IBMA position on the SUR proposal

Discover here IBMA Position on the Sustainable use of PPPs Regulation proposal.

IBMA welcomes that the Directive is being upgraded to a Regulation, which will certainly give it an implementation force that is quite different to its previous position as a Directive. IBMA also welcomes the coherence with the CAP Strategic Plans as MSs may apply financial incentives or mitigation to offset some impacts.

IBMA appreciates that an EU definition of ‘biological control’ that encompasses the four categories of biocontrol has been included in the Regulation. These categories are: invertebrate biocontrol agents, microbials, semiochemicals and natural substances.

The text of the Regulation contains mainly references to ‘low-risk’ products as products that preferably should be used. IBMA advocates that this should be extended to biocontrol products in general. To promote the use of biocontrol even more the definition of ‘non-chemical methods’ can be expanded by explicitly mentioning biocontrol. In addition, all products that are currently authorised for non-professional use should remain available for ‘non-professional users’. Distributors should be stimulated to recommend not only low-risk products, but low-risk and/or biocontrol products.

IBMA advocates that the use of biocontrol should be permitted in sensitive areas.

In the Regulation it is stated that each MS should include an indicative positive target for biocontrol in their NAPs. IBMA recognizes the reduction targets and asks for an equivalent positive target to provide legal clarity for investment in biocontrol in Europe. IBMA advocates that a 75% positive target for biocontrol at EU level would be necessary to achieve the full agro-ecological transition. Relevant indicators to measure and monitor this transition are provided.

IBMA welcomes the inclusion of biological control adoption measures and national indicative target for each “non-chemical method” in National Action Plans including a list of the obstacles to biocontrol and the steps being taken to remove these obstacles.

The definition of Integrated Pest Management (IPM) has not really been ‘modernised’ compared with the one in the Sustainable Use Directive and is still considered not strong enough as it should explicitly refer to prioritise biological control and using chemicals only if essential. The definition of IPM should also reflect that IPM is ‘an ecosystem-based strategy’. In this respect also the contribution from IPM to the EU Biodiversity Strategy for 2030 and the functioning of ecosystems and ecosystem services should be more emphasized and indicators for IPM such as the presence of pollinators and beneficial invertebrates should be established in this context.

IBMA welcomes the mandatory training for professional users and advisors on IPM and biocontrol, as well as the incentive for advisors to attend such training through conditional renewal of professional advisory qualification. The establishment of mandatory IPM advice records through an electronic IPM register to justify the treatment programmes used, is considered essential to compare IPM practices. The knowledge and experience that growers have gained on IPM methods need to be communicated more widely. To achieve this appropriate training and communication tools need to be used. Also ‘Crop-profiles’ or ‘IPM Profiles’ that provide an overview of production and pest management practices for a specific crop can become important tools to achieve these goals.

Drone (UAV) application should apply both to biocontrol products and to low-risk products. IBMA welcomes that a competent authority designated by a Member State may permit aerial application by a professional user.

Harmonised Risk Indicators should allow separation from chemical control, measurement of biological control and to apply a fair weighting system. Measurement of biological control should be based on area treated, not volume. The French calculation of NODU allows to convert quantities of active substances into treated areas.

5 Top Priorities explained:

Definition of biological control: IBMA welcomes the recognition of biological control as a specific form of plant protection through an EU definition of ‘biological control’ including the four categories of biocontrol (Article 3(23)). These categories are: invertebrate biocontrol agents, microbials, semiochemicals and natural substances. The definition of ‘biological control’ should read as follows: ‘biological control’ means the control of organisms harmful to plants or plant products using natural means of biological origin or substances identical to them, such as micro-organisms, semiochemicals[1], extracts from plant products as defined in Article 3(6) of Regulation (EC) No 1107/2009, and other natural substances[2] , or invertebrate macro-organisms.
Sensitive areas: The use of biocontrol (including invertebrate macro-organisms) should be permitted in sensitive areas as the current text now states that “The use of all plant protection products is prohibited in all sensitive areas and within 3 meters of such areas” (Article 18(1)). As a general principle biocontrol products should be allowed to be used in all areas used by the general public, such as a public park or garden, recreation or sports grounds, or a public path. The use of biocontrol would also allow the continuation of organic farming in ecologically sensitive areas as it is today, such as crop production, forestry and grassland use. It is recommended to distinguish between “sensitive areas relating to human activity e.g. public spaces” and “ecologically sensitive areas” because human and environmental exposure scenarios are different in urban and rural situations.
Therefore, it is recommended to amend Article 18(1)) as follows: “The use of all plant protection products except biological control plant protection products and invertebrates macro-organisms as defined in (Article 3(23)) is prohibited in all sensitive areas and within 3 meters of such areas. This 3 meter buffer zone shall not be reduced by using alternative risk-mitigation techniques.”.
If permits for the use in sensitive areas are issued by competent authorities, IBMA questions how harmonization between MSs can be guaranteed and how the competent authorities deal with the differences between a ‘human health sensitive area’ and an ‘ecologically sensitive area’.
Positive Targets: In the Regulation it is stated that each MS should include an indicative positive target for biocontrol in their NAPs (Article 9). IBMA recognizes the reduction targets and asks for an equivalent positive target to provide legal clarity for investment in biocontrol in Europe. IBMA advocates that a 75% positive target for biocontrol at EU level would be necessary to achieve the full agro-ecological transition.
Harmonised Risk Indicators (HRI): In the current SUR proposal the calculation of HRI 1 will be based on statistics on the quantities of active substances placed on the market in plant protection products under Regulation (EC) No 1107/2009 (Article 4, Annex I). IBMA asks that HRI 1 measurement be adapted for biological control because, contrary to chemical active substances, biocontrol may work at hundreds of grammes or be measured in different units such as colony forming units (cfu). The current system favours chemical plant protection products. Measurement of biological control should be based on area treated, not volume.To overcome the limitation posed by volume the French calculation of NODU[1] allows to convert quantities of active substances into treated areas. While we recognize that data available to include in HRI will be governed by the Statistics of Agricultural Inputs and Outputs (Draft Regulation on SAIO)[2] which is currently under review, IBMA considers that an HRI based solely on quantity of active substance is limiting visibility of the achievement of the Farm to Fork objectives. It is important that the HRIs provide a measure of progress towards pesticide reduction targets and indicate the growth of alternative methods such as biological control. To do this requires:

Separation of biological control from chemical PPPs so they can be measured separately. For this, biocontrol PPPs should be clearly identified on a list.
Quantity of active substance can be used but should be noted that modern chemistry has application rates of a few grammes while biocontrol may work at hundreds of grammes or being measured in different units such as colony forming units (cfu’s)
Replacement of uses with biological product alternatives is a measure that can be used and is applied in Article 9 in the preparation of National Action Plans. It may be necessary to take this into consideration when evaluating any modifications in the HRI.
The calculation of HRI 2 should be adapted for Biological control. It is recommended that biocontrol and low-risk products should be treated similarly regarding the calculation for Harmonised Risk Indicator 2 (number of emergency authorisations, Annex VI) as these type of products should preferably be used. Although a hazard weighting is applicable for low-risk substances, this is currently not foreseen for biocontrol products in general. Now biocontrol products could even be weighted with a factor 8 or even 64. Therefore, biological control should be treated similarly to low-risk products and be included in ‘group 1’ or, alternatively, both groups should be excluded from this calculation. This would result in a fair weighting system.

Separation of biological control from chemical PPPs so they can be measured separately. For this, biocontrol PPPs should be clearly identified on a list.
Quantity of active substance can be used but should be noted that modern chemistry has application rates of a few grammes while biocontrol may work at hundreds of grammes or being measured in different units such as colony forming units (cfu’s)
Replacement of uses with biological product alternatives is a measure that can be used and is applied in Article 9 in the preparation of National Action Plans. It may be necessary to take this into consideration when evaluating any modifications in the HRI.
The calculation of HRI 2 should be adapted for Biological control. It is recommended that biocontrol and low-risk products should be treated similarly regarding the calculation for Harmonised Risk Indicator 2 (number of emergency authorisations, Annex VI) as these type of products should preferably be used. Although a hazard weighting is applicable for low-risk substances, this is currently not foreseen for biocontrol products in general. Now biocontrol products could even be weighted with a factor 8 or even 64. Therefore, biological control should be treated similarly to low-risk products and be included in ‘group 1’ or, alternatively, both groups should be excluded from this calculation. This would result in a fair weighting system.
5.Integrated Pest Management (IPM): The definition of Integrated Pest Management (IPM) has not really been ‘modernised’ compared with the one in the Sustainable Use Directive (Article 3(15)). The definition of IPM is still considered not strong enough as it should explicitly refer to prioritise biological control and using chemicals only if essential. Only in Article 13(4) it is stated that “Professional users shall use biological controls, physical and other non-chemical methods. Professional users may only use chemical methods if they are necessary to achieve acceptable levels of harmful organism control after all other non-chemical methods ….have been exhausted”.
While article 13 of the SUR does recall the eight principles of IPM defined, it fails to rank them. It is considered essential to apply a preventative approach, in line with the IOBC, IBMA and PAN Europe triangle on IPM[1].
It is also recommended that the definition of IPM reflects that IPM is ‘an ecosystem-based strategy’ or “nature-based strategy” (or similar wording) rather than just a number of different measures. Such terminology would also fit better within the language used in the Farm-to-Fork Strategy. In this respect also the contribution from IPM to the EU Biodiversity Strategy for 2030 (Recital 42) and the functioning of ecosystems and ecosystem services should be more emphasized in the core text of the Regulation and indicators for IPM such as the presence of pollinators and beneficial invertebrates should be established in this context. The emphasis on ecosystems based strategies could be created by reinstating the following statement in the definition: “Integrated pest management’ emphasises the growth of a healthy crop with the least possible disruption to agro-ecosystems and encourages natural pest control mechanisms”.
To promote the use of biocontrol even more the definition of ‘non-chemical methods’ (meaning alternatives to chemical plant protection products, Article 3(22)) can be expanded by explicitly mentioning biocontrol, e.g. ‘non-chemical methods’ means alternatives to chemical plant protection products like biological controls, physical and other non-chemical methods.

[1] Ibma value

[2] What is biocontrol?

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