It’s a waiting game. That seems to be the main message from the crop protection specialists, as the rug has been pulled from beneath the feet of commercial growers.
Last month saw the implementation of the EU agrochemical registration regulation 1107/2009, which covers data requirements for active ingredient registrations, data requirements for product registrations, the uniform principles that must be followed in assessments of products, product labelling requirements and a list of actives that have already been approved and added to Annex I of the old EU agrochemical registration directive 91/414.
This brings stricter standards for registering a plant protection product, with possibly the biggest change moving away from the concept of risk and towards an assessment of hazard. The short-term outcome will be fewer, more expensive chemical crop protection solutions, reduced yield, less consistency in the end product and a higher cost of fruit and vegetables for the UK consumer. In the long term, European growers could end up a lot worse off than their non-EU producing neighbours.
The challenges on the horizon
At the moment, it takes around 10 years and costs in the region of €300m to register a new active ingredient in the EU, and costs are sure to rise. Plant protection products were previously registered for use in the EU through directive 91/414 and under this process, around 600 active ingredients were lost to EU growers through the review programme.
“Some of these would have been because they didn’t meet the criteria for approval, but others were commercially withdrawn by companies due to the cost of the approval process compared with the potential sales,” says Bayer CropScience food industry manager Stephen Humphreys, who worries that chemical companies will become reluctant to put money into horticultural actives in favour of larger, high-production products in the wake of the new regulation.
“Existing actives will not reach the new regulation and for the ones that do, chemical companies may not find it appropriate to re-register a product as an active may survive but it will have fewer crops on the label. While it is absolutely correct that plant protection products should be well regulated, it is unfortunate that the new legislation will reduce the tools available to growers to produce healthy, nutritious food at a time when it’s becoming increasingly important that we increase food production to feed a rapidly growing world population. This is not the time to cut actives on a hazard assessment, rather than risk.”
As Agrovista’s regional director Charles Coslett puts it, anything in life that follows the trend of basing decisions on hazard rather than risk presents problems. It leads to products, which could be risky but easily controlled - like alcohol in society - disqualified because of their hazardous nature alone.
“Crops such as top fruit, soft fruit and vegetables, where there is a reduced area of product to the likes of say cereals, are going to be hit hard,” says Coslett. “Chemical companies will need more resources to produce them for fewer customers and a smaller area. The cost of such products will definitely rise. For Agrovista, as a distributor, it is a problem as there are very little options for horticulture other than to use the agrochemicals, and the cost of producing them will inevitably be passed on to growers, who will have trouble making the money back from their end customers. The economic problems are going to be long term.”
It has been reported that the global population will reach seven billion by October this year and with the government pushing further domestic food production in the Food Vision 2030 report, the changes to the directive seem to be a step backwards.
Coslett believes that what could be seen as a misguided pledge to put the environment first is ultimately taking the horticulture industry back a step. “The EU is looking to retain some good environmental credentials, but the consequences on farming in the UK has not been thought through,” he says. “Commercial growers of horticultural products in this country rely on actives to make up for lack of labour and the changeable nature of the weather.
“Unfortunately, the environmental impact could end up being larger in some cases, for example if farmers start widening the rows between crops so they can mechanically plough rather than using an insecticide, then the use of diesel will go up. Yields will decrease and blemishes will have to be accepted by consumers. The perception that uniformity equals quality will have to stop.”
The impact of the new legislation will not be felt immediately and existing products will only be reviewed under the new system when the active ingredients they contain approach the 10th anniversary of their inclusion on Annex I of directive 91/414. But it is clear that the new legislation will put EU growers at a disadvantage and products that have been treated with actives that are not allowed could very well have been used on fruit and vegetables from further afield being sold alongside it.
“Further active ingredients will be lost to EU farmers, either as a result of failing to meet the new criteria or because the manufacturer considers it not commercially worthwhile supporting the active ingredient through the new process,” says Humphreys. “We are also likely to see a reduction in the number of crops on the label of re-registered products, again due to the cost associated with supporting each crop. As a result, EU farmers and growers will lose access to a growing number of products that may still be legally used outside of the EU.”
Searching for a solution
The DEFRA Horticulture LINK project SCEPTRE is designed to assess new active ingredients and develop novel technologies for sustainable pest, disease and weed control in edible crops. It is providing a glimmer of light and at EU level, momentum is gathering to establish a minor use fund to help to improve availability of crop protection products for growers of speciality crops.
“There are obvious concerns that the new regulation may reduce the availability of crop protection products,” says Vivian Powell, crop protection manager at the Horticulture Development Company (HDC). “However, it is currently difficult to establish the impact that the new regulation will have in terms of the registration of new active ingredients. In the longer term, we hope that the new zonal authorisation scheme will improve the availability of conventional and biorational products in the UK and throughout Europe.
“The EU has employed a consultancy firm to consider the level of support for [a minor use fund] scheme across the EU,” she continues. “UK representatives including the HDC, National Farmers’ Union and industry representatives recently attended a meeting with the consultants and confirmed that we in the UK support EU funding and
co-ordination of research at EU level, to minimise duplication of effort and to maximise crop protection solutions for growers of horticultural crops. The consultation will be completed by December, but it could be some time before a final decision is reached by the EU.”
So could the new legislation eventually benefit the industry? Companies such as Bayer CropScience say they will continue to look to register new products and defend existing products within the EU wherever possible. Coslett is adamant that the horticulture industry will evolve regardless of what obstacles are thrown in its path.
“Horticulture is practical and innovative, and growers are solution finders,” he insists. “We will always find ways of surviving, but the new legislation will result in greater energy use, a change in product perception among the public and inevitably, people will have to pay more for their fruit and vegetables.”
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