Position paper on the draft EU regulation on the sustainable use of plant protection products

Background:

In mid-June 2022, the EU Commission published the draft regulation for the sustainable use of plant protection products (Sustainable Use Regulation – SUR). This is intended to replace the current directive on the sustainable use of pesticides (SUD). According to the Commission, the current SUD is moderately effective, no quantitative figures or indicators are anchored in national action plans, no effective monitoring system has been established and too little data is available on the use of plant protection products (PPPs).

The proposed regulation contains various approaches to make the use of PPPs more sustainable in the sense of the EU:

50 % reduction in the use and risk of pesticides and the use of more hazardous PPPs (both EU-wide and according to national, own targets) compared to the average for the years 2015 – 2017.
Ban on the use of all PPPs in so-called sensitive areas (including urban areas and protected areas in accordance with Directive 2000/60/EC, Natura 2000 areas). A buffer strip of 3 metres must also be maintained. Exceptions are only granted by the authorities for 60 days under special conditions.
A ban on the use of all PPPs in all surface waters and within a radius of 3 metres around them.

Position of Fair and Green e. V.:

As an association for sustainable viticulture, Fair and Green e. V. fundamentally supports the EU Commission’s ambition to reduce the potential environmental risks of PPPs. As an association for sustainable viticulture, Fair and Green e. V. fundamentally supports the EU Commission’s ambition to reduce the potential environmental risks of PPPs.

Far-reaching consequences for German cultural landscapes

There are currently no concrete figures available for Germany on how many hectares (ha) of vineyards would be affected by the Commission’s proposal on sensitive areas. Corresponding data is currently being collected by the BMEL. However, the estimates of regional winegrowers’ associations for their areas are alarming. Almost the entire Moselle valley has been designated a protected landscape area. The areas along the Nahe and Ahr rivers would also be severely affected. The Rheingau winegrowing department lists 27 hectares of vineyards in nature conservation areas, 25 hectares in FFH areas and 324 hectares in water protection areas. In Baden-Württemberg, around a third of the vineyard area, 9,100 hectares, fell under the restriction. The EU Commission’s current proposal acutely jeopardises viticulture in many German regions and thus also the preservation of valuable cultural landscapes with unique flora and fauna, some of which are 2000 years old. In addition, the preservation of landscapes for recreation and tourism would be jeopardised and established village structures would be severely threatened or even disappear.

Focus on reducing negative environmental impacts instead of quantities

The moderate use of plant protection products is also essential in sustainable agriculture in order to ensure the quality and quantity of yields and thus the economic viability of farms. The potential yield loss due to harmful organisms in viticulture is estimated at 17 to 40 per cent. In the course of increasingly extreme weather events, complete yield losses are also possible. The active ingredients used can have side effects on the environment and humans, which must be minimised. However, the quantity applied and the origin of a PPP say nothing about its environmental impact. For this reason, systems are needed that are not exclusively aimed at reducing the quantity but at reducing the negative environmental impact of PPPs.

From the very beginning, it has been an important goal of Fair and Green e.V. to ensure that viticulture can continue to produce sufficient, high-quality grapes in the future and at the same time provide concrete environmental protection measures. Against this background, Fair and Green e. V., together with plant protection expert Lars Neumeister, further developed the Toxic Load Indicator (TLI) for viticulture back in 2013 in order to evaluate PPPs based on their toxicity and thus be able to advise farms on their appropriate use. Several years of application and the associated data collection have shown that the farms have been able to significantly reduce the use of highly toxic PPPs with the help of the TLI and at the same time maintain or even improve yield quality in the long term. The TLI system is also used successfully by both organic and non-organic farms. The TLI for viticulture is therefore a tried-and-tested system that can successfully realise the goal of reducing the environmental risk of PPPs.

Fair and Green e. V. calls for the European PPP reduction targets to be linked primarily to the environmental impact of the active ingredient and not exclusively to the quantity. The one-sided black-and-white view of plant protection must be replaced by a science-based approach. This is the only way to achieve environmental protection goals while at the same time securing yields, preserving cultural landscapes and generating an adequate income for the vineyards.

You can download the full position paper as a PDF here