Eco Hvar

Pesticides, Laws and Permits

Published in Poisons Beware

Pesticide regulation, registers, laws. We provide a guide to the systems governing them, with an overview of some of the many problems arising from pesticide use.

Pesticides, Laws and Permits

For a list of pesticides commonly used on Hvar, including their scientifically proven possible adverse effects, please click here.

WHAT YOU NEED TO KNOW

Pesticides are used in massive quantities around the world. The World Health Organisation (WHO) has expressed concern about Pesticide residues in food (February 2018) : 
  • Pesticides are potentially toxic to humans and can have both acute and chronic (long-term) health effects, depending on the quantity and ways in which a person is exposed.
  • Some of the older, (often cheaper version) pesticides can remain for years in soil and water. These chemicals have been banned from agricultural use in developed countries, but they are still used in many developing countries.
  • People who face the greatest health risks from exposure to pesticides are those who handle them or come into contact with them at work, in their home or garden.

Information about potential hazards and long-term effects is vital for all those involved in the manufacture of pesticides, all those who handle pesticides in the marketplace, all those who use pesticides in fields or gardens - and all the consumers who buy products of any kind which have been treated with pesticides. In short, everyone needs to understand all the issues at stake in relation to pesticides.

PESTICIDES IN THE FOOD CHAIN

Pesticides are a lucrative business, promoted through powerful marketing and political clout. Pesticide control is complicated at international, national and local levels. Public information is vital. Pesticide vendors and users should be fully aware of what they are dealing with. Consumers, the end-users, need to be told what substances have been used in the production and packaging of foodstuffs and personal hygiene products. When pesticides are approved for the market, the first area of concern is that the safety and efficacy studies which support an application are produced by the commercial companies: these are usually unpublished papers, whereas independent studies published in peer-reviewed journals are hardly, if ever, taken into account. On approval, for pesticides which are likely to enter the food chain, so-called 'safe' levels are established as the maximum amounts which can be present in crops and foodstuffs without jeopardizing health. The 2015 report produced by the United States Department of Agriculture (USDA) revealed that only 15% of 10,187 sample foodstuffs tested were free of pesticide traces, while over 99% contained residues below the tolerances established by the U.S.Environmental Protection Agency (EPA). The European Food Safety Authority (EFSA) reported that of 84,657 samples tested in 2016, 96.2% were within the limits set by EU legislation and 50.7% were free of quantifiable residues, while legal limits were exceeded in 2.4% of the samples from EU and EEA countries, and 7.2% from non-EU countries.

Are Maximum Residue Levels (MRLs) a guarantee of safety? There are drawbacks: 1) MRLs do not cover the effect of a combination of poisons in foods, if, as is usual, 'conventional' crops have been treated with several different types of pesticide; 2) inspections in different countries (eg Kuwait) all too often discover pesticide residues above permitted levels, not to mention banned pesticides, in foodstuffs (eg Denmark, 2017); 3) MRLs have an alarming tendency to be raised, quite often for marketing reasons, as with glyphosate in 2013, and lasaloocid in 2015; 4) it is worrying that commercial pesticide manufacturers can ask for MRLs to be raised, eg Syngenta's request in 2012 for a significant increase in permitted levels of neonicotinaoid insecticide residues in olives, artichokes and cauliflower (EFSA Journal 10 (11) 2990); 5) on one hand it is good that the setting of MRLs is reviewed periodically, as in the EFSA paper 'Scientific opinion on pesticides in foods for infants and young children' (EFSA Journal, May 2018), but on the other hand this brings the worry that MRLs in infant foods were incorrectly set for years previously. 

Contamination of water sources and therefore drinking water by pesticides is another major area of concern, for which the World Health Organisation has drawn up widereaching guidelines. The EU has Directives governing drinking water quality, while in the United States the EPA has set more specific Maximum Contamination Levels for different kinds of pollutants. On the ground, pesticide users must be aware of the dangers of groundwater contamination, not only when applying pesticides, but also when disposing of excess or outdated poisons and discarding pesticide packaging. 

PESTICIDE REGISTERS

European Chemicals Agency (ECHA) lists approvals of active substances and products. Its website is the primary source of information about the laws governing pesticides and their approval processes. You can check its list of substances which are approved or under review, or you can check on active ingredients and approved products on the ECHA 'biocidal products' page, by typing the name of the active ingredient in the box marked 'Active Substance Name' or the name of a pesticide product in the box marked 'Product Name'. The listing is updated regularly. However, herbicides and agricultural fungicides are not included in this listing.

European Commission: EU Pesticides Database (home); search active substances; search products, download MRL data.

EU Pesticides Database: Updates on regulations for Active Substances and MRLs. (Note: this database is not fully updated, but it does carry the latest legislation for listed substances)

EPPO (European and Mediterranean Plant Protection Organization) Listing of national databases of pesticides

Ministry of Agriculture, Republic of Croatia. List of Registered Plant Protection Products. [For 'plant protection' read pesticides] Includes section on substances which are no longer approved, listed by year.

Croatian Institute of Toxicology and Anti-doping: About the Institute. The Institute carries a list of pesticides in Croatian, but only up to 2015, and warns that the list is not in keeping with current EU laws.

University of Hertfordshire: Pesticide Properties Database (PPDB) - database listing pesticide chemical identity, physicochemical, human health and ecotoxicological data.

University of Hertfordshire: Bio-Pesticide Database (BPDB) - database of data relating to pesticides derived from natural substances.

PubChem Open Chemistry Database. U.S. National Library of Medicine, National Centre for Biotechnology Information. Comprehensive technical information about chemical substances, including toxicity.

List of banned pesticides by active substances, and pesticide watchlist (2015), UTZ Amsterdam, the Netherlands

United States National Library of Medicine: Toxnet. Databases on toxicology, hazardous chemicals, environmental health  and toxic releases.

United States Environmental Protection Agency: Pesticide Registration, Inert Ingredients Overview and Guidance.

OFFICIAL PROCEDURES GOVERNING PESTICIDE REGISTRATION AND USE IN CROATIA

European Commission: Approval of Active Substances; (EU LINK) National Inspectorate: Croatia

Food and Agriculture Organization of the United Nations (FAO): Prevention and Disposal of Obsolete Pesticides.

The Croatian Agriculture Ministry is the main coordinator for registering pesticides and issuing permits for them. Documentation is checked for completness, and then submitted to one of the two registered authorities / institution named below for a document and risk assessment. This authority may then ask for further documented evidence and information. Communications with the applicant are coordinated through the Agriculture Ministry. When the documentation is satisfactory, the registered authority submits its proposal for registration to the Agriculture Ministry for enactment.

Croatian Centre for Agriculture, Food and Rural Affairs (as of 1st January 2019 the Croatian Agency for Agriculture, Food and Rural Affairs): Institute for Plant Protection. This Institution department evaluates active ingredients and substances in pesticides and their efficacy, establishes analytical methods, studies pesticide residues in foods and the behaviour of pesticides in the environment, ecotoxicology, and assesses the exposure of operators, workers and others involved in pesticide use.   

Institute for Medical Research and Occupational Health. This Institute at the request of the Ministry of Agriculture prepares documentation for pesticides regarding registration, obtaining certain permits, extending registrations, and expanding registration for small-scale operations. it also provides scientific opinions on mammal toxicology and exposure risks for operators, workers and others involved in pesticide use.  

The Croatian Ministry for Environmental Protection and Energetics is responsible for creating conditions for sustainable development, including "tasks related to protection and conservation of the environment and nature in line with the sustainable development policy of the Republic of Croatia, as well as tasks related to water management and administrative and other tasks from the field of energy." Although soil, air, water and sea quality lies within its remit, it does not include specific projects relating to pesticides.

FURTHER SOURCES OF ADVICE ON PESTICIDE USE IN CROATIA

Hrvatska polioprivredno-šumarska savjetodavna služba (Croatian Agriculture and Woodland Advisory Service): 'Plant protection' (in Croatian)

Agroklub: Pesticides. A selective database of pesticides available in Croatia; no adverse effects listed; list not totally up to date (in Croatian)

INTERNATIONAL REGULATIONS GOVERNING PESTICIDE USE

EU LAWS:

European Chemicals Agency: REACH (Registration, evaluation, Authorisation and Restriction of Chemicals) - an explanation

Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC

 
Directive 2009/128/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for Community action to achieve the sustainable use of pesticides (Text with EEA relevance)
 
Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 October 2009 concerning the placing of plant protection products on the market and repealing Council Directives 79/117/EEC and 91/414/EEC

Regulation (EU) No 528/2012 of the European Parliament and of the Council of 22 May 2012 concerning the making available on the market and use of biocidal products Text with EEA relevance

Decision No 1386/2013/EU of the European Parliament and of the Council of 20 November 2013 on a General Union Environment Action Programme to 2020 ‘Living well, within the limits of our planet’ Text with EEA relevance

Regulation (EU) No 649/2012 of the European Parliament and of the Council of 4 July 2012 concerning the export and import of hazardous chemicals Text with EEA relevance

Regulation (EU) 2016/2031 of the European Parliament of the Council of 26 October 2016 on protective measures against pests of plants, amending Regulations (EU) No 228/2013, (EU) No 652/2014 and (EU) No 1143/2014 of the European Parliament and of the Council and repealing Council Directives 69/464/EEC, 74/647/EEC, 93/85/EEC, 98/57/EC, 2000/29/EC, 2006/91/EC and 2007/33/EC

Commission Regulation (EU) 2018/605 of 19 April 2018 amending Annex II to Regulation (EC) No 1107/2009 by setting out scientific criteria for the determination of endocrine disrupting properties (Text with EEA relevance. )

Corrigendum to Commission Regulation (EU) 2018/605 of 19 April 2018 amending Annex II to Regulation (EC) No 1107/2009 by setting out scientific criteria for the determination of endocrine disrupting properties (OJ L 101, 20.4.2018)

CROATIAN LAWS

Ministarstvo poljoprivedbe RH: Propisi - Sredstva za zaštitu bilja; ostaci pesticida; održiva uporaba pesticida; zdravstvena zaštita bilja.  Croatian Agriculture Ministry: Regulations governing 'plant protection products'; pesticide residues; sustainable use of pesticides; plant health protection. (in Croatian) 

Ministarstvo zdravstva RH: Kemikalije i biocidni pripravci - Croatian Ministry of Health: Chemical and Biocidal Products, regulated according to EU laws. (Website in Croatian) 

Ministarstvo zdravstva zakonodavstvo: Ministry of Health, website in Croatian only.  Laws governing chemical and biocidal substances; import and export of dangerous chemicals; disease prevention; preventive disinfection, insect and vermin suppression measures; and safety in the workplace.

Ministarstvo zaštite okoliša i energetike RH; Propisi i međunarodni ugovori. Croatian Ministry for Environmental Protection and Energetics: Regulations and International Contracts: environmental protection; air quality protection; climate and ozone layer protection; waste management; nature protection; sea and coastal region protection. (in Croatian)

Croatian Institute for Public Health: Laws and Regulations. Laws relating to the prevention of transmissible diseases include the use of pesticides.

© Vivian Grisogono 2018, updated February 2019

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