Comments to the European Commission regarding the application of EU health and environmental standards to imported agricultural and agri-food products
Re: Ref. Ares(2022)1138409 – Application of EU health and environmental standards to imported agricultural and agri-food products (16 February 2022)
CropLife America (CLA) is providing this submission in response to the Call for Evidence (Ref. Ares (2022) 1138409) seeking feedback on the application of European Union (EU) health and environmental standards to imported agricultural and agri-food products. CLA, established in 1933, represents the developers, manufacturers, formulators and distributors of plant science solutions for agriculture and pest management in the United States. CLA’s member companies produce, sell, and distribute virtually all the pesticide products used by U.S. farmers, ranchers, and landowners to ensure healthy crops and strong yields. Together with its members, CLA works to ensure that our companies can provide environmentally sustainable agricultural products that support a safe food supply and reduce the risks posed by destructive pests and plant diseases. Similarly, pesticide products provide benefits to plant nurseries as well as turf protection for areas such as sports fields, golf courses, and lawns. Pesticidal chemicals also prevent public health problems by controlling harmful insects such as mosquitos and ticks. Pesticides play a crucial role in supporting healthy food, healthy people, and a healthy planet.
U.S. farmers depend on pesticides to grow healthy and safe crops, fruits, and vegetables that are used as food, as well as other farm products, including fibers, lumber, and fuel for consumers domestically and around the world. Without modern pesticides, insect pests, weeds, and crop diseases would destroy or reduce crop yields and quality and substantially reduce the availability of U.S.-grown farm and food products. Many U.S. grown crops are exported to the EU so EU policies that adversely impact trade are critically important to U.S. growers and CLA.
In addition, pesticides play a vital role in achieving U.S. goals for sustainable productivity by allowing for reduced / zero-till agriculture, and the use of cover-crops. These agronomic practices allow U.S. farmers to reduce greenhouse gas emissions, improve soil quality, and sequester atmospheric carbon dioxide. Increasing production while minimizing environmental impacts and preserving natural resources is the greatest challenge for today’s farmers, especially in the face of a changing climate and the pressures on agriculture that come with it. Farmers carefully track which pests and diseases are affecting their crops and which parts of their fields are affected. If they must use pesticides, they carefully select the right pesticide and smallest quantities possible for each pest and crop at issue. In response to changing methods of farming, pesticide manufacturers are focusing on the farmers’ needs by developing more targeted, more selective, and safer solutions to control weeds, disease, and insects that threaten the food supply. These new pesticide innovations allow farmers to use fewer, more targeted pesticides within an Integrated Pest Management system.
Registering these instrumental agricultural products already requires a thorough, science-based risk assessment evaluating potential adverse effects to the environment. The United States Environmental Protection Agency (EPA) conducts these risk assessments based off conditions relevant for the region where the products are applied. The U.S. EPA has listed tolerances (MRL) for more than 1,300 active pesticide ingredients while the EU has just over 400 (more than a 60% reduction in comparison to 1991)1. Mirror clauses requiring the production of agricultural goods in the U.S. or any other country following practices a manner determined by the EU is an extraterritorial overreach.
Read the complete comments submitted by CropLife America.