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The Merger of Agrochemicals and Biorationals – Integrated Pesticide Use in EUqrcode

Dec. 26, 2023

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Dec. 26, 2023
Carla Lorenz

Carla Lorenz

Manager Regulatory Affairs, Agrochemicals and Biorationals – Biorationals, Fertilisers, IPM

Scientific Consulting Company (SCC)

Lars Huber

Lars Huber

Senior Manager Regulatory Affairs, Head of Biorationals, Fertiliser, IPM

Scientific Consulting Company (SCC)

Sustainability, Green Deal, Farm to Fork and biodiversity are often discussed in remarkably diverse and contradictory ways by different stakeholders. Regarded as necessary and beneficial by the one and as overrated, unnecessary, and potentially problematic by the other. However, from a holistic perspective, the huge economic and ecologic potential of these EU agricultural goals becomes obvious. This is especially true if attention is not only paid to the respective lex specialis regulations on pesticide use such as the SUD (Sustainable Use Directive 128/2009) or the proposal for SUR (Sustainable Use Regulation; COM(2022) 305 final). Rather, it is the overlying or accompanying frameworks and lex generalis legislative acts, such as the initiative for a Sustainable Union Food System, the Common Agricultural Policy, Circular Economy or Regulation 2020/852 on the establishment of a framework to facilitate sustainable investment. These frameworks and legislative acts consider not only ecologic, but also economic aspects on a broad basis including farm level. Moreover, the enormous potential of a sustainable approach is already embedded in the main plant protection specific pillar, Integrated Pest Management (IPM). The European Commission defines IPM in the SUR proposal as ‘careful consideration of all available means that discourage the development of populations of harmful organisms, while keeping the use of chemical plant protection products to levels that are economically and ecologically justified and minimise risks to human health and the environment″ (COM(2022) 305 final). The close examination of this definition reveals the enormous potential to unite economic and environmental interests and needs of all stakeholders. 

One of the many logical consequences is the merging of agrochemicals and biorationals in a systemic approach to innovative and sustainable agriculture. 

Considering the ongoing loss of chemical active substances and products as well as the necessary reduction of dose rates or number of applications, many agrochemicals benefit from IPM. Thus, numerous chemical substances which would disappear from the market due to critical risk assessments could remain available if they are used in IPM programs. For these chemical active substances and products, IPM (combined with forecasting models, mechanical/physical and biological methods and, if applicable, new application equipment) can effectively reduce application rates and timings, hence leading to possibly safe risk assessments. In this way agrochemicals can also be a tool to balance economic considerations on farm level regarding the choice of plant protection methods available in the farmers’ toolbox considering the currently still higher prices of many biological plant protection products or mechanical methods for example. The merger of agrochemicals and biopesticides therefore can assure the balance between economic and ecologic aspects, as required by EUs IPM definition. This also strengthens the resilience of the EU agricultural sector and food supply as requested by the European Parliament and many Member State governments in the light of recent events, such as the Covid pandemic, the war in Ukraine or other disruptions of the global supply chains.

Besides the regulatory active substance approval and product authorisation process, the IPM approach is completely in line with the actual pesticide use in the agricultural practise. Recommendations for use by public advisory services anyhow require growers to alternate between different active substances, mainly due to resistance issues. Regrettably, the IPM approach is nearly completely missing or not required in the official regulatory registration process until now, i.e., concerning Good Agricultural Practice (GAP), efficacy testing and evaluation, risk assessments, and more. The only exception is a short link in the Biological Assessment Dossier in which applicants can provide information on suitability of a product with IPM. Although IPM-conform GAPs, risk assessments etc. are currently not needed from a regulatory point of view due to the lack of specific data requirements, applicants are free to provide such information and should do so. Especially regarding efficacy dossiers, possibilities are manifold to provide the respective information, particularly if chemical products are suitable for use in combination or alternations with biological active substances in IPM spray schedules. This can be a huge asset for such chemical products, not only regarding regulatory issues, but obviously also for marketing and sales purposes. Current and future developments such as digital labels, for example, are another good reason to consider IPM as early as possible in R&D, registration, and sales of agrochemicals.

Similarly, the IPM approach can also benefit the registration as well as marketing and sales of biopesticides. An example is the frequently discussed reduced effectiveness of biological pest control compared to chemical products. This often leads to a lower confidence in such products compared to chemical products by farmers. Of course, lower efficacy rates are systemic for several biological active substances and products since they are not designed as stand-alone products but as part of reasonable spray schedules and GAPs. The merger of biopesticides with agrochemicals thus can assure an effective and sustainable pest management also at high infestation levels, increase confidence of farmers as well as guarantee sustainable food production and supply. This also applies, for example, for certain microorganisms which are well known to act much better in microbial consortia. Until the recent past, however, it was not possible to register microbial consortia. This changed in August 2022, when Regulation 2022/1439 (amending Regulation 283/2013 on the data requirements for micro-organisms) was published. In contrast to the previous version of the data requirements, the current regulation explicitly includes the possibility of having a qualitatively defined combination of micro-organism strains, i.e., a microbial consortium, as a single active substance. This opens the possibility to combine micro-organisms with different modes of actions against the target pest or even different host ranges as well as choosing a combination of active micro-organisms functioning optimally under different environmental conditions. Thus, the revised regulation (in combination with other updated regulations for micro-organisms published at the same time) offer additional possibilities for microbial control agents and are a step forward for plant protection products based on microbial consortia becoming available to farmers. 

In conclusion, the merger of agrochemicals and biorationals in the scope of IPM programmes is a huge benefit for both types of products. Moreover, IPM can also help to amend several socio-economic problems and thus can be a huge asset to the chemical and biotechnological industries, especially regarding marketing and sales as well as public opinion. One example is the misconception regarding agriculture in many public discussions. The perceived focus on agriculture in the discussion on Greening and Sustainability, implies a causative nature regarding the environmental problems and challenges at hand. Of course, the use of mainly chemical pesticides as well as inorganic fertilisers and a very industrialised approach to agriculture have caused several problems in the past in itself. The current call for the reformation of the agricultural sector, however, is also influenced by factors not or only partially related to agriculture, such as climate change, pollution, or biodiversity loss. The latter is strongly influenced by the general habitat loss and only partly related to agriculture. Modern agriculture can become a key player to solve the current economic, socio-economic, and ecological problems by combining latest innovations, e.g., the use of biostimulants, elicitors and plant activators, digital farming systems, new application methods including drones, etc. At the same time, the crop health and nutrition industry can add the beneficial additive effects of their sustainable work to their value chain. 


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