Brussels, September 2022
Primary Food Processors (PFP) submitted its position on the proposed Regulation on the Sustainable Use of Plant Protection Products (SUR), supporting efforts to reduce pesticide risks and promote safer alternatives while emphasising the need to maintain food security, agricultural productivity and the competitiveness of Europe’s agri food sector.
The organisation supports the objective of reducing the use and risks associated with hazardous pesticides and increasing the adoption of lower risk and non chemical alternatives where practical and effective.
PFP stresses that primary food processors depend on a stable supply of safe, sufficient, high quality and affordable agricultural raw materials. According to the organisation, pesticide reduction targets should therefore be accompanied by economically viable transition frameworks that reflect scientific, technological and economic realities.
The association also highlights the importance of providing farmers and supply chain operators with sufficient time to adapt, develop alternative crop protection solutions and avoid unintended impacts on agricultural production.
PFP identifies New Genomic Techniques (NGTs) as an important tool for reducing reliance on chemical plant protection products. The organisation notes that these technologies can make plant breeding faster, more precise and more effective, contributing to more sustainable agricultural systems and lower pesticide use.
The organisation also raises concerns regarding elements of the proposed Integrated Pest Management framework. According to PFP, requiring all alternative methods to be tested before intervention and introducing additional procedural conditions could delay effective crop protection measures and reduce flexibility for farmers facing rapidly evolving challenges.
PFP therefore recommends maintaining the current definition of Integrated Pest Management established under Article 6.3 of the Sustainable Use Directive.
The association further argues that the proposed definition of sensitive areas lacks sufficient legal clarity. Combined with proposed buffer zone requirements, the measures could significantly reduce available agricultural land and create uncertainty regarding future production capacity.
The organisation also highlights competitiveness concerns. PFP warns that stricter production requirements may place European producers at a disadvantage if equivalent standards are not applied to imported products. It therefore supports greater reciprocity in international trade, the use of mirror clauses where appropriate and fair implementation of Maximum Residue Limits.
PFP emphasises that farmers must be supported throughout the transition through access to effective crop protection tools, innovation, modern technologies, predictable implementation frameworks and appropriate economic incentives.
Overall, PFP supports proportionate and achievable pesticide reduction measures provided they do not reduce agricultural production, undermine food security or increase Europe’s dependence on imported agricultural raw materials.
PFP brings together the European Committee of Sugar Manufacturers (CEFS), the European Cocoa Association (ECA), the European Flour Milling Association, the European Vegetable Protein Association (EUVEPRO), the European Vegetable Oil and Proteinmeal Industry (FEDIOL), and the European Starch Industry Association (Starch Europe).
PFP members process approximately 220 million tonnes of raw materials and employ more than 120,000 people across the European Union.
