A team of researchers of the Wageningen University and Research Centre (Agricultural University of the Netherlands) published on 28 October a 150 page report on the economic impact of the proposed revision of the directive 91/414 on thirteen of the most important crops grown in the Netherlands. Below is a summary of the report.

The field crops include seed- and ware potatoes, direct seeded onions, sugar beet, winter wheat, Brussels sprouts and apples, but also two very traditional and high-value Dutch crops, tulip bulbs and ornamental shrubs. The economic impact was also assessed in the following vegetable and floricultural crops grown under glass: cucumber, tomatoes, roses and Chrysanthemum.

Two scenarios were studied:

1. Impact of “Cut-off” criteria based on the position of the European Parliament after a plenary vote, which would result in a ban of 85 % of the active substances. In this summary, this scenario will be referred to as EPP cut-off scenario. Please see Table 1.
2. Impact of “Cut-off” criteria based on the proposal of the European Commission, in which pesticides would be banned if they are endocrine disruptors, carcinogenic, mutagenic and reprotoxic substances as well as Persistent Organic Pollutants. This scenario will be referred to as EC/CMR/POP scenario.  Please see Table 2.

To calculate the impact of banning certain pesticides on the crop margin/Ha, Ir. Spoorenberg and his team looked in a very systematic manner at the following parameters:

• Pesticides currently in use
• Crop yield and crop margin in current situation
• Pesticides allowed when scenario 1 or 2 have been implemented and their impact on the crop margin
• Yield reduction due to the ban of active substances
• Requirement of additional manual labour e.g. manual weeding and how this impacts the variable costs / ha.
• Efficacy of alternative products and effect on crop yield their cost/ha in comparison to the products that would be banned
• Long-term “survival” chances of the crop, e.g. build-up of nematode populations, faster development of resistance of fungi and insecticides and increased weed problems due to the reduced number of products available for treatment of that crop. These long-term effects could not be quantified, but they will undoubtedly have a serious impact in the future.

Implementation of the EPP cut-off scenario will result in yield decreases between 50 to 100% (!) in Brussels sprouts, tulip bulbs, direct seeded onions, ornamental shrubs and with the exception of tomatoes, in all glass house crops evaluated. In all these crops, as well as in tomatoes and sugar beet, the crop margin will decrease > 50%. This implies that growing these crops would not longer be economically viable if EPP cut-off scenario would be implemented.  See Table 1.

Also yield reductions ranging between 15 and 32 %,  as is the case for seed-and ware potatoes, winter wheat, apple and the earlier mentioned crops tomatoes and sugar beet, will already have a major impact on the returns / ha, which makes it increasingly difficult to pay the fixed costs from the lower crop margins. This could result in these crops also disappearing completely from the Netherlands.

Assuming the EC/CMR/POP scenario could be implemented without further amendments far fewer active substances would be lost from the toolkit of the farmer. The estimate is that between 9 and 25% of the active substances would disappear. This raises the question whether this scenario would improve the situation for the crops endangered when the EPP cut-off scenario would be enforced. The data are summarized in Table 2.

The EC/CMR/POP scenario results in lower crop yield reductions in all crops studied than with the EPP cut-off scenario. However, decreases of the crop margins > 50% will still occur in the following crops: direct seeded onions (56%), tulip bulbs (99%), ornamental shrubs (> 100%) and Chrysanthemum (62%).

This will continue to lead to economic losses or at least to decreased profitability in those crops. Also in this scenario, it is far from certain that in the future growing tulip bulbs, ornamental shrubs, direct seeded onions and Chrysanthemums can survive.

Not only the crops mentioned are in danger of disappearing permanently from the Dutch soil. In the case of flower bulbs, the tulip bulbs have been chosen as example for this study, because nearly 50% of the flower bulb acreage (23,000 Ha) is planted with tulip bulbs. Also the other flower bulb crops will be under pressure.
Implementation of either one of the scenarios would mean that the total number of flower bulbs produced could decrease by as much as 80%. Dutch flower bulbs are a big export article; of the 12 billion bulbs harvested annually more than 75% are exported world wide. The macro-economic consequences when this would disappear do not need to be stressed here.

Another example shows perhaps even better that before decisions are made regarding the revision of Directive 91/414, it is of great importance to get all parties concerned involved in the dialogue. The Netherlands is world’s biggest producer (1.25 million MT/annum) and exporter of seed potatoes; famous for their high quality. This high standard can only be maintained by reliance on pesticides for control of potato virus vectors (aphids), Colorado beetle, wire worms, fungal diseases, and cyst and other nematodes. Irrespective of the economic blow the disappearance or even the partial disappearance of seed potatoes would cause in the Dutch home market, the fact that the major global supplier of seed potatoes can no longer deliver will severely affect ware potato production not only in the EU but globally. This will certainly have a major negative impact on food security as well as on food prices.

In summary, the impact study made by the Wageningen University demonstrates clearly that the implementation of either the EPP cut-off scenario or even the EC/CRM/POP scenario will have enormous economic ramifications in the Netherlands, because entire crops which are major export contributors will disappear because growing them is no longer economically viable. The crop margins / profitability of the “surviving” crops will be under increased pressure, while medium- to long-term the chances of developing resistance to the reduced number of available insecticides and fungicides, weed problems, and higher nematode populations will greatly increase.

It seems reasonable to assume that other EU member states will be confronted with identical issues when they sponsor similar studies in their country.

Securing the safety of our children, family and co-workers is, apparently, increasingly important in many countries around the world. Governments continually pass legislation to restrict certain behaviours as well as products that could potentially cause harm. But are we going too far in wanting to remove all potential risks from our daily lives … and can our obsession with increasing safety actually cause harm?

In attempting to pass strict new regulations of pesticides, the European Commission and some in the European Parliament may be attempting to create a safer world. It is fairly easy for politicians and bureaucrats to argue in favour of certain regulations based on the idea that they will reduce our exposure to harmful chemicals. Dan Jorgensen, a Danish MEP, recently explained how he worked with an activist group to test the pesticide residues on fruit and vegetables bought in a supermarket within the European Parliament. Jorgensen reported that many different pesticides were found on the produce and he used that fact as part of his justification of pushing forward with the controversial amendments to Directive 91/414 .
The great shame is that Jorgensen didn’t engage with unbiased scientists to conduct the testing and interpret the results. Undoubtedly there were pesticide residues on the produce … but so what? What does that actually mean for human health and the environment? It isn’t enough to simply find the presence of a chemical; one has to connect the dots and prove that that chemical is responsible for causing harm to human health or the environment, excluding all other possible cause of harm. And once that has been done, logically one would want to know how serious and widespread that harm is and how that compares with the benefits of using the chemical.

It seems however that in selling regulations supposedly designed to protect people, evidence of harm is not required; the mere presence of a man-made chemical is sufficient. Jorgensen and others would do well to read the worlds of two world renowned scientists, Bruce Ames and Lois Gold. Their work assessing the risks posed by man-made chemicals is enlightening and should be made widely available in Brussels.

Ames and Gold show that most cancers are caused by smoking, dietary imbalances, chronic infections (which is more of a problem in developing countries) and hormonal factors influenced by lifestyle. Around half the chemicals ever tested are known to be carcinogenic, but because we typically ingest them in low doses, they do not pose a threat. The synthetic chemicals that we are exposed to are not important when it comes to human cancer. Almost all of the carcinogens that we are exposed to are not from synthetic chemicals, but from natural chemicals found in food such as broccoli, carrots, potatoes, coffee, lime … and on and on and on.

When regulators attempt to make our lives safer by regulating synthetic chemicals, they end up costing industry, taxpayers and consumers billions of Euros. Where are the benefits when the main risks from cancer don’t come from the chemicals but from our lifestyle? Furthermore insofar as the regulations increase the cost of food (as the new EU regulations would), they reduce our consumption of fresh fruit and vegetables, which could worsen cancer rates, especially for the poor.

Regulators and politicians seems to think that if these products are banned, chemical companies will be motivated to go out and develop new, safer chemicals. How this will happen with a regulatory system that is not based on scientifically rigorous risk-assessments is anybody’s guess. This idea also lays bare a worrying lack of understanding of business incentives as well as a complete disregard for the unintended consequences of regulations that will harm the poor in the EU and far beyond.

As has been described here and elsewhere, these regulations are likely to make the use of chemicals in farming and public health programs harder to use and more scarce. Perhaps before any EU Commissioner or Parliamentarian promotes the regulations, they should be made to spend a month living and surviving on a small holder subsistence farm in a malarial part of Africa. Perhaps then they would get a better understanding of the value of modern chemicals and the real dangers posed by a world in without pesticides.