Brexit: What direction for crop protection?
Jun. 2, 2017
Some of the UK’s options have been examined in a dedicated Horizon Market Intelligence report, produced by the Agriculture and Horticulture Development Board (AHDB), a statutory levy board funded by farmers, growers and others in the supply chain and managed as an organisation independent of both industry and Government.
As the report notes, the UK Government’s intention is to ‘lift and shift’ existing EU rules as far as possible through a ‘Great Repeal Bill’, which could include the current pesticide regulations. However, as authors Sarah Baker and Jon Knight note, this may be considered inoperable unless the UK Government chooses to align with the EU on current and future regulation because current PPP regulations are dependent on EU bodies, including the European Food Safety Authority (EFSA) and the European Commission, for approval.
The UK’s room for manoeuvre on future regulations is also likely to be restricted by its significant trade with the EU (for example, 91% of oilseed exports go to the EU, as do 82% of cereal exports) and EU-agreed Free Trade Agreements, which are based on current PPP rules and regulations. However, the authors conclude that change may well come once the dust has settled and that trade deals with countries outside the EU may offer scope for greater regulatory flexibility.
They write: “Since a policy needs to be in place at the point of exit, it would appear likely that the vast majority of PPP regulations will be ‘lifted and shifted’ as part of ‘The Great Repeal Bill’. However, following this, change is possible and the industry needs to think ahead regarding what it wants and needs to compete effectively in a changing global trading environment, as well as satisfying consumer preferences in a domestic market.”
The authors identify four key options for a post-Brexit regulatory framework in the UK. The first is for the UK to remain aligned with the EU for pesticide registration and the setting of maximum residue levels (MRLs). However, this would see a continuation of the EU’s precautionary, hazard-based approach, which has been criticised in some quarters of the UK by those who would prefer a risk-based approach.
Indeed, this clash between precautionary and risk-based approaches is likely to be a major sticking point in the UK, with the farming industry very concerned about the possible loss of more than 70 chemicals judged to have endocrine-disrupting properties. The country’s Farmers Weekly magazine reported earlier this year on a speech given at a fringe event during the Oxford Farming Conference by Colin Ruscoe, head of the British Crop Production Council.
Calling for the introduction of robust risk assessment, he told the BASF-hosted event: “Hazard is the intrinsic danger of a technology or a chemical. Electricity is hazardous. You can kill yourself with it. Oxygen is hazardous. If you have too much of it you will die.
“It is the way you are exposed to the technology that creates the risk. The hazard must be tempered by the other aspects of risk, which are exposure and recognition that we and indeed other organisms do have livers. We are capable of detoxifying or degrading chemicals, which if left to accumulate could cause harm.”
In contrast, environmental groups have underlined the importance of maintaining a precautionary approach. Friends of the Earth campaigner Samuel Lowe said in March: “The Great Repeal Bill is necessary but on its own, it isn’t enough to protect nature and our environment. We must commit to bringing over the precautionary principles which underpin our high environmental and wildlife standards.”
Option two would be to align with the United States, which does follow a risk-based approach, with the UK’s Chemicals Regulation Division (CRD) working in partnership with US agencies. The authors note: “This may mean more actives would be available to the UK industry, greater numbers of registrations for biological products and better availability of products for speciality uses, as the UK would become part of a much bigger market for PPP manufacturers. The UK would retain the power of veto for use of certain products here in the UK if required.”
As the authors note, this is not a problem-free scenario as the registration and use of PPPs would need to be acceptable with trading partners, environmental groups would not support a more permissive crop protection policy regime and data packages in support of registrations would need to reflect the UK’s growing conditions, which could be achieved by using data from the climatically similar Pacific North West.
The third option would see the UK adopt the Organisation for Economic Co-operation and Development’s (OECD) global standards regulation. Again, this is a risk-based approach and would put the UK in control of which active ingredients can be used in its agriculture. The authors note that more active ingredients should be available under this scenario and, if governments work together, risks could be evaluated more quickly and thoroughly as it would provide cost savings (for example, Canada and the USA, and Australia and New Zealand have such collaborations).
The final option explored by the authors is the UK taking full responsibility for registering PPPs which, while it would place a considerable burden on administrators, would allow it to have control of the approvals process and adopt a risk-based approach. The authors note: “There may be opportunities to speed up the approvals process for low risk substances, such as biopesticides. This might potentially enable everything in the ‘toolbox’ from biologicals to gene editing, RNA interference (RNAi), and genome editing (CRISPR) to be used, using domestic crop scientists.”
The authors note that a number of factors will influence the UK’s choice in the coming years, not least of which is the UK’s trading relationship with the EU after Brexit and the country’s future agricultural policy. They conclude: “At present it is not clear which approach the UK Government will adopt, as each have associated pros and cons. This is something that AHDB will be monitoring closely and we will be keeping our levy payers informed of future developments.”
*AHDB Horticulture launched SCEPTREplus, a new £1.4 million, four-year programme of crop protection product trials this spring, targeting high-priority diseases, pests and weeds. The programme builds on the original SCEPTRE project, which saw more than 140 chemical and biocontrol products trialled in the UK, with the issue of 12 Extension of Authorisation for Minor Uses (EAMU) directly linked to SCEPTRE.
AHDB Horticulture notes that while chemical companies continue to produce new, lower environmental impact actives for use on major world crops, the number of new actives registered for use on horticultural crops is relatively small, largely due to the small size of the markets in relation to development costs.
AHDB Horticulture Strategy Director, Steve Tones said: “We understand Extensions of Authorisations for Minor Uses (EAMUs) are essential crop protection measures for our growers and this project will escalate the rate at which new products get authorised. Other, more forward-looking work will focus on the long term development of robust integrated crop management systems to minimise future crop losses from diseases, pests and weeds.”
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