Category Archives: Positions

Key Messages

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:

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:

Source :

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.

Recommendations

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.

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 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.

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 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.