Three NGOs, PAN Europe, IFOAM Organics Europe and Global 2000, lodged a formal complaint before the European Ombudsman concerning the European Commission’s reliance on the Harmonised Risk Indicator 1 (HRI1) to measure use and risk of pesticides.
Helmut Burtscher-Schaden, chemicals officer at Global2000 (Friends of the Earth Austria) said: “The current indicator does not reflect the real toxicity of pesticides. For instance, this indicator attributes over 800% more risk to potassium bicarbonate (baking powder, used in organic agriculture) than to difenoconazole, a synthetic fungicide flagged as highly toxic and persistent.”
Eric Gall, deputy director at IFOAM Organics Europe, said: “The HRI-1 indicator leads to absurd results and gives the wrong impression that organic farming is the problem, because it is mainly a volume based indicator that discriminates against natural substances. Relying on a misleading indicator to measure pesticides use is ineffective and unfair to organic farmers who are the ones who strive to apply agroecological methods as alternatives to toxic synthetic pesticides."
Martin Dermine, executive director at PAN Europe, said: "The European Commission regularly communicates that pesticide use is decreasing in Europe thanks to their flawed indicator. This is untrue: available pesticide sales data show that there is no substantial reduction in use of toxic pesticides. Using this false indicator is misleading both policy makers and the general public."
By filing this complaint, the three organisations ask the European Ombudsman to assess whether the Commission has committed maladministration by breaching its duty of accuracy and transparency by using and promoting HRI-1.
The NGOs demand that the Commission:
- Immediately fixes the major flaw of the current methodology and corrects previous misleading announcements to restore public trust.
- Adopts a scientifically robust indicator that takes into account human and environmental toxicity, as well as water contamination, to provide a credible measure of pesticide reduction.
Background information:
PAN Europe, Global 2000 and IFOAM Organics Europe argue that the use of this flawed indicator, and the Commission and Member States' public claims based on it, mislead EU citizens, farmers and policymakers.
1. HRI1, adopted by member states in 2019, is supposed to measure the “use and risk” of pesticides. However, it has been widely criticised by NGOs, scientists, and even the European Court of Auditors for producing misleading results :
- Artificial reductions: through a mathematical trick, the decrease in the use and risk of chemical pesticides published annually by the Commission [1] largely reflects bans or phase-outs of certain substances, not real decreases in toxic pesticide use on farms. Once banned, a pesticide gets an additional factor 8 for the use in previous year. Therefore, if a pesticide is banned and the use is replaced by an almost equally toxic pesticide, it still counts as a sevenfold reduction of the use of this pesticide.
- The current indicator HRI1 does not reflect actual risk in real-life conditions such as acute and chronic toxicity to humans or the environment, as well as risks of water pollution
- Bias against natural substances: studies, including a report by GLOBAL 2000 [2], show that HRI-1 systematically exaggerates the risk from natural substances used in organic farming compared to synthetic pesticides. For example, the indicator attributes over 800% more risk to potassium bicarbonate (a harmless substance also used as baking powder) than to difenoconazole, a synthetic fungicide flagged as highly toxic and persistent.
- Undermining ambition: by inflating progress, HRI1 seriously weakens the EU’s credibility in achieving its target to truly reduce pesticide use and risk by 50% by 2030.
2. NGOs have long warned against HRI1. In June 2022[3], they urged the Commission to develop a new, scientifically robust indicator that reflects actual use, toxicity, and exposure, echoing earlier calls from the European Court of Auditors [4]. In 2024, they developed the PURI, a new indicator designed to address these shortcomings and provide a more accurate representation of pesticide use intensity and risk, thereby supporting the Commission’s work in designing an improved monitoring tool. [5]
3. The unscientific calculation method used to calculate HRI1 has already been underlined by several national agencies' reports : in 2023 by the German Environmental Agency (UBA) [6], and in 2025 by French National Research Institute for Agriculture, Food and Environment (INRAE) [7].
By challenging the use of HRI1, NGOs seek to ensure that EU pesticide reduction targets are monitored with scientifically sound tools that reflect reality on the ground, not distorted statistics.
Contact:
- Tjerk Dalhuisen, Senior Communications Officer of PAN Europe, tjerk [at] pan-europe.info, +31 6 146 99 126
- Helmut Burtscher-Schaden, Chemicals officer, Global 2000, helmut [at] global2000.at, +4369914200034
- Eric Gall, Deputy Director, Organics Europe - IFOAM, eric.gall [at] organicseurope.bio, +32 491 07 25 37
Useful documents
- HRI-1: A risk indicator to promote toxic pesticides?, Global 2000, 2022.
- Revision of the Harmonised Risk Indicator 1 (HRI-1), IFOAM Organics Europe and Global 2000, 2024.
- The deceptive Harmonised Risk Indicator HRI1 (YouTube video), PAN Europe, 2023.
- Reducing pesticides use and risks: Why the SUR's HRI-1 indicator is not fit for purpose (YouTube video), IFOAM Organics Europe, 2023.
- #StopHarm Campaign, IFOAM Organics Europe
Notes:
[1]https://food.ec.europa.eu/plants/pesticides/sustainable-use-pesticides/p...
[2]https://www.global2000.at/sites/global/files/GLOBAL-2000_Report_HRI-1_22...
[3]https://www.pan-europe.info/press-releases/2022/06/environmental-ngos-an...
[4]https://www.eca.europa.eu/en/publications?did=53001
[5]https://www.organicseurope.bio/content/uploads/2024/12/IFOAMEU_POLICY_HR...
[6]https://www.umweltbundesamt.de/sites/default/files/medien/11740/publikat...
[7]https://hal.inrae.fr/hal-04956205v1
About the organisations:
Pesticide Action Network Europe is a network of NGOs working to reduce the use of hazardous pesticides and have them replaced with ecologically sound alternatives. We work to eliminate dependency on chemical pesticides and to support safe sustainable pest control methods. Our network brings together 49 consumer, public health and environmental organisations and women’s groups from across Europe.
GLOBAL 2000 is an independent Austrian environmental organization and a member of Friends of the Earth, the largest international network of environmental organizations. GLOBAL 2000 closely monitors the development of environmental policy in Austria and is committed to ecological fairness and a future worth living both locally and around the globe.
IFOAM Organics Europe is the European umbrella organisation for organic food and farming. With almost 200 members in 34 European countries, our work spans the entire organic food chain and beyond: from farmers and processors organisations, retailers, certifiers, consultants, traders and researchers to environmental and consumer advocacy bodies.
