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CropLife AME (CL AME) calls on the EU to base its MRLs setting system on evidence and science, which has proven to be very effective in ensuring consumers’ safety. MRLs setting should
be done according to the EU “Better Regulation” principle, which ensures evidence-based and transparent EU law-making based on the views of those who may be affected. More precisely:

The trend of decreasing maximum residue levels is a major threat to the achievement of the Sustainable Development Goals in the Africa Middle East region. CL AME believes that getting
the sustainable growth agenda right in agriculture is essential and therefore welcomes the ambitions of improved and more effective MRLs.

Using MRLs, however, as a tool to unilaterally drive environmental sustainability is not something we support. We believe that there is no ‘one size fits all’ approach when it comes to sustainability, and the means should therefore be tailored to a country’s agricultural specificities and trade needs. Therefore, considering the increasing tendency of the European Union (EU) to decrease MRLs and import tolerances, CL AME would like to recall the following:

The challenges that agriculture faces in Africa range from climate change, food security, water scarcity, inflation of fuel prices, trading and export uncertainties and restrictions (and many
more). These challenges are currently only being exacerbated by the impact, and likely future impact, of EU regulations.

By adopting a ‘one size fits all’ approach for sustainability the EU is not considering the climatic and agronomic conditions of the Africa Middle East region and the impacts that their changes will have. There exist many examples where it is necessary to use certain types of plant protection products (and in various quantities) to combat local pests and needs. The blanket approach discriminates against agricultural exports of products from many African and Middle Eastern countries.

A maximum residue level is the highest level of a pesticide residue that is legally tolerated in, or on, food or feed when pesticides are applied correctly (cf. Good Agricultural Practice). With
MRLs based on robust scientific assessment, authorities ensure that the amounts of residues found in foods are safe for consumers and are as low as possible. For example, according to
the European Food Safety Authority (EFSA) monitoring report on residues that is published every year, about half of all samples in the EU are free of detectable residue traces. In the remaining half (45%), residues found were within the legal limits (maximum residue levels or MRLs)1 ; such data shows that pesticides are applied according to Good Agricultural Practice and therefore that foods are safe because they are always below, or within, the MRLs set by EFSA.

Considering this lack of science-based evidence showing that such limits are not safe, it is unclear why there is a need to further decrease MRLs. More worryingly this is done with little
regard for how farmers should protect their crops going forward. It takes considerable time, work, research and resources to place new products on the market. Additionally, as farmers are the first line of defense in minimizing residues through good agricultural practices, the industry is taking responsibility by implementing and rolling out programs to train farmers in how to safely use pesticides. When used properly, pesticides are safe, and ensure that consumers have access to a safe supply of foods which are part of a healthy and balanced diet.

In addition to ensuring consumer safety, MRLs are in essence trading standards and the cornerstone of agricultural trade, as crops cannot be legally traded if they exceed MRLs. The
lack of globally harmonized MRLs is already a challenge for farmers, as they must comply with MRLs in both exporting and importing countries. It is key that MRLs are based on evidence and science and remain independent from political agendas.

CL AME is particularly concerned by the trend of ever-decreasing MRLs in the EU as part of the EU Green Deal. This is notably due to the possible deletion of existing MRLs for nonapproved active substances in the EU (so called ‘mirror clauses’) as well as the possible setting of MRLs with new data points such as environmental factors, especially when the latter is based on the use of the precautionary principle and not science or evidence-based2 .

CL AME notes that the environmental safety of pesticides is thoroughly assessed during the authorization processes; therefore, there is no necessity to do so in the setting of MRLs. Such
practices by the EU raise serious questions about the consistency of their measures. EU regulations are already more trade restrictive than necessary to fulfil a legitimate objective, as being based in essence on the precautionary principle. They also fail to consider Good Agricultural Practices (GAP) for legal uses in non-EU countries. The continued decrease of MRLs will cause further trade disruptions (contrary to WTO principles), a deterioration of relations with trading partners and additional administrative burden.

Finally, the decreasing trend of MRLs not only affects the agri-food exports to the EU, it also has a detrimental effect on the agricultural production of African and Middle East countries,
and consequently their food security and the region’s stability. CropLife Africa Middle East A.I.S.B.L is a non-for-profit industry association representing the leading global manufacturers of pesticides, seeds and biotechnology products in its territory. The regional association was registered in Brussels in November 2002 and represents today more than 20 national associations across its region. The association is legally fully y independent but maintains a strong link with the global CropLife network (www.croplife.org).

Executive summary

The Africa-EU partnership covering agriculture is an opportunity to build a partnership that delivers for both continents, taking into account the varying agronomy and technology needs of both continents due to varying climatic conditions and pest and disease pressures. Impact assessments should guide decision-making and enable the varying
realities to be accounted for in achieving the United Nations’ Sustainable Development Goals in each continent. Access to the necessary technologies plays a key role for livelihoods and improved food security in Africa. Their proper control and responsible use remain a joint public and private sector priority.

CropLife Africa Middle East (the crop protection industry in Africa) is ready to support the implementation of a localized green transition in Africa. This includes on-the-ground farmers training and capacity building, the transition towards a circular economy and national programs for responsible management of waste and tackling the circulation of illegal and or counterfeit inputs and products. The Summit is taking place against a backdrop of farmers in Africa asking for improved market access to the EU and concerns from parties including Governments from many nations worldwide about the EU’s approach to market access and adherence to international agri-food trading standards.

Introduction

Agriculture is a key industry for Africa. However, it faces a range of evolving challenges. Technologies that support sustainable agricultural practices and development can help
mitigate these. The average African farm currently performs at 40% of its full potential, with the continent being home to more than half of the world’s population facing food insecurity. This makes the use of agricultural innovations even more critical.
As Africa and the European Union renew their partnership and agree a new strategy at the February 2022 EU-Africa Summit, agriculture is expected to be discussed under the heading of a green transition. The EU is working to overcome the challenges of climate change and environmental degradation through its Green Deal. Food and agriculture have a specific Green Deal “Farm to Fork Strategy”, that aims to to make food systems fair, healthy and environmentally-friendly.

The African Union has its agenda 2063, which is a strategic framework that sets its aspiration for “a prosperous Africa based on inclusive growth and sustainable development”. The Comprehensive African Agricultural Development Programme (CAADP), one of the frameworks under Agenda 2063, aims to help African countries eliminate hunger and reduce poverty by raising economic growth through agriculture-led development as well as promoting increased national budget provision to the agriculture sector. While both continents strive to achieve the United Nations’ Sustainable Development Goals, how they achieve this is defined by their varying realities.

Policies suited to the needs of one continent will not necessarily be suited to the other. Africa is more vulnerable to the impact of climate change and its farmers face
pest and disease pressures that European farmers do not. Access to the necessary technologies plays a key role for livelihoods and improved food security
on the continent. Their proper control and responsible use remain a joint public and private sector priority. The Summit is taking place against a backdrop of farmers in Africa asking for improved market access to the EU and concerns from parties including Governments from many nations worldwide about the EU’s approach to market access and adherence to international agri-food trading standards.

Clame position

CropLife Africa Middle East (CLAME) is an industry association representing seven companies and 22 national associations. We recognise the importance of supporting
farmers across the African continent, Europe and the rest of the world when it comes to the use of crop protection products. It is a fundamental concept that pesticides in use should be safe for people and the environment when used in accordance with the label instructions.

All stakeholders in food production and supply have common priorities: ensuring adequate supply of safe food, protecting the environment and ensuring the wellbeing of people. CropLife member companies are fully committed to the ongoing research, development and introduction of innovative solutions to support the agricultural sector year after year, as challenges such as climate change, pests and disease impacts evolve. Member companies are producing technologies to empower farmers to grow more with less in support of sustainability in food and agriculture. Crop protection products are quite rightly strictly regulated and, prior to being placed on the market, must pass thorough safety and environmental risk assessments. In line with the FAO/WHO International Code of Conduct on Pesticide Management.

CLAME’s aim is to support the Africa EU partnership relating to agriculture in Africa by helping find adapted sustainable solutions. CLAME member companies are adopting and committing to measurable sustainable agricultural practices to mitigate the impact of climate change and ensure sustained food security and food affordability.

CropLife AME members are helping increase yields in Africa and are striving to support Africa’s sustainable development. For maize, a staple crop in Africa, farmers in the EU produce more than 4 times per hectare than farmers in Sub-Saharan Africa. Through improved access to technologies and training on good agronomic practices, CLAME members are helping farmers produce more food more sustainably.

Ensuring that the partnership agreement delivers for both continents will require an evidence-based and science-led discussion and assessment of data from both continents. CLAME members stand ready to support partnerships in agriculture.

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