Briefings

November 2022

Comparative Assessment and Substitution

Under Regulation (EU) 1107/2009, active substances that are the most hazardous to human health or the environment are approved as candidates for substitution. In addition to being approved for a maximum period of seven years, these substances can only be authorised in pesticide products by Member States when a comparative assessment has shown that they cannot be substituted with safer alternatives. Comparative assessment, in line with Article 50, is a legal requirement for all Member States since 1 August 2015.

November 2022

Position Paper on the Implementing Regulation on the Identification of Unacceptable Co-formulants of pesticides

PAN Europe considers that the Commission’s proposal for a new implementing regulation on co-formulants used in pesticides[1] fails to ensure compliance with Reg. (EU) 1107/2009, i.e that co-formulants used in pesticide products cause no harm to human health or have no unacceptable effect on the environment.

October 2022

Joint Statement on the revision of lists of surface and groundwater pollutants

As a joint alliance of EU health and environmental civil society organisations we hereby share our main policy recommendations on the update of the lists of surface and groundwater pollutants under the Water Framework Directive (2000/60/EC – WFD), the Environmental Quality Standards Directive (2013/39/EU – EQSD) and the Groundwater Directive (2006/118/EC – GWD).

September 2022

PAN Europe’s Position Paper on the EU proposal for a Regulation on Sustainable Use of Plant Protection Products

On 22 June 2022, the European Commission published its proposal for a Regulation on Sustainable Use of Plant Protection Products (SUR) and repeal the current EU Directive (128/2009/EC) on the Sustainable Use of Pesticides (SUD).

March 2022

Application of EU health and environmental standards to imported agricultural and agri-food products: Contribution to the call for evidence

The European Commission is consulting stakeholders on the rationale and legal feasibility of applying EU health and environmental standards (including animal welfare standards and processes and production methods) to imported agricultural and agri-food products. PAN Europe welcomes the opportunity of providing feedback and proposes below concrete actions to ensure greater consistency between the pesticide residue standards applied to domestic production and those applied to imported products. 

March 2022

Updated version: Position paper on the development of a risk assessment of pesticides on bumblebees and solitary bees

While the collapse of biodiversity is not questionable anymore and, particularly, that of insects, the pace of improving the situation at the pesticide regulatory level is extremely slow. The revision of existing guidance documents and the development of new ones are lengthy processes that do not correspond to the urgency of the environmental situation.

March 2022

Position paper on the revision of the Sustainable Use of Pesticides Directive

The European Commission will present a proposal for a new Pesticide Reduction Regulation on 23 March 2022. That will be the start of a discussion with the European Parliament and the member states. It will lead to important discussions in all EU countries that should not be dominated by the lobbyists for the industrial farming model.

March 2022

Pesticide checklist on National Strategic Plans of the Common Agricultural Policy

The European Union has agreed to reform EU’s Common Agricultural Policy (CAP) and, as part of that, Member States (MS) need to prepare National Strategic Plans (NSP) by end of 2021. The European Commission is currently reading and commenting on the plans.

December 2021

Factsheet: Contribution to the EU feedback mechanism on Sustainable Food Systems – new initiative

The European Commission has published an Inception Impact Assessment to inform citizens and stakeholders about the Commission's plans to move EU towards development of Sustainable Food Systems aiming at allowing citizens to provide feedback on the intended initiative and to participate effectively in future consultation activities.

November 2021

PAN Europe and PAN International call on WHO and OECD to reject and condemn EFSA's methodology to assess cocktail effects of pesticides

Today, PAN Europe and PAN International are calling on the WHO and the OECD, via a letter, to reject and condemn EFSA's methodology to assess cocktail effects of pesticides. Salomé Roynel, Campaigner at PAN Europe commented: “In this letter we argue, based on our work, that EFSA's methodology is inherently biased.

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PAN Europe gratefully acknowledges the financial support from the European Union, European Commission, DG Environment, LIFE programme. Sole responsibility for this publication lies with the authors and the funders are not responsible for any use that may be made of the information contained herein.