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Pesticide Action Network Europe

PAN Europe

Pesticide Action Network Europe is a coalition working to reduce chemical pesticide use in Europe.

Lobbying Activity

PAN Europe urges mandatory digital pesticide recording in CAP

11 Dec 2025
Topic — The Commission proposal simplifies CAP by removing pesticide reporting from geospatial applications.
Message — The organization demands keeping mandatory pesticide recording within the geospatial aid application framework. They argue that centralizing digital records reduces administrative burdens and ensures policy coherence.12
Why — Mandatory digital records empower the group to hold authorities accountable for pesticide reduction targets.3
Impact — Taxpayers and researchers lose the transparency needed to verify if public funds achieve environmental goals.4
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Meeting with Jutta Paulus (Member of the European Parliament)

10 Dec 2025 · Webinar on urban surface water pollution

Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis), Michael Hager (Cabinet of Commissioner Valdis Dombrovskis) and

2 Dec 2025 · Roundtable on Food and Feed Safety Omnibus

Meeting with Jeannette Baljeu (Member of the European Parliament)

20 Nov 2025 · Pesticides

Meeting with Ana Vasconcelos (Member of the European Parliament)

19 Nov 2025 · Food and feed safety – simplification omnibus

Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament)

4 Nov 2025 · Plant protection products

Response to Food and Feed Safety Simplification Omnibus

14 Oct 2025

PAN Europe calls on the European Commission to use the Food and feed safety simplification omnibus initiative as an opportunity to strengthen the implementation and enforcement of EU food and feed safety legislation, particularly Regulation 1107/2009 on pesticide approvals and Directive 2009/128/EC on pesticide use, as well as Regulation 396/2005 on MRLs. This represents an opportunity for the EU to align better with citizens' repeated demands for more protection and less use of pesticides. Decades of scientific evidence demonstrate that harmful pesticides, including endocrine disruptors, carcinogenic substances, and substances with developmental neurotoxicity impacts, continue to pose serious risks to human health, wildlife, and ecosystems. Current shortcomings in pesticide risk assessment, prolonged approval periods, and poor enforcement of the legislation undermine its objectives and violate the precautionary principle. Please find our detailed feedback attached.
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Response to Amendment of data requirements for applications for the approval of active substances

9 Oct 2025

Pesticide Action Network Europe (PAN Europe) welcomes the initiative of the European Commission to update the data requirements laid down in Regulation (EU) No 283/2013 and appreciates the opportunity to provide comments on the draft Commission Regulation amending this legal framework. We support the Commissions efforts to ensure that risk assessment procedures for active substances in plant protection products are informed by the most up-to-date scientific knowledge and rely on the most sensitive and reliable testing methodologies available. Such an approach is essential to safeguard human health and to ensure a high level of protection of the environment from the potential toxic effects of pesticides. PAN Europe considers that ensuring robust risk assessment methodologies to avoid adverse impacts constitutes an institutional responsibility. In this spirit, we submit several targeted suggestions intended to reinforce certain aspects of the proposed amendments and to ensure that the regulation effectively reflects current scientific understanding and societal expectations for safety and sustainability. Please find attached our detailed written feedback for the Commissions consideration.
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Pesticide Action Network Europe demands stronger bee protection testing requirements

9 Oct 2025
Topic — EU regulation updating risk assessment procedures for plant protection products affecting bees and wildlife.
Message — The organization requests explicit inclusion of long-term toxicity testing for bees and expanded sublethal effect monitoring for bumblebees and solitary bees. They argue current testing protocols underestimate impacts from prolonged low-dose pesticide exposure.123
Why — This would require more comprehensive testing before pesticide authorization, potentially blocking products harmful to bee populations.45
Impact — Pesticide manufacturers face higher testing costs and potential product rejections from stricter assessment requirements.67
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Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen) and Friends of the Earth Europe and

29 Sept 2025 · presentation of and discussion about their roadmap to reduce pesticide use in Europe

PAN Europe Demands Ban on Exporting EU-Banned Pesticides

10 Aug 2025
Topic — A consultation on rules governing the international trade of hazardous chemicals.
Message — PAN Europe urges the EU to prohibit exporting pesticides banned within its borders. They demand an end to the double standard of manufacturing toxic chemicals for foreign markets.12
Why — This would protect global health and align EU trade with its environmental principles.3
Impact — Large agrochemical companies would lose revenue from selling hazardous chemicals in foreign markets.4
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Meeting with Majdouline Sbai (Member of the European Parliament)

26 Jul 2025 · Mercosur

Environmental NGO Urges Stronger EU Pollinator Monitoring Standards

17 Jul 2025
Topic — EU regulation establishing standardized methods for monitoring pollinator diversity and populations.
Message — The organization requests expanding the monitoring scheme to include more sites, broader taxonomic groups beyond bees and butterflies, mandatory monitoring of rare species, and site-specific threat data especially on pesticide exposure. They want the scheme to track drivers of pollinator decline and impacts of agricultural policies.12345
Why — This would provide comprehensive data to support stronger pesticide regulation and environmental policies.67
Impact — Agricultural chemical industry faces stricter regulation if pesticide impacts are more rigorously documented.89
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Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

13 May 2025 · Water Resilience Strategy and Zero Pollution

Meeting with Emma Rafowicz (Member of the European Parliament)

24 Apr 2025 · Droits humains - Martinique/Guadeloupe

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

16 Apr 2025 · Chemicals legislation/ export ban

Meeting with Claire Bury (Deputy Director-General Health and Food Safety)

10 Apr 2025 · Pesticides

Meeting with Csaba Molnár (Member of the European Parliament)

26 Mar 2025 · Environmental policies

PAN Europe Calls for Clearer Pesticide Risk Warning Labels

3 Feb 2025
Topic — Updated European Union rules regarding the labelling requirements for agricultural plant protection products.
Message — PAN Europe wants to replace "to protect" with "to reduce exposure" to show risks remain. They want bee safety labels to include chronic toxicity and reflect chemical mixture dangers.123
Why — Clearer labels would help the group reach its goal of reducing overall pesticide usage.4
Impact — Chemical manufacturers would lose the ability to downplay risks associated with hazardous mixtures.5
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Meeting with Martin Häusling (Member of the European Parliament) and Heinrich Böll Stiftung e.V.

12 Dec 2024 · KONFERENZ: "AUF DEM WEG ZU EINEM INTERNATIONALEN REGELWERK FÜR PESTIZIDE"

Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur) and Bund für Umwelt und Naturschutz Deutschland e. V.

26 Nov 2024 · Surface water and groundwater pollutants

Meeting with Sigrid Friis (Member of the European Parliament)

19 Nov 2024 · PFAS pesticides

Meeting with Anna Strolenberg (Member of the European Parliament)

13 Nov 2024 · Pesticides in agriculture

Meeting with Martin Häusling (Member of the European Parliament, Shadow rapporteur)

13 Nov 2024 · Treffen mit SOLO über das SML

Meeting with Stine Bosse (Member of the European Parliament)

12 Nov 2024 · European pesticide policy

Meeting with Christophe Clergeau (Member of the European Parliament)

7 Nov 2024 · Pesticides

Meeting with Sebastian Everding (Member of the European Parliament)

6 Nov 2024 · Support Citizens’ Demand for Pesticide Reduction

Meeting with Cristina Guarda (Member of the European Parliament)

21 Oct 2024 · Pesticides

Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

16 Oct 2024 · Surface water and groundwater pollutants

Meeting with Martin Hojsík (Member of the European Parliament)

11 Oct 2024 · Pesticides, impact on non-target species

Meeting with Christophe Clergeau (Member of the European Parliament)

10 Oct 2024 · Pesticides

Meeting with Biljana Borzan (Member of the European Parliament)

20 Sept 2024 · ENVI topics in general

Meeting with Marie Toussaint (Member of the European Parliament)

20 Sept 2024 · pesticides

Meeting with Christophe Clergeau (Member of the European Parliament)

25 Jul 2024 · Protection de l'environnement

Meeting with Manuela Ripa (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau

16 Apr 2024 · Soil monitoring and resilience directive

Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

8 Apr 2024

PAN Europe supports the mission of EFSA. The EU needs an independent & transparent scientific agency to support the decisions about the protection of human and animal health, the environment, its resources and ecosystems from chemical pollution including that of pesticides. Pesticides, particularly the synthetic ones, may cause cancer, toxicity to reproduction, neurodegenerative diseases and other serious disorders, even in small amounts. Environmental species are at high risk, as pesticides are sprayed on open fields. Taking this into account, in 2009, Europe adopted a landmark regulation (Reg (EC) 1107/2009) to prevent all human contact with pesticides that may cause harm and protect the environment from potential adverse effects. In case of scientific uncertainty, the precautionary principle should be implemented. EFSA plays an important role in delivering scientific methodologies and guidances to correctly implement the EU law, assess objectively the risks based on all available science and provide the required high level of protection from pesticides. EFSA should examine all scientific evidence from scientific literature, and objectively highlight the identified risks, as well as the uncertainties enabling risk managers to take the most protective decisions, including to apply the precautionary principle. EFSAs support should be purely scientific, without taking into consideration economic or political factors. It should remain independent from the influence of the food industry or any party supported by the business sector. Therefore, it is crucial to ensure that EFSA is an independent, scientific body that European citizens can trust, which prioritises the protection of their health and environment, before any other interest. EFSA must thus comply with its founding regulation, and its work must be in line with the pesticide regulation (EC) 1107/2009. Unfortunately, despite the good provisions of the funding regulation and the Pesticide Regulation, there are several shortcomings in relation to the independence of EFSA, the objectivity of its scientific and technical assessments as well as transparency in the procedures. Attached we provide evidence indicating the areas that EFSA should improve to become fully aligned with its mission, and with EU law.
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PAN Europe urges faster safety reviews for pesticide additives

19 Dec 2023
Topic — New EU rules defining data requirements and review programs for pesticide additives.
Message — PAN Europe calls for shortening the review period to three years and setting safety limits for food residues. They also demand the immediate withdrawal of products containing unapproved or unregistered additives.123
Why — Rapid removal of potentially harmful chemicals from the market strengthens the group's environmental protection mission.4
Impact — Chemical manufacturers would lose revenue from products withdrawn without the proposed lengthy transition period.5
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

15 Nov 2023 · Soil Health Law

Meeting with Beatrice Covassi (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

15 Nov 2023 · Public Hearing - Soil Monitoring Law

Meeting with Norbert Lins (Member of the European Parliament, Committee chair)

7 Nov 2023 · SUR

PAN Europe urges legally binding targets for EU soil health

3 Nov 2023
Topic — This consultation concerns a new EU law to monitor and restore soil health.
Message — PAN Europe requests legally binding targets and mandatory sustainable soil management practices rather than voluntary guidelines. They also call for national action plans and a pesticide tax based on the polluter pays principle.123
Why — Stricter monitoring would provide the evidence needed to ban or restrict harmful pesticide products.4
Impact — Pesticide manufacturers and industrial farmers would face higher costs from taxes and mandatory requirements.56
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Meeting with Martin Hojsík (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

28 Sept 2023 · Soil Health Law

Pesticide Action Network demands ban on toxic pesticide exports

31 Jul 2023
Topic — EU initiative to prohibit production and export of hazardous chemicals banned within Europe.
Message — They demand legally binding measures to stop companies from exporting banned hazardous chemicals. The EU should amend regulations to prohibit exports despite third-country consent.12
Why — This would help the organization achieve a toxic-free environment globally.34
Impact — Chemical companies lose profits from selling toxic products to regions with weak regulations.56
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Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur)

26 Jun 2023 · SUR, pesticides

Meeting with Tom Vandenkendelaere (Member of the European Parliament)

9 May 2023 · Sustainable use of pesticides regulation

Meeting with Martin Häusling (Member of the European Parliament)

11 Apr 2023 · Veranstaltung zu Glyphosat

Meeting with Maria Arena (Member of the European Parliament)

27 Mar 2023 · Les pesticides en Belgique

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

7 Mar 2023 · VTC Meeting: Pesticides

Meeting with Franc Bogovič (Member of the European Parliament, Shadow rapporteur for opinion) and Bayer AG

2 Mar 2023 · Meeting on SUR regulation proposal

Meeting with Pascal Canfin (Member of the European Parliament)

27 Feb 2023 · Green Deal

PAN Europe demands stricter labels for hormone-disrupting chemicals

17 Oct 2022
Topic — The EU is revising rules for the classification and labelling of hazardous chemical substances.
Message — They support new hazard classes but demand a shorter transition period for better protection. The group requests pictograms for all classes and clearer warnings about risks to children.123
Why — Faster implementation helps the group achieve its main goal of a toxic-free environment.4
Impact — Chemical manufacturers would face tighter deadlines and more complex requirements for their products.5
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Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and Friends of the Earth Europe and

27 Jul 2022 · staff only: Discussion on the Harmonised Risk Indicator 1 (SUR proposal)

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and Corporate Europe Observatory and

25 Jul 2022 · staff only: Discussion on the Harmonised Risk Indicator 1 (SUR proposal)

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and Friends of the Earth Europe and GLOBAL 2000, Friends of the Earth Austria

20 Jul 2022 · staff only: Discussion on the Harmonised Risk Indicator 1 (SUR proposal)

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

13 Jul 2022 · staff only: Discussion on the Harmonised Risk Indicator 1 (SUR proposal)

Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur) and Stichting BirdLife Europe and

12 Jul 2022 · staff only: Sustainable Use Regulation, exchange of views on the Commission proposal

Meeting with Bas Eickhout (Member of the European Parliament)

10 May 2022 · Protection wild bees - EFSA

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski), Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

26 Apr 2022 · Ideas towards boosting the EGD regarding pesticides

Meeting with Janusz Wojciechowski (Commissioner) and

22 Apr 2022 · Farm to Fork Strategy for food security

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

PAN Europe would like to thank the European Commission for the opportunity to comment. PAN Europe is concerned that the current text does not make any specific reference to the potential of pesticides influencing negatively on soil, when knowing that agricultural pesticides harm soils in various ways. Worth mentioning that currently EU pesticides permitting and risk assesment schemes do not exclude pesticide use harming soil life. Only 99.9% of the applied pesticide does not interact with its targeted weed or pest and remains as a pollutant in the environment, mainly in the soils and in waters. Pesticide harm soils life in different ways: Pesticides destroy the soil microflora - many studies have proved that plant protection products change the composition, diversity and functioning of soil microbiome. Pesticides can even decrease the soil microbial biomass. An example on glyphosate: a review article (Bruggen, 2021) exposed that the herbicide interferes with the shikimate pathway in plants and in major groups of microorganisms impeding the production of aromatic amino acids. Plant growth promoting rhizobacteria and beneficial intestinal bacteria often are negatively affected, while pathogenic bacteria and fungi are enhanced. Outbreaks of several animal and plant diseases have been related to glyphosate accumulation in the environment. Friends of the Earth publication highlighted that pesticide use causes alterations of biochemical processes: Soil microbes and plants make enzymes that catalyze biochemical transformation; these enzymes are the drivers of carbon and nutrient cycling. Scientific evidence demonstrates that some pesticides can also hinder nitrogen fixation — another key regenerative agriculture aim — by inhibiting molecular communication between plants and rhizobia, the bacteria that fix nitrogen inside legume roots, and by diminishing root growth and reducing the number of root sites available for essential rhizobia. Long-term glyphosate application could affect rhizosphere nutrient status (Newman, 2016). A comprehensive review study (Gunstone, 2021) found that based on about 400 studies, that common pesticides harmed beneficial, soil-dwelling invertebrates including earthworms, ants, beetles and ground nesting bees in 71% of cases reviewed. A new study (Owagboriaye, 2020) illustrates well the possible effects on agriculture of the disturbance of earthworm communities: “Only the tomatoes planted with the casts of the exposed earthworms were unable to set fruit. Surface casts of earthworms exposed to GBH could not enhance tomato growth while casts produced by unexposed earthworms greatly improved the performance of tomato plants.” A study (Jason. 2014) showed that a mixture of glyphosate and a soybean diflufenican increased the toxic effects of both herbicides on soil biological activity as well as the persistence of each herbicide in the soil. The further work on the soil strategy should looks at how to improve the situation, among other things, looking at: Re-establishing a legal basis for LUCAS also looking at pesticide occurrence in soil, accompanied by a monitoring programme with solid indicators to assess the health status of European soils, as well as the one agricultural waterways, puddles, runoff waters, ground water. Environmental quality standards (limit values) are needed for all pesticides approved in the EU both in surface waters and in soils. Risk assessment of active assessment shall take into account the effect of the active substance to soil life. Unacceptable negative effects, including persistence, should become cut off criteria under Regulation (EC) No 1107/2009. how agricultural practices (and CAP funding) influences the soil health status both in the short and long run, zooming in when agriculture is part of the problem and when it is part of the solutions among others helping in ensuring long term food security.
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Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and ClientEarth AISBL and GLOBAL 2000, Friends of the Earth Austria

9 Mar 2022 · VTC Meeting: Revision of SUD proposal and pesticide indicators.

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and GLOBAL 2000, Friends of the Earth Austria

9 Mar 2022 · Reducing the use and risk of chemical pesticides

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

21 Feb 2022 · Reducing the use and risk of chemical pesticides

Meeting with Roberta Torre (Cabinet of Commissioner Paolo Gentiloni)

21 Jan 2022 · The meeting dealt with the Commission proposal for a Regulation on Statistics on Agricultural Input and Output (SAIO), focusing on the provisions related to statistics on plant protection products.

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and ClientEarth AISBL

21 Jan 2022 · VTC Meeting: SAIO and Pesticides

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and ClientEarth AISBL

21 Jan 2022 · Pesticides statistics

Response to Sustainable food system – setting up an EU framework

26 Oct 2021

Pesticide Action Network Europe (PAN Europe) welcomes the opportunity of providing feedback. PAN Europe calls on the European Commission to proceed with the establishment of a new EU legislative framework for development of sustainable food systems ensuring that already agreed EU laws are seriously implemented and establishing a new EU legislative framework setting a clear vision and direction of travel for EU food systems. PAN Europe proposes the European Commission to proceed with option 4, including an approach where pathways are being prepared towards a pesticide free model. Doing so will be in line with the requests of the European Citizens Initiatives, first ‘Ban glyphosate and protect people and the environment from toxic pesticides’ and now ‘Save Bees and Farmers’. Each of the four options must give full recognition of both the new Common Agricultural Policy, to the Farm to Fork and the Biodiversity Strategies as these by now have all been embraced by all EU institutions, and should represent and be included in the “status quo” option. Also, each of the options need to include reflections on the costs of no-action, at least by delivering a literature overview in line with the benefit to human health for setting cut off criteria for pesticides. Finally, each of the policy options must include reflections on the road of travel, also reflections on financial support and other fiscal instruments to accompany the policy objectives. PAN Europe proposes to include the UN’s human right Council new condition of giving children and future generation, at large, a right to a clean, healthy and sustainable environment. In so doing, we call on each of the four policy options to include a reflection on what each one of them would mean for future generations. PAN Europe calls on the IIA to include a serious reflection on what is not sustainable food systems. PAN Europe recalls the importance of enhancing food environments, and for looking at the possibility of developing an EU planet score using the model already being prepared in France, with pesticides being one of the topics monitored. To put an end to the ongoing externalisation of unsustainable practices and to raise global standards, PAN Europe suggests the introduction of legal provisions to align all MRL regimes for imports (important tolerances and CXLs) on the requirements/MRLs applied at EU level. This point should apply both to environmental and health concerns. Additionally, the European Commission should quickly turn into action its Farm to Fork commitment to ban the export of prohibited chemical inputs, including pesticides. PAN Europe questions the ongoing work with industry in the development of Life Cycle Assessment (LCA) and the Product Environment Footprint (PEF) as it could lead to a situation where monitoring of environmental exposure caused by food and feed production will partly be reliant on the industry’s willingness in collecting and releasing data. Such an approach should neither replace the work of public administrations nor become the backbone in future discussions on labels. PAN Europe calls on the European Commission to develop a solid set of EU indicators to constantly monitor environmental contamination, including collecting pesticide use data while also monitoring pesticide residues in water, air, soil, bystander exposure etc. while making sure that the polluter pays principles is being applied. PAN Europe proposes the European Commission to consider to applying an alternative consultation process and start asking non-bureaucratic questions encouraging more citizens to reply. PAN Europe calls for full integrating into the IIA further reflections of the European Citizens Initiatives Ban glyphosate and protect people and the environment from toxic pesticides and Save bees and farmers.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

13 Oct 2021 · Transparent and inclusive process of CAP plans

Response to Conversion to a Farm Sustainability Data Network (FSDN)

2 Jul 2021

PAN Europe thanks for the opportunity to comment on the roadmap proposing to convert the Farm Accountancy Data Network (FADN) into the Farm Sustainability Data Network (FSDN).   PAN Europe welcomes the recognition that the overall aim of the FADN is to address the needs of the Common Agricultural Policy (CAP) and that it therefore need to envisage that environmental and social dimensions are being taken into account next to the economic dimension.   In order for the development to be in line with the objectives of the Common Agricultural Policy and the EU Green Deal, it is crucial that every farmer taking part in this survey delivers information about his/her pesticide use (name of the product, name of the active ingredient, number of applications, amount of applications) but also on which crop it was sprayed, where and especially why.   According to the EU Directive on Sustainable Use of Pesticides it is mandatory for farmers to apply Integrated Pest Management (IPM) on their farm since January 2014. PAN Europe recalls the concept of IPM being a concept of applying prevention first, explained very well in this study (https://agritrop.cirad.fr/598263/1/Deguine%20et%20al%202021-%20IPM%20ASD.pdf), but which is not widely used across Europe.   To help farmers across Europe to uptake IPM and to monitor the environmental performance it is crucial that the data of the FSDN will be fully connected to the data collected within Integrated Administrative and Control System (IACS), but to the level that will allow to obtain knowledge not only ‘if’ the farmer is applying ‘a’ rotation’ but knowledge about what kind of rotation is being applied and which crops. The same would be needed for landscape features, buffer strips etc. Among the environmental variables to be collected we would expect that soil analysis is reported, as well as monitoring of pollinators and beneficial insects.   It is crucial to integrate the concept of ‘transition’ into the FADN, and as a result at least half of the farmers, if possible more, must be the same farmers over the years. A substantial share of constant sample will allow to assess the cumulative effect over the years of farming practices.   In the roadmap, it is envisaged that there also need to be make links to the Farm Advisory Services (FAS). However, since 2015 it has been mandatory for FAS to be able to inform about alternatives to pesticides. Despite that, pesticide sale has not significantly been reduced in the period. Therefore, instead of linking the FSDN with the FAS, a more appropriate concept would be ensuring that at least half of the farmers taking part in the FSDN will be accompanied by scientists, civil society associations and organic growers towards application of agro-ecological practices.   Finally, the secondary legislation should consist of delegated acts.
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Response to Revision of Food Information to Consumers for what concerns labelling rules on alcoholic beverages

28 Jun 2021

Pesticide Action Network Europe (PAN Europe) welcomes this opportunity to be allowed to provide feedback to the impact assessment options being proposed regarding food labelling. PAN Europe welcomes the option 2 'revoke the exemption and require all indications on-label' including requirements on the pesticides used to produce the alcohol in questions. Giving not only information to the consumers who are drinking the alcohol about the pesticide residues that they are consuming but also giving information to the general public about bystander exposure for citizens living close to the areas where the primary product has been produced that is the basis of the alcohol.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

27 May 2021

PAN Europe welcomes the European Commission’s intent to upgrade the CLP Regulation. In view of its downstream consequences on different Regulations, including the PPPs Regulation 1107/2009, it is a key factor to significantly increase the level of protection of human health and the environment provided by the EU chemicals framework. Section A - Basis for the intervention We would have liked to see a reference to the Chemicals Strategy for Sustainability’s objective to ban the most harmful, but very much present, chemicals in consumers products; as well as a mention of the permanent chemicals’ exposure of humans and the environment. Section B – introduction of new hazard classes and corresponding criteria We welcome this plan to introduce different new hazard classes and criteria under the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation of chemical substances. Namely, we want to demonstrate our strong support to the introduction of horizontal and legally binding criteria for the identification of EDCs, PBT/vPvB, PMT/vPvM and terrestrial toxicity. In addition, PAN Europe strongly endorses the proposal of the Chemical Strategy for Sustainability to develop specific criteria for immunotoxicity and developmental neurotoxicity. All these new criteria should reflect the current state of scientific knowledge and apply the precautionary principle. Where relevant (i.e., on EDs), these criteria should be based on an integrated approach for human health and the environment. Specific comments: 1. EDs We call on the EU to fully align with the WHO ED-definition, including potential EDs, and with its definition of adverse effects. Moreover, this categorization exercise should include substances showing endocrine-active properties. 2. PBT & terrestrial toxicity We welcome the European Commission’s intent to address the lack of global harmonized standards (GHS) for terrestrial toxicity though the development of specific criteria for non-aquatic organisms. This very needed action should be coupled with the development of criteria for terrestrial persistence. 3. Immunotoxicity (DIT) and neurotoxicity (DNT) criteria Based on our experience of the PPPs Regulation’s implementation, we want to stress how key the development of stand-alone criteria for immunotoxicity and developmental neurotoxicity is. In the present circumstances, their intrinsic properties are more than neglected during the risk assessments of active substances. The development of neurodegenerative diseases such as Parkinson's is becoming a major public health problem. 4. Downstream effects on the Plant Protection Products Regulation 1107/2009 We want to highlight that this CLP Regulation upgrade can significantly improve the implementation of the PPPs Regulation due do its downstream effects on its risk assessment process. For this reason, we call for: - The regulatory consequences of these new classifications to apply rapidly to the PPPs Regulation. - These new classifications to preclude approval of any active substance; in the same current manner than for mutagenic, carcinogenic and toxic for reproduction substances. No threshold or cut-off value should be developed. Section C - Preliminary Assessment of Expected Impacts Likely economic impacts: We would like to point out the imbalance between this section and the following ones, especially as it only seems to mention the costs likely to be generated and not the costs that could now be avoided, particularly in terms of health. In our view, the positive effects on human health must also be quantified as economic costs/benefits. On the contrary, the current approach suggests that they are underestimated. Likely environmental impacts: A reference to environmental health would have been much appreciated. The current approach seems to approach issues of human health, environmental protection and social well-being in silos.
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Response to Statistics on pesticides, as regards the list of active substances

21 Apr 2021

Pesticide Action Network Europe (PAN Europe) thanks the European Commission for consulting stakeholders on their proposal for amending Regulation (EC) No 1185/2009 concerning statistics on pesticides. We trust that these contributions will be taken into consideration as part of the EU decision making process. PAN Europe welcomes that the European Commission is proposing to update the list of active substances to also include certain alternatives to synthetic pesticides. Though, we call for a clear split in the list of active substances between synthetic pesticides and alternatives. We call for the list to be upgraded to ensure annual reporting on emergency derogations (indicating quantities used and areas treated published on regional basis). Also we call for the collection of statistics to include annual collection of actual use data (again indicating quantities used and area treated published on a regional basis) based not on surveys but on actual collection of data from farmers as foreseen in article 67 of EU Regulation 1107/2009. Finally, we find it is time to delete the confidentiality clause giving EU the possibility to start collecting and releasing pesticide statistics without aggregation. Attached a more detailed position.
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Response to Statistics on Agricultural Input and Output

31 Mar 2021

Pesticide Action Network Europe (PAN Europe) thanks the European Commission for having been offered the opportunity to comment on the legislative proposal aiming at establishing Statistics on Agricultural Input and Output (SAIO) Below PAN Europe’s four comments on the text, with explanations in the attachment. 1. Welcome that the legislative proposal aims at making Member States accountable in relation to pesticide statistics 2. Oppose that Member States can base statistics on survey and ask derogations in the collection of pesticide statistics 3. Call for inclusion of EU strategy on zero pollution to measure pesticide leakage 4. Call for full recognition of the European Parliament and civil society in defining which data to deliver under SAIO
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Response to Information and promotion measures for agricultural and food products in the internal market and in non-EU countries

9 Mar 2021

Pesticide Action Network Europe (PAN Europe) thanks for the opportunity to comment on the inception Impact Assessments of the EU’s agricultural promotion policy. PAN Europe believe that the IA still needs adjustments moving policy focus towards citizens rather than businesses while focusing on policy developments towards sustainability rather than on competitiveness. Also, we propose to add a forth policy option into the IA in which eligibility is limited to promotion of circular and organic products. Finally, we call for this IA to look at the potential of enlarging the scope of EUs promotion policy of agricultural products to encourage local exchanges between citizens and farmers while upgrading the rules to ensure that at least one civil society organisation take part in each call. Each of these ideas are developed more in the attached document.
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Response to New EU Soil Strategy - healthy soil for a healthy life

8 Dec 2020

Pesticide Action Network Europe (PAN Europe) welcomes the possibility of giving feed back on healthy soils new EU soil strategy. PAN considers that, In updating the EU soil strategy, renewed commitment to a directive is required. The main issues to be addressed are soil organic matter (SOM) and soil biodiversity . We believe that baseline data on SOM needs to be expanded including wrt soil depth and where SOM is already compromised that the CAP national strategic plans should address the subject effectively covering both structure and climate issues . On soil biodiversity, we are greatly concerned about the decline in beetles, bees and earthworms whose homes are in soil and equally by the state of microorganisms where several scientists (ex. Celine Pelosi and Violette Geissen) have proven huge damage from pesticides. Soil biodiversity is starving to extinction and the effect on all soil properties is devastating. We seek action to address biodiversity issues now, and welcome that the European Commission is proposing to zoom in on soil biodiversity in all its aspects.
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Response to Revision of the EU geographical indications(GI) systems in agricultural products and foodstuffs, wines and spirit drinks

25 Nov 2020

Pesticide Action Network (PAN) Europe welcomes the opportunity to provide feedback on the roadmap on the revision of the EU Geographical indications schemes. As it was identified in the problems this initiative aims to tackle, PAN Europe agrees that sustainability is a criteria that is not sufficiently reflected in the current GIs framework and that GIs are under-exploited for the purpose of promoting sustainability characteristics. This is particularly true in a context of European citizens clearly expressing concerns regarding environmental sustainability and health. In order to achieve the objective of GIs product that are environmentally and socially sustainable and meeting societal demands and consumer expectations, PAN Europe proposes that the attribution of GIs label should be directly linked to environmental indicators evaluating the sustainability of farming practices. As PAN Europe, we propose that, in the context of the Farm to Fork Strategy and its objective of 50% pesticides reduction by 2030, GIs should act as a leading example of sustainable farming practices. This label of quality thus should be conditioned to a plan at farm-level heading towards a pesticide-free agriculture, with the commitment of effectively reducing the use of pesticides by at least 50 % by 2030. Moreover, in the context of the biodiversity strategy, PAN Europe proposes that GIs be also directly conditioned to mandatory measures of restoration of biodiversity in farms. With such conditionality, GIs would be not only indicators of traditional know-how, but also indicators of sustainability improvement on farms, providing European citizens with of label of quality, but also ensuring them that the products they buy are safe and environmentally responsible.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development) and ClientEarth AISBL

9 Nov 2020 · IPM under the new CAP

Meeting with Virginijus Sinkevičius (Commissioner) and

23 Jul 2020 · To discuss the Chemicals Strategy for Sustainability, especially with relation with endocrine disruptors.

PAN Europe demands immediate pesticide reduction without further delays

25 Jun 2020
Topic — Revision of EU rules to protect human health and environment from pesticide risks.
Message — PAN Europe calls for skipping the impact assessment to avoid pesticide reduction delays. They demand rigorous enforcement and linking agricultural subsidies to mandatory pest control standards.12
Why — Stricter rules would help protect biodiversity and public health by reducing chemical dependency.34
Impact — Chemical pesticide producers lose influence as their claims about alternative farming are challenged.5
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and

25 Jun 2020 · VC-meeting on Farm to Fork Strategy and Pesticides.

PAN Europe urges 80% reduction in pesticide use

13 Mar 2020
Topic — The European Commission's roadmap for a sustainable and healthy food system.
Message — PAN Europe calls for an 80% reduction in pesticide use by 2030. They advocate for EU-wide targets and a vision for pesticide-free agriculture.12
Why — This would fulfill the group's mission by replacing chemicals with sustainable methods.3
Impact — Chemical companies lose market share as products are phased out or taxed.45
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

6 Mar 2020 · Veneto initiative on Integrated Pest Management

Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

6 Feb 2020 · Biodiversity Strategy

Meeting with Stella Kyriakides (Commissioner)

6 Feb 2020 · Discussion on food safety

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius)

6 Feb 2020 · EU Biodiversity strategy 2030 and pesticides

Meeting with Natalie Pauwels (Cabinet of Commissioner Janez Lenarčič)

28 Jan 2020 · Green Deal

Response to EU 2030 Biodiversity Strategy

14 Jan 2020

The previous Biodiversity Strategies for 2010 and 2020 have failed to meet their objectives. PAN Europe welcomes this new attempt to define an EU-wide Biodiversity Strategy but would like to underline that this ‘new version’ should be considered the last chance for the European Commission to develop such a strategy as its credibility is now seriously undermined. PAN Europe believes that the problems identified in this roadmap are too limited leaving out an ever increasing amount of scientifically-established causes of the biodiversity decline. It remains clear that the Commission is taking an anthropocentric angle to consider biodiversity protection while the concept of ‘nature serving humans’ is at the very basis of biodiversity collapse. Nature should be protected for what it is. Protecting only the parts we believe we need will inevitably lead to an ever greater collapse of ecosystem’s resilience and biodiversity. PAN Europe calls on the European Commission to expand the identified problems including a specific reference to our intensive European model of farming including mentioning the problem caused by farmers using chemical inputs. Dropping agrochemicals and restoring habitats are of major importance to counter the collapse of biodiversity. Transforming our agriculture towards a chemical-free and biodiversity-friendly model should be clearly mentioned, considering that agriculture represents an important deal of the EU territory. Such targets are expected to be included in the EU farm to fork communication as well but we wish to recall that pesticide use is a horizontal issue which needs to be tackled through different EU policies by different Directorate Generals, as mentioned clearly in the mission letters from President von der Leyen. Furthermore, in its December 2019 resolution on the EU Pollinator Initiative, the European Parliament underlines that more efforts need to be done to reduce the use of pesticides and restore habitats to support pollinators. In addition, citizens’ support to a different agriculture is increasing in many areas of the EU, through local, regional or national initiatives or through European Citizens Initiatives such as the “Save Bees and Farmers” ECI. PAN Europe calls on the European Commission to add a specific reference to the importance of reducing dependency of pesticides and fertilisers into the upcoming biodiversity Strategy and the need to revise the CAP (including the current reform proposals). That would be in line with the missions as identified by the new Commission.
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Response to A new Circular Economy Action Plan

10 Jan 2020

The roadmap lacks any reference to the importance of also encouraging the circular economy in the EU model of farming. However, reality is that the European model of farming is becoming even more depending on exports (the European Commission tweeted recently that the export from the EU agri-business model has never been higher, showing the circularity has seriously diminished. Also, the Europe model of farming keeps on being heavily reliant on chemical inputs like pesticides. To kick of an exchange on the ecological transition that has been launched by the new Commission among others with the EU Green Deal it is crucial that the circular economy communication explicitly address the EU model of farming and as part of that its pesticides use reductions should be part of the reflection on the circular economy.    Pesticide use reductions are considered a policy instruments to support green growth in agriculture according the OECD. Their Green Growth Study says: “Specific, quantifiable and time-bound targets have been mostly reported in the area of reducing energy use, increasing the share of renewable energy in total energy use, use energy efficiently, increasing that of buildings, extending the area of organic farming, and, for a handful of countries, reducing the use of harmful pesticides”.
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PAN Europe demands full implementation of bee protection standards

11 Jul 2019
Topic — This consultation concerns updating uniform principles for evaluating and authorizing plant protection products.
Message — PAN Europe requests the full implementation of updated bee safety guidelines. They argue that excluding chronic toxicity and bumble bee health from assessments is illegal.12
Why — This would advance their advocacy goals of securing stricter environmental and health regulations.3
Impact — Pesticide manufacturers would face more rigorous testing requirements and more frequent authorization denials.4
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PAN Europe slams premature EU endocrine disruptor fitness check

10 Jul 2019
Topic — Evaluation of EU regulations protecting health and environment from hormone-disrupting chemicals.
Message — The organization argues the fitness check is premature and risks causing unnecessary delays in protecting human health. They urge the Commission to implement existing laws immediately and establish a category for potential endocrine disruptors.123
Why — Faster enforcement would help achieve their goal of phasing out hazardous chemicals from the market.45
Impact — Pesticide and biocide manufacturers would face more frequent product bans and mandatory testing requirements.67
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Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker) and Greenpeace European Unit and

20 Jun 2019 · Pesticides

Response to EU agricultural policy : Evaluation of its impact on knowledge exchange and advisory activities

19 Jun 2019

Pesticide Action Network Europe (PAN Europe) welcomes this public consultation. PAN Europe fully agree with the proposals made by EEB. With a special focus on pesticides, PAN Europe regrets that the public consultation does not explicitly mention that it is mandatory for Member States to inform farmers about alternatives to pesticides and uptake of requirements in the EU Directive on Sustainable Use of Pesticides since 2015. As highlighted in the attached position paper, PAN Europe believes that not enough attention is being given at neither EU nor regional level to build up independent, neutral, visual and dynamic Farm Advisory Systems. As member of the expert group on EIP-AGRI we also notice that level of ambition at least at Member State level is not overwelming. So building on the proposals from EEB, we would like to add that the upcoming evaluation should focus on - To what extend each FAS has the adequate knowledge about alternatives to pesticides (which is often crop specific) including the more agro-ecological solutions and how farmers at the local level obtain this knowledge not only when asking but also as inspiration (assisting the farmers in not only applying the already approved neo-nicotinoid ban but also preparing him/her for potential future bans) - To what extend each FAS is independent and neutral (how are the advisers being trained, how does the advisers obtained information..) and what each adviser do to actively assist farmers in thinking longer term planning (economic and agronomic planning) proposing forgotten solutions like introduction on crop rotations with use of leguminous, introduction of hedges, bufferstrips... Also, we would encourage a part of the evaluation looking into how the Member States are using the current knowledge being build up within the EIP-AGRI (with a few examples mentioned in the attached position paper). Finally, the evaluation should look into how the advisors are informing farmers about the health and environmental effects of using pesticides.
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Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

7 Feb 2019 · Neonicotinoids

Response to Establishment of Harmonised Risk Indicators to measure the reduction in risks and adverse impacts from pesticide use

11 Dec 2018

PAN Europe believes that this is a positive start to developing the much needed harmonized risk indicators throughout the EU but it does not go far enough to deliver the required objectives as foreseen in the SUD. We urge the Commission and Member States to adopt these proposals and to further amend and enhance them over time in order to provide the highest level of protection for human health and the environment across the EU. For details please do see our attached position done as a collaboration between PAN Europe, PAN Germany and PAN UK.
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Response to Evaluation of the impact of the CAP on habitats, landscapes and biodiversity

6 Dec 2018

Pesticide Action Network (PAN) Europe recalls the following studies showing the major decline of biodiversity linked to agroindustrial practices: • Hallmann CA et al. (2017): more than 75 percent decline over 27 years in total flying insect biomass in protected areas neigbouring agricultural areas • Silva V et al. (2018) identifying pesticide residues in more than 80% of European agricultural soils and concluding that pesticide mixtures need urgent attention PAN Europe therefore recommends that the Commission’s evaluation of the impacts of the CAP on habitats, landscape and biodiversity gives a special attention to pesticide use. More generally we recommend the evaluation to cover the following topics: 1. Impact of CAP on drivers of biodiversity loss, including: a. pesticide use b. fertilizers’ use as fertilizers weaken plants’ health c. water use and water contamination with pesticides/fertilizers d. destruction/maintenance/restoration of landscape features e. direct persecution of wildlife (including beneficial species) f. intensification of management (increasing chemical inputs, use of mono-cultural cropping leading to reduced plant health, as explained in the Danish fact finding mission (http://ec.europa.eu/food/audits-analysis/audit_reports/details.cfm?rep_id=3897). This report indicates that: §80: An increasing problem controlling grass-weeds due to higher concentration on winter crops (with higher revenue) rather than having better rotation with more spring crops which could facilitate more cultural control. The Competent Authorities are aware of this issue, but to date they have not introduced any specific initiative to promote better rotations. §81: SEGES stated that the control of Septoria on winter wheat is becoming more difficult due to the declining efficacy of triazole fungicides; that there are limited alternatives to chemical pesticides, but growing more spring crops and sowing a mixture of varieties within the same field can help. 2. Knock on impacts of CAP subsidies, including the impact of pesticide use on biodiversity 3. Assessing the impact of individual CAP tools: a. Cross compliance: an analysis on the actions taken by the European Commission since the CAP aims at integrating the Directive 128/2009 on Sustainable Use of Pesticides and the Water framework directive 2000/60 into Cross compliance b. Greening payments: an analysis of how pesticide-free Ecological Focus Areas are expected to protect biodiversity c. Agri-environment schemes: an analysis on how much farmers have benefitted from IPM payments, how much they have received per ha in the various Member States, and how much the pesticide use has been reduced g. Natura 2000 payments: an overview of the proportion of these areas are pesticide-free 4. CAP and data gathering: a. Whether and to what extent the CAP is contributing to appropriate gathering and use of biodiversity-relevant data and evidence, including a reflection on how to expand EU tools like LUCAS to measure biodiversity and indicators of pollinators (pilot project of DG SANTE) on butterflies (pilot project of DG ENVI). b. Which tools are best 5. Evaluation process, methods and transparency: it shall be transparent and science based. Peer review scientific literature produced by scientists that have no conflict of interest with the agro-industry must be given priority. Attention should be given to grey literature and comments should be provided a feed-back. 6. Evaluate how the current CAP negatively impacts beneficial organisms that can replace pesticides. How CAP fail from supporting farmers in selecting plant resistant varieties. 7. Evaluate how CAP fails to support a transition of agriculture that is compatible with the objectives of the European Commission Pollinator Initiative.
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PAN Europe demands stricter pesticide checks for endocrine disruptors

11 Oct 2018
Topic — Updating renewal procedures for pesticides based on new endocrine disrupting property criteria.
Message — Apply new scientific criteria to all active pesticide substances currently undergoing assessment. Prevent companies from submitting additional data to challenge findings on endocrine properties. Ensure substances meeting any criteria are immediately withdrawn from the European market.123
Why — Strict rules would help the group achieve its goal of chemical-free environments.4
Impact — Pesticide producers lose opportunities to provide evidence defending their products' market status.5
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Response to Multiannual Financial Framework - CAP Strategic Plans

22 Jul 2018

Pesticide Action Network Europe (PAN Europe) would like to take this opportunity to express its disappointment with the 9 EU wide objectives measured by 36 impact indicators. The proposed indicators needs to be come much more targeted to successfully measure environment, biodiversity and health aspects of the the CAP strategic plans. Also, PAN Europe highlights that it is crucial that the CAP strategic plans will find away to upkeep links between actual farmers compliance and the CAP, rather than only depending on Member States reporting. As a beginning the CAP strategic plans should expanded adding mandatory monitoring of pesticide use as foreseen in article 67 of EU Regulation 1107/2009 into the mandatory statutory mandatory requirements of the cross compliance rules. Finally, it is another lost opportunity of the CAP and the MFF discussions that the aspect of polluter pays principle is getting any attention. Why not add a third pillar of the CAP containing possible new funding from introduction of taxations starting with pesticide taxation, like proposed as part of the campaign living land: https://www.living-land.org/blog/2017/3/23/progressive-taxes-on-pesticides-can-save-both-agriculture-and-nature?
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Pesticide Action Network urges ban on endocrine disrupting chemicals

19 Jul 2018
Topic — The European Commission is seeking feedback on a comprehensive framework for endocrine-disrupting chemicals.
Message — PAN Europe demands the total elimination of endocrine-disrupting pesticides from agricultural use. They call for harmonized identification and the rapid adoption of updated safety testing requirements across all EU legislation.123
Why — Stronger regulations would help the group achieve its goal of protecting public health.45
Impact — Chemical manufacturers would see profitable pesticides removed from the European market.6
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Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

5 Jun 2018

PAN Europe strongly supports an amendment of the Aarhus regulation in order to comply with the Aarhus convention and with the findings of the Aarhus convention compliance committee from 17/03/2017. The way the Aarhus regulation prevents citizens and NGOs to have access to justice concerning environmental matters is a denial of citizens’ democratic rights. PAN Europe regrets that at the last MOP meeting, the European Commission tried to block the endorsement of the ACCC decision. In our opinion, the European Union should take the lead in terms of access to justice concerning environmental matters. We strongly oppose to the argument provided in the roadmap that this might have an increased cost as this would guarantee a proper implementation of environmental laws and an increase in trust towards the institutions by citizens. The EU as a whole would benefit from such a measure. Furthermore, the European Parliament and the Council have reacted positively to the conclusions of the ACCC and the Commission should thus swiftly make the necessary changes. Concerning pesticide authorisations, access to justice is very different from one Member State (MS) to another. While some more progressive MSs like the Netherlands and France provide easy access to justice concerning the authorisation of pesticides, it is not the case in many others (Germany) or at the level of the Court of Justice of the EU (CJEU). Furthermore, Dutch or French citizens/NGOs can potentially have access to the CJEU through prejudicial questions sent by national courts while German citizens cannot. This unequal situation should be solved by opening access to justice for civil society to all administrative acts related to the environment Furthermore, while currently companies have access to justice when they do not agree with a decision taken by an administrative authority, it is generally not the case for citizens. This is an undemocratic situation as this lack of balance will inevitably lead to decisions made in order not to displease companies rather than in the interest of the general public. Currently the only way NGOs can act against maladministration by the European Commission is by sending a complaint to the EU Ombudsman. Even if the Ombudsman agrees with the complaint done by civil society, its decisions are not legally binding and the European Commission sometimes simply do not implement the Ombudsman’s recommendations. This lack of balance is unacceptable for citizens and gives the feeling the European Commission gives more importance to industry rather to citizen’s will and the environment. We thus ask the European Commission to remedy without delay to the incorrect transposition of the Aarhus convention into EU law and follow the ACCC recommendations. This would send to the general public a very good sign of improvement of our democratic system.
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Meeting with Vytenis Andriukaitis (Commissioner) and

20 Apr 2018 · General Food Law

Response to Minimum standard VAT rate proposal

18 Jan 2018

Pesticide Action Network Europe congratulates the European Commission for taking forward the idea of amending Directive 2006/112/EC on the common system of value tax with regard to the obligation to respect a minimum standard. What is urgently needed is to make sure that Member States: 1) stop applying artificially low VAT on products like pesticides and fertilisers which are harmful to the environment and public health, while we are not again applying low levels of VAT on products which are beneficial for the environment (ex. organic products). 2) start considering applying taxes reflecting the 'pollutor pays' principle. 1) A number of member states (among others Cyprus, Romania, Slovenia, Portugal and Poland) are according the EU's own official statistics applying artificially low levels of VAT for pesticides: https://ec.europa.eu/taxation_customs/sites/taxation/files/resources/documents/taxation/vat/how_vat_works/rates/vat_rates_en.pdf. We regret that this aspect has not been integrated into the amended proposal (COM (2017)718 final). COM (2017(718) final says on page 2 that 'Considering that all Member States currently apply a standard rate of at least 17%..." In reality countries like Cyprus, Romania, Slovenia, Portugal and Poland all apply VAT levels below this level for chemical pesticides and fertilisers. It is crucial that minimum VAT levels of 15% are set for products which are damaging environmental and public health, such as pesticides. On the other side, in the discussions on introducing of 15% minimum VAT, it is needed to look into allowing low VAT levels for environmental and public health friendly products, ex. organic, to booth consumption. 2) A few member states have started to introduce pesticide taxation: http://www.pan-europe.info/issues/pesticide-taxation. We regret that the proposal COM (2017)728 (final) does not go beyond the idea of proposing a common system of VAT, to also start looking at the issue of environmental taxation. Recent work which should have been included covers not only work of PAN Europe (mentioned above) but also reports from Institute for European Environmental Policy (IEEP) and from Green Budget Europe as well as scientific papers from scientists like Robert Finger, all giving clear guidelines on how to take this approach further.
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PAN Europe urges pesticide reductions to save EU pollinators

19 Dec 2017
Topic — A consultation on an EU strategy to stop the decline of pollinators.
Message — PAN Europe demands quantitative pesticide targets and an end to emergency authorizations. They advocate for agricultural reforms prioritizing nature-based solutions and low-impact farming.123
Why — This would accelerate the transition to the organic farming models they promote.4
Impact — Pesticide manufacturers would lose revenue from stricter marketing rules and banned emergency authorizations.5
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Response to Fitness Check of the Water Framework Directive and the Floods Directive

17 Nov 2017

Taking into account the scope of this fitness check, that will look at “the relevance, effectiveness, efficiency, coherence and EU added value of the Water Framework Directive”, which represents “the most comprehensive instrument of EU water policy…with the aim of achieving good status of EU waters”, it seems quite reductive and biased to have as purpose “a quantitative assessment of actual costs and benefits including impacts on business” and “an assessment of the potential for regulatory simplification and burden reduction”. Indeed, the scope of this evaluation cannot be just an analysis from an economic and regulatory point of view, but it should include also the social, public health and environmental aspects. The WFD and its “daughters-directives” aim to establish guidelines and standards in order to achieve a good ecological status in all european water bodies, which includes the aquatic contamination matter. From this point of view, it’s important to point out that the list of the main pollutants present in the WFD includes substances “which have been proved to possess carcinogenic or mutagenic properties or properties which may affect steroidogenic, thyroid, reproduction or other endocrine-related functions in or via the aquatic environment.” In fact, several man-made chemicals present in the aquatic environment may influence the reproductive capabilities of both vertebrates and invertebrates by adversely affecting the function of the endocrine (hormonal) system, thus resulting in several adverse health outcomes including reduced fertility and fecundity, spontaneous abortion, male and female reproductive abnormalities, precocious puberty, neurobehavioural disorders, impaired immune function and a wide variety of cancers among other effects. In the aquatic environment, several well-documented studies have described the impact of these compounds, termed endocrine disruptors, in wildlife. Many chemical pesticides have showed these properties, as they are designed to have a a toxic action to living organisms mostly by affecting enzymatic activities with key role in the regulation of the endocrine system, thus representing the largest group of EDs. A few of these endocrine disrupting pesticides (EDPs) have been already banned, though they are still present at environmentally relevant dosis, and others are in the market yet. A complementary table is provided together with this feedback, focusing on some exemplary EDPs and their toxic effects on aquatic species. Pesticide pollution is an important element of the WFD. Here it’s important to point out that traditional approaches to determining safe exposure levels (for example, chemical risk assessments) do not work with EDCs, as a central feature of endocrine disruption is that may cause detrimental effects on organisms at very low chemical concentrations Thus, while wildlife is particularly vulnerable to the endocrine disrupting effects of pesticides at the environmental level, with effects noted in invertebrates, reptiles, fish, birds and mammals, it is often difficult to duplicate these precise effects in laboratory animals. At this stage therefore we call for a better implementation of the WFD before requiring any changes. We fully support the Commission’s feedback that “we still have a long way to go before the quality of all EU waters is good enough, due to decades of previous degradation and persisting ineffective management” (Communication from the EU Commission 9.3.2015 COM(2015)120 final, p. 3). Our focus right now should be directed to implement the protection targets, and helping Member States to reach these goals.
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Meeting with Vytenis Andriukaitis (Commissioner) and

12 Jul 2017 · Neonicotinoids

Response to Changes to greening rules and clarifications of certain other direct payments' rules

11 Jan 2017

PAN Europe welcomes the idea of the European Commission to ban pesticide use in Ecological Focus Areas (EFAs). These EFAs were introduced as part of the greening measures of the 2013 reform of the CAP ‘in order to safeguard and improve biodiversity on farms’. Banning pesticides is a simple and humble move to help citizens understand the “ECOLOGICAL” in ecological focus areas. Reality so far is according the European Commission analysis entitled “greening after one year” that 1) the majority of the EFAs so far defined by Member States are linked to a productive activity — nitrogen-fixing crops and catch crops — accounting for 73.1 % of the total EFA area (before the application of weighting factors), and that 2) only a few Member States have introduced restrictions on pesticides use: three for catch crops (BE Flanders + Wallonia, DE, NL) and one for nitrogen-fixing crops (BE, Wallonia). This is definitely not a satisfying situation and needs to be changed. If we can’t even ban pesticides in EFAs, it is worth considering at least the continuation of the payment of the greening of the CAP in the next EU budget review. It is a pity that the debate on EFAs to production related elements is really a pity. It is time to recall that EFAs is a tool able to attract more natural predators and pollinators into the fields again. and not only, extensive research work (http://www.pan-europe.info/sites/pan-europe.info/files/presentation%20Wäckers%201%20dec%2016.pdf) shows very clearly that, properly managed EFAs, deliver not just more biodiversity but can even result in yield increases in adjacent fields of greater than 10% for wheat, 20% for beans and 30% for carrots. Many comments made by the farming community so far in this public consultation argue for the importance to reduce dependency on important protein crops. We welcome this remark but - like the 33 MEPs mentioned in their letter on this topic http://www.greens-efa.eu/legacy/fileadmin/dam/Images/Topics/Agriculture_and_fisheries/PPP_on_EFAs_letter_10_10_2016.pdf - we would like to recall that reducing this dependency will be best addressed by growing more leguminous crops as part of a crop rotation in the fields, while the main purpose of EFAs should become encouraging more biodiversity in the fields.
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and Greenpeace European Unit and Corporate Europe Observatory

9 Mar 2016 · Glyphosate

Meeting with Vytenis Andriukaitis (Commissioner) and

30 Jan 2015 · The Food Chain, Innovation and Challenges, Food Information to Consumers, Nutrition, and Food Waste, Animal Health, Animal Welfare and Plant Health

Meeting with Vytenis Andriukaitis (Commissioner) and

23 Jan 2015 · EU Policy on Pesticides