Global association AgroCare letter to India Government regarding Draft Banning of Insecticides Order 2020

Reference Draft Gazette Notification S.O.1512(E), dated 14th May 2020 and Banning of Insecticides Order, 2020 issued by Ministry of Agriculture and Farmers Welfare, Govt. of India, proposing to ban 27 Generic Pesticides.

Responding to the above Draft Banning Order, Global Association AgroCare, Brussels, Belgium which represents 850 Generic Pesticides Manufacturers from all over the world, sent the attached letter, dated 9th June 2020 to Joint Secretary (Plant Protection), Ministry of Agriculture and Farmers Welfare, appealing to follow the world protocols and transparent practices adopted to scientifically review Pesticides before taking a decision on its restriction, phase out or Ban. 

AgroCare is the Global Association, established on April 28, 2008 with Headquarters in Brussels, Belgium, representing the manufacturers of post-patent pesticides. Its members, the four regional associations from South America, Europe, India and China represent more than 850 individual manufacturers. As a global organisation, AgroCare defends the interests of generic manufacturers at global platforms such as the Joint Meeting on Pesticides Specifications (JMPS), the Joint Meeting on Pesticides Management (JMPM), The Collaborative International Pesticides Analytical Council (CIPAC), Food and Agriculture Organisation (FAO) and World Health Organisation (WHO).

At the global level, AgroCare consolidates its members’ interests by not only collecting information for its members on regulatory developments, but also to intervene on their behalf, to ensure that new global procedures, regulations or guidance do not create specific hurdles for generic manufacturers. In close cooperation with its regional member associations and their industry members, AgroCare is the international advocate for achieving feasible rules for establishing equivalence of active substances and products, at the same time maintaining high quality standards, and lowering barriers for the introduction of generic competition, to offer farmers around the world the benefits of free competition after patents have expired. AgroCare amplifies the voice of generic manufacturers who run into anticompetitive regulations, barriers and speaks on their behalf. 

Recently a Government of India Notification No. S.O. 1512 (E) dated 14.05.2020 issued by the Ministry of Agriculture and Farmers Welfare and published in the Official Gazette on 18.05.2020, containing the Draft Banning of Insecticides Order, 2020, proposing, inter-alia, a ban on the import, manufacture, sale, transportation and distribution of 27 pesticides and calling for objections/suggestions within 45 days (Draft Ban Order). 

AgroCare, on behalf of its Regional Generic manufacturers has to respectfully state that the Pesticide review, data call-in and restriction of use and banning are totally science driven scientific procedures, involving all the stakeholders, namely Pesticides Users, Pesticides Manufacturers and Regulators. There are set protocols of Pesticides Review by USEPA and OECD, which are being followed by the entire world. 

AgroCare strongly urges the Government of India to follow the world protocols and transparent practises adopted to scientifically review Pesticide products, before taking a decision on its use restriction, phase out or ban.

The Indian Agriculture and Indian Generic Pesticides manufacturers, both being one of the largest in the world, AgroCare sincerely hopes that the Government of India will choose Science in their best interest instead of taking arbitratory banning decisions which are not transparent, not involving its stakeholders and which will certainly risk Food Security of India. 

AgroCare requests the Government of India to keep the implementation of the Draft Ban Order in abeyance until the proper Scientific Review procedures are followed.