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”.