The withdrawal of traditional pesticide active ingredients as a result of the EU biocides review could pose a serious problem for pest control in Europe, believes industry, user and regulatory representatives. In addition, the high re-registration costs have resulted in the loss of low-risk ais such as plant oils, concludes a case study carried out by German companies Hydrotox and Okopol and UK company Risk & Policy Analysts. The study was part of a consultation held by the European Commission into the impact of the implementation of the EU biocidal products Directive 98/8.
Directive 98/8, which covers a wide range of products including non-crop pesticides, has initiated a review of existing ais. The first round covers wood preservatives and rodenticides, while the second includes products such as insecticides and insect repellents. All products containing ais that were not supported by companies for the review had to be withdrawn by September 1st 2006.
The study concludes that there is no clear evidence of a negative impact on pest control performance at this stage because the Directive's implementation time has been too short. Some member states believe that the negative impact of phasing out the initial group of unsupported ais will be limited. Many point out that the move has already created benefits for the environment and health as it removed several high-risk ais from the market. Nevertheless, regulators and industry warn that future losses of ais in the review will have a considerably larger impact.
One of the primary concerns is the risk of the development of resistance in pests due to the decline in the number of different modes of action available. This is considered particularly relevant for rodenticides and insecticides, but less so for wood preservatives. Experts conclude that there may be treatment gaps if fewer than four ais are available for a particular sector, the study says.
Serious concern is expressed about rodent control, where resistance of rats and mice to first- and some second-generation anticoagulants is already well documented. Respondents to the biocide consultation point out that there was a wide choice of first- and second-generation products before the implementation of the Directive. Since the Directive came into force, more second-generation products have been used, which may lead to greater resistance.
The study cites suggestions that, even though resistance management is considered in the evaluation process, it should be extended to consider specific target pests and applications on a case-by-case basis.
The withdrawal of the insecticide, chlorpyrifos, is considered a "serious problem". Dow AgroSciences decided to withdraw its support for non-crop uses of chlorpyrifos in Europe due to biocide re-registration costs. In addition to chlorpyrifos, the pest control industry is particularly concerned about the removal of traditionally useful ais such as calciferol, hydramethylnon, pirimiphos-methyl and citronella, the study says. The industry is critical of the disappearance of ais like boric acid and citronella oil "that have been used for decades without problems", the study adds.
The comments also reflect the broad concern that many ais considered as low-risk, such as essential oils and plant extracts, have been withdrawn from the review, largely due to costs. In a similar fashion to the EU agrochemical re-registration programme, the biocide industry has previously warned about the loss of products for niche markets due to unsustainable costs. Respondents to the consultation suggest that low-risk ais such as natural insect repellents should be exempt from registration for general insect control and that a history of safe use should be taken more into account.
Other observations criticise complications and confusion that have arisen over the division of review ais into different product types. Permethrin is being supported through the review under product type 18 (insecticides), but has been withdrawn from the review of product type 19 (repellents). Respondents point out that the application rate is much lower for an insect repellent than when the ai is used as an insecticide. They suggest that if an ai successfully completes the review and is registered as an insecticide, it should also be approved as a repellent.
Similarly, widespread withdrawals of support for ais from the molluscide product section occurred because they were already covered under product type 11 (cooling water biocides) and product type 2 (use in swimming pools, aquariums and other waters).