The next National Action Plan on the Sustainable Use of Pesticides (NAP) was due to be published in 2018. However, here we are 5 years later, still without a published NAP. The Pesticide Collaboration has now published a document outlining our ‘red lines’ for the final NAP. 

The final NAP should build on the 2020 draft and respond to the submissions from civil society and experts. Our document sets out the minimum standards we expect from the plan that has taken over 5 years to publish.

The summary of our key red lines are below, and we have gone into more detail here.

The NAP must: 

1) maintain the UK’s ‘hazard-based’ approach to pesticide regulation and continue the commitment to the precautionary principle 

The UK – along with the EU – currently follows a version of the hazard-based approach to pesticide regulation. This follows the principle that if an active substance possesses intrinsically hazardous characteristics – for instance by being able to cause cancer or persistent pollution – then it is simply considered too dangerous to be used safely and should not be authorised. This approach is in line with the precautionary principle. The NAP must include a commitment to retain a hazard-based approach and continue to follow the precautionary principle, which theoretically underpins all current UK decision-making on pesticides.

2) include commitments to increasing the uptake of Integrated Pest Management (IPM) 

Integrated Pest Management (IPM) is an approach to managing pests, diseases or weeds in which chemical pesticides are used only as a last resort, if at all.  It sits in direct contrast to the majority of conventional agriculture in which pesticides tend to be the first weapon of choice for dealing with unwanted organisms. We know the Government wants to support uptake of IPM – and the simple fact that an IPM standard is included in the first batch of standards within the Sustainable Farming Incentive (SFI) to be rolled out is important. 

However, without the right support in place to help farmers and other land managers to adopt genuine IPM then uptake will remain low. We therefore expect the NAP to outline what this support will look like as well as include overall commitments to increasing uptake of IPM as a means to reduce the risk to people and the environment from pesticides. 

3) commit to breaking the link between farm advice and pesticide profits 

It is important that the NAP recognises the importance of increasing transparency and independence from industry when it comes to pesticides. For example, the NAP must commit to breaking the link between farm advice and pesticide profits and commit to making agronomic advice independent of pesticide sales available to farmers. The NAP must provide assurance that any regulatory enforcement system will be created independently from the industry it seeks to regulate. 

4) include a commitment to reducing pesticide use, through the introduction of clear  reduction targets for both usage and toxicity 

It is vital that the UK reduces the amount of pesticides being used, as well as the related harms to human health and the environment. 

The UK has committed to “reducing the overall risk from pesticides and highly hazardous chemicals by at least half” in the Kunming-Montreal Global Biodiversity Framework agreed at COP15. This should now be reflected in national policy, and domestic pesticide regulation must go further than this and use the words ‘use’ and ‘toxicity’ instead of risk. 

To not include a commitment to clear and robust targets in the NAP would be unacceptable. The Pesticide Collaboration has commissioned a detailed report on what pesticide reduction targets should look like.

5) commit to a phase out of pesticide use in urban areas 

The phase out of urban and amenity use of pesticides is essential. Many towns and cities around the UK and globally have already ended pesticide use in urban areas. Most urban pesticide use is purely for cosmetic reasons so there is no risk of a knock on effect on food security: the vast majority of urban and amenity pesticides are entirely unnecessary and there are plenty of non-chemical alternatives available. 

The NAP should set out a strategy to phase out pesticide use in urban areas, particularly green spaces, pavements, and around hospitals, schools, and housing estates. This would be a clear recognition of the harmful impacts of pesticides on human health, as well as on the local environment. Local authorities and other land managers should be given the resources and knowledge to use alternatives to pesticides.

6) commit to ending emergency authorisations of banned pesticides

In January 2022 and 2023, the government permitted the ‘emergency’ use of the banned pesticide thiamethoxam – a type of neonicotinoid – on sugar beet in England in 2023. These banned pesticides are lethal to wildlife – a single teaspoon of neonicotinoid is enough to deliver a lethal dose to 1.25 billion bees. The Court of Justice of the EU (CJEU) declared that providing emergency derogations for expressly prohibited neonicotinoid-treated seeds is not in line with EU law – the UK should follow this example. 

The NAP should set out a path to end the repeated ‘emergency’ authorisations of banned pesticides that have been granted for neonicotinoids in recent years. The emergency authorisation process was not designed for repeated year-on-year authorisations like we’re seeing, so the NAP should commit to action to ensure it isn’t exploited to allow continued use of banned substances. The NAP must also commit to funding research into alternatives for all pesticides that are granted emergency derogations, including the use of neonicotinoids such as thiamethoxam on sugar beet crops.