July 2015 ECPA’s views on Private standards and certification schemes for crop value chains The crop protection industry fully supports the principles of sustainable agricultural production, including the responsible and efficient use of natural resources, using technological innovation to help farmers deliver profitable and high quality produce. We believe that only standards or certification schemes which support the responsible use of natural resources and technical tools in line with good practices and IPM principles are appropriate means of ensuring sustainable production methods and high quality produce. The setting of private standards and certification schemes which arbitrarily restrict or ban the use of legally authorised pesticides is inappropriate, counter-productive and runs contrary to the aims of sustainable and integrated crop production. Why are private standards and certification schemes inappropriate? Private (secondary) standards or certification schemes which either ban or restrict the use of certain legally authorised pesticides, restrict the number of active substances or operate below the legally authorised limits for pesticide residues are unnecessary in an already robust and risk-averse EU regulatory system. Before they can be authorised for EU use to protect our food against pests and diseases, pesticides must undergo and pass a range of stringent tests and assessments to comply with the high safety standards set under EU legislation. This regulatory process is obligatory and binding. Based on decades of scientific experience and relevant new developments, these tests and assessments look for, among other factors, effects on the environment (incl. plants, birds and mammals) and human health. In the case of pesticide residues in food, safety is rigorously assessed across a full range consumer groups and dietary habits. Firstly assessed by a Member State, then by the European Food Safety Authority (EFSA) and finally agreed by all Member States, the EU’s legally binding framework ensures the highest protection of human health and the environment. Once the process is successfully completed, the pesticide in question is authorised and is deemed safe for commercial use when applied in accordance with Good Agricultural Practice, as defined in the terms of the authorisation. Establishing individual private standards or certification schemes undermines industry and public confidence in the existing science-based European approval process. Such an approach, based on the limitation or prohibition of a certain technology is producing distortive and potentially destructive effects. The setting of such individual private standards or certification schemes can: •
Endanger the production of a large variety of high quality fruits and vegetables.
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Confuse consumers and create unjustified fears concerning the quality and safety of foods.
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Undermine existing and generally accepted good practices, including Integrated Pest Management (IPM), which aim to optimise and safeguard crop production.
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Create uncertainty as to which pesticides can be used by producers and consequently endanger the good functioning of the EU internal market.
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Expose the farmer to harvest losses, higher production costs and loss of profit.
Conflict with the overall principles of sustainable agriculture and IPM, where all methods, cultural, physical, biological and chemical, are adopted to prevent or manage pests. Conventional pesticides continue to play a vital role in IPM schemes. By placing additional, non-statutory, constraints on the use of pesticides, private standards will erode the valuable contribution that pesticides make to sustainable food production. This is not the way forward for Europe.
The withdrawal of many of the non-scientific private standards and certification schemes would remove confusion and potential for market distortion. This would allow the food chain to focus on continued improvements to ensure the supply of sustainable, safe and affordable food. ECPA members are committed to working with the entire supply chain to improve communication and wider adoption of best practices designed with producers wishing to trade in the EU. ECPA will continue its efforts to promote best practices within and beyond the EU with its ‘Hungry 4 Change’ programme1. ECPA advocates engaging with those private standards and certification schemes which support sustainable agricultural principles as an appropriate means of ensuring high yielding and high quality crops. Support will be given to the responsible use of natural resources and technical tools, in line with good practices and IPM principles. ECPA supports global schemes (e.g. GlobalGAP, QS, etc.) which are based on EU legally binding rules, commonly agreed science-based criteria, discussed and agreed in an open way through consultation with all relevant stakeholders. These schemes are also assessed and controlled via experts and support the implementation of the European legal and regulatory framework, working towards a transparent framework which is cost-effective and easier for growers to adopt and comply with. ECPA agrees with and supports the European Commission’s views on private standards as discussed in a Commission Communication2 on best practice guidelines for voluntary certification schemes. It states that private standards should not prejudice or aim to replace existing official standards, nor discredit the safety of other products on the market or the reliability of official controls3. Furthermore, all claims should be based on objective evidence and scientifically sound documentation, which should be made openly available4. In conclusion, Europe’s crop protection industry considers those private standards and schemes, which impose restrictions on pesticide use and go beyond the conditions already set by a robust EU regulatory system, are superfluous and divisive. ECPA will continue to support the principles of sustainable agricultural production and the safe, responsible use of pesticides as vital tools in achieving the global food demands of the future.
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http://www.hungry4change.eu/ Commission Communication — EU best practice guidelines for voluntary certification schemes for agricultural products and foodstuffs 2010/C 341/04 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2010.341.01.0005.01.ENG 3 Ibidem 3.2 4 Ibidem 5.2 2
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