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Document 52021DC0790
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Regulation (EC) No 1185/2009 of the European Parliament and of the Council of 25 November 2009 concerning statistics on pesticides
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Regulation (EC) No 1185/2009 of the European Parliament and of the Council of 25 November 2009 concerning statistics on pesticides
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the implementation of Regulation (EC) No 1185/2009 of the European Parliament and of the Council of 25 November 2009 concerning statistics on pesticides
COM/2021/790 final
EUROPEAN COMMISSION
Brussels, 14.12.2021
COM(2021) 790 final
REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL
on the implementation of Regulation (EC) No 1185/2009 of the European Parliament and of the Council of 25 November 2009 concerning statistics on pesticides
1.Introduction
1.1.Background
Regulation (EC) No 1185/2009 1 (the ‘Regulation’) establishes a common framework for European statistics on pesticides. It covers statistics on the marketing of pesticides (‘statistics on pesticide sales’) and statistics on the agricultural use of pesticides. Under Article 7 of the Regulation, the Commission is required to submit a report on its implementation to the European Parliament and to the Council every 5 years. This report evaluates in particular the quality of the data transmitted, the methods used to collect the data and the burden this poses on businesses, agricultural holdings and national administrations. It also examines the extent to which these statistics are useful in deploying the strategy on the sustainable use of pesticides, and in particular, in meeting the objectives set out in Article 1 of the Regulation. It contains proposals for further improving data quality and data collection methods that in turn help to improve the coverage and comparability of data and reduce the burden on businesses, agricultural holdings and national administrations.
European statistics on pesticides serve in particular the purposes of Articles 4 and 15 of Directive 2009/128/EC 2 . Moreover, the Regulation has a strong link to Regulation (EC) No 1107/2009 3 and, in particular, Article 67, which lays down certain reporting and record keeping obligations concerning the placing on the market and the use of pesticides.
This is the second report on the implementation of the Regulation and it covers the reference years 2015-2019 for both pesticide sales and agricultural use of pesticides. Adopted in 2017, the first report 4 covered the reference years 2011 to 2014 for pesticide sales, and the reference period 2010 to 2014 for the agricultural use of pesticides.
1.2.Developments at EU level since the last report
In May 2019, Commission Directive (EU) 2019/782 5 establishing harmonised risk indicators to estimate the trends in risks from pesticide use was adopted. This Directive establishes harmonised risk indicators as referred to in Article 15(1) of Directive 2009/128/EC. Harmonised risk indicator 1 (HRI 1), which measures the use and risk of pesticides, is calculated by Eurostat using the pesticide sales statistics collected under the Regulation and the grouping and hazard weightings stipulated by the Commission Directive.
In May 2020, the Commission adopted the ‘Farm to Fork Strategy – for a fair, healthy and environmentally-friendly food system’ 6 . This strategy aims to accelerate the transition to a sustainable food system. It includes a target to reduce the overall use and risk of chemical pesticides by 50% and the use of more hazardous pesticides by 50% by 2030. In the strategy’s action plan, the Commission proposed revising the Regulation to fill data gaps and reinforce evidence-based policymaking.
In February 2020, the Court of Auditors published a report on the ‘Sustainable use of plant protection products’ 7 which assessed whether the actions of the Commission and Member States had led to a reduction in the risks related to the use of plant protection products (PPPs) and whether the relevant legislation provided effective incentives to reduce dependency on PPPs. The report included a number of recommendations to the Commission concerning statistics on pesticides:
·improve access to PPP statistics;
·remove restrictive aggregation requirements for PPP statistics (Article 3(4) of the Regulation) to allow publication of more useful statistics (e.g. low-risk PPPs and active substances with specific properties);
·clarify, improve and harmonise the requirements for EU statistics on the agricultural use of PPPs (Annex II of the Regulation) to make it more available, comparable and useful (timeframe 2023).
The legal instrument chosen to address the improvements needed is the legislative proposal for a Regulation on statistics on agricultural input and output (SAIO) adopted by the Commission on 2 February 2021 8 . This proposal covers agricultural statistics on crops, animals and agricultural prices, nutrients and organic production, as well as the sales and agricultural use of plant protection products. It will repeal the Regulation when in force.
2.Coverage and content
According to Article 2 (a) of the Regulation, ‘pesticides’ refer to ‘a plant protection product’ (PPP) as defined in Article 2(1) of Regulation (EC) No 1107/2009 or to a biocidal product used as a PPP as defined in Article 2(1) of Directive 98/8/EC. They are grouped into the following categories:
·fungicides and bactericides
·herbicides, haulm destructors and moss killers
·insecticides and acaricides
·molluscicides
·plant growth regulators
·other plant protection products.
The list of active substances was updated for reference year 2016 by Commission Regulation (EU) 2017/269 9 . Substances approved between 2011 and 2016 were included in the data collection, while some substances were classified differently (for example, changed from the major group ‘Insecticides and acaricides‘ to ‘Other plant protection products’, or from the latter major group to ‘Fungicides and bactericides’). This introduced a break in the time series. The Commission (Eurostat) and the Member States are working to create a harmonised dataset over time.
The Regulation stipulates that the Member States 10 have to transmit annually to the Commission (Eurostat) their statistical data on pesticides placed on the market each year (pesticide sales statistics). In addition, they have to provide statistics on the agricultural use of pesticides in five-year periods. This report refers to the data and quality reports transmitted for reference years 2015 to 2019 inclusive.
Two major drawbacks stem from the stipulations of the Regulation. The data aggregation requirements of the Regulation (Article 3(4)) make all active substance level data non-publishable. This has a drastic impact on the data availability. Another major drawback of the current data collection is the lack of harmonisation of the pesticide use data: Member States can freely choose the reference year in the five-year period (2015-2019) and a list of crops they deem representative of their national circumstances.
2.1.Coverage
2.1.1.Statistics on pesticide sales
Under the Regulation, EU Member States, Iceland and Norway have the obligation to send statistics on pesticide sales before 30 December of the year N+1 and national quality reports before 31 March of the year N+2. Switzerland, Montenegro and Turkey transmit data and quality reports on a voluntary basis.
2.1.2.Statistics on the agricultural use of pesticides
Under the Regulation, EU Member States, Iceland and Norway (for the purposes here referred together as “Member States”) are obliged to send data and quality reports on the agricultural use of pesticides for selected crops within 12 months of the end of each five-year period. The second five-year period ended on 30 December 2019 and countries were obliged to transmit data and quality reports until 30 December 2020. The selection of crops must be representative of the crops cultivated in the Member State and of the substances used. The reference period is a period of a maximum of 12 months covering all plant protection treatments associated directly or indirectly with the crop.
2.2.Data collection methods and sources
According to the Regulation, Member States can use different means for collecting the necessary data. Member States can use surveys, information concerning the placing on the market and use of pesticides stemming from the obligations pursuant to Article 67 of Regulation (EC) No 1107/2009, administrative sources or a combination of these means, including statistical estimation procedures based on expert judgements or models.
2.2.1.Statistics on pesticide sales
For most of the Member States underlying primary data on pesticide sales are derived from administrative sources for which reporting is obligatory: Article 67(3) of Regulation (EC) No 1107/2009 stipulates that authorisation holders have to provide the competent authorities of the Member States with all data relating to the volume of sales of plant protection products in accordance with EU legislation concerning statistics on plant protection products. Several countries use other data sources such as census and (sample) surveys, or a combination of administrative and other sources. More information on national practices can be found in the national quality reports 11 .
2.2.2.Statistics on the agricultural use of pesticides
Statistics on the agricultural use of pesticides are generally based on statistical surveys of farmers. In some countries, a census is carried out on farms above a set threshold of hectares or based on the expected turnover of the farm. Only in exceptional cases are other data collection methods used: two countries use existing administrative data on pesticide use, two countries use the data from the Farm Accountancy Data Network (FADN), two countries extrapolate the use from the pesticide sales data and one country uses a scientific study based on the amounts of pesticide residues in ground water stations.
In some cases, the information is collected using electronic means such as online surveys or using farm management software. However, several countries pointed out that electronic means could not be used. The main methods countries used for data collection are paper questionnaires (7 countries) followed by face-to-face interviews (6 countries) as well as phone interviews and electronic questionnaires (4 countries each), or a combination of methods. Other methods are digital recordings by users through webpages, direct constant access to data in databases, computer-assisted telephone interviews and computer-assisted web interviews. More information on national practices can be found in the national quality reports 12 .
2.3.Quality of the transmitted data
While Member States are responsible for the quality of pesticide statistics, the Commission (Eurostat) takes the necessary measures to detect errors in the data it receives. Member States transmit information on all active substances and all aggregates of the code list 13 , including confidential data, via the single entry point (EDAMIS portal), complying with the requested file structure and record format. The technical arrangements for data transmission apply a high level of standardisation. The Commission (Eurostat) maintains a reliable IT system for data reception, validation and processing and performs several types of data checks: completeness and consistency of each country’s reporting questionnaire, verification of aggregations of pesticide volumes, and a time series check of the development over time. The Commission (Eurostat) also applies manual checks on secondary confidentiality before disseminating the statistics and asks countries to send revised data for any errors detected.
2.3.1.Statistics on pesticide sales
Most Member States continued to provide their data sets on time and cooperated well when further checks or corrections were required. Concerning accuracy, reliability, and comparability, most countries confirmed that their primary pesticide sales data were collected from the authorisation holders. They considered that the data supplied from those sources were of good quality overall.
The Member States reported taking measures to ensure the statistical quality of their data: comparison of quantity data to previous year data, comparison with external data sources, control of reliability of declared quantities and products, control of abnormal and missing quantities and random checks. They also reported applying the provisions of the European Statistics Code of Practice 14 .
2.3.2.Statistics on the agricultural use of pesticides
Most countries provided their data sets on time and reacted quickly to requests for further checks and/or corrections. One country delivered the data several months late.
Concerning accuracy, reliability, and comparability, most Member States considered that the data supplied was good. Most countries consider that the quality of the data is stable since the publication of the first report in 2017. Six countries reported overall improvement of the quality of the statistics. Only one country reported that the comparability of data had deteriorated.
The area treated with pesticides is not easy to sum up because of the aggregation requirement of active substances in chemical classes. If active substances belonging to the same chemical class or group are applied on the same physical area, the correct summing up of the area without double counting can only be done if the survey is designed taking this into account. More than half of the countries cannot guarantee having excluded double counting of the crop areas treated with pesticides, which limits the possibilities of disseminating the area-treated data. This area aggregation can only be done by the national statistical authorities, because detailed parcel level information is needed.
3.Relevance – Usefulness of the statistical data and dissemination
Eurostat publishes two datasets on pesticide statistics in its dissemination database: sales and the agricultural use of pesticides 15 . The data aggregation requirements of the Regulation (Article 3(4)) stipulate that the Commission (Eurostat) cannot publish any data on active substances.
Due to the data aggregation requirements and complex confidentiality issues, the Commission (Eurostat) initially disseminated only statistics on pesticide sales on the highest hierarchical level defined in Annex III of the Regulation: ‘major group’ (disseminated since 2013). The next hierarchical level, ‘category of products’, was added in 2018 and ‘chemical class’ in 2021. Hence, the availability of the data has improved since the previous reporting period.
The published pesticide statistics are still affected by confidentiality restrictions. These are related to the statistical confidentiality as defined by Regulation (EC) No 223/2009 16 and refer to data which allow statistical units to be identified, either directly or indirectly, thereby disclosing individual information. The impact of statistical confidentiality varies, depending on the Member State, the type of pesticide and the year. This is linked to the structure of the pesticide industry and agriculture in the country. For the period 2011-2019, data on less than 1% of the total volume sold is confidential.
Several Member States disseminated pesticide sales statistics nationally, without any confidentiality applied. The Commission (Eurostat) facilitates access to the national statistics by providing the web links to the national pesticide statistics in the annex to the European metadata file 17 .
It is very challenging to publish statistics on the agricultural use of pesticides due to aggregation requirements, lack of harmonisation of reference years and crops and the ‘treated area’ concept;
·The Regulation stipulates that each country has to cover selected crops and related active substances representative of their agriculture and not all crops and pesticides used in the country. For a single reference year, the number of crops reported on by a single country ranges from 2 to 51. Around 150 different crops have been surveyed in total 18 . The Commission (Eurostat) has issued a crop-harmonisation proposal in order to improve the comparability of the data for the reference period 2020-2024. However, it is up to the countries to decide whether they want to follow the proposal.
·The countries can choose a reference year within the 5-year period stipulated by the Regulation. Some countries reported data from 1 out of 5 reference years, others reported from all 5 reference years (different crops).
·The area treated with pesticides is not easy to sum up because of the aggregation requirement of active substances in chemical classes, as mentioned above in Section 2.3.2.
All these factors substantially limit the comparability and usefulness of data on the agricultural use of pesticides.
In 2019, the Commission (Eurostat) published a research paper on the data on the agricultural use of pesticides 19 . This research paper summarised the main results and challenges of the data collection. The data set for the five-year period 2010-2014 was published in 2020, and the period 2015-2019 was added in 2021. From the beginning, this dataset contained all three hierarchical levels: major group, category of products and chemical class. The treated areas (hectares) could not be disseminated at all for the first five-year period, as double counting could not be excluded. For the second five-year period, the treated areas could only be disseminated from countries that could guarantee that the area was counted only once (11 countries). For all other countries, only the quantity of pesticides (kilograms) is disseminated.
The reporting unit (kilograms of active substance) hampers the publication of microbiological pesticides, as there is no harmonised way to convert the more suitable units for microbiological pesticides (colony-forming unit (CFU) or international unit (IU)) into kilograms. Due to these conversion problems, the microbiological substances are not included in the disseminated data (sales or agricultural use). This limits the possibilities for monitoring the use of these active substances.
The Commission calculated and published harmonised risk indicator 1 20 based on the pesticide sales statistics following the obligations set out in Article 15(1) of Directive 2009/128/EC and Commission Directive (EU) 2019/782. These statistics are also used to monitor the farm to fork strategy targets on reducing the overall use and risk of chemical pesticides and the use of more hazardous pesticides 21 .
The main users of pesticide statistics in the European Commission are the Directorate-General for Health and Food Safety, the Directorate-General for Agriculture and Rural Development, the Directorate-General for Environment, and the Joint Research Centre. Other users of pesticide statistics are national authorities, researchers, the business sector, NGOs, students and the public. The statistics are used to measure progress in reducing the risk from the use of plant protection products, together with other relevant data.
The data users have repeatedly pointed out the need for more available data, i.e.:
·data on active substances in pesticides for sale and agricultural use;
·harmonised and more frequent data for the agricultural use of pesticides: same crops and annual data collection; and
·more detailed spatial-level (regional) data for agricultural use.
The Commission is working to improve the availability and quality of the data (see further details under Section 5).
4.Cost and burden
4.1.Cost
The national statistical institutes and other statistical authorities have estimated the global annual cost 22 of collecting data on pesticide sales and the use of pesticides in agriculture to be around 4.7 million euro for 23 EU Member States and Norway. In addition, it involves about 43 persons labour input (in full-time equivalents). The median figure per country is EUR 53 000 and one full-time equivalent labour force. The reported cost and labour force is rather limited in most countries.
4.2.Burden
The burden on respondents (authorisation holders for pesticide sales and agricultural holdings and other professional users active in the agricultural sector for the agricultural use of pesticides) and national administrations vary, depending on the data collection method chosen.
The countries reported that the burden on authorities and respondents for the pesticide sales data collection is relatively small, as the authorisation holders have an administrative responsibility to report to the competent authorities the sales of all active substances placed on the market. The statistics are in most cases a by-product of this administrative process.
For the agricultural use of pesticides, the situation is different: under Regulation (EC) No 1107/2009, all professional users are required to keep records on their use of pesticides. This information should, in principle, be available upon request. However, several issues make their use for statistics very challenging: the records are kept at farm level; they are rarely harmonised; and they can be kept in any format (paper or electronic). Because of this, most national statistical authorities have opted for organising a statistical survey.
The countries using statistical surveys reported different levels of burden on respondents, ranging from a few minutes (small farms using electronic reporting) to three hours (larger farms using paper questionnaires). Even for countries carrying out statistical surveys, the additional burden on respondents is reasonable, as in any case the professional users are obliged to keep records on the use of pesticides. For the seven countries using the administrative records on pesticide use, the FADN data, expert estimates or scientific modelling, there is no additional burden on respondents.
Compared to the first five-year period, several countries reduced the burden through various measures: more user-friendly questionnaires (6), easier data transmission (5), less variables surveyed (3), multiple use of the collected data (3), other (3). Eight countries reported not having applied any measures to reduce the burden since the previous quality report (5 years ago).
For efficiency gains, most of the countries reported efficiency gains due to further automation (11), an increased use of administrative sources (5), online surveys (5), further training (4) and other measures (5). Ten countries reported no change since the previous quality report (5 years ago).
5.Proposals for further improvements
The Commission is updating the list of active substances for which statistics should be reported (Annex III of the Regulation) in 2021 in accordance with Article 5(3) of the Regulation 23 . The proposed amendment includes several aggregations of active substances classified according to the groups and categories of the harmonised risk indicators 24 , and voluntary reporting on the placing on the market of pesticides according to the intended sector of use (agriculture, forestry, amenity areas and storage). A large majority of the Member States have indicated that reporting the sector of use is currently not feasible for the statistical authorities because the data is not available. With this legal update, the Commission intends to improve the availability of pesticide statistics under the present legal framework.
In 2016, the Commission evaluated the statistics on pesticides as part of the overall evaluation of agricultural statistics 25 and subsequently launched the ‘Strategy for Agricultural Statistics for 2020 and beyond’ 26 . This is a major programme the Commission has launched in close cooperation with Member States to modernise EU agricultural statistics.
As part of this modernisation process, the Commission put forward a legislative proposal for a Regulation on statistics on agricultural input and output on 2 February 2021. It will repeal Regulation (EC) No 1185/2009 when adopted. With this proposal, statistics on the agricultural use of pesticides would be collected every year and not only every 5 years, as is the case now. The proposal does not include any compulsory data aggregation requirements for published data. This change would make the active substance level data available. However, the statistical confidentiality in accordance with Regulation (EC) No 223/2009 will apply when relevant. The legislative proposal is currently under interinstitutional negotiations between the European Parliament and the Council. The Regulation on statistics on agricultural input and output covering also pesticide statistics is expected to be adopted in 2022 and would apply from 2024 onwards.
The Commission is working to improve, in general, data reporting on the use of pesticides. Several initiatives are being prepared to make more statistics available and, in particular, to harmonize pesticide use records and make them available in electronic format to authorities so. It is expected that they can be used to better manage related policies. These efforts are being made in cooperation with other Commission departments.
6.Conclusions
Statistics on the sale and use of pesticides in agriculture have been collected and published for pesticide sales since 2011 and for the agricultural use of pesticides for two 5-year data collection rounds 2010-2014 and 2015-2019. The availability and quality of the data have improved since the previous Commission report in 2017 both for pesticide sales and for the agricultural use of pesticides. More than half of the Member States have made data collection more efficient and less burdensome for the respondents.
However, the same problems observed in the first report still persist:
·The data aggregation requirements of the Regulation (Article 3(4)) prevent the publication of all active substance-level data. This has a detrimental impact on data availability.
·Lack of harmonisation of the data on pesticide use: Member States can freely choose the reference year in the five-year period and a list of crops they consider representative of the national circumstances.
·Availability of data on pesticide use in agriculture only every 5 years.
·Avoiding double counting of the crop areas treated with active substances on higher hierarchical pesticide levels is a methodological challenge.
·Lack of availability of administrative data on the professional use of pesticides in most Member States: professional users are required to keep records, but they are not harmonised and rarely kept electronically.
·No proper solution has been found for converting microbiological substances into kilograms. This keeps microbiological pesticides from being disseminated and monitored.
The Commission is taking action to overcome these disadvantages of pesticide statistics:
·The Commission proposal for a Regulation on statistics on agricultural input and output put forward on 2 February 2021 will incorporate pesticide statistics: no dissemination restrictions are proposed, and the periodicity of agricultural use statistics would be increased from once every 5 years to once a year. This proposed Regulation is currently in the co-legislation process and is expected to be adopted by the European Parliament and the Council in the course of 2022 and be applicable from 2024 onwards.
·The Commission and the national authorities are cooperating closely to make the records on the professional use of pesticides more harmonised and available for statistical authorities in electronic format.
·Technical and methodological exchanges with the Member States are continuing in the form of meetings, webinars and written exchanges.
Commission Regulation (EU) 2017/269 of 16 February 2017 amending Regulation (EC) No 1185/2009 of the European Parliament and of the Council concerning statistics on pesticides, as regards the list of active substances (OJ L 40, 17.2.2017, p. 4).