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Agricultural Industries Confederation Ltd

AIC

AIC is a trade organisations which exists to serve the interests of its members in the field of agri-supply.

Lobbying Activity

Response to Amendment of products and substances allowed in organic production

15 Aug 2019

Regulation 889/2008 contains the following sections in article 25k: 4. Astaxanthin derived primarily from organic sources, such as organic crustacean shells may be used in the feed ration for salmon and trout within the limit of their physiological needs. If organic sources are not available natural sources of astaxanthin (such as Phaffia yeast) may be used. 5. Histidine produced through fermentation may be used in the feed ration for salmonid fish when the feed sources listed in paragraph 1 do not provide a sufficient amount of histidine to meet the dietary needs of the fish and prevent the formation of cataracts. Neither of these are listed in the annexes V and VI accompanying the Regulation. The request from the AIC Fish Feed Committee is to have both listed in the revised lists of feed materials and additives approved for use in organic production. The preferred form of words for the listing to be as follows: Astaxanthin – derived from organic or natural sources – for use in salmon and trout. Histidine – produced through fermentation – salmonids Could you please give this request for their addition to the positive list (on the grounds that both are currently approved for use) due consideration.
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Response to Establishment of Harmonised Risk Indicators to measure the reduction in risks and adverse impacts from pesticide use

21 Dec 2018

AIC supports the Commissions intent to develop harmonised risk indicators (a requirement under the Sustainable Use Directive2009/ 128/ EC). AIC considers that risk indicators must however address the risks presented by plant protection product (PPP) use and not the hazards. AIC is concerned that the Commission proposals are hazard based and do not consider the way in which PPPs are used which ultimately determines the risk to human health and the environment. AIC has therefore put forward alternative suggestions for indicators which demonstrate adherence to good agricultural practice as a better way to measure any risks presented by PPPs and we ask that these are considered.
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Response to Criteria to identify endocrine disruptors for plant protection products

27 Jul 2016

The need for hazard characterisation, including potency, in the definition for endocrine disruptors Inclusion of potency in the WHO / IPCS definition will allow the continued use of active substances (ais) used to control weeds, pests and diseases in crops contributing to the production of safe, wholesome, affordable food for consumers. Some ais used to protect human and animal health (e.g. fungicides used to control mycotoxins in grain), could be classified as endocrine disruptors without the inclusion of potency in the criteria. Mycotoxins can cause liver cancer, damage to DNA and reproductive disorders. The Commission has strict legislative limits for mycotoxins in certain foodstuffs, it must not remove the tools to enable the agricultural industry to meet these limits. The outputs from the impact assessment concluded that all definitions offered the same level of protection to human health and the environment. However Options 2 and 3 were identified as having the highest impact on sectorial competitiveness, agriculture and trade. Under Option 2 many substances ingested daily by EU citizens e.g. caffeine, would be classified as endocrine disruptors without the inclusion of potency. Hence the need for potency in the definition. AIC supports the Commission decision to exclude categories in the proposal.The introduction of categories is beyond the legislative requirements of 1107/2009, and so is unnecessary. The categories proposed do not align with existing CMR categories under the CLP regulation, where hazard characterization and not weight of evidence are key. The introduction of categories would not add to the protection of human health or the environment. It would lead to unnecessary concern and confusion amongst EU citizens as to the safety of PPPs falling into one of the categories. Products not classified as endocrine disruptors under Option 2 could be blacklisted by retailers and consumers as they sought to minimise their exposures to them. This could lead to withdrawal of these ais for commercial reasons as farmers would be forced to cease their use, if they wished to sell their produce. Therefore ais important for agricultural production, falling outside the endocrine disruptor definition, would be withdrawn unnecessarily. The results of the screening study in the impact assessment do not constitute evaluations of individual substances under 1107/2009. However the inclusion of categories (Option 3) captures 50% of the 324 ais screened. Removal of such a vast number of ais with many important uses, would have a huge impact on food and feed production in the EU. Given that Option 2 and 4 offer the same degree of protection of human and health and the environment we agree that inclusion of categories in the criteria is not justified. Derogations Active substance availability should not depend on the use of derogations, as this provides little certainty to approval holders when developing new ais or maintaining approvals for ais that may fail cut-off criteria, but could be approved under the derogation.Negative impact on international trade The removal of ais classified as endocrine disruptors will have significant consequences for the import of feed and food crops from third countries. If Maximum Residue Levels will be lowered to the limit of determination (effectively zero), producers in third countries would be forced to find substitutes to control weeds, pests and diseases if they wished to export produce to the EU. This would have a negative impact for trade and EU food security - smaller, higher priced crop volumes, inferior quality food and less feed for animal production, impacting the entire value of animal production in the EU. Endocrine disruptors must be regulated like most other substances of potential concern and be subject to risk assessment which considers both hazard and exposure.
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