POLLINIS
POLLINIS, a nonprofit organization, campaigns for sustainable farming in Europe.
ID: 423355921224-78
Lobbying Activity
Response to Farm to Fork Strategy
16 Mar 2020
Farm to Fork Strategy - POLLINIS’ feedback
Europe faces a massive decline of pollinators. This dramatic decline will have serious consequences on food security, biodiversity and the overall ecosystem. As demonstrated by a growing scientific consensus, urgent measures have to be adopted to hamper this decline, by intervening on its main drivers: loss of habitat and exposure to pollutants, linked to intensive, industrial-scale farming practices (genetically-uniform monocultures, wholesale use of synthetic pesticides and fertilizers, land-use change and landscape fragmentation, elimination of hedgerows and trees). As stated by the authors of a recent meta-analysis on insect decline (encompassing 73 studies published in the last 13 years),« unless we change our ways of producing food, insects as a whole will go down the path of extinction in a few decades ».
Hence, the Farm to Fork Strategy represents one of the last opportunities for Europe to halt the extinction of pollinators and its consequences. The European Court of Auditors stated that the CAP reform, as presented by the European Commission, is not sufficient to respond to the environmental emergencies we are facing. In this context, POLLINIS appeals to the European Commission to guarantee that the Farm to Fork Strategy can live up to the European Green Deal’s objectives, by playing a pivotal role in the transition to diversified agroecological systems and the phasing out of the use of synthetic pesticides and fertilizers. Such an objective needs a cross-sectoral and holistic approach. A proper coordination and harmonization of all EU legislations, including legislations on pesticides, the Green Deal, the Farm to Fork Strategy, the CAP reform, is the conditio sine qua non for a successful transition towards a sustainable, pollinator-friendly food production system.
In particular, POLLINIS underlines four key points of this cross-sectoral approach: 1) the phasing out of the use of synthetic pesticides and fertilizers and the improvement of risk assessment; 2) the CAP reform; 3) a moratorium on new genomic techniques; 4) the transparency issue.
Read full responseResponse to EU 2030 Biodiversity Strategy
20 Jan 2020
While welcoming the aims of the EU 2030 Biodiversity Strategy, POLLINIS stresses the importance of tackling the root causes of the present dramatic decline of insect populations and, in particular, of pollinators, in order to halt and overturn the present negative trends. These root
causes are the loss of pollinators’ habitats and their exposure to pesticides.
Insect population decline is taking place at an alarming rate. The most recent scientific evidence is overwhelming: the proportion of insect species decline (41%) is twice as high as that of vertebrates, and the pace of local species extinction (10%) eight times higher. Globally, over a
third of all insect species are threatened with extinction.
76% of flying insects have disappeared from German protected areas, a figure that can be extended to the whole of Europe. Pollinating insects are particularly endangered, with many species extinct or threatened with extinction. Behind the well-documented loss of honey bees, is
a wider problem: the collapse of European wild pollinating insects.
Considering the crucial role that insects and pollinators play in the reproduction of ecosystems and agricultural production, their plummeting decline will trigger catastrophic repercussions on both biodiversity and food security.
Scientific evidence indicates that the main drivers of pollinators’ decline are loss of habitats and exposure to pollutants, as a result of farming practices: monocultures, synthetic pesticides and fertilizers, land-use change and landscape fragmentation, elimination of hedgerows and trees.
As stated by the authors of a recent meta-analysis on insect decline "Unless we change our ways of producing food, insects as a whole will go down the path of extinction in a few decades". The EU needs to make this transition now: we only have limited time to act.
In order to preserve pollinators and the whole ecosystem in which insects are the structural and functional base, the 2030 EU biodiversity strategy must focus, as key priorities, on the transition to diversified agroecological systems and the phasing out of synthetic pesticides and fertilisers, including EU-wide binding reduction targets.
Without the clear objective of a paradigmatic shift in agricultural practices, leading to a pollinator-friendly and sustainable food system, based on diversified agroecological systems, it is likely that the future strategy will fail, as did the two preceding ones.
This ambitious objective must be achieved through a cross-sector approach, in which the 2030 EU biodiversity strategy is interwoven with the different EU policies that affect food production and mainstreamed in the relevant EU regulations, to ensure ambitious and enforceable legal
measures and binding targets.
In this perspective, sectoral policies should be realigned with the biodiversity strategy goals: especially the future CAP must ensure consistency of farm practices with biodiversity conservation and the preservation of pollinator populations. The strengthening of systemic agri-environment measures and the transition to organic farming need to be a priority of the next CAP.
Finally, additional measures must include:
• Those mentioned in the EU Pollinator Initiative, as amended by the recent PE resolution, which should become an integral part of the Strategy.
• The creation and protection of pollinator-friendly habitats (natural areas, wildlife set aside land, wild-flower set aside, grass strips, grasslands, hedgerow), which supply essential resources for pollinators, and form ecological corridors favouring species movements.
• The preservation of local bee species and sub-species, through the establishment of conservation areas on the different geographical habitats of these species and their legal recognition.
(Integral contribution and bibliographical references in Annex).
Read full responseResponse to Uniform principles for evaluation and authorisation of plant protection products
4 Jul 2019
POLLINIS believes that the proposed amendments to the uniform principles (Reg. 546/2011) should not be limited to acute toxicity tests, but should also include chronic toxicity and larvae toxicity tests.
This comment represents the citizens who have already signed POLLINIS' petitions at national (France) and European level for the immediate implementation of the EFSA Guidance Document on Risk Assessment for Bees (2013, 2014). These petitions have attained so far almost 300,000 signatures.
The EFSA GD tests for acute, chronic and larvae toxicity were developed as a whole, whose various components complement each other, in order to provide a sufficient database to identify potentially harmful products in the first-tier evaluation. Each test provides a different type of data, which nonetheless are all indispensable to identify potential risks that plant protection products may pose to pollinators. Limiting this step exclusively to acute toxicity tests would prevent a reliable evaluation of such products’ impact on bees and biodiversity. It is scientifically proven that an assessment of lethal and sublethal effects derived from chronic exposure is crucial for a proper risk assessment on pollinators.
Thus, being limited to the acute toxicity tests alone, the proposed amendments cannot guarantee that the specific protection goals for pollinators are met, nor that these insects' protection will be efficiently ensured across Europe.
In the light of the ongoing and dramatic decline of pollinators, the reasons behind such a decision to exclude chronic end larvae toxicity tests from the proposed amendments remain incomprehensible, considering that:
● Chronic toxicity and larvae toxicity tests are required by current regulations (EU No. 283/2013 and EU No. 284/2013);
● Their implementation is simple and cost-effective;
● Their protocols have been internationally ring-tested and validated (OECD 245; OECD 239);
● The main scientific experts at the European level have conducted a comprehensive and transparent research to determine trigger values for these tests, which no scientific work has questioned.
Citizens represented by POLLINIS believe that there is an urgency to adopt chronic and larvae toxicity tests, and request that the Commission also include these key tests into their amendment proposal, as initially foreseen in its proposition to Member States of July, 2018. These tests could make a difference in protecting pollinators across Europe.
Finally, we express our concern for the lack of transparency surrounding the activities of SCoPAFF, the committee which has been blocking the adoption of the EFSA Bee Guidance Document for the last six years. Citizens are prevented from knowing the position of Member States or the reasons why some of them continue to block the adoption process.
The DG SANTE has denied us access to such information. However, in addressing our complaint on this matter, the European Ombudsman has clearly stated that:
“there is no provision in the Comitology Regulation which says that summary records shall not contain the individual positions expressed by Member State representatives within the scope of committee proceedings. Nor is there any other provision in the Comitology Regulation, which would impose confidentiality requirements on committee proceedings. On the contrary, Recital 19 of that Regulation makes it clear that public access to information on committee proceedings should be ensured in accordance with the EU law on public access to documents”.
For these reasons, she states, “The Commission should grant public access to the requested documents, showing the positions of Member States on the draft bee guidance, in line with the principles explained above”.
Read full responseMeeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker) and Greenpeace European Unit and
20 Jun 2019 · Pesticides
Response to EU Pollinators Initiative
22 Dec 2017
POLLINIS welcomes this urgent and much needed EU Pollinators Initiative. An improved coordination of EU actions beneficial to pollinators, associated with this initiative objectives, are now essential to avoid a pollinators armageddon in Europe.
I. As far as the first objective is concerned (Improve knowledge on pollinators), we would like to recall that the main reason of such a lack of datas on wild pollinators is the present model of research applied to agriculture, which privileges private research at the expenses of independent, public institutions-based research. For this reason, important research programs funded by the EU are crucial to fill these knowledge gaps on challenges faced by pollinators.
As far as the second objective is concerned (Tackle the causes of the decline of pollinators), POLLINIS recalls that no initiative on pollinators protection will be effective if several urgent issues regarding pesticides are not tackled, namely:
1) Neonicotinoid-based pesticides, which play a certain role in the worrying decline of pollinators, as can be seen from a range of international studies (see for instance TFSP 2017, Woodcock et al. 2017, Goulson et al. 2015) should be permanently banned on the European market, with no derogations and as a priority measure, in order to protect pollinators populations.
2) The juridical and technical frame of risk assessment needs to be better implemented/updated. In particular, specific protocols should be implemented/developed to assess and monitor:
a) sub-lethal effects of PPP, and of systemic pesticides especially, and chronicle exposure impacts on pollinators;
b) the interactions among the different components of PPP formulations (active substances and their safeners, synergist and coformulants (Mullin et al. 2015);
c) the synergic effects among different substances (neonicotinoids and fungicides for instance, see Sgolastra et al. 2016,) present in the environment;
d) the impact of PPP on real field contexts and not only laboratory testing.
e) the list of unacceptable coformulants, as provided by art. 27.2 of CE 1107/2009 regulation.
f) to clearly establish that environmental laws and regulations (i.e. of superior public interest) should take precedence over commercial ones.
A good starting point for the development of such protocols could be the Guidance Document on Risk Assessment on Bees (EFSA 2013), which need to be approved and put into action without further delay.
3) European agricultural policy: a)Integrate pollinators issue in the current CAP reform, especially on farm subsidies, which should take account of pollinators-friendly practices (i.e. ecological focus areas).
b) Juridical frame of Integrated Pest Management should become legally binding : the directive 128/2009 promoting the sustainable use of pesticides and IPM should be converted into a binding and harmonised regulation for all Member States.
POLLINIS also stresses the importance of EC further commitment to put in place measures to increase legal protection and financial support for local honey bee ecotypes and pollinator populations throughout the European Union, including legally protected locally endemic honeybee and other endemic pollinators conservation areas.
III. As far as the third point is concerned, POLLINIS would like to stress that, beside the initiatives mentioned in the roadmap, it is very important to further enhance civil society participation, including associations not only in public consultations but also in workshops and other institutional debates.
To go further, you can watch the interview of the vice-president of the Task Force on Systemic Pesticides here : https://www.youtube.com/watch?v=rJFshy9PuX0
You can also see the interview of Professor Hans de Kroon and Caspar Hallmann, authors of the study "More than 75 percent decline over 27 years in total flying insect biomass in protected areas" : https://www.youtube.com/watch?v=6fonVSsGvOQ
Read full response