Why emergency authorisations are on the rise

Why emergency authorisations are on the rise

Blick and Beobachter report that the federal government is increasingly approving emergency authorisations for crop protection at the request of manufacturing companies, suggesting that substances banned on the Swiss market are being reintroduced through the back door, so to speak. The story is as engaging as it is false. What is true, however, is that there are more and more pests for which no authorised products are available. The authorisation process is stalling.

Thursday, January 11, 2024

"The federal government is increasingly authorising pesticides via emergency approvals that are actually no longer allowed to be used. Is this a way of circumventing the increasingly strict guidelines?" ask Blick and Beobachter. The same question was also investigated by French-speaking Swiss television. As it reported at the beginning of the year, the number of emergency authorisations for "normally unauthorised" pesticides rose from six in 2019 to 29 last year.

According to the Federal Food Safety and Veterinary Office (FSVO), the reasons for the increase in emergency authorisations of plant protection products that are "banned" according to Blick and Beobachter lie in stricter authorisation criteria. The aim is to better protect humans, animals and the environment. This is why many older active substances and products have been withdrawn from the market in recent years. However, according to the FSVO, many companies no longer wanted to take on the expense of new studies. No wonder, as the Swiss market is far too small and not very lucrative for many companies. At the same time, according to the FSVO, new pests have emerged in recent years. "If a pest or disease cannot be controlled with the authorised plant protection products, the FSVO may grant the manufacturer an emergency authorisation," writes the Beobachter. Emergency authorisations are generally valid for one year, but can also be extended. "A total of 208 active substances have had their authorisation withdrawn since 2005."

Sandra Helfenstein, Head of Communications at the Swiss Farmers' Association, confirmed to the Beobachter that it is becoming an ever greater challenge for farmers to protect their crops from pests. "Crop protection is less and less guaranteed and the production risk is increasing enormously." And she points out a serious problem: If there is a lack of active ingredients, resistance increases, just like in medicine. At least three different active ingredients should be available to combat pathogens in order to prevent resistance. Helfenstein says: "Where there are alternative protection options, these are also used in practice." If these are lacking, if they are unreliable or if the alternatives are too labour-intensive or costly, the production of certain vegetables, fruit or animal feed will be abandoned. In other words: If the economic viability is not there, the willingness to cultivate decreases and the missing quantities have to be imported. This can be seen, for example, with rapeseed, sugar beet and potatoes. Ruedi Fischer, President of the Swiss Potato Producers Association (VSKP), told the Luzerner Zeitung newspaper: "The increasing problems caused by climatic changes and the lack of crop protection have reduced the willingness to grow potatoes. This is because potatoes are a capital-intensive business compared to other vegetables." Farmers have to invest around CHF 11,000 for one hectare of potato fields. If the harvest fails, the loss is huge. "And many people no longer want to take that risk."

The increasing number of invasive species is a problem for our crops and biodiversity. They are also a global threat: according to the UN World Biodiversity Council, they play a major role in 60 per cent of animal and plant extinctions. Last year, for example, the FSVO issued emergency licences to combat the Japanese beetle. This beetle is not at all picky: it causes feeding damage to over 400 host plants. According to the Beobachter, a total of seven new pests could be controlled with ten emergency licences in 2023.

In the article, Hans-Jakob Schärer from the Research Institute of Organic Agriculture (FiBL) brings in another aspect and refers to the consequences of climate change. "Sometimes it's too dry and too hot, and insects can multiply, sometimes it's extremely wet, which leads to increased infestation by pests." However, he is also wrong. It is not the producers who apply for emergency licences, but those directly affected, for example the fruit and vegetable associations. Emergency authorisations are therefore not an instrument used by producers to circumvent the regular authorisation procedure, as Hans-Jakob Schärer implies.

What all three reports ignore: The vast majority of emergency authorisations are indication extensions for plant protection products normally authorised on the Swiss market. This is because plant protection products are authorised for specific crops and only against the specific fungus or pest listed in the authorisation for the respective crop. For example, against the oilseed rape beetle in oilseed rape. If a new pest appears, the indication must be extended. This is not the only area where press reports reach their limits. What remains unmentioned is that Switzerland actually has a bigger problem than the EU when it comes to the authorisation procedure for new and modern plant protection products. swiss-food has been pointing this out for some time now. While in the leading agricultural countries innovations are relatively quickly on the market thanks to risk-based authorisation processes, the precautionary principle in the EU and Switzerland, which is based on the (erroneous) idea of avoiding any risk, slows down these innovations. However, while certain new plant protection products are (currently still) being authorised even in the extremely restrictive EU, the Swiss authorities are pushing a mountain of authorisation applications in front of them. Research into new plant protection products is already extremely demanding. It takes eight to twelve years for a new active ingredient to be found and authorised - and there are only a few companies left that can manage this complexity, make the necessary effort and bear the immense costs. In Switzerland, it will be another eternity before the active ingredient reaches the farmers - if at all. At the moment, 783 applications are pending, but according to the authorities, only 100 applications can be processed per year. The authorities therefore take it upon themselves to prioritise which applications they prefer - and thus interfere in the competition between crop protection companies.

There is also an asymmetry. While Switzerland immediately withdraws plant protection products that the EU takes off the market, the bureaucracy in Bern has so far insisted on an autonomous authorisation process. With fatal consequences: There are fewer and fewer plant protection products that help farmers to protect their harvests and thus our food. And with only a few active substances left, resistance is also increasing, as in medicine. What the farmers' association and the agricultural media have been warning for a long time has come to pass: "The cancellation concert will have consequences." was the headline in Schweizer Bauer in February 2023, for example, but farmers must be able to protect their crops - they need real solutions and answers, not the principle of hope. So their associations are applying for emergency authorisations. The development "lack of protection options, sharp rise in emergency authorisations" was also highlighted by the Federal Office for Agriculture at its annual meeting on the implementation status of the Plant Protection Action Plan in September 2023 (page 18 of this presentation). The action plan is actually intended to address the protection of crops, the environment and people, i.e. to cover the sustainability dimensions. However, in the more than 50 measures, the protection of the environment is overemphasised and the protection of crops is massively underemphasised. However, there is no sustainable agriculture without marketable products.

However, there has been some movement on the dossier. Parliamentary initiatives and motions in the Swiss parliament are calling for the EU authorisation to be adopted in the same way as the revocations. And the consultation on a total revision of the Plant Protection Ordinance is currently underway. The Bauern Zeitung has also reported on this. The aim of this amendment to the ordinance is to harmonise the Swiss authorisation process with that of the EU, but not to adopt it completely. However, a swift adoption of the authorisation process for new and modern plant protection products would be the best way to combat the constantly increasing number of emergency authorisations.

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