Revision of the Sustainable Use of Pesticides Directive (SUD)

EESC opinion: Revision of the Sustainable Use of Pesticides Directive (SUD)

Key points


  • acknowledges the need for this revision and is pleased that many of the limitations identified in the current Directive and many of the initiatives planned under this new proposal had already been mentioned in the observations and recommendations made in its evaluation report[1]. The proposal aims to improve the environmental, economic and social sustainability of food systems and the EESC welcomes the benefits this brings in improving the health of citizens and consumers as well as the environment.
  • recognises that new EU strategy introduces quantitative targets to reduce the use and risk of pesticides by 2030. These targets are certainly ambitious, making it necessary to establish reasonable transition periods that take into account[2] historical reduction in use and the geographical, agronomic and socio-economic circumstances of the various Member States, and during which farmers are able to access new alternative products. Flexibility should be given to ensure that "no one is left behind".
  • highlights that harmonised risk indicators (HRIs) require clear guidelines and suitable indicators. As only limited data are currently available, especially on the use of chemical pesticides, extreme care must be taken with regard to the method used. This is particularly important when it comes to using commercial sales as a baseline (HRI 1). Equally, special attention must be paid to the time period used to calculate it. In this respect, pesticide marketing estimates could be improved, for example by distinguishing between authorisations for commercial use and for "domestic and garden use".
  • acknowledges that the negative effects of the most recent crises make food production and food security one of the top priorities on the EU's political agenda. However, the EU should continue to develop the roadmap in order to achieve its commitments on climate action and sustainability.
  • stresses the importance of focusing on alternative solutions (toolbox), prioritising better implementation and enforcement of integrated pest management (IPM), increasing and supporting the use of alternative pest controls such as low-risk or bio-based plant protection products. This toolbox should focus on the use of various solutions and measures based on science and innovation. The use of more resistant varieties, certified seed, conservation agriculture, integrated production, new breeding techniques (NBTs), organic farming, crop rotation, digital techniques and the use of minor crops must serve as a guide for successfully moving towards a model based on reduced use of plant protection products.
  • recalls the need for reciprocity of rules, to ensure that imports from third countries are subject to rules that are at least equivalent to those applicable in the EU, and for avoiding a disproportionate increase in the bureaucratic burden on farmers, especially small and medium-sized farms.
  • welcomes the introduction of a specific measure to provide financial support to compensate farmers for the costs incurred. However, it believes that it is still necessary to more fully explain how this fits in with the common agricultural policy (CAP), in particular with regard to the timetable and implementation, bearing in mind that the new CAP and corresponding strategic plans from the Member States need to be approved by 1 January 2023 and should enter into force on this date.

[1]        EESC information report on the Evaluation of the Sustainable Use of Pesticides Directive.

[2]        Eurostat, Pesticides sales in the EU.