Nick von Westenholz, CEO of the CPA said, "The restriction on NNis that came into force in December 2013 was introduced amid claims that their use could have a harmful impact on honey bees, despite widespread acknowledgement - including from beekeeping groups - that the long term decline in pollinator populations is largely due to a mix of weather, disease and changing habitat.
"In the 12 months since then there has been a series of reports from growers who have seen yields fall and have had to revert to older crop protection technologies since the ruling came into force. We have also released new research suggesting that the production of a host of British food crops is under threat as a result of the loss or restricted use of many useful pesticides.
"What the past year has shown is that over-precautionary regulation denies farmers the use of vital tools because of theoretical and unrealistic threats rather than actual risks."
This autumn, farmers experienced significant damage from cabbage stem flea beetles to their oil seed rape (OSR) crops - the first planted since the moratorium came into force. A HGCA report published in September noted that 2.7% of the national winter OSR crop, equivalent to 18,000 hectares, has been completely lost to the beetles. These losses also represent a reduction in one of the most abundant sources of early nectar and pollen for bees in the UK.
In October the CPA launched a report in conjunction with the National Farmers Union (NFU) and Agricultural Industries Confederation (AIC) that provides a clear picture of the implications of the flawed system that governs pesticide availability in the EU.
The report shows that the availability of many of these substances is under threat, posing a real risk to the production of food crops in the UK. This is the result of a regulatory system at EU level which places hazard rather than risk at the centre of its decisions and which creates uncertainty by allowing political decisions to circumvent the approvals process - as has been seen with the neonicotinoid moratorium.
Von Westenholz continued, "I want to be clear that the crop protection industry recognises the importance of good regulation. The crop protection industry is one of the most thoroughly regulated sectors in the world. This is as it should be; it means that where there are doubts about the safety or risk associated with a product - whether to people, the environment or wildlife - it does not get put on the market. But it is crucial that the system ensures proper risk assessment of products being placed on the market, so that we know they can be used safely while providing real benefits to farmers and consumers.
"Scientific evidence and research needs to play a much stronger part in European policy decisions, not least in response to the food security challenge. Safety comes first, but regulation should be risk-based and the precautionary principle and its relationship to assessing risk needs to be reviewed.
"This is critical for industry to have confidence to invest in the development of new and more sophisticated forms of crop protection technology - not only to provide vital tools to UK agriculture, but also to mitigate the knock-on impact on global food price volatility."
Von Westenholz concluded, "There are two main measures we believe policy-makers in the EU and the UK can take to stop future declines in productivity:
- Firstly, we believe that policy making in the EU needs to actively foster innovation and investment, to ensure long-term resilience in the food chain. This can be achieved by introducing an innovation principle into decision making. Which would mean, in its simplest terms, that whenever precautionary legislation is under consideration, the impact on innovation should also be taken into full account in the policy and legislative process.
- Secondly, we want scientific advice more firmly embedded in European Policy making. In the first instance this requires clarification on future plans for the role of scientific advice in the EU, following the extremely worrying abolition of the post of Chief Scientific Adviser. What we would really like to see is more formal powers for scientists at the European Commission level to review the use of scientific evidence in risk management legislation, regulation or administrative decisions, and to require further scientific assessment where appropriate, as well as the establishment of chief scientist posts in all EC Directorates General.
"We urge European policy-makers to realise how imperative it is to make a proper assessment of risk and impact when they take decisions affecting food production, and to make sure they foster rather than stifle innovation."