Derogations to CAP conditionality in 2023 are unacceptable

Dear Executive Vice-President, Dear Commissioners,

We are writing to express our deepest concern in relation to the possibility of the European Commission granting derogations on two basic conditionality standards of the new Common Agricultural Policy (CAP). 

This topic was discussed in the June meeting of Agriculture and Fisheries Council, with the European Commission showing its readiness to prepare such derogations and 16 delegations voicing their support. While this debate was held “behind closed doors”, the information we have gathered suggests that these derogations would be granted in accordance with Article 148 of the CAP Strategic Plans regulation, and could affect two Good Agricultural and Environmental Conditions (GAEC): GAEC 7 on crop rotation and GAEC 8 on non-productive areas or features.

The main argument used to justify such derogations is the situation of agricultural markets, aggravated due to the war in Ukraine, which we also find extremely worrying and requiring urgent action. Nevertheless, the derogations currently under consideration are a false solution that would hardly contribute to improving the market situation1. 

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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.