Effects of the planned withdrawals of plant protection
In the European Union, legislation concerning the use of plant protection products has become increasingly strict over recent years. The original hazard-based assessment has been replaced by the risk-based approach, meaning that the authorisation and/or exclusion of any active substances in plant protection products are no longer made on the basis of comprehensive evaluation of hazard factors; rather certain cut-off criteria are examined. Several active substances have been withdrawn and the decision-makers are planning the withdrawal of further active substances. The potential for significant increase in the number of active substances withdrawn, and the consequences of such, must be taken into consideration.
The new authorisation system may have serious consequences. Without efficient options being available plant protection may become completely unviable, therefore this in turn shall jeopardize agricultural production, and as a consequence food supply.
The pesticide manufacturers and importers association commissioned the Kleffmann Group (agricultural market research & consulting services) to make an impact assessment report with the participation of well-known weed biologists, phyto-pathologists and entomologists on the anticipated effects of the planned withdrawals of plant protection products on the Hungarian agricultural production in three crop species: winter wheat, sunflower and maize.
The report covers the effect of three planned regulations and the possible consequences of an already effective regulation:
- Commission Staff Working Document Impact Assessment for Defining criteria for endocrine disruptors (15.06.2016) – the report analyses the possible effects of options 2 and 4 of the planned regulation
- Commission Implementing Regulation (EU) 2015/408 which contains the list of candidates for substitution (11.03.2015)
- Commission Implementing Regulation (EU) 2016/1056 as regards the extension of the approval period of the active substance glyphosate (29.06.2016), extending its validity until 31 December 2017
- Commission implementing regulation (EU) No 485/2013 as regards the active substances based on neonicotinoid chemistry suspending the use of plant protection products containing clothianidin, thiamethoxam or imidacloprid for seed treatment in crops attractive for bees (24.05.2013)
The main conclusion of the report
1. Under the actual intensive production practice it is indispensable and necessary to implement chemical control in order to keep the present quantitative and qualitative levels in the major field crops which have significantly been improved over the last 20 years. It is pertinent, however, that even with such yield improvements made in wheat and maize, Hungary is still behind the averages observed in the European Union.
2. Other tools of the integrated pest management are very important and have shown continuous improvements, but they offer only restricted solutions for the control of weeds, pathogens, and insect pests.
3. Without reliable and proper application of plant protection products wheat management would become impossible and, within a short while, Hungary would lose almost half of the present annual yield volume which means that wheat production would fall back to the level of the 1960s. In the lack of efficient control of fungal diseases, a major part of the wheat crop – infected by ear Fusarium – would become unusable for both human and animal consumption, and a significant quantitative decrease would be expected because of rust and other leaf diseases. The planned legislation would prohibit almost all fungicides which are authorised for use at present in cereals so with the remaining active substances the control of important fungal diseases in wheat production would not be successful. The planned regulations therefore could result in nation-wide feeding problems and would cause significant effects of economic importance in wheat production at a national level. In an average year a loss ranging between 40 and 60% might be encountered, furthermore the whole wheat production could be lost under rainy conditions favouring the spread of fungal diseases, which would be as high as HUF 180-200 billion in terms of national economy and would result in unconceivable nation-wide food supply problems.
4. Considering all herbicides covered by the planned legal restrictions, at least 100 thousand tons of yield losses of winter wheat can be foreseen causing at least HUF 4 billion of loss for the Hungarian agricultural industry while the same yield loss in maize can reach 550 thousand tons amounting to some HUF 25 billion.
5. If the planned legislation is enforced, it would effectively mean that management of the present sunflower sector would become impossible due to the range of herbicides authorised for use in weed eradication becoming too narrow. Desiccation would not be possible any longer as the active substances diquat-dibromide and glyphosate are planned to be withdrawn at the same time. Due to the harmonised developments in breeding and plant protection over the last 10 years a promising and successful solution has been found to control difficult to kill broad-leaved weeds which are known to cause serious yield losses in sunflower production. The planned legislation would totally hinder the application of these developments in practice and as a consequence, agricultural holdings would suffer losses of some 700 thousand tons, amounting to a decrease of income of HUF 75 billion - in other words, 40 % of the production value. It must also be noted that the planned measures would make the efficient control of common ragweed impossible and the nation-wide public health problems caused by the spread of this allergenic and aggressive weed species could not be managed.
6. Possibilities of controlling the fungal diseases of sunflower would also be severely curtailed by the planned restrictions. The head rots and stalk spots, if not properly controlled, would annually cause 130-190 thousand tons of yield losses amounting to a decrease of income of HUF 15-22 billion for the farmers.
7. Withdrawal of the active substances used for the control of insect pests probably would not cause losses in pest management programs in the short term because the efficacy of the remaining active substances would offer an adequate solution. However, as a consequence of a reduction in the number of active substances, it is expected that pest resistance to the remaining chemistry would quickly establish and therefore the efficient control of the most important insects might easily become impossible in the longer term. In this case a total of 100 thousand tons and some 15 thousand tons of yield losses may result in winter wheat and sunflower, respectively. The value of losses in these cases together may rise to HUF 5-6 billion. The problems caused by pest resistance as a consequence of the narrowing supply/availability of active substances are only apparent later on; with control difficult and no adequate solutions at hand.
8. Withdrawal of the active substance glyphosate would cause immense damage not only for agriculture, but also for forestry and would make weed eradication impossible in non-cultivated areas, public areas of towns and along the railway tracks. As regards the agricultural sector, special note must be made of stubble treatment as over one million hectares are annually treated. Without glyphosate, farmers would encounter severe problems in controlling many difficult to kill weed species. Here again special emphasis must be placed on ragweed control, which is of particular importance from a public health point of view.
9. With the restrictions placed on the neonicotinoids, the use of an efficient solution, i.e. the use of insecticides for seed treatment (which means furthermore less environmental burden than the application of foliar insecticides) has become impossible. The result is that the damage caused by soil-borne pests and pests of young plants have increased. In addition, the extent of soil disinfection and in-row treatments has significantly increased, leading to even greater negative “environmental loading”. At the same time it is to be noted that the establishment of insect resistance to existing products will speed up. In case of the eventual withdrawal of these active substances in winter wheat, the control of early infestation by aphids playing a role in the transmission of virus diseases could only be made by in-row treatment, which in turn, would also increase the environmental burden.
The effect as a whole
The effect of the above legislation, as a whole, could amount to HUF 300-320 billion loss of income caused by yield losses in the crops studied (winter wheat, maize and sunflower). Besides these crops the legislation also potentially affects winter oilseed rape, apple, grapevine and different vegetables to various levels of significance.
Alternative solutions do exist as an alternative to an out-right ban. With the combinations of active substances currently available, an industry-wide approach could be adopted such that synergies could be further exploited. For example synergism can be developed such that the dosages of the individual active substances applied could potentially be greatly reduced (even to one-half or one-third). The number and volume of active substances used can also be significantly reduced by preventative pest control techniques, such as pests and diseases outbreak forecasting. Furthermore, by using improved crop rotation practices damages can be significantly avoided and therefore the necessity of applying plant protection products can be reduced.
Integrated crop and pest management properly applied can provide a more efficient solution for mitigating any negative environmental effects as compared to an outright ban imposed on any given active substance. Moreover, the proposed prohibiting measures will probably increase rather than decrease the use of older less “environmentally friendly” plant protection products; largely as less efficient solutions will be available for the farmers for their increasing problems.
Experts from Kleffmann & Partner Kft:
Béla Bartók – Managing Director – sociologist, survey statistician
Mihály Csősz – Operational Manager – agricultural engineer, plant protection specialist engineer
Pál Schmidt– Project Coordinator – chemical engineer, pesticide chemical special engineer
- Weed pressure and weed control
Balázs Gyulai – agricultural engineer, soil resource management specialist engineer
Ádám Tóth– agricultural engineer, weed biologist, plant protection and soil science specialist engineer
- Pathology and fungal disease control
Dr. Pál Békési – honorary university professor, plant protection specialist engineer, plant pathology
Bernát Poós – agricultural engineer, plant protection specialist engineer
- Insect pressure and insect damage control
Dr. Géza Ripka – honorary university professor, National Food Chain Safety Office (NÉBIH), Department Head