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Categories Positions

CropLife Africa Middle East’s Position Paper on the EU Export Ban Initiative November 2023

Key Messages

  • Protecting human health and the environment is of utmost importance and CropLife Africa Middle East (CL AME) welcomes the European Union’s (EU) intentions and objectives behind this initiative. However, we believe the chosen policy instrument is missing the core intended objectives.
  • An EU export ban on prohibited chemicals may shift product supply to other regions, displacing the problem instead of solving it. It may also lead to an increase in use of counterfeit and illegal pesticide.
  • CL AME is willing to collaborate to enhance knowledge transfer and traceability in the supply chain through the EU’s Prior Informed Consent legislation, creating a more effective and transparent system for managing chemicals globally
  • As an industry, we take our responsibility to reduce the potential risks of pesticides use at all levels of the network, notably by promoting adoption of integrated pest management activities. To support countries in reducing their reliance on Highly Hazardous Pesticides (HHPs) over time, CropLife has also launched the Sustainable Pesticide Management Framework in Kenya and Morocco, in 2021 and 2022.
  • CL AME believes that an EU export ban of chemicals prohibited in the EU will negatively affect smallholder farmers in the Africa Middle East region, by reducing their toolbox of solutions, limiting options to combat pests and diseases, and to manage resistance, which will negatively impact food security, trade, and their livelihoods. Therefore, CLAME calls for a localized green transition in Africa, with sustainability agendas tailored to each country’s unique needs and challengs.

Context

Agriculture is a key sector in the Africa Middle East region, employing a large portion of the population and serving as a vital source of foreign exchange through the export of crops1
. However, food insecurity remains widespread due to various factors such as climate change, pests and diseases, and further exacerbated due to recent crises like COVID-19, the war in Ukraine and price inflation. Farmers, especially smallholders, are encountering difficulties in adapting to these challenges, and nearly 60% of the African continent’s population experience food insecurity2.
Considering the EU is a leader in terms of production standards, quality, worker safety, and environmental sustainability, CL AME believes3 that an EU blanket ban on certain pesticides would
worsen the situation. Removing these EU active ingredients from the market, which have undergone local safety assessments, would leave little alternatives and few modes of action available, limiting farmers’ options in combating pests and diseases, limiting resistance management options, ultimately impacting food security, trade, and the livelihoods of farmers in the Africa Middle East region. Smallholder farmers play a crucial role in food production and are highly vulnerable to these challenges, especially where removal of EU sources may escalate counterfeit and illegal trade.
Moreover, it should be taken into consideration that different regions have specific agronomic and climatic conditions that require different pesticides for effective control. Some pesticides are also used beyond agriculture for controlling pests that transmit diseases like Dengue, Malaria, and Zika.

CL AME Recommendations

1. An EU export ban of chemicals prohibited in the EU may lead to unexpected collateral damage and miss the opportunity to improve transparency in the global trade of chemicals

An EU Export Ban may result in a shift of product supply from the EU to other regions and countries, therefore displacing the problem instead of solving it. In addition, what is often overlooked is that the EU is not just a leader in terms of production standards, quality, worker safety, and environmental sustainability, but also in terms of long-term investments and well-established programs that promote the responsible and sustainable use of pesticides. A blanket ban on production could jeopardize these investments. Furthermore, most of the affected companies operating in the EU are also the ones investing in local programs to support the proper use of their products compared to other operators in the region coming from outside Europe. Additionally, such a ban could lead to an increase in the circulation and sale of counterfeit and illegal pesticides. This is a well-documented4 consequence of banning decisions, even within the EU itself. Illicit markets for counterfeit pesticides are widespread across many countries.

To ensure food and human safety while protecting the environment, and instead of imposing hazard-based regulation schemes to other regions in the world that follow FAO’s guidance on risk based assessments, EU’s efforts should be focused on supporting capacity building. It should also be focused on combating the sale of illegal products, rather than banning pesticide exports from the EU despite their registration at the point of sale. Indeed, it is important to recall that regions have different needs, and each country is best placed to assess the impacts of pesticides they decide to authorize (already thoroughly assessed during the authorization process). CL AME acknowledges the European Union (EU) as an international leader in chemical policy and supports its goal of enhancing chemical safety globally. Furthermore, prohibiting the export of products that have applications beyond crop protection, such as those used in public health for vector control in other countries, may potentially violate World Trade Organization (WTO) rules

2. To reduce the potential risks associated with pesticide use, governments and industry need to collaborate on stronger stewardship, effective use, and waste management activities

CL AME recognizes the potential of the EU and Rotterdam Convention’s Prior Informed Consent (PIC) processes to create a more effective and transparent system for managing the global chemical supply chain. These legislations already contribute to the safe use of hazardous chemicals by all stakeholders. CL AME, and our regional network, is willing to facilitate collaboration with all stakeholders to explore ways to further enhance knowledge transfer and traceability in the supply chain.
As an association, we encourage our members to take responsibility to further reduce the potential risks of pesticides use at all levels of the network. CL AME promotes the implementation of integrated pest management programs5 (e.g., the use of conventional products in combination with biological products) and we support national associations to establish both empty container and obsolete stocks management schemes. In addition, in Kenya and Morocco, the Sustainable Pesticide Management Framework (SPMF) was launched in 2021 and 2022 respectively. This is a dedicated five-year capacity-enhancement program driven by the industry to achieve a stepchange in responsible pesticide management, in line with the FAO-WHO Code of Conduct on Pesticide Management. The SPMF program combines best regulatory and stewardship practices to create an enabling environment for innovation and infrastructure that supports the responsible use of pesticides. This includes collaboration with governments on establishment of risk-based frameworks, improvement of poison information reporting centers, container management
programs, innovation and anticounterfeit activities.

3. An Africa localized green transition that takes into consideration the vital crop protection needs of farmers outside the EU

CropLife Africa Middle East calls for an Africa localized green transition, which is not only essential for agricultural development but also socio-economic progress:

  • “One size does not fit all”: sustainability agendas and objectives should be tailored to a region’s unique requirements.
  • Major trading partner green programs, such as the European Union Green Deal, should not undermine the actions and ambitions of African countries striving for inclusive and sustainable growth.
  • Every country is best placed to assess the environmental impact of pesticide use that they choose to authorize for their farmers. Pesticides are not automatically “less necessary” because they are not authorized in Europe.
  • CropLife Africa Middle East believes that the EU’s Green Deal can support Africa’s Green Transition without a blanket export ban in several ways, notably by:
  • Giving African farmers adequate and realistic transition periods;
  • Ensuring transparency and predictability, which are of the utmost importance for the whole food industry, in exporting as well as importing countries;
  • Ensuring that proposals impacting Africa are based on impact assessments conducted in/for Africa;
  • Consulting African partners more closely and regularly.

As per targets adopted at ICCM56, CL AME supports an approach according to which “by 2035, stakeholders have taken effective measures to phase out highly hazardous pesticides in agriculture where the risks have not been managed and where safer and affordable alternatives are available; and to promote transition to and make available those alternatives”.

Annex 1: CropLife Africa Middle East’s preliminary data on the impact of the EU prohibition of production of hazardous chemicals for export on key crops7 in the Africa Middle East’s region:

  • Coffee in Kenya: 72 active ingredients are registered against six main coffee pests. 33 of them are likely to be impacted as they are on the EU PIC listing. This has a 58% impact on the farmers’ toolbox. The possibility to ensure resistance is adequately managed is minimal as only one mode of action (MOA) will still be registered in the case of coffee berry borer, antestia bugs, and mites respectively, while none for the leaf miner and whiteflies.
  • Maize in Kenya: A total of 49 active ingredients (AI’s) cater for the crop protection solutions registered for 11 main pests affecting maize. Out of these, a majority of products are registered for three main pests including fall armyworm (FAW), stem borers and stored grain pests, representing 65%. The likely impact from the EU PIC listing related withdrawal will be 75% reduction in the toolbox for maize pests. There is a likelihood of resistance building up entirely on all the solutions as less than two MOAs will remain for all the pests, except in the case of FAW which has four.
  • In the case of Cote d’Ivoire, two of the AI’s, also registered in Kenya, are listed on the EU PIC listing and are likely to be affected. Unlike in the situation of Kenya, five MOAs will still be registered against FAW and may not be as affected. Maize in Ghana will also be impacted, as there are only two MOAs which is not sufficient for resistance management. If the attacks by FAW continues as experienced in the last few years, this will be a difficult pest to manage unless adequate alternatives are developed.
  • Mangoes in Senegal and Cote d’Ivoire: Mangoes are listed in several countries as main crops and exhibit a blend of local and export use respectively, with Senegal and Cote d’Ivoire leading on exports. The major pests attacking mangoes in Senegal are fruit flies and anthracnose. Currently the AI’s constituting the two registrations are not in the EU PIC list. There are also biological solutions listed in the registrations such as plant extracts. In Cote d’Ivoire, there are only four AI’s, out of which one is listed on the EU PIC list. For both countries, there will not be sufficient tools to ensure resistance management as only one MOA will still be registered to be combined with male annihilation technique, in the case of Senegal and only two for Cote d’Ivoire.
  • Tomatoes in Senegal: Three major pests; white flies, tuta absoluta and ralstonia solanacearum affect tomatoes. This is a key crop used locally. Only one a.i solution exists for ralstonia solanacearum and this is included in the EU PIC listing and likely to be restricted in EU policy is considered in decision making. There is also no Mode of Action that will still be registered.
  • Tomatoes in Morocco: In the case of Morocco, seven actives are registered for nematodes. Out of this, two are likely to be impacted due to EU PIC listing.
  • Cocoa in Cote d’Ivoire and Ghana: 11 AIs are registered to provide cover against the major pests affecting cocoa including Brown pod rot, Mirids and other drillers. Out of these, four are included in the EU PIC listing and likely to be restricted if EU policy is considered in decision making. In the case of Mirids and other drillers, there are only two MOAs that will still be registered, which are not sufficient for resistance management. In the case of Ghana, only one solution is registered for Capsid mirids. In addition, only one MOA will be registered against the pest and therefore there will not be sufficient tools for resistance management.

Source :

Categories Positions

CropLife Africa Middle East Position Paper on Maximum Residue Levels (MRLs)

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:

  • CL AME calls for the sustainability agenda to be tailored to national specificities. CL AME advocates for an Africa localized green transition while always maintaining a safe and secure supply of foods, which should be non-negotiable. Every country is best placed to assess the environmental impact of pesticide use that they choose to authorize for their farmers, based on their unique sustainability objectives and challenges, requiring the use of diverse methods, tools and technologies to sustainably meet the world’s growing demand for food and feed in the face of climate change. CL AME believes that a safe and secure supply of food can be ensured with the help of plant science tools including crop protection products that are recognized for their longterm and essential role in sustainable agriculture, food safety and food security.
  • CL AME supports MRLs based on Codex MRLs, or Import Tolerances, established via independent scientific risk-assessment, and encourages all governments to adopt Codex MRLs for global alignment and trade purposes. These should be science-based food safety standards that protect consumers’ health and fair-trade practices.
  • CL AME calls for ‘mirror clauses’ to be compatible with WTO rules and based on solid internationally recognized science.
  • CL AME calls for adequate transition periods when decreasing MRLs. Any policy or change of national standards should be communicated with sufficient notice with information on transitional measures, for example via public websites. Transparency and predictability are of the utmost importance for the whole food industry, in exporting as well as importing countries.
  • CL AME calls for MRLs setting system that focuses on ensuring consumers’ safety, as the environmental safety of pesticides is thoroughly assessed during the authorization processes; therefore, there is no necessity to expand the scope of existing MRLs regulations beyond consumer protection to environmental considerations. In addition, we strongly believe that global challenges, such as environmental concerns, should be addressed at an international level, through fora that have been set up to facilitate multilateral discussions and decision-making, such as at Codex Alimentarius.

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:

  • While there is a need for a sustainability agenda to be rolled out in all countries, each transition must be tailored to a country’s agricultural and trading specificities; that is why CL AME supports an Africa localized green transition in order to achieve the Sustainable Development Goals (SDGs). As CL AME, we promote sustainable agricultural practices and food systems, utilizing the best mix of tools and techniques to achieve more sustainable production as well as to meet countries' individual needs based on their geographic location, agronomic conditions, and environment.
  • MRLs should be science and evidence-based in order to ensure that food products are safe for consumers, as per the ‘Better Regulation’ principle. Data shows that when the decision-making process follows a science-based risk assessment, consumer foods are safe. The setting of MRLs should therefore remain independent from political agendas.
  • In addition to ensuring consumers’ safety, MRLs should be science-based for predictability and smooth trading practices. Lowering MRLs without adequate transition periods based on political agendas, can lead to administrative burden, trade disruption and a loss of confidence between trading partners.

1- The Africa localized green transition: the need for sustainability agendas that should take into consideration countries’ agricultural and trade specificities

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.

2- Science-based MRLs ensure a safe, consistent, and vital supply of food as part of healthy and balanced diets

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.

3- MRLs are key to many African country’s economic growth objectives and to the achievement of their Sustainable Development Goals targets

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).

Source :

  • 1 https://croplife.org/case-study/maintaining-high-standards-on-pesticide-residues/
  • The European Food Safety Authority (EFSA)’s Q&A on its neonicotinoid review findings of 2018 in which « The information on this phenomenon is somewhat limited, but EFSA concluded that, in some cases, bees might still be exposed to harmful level of neonicotinoids pesticides through this route », show an excessive use of the precautionary principle, non-science based - https://www.efsa.europa.eu/sites/default/files/news/180228-QANeonics.pdf
Categories Positions

Clame position and recommendations on the Africa-eu partnership related to agriculture

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.

Recommendations

  • In order to help enhance sustainable food output from farms, on-the-ground training and capacity building must be prioritised. CLAME member companies are adopting and committing to measurable sustainable agricultural practices to mitigate the impact of climate change, ensure food security and keep food affordable. These practices include training farmers in the secure and correct use and storage of pesticides as well as the implementation of integrated pest management strategies. It is also imperative that access to local language labels and protective equipment be strengthened.
  • A transition towards a circular economy and national programmes for responsible management of waste is crucial. CLAME stands ready to partner with national authorities. The plant science industry globally and in Africa Middle East, has developed stewardship initiatives to responsibly manage the full life cycle of products, such as the empty container management programme. This has included ecycling empty containers thus helping cut emissions and support the transition towards a circular economy by keeping resources in the economy for longer.
  • Data-driven decision-making and outcome-based goals should be the foundation for progress in sustainable agriculture. The summit should ensure that the different needs and challenges on both continents are considered when determining the best way forward for enhanced agricultural sustainability.
  • Thorough, science-based evaluations and impact assessments should be conducted on all policies affected agri-food production and trade between the EU and African nations, taking into account all pillars of the sustainable development goals. This analysis must consider the critical role plant science tools play in helping farmers protect their crops and the environment, increase yields and produce a safe and abundant food supply. These inputs not only boost crop quantity and quality, but also prevent food loss and waste. As such, they are essential to ongoing food security. Social, economic, and territorial impact assessment would help in guiding the policy-making process.
  • Thorough, science-based evaluations and impact assessments should be conducted on all policies affected agri-food production and trade between the EU and African nations, taking into account all pillars of the sustainable development goals. This analysis must consider the critical role plant science tools play in helping farmers protect their crops and the environment, increase yields and produce a safe and abundant food supply. These inputs not only boost crop quantity and quality, but also prevent food loss and waste. As such, they are essential to ongoing food security. Social, economic, and territorial impact assessment would help in guiding the policy-making process. An operation similar to the Operation Silver Axe supported by Europol should be introduced. Tackling the circulation of illegal and or counterfeit inputs and products must remain a priority for both continents. Illicit plant protection products may contain unassessed, unapproved, or poorly manufactured ingredients, with potential to endanger human health and biodiversity, plus the potential to destroy crops, compromising farmers’ livelihood. As a partner of the Transnational Alliance to Combat Illicit Trade, CropLife remains committed to working with authorities to stamp out counterfeit agrochemicals and pesticides.
  • CLAME members stand ready to support the implementation of a localised green transition in Africa.
Categories Positions

CropLife Africa Middle East position on the EU Green Deal

Key points

  1. CropLife Africa Middle East believes that the African Green Transition agenda needs to be uniquely tailored to, and supportive of, African needs. In agriculture, this requires greater access to high-quality sustainable organic and synthetic inputs and innovation. Technology transfers resulting in more innovation are a key driver of Africa’s Green Transition.
  2. CropLife Africa Middle East believes that major trading partner green programmes, notably the European Green Deal and Farm to Fork Strategies, should not undermine African countries’ actions and ambitions for inclusive and sustainable growth. There are generational opportunities to support a transition in agriculture across Africa that should not be lost.
  3. CropLife Africa Middle East believes that the EU’s Green Deal and Farm to Fork Strategy can support Africa’s Green Transition in several ways, by:
    • Ensuring timely communication of new requirements;
    • Giving African farmers adequate and realistic transition periods;
    • Ensuring that EU Mirror clauses are WTO-compatible and science-based;
    • Ensuring that EU MRL and IT rules are science-based and changes communicated early;
    • Making sure that proposals impacting Africa are based on impact assessments conducted in/for Africa;
    • Consulting African partners more closely and regularly.

Green transition in Africa

All 54 African countries signed the Paris Agreement in 2015 and the African Union’s development goals in its Agenda 2063, in 2013. In the last decade much effort has been invested in working towards building green economies across Africa.

Given many African countries reliance on agriculture for both trade and food/feed, this agenda goes far beyond just farmers and the environment. The Green Transition in Africa represents both challenges and opportunities across several areas: economic growth and social progress; sustainable and inclusive development; gender equality and youth empowerment; technology transfer; increased trade and unity within Africa and development and investment opportunities.

African Green Transition

African Green Transition is a “green growth model, including circular and blue economies; combatting climate change; protecting biodiversity and natural resources; ensuring food security and rural development as well as access to sustainable energy and developing transport solutions.” [EEAS Nov. 2021]l

African countries contribute 3% of global carbon emissions. They face the most severe impacts of global climate change. Natural disasters like locust infestations, droughts and floods have displaced millions of people and massively disrupted socio-economic structures.

Access to innovations and technologies that can help improve resilience to the impact of climate change as well as helping reduce carbon emissions are needed. Removing barriers to trade in agriculture within Africa can also reduce emission by making it easier for global companies to produce and supply for Africa from within Africa.

The green transition can help fuel sustainable and inclusive growth for Africa. Africa has a large social and economic footprint in the continent and as such, can empower not only farmers, and the value chains that they belong to across Africa, but also the continent as a whole.

Technology can help African farmers deliver more with less and embed sustainable business development that in turn can drive more intra-regional agricultural trade (and decrease dependence on imports and simultaneously reduce CO2 emissions). Unfortunately, these opportunities will be missed if the African Green Transition continues to largely be driven by policies formulated in a different continent based on different realities, most notably by the European Union’s Green Deal and Farm to Fork Strategy.

Eu green deal & the african green transition

African Green Transition

“The MRL issue is the trade policy measure of most immediate relevance and significance for developing countries” [Professor Alan Matthews, Euractiv Interview, 25 February 2022]

The EU and African countries are developing policy measures to combat the effects of climate change. The EU’s vehicle to achieve this is the European Green Deal. Central to this effort
is the ‘Farm to Fork Strategy,’ published in 2020. It aims to reduce the environmental and carbon footprint resulting from food production and consumption. Key measures cover food production, processing, retailing, and waste. The external dimensions of these proposed changes are will shape the African Green Transition in significant ways. The evolving EU policy framework will require African countries to adhere to many new rules stemming from the Green Deal and Farm to Fork strategies.

The socio-economic and environmental impact of policies tailored to European realities is not likely to match reality in other parts of the world where the socio-economic, environmental and agronomic context including soils, climatic conditions and pest pressures are different. Compliance with these new rules, if they do not take African needs into considerations, could become a burden on African businesses and notably African farmers who want to continue accessing the vital EU market.

Many African leaders have expressed concerns that the enactment of the European Green Deal will damage, instead of support, Africa’s Green Transition process. There is a building body of research and data on the impacts that the EU Green Deal could have on Africa – but more is urgently needed.

In the same process technology needs to be viewed as an enabler to achieving a green transition while also considering that the technology needs of different continents are different due to varying agronomic and climatic conditions. Pests like Fall Armyworm, which don’t exist in Europe, may require technologies that Europeans choose not to authorise for use in their domestic market except in exceptional cases.The evolving EU Green Deal and Farm to Fork policies offer opportunities, and challenges, to the African Green Transition.

African Green Transition

Compliance with EU Farm to Fork policies represent a huge potential to damage Africa’s Green Transition process.

Four focus areas

1. Uncertainty & compliance costs

Concern: Major policy upheaval, such as those resulting from the EU Farm to Fork Strategy inevitably generate uncertainly, especially in sectors as complex as agri-food chains. Understanding the exact requirements and the associated costs takes time and put business at risk.

Solution: CropLife Africa Middle East asks for additional investments and special emphasis on communicating, in a timely manner, any new requirements as soon they are known. Moreover, African farmers must benefit from adequate and realistic transition periods (at least 24 months).

2. Mirror clauses

Concern: The use of mirror clauses is hotly debated in the EU. Mirror clauses describe when an imported product is produced under the same sanitary, phytosanitary, welfare and environmental standards as products produced within the EU.

Solution: CropLife Africa Middle East calls for mirror clauses to be compatible with WTO rules and based on solid internationally recognised science.

3. Maximum residue limits (mrls) & import tolerances (its)

Concern: Changes to EU MRL and IT policies may negatively impact the African Green Transition. There is grave concern for the potential revocation of import tolerances for any active ingredient not registered in the EU. There is also concern that potential future MRL’s be set with new data points such as environmental factors.

Solution: CropLife Africa Middle East asks that MRL and IT policies be science-based and communicated as early as possible.

4. Support for the african green transition

Concern: African farmers not only require adequate transition periods, but also significant technical and financial assistance to adapt their farming practices. These needs must be supported by stronger advocacy and engagement by African governments.

Solution: CropLife Africa Middle East calls on African governments to do more research on their specific situations and to subsequently build this into advocacy towards trade partners. CropLife Africa Middle East is ready to play its part as a key partner in this process.

Croplife Africa Middle East

CropLife Africa Middle East A.I.S.B.L. is a non-for-profit industry organization representing the leading global manufacturers of pesticides, seeds and biotechnology products in Africa and the Middle East. Together with more than 20 national associations, CropLife Africa Middle East is the voice and advocate for the plant science industry in its region and worldwide.

CropLife Africa Middle East is committed to sustainable agricultural practices and to the responsible use of plant science technologies in the region. We promote the understanding of the benefits of modern plant science solutions. We are convinced that these products and solutions, developed and distributed by our member companies, are indispensable to control weeds.

We believe that the professional and responsible use of these products improve the incomes and livelihoods of farmers and their families and has the potential to contribute decisively to the growth of rural and national economies, as well as promoting food security in the region.

Categories Positions

African green transition in agriculture

Key points

  1. CropLife Africa Middle East supports an African Green Transition that is a vital pathway to not just agricultural development but also socio-economic development, African (and global) trade development and the empowerment of local communities. This transition offers multiple opportunities for Africa to thrive and accelerate the path to achieving the United Nations’ Sustainable Development Goals.
  2. CropLife Africa Middle East believes that the African Green Transition agenda needs to be uniquely tailored to, and supportive of, African needs. In agriculture this requires greater access to high-quality sustainable organic and synthetic inputs and innovation. Technology transfers resulting in more innovation are a key driver of Africa’s Green Transition.
  3. CropLife Africa Middle East believes that major trading partner green programmes, notably the European Green Deal and Farm to Fork Strategies, should not undermine African countries’ actions and ambitions for inclusive and sustainable growth. There are generational opportunities to support a transition in agriculture across Africa that should not be lost.
  4. CropLife Africa Middle East calls on African policy-makers to urgently address the barriers to producing, supplying and trading goods within Africa. These barriers need to be removed as part of the African Continental Free Trade Area to further support the African Green Transition.
  5. CropLife Africa Middle East supports African countries ongoing work towards an African Green Transition agenda including within the African Union and in talks with the UN and with major partners including the EU.

Green transition in Africa

All 54 African countries signed the Paris Agreement in 2015 and the African Union’s development goals in its Agenda 2063, in 2013. In the last decade much effort has been invested in working towards building green economies across Africa.

Given many African countries reliance on agriculture for both trade and food/feed, this agenda goes far beyond just farmers and the environment. The Green Transition in Africa represents both challenges and opportunities across several areas: economic growth and social progress; sustainable and inclusive development; gender equality and youth empowerment; technology transfer; increased trade and unity within Africa and development and investment opportunities.

African Green Transition

African Green Transition is a “green growth model, including circular and blue economies; combatting climate change; protecting biodiversity and natural resources; ensuring food security and rural development as well as access to sustainable energy and developing transport solutions.” [EEAS Nov. 2021]

African countries contribute 3% of global carbon emissions. They face the most severe impacts of global climate change. Natural disasters like locust infestations, droughts and floods have displaced millions of people and massively disrupted socio-economic structures.

Access to innovations and technologies that can help improve resilience to the impact of climate change as well as helping reduce carbon emissions are needed. Removing barriers to trade in agriculture within Africa can also reduce emission by making it easier for global companies to produce and supply for Africa from within Africa.

The green transition can help fuel sustainable and inclusive growth for Africa. Africa has a large social and economic footprint in the continent and as such, can empower not only farmers, and the value chains that they belong to across Africa, but also the continent as a whole. The African green transition in agriculture needs to consider the following context in Africa:

  1.  It is one of the most food insecure parts of the world.1
  2. It is home to the world’s second largest rainforest, the Congo Rainforest. Achieving higher yields without that coming at the expense of forest land will require the use of high-quality inputs and good agronomic practices to help increase yields sustainably.
  3. Most farmers are smallholders and do not use modern technologies.2
  4. The average farm performs at approximately 40% of its potential.
  5.  Agriculture has a large share in GDP and employment.
  6.  It remains the continent the most impacted by climate change.

Technology can help African farmers deliver more with less and embed sustainable business development that in turn can drive more intra-regional agricultural trade (and decrease dependence on imports and simultaneously reduce CO2 emissions). For these opportunities to be realised, the African Green Transition needs to be driven by policies formulated based on the local context and realities. While a dialogue with global trading partners like the EU is important, the European Union’s Green Deal and Farm to Fork Strategy are formulated for the European continent based on their realities.

African Green Transition

“Against the 2021 targets of Agenda 2063 Africa as a whole is only 51% on track” [UN report February 2022]

Croplife Africa Middle East recommendations

  1.  Improved access to, and use of, yield increasing high-quality technologies must remain a priority so as to enable better use of existing farm land and avoid forest land being used for farming purposes.
  2. Steps need to be taken to enable the transition towards a circular economy so that plastics used for containers are kept in circulation in the economy for longer, helping cut carbon emissions and helping responsibly manage waste. The plant science industry globally and in Africa Middle East, has developed stewardship initiatives to responsibly manage the full life cycle of products, such as the empty container management programme. This has included recycling empty containers thus helping cut emissions and support the transition towards a circular economy by keeping resources in the economy for longer. Plastic takes 400 years to degrade and only around 11% is recycled. Recycled plastic has around 70% lower carbon footprint than virgin plastic.
  3. Tackling counterfeit and illegal products must remain a priority. Illicit plant protection products may contain unassessed, unapproved, or poorly manufactured ingredients, with potential to endanger human health and the environment including biodiversity, plus the potential to destroy crops, posing a risk to farmers’ livelihood and food security. As a partner of the Transnational Alliance to Combat Illicit Trade, CropLife remains committed to working with authorities to stamp out counterfeit agrochemicals and pesticides.
  4. Removal of barriers to trade within Africa would make it easier to produce and supply in Africa from within Africa, hence helping cut the carbon footprint of agricultural inputs. The African Continental Free Trade Area offers potential in this regard. Within the AfCFTA, there is also the potential, for a new protocol on climate and sustainability, to ensure greater alignment between it and the AU’s African Green Stimulus Programme (AGSP) and Green Recovery Action Plan (GRAP), which includes the concept of “resilient agriculture” and already seek to support climate finance.3

Croplife Africa Middle East

CropLife Africa Middle East A.I.S.B.L. is a non-for-profit industry organization representing the leading global manufacturers of pesticides, seeds and biotechnology products in Africa and the Middle East. Together with more than 20 national associations, CropLife Africa Middle East is the voice and advocate for the plant science industry in its region and worldwide.

CropLife Africa Middle East is committed to sustainable agricultural practices and to the responsible use of plant science technologies in the region. We promote the understanding of the benefits of modern plant science solutions. We are convinced that these products and solutions, developed and distributed by our member companies, are indispensable to control weeds.

We believe that the professional and responsible use of these products improve the incomes and livelihoods of farmers and their families and has the potential to contribute decisively to the growth of rural and national economies, as well as promoting food security in the region.

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