EU Reset Impact on Plant Protection Products
In this episode of The AIC Podcast, Hazel Doonan, AIC Head of Crop Protection and Agronomy, takes a closer look at the implications of the UK–EU reset for Great Britain’s crop production and supply chains.
The conversation explains, in clear and practical terms, how proposed Sanitary and Phytosanitary (SPS) alignment could affect the approval and availability of plant protection products (PPPs), changes to maximum residue levels (MRLs), and what this means for growers, agronomists and distributors across England, Scotland, Wales and Northern Ireland.
This episode is ideal for listeners involved in UK agricultural supply chains who needs to understand how evolving UK–EU regulatory relationships may affect practical farming decisions.
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Transcript
Wendy Welcome to the AIC podcast, where we share practical guidance and insight for Members and help the industry understand how the agri food supply chain works. I'm Wendy Ford, I'm the AIC Communications Manager, and today we'll explain what the EU reset involves and what this could mean for plant protection products (PPPs), trade and day to day agronomy. I'm joined by AIC Head of Crop Protection and Agronomy, Hazel Doonan. Welcome to the podcast, Hazel.
Wendy Let's begin with explaining in simple terms what the EU reset is, and why do plant protection products fall under the sanitary and phytosanitary part of those discussions?
Hazel EU reset aims to remove trade friction between GB and the EU and Northern Ireland, which arose following EU exit and the subsequent divergence in some regulations, for example the approval of plant protection products. It's important to realise that EU reset is not a reversal of EU exit. The Sanitary and Phytosanitary (SPS) Agreement of the SPS agreement focuses on specific areas relevant to agricultural produce. Pesticides are in scope because when commodities are traded, such as grain and oilseeds, for example, a pesticide has been used in their production. The residue of that pesticide must not exceed a maximum residue level or an MRL.
Wendy Let's talk about what alignment would actually mean if Great Britain aligns with the EU. List of PPPs and MRLs. What does alignment actually look like for growers and distributors?
Hazel For GB growers, it means that if an active substance is not approved for use in the EU, when the EU reset negotiations are completed, then the active substance will be withdrawn from use in GB and growers will no longer able to use it. The MRL alignment follows the same principles in that if an EU MRL is lower than the GB MRL, the GB must align with the lower EU MRL.
Wendy Okay, with that in mind, what kind of actives look most exposed and what would you say are the realistic consequences if those actives go?
Hazel AIC and other industry stakeholders have compared the actives currently available in the EU to those currently available in GB. And of course, this may change before the negotiations are concluded as the EU continues to assess and approve or withdraw active substances and the regulator for the UK, the Chemicals Regulation Division (CRD), approves new active substances At the minute. There are about twenty active substances that GB farmers and growers have access to, which the EU has made nonrenewal decisions on since EU exit. The consequence to growers depends on a number of factors. For example, the transition period given for alignment with the EU list and EU MRLs. It is critical that the transition time scale allows pesticides in the supply chain to be used according to the label, to avoid disposal costs. It is also vital that crops treated with a pesticide, which is subsequently withdrawn as a result of alignment with the EU pesticide list, can continue to be traded, in particular where that treated crop may be stored for one or two years beyond harvest.
Wendy You've clarified some important implications there. Thank you. And that brings us to trade. How do shifting MRLs ripple through procurement and exports. And where are Members most concerned about friction.
Hazel Where the GB MRL for a product is higher than the EU MRL. Growers must ensure that if they are trading that crop into Northern Ireland or the EU, that they either do not treat the crop with the product, or that they do not export that crop to the EU or Northern Ireland if it is treated. This could mean having to segregate crops for different markets after harvest, which is really not that convenient, or perhaps sometimes not possible. If the crop is traded with the EU or Northern Ireland with a higher MRL than the EU MRL, then the crop could be rejected with subsequent costs to the grower who is actually responsible for MRL compliance.
Wendy Understood that that is a pressure point. So let's talk about divergence as it stands today. Where does Great Britain already differ from the EU on substances or renewables? And why is that more about process and cadence than weaker or stronger rules?
Hazel So when the UK exited the EU, the active substance list for the EU was carried across to GB. So active substances available in both designations were exactly the same. GB is still developing and active substance renewal programme. And so as actives come up for renewal, their approvals have been extended by perhaps from one to five years and extensions have occurred perhaps two or three times. This means that GB has made only a very few nonrenewal decisions since we exited the EU. For example mancozeb. Meanwhile, the EU has continued to assess active substances and in some cases has made non-renewal decisions on actives, which GB continues to have access to. This means that these actives are no longer available in the EU or Northern Ireland. Now, CRD has indicated that they retain the right to assess a GB approved active substance at any time if there are any concerns for human health or the environment.
Wendy Really well put. Now, Northern Ireland is a big part of this picture. What should listeners know about the Northern Ireland position and what are the real world effects on supply chains?
Hazel Okay, so under the terms of the Withdrawal Agreement and Northern Ireland Protocol, Northern Irish farmers and growers can only use active substances that are approved for use in the EU and EU. MRLs also apply in Northern Ireland. So once an active substance is approved in the EU, member states then authorise products containing the active substance and the Chemicals Regulation Division. CRD undertakes this role for Northern Irish products. So Northern Irish farmers and growers and agronomists need to make sure they keep abreast of EU decisions on active substances to ensure that any stocks that they have contain a non renewed active substances are used, up or disposed of ahead of the expiry date for storage and use. And also we can see that sometimes the EU renewal will change the conditions of use of a product relative to GB. So where this divergence occurs there are separate MAPP numbers on the products. And they differ between Northern Ireland and GB. And that means that distributors moving product from GB to Northern Ireland must ensure that they ship only Northern Ireland authorised products.
Hazel Currently, when the approval of an active substance is withdrawn, the regulation sets grace periods, usually six months for sale and supply and twelve months for storage and final use.
Wendy So to avoid waste and unnecessary cost, what transition period and handling rules does AIC think is essential for existing stocks and legally treated produce?
Hazel So, to avoid disposal costs, AIC has stressed the need for sufficiently long transition periods, which allow orderly movement of stock through the supply chain and for maximum residue levels. A sufficiently long period is also needed following application of the product to the crop. So, for example, if a crop is treated with a pesticide, it could go into storage for one or two years before it is sold to the end user or processor. if that crop is treated with a pesticide and the pesticide is subsequently withdrawn with little notice, farmers must have the assurance that the treated crop remains marketable with the MRL in place at the time the pesticide was applied.
Wendy And what would you say are the consequences?
Hazel The consequences of not allowing sufficiently long transition periods would be the unnecessary disposal of pesticides, with the cost of disposal and opportunity loss for use. So a really a double whammy for growers. The other issue is source and alternatives to withdrawn products. Because distributors plan product volumes with manufacturers probably around eighteen months ahead of the season of use. So sudden withdrawals could mean that there would be no alternative products available in the marketplace, as they would not have been planned for or even manufactured. So this would leave crops very exposed to weeds, pests and diseases and of course, growers gross margins would be negatively impacted.
Wendy Thank you for being so clear on the impacts and the importance of the transition period. If we look to on the ground reality, you've recently had officials visiting professional PPP stores. Can you tell us more about what did this involve and any big misconceptions busted?
Hazel Yes. That's right. AIC recently invited policymakers to AIC members distribution depots and I think collecting feedback from the attendees. The main takeaways were the numerous regulations around the storage and distribution of professional pesticides that members have to adhere to, and the best practice as well. Also, the varied role of agronomists and how passionate agronomists are about helping their growers make informed choices about crop production and helping those growers improve the outcomes for their crop. And also, the challenges distributors have in managing, to ensure that the right product is in the right store at the right time of the year, bearing in mind the seasonality of product use. The narrow windows of application for some products, and how actually weather can prevent application of product at all. And to I think the misconceptions that were busted were I think visitors were fascinated by the diversity of advice offered to growers by agronomists, beyond the use of just plant protection products, and this advice was very much tailored to the needs of the grower.
Wendy I really like that insight. Let's widen the lens to integrated pest management. How does protecting access to a diverse set of PPPs support the National Action Plans push for IPM? And where could alignment narrow options if mishandled?
Hazel So Integrated Pest Management (IPM) includes the use of a range of solutions to control weeds, pests and diseases, including plant protection products. And when plant protection products are used in an IPM approach, it is vital that active substances with different modes of action are used to control them, to allow that to be done effectively and prevent the development of resistance. So the withdrawal of active substances, particularly if a decision is made to withdraw many, simultaneously puts more pressure on remaining actives and will present growers and agronomists with real problems in selecting different modes of action.
Wendy And with that in mind, which regulatory decisions should Members track in twenty twenty six?
Hazel So this year we will see the outcome of the negotiations on EU reset and hopefully have a lot more understanding about the transition periods which have been negotiated. We'll also see, towards the end of this year a decision on the GB renewal of glyphosate, because the current approval expires mid-December. And then also there's a classification of trifluoroacetic acid, which is a short chain polyfluoroalkyl substance, a PFA. And that's been assessed by ECHA. They sorry, there's a lot of acronyms here, the European Chemicals Agency. So some pesticides can break down to form trifluoroacetic acid. And so the outcome of the assessment by ECHA could impact the use of some pesticides in the EU. And hence of course GB. And the outcome of that ECHA assessment is expected in October this year. And then of course you mentioned the National Action Plan. And within that the pesticide load indicator will also be updated towards the end of twenty twenty six to include the data from the Pesticide Usage Statistics for Arable Crops, which was published in December twenty twenty five.
Wendy That's a great steer. Thanks, Hazel. And finally, let's talk action. What are your top three actions now for distributors and agronomy teams around inventory planning, MRL vigilance, and proactive customer communications.
Hazel So I think it would be very sensible for farmers and growers to make a list of the plant protection products they have in stock so they can use or dispose of them ahead of the expiry dates, which will be set after the EU reset. Negotiations are finalised. I think it's also helpful if they share that list with their agronomist. Also, when planning rotations, growers need to think about problematic weeds in fields. So in the event that a pesticide is not available, they have perhaps considered with their agronomist how they would control that weed with perhaps alternative solutions. For distributors, they obviously need to review their current stocks and obviously discuss with manufacturers what their planned offtake might be, thinking ahead of the outcomes of the EU reset negotiations.
Wendy Brilliant actions. Thanks for that, Hazel. Thank you so much for joining us today, Hazel.
Hazel Thank you.
Wendy Members can find further updates, guidance, and resources on the AIC website and through our Member Communications. Thank you for listening, and we'll be back with another episode soon. If you found this useful, please share it with a colleague and check the show notes for links and definitions. And again, thank you for joining us.
