France reintroduces pesticide plan, this time with EU indicator

Regulatory background

• Until recently, the EU had plans to halve pesticide reduction by 2030. The proposal for a regulation on the sustainable use of pesticides (SUR), however, died in European Parliament in November 2023.
• Several iterations of the French Ecophyto Plan have been observed over the years. The first version of the plan, whose goal was reduction of use of pesticides (or “plant protection products, as the plan called them) was unveiled in 2008 with the aim of cutting pesticide use in half by 2018. In the several years that followed, a network of French pilot farms successfully trialed reduced pesticide use, though popular uptake was disappointingly modest, according to a 2015 roadmap for the next iteration of Ecophyto.
• When it became clear this target was not going to be met, Ecophyto II was released in 2015. Again, it emphasized a goal of reducing pesticide use by half, this time by 2025. Ecophyto II laid out seven guiding principles, beginning with the 50% pesticide reduction goal. Some other goals included working locally and collaboratively, keeping the project at the center of the green agriculture movement, focusing on commercial adoption of alternative practices while respecting economic realities, and keeping messaging positive. A set of six priority areas mapped out specific action steps in relevant areas; for example, one priority was to promote practices among farmers that would help them reduce pesticide use. A means of accomplishing this was planned to be a certification program for low users of pesticides.
• In 2018, this plan was refreshed and renamed the Ecophyto II+ Plan. It kept the same primary aspiration, guiding principles, and priority areas as the previous iteration, but integrated domestic initiatives to reduce reliance on glyphosate, and pesticides more generally. Ecophyto II+ also incorporated European obligations under Directive (EC) 2009/128 on the sustainable use of pesticides (SUD) to adopt national action plans setting targets for pesticide reduction.
• In June 2023, the French Socialist party used its allotted yearly right of inquiry to question the government on its failure to implement Ecophyto ambitions. [See AgencyIQ’s analysis of this event here.]
• In late October 2023, the French government announced yet another version: Ecophyto 2030. Originally, it was slated for full publication in early 2024, pending a stakeholder consultation. However, intense farmer protests led the French government to pause Ecophyto 2030 indefinitely. [ See AgencyIQ’s analysis of French concessions to farmer protests here.]
• The wider farmer protest movement began in spring of last year, and peaked in the opening months of the new year, spreading across the EU. Cheap imports, price pressures, extreme weather events, and growing debt are also among the grievances voiced by the bloc’s farmers. However, pesticide regulation has remained a political flashpoint in France, where EU environmental regulations may be not only upheld, but sometimes supplemented with further domestic requirements.

Ecophyto 2030

• On Monday, May 6, 2024 the French government officially unveiled Ecophyto 2030, ending the pause initially put in place to appease protesting farmers. The newest iteration of Ecophyto again seeks to cut pesticide use in half, though this time by 2030 rather than 2025. This is no easy undertaking given that France is still one of the most intensive users of pesticides on the continent.
• Much financial weight is thrown behind Ecophyto 2030. In a recent interview with Le Parisien, French minister of agriculture MARC FESNEAU said that “this is the first time that we have allocated so many resources” towards pesticide reduction. The plan earmarks 250 million euros for executing its objectives in 2024 alone. 146 million of this will be allocated to researching pesticide alternatives, while 50 million will be used to finance new agricultural equipment.
• Ecophyto 2030 names the one health concept as one of its key guiding ambitions. The One Health approach seeks to consider the interactions between the health humans, animals, and the environment. This week, five EU agencies, including ECHA and EFSA, published a joint framework for strengthening the implementation of the One Health concept. Global regulators are embracing the framework with The frequency with which this framework is appearing, at both the EU and member-state level, is only increasing with time.
• The most significant change made by Ecophyto 2030 is the metric it uses to measure pesticide reduction progress. It replaces the longstanding Number of Unit Doses (NODU) indicator with the EU’s Harmonized Risk Indicator 1 (HRI-1). The NODU indicator has been used exclusively in France; it uses pesticide sales data to generate information about the intensity of pesticide use based on the number of hectares treated with a given active substance. While green NGOs have long lauded NODU for reflecting efficiencies inherent to organic farming, it has also drawn the ire of agricultural actors, as reported earlier this year by POLITICO Pro EU. In February, Prime Minister GABRIEL ATTAL pledged to replace the NODU indicator as a means of placating protesting farmers, though did not say then what he would be replacing NODU with. [ See AgencyIQ’s full analysis of the EU’s harmonized risk indicators here.]

A closer look at HRI-1

• Now that France has committed to aligning with the EU by borrowing its indicator, it is worth investigating HRI-1. Though it also uses sales data, it is calculated using a weighted factor. This means that some pesticide transactions count more than others when determining the HRI 1 index value for any given year. The methodology behind this weighted scheme is contained in annex IV of the SUD, which categorizes active substances into four groups as follows:
• Group 1: These are active substances approved under article 22 of the Plant Protection Products Regulation (PPPR) (1107/2009/EC), which specifically applies to low-risk active substances. Products containing group 1 active substances which are placed on the European market are given a weighting of 1 for the calculation of HRI 1. This means that sales of pesticides containing low-risk active substances are not amplified any further when creating the HRI 1 index.
• Group 2: These are active substances approved under the PPPR which do not fall under any sub-categories. This is the group with the most entries. Instances of pesticides containing these active substances being placed on the market are weighted by a factor of 8.
• Group 3: These are active substances approved under article 24 of the PPPR, which is concerned with candidates for substitution. For Group 3 substances, member states must investigate to see if alternatives exist with a view to eventually phasing them out in favor of more sustainable methods. These substances are weighted by a factor of 16 for the purpose of calculating HRI 1.
• Group 4: These are simply active substances which are not approved under the PPPR. These are weighted the most, with instances of them being placed on the market multiplied by 64.

Criticism of HRI-1 has been levied by green groups, but also by the EU itself

• Critics argue that this weighting system gives the EU too much credit for banning the most toxic pesticides that might be seen as low-hanging fruit. For this reason, green groups have in fact called for HRI-1 to be replaced with the NODU indicator, with some taking to social media to air a litany of faults with HRI-1.
• Since the Monday announcement of Ecophyto 2030, Green NGOs have wasted no time in weighing in. Générations Futures has called the plan “a big lie”, dismissing HRI-1 as an artificial calculation. They claim that while HRI-1 indicated a 32% decrease in pesticide use in the ten years following 2011, the NODU indicator reflected a 3% increase.
• The EU’s statistical office, Eurostat, issued a May 2023 report announcing that “EU sales of pesticides rebounded in 2021” with a 2.7% increase from the previous year. However, a later EU report using the HRI-1 weighted approach showed that HRI-1 declined by 6% during this period. The apparent discrepancy can be attributed to the weighting scale used to obtain the HRI-1 metric of “risk to human health,” where substances deemed potentially more harmful to human health receive higher weights, as explained above. According to the report, the decline in HRI-1 resulted primarily “from reduced sales of the substances in the category ‘not approved,’” and not from an overall decrease in sales.
• However, a 2019 European Court of Auditors report summed up other criticisms member states and green groups have leveled against the scale, noting that if the scientific rationale behind the weighting scheme is flawed and needs to be changed, the scale would yield different results. In 2020, the auditors issued another report that borrowed heavily from the previous one, writing that HRI-1 did not successfully show “the extent to which [EU legislation] has been successful in achieving the EU objective of sustainable use of [pesticides]” before recommending that the Commission either “improve the harmonized risk indicators, or develop new ones.”

To contact the author of this analysis, please email Rayan Bhargava ( rbhargava@agencyiq.com).
To contact the editor of this analysis, please email Kari Oakes ( koakes@agencyiq.com).

Key Documents and Dates

• • • Planification écologique et agriculture : le Gouvernement publie la stratégie Écophyto 2030 (May 6, 2024)
    • Stratégie Écophyto 2030 (May 6, 2024)