EURO COOP welcomes the European Commission initiative to harmonise maximum residue levels of pesticides allowed in products of plant and animal origin.

EURO COOP agrees with the primary objectives of the proposal to consolidate and to simplify the existing legislation in this area and to define the roles of the different actors, particularly that of the European Food Safety Authority (EFSA).

However, EURO COOP believes that another primary objective must be to protect the environment and human health.

In this respect, there must be a co-ordination and coherence between this proposal and the upcoming thematic strategy on the sustainable use of pesticides.

As such, the proposal should take into consideration the five objectives outlined in the Communication "Towards a thematic strategy on the sustainable use of pesticides" (COM (2002) 349):

• To minimise the hazards and risks to health and environment from the use of pesticides.
• To improve controls on the use and distribution of pesticides.
• To reduce the levels of harmful active substances, in particular by replacing the most dangerous by safer (including non-chemical) alternatives.
• To encourage the use of low-input or pesticide-free crop farming.
• To establish a transparent system for reporting and monitoring progress including the development of appropriate indicators.

In the long term, focus must be on how to minimise the use of pesticides and to find out where it is not necessary to use pesticides, hence finding safer, including non chemical, alternatives. One way to achieve this, could be to introduce a levy on the most hazardous pesticides in order to make it less profitable to use them.

More specifically, EURO COOP has the following comments to make:

1. Scope:

The proposal only addresses limits on individual substances. However, the combination of different pesticides in a product must be addressed too. The individual pesticides may be below or equal to the allowed level but together they may have adverse effects to human health and the environment.

EURO COOP would therefore like to see the scope of the proposal extended to address this problem.

2. Stakeholders:

Whereas the role and authority of EFSA, the European Commission and the Member States is clearly outlined in the proposal, EURO COOP feels that it is not the case for other stakeholders. For instance, there is no mentioning of the role of the consumer. The consumer, however, is the one choosing the product by the end of the day given the information provided to him/her. Therefore, information to the consumer via labelling, information brochures, web-sites etc. becomes an important tool to promote sustainable consumption and development by giving the consumer the option to make an informed choice between products.

In particular, vulnerable groups of consumers, such as, young and old people, and pregnant women, should be addressed. As they can be more sensitive to certain pesticides, a certain level of pesticides or a combination of pesticides in products.

In this respect, consumer co-operatives clearly play a role being a link between the producers and its consumer members regarding information to and education of consumers.

EURO COOP's member organisations are being active in this field and are, for instance, raising awareness about effects of certain pesticides and products on vulnerable groups via information campaigns.

Furthermore, the consumer co-operatives have a "code of practice" for producers on the pesticides that the producers may use with permission and what pesticides consumer co-operatives have banned.

In general, the member organisations demand lower levels of pesticides in products than the official levels. However, in order for it to work, the producers will have to be willing to co-operate. Otherwise, it becomes next to impossible for EURO COOP's member organisations to trace back pesticides through the food chain.

However, currently most consumer co-operatives bear the costs of controlling that the products fulfil the criteria. This means that consumer co-operatives are being punished economically for behaving responsible. EURO COOP therefore calls on the Commission to address this problem by making it the suppliers' and producers' responsibility to pay the costs.

3. Monitoring:

It will be necessary that some co-ordination of the monitoring programmes take place at EU level in order to avoid differences in national implementation criteria. Since the Member States are responsible for monitoring. As well, a clear, transparent set of rules on penalties for non-compliance should be set up to ensure a proper harmonisation.

Furthermore, appropriate information and occupational training measures should be introduced during the period of transition so that operators at all levels can adjust to the changes in the new legislation.

4. Deadline for MRLs:

The maximum residue levels (MRLs) of all detected pesticides in products must be fixed by the time the proposed Regulation enters into force, preferably by 30 June 2004.