Ban endocrine disruptors, glyphosate and more: PAN Europe’s letter to SCoPAFF

This week the Standing Committee on Plants, Animals, Food and Feed (SCoPAFF) will meet for two days. Regulatory experts representing the EU member states will discuss and/or vote on behalf of their country on several Commission’s proposals. Top issue is the EU Commission’s proposal to renew the licence for glyphosate for ten years. Very important indeed, for this most used herbicide is the flagship of chemical agriculture. However, many more important matters are at stake in the SCoPAFF meeting. From other very toxic pesticide active ingredients and their harm to health and the environment to the way these substances are assessed. The Commission is finally proposing the ban of some endocrine disrupting pesticides, after over 10 years of PAN Europe and partners’ campaign to end their use. Our expert letter to the committee members delivers clear evidence why many other pesticides on the agenda do not meet the criteria to be on the market and hence need to be banned. We also explain why certain practices are not in line with EU law as clearly stated in recent opinions by the EU Court of Justice. These Important developments are urgent to reduce the use of pesticides, especially the most harmful ones.

The good news is that the EU Commission is finally proposing to ban the first five pesticides because they are endocrine disruptors. This is 5 years after the criteria went into force and 10 years after the introduction of the regulation. It is an urgent matter, for pesticide residues on food is the main source of endocrine disrupting chemicals exposure for humans. These chemicals alter the function of our hormonal system and can have adverse effects at a very low dose, particularly when exposure takes place during early life. Young children and pregnant women are especially vulnerable and therefore the ones at higher risk. See for more explanation on our page on this topic

Another positive point is the proposed ban of the herbicide S-metolachlor, until recently widely used in maize cultivation for animal feed and found to pollute groundwater. However, discussions on other very dangerous pesticides are far from positive as their use will still be allowed on the market according to proposals by the Commission.


In short the main topics in the letter

1. Proposal to renew the approval of glyphosate

We summarise the load of scientific evidence that shows the harm done to health and the environment, as detailed in many of our publications and on the website. We ask the Member States to reject the Commission’s proposal to renew the approval.

2. Proposal to renew the approval of ethephon

Bayer’s ‘growth regulator’ or better ‘dwarfing agent’ is widely used to keep stems of grain short. While ethephon is not an endocrine disruptor for humans, available data shows it has endocrine disrupting activity on non-target species. Experts agreed this positive evidence required further studies to be carried out to conclude on the endocrine disrupting properties of ethephon. Yet, EFSA did not require such studies and has opted for the least precautionary option, contrary to what the experts had agreed and what is written in the relevant guidelines. To PAN Europe, a serious scientific doubt remains, which requires the implementation of the precautionary principle in decision-making while further scientific investigation is carried out on this key approval criteria.

3. Proposals for non-approval of asulam sodium and non-renewal of the approvals of metiram, benthiavalicarb, clofentezine and triflusulfuron-methyl

We fully support the Commission's five proposals to ban a series of active substances identified as endocrine disruptors.

4. Proposal for non-renewal of the approval of s-metolachlor

This substance and its metabolites are found to contaminate groundwater. On top of that, for the metabolites, there were concerns or data gaps in relation to genotoxicity and/or carcinogenicity.

Furthermore, s-metolachlor is also posing a high risk to earthworm-eating mammals. So it is evident that the substance does not meet the requirements for approval and we fully agree with the proposal to ban it.

5. Proposal to renew the approval of captan for use in greenhouses

Captan has been classified as suspected of causing cancer (carcinogenic category 2) and poses long-term high risks to birds, mammals, aquatic organisms, bees and non-target arthropods other than bees for all its representative uses according to EFSA. Furthermore, important data gaps regarding contamination of surface and drinking water remain. These unacceptable effects cannot be addressed by restricting the use of captan to permanent greenhouses. Both field studies and monitoring data have shown that greenhouses are not closed systems.

6. EFSA conclusions on flutolanil, dimethomorph, metribuzin, and mepanipyrim

EFSA has concluded that these substances have endocrine disrupting properties. Therefore we expect a proposal to ban them as soon as possible. Flutolanil is a PFAS and its breakdown product TFA (also a PFAS) contaminates groundwater.

7. Confirmatory information on pendimethalin

In 2017, pendimethalin was reapproved as a candidate for substitution as it fulfilled the criteria as persistent (P) and toxic (T). However, in its peer review which preceded this renewal decision, EFSA could not exclude the bioaccumulation (B) potential of the substance. As a result, the renewal was conditioned on the submission of further confirmatory information regarding the potential for bioaccumulation (B) of pendimethalin. Now this information is available and confirms that pendimethalin meets the PBT criteria. We call on the SCoPAFF members to invite the Commission to propose a withdrawal of the approval of pendimethalin. It has been in our environment far too long.


We call for a phasing out of the PFAS-active substances approved for use in pesticide products in the EU to achieve the toxic-free environment promised by the EU

9. EFSA Guidance Document on the risk assessment of plant protection products on bees

Ten years after the publication of the first version of this guidance document, PAN Europe calls on the Member States to endorse this new guidance document without delay. Nevertheless, we would also like to reiterate our criticism of the 10% mortality in one single pesticide treatment accepted by Member States. Considering the fact that bees are exposed to a cocktail of pesticides, simultaneously with other stressors such as pathogens or lack of resources, PAN Europe considers that this figure is unsustainable and might reduce the positive impact of the progress made with the new Bee Guidance Document. We therefore ask Member States to review their position and reduce it to a maximum of 3%.

10. Working groups on comparative assessment and negligible exposure

While PAN Europe welcomes the substantial progress made by the Commission on the revision of Annex IV, we consider the current proposal maintains several shortcomings. For instance, in the proposal, it is assumed that resistance always exists and that chemical diversity is essential in all cases. Yet, this is untrue. This argument is often used not to ban the most toxic pesticides, as shown in our Toxic 12 campaign. See the letter for more detailed comments.

Another area of concern is the ‘negligible exposure’ concept. This is also used to keep dangerous pesticides on the market under the assumption that health and the environment are not seriously harmed under certain conditions. We remind SCoPAFF members of our concerns and remarks expressed in an earlier detailed position.

In short, in the letter we:

  • Welcome proposals to ban hormone disrupting chemicals
  • Deliver clear evidence to member states that many other pesticides on the agenda do not meet the criteria to be approved and need to be banned
  • Explain why certain practices and decisions are not in line with EU law as clearly stated in recent opinions
  • Provide handles to improve procedures to close loopholes and make pesticide assessment more in line with the goal of EU law to provide a high level of protection for health and the environment

Letter to the members of the SCoPAFF 4 October 2023.

© Pesticide Action Network Europe (PAN Europe), Rue de la Pacification 67, 1000, Brussels, Belgium, Tel. +32 2 318 62 55

Pesticide Action Network Europe (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.