The European Commission and Member States are meeting on the 1 - 3 October this week. The SCoPAFF committee’s somber agenda is overtaken by further delays of urgently-needed bans and extensions of the approval periods of several toxic substances. PFAS pesticides, endocrine disruptors, and reprotoxic substances are on the list, of which many are ‘candidates for substitution’. If this reads like a déjà vu, it’s because no real progress has been made since the start of the year, meeting after meeting. PAN Europe calls on the committee to take responsibility, fully apply the law, and act now to protect our future and that of generations to come from toxic pesticides.
No progress on banning PFAS pesticides approved as candidates for substitution
Member States have been blocking the proposed ban on the ‘very persistent’ PFAS flutolanil since the beginning of this year, despite clear legal grounds for its non-renewal on the basis that it emits TFA (see box below). [1][2][3]
Additionally, there is no movement on banning another PFAS currently on the agenda, penoxsulam, a potential TFA emitter which poses a significant risk of groundwater contamination.
Meanwhile, extensions of approval are underway for two PFAS pesticides approved as candidates for substitution:
- Diflufenican, a known source of TFA, highly toxic to aquatic life and extremely persistent in the environment. Its approval period has been repeatedly prolonged without adequate justification since December 2018.
- Flurochloridone, a potential TFA emitter. Its authorisation has been prolonged since May 2021, despite meeting the ‘cut-off criteria’ as toxic for reproduction. This is another very serious violation of the Pesticide Regulation.
What do these substances have in common?
Flutolanil and diflufenican - and potentially flurochloridone and penoxsulam - are all PFAS which eventually degrade into TFA, an extremely persistent ultra-short-chain PFAS that has been detected in food, drinking water and groundwater. [4] Evidence that TFA causes severe developmental harm has led to its proposal for classification as ‘toxic for reproduction 1B’ at EU level. Therefore, according to the Pesticide Regulation (Article 4(3)), TFA is a (toxicologically) ‘relevant’ metabolite - meaning that if TFA is detected in groundwater above the 0.1 μg/L limit, the parent active substance must be banned from use in pesticide products. Yet the dangerous accumulation of this ‘forever chemical’ in our environment not only routinely exceeds this limit, but in some cases even surpasses the 10 μg/L limit for ‘non-relevant’ metabolites. Further delays on the bans of these active substances that emit TFA, therefore, are highly incompatible with the Pesticide Regulation.
No progress on four endocrine disruptors & candidates for substitution
EFSA’s recent conclusions are categorical: buprofezin, cyprodinil, fenoxaprop-P-ethyl and fludioxonil are confirmed endocrine disruptors. The Committee’s repeated failure to ban these four substances constitute yet additional and highly concerning violations of the Pesticide Regulation. [5]
Although not recognised by EFSA, independent scientific studies have additionally provided substantial evidence that endocrine disruption is also caused by a fifth substance, approved as a candidate for substitution: fungicide difenoconazole. What is more, difenoconazole degrades into the reprotoxic substance 1,2,4-triazole. Under the Pesticide Regulation, this evidence should have swiftly led to its non-renewal. Instead, it is repeatedly prolonged on the EU market. [6] Finally, the use of conazoles like difenoconazole in agriculture is a major driver of antifungal resistance to the fungus Aspergillus fumigatus, the global leading cause of aspergillosis (and responsible for one of the highest numbers of fungal disease related patient deaths). [7] Since conazoles play a critical role in antifungal therapy for treating aspergillosis, their phase out in agriculture should be a priority.
Alarmingly, the list of cut-off substances requiring an immediate ban continues to grow. Genotoxic phosphine and reprotoxic halosulfuron-methyl, the latter another candidate for substitution, have recently been added to the list of substances under discussion, for which Member States are seeking derogations to keep them in the market.
Candidate for substitution pendimethalin is back on the agenda
Pendimethalin is part of the ‘Toxic 12’ - the twelve most toxic pesticides authorised in the EU, for which PAN Europe demands an immediate ban. [8] Reproductive toxicity, endocrine disruption and developmental effects are just some of its numerous health impacts. [9] Rather than taking action - and despite having all the necessary and relevant data since 2021 to classify it as ‘bioaccumulative’ as part of its PBT (persistent, bioaccumulative, toxic) assessment - the Commission and Member States have instead accepted the industry’s decision to submit additional, non-requested studies. The Committee yielding to what strongly resembles an industry manoeuvre to downplay pendimethalin’s risks, and generate further delays, is unacceptable.
Candidates for substitution: a still-functional category?
The category ‘Candidates for substitution’ was introduced under the Pesticide Regulation to identify the most harmful approved active substances for humans and the environment. The aim of this provision is to substitute them with less harmful alternatives to finally drive their phase-out. Despite this, the approval periods of these substances continue to be routinely extended without adequate justification, and despite the presence of viable alternatives. As a result, their presence in food has increased dramatically over the last decade. [10]
Digitalisation of pesticide data at risk
Electronic record-keeping of pesticide use was made mandatory from 1 January 2026. PAN Europe opposes the Commission’s proposal of allowing a one-year delay despite this ample time for implementation. Long-overdue, the electronic registration of pesticide data is pivotal to effectively monitor pesticide use reduction and risk, reduce administrative burden and focus attention on knowledge transfer on alternatives.
The full implementation of the Pesticide Regulation, unique for being one of the most protective chemical regulations in the world (in theory), is fundamental to protecting the right of EU citizens to health and to a healthy environment. The continued approval of candidates for substitution with reprotoxic, endocrine-disrupting and TFA-emitting properties represents a failure by the Commission and Member States to uphold this right, which PAN Europe urgently calls upon to redress in the upcoming ScoPAFF meeting.
Notes:
[2] Why do EU countries block a ban on PFAS and Endocrine Disrupting pesticides?
[3] EU Pesticide meeting: Reprotoxic, Hormone-Disrupting, and Forever Pesticides
[4] Study reveals alarming surge of forever chemical TFA in European wine
TFA: The Forever Chemical in the Water We Drink
[6] Request to ban the fungicide difenoconazole
[8] Ban Toxic 12
[9] Pendimethalin
[10] A new campaign denounces the increasing presence of 55 most harmful pesticides on the EU market
