreement between the two viewpoints was for there to be more research carried out to back-up the authorisation process of plant protection products.

(3) Environmental, human and animal health impacts of pesticde use mainly raised by NGOs, other industry impacted by the sustainable use of pesticides Directive (i.e. water industry) and environmental organisations. In particular, many of the respondents provided evidence of envrionmental and human health impacts from their specific region or local area.

Stakeholder events

In the stakeholder workshop on 19 January 2021 a representative of the Group of EU Chief Scientific Advisors placed the initiative in the context of achieving sustainable food systems. The Member State perspective focussed on the difficulties stemming from a reduced number of pesticides on the market while having to control a high number of pests under prevailing climatic conditions and the limited financial support under the Common Agricultural Policy for the implementation of integrated pest management. A farmer representative stated that the sustainable use of pesticides Directive should aim at meeting consumer demand and achieving a sustainable income for farmers. They stressed that pesticides are an indispensable tool for farmers and advocated for national/regional/local measures, reduced burden e.g. for aerial spraying exemptions, and technological innovations. According to the presenting agricultural machinery association, new technologies can help in reducing the use of pesticides and harmonisation in that area could help reducing barriers to new technologies. Fostering of innovative tools was supported by the pesticide industry, which also advocated for refining and better implementation of the sustainable use of pesticides Directive. Consumer representative asked for better protecting the health of consumers and workers and the environment by using as little pesticides as possible, banning aerial spraying, better integrated pest management implementation, enforcement and incentivising organic production. NGOs stressed the importance of achieving the European Green deal ambition and related targets, the need for adequate monitoring indicators, considering long term external costs and benefits. A water industry representative considered the ambition and enforcement of national action plans weak, thus impacting on the risks on water resources and imposing extra costs for water treatment for the sector and by extension for consumers and citizens. Beekeepers highlighted the detrimental effect of emergency pesticide authorisations on the environment and advocated for best practice in pesticide application, strengthened enforcement, improved monitoring and indicators and the promotion of alternatives to pesticides. EU research projects such as the Health Biomonitoring for EU project (HBM4EU) presented their aim of improving our knowledge on pesticides risks. An example for pesticide-free management in the non-agricultural sector, such as urban areas, sports grounds and along railways, was presented by a regional Member State environment agency.

In a second workshop on 25 June 2021 stakeholders were updated on the preliminary results of the evaluation and consulted on possible policy options. Stakeholder positions presented were in line with the first workshop. NGO and beekeeper organisations expressed their opposition to any policy options relaxing the current sustainable use of pesticides Directive general prohibition on aerial spraying.

In a third workshop on 5 October 2021 more advanced conclusions of the evaluation and draft findings on the impact assessment work of the supporting study were presented. Feedback from stakeholders was generally in line with the previous events. NGOs and beekeeper organisations expressed criticism that some of their more ambitious policy options (e.g. more ambitious pesticide reduction targets) raised at the June event and the subject of a European Citizens’ Initiative which closed on 30 September had not been taken into account. A representative of the bioprotection and biocontrol industry also repeated their call for a definition of biocontrol to be included in the future SUD. Stakeholders generally agreed on the presented main evaluation findings. The importance of possible impacts of any policy changes on non-EU countries, including developing countries, was emphasised.

Targeted interviews and surveys

Summary of results

The following section aims to synthesise and present an overview of the main responses across each of the stakeholder consultation activities with regard to three core aspects which were central to the discussion of the evaluation and potential revision of the sustainable use of pesticides Directive. These include [1] the use of pesticides and contribution of the sustainable use of pesticides Directive, [2] the level of implementation of the provisions of the sustainable use of pesticides Directive, and [3] the future of the sustainable use of pesticides Directive and meeting the Farm to Fork targets.

Use of pesticides and the contribution of the sustainable use of pesticides Directive

Results from the public consultation aimed to understand questions relating to why pesticides are being used and what were the main drivers in this regard. Figure 10 below presents the results on the reasons why pesticides are used instead of other control techniques.

Figure 10. Public consultation: As a professional user, why do you use pesticides instead of other control techniques? (n=362)

With regard to the sustainable use of pesticides Directive more specifically, in the targeted online surveys, the three main stakeholder groups of Member State authorities, plant protection product users and industry and environmental organisations were asked specifically on the contribution of the sustainable use of pesticides Directive across different objectives. As shown in the figure below, notable differences were observed with plant protection product users and industry generally providing a more positive view of the sustainable use of pesticides Directive’s contribution, compared to environmental organisations which had largely opposite views. Member State views were generally balanced, with the exception of the sustainable use of pesticides Directive having contributed to improving behaviour of plant protection product users and reducing the dependency of chemical pesticides.

Figure 11. Cross targeted survey results: In your opinion, to what extent has the SUD contributed to the following objectives?

N.B. Member State survey (n=55), PPP users and industry (n=161), Environmental NGOs and civil society organisations (n=28)

From the external study interviews CCXX , a more ambiguous picture was presented, with the sustainable use of pesticides Directive being seen to provide more indirect benefits rather than clear, measurable effects. The sustainable use of pesticides Directive was seen to have an important impact on informing and raising awareness of sustainable pesticide use, particularly through integrated pest management. This was confirmed in six interviews where it was noted in particular by one Member State authority that while the sustainable use of pesticides Directive does not have a clear impact on reducing human health risks of using professional plant protection products, it had helped in reducing the risk of plant protection productss for non-professional users by raising awareness on risk of pesticide use.

In addition, some stakeholders (primarily EU institution representatives and Member State authorities) acknowledged the sustainable use of pesticides Directive as being a key driver in raising the importance and overall relevance of pesticide risks across Member States and economic stakeholders. This was primarily achieved through raising awareness, dissemination of knowledge, and development of educational and training campaigns, as well as more guidance or controls on the use of plant protection productss. This point was contested, however, with some stakeholders (primarily environmental NGOs and other economic stakeholders impacted by the sustainable use of pesticides Directive) answering that there is a lack of understanding and/or awareness of the risk of pesticide application for the users and the surrounding environment.

Level of implementation of the provisions of the SUD

As regards the level of current sustainable use of pesticides Directive implementation, the main results were obtained from the targeted survey to plant protection product users and industry and environmental organisations. As shown below, stark differences were found between the two groups, most notably on the option of integrated pest management impementation. From the perspective of the in-depth interviews the majority of interviewed stakeholders highlighted that the sustainable use of pesticides Directive had not been fully implemented.

Figure 12. Cross targeted survey results: In your opinion, to what extent are the following elements of the current SUD actually being implemented? 51

N.B. PPP users and industry (n=161), Environmental NGOs and civil society organisations (n=28)

In exploring the potential drivers for reasons why certain aspects of the sustainable use of pesticides Directive have not been fully implemented, the in-depth interviews uncovered a series of possible issues. The most salient theme which emerged from the interviews was the absence of less hazardous alternatives to pesticide products. From the 19 responses to this theme, it was noted that while there has been a noticeable reduction in the number of hazardous pesticides being available on the market, it has not had a significant impact on reducing the reliance on such products.

The future of the sustainable use of pesticides Directive and meeting the Farm to Fork targets

Following questions on the contribution and implementation of the sustainable use of pesticides Directive (backwards looking elements), the consultation activities also sought to look to the future of the sustainable use of pesticides Directive and its role in the meeting the Farm to Fork pesticide targets 52 . From the public consultation, overall there is some agreement across stakeholder groups on the most effective option being to “introduce economic incentives” (9 out of 11 stakeholder groups).

Figure 13. Public consultation: In your view how effective would the following options be to reduce the use and risk of chemical pesticides in the EU? (N=1640)

Differences in stakeholder views arose from consumer organisations and environmental organisations, whereby consumer organisations ranked increased sampling and inspection of food produced in the EU as the most effective option, while environmental organisations ranked the promotion of the expansion of organic farming in the EU as the most effective. A similar projection was found in the targeted online surveys, where plant protection product users and industry and environmental organisations were asked to provide feedback on potential policy elements for the revision of the sustainable use of pesticides Directive. As shown below, there was general agreement for the options regarding more detailed training for advisors and users of plant protection products, however there was strong deviation on the options regarding the use of drones for aerial spraying and prohibiting the use of all chemical pesticides in sensitive areas.

Figure 14. Cross targeted survey results: In your opinion, to what extent would the following changes lead to a reduced use and risk of chemical pesticides, in line with the targets announced in the Farm to Fork Strategy?

Annex 2.3. Integration of consultation results and analysis of responses

While the number of stakeholders consulted differs significantly across the different levels of governance, a concerted effort was made to consult all relevant stakeholder groups. While all groups were contacted, there was a limited response from non-professional and non-agricultural users, limiting their contribution in the triangulation of results. Isolating the responses by EU citizens gathered in the public consultation, the total number of consultations per stakeholder group is relatively balanced. In the case of the interviews, the main stakeholder groups targeted were Member State authorities, representative stakeholders as well as relevant representatives of EU institutions such as representatives of DG SANTE and relevant other Commission DGs which could provide insights into the functioning of the sustainable use of pesticides Directive. In terms of geographical coverage, overall, there is an even geographical distribution of respondents, however there is a noticeable geographical bias in the public consultation from the high numbers of respondents answering from Germany, Spain and Italy.

With regard to the surveys, a slight bias towards greater representation of users of pesticides and pesticide industry was found in the overall sample size compared to other groups. No weightings were applied in relation in the different sample sizes, but rather the data was triangulated, and biases were taken into account in the presentation of results. From the different activities described above, triangulation of the data uncovered that the stakeholder views were largely divided across two broad points of view: [1] pesticide use should be reduced in line with risk reduction in a manner which works with plant protection product users, and [2] pesticide use should be reduced significantly if not completely. While these differing views were found in each of the consultation activities, they have been taken into account and adequately represented in the analysis, taking into account any possible bias which may be incurred.

Annex 3: Who is affected and how?

Annex 3.1. Practical implications of the initiative

Farmers would need to change their recording on pesticide use from paper records to electronic records. Depending on the national solution chosen, that digitalisation may include a change in format and record-keeping locally or centrally.

In addition to recording pesticide use they also need to record the integrated pest management approach they are following. The record-keeping could take the form of a decision tree based on IPM pyramid including pest/economic injury thresholds as applicable. It could mean to answer questions such as ‘is a certain tool feasible: yes, no, if not, why not?’, providing justification and evidence for this decision and then move to the next decision step in the pyramid. Guidance provided by Member States would help them to identify the pest management measure best suited to their circumstances. Advisory services will give them further independent advice.

The farmer’s electronic records would be accessible to the local/regional/or national authority. The first time a farmer/pesticide user is going to have his pesticide application equipment inspected this will be entered in a local/regional or national register. Any changes in ownership of this equipment would need to be notified to the competent authority/ register.

National authorities would set up digital systems for collecting records both on pesticide use and IPM application. They would collect the electronic records from pesticide users. Alternatively they could foresee that records are stored centrally. They would annually analyse the data and transmit information to the European level. National authorities would use the data to assess progress towards their national targets and objectives of their national action plans and update their plans accordingly each year and submit those plans to the European Commission.

National authorities would set out the requirements for an independent advisory system and monitor the implementation of such a system. This could be linked with the existing farm advisory system under CAP. National authorities would inspect and control certificates and the system as needed on a risk basis.

Advisors would need to undergo a certification under the new system demonstrating their independence from pesticide and pesticide application equipment sales activities.

National authorities would establish national registers for pesticide application equipment. They would update the information on the equipment after inspection and when the status of the equipment (e.g. ownership, or removal from use/ decommissioning) changes.

Annex 3.2. Summary of costs and benefits

Table 6. Summary of benefits

Table 7. Summary of costs

Annex 4: Analytical methods

The baseline scenario is dynamic assuming that the SUD and related policies (except the pesticide-related targets in the Farm to Fork Strategy and Biodiversity Strategy) continue on the current trajectory through to 2030, and that other influences, such as climate change, continue to affect the environment, economics and wellbeing. Then, the assessment of social, economic and environmental impacts (positive and negative) of the Farm to Fork Strategy and Biodiversity Strategy pesticide targets relied on the mapping and identification of material impacts and associated indicators of impact from achieving those targets. The environmental, economic and social indicators selected were representative of the main categories of impacts (both intended and unintended, and short and long term) across the key stakeholders. An in-depth literature review was conducted with a view to:

·Identify indicators and metrics to qualitatively or quantitatively predict the relationship between reduced (hazardous) pesticide use and potential impacts; and

·Identify the most recent and comprehensive evidence base to inform the evolution of each indicator in the 2020 to 2030 baseline and in the scenario in which the pesticide-related targets announced in the Farm to Fork Strategy and Biodiversity Strategy are achieved.

Social, economic and environmental impacts are assessed for all policy options. Policy options are grouped into two strands:

1.Policy options that make reaching the two pesticide related Farm to Fork targets compulsory for Member States; and

2.Other policy options, aiming at improving current provisions and implementation of the SUD.

The first strand has potentially macroeconomic, environmental and social implications across Europe and, potentially, outside of Europe. However, the pathways are somewhat unclear since the mechanism to reach these targets would be defined by Member States, which does not allow for assessing direct costs, such as administrative or compliance cost.

The second strand aims at reducing the use and risk from pesticides; however, it is not possible to differentiate the contributions from individual provisions to the overall objective and the extent to which they together contribute to the objective. This is due to a few reasons which are listed below:

·Many of the provisions together (e.g. training and promotion of IPM) aim at accomplishing a behavioural change among pesticide users;

·Other provisions aim at supporting policy monitoring and enforcement which provide a framework for behavioural changes, but have no direct effect on pesticide use;

·The provisions reinforce each other and are to some extent interdependent (one will not function without the other).

Hence, for most of those policy options, it is very challenging to assess their social, macroeconomic and environmental impacts, other than in qualitative terms. However, the policy options having potentially direct economic costs (such as administrative costs) can be assessed.

Based on the reflections above, the following streams of assessment of impacts are presented:

·An assessment of social, macroeconomic and environmental impacts in Europe as well as outside of Europe of the situation in which the two pesticide related Farm to Fork Strategy and Biodiversity Strategy targets are made legally binding in the EU, and thus reached, by 2030.

·A qualitative assessment of the likely social, economic and environmental impacts and a quantitative assessment of direct economic costs of the policy options of group 2 mentioned above.

Harmonised risk indicators: description and calculation methodology

Harmonised Risk Indicators established under Directive 2009/128/EC aim to show the evolution in the risks to human health and the environment from pesticide use.

The European Commission shall calculate them for the EU, and Member States should calculate the Harmonised Risk Indicators at a national level. The data to be used for the calculations shall be statistical data collected in accordance with Union legislation concerning statistics on plant protection products, i.e. Regulation (EC) No 1185/2009 on pesticide statistics, and other relevant data.

The European Commission is obliged to calculate and publish the Harmonised Risk Indicators for the European Union, while each Member State is obliged to calculate and publish the Harmonised Risk Indicators for their territory. Member States must also identify trends in the use of certain active substances, and identify priority items or good practices.

All active substances are categorised into a Group and a Category (Table 8 below).

Table 8. Categorisation of active substances and weightings for the purpose of calculating Harmonised Risk Indicators 1 and 2

There are three Groups for approved active substances, Groups 1–3, and six Categories, Categories A–F. All non-approved active substances are placed in Group 4, Category G. Weightings are defined for the Groups, under Directive 2009/128/EC (Annex I).

The Harmonised Risk Indicator 1 is calculated by combining the statistics on the quantities of pesticide active substances placed on the market in accordance with Regulation (EC) No 1185/2009 and the information on active substances in accordance with Regulation (EC) No 1107/2009, including if they are low risk active substances, candidates for substitution, or other active substances. Candidates for substitution are active substances with more hazardous properties identified in accordance with the criteria in point 4 of of Annex II to Regulation (EC) No 1107/2009.

HRI 1 is based on the total quantities (kg) of active substances placed on the market in the EU or in a Member State during a reference period as reported under Regulation (EC) No 1185/2009. HRI 1 is presented as an index. The reference years concerned are from 2011 until the last available reference year. HRI 1 shall be calculated by multiplying the annual quantities of active substances placed on the market for each Group in Table 8 by the relevant weighting set out in Row (vi), followed by the aggregation of the results of these calculations.

The second Indicator, Harmonised Risk Indicator 2 (HRI 2), is based on the number of authorisations granted for plant protection products under Article 8(4) of Council Directive 91/414/EEC and Article 53 of Regulation (EC) No 1107/2009 as communicated to the European Commission in accordance with Article 53(1) of that Regulation during a reference period. The HRI 2 is presented as an index. The reference years concerned are from 2011 until the last available reference year. Since June 2016, the Plant Protection Products Application Management System database is used to collect all notified emergency authorisations. The HRI 2 shall be calculated by multiplying the number of authorisations granted for plant protection products under Article 53 of Regulation (EC) No 1107/2009 for each Group in Table 8 by the relevant weighting set out in Row (vi), followed by the aggregation of the results of these calculations.

Calculation methods

1. Calculation of costs for procurement of a plant doctor advisory system

Table 9. Estimations of costs for procurement of a plant doctor advisory system CCXXII  (this links to a possible prescription system for pesticides which was finally discarded as a possible policy element)        

2. Calculation of costs for a mandatory electronic IPM record-keeping and reporting system

The results from the survey with national authorities suggest that no country so far has a mandatory electronic IPM record-keeping in place. Only one country has a system for voluntary record-keeping on IPM in place (Finland). Another country (Denmark) has a system in which they require farmers to answer questions regarding IPM; however, these data are not collected by the authorities.

Thus, given that such a system would be new in all countries, it would entail one-off costs for creating the system and then costs for maintaining it. Costs would accrue for professional users and national authorities.

Professional users

Professional users of pesticides under this policy option includes farmers but excludes other professional users. According to the latest available data, 57  in total there are around 10.3 million farms in the countries potentially covered by the SUD, which include the EU Member States as well as Iceland, Liechtenstein, and Norway 58 . The numbers per country are presented in Table 10 below.

Table 10 Number of farms per country CCXXIII

Source: 2016 Farm Structure Survey

Large differences in the number of farms translate into different overall costs per country for policy options. This should be understood as context for the subsequent assessment of costs.

It can be expected that farmers face one-off costs for creating the necessary infrastructure as well as returning costs for the report keeping and reporting. Their expected costs are summarised in Table 11 below. Qualitatively, results from the targeted survey to users of pesticides and industry found division in the impact that electronic IPM record-keeping would have on reducing the use and risk of pesticides, in line with the Farm to Fork targets (17 out of 50 answering that it would have an impact and 20 out of 50 answering that its impact would only be minor).

Table 11. Overview of quantitative estimations of costs for professional users CCXXIV

Source: Own elaboration

National authorities

Costs for national authorities depend heavily on how the data collection will eventually be organised. For the cost assessment is assumed that data collection will be done as part of the upcoming Farm Sustainability Data Network (FSDN), as specificized in the policy option, and which is the most likely way forward. At the time of this study, the initiative for converting the existing Farm Accountancy Data Network (FADN) into a FSDN is still ongoing and it is assumed that the Commission will adopt the initiative in the second quarter of 2022 63 . Quantitative estimations on costs for national authorities are presented in Table 12 below.

Table 12. Overview of quantitative estimations of costs for national authorities CCXXVI

Source: Ramboll, Study supporting the evaluation of Directive 2009/128/EC on the sustainable use of pesticides and impact assessment of its possible revision, Final report – impact assessment part, Luxembourg: Publications Office of the European Union, 2022, doi: 10.2875/074218

Additional costs will occur for the infrastructure. However, since data collection can build on existing processes and infrastructure, the only costs that occur are for adapting the current system. As found in a recent study on the costs for FADN data collection, although extending the collection of any type of data to the Member States that do not currently collect it would incur costs, there would be marginal to the basic data collection infrastructure already in place.

As said, under the current FADN, statistics from around 80,000 farms throughout the EU are collected annually and it is expected that this sample size remains somewhat stable. This represents only a fraction (0.8%) of the existing farms which report data annually. Between years, the turnover rate within the samples (i.e., the number of new sampled farms compared to the prior year) differs between Member States between 5% and 30%, with just over a third of Member States have a turnover of around 10%.

Those two metrics (sample size and sample turnover) of the FADN have an impact on the usability of the collected data for policy purposes. While not further specified in the policy option, the data could be used for policy reporting (e.g., for progress towards implementation of the SUD), within the policy cycle (e.g., for feeding into future revisions of the SUD or other IPM related policy frameworks) or for enforcement of the obligation of farmers to apply IPM. For the first two use cases, it can be assumed that the sample size and turnover are sufficient.

For the third use case, however, it can be assumed that the sample size and low turnover rate are not sufficient in addition to two supplementary factors: firstly, participation in the survey voluntary and secondly, the validation of data is mostly automated 67 . The first supplementary factor would be detrimental to the use of the data for enforcement. The second factor would imply that considerably higher costs could accrue for national authorities for applying additional plausibility checks to ensure proper enforcement. While the exact costs for this cannot be quantified because too many variables are unknown, it can be assumed that those costs would be considerably higher than the ones listed in Table 12 above.

3. Calulation of cost for developing crop specific IPM standards

Table 13 below shows the crop specific IPM guidelines that are already in place in the EU Member States.

Table 13. Development of IPM guidelines in the Member States

Source: EU Commission data based on 2017 web survey among Member States, complemented with audits and fact-finding missions (status as per 2021)

As can be seen, there are large differences between the Member States but that in general most Member States have already specific guidelines in place, some of which already meeting the target of 90% of the utilised agricultural area. However, it should be noted that there is no one definition of what an IPM guideline is and that there are major differences of how those can be and have been approached 68 . Thus, even if guidelines exist, in many Member States, there are large differences in what they define in detail.

The above should be seen as baseline to this policy option and defines the costs for the different stakeholders together with a crucial second factor which is the specific result this policy option aims to achieve. There are two main options in this regard.

National authorities and European institutions

A first possibility is that the policy option aims at improving IPM practice by providing specific guidance to farmers, accounting for the fact that the overall IPM principles are fairly general and hard to operationalise for farmers. To this end, crop-specific guidance could help farmers taking sensible decisions in their day-to-day work and improving the implementation of IPM. To this end and to improve effectiveness, it would likely be beneficial if the European Institutions could define minimum quality standards for crop-specific rules. Those would likely require at least parts of the existing guidelines to be revised. However, it can be expected that a large share of the existing catalogue of crop-specific guidelines could be maintained. In this case, the Member States which do not yet have guidelines in place would face costs for developing them.

The second possibility goes further than this by providing considerably more specificity of what a crop-specific rule is; i.e., by highly operationalising the guidelines to an extent at which they can be used a) as a concrete decision-making tool by farmers (e.g. in the form of a decision-tree) and b) as a basis for controls and enforcement.

This second possibility would likely cause higher costs for the Member State authorities since it is likely that they would have to revise the majority of already existing guidelines.

Professional users

The costs for the farmers cannot be defined since, even if they would have to adapt practices following specific guidelines, this will vary widely at rotation level per plot/field in addition to the crop level and with considerable differences across crops, regions, production types and even farmers within a region. In addition, since only very scarce data on the actual implementation of IPM at farm level exists, no baseline can be created.

In addition to potential costs, however, it can also be expected that this policy option would entail benefits for farmers due to the existence of guidance which to some extent can replace own research and potentially bad practices.

4. Calculation of costs for spot checks on IPM compliance

Direct economic impacts

Currently, as per results from the survey with national authorities, three countries already have a system in place to control implementation of IPM at farm level. This includes France which controls implementation of some IPM provisions; Belgium, which controls implementation of some IPM measures for a certification scheme on sustainable agriculture and other provisions as part of CAP cross-compliance checks; and Poland 69 .

Professional users

This policy option only concerns farmers and no other professional users. The costs for farmers for this policy option will depend on how the final framework for controls will look like.

It is not possible to foresee the fees to be charged by national authorities for these controls given that they would likely vary widely per country. However, as per Article 80 of the OCR, the fees would need to be cost based.

It should be noted that the OCR also foresees actions to be taken by competent authorities as well as penalties in the case of non-compliance. Those would, in case of non-compliance, pose costs for farmers. However, those costs, which are punitive or deterrent in nature, are not counted into the assessment of costs and benefits of this policy option.

Another aspect of potential costs for farmers stemming from this policy option which are not counted as part of the analysis are costs for farmers which so far did not comply with IPM standards and would change their practices to avoid penalties.

Another potential pathway for building on an existing mechanism for this policy option is by including the controls in the performance-based penalty system of the CAP. In the current CAP (until 2023), this is the cross-compliance mechanism; in the new CAP, starting in 2023, this will be replaced by conditionality. Controls under this mechanism would not create direct costs for farmers since the costs for the controls are borne by the public authorities. However, farmers could receive penalties in the form of reduced CAP payments. Again, those penalties do not count into the cost benefit assessment of the impact assessment, as well as the costs for changing practices. It should be noted that not all sectors/farmers receive CAP payments.

However, in any case the process needed for this policy option (creation of crop- and region specific IPM standards, preparation for recording, start of recording and submission of first data) can be expected to take a considerable amount of time before being operational. Thus, while it can be expected that this policy option is effective towards reaching the objective of improving measurability and monitoring of implementation of IPM (and through this the uptake of IPM), this would be rather in the long-term and it is unlikely that it will be instrumental in contributing to the two-pesticide related Farm to Fork targets which are to be reached by 2030.

For both pathways, farmers would also face costs due to time spent during the controls. However, it can be expected that those would be fairly low – for example, a study on administrative burden from certain rural development measures CCXXVII  found that on-the-spot checks only account for 2% 70  of all administrative costs that farmers face linked to CAP direct payments (while application for those payments account for almost 80% of all administrative costs). Thus, even if on-the-spot checks would become more time intensive due to additional cheeks of IPM implementation, those costs would overall be minor.

National authorities

For national authorities, the costs also depend on the final selected mechanism of this policy option. As mentioned, the costs for controls through the OCR are recovered from fees so eventually no costs would accrue.

For the inclusion of the IPM controls the national authorities would face some costs for additional time spent during on-the-spot checks. Quantitative estimations on costs for national authorities are presented in Table 14 below.

Table 14. Overview of quantitative estimations of costs for national authorities CCXXVIII

Also, for both pathways the competent authorities would face costs for training the controllers. Since it is unclear how complex the recording framework would be, it is not possible to calculate how much training would be required.

It should be noted that during stakeholder consultations it was brought up that incentives for good implementation of IPM might work better than penalties for lacking implementation of IPM since the latter might only get farmers to do the bare minimum in order to pass the checks.

5. Calculation of costs linked an independent advisory system

As mentioned earlier, advisors in the context of the SUD are defined in Article 3(3) as “any person who has acquired adequate knowledge and advises on pest management and the safe use of pesticides, in the context of a professional capacity or commercial service, including private self-employed and public advisory services, commercial agents, food producers and retailers where applicable”. Those advisors need to receive specific training (including on IPM) and a certificate on that training. 73  Below, the costs of this policy option for the different stakeholder groups are discussed against this baseline.

National authorities

In terms of cost for national authorities, there are costs for developing the more detailed training, rolling it out, and conducting it.

For developing the more detailed training and given that in a number of Member States the advisors already receive thorough training, and also given the need for crop- and region specific advice, it is unlikely that at European level new topics and detail could be added with relevance and added value for all of Europe. One possibility to add more detail to the training with relevance for all of Europe would be linking the additional training more specifically to the guidelines. The costs for doing so are discussed in that section.

For rolling out the training, it is assumed that only little cost would occur since almost all countries can build on a well-established training system into which the new training subjects can be integrated 74 .

In terms of costs for conducting the trainings, results from the member state survey have shown that in the majority of cases the costs are fully recovered through fees from the trained stakeholders 75 as can be seen from Figure 15 below.

Figure 15 Survey with national authorities: Please provide information on how the training and certification system is financed

Source: Ramboll study elaboration based on survey with national authorities

Given that in the majority of cases the costs are recovered through fees from the advisors, the costs for conducting the trainings are discussed below in more detail. In short, no numbers on the total numbers of advisors are available but it is estimated that an additional 7 EUR per advisor would accrue for this policy option for countries in which training is funded by public sources 76 .

Advisors

Through the survey with national authorities, respondents provided estimates on average training costs for advisors 77 . Table 15 below summarises the detailed replies.

Table 15Error! No style name given.. Estimates of training and certification costs for advisors in cases where the courses are fully financed through fees

Source: Ramboll study elaboration based on survey with national authorities

As can be seen, there are large differences between countries and complexity is added by different prices for basic and follow-up courses. However, based on the numbers, it can be assumed that the average for one training at European level is at around 200 EUR.

Costs for advisor training vary between Member States between 40 and 500 EUR. An average of 200 EUR per training is assumed.

Based on the information above, estimated costs of the policy option are presented in Table 16 below.

Table 16. Overview of quantitative estimations of costs for advisors CCXXIX

Source: Ramboll study

Professional users

It can be expected that direct cost of advisory services would increase for professional users, the estimation from France arrives at a total cost of 540 Euro per year for large farms and 180 Euro per year for smaller farms for the obligatory “strategic advice”. For more specific advice on treatment, it estimates 1.500 Euro annually for large farms and 300 Euro annually for smaller farms.

It is also assumed that the change would lead to a decrease of pesticide use overall (due to increased quality of the service and decoupling from commercial interest) which may balance the increased costs. In the French impact assessment it was estimated that farms could save up to 25% of their pesticide input costs, which would offset the additional costs for buying mandatory advice (it was estimated that French farmers spend approximately 10.000 Euro per year on pesticide on average, thus generating a net benefit of 2.500 Euro per year once strategic advice and specific advice has been fully implemented) 79 .

The costs from the change of the system could be partly balanced by higher subsidies or support to independent advisory structures.

6. Costs for PAE registration schemes

National authorities

Approaches vary widely in the existing registration systems in terms of governance and consequently the question of who bears the costs.

However, some costs would occur for national authorities for the creation of the national infrastructure (i.e. creation of a platform or integration of existing platforms and then maintenance) which would, however, be relatively low and thus it is not attempted to quantify them. Through case-based fact-finding, indicative costs for national authorities which have implemented a PAE register are presented below.

Table 17. Indicative costs for existing PAE registration schemes 80

Additional costs for national authorities depend again on the governance model. If (like in Spain) only newly acquired PAE would have to be self-registered by the owners, it would not create any further costs for the authorities.

If, however, it is part of the policy option (through a cut-off date or an additional provision) that all PAE have to be registered, including the existing stock, this would likely create additional costs for the national authorities. Different pathways taken to achieve this would again entail different costs. For example, if a survey is used (like in Spain) this would likely create some costs which are, however, expected to be low if done through online forms.

Other options could e.g. entail a specific campaign in which inspectors visit all farms to take stock of PAE which would create considerable costs. However, since this is not required as part of the policy option and there are more efficient and less costly ways, it is unlikely that any Member State would take this route.

Farmers and other owners of PAE

The costs for owners of PAE would to some extent depend on the governance structure selected by the respective national authority. However, since registration would only take very limited time and would be a one-off cost (either when buying new equipment or through a survey) those costs can be considered negligible.

7. Costs linked to annual reporting on national action plans

National authorities

The current provisions on NAPs require Member States to review their plans every five years (Article 4 Paragraph 2) and report on the harmonised risk indicators, trends in active substances, as well as other priority items to the Commission and the public (Article 15 Paragraphs 2 and 3). The policy option to report annually on the national action plans would add additional yearly reporting requirements on other elements of the NAP, including monitoring information on the Farm to Fork Strategy pesticide targets and the HRIs.

Direct economic impacts would arise for Member States to collect the information and report on it to the Commission. There would also be a possibility of yearly reporting to the public in individual Member States.

Table 18. Overview of quantitative estimations of costs for national authorities

Impacts on Member States depend on the current reporting system of the country. Based on the survey responses made by national authorities, Member States can be grouped into two categories 81 :

·Ones that already have national reporting obligations and therefore do not expect substantial additional costs, and

·Ones that do not presently report at such frequency and therefore expect relevant additional costs for relevant authorities.

The first group is smaller and comprises Belgium, Czechia, Denmark, Germany, France and the Netherlands. These Member States see only minor additional costs as long as the reporting covers high-level information on the elements of the NAPs and indicators based on sales data. Should, however, detailed requirements be made, or a translation to English be required, costs would also arise for these Member States.

In the remaining Member States, structures for annual reporting would have to be established. This would lead to additional human resources needed for the collecting the data and drafting the report. Nine Member States indicate the additional burden this would cause is substantial but not directly quantifiable. Yearly reporting is assumed to be less labour-intensive than revising the NAP, but due to data collection and reporting, considerable work is still needed. Therefore, the time assumption is made at the lower end of the spectrum of estimations for the evaluation and revision of a NAP. Thus, 0.5 FTE are assumed to be needed in 20 Member States (building on the fact that some Member States already have reporting mechanisms but those were more likely to reply to the survey).

Professional users

As the monitoring of certain measures of some NAPs is based on surveys with professional users, additional time requirements would arise for these as well, if yearly surveys would be needed. Only one Member State indicated this concern in the survey, but others may not have such a system yet, because systematic monitoring and reporting is not undertaken. The costs are therefore difficult to quantify. However, they would be driven by the measures of the NAP, the time needed to respond to such a survey and the number of farmers in that Member State.

In case of a survey to professional users, a combination of two elements is assumed based on the existing mechanism in place in Sweden:

·a short online questionnaire on elements such as PAE used or storage of pesticides that takes about 15 minutes to complete, and

·an extensive survey followed by an interview on pesticides used, crops, doses, etc., which in total requires 2.5 hours to complete.

Table 19. Overview of quantitative estimations of costs for professional users

8. Costs linked to electronic record-keeping

Electronic record-keeping for the collection of data from professional pesticide users regarding pesticide use is currently in place in six Member States, according to the targeted survey to Member State authorities. A further six Member States noted that record-keeping systems are under implementation.

Evidence gathered during the evaluation of the study uncovered that under Article 67 on Regulation (EC) No 1107/2009, professional users are required to keep records, however the process is not automated, and data are not collected in electronic format in one system. Therefore, it can be the case that use data is currently being recorded at the farm level, however there is a disconnect from the farm to national level and national level to EU level.

Professional users

In understanding the direct economic costs to professional users, it is useful to examine the impact from two processes: [1] the recording of data and [2] the transfer of data onto an electronic system. Under the first process, given that users are already required under Article 67 of Reg. 1107/2009 to record such information, the direct economic cost from the implementation of this option would be comparable.

On the transfer of data, evidence from countries which already collect use data often have in place a strong advisory service network thus reducing the time for users to upload data, as well as ensuring that the data that is uploaded is accurate. Thus, for those countries which already report the data at the national level, the direct economic impact would remain the same. The cost per hour is based on the EU average of 12 EUR per hour for an agricultural worker. Overall, while some Member States (BG, DK, FI) noted an increased administrative burden, the current data outlines minimal extra costs for users to provide the data to the national authorities.

Furthermore, on the assumption that most of Member States have in place a form of advisory service that could assist with reporting, it could be assumed that the costs to report the data would be low. However, if such services are not available, this could require greater time for the user to report, thus increasing the direct economic impact.

Table 20. Cost estimates for reporting use data across selected countries by users through surveys

Source: Eurostat. 2018. Pesticide use in agriculture (aei_pestuse) - National Quality Reports. [online] Available at: https://ec.europa.eu/eurostat/cache/metadata/en/aei_pestuse_esms.htm

National Authorities

Estimates on the development of an electronic system were provided in the region of 500,000 EUR by two Member States while monitoring ranged from two full time employees to a sum of 100,000 EUR. The divergence in these estimates and the lack of comparable estimates means that these figures should be treated with caution and only seen as indicative.

Using figures from quality reports of use data submissions by Eurostat, the total cost of conducting data collection (most commonly through surveys) is estimatedr period as being between 125,000 EUR – 209,800 EUR, thus averaging 25,000 EUR – 42,000 EUR per year.

EU Institutions

With regards to the impact on EU institutions, no quantitative assessment was possible, however on the basis of informed assumptions, the impact is foreseen to be minor. On the basis that the EU’s statistical body, Eurostat, already collates data on the use of pesticides, it is assumed that an increase in the volume of data being transferred would only lead to a minor impact.

Annex 5: Relevant background analysis and other relevant policy initiatives of the commission

Modelling and Estimates of the effect of Green Deal and Farm to Fork Strategy targets in the EU

Several recent publications have tried to provide estimates of the impacts of achieving the Farm to Fork Strategy targets, including the pesticide reduction targets which are within the scope of this impact assessment. The publications include computable general equilibrium models (Beckman et al. 2021) CCXXXI ; partial equilibrium models for the agricultural sector (Barreiro-Hurle et al. 2021 CCXXXII ; Bremmer et al. 2021 CCXXXIII ; Henning et al. 2021 CCXXXIV ), extrapolation of assumptions to actual market data (Noleppa and Carstburg, 2021 CCXXXV ; COCERAL, 2021 CCXXXVI ) or simulation of assumptions with farm level data (Guyomard et al. 2020 CCXXXVII ). None of these publications can be considered a fully-fledged impact assessment of the policy, but their results provide some insights into the economic impacts of policy decisions limiting the use of plant protection products.

These assessments, in general terms, introduce an assumption on the change in farming practices from reducing plant protection product use and its related impact on yields. For example, Barreiro-Hurle et al. (2021) consider a reduction in costs associated with the lower use of plant protection products, assume an increase in other costs to reflect increased mechanical weeding, and consider an increase in the use of cover crops as a pest management alternative. As expenditure for pesticides is included in the cost function of the economic model used for the analysis, but there is no associated yield response function, an exogenous yield loss of 10% is introduced to simulate the effect on production of a 50% target reduction in pesticide use 83 . Similar approaches are used by all the other analyses published. As the actual targets refer to reduction in use and risk of plant protection products, the translation of this to expenditure is, at best, a very crude measure.

The range of impacts reported is large, but in general (and with the exception of the USDA study, where an assessment cannot be made of the effect of pesticides alone) the impact of reducing plant protection product use is that of a reduction in production in the EU with associated reductions in net exports (i.e. higher imports and lower exports). Some of these supply-side impacts could be readily mitigated by additional actions on the demand side such as food waste reduction, added value chains for sustainable food, etc. Moreover, the simultaneous achievement of different policy targets shows that some of these (e.g. increased land under high-diversity landscape features) can ease the achievement of the reduction in plant protection products use and risk.

Leaving aside the imperfect representation of the pesticide reduction target in the models, in order to fully capture the impact of this target, other changes that are likely to happen by 2030 in absence of policy and other induced changes due to the extensive support actions announced under the Farm to Fork strategy to support the implementation of these targets should be included. For this reason, the mentioned studies qualify their results as an upper-bound of the expected production impacts of meeting this target on the agricultural sector. As the analysis of Barreiro-Hurle et al (2021) also tries to capture the contribution of aligning the CAP support to the Farm to Fork Strategy targets and the impact of Next Generation EU 84  (NGEU) funding, it is further outlined how this can be used to revise the magnitude of the impact of plant protection products use reduction on the agricultural sector in more detail.

JRC study “Modelling environmental and climate ambition in the agricultural sector with the CAPRI model”

Published in 2021 CCXXXVIII  the JRC study models the impact of the four Farm to Fork Strategy targets together on a range of indicators including production, price and land use, with data provided for a range of different crops and animal products. The impact of achieving these targets is analysed assuming different CAP implementations; a continuation of the CAP 2013-2020 implementation, an implementation of the 2018 Commission CAP legal proposal in which countries which aim for a higher environmental and climate ambition, and one adding to the latter the potential impact of the NGEU funds for the agricultural sector.

The study concludes that the four targets together can achieve a significant positive environmental impact. The environmental impacts reported are restricted to greenhouse gas, ammonia and nitrogen emissions. The analysis does not attempt to quantify any secondary health benefits derived from lower emissions (e.g. reduced mortality and morbidity) 85  or plant protection product use CCXXXIX . The study makes some statements of the potential for leakage of issues to third countries, specifically for greenhouse gas emissions, but acknowledges that the model considers only the EU acting in isolation and does not consider the actions taken in international agreements, support for third countries and the complementary actions of international organisations. The corollary from achieving these targets is the impact on domestic production due to the assumed reductions in yields.

The study transparently acknowledges that there are limitations in these conclusions as they are based on broad assumptions. First, and most importantly, as plant protection products are considered in monetary terms, the baseline projection does not fully capture the starting downward trend in the HRI 1 observed in recent times. Secondly, the long list of supporting actions (with the exception of the CAP) that will support this transition (such as bringing new substances on the market, the market for sustainable foodstuffs, reducing food waste, etc.) are not incorporated into the analysis. Lastly, the study report presents results for all four Farm to Fork Strategy targets taken together and, for this reason, does not capture the synergies between the four targets. These three issues are addressed in turn below.

Taking first the issue of the baseline, the JRC study simulates a cut in pesticide use and risk of 50% with respect to the baseline counterfactual, implying that in the absence of a policy measure, the level of pesticide use would be the same in 2030 as in the 2015-17 reference period. However, there has been a clear downward trend over the last decade.

Table 21 below presents the sales of pesticides per Member State for 2018 and 2019.

Table 21. Sales of pesticides per EU Member State CCXL