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ALLEGATO 8

Commission Communication on the sustainable use of pesticides⁴

Dear Mrs Hellsten,

Dear Sir, Madam

I am writing to you as a result of having read the Commission's Communication on the Sustainable Use of Pesticides. As a scientist who has

dedicated most of his career to researching and developing crop protection products, I believe there are a number of elements of this strategy

that need to be further considered, and I hope that my letter to you will convince you that a reduction in the use of pesticides is not a feasible

method for achieving sustainable agriculture in Europe.

The objective of policy on use of pesticides is to avoid any risks to or impact on human health and the environment. At first glance, it may

appear that an arbitrary use reduction, by 50% for example, is a simple means of reducing risk. However, this is not the case.

The most effective way to reduce risks associated with the use of pesticides is to use these products appropriately. Improved application

technology, regular inspections of equipment, improved user education and the adoption of integrated techniques such as Integrated Crop

Management (ICM) and Integrated Pest Management (IPM) are all ways of ensuring that the type of chemical control chosen is appropriate

and used as sparingly as possible.

Any imposed use reduction programmes do not consider qualitative aspects of pesticide products like their environmental properties, and thus

are not in accordance with the principles of Integrated Pest Management and Integrated Crop Management. It is a fact, however, that there has

been a reduction in the amounts of pesticides used in the EU over the last ten years. But this is thanks to technological innovation, novel c

hemistry and improved application technology; moreover, the review of existing active substances as laid out in EU Dire c t i v e 91/414/EEC is

 contributing to the further withdrawal of pesticide products from the market.

An arbitrary restriction on the use of pesticides (quantitative by volume or number of applications) could have serious repercussions on both the

farming sector and the economy in general. There could be job consequences, income losses for the farming community, deterioration of  food 

quality and affordability, and the necessity to use more land for agriculture. Arbitrary use reduction measures should thus not become part of the

 envisaged Thematic Strategy nor of national risk reduction programmes.

I hope that you will take the mentioned points into consideration and I look forward to a fruitful and workable strategy for the sustainable use of

pesticides in E u ro p e.

With kind regards,

Dr. Birgitt Walz-Tylla

4 Le parti evidenziate sono identiche a quelle dell’allegato 5 della Basf