Dear Commissioner Andriukaitis,
Since the next PAFF(1) meeting is taking place later this week on July 19-20, from BeeLife European Beekeeping Coordination, we wish to share our concerns regarding the emergency authorisations of three restricted neonicotinoids (clothianidin, imidacloprid and thiamethoxam) and their evaluation by the European Food Safety Authority.
During the nineties, European beekeepers reported the harmful effects of neonicotinoids on bees. Later, after two decades, their pleas were heard. The Commission took a good first step to improve conditions for bees and other pollinators by restricting the use of three neonicotinoids. Besides, this year's ban on all open-air uses of these pesticides reassures EU's commitment to improving the situation. However, adverse effects of neonicotinoids continue to be a threat since some Member States recurrently issue emergency authorisations.
The Commission requested EFSA’s assistance to evaluate emergency authorisations issued in 2017, but the evaluations have only been published in June 2018(2). However, EFSA’s reports neither provide an external view of the situation nor do they thoroughly review all the possible alternatives. Unfortunately, the reports have proven to be insufficient to provide an overall assessment of the conditions in the field. For instance, it is worrying to see that they do not review the validity of the authorisations nor include any non-chemical methods as possible alternatives. In fact, EFSA only present other non-banned neonicotinoids, such as acetamiprid and thiacloprid.
EFSA provided the technical assistance as requested by the Commission, but it has only taken into account the notification by Member States, meaning it has not considered the validity of the emergency authorisation. Furthermore, it is clear that there is no critical analysis of the claims by national governments about available non-chemical methods. EFSA is an expert on pesticide risk assessment but not necessarily on agronomy or agriculture. It examined each of the proposed alternatives on a country by country basis, without considering that the same alternatives may be efficient across countries. The reports show that there are available alternatives in Hungary, but there is no discussion on the expansion of such alternatives in other territories, where similar measures could be taken. Furthermore, even when taking into consideration the different situations in different countries, one could wonder why some countries which not providing derogations found alternatives to culture the same crops while countries like Bulgaria, Finland or Romania did not.
The working document on Article 53 for Emergency Authorisations clearly states that these should only be reserved for "exceptional and restricted cases of obvious dangers to plant production or ecosystems that cannot be contained by any other reasonable means"(3). Nonetheless, Member States continue to issue them without sufficient evidence of the emergency or lack of alternatives. It is necessary that EFSA, perhaps in collaboration with other institutions, reviews the quality of data and arguments presented in notifications of Member States. Especially as it has not put into question the quality of the arguments and the data supporting a 'lack of alternatives'.
The situation is urgent, beekeepers from countries where governments massively grant derogations are witnessing the same losses reported in the nineties in countries like France and Italy, even though agricultural methods have evolved enough not to allow these losses to occur again. It shows that in twenty years we learned nothing in Europe about the real risk of these products. The high risk that neonicotinoids pose to bees has already been confirmed, and European institutions have recognised the need to avoid their use to protect both the beekeeping sector and biodiversity. However, beekeepers continue to experience these conditions which we have supposedly overcome in Europe. Even worse, the rules seem to be avoided since many of the notifications Member States present to the Commission are incomplete or have an inferior quality than what is requested.
It is clear that to better review the emergency authorisation notifications by Member States, EFSA's technical expertise on risk assessment is not enough. Besides, surprisingly, the quality of the work developed in these evaluations is of inferior scientific quality, subpar of the standard we have seen from EFSA in the last years. The Collaboration among agencies is necessary. We ask the Commission to improve the process to review emergency authorisations, which requires an integrated effort on pesticide risk assessment, agronomy and law. Besides, we ask that the review process is swift, results should be presented before sowing has already been carried out and it is too late to avoid another year of harmful effects on pollinators.
We thank you for taking into consideration the presented concerns and for your support to the beekeeping sector. Best regards,
President of BeeLife European Beekeeping Coordination
(1) The Standing Committee on Plants, Animals, Food and Feed