Counterfeit and illegal pesticides are a growing problem in Europe
Counterfeit and illegal pesticides, which are untested and unregulated are a growing problem in Europe and around the world and is an emerging issue for any company with global agricultural and food supply chain. Counterfeit and illegal pesticides threaten the health of users and the environment at application, and can cause problems beyond the farmgate, such as residues in food which can present a human health risk. Businesses have a duty to ensure these types of pesticides are not used in order to protect the health of farmers, consumers and the environment. Action is required to identify whether supply chains are at risk, and introduce appropriate control measures in order to avoid costly product recalls and negative publicity.
Trade in illegal and counterfeit pesticides
Increasing quantities of illegal and counterfeit pesticides are being produced, marketed and sold around the world. Global revenues from the trade in counterfeit and illegal pesticides are estimated to be €4.4 million per annum, with with an estimated 7-10% of all pesticides traded in Europe thought to be illegal. The high profit margin, combined with the lack of harmonisation in legislation, make counterfeit and illegal pesticides a fast growing area of organised crime. Common risks associated with the use of counterfeit and illegal pesticides include:
Human health risks at application or potentially harmful residues left in food;
Environmental risks such as water pollution and impacts on biodiversity;
Security of supply if crops fail due to use of an illegal or counterfeit pesticides; and
Reputational risks from using or distributing counterfeit or illegal products.
The trade in counterfeit and illegal pesticides is estimated to represent 10% of the worldwide pesticide market. The issue can be even larger in individual countries and in China, counterfeit and illegal pesticides are estimated to comprise 30% of the pesticide market, aided by the rapid growth of chemical-manufacturing capabilities in this country. This is a problem for the European Union (EU) Member States as pesticide imports from China are growing eight times faster than average worldwide pesticide imports into the EU. North Eastern Europe is particularly affected by the counterfeit and illegal pesticide trade, and it is estimated that 25% of the pesticides in circulation in some EU member states are illegal or counterfeit.
There are three main types of illegal and counterfeit pesticides that enter the European market, these are:
- Counterfeit pesticides which are produced and packaged to look like legal products, but their contents may not match their labels. Counterfeit products can contain less active ingredient, or cheaper, possibly more toxic, active ingredients than their legal counterparts. Counterfeit pesticides can potentially be distinguished from the equivalent legal product due to differences in the smell or colour of the product.
- Counterfeit pesticide products with limited labelling or in different packaging from the original product, claiming to be the same as “product X”.
- Illegal parallel imports - The parallel import system is an approval mechanism which allows products approved in one EU country to be used in another. However, this route can be misused, with pesticides presented as legitimate parallel imports, but containing a non-identical product and can contain unknown impurities, contaminants and harmful solvents.
Counterfeit and illegal pesticides are most often produced in Asia and from there they are smuggled onto the European market. These are either bulk formulated products, ready for packing and labelling, or ready formulated, packed and labelled ready for sale, or introduced as parallel imports (imported products from another country that are identical to one authorised for use in the country of use). Once shipped to the EU, illegal pesticides are often then transported freely between Member States, with little control. There has been some work towards reducing the flow of illegal pesticides between EU Member States. In 2011, two multi-tonne shipments of illegal pesticides were intercepted in Eastern Europe containing substances banned in the EU.
Evidence suggests that there are considerable differences between EU Member States in terms of their market share of illegal pesticides. In particular, EU Member States that border third countries (such as those in Eastern Europe) are generally those which are considered to have the highest levels of illegal pesticides. In contrast, Nordic Member States (Denmark, Sweden and Finland) are generally considered to have the lowest level. The amount of illegal pesticides traded and used in EU Member States is affected by; the level of awareness of the issue of illegal pesticides within Member States, the use of sanctions against suppliers and distributors of illegal and counterfeit pesticides, and the level of control once pesticides have entered the market.
Minimising the risk of counterfeit or illegal pesticide products in your raw material supply chain
ADAS can assess the vulnerability of your supply chain to counterfeit or illegal pesticides. The approach involves mapping the supply chain, reviewing current procedures and controls (such as pesticide residue testing programmes), identifying gaps and implementing new plans for reducing the risk. This can either be focussed specifically on counterfeit and illegal pesticide use, or as part of a wider pesticide risk assessment review which includes looking at risk of exceeding Maximum Residue Limits (MRLs) and engaging with suppliers to target high risk supply chains.
As a result of taking a such an approach ADAS has worked with organisations to reduce risk of illegal and counterfeit pesticides by developing a toolkit, including a producer checklist that can provide an indicator of the robustness of the protocols in place, help prioritise high risk supply chains (e.g. geographical areas or products where use of illegal or counterfeits is thought to be high) and engage with producers to raise awareness of illegal or counterfeit pesticides. This can be a very cost-effective mechanism to control the risk as it can be integrated into existing checklists/specifications to reach the whole supply base.
The benefits of taking action to tackle the risk of counterfeit or illegal pesticides in supply chains include:
Minimises the risk of adverse effects such as yield loss, environmental damage or human health incidents occurring in your food supply chain as a result of counterfeit or illegal pesticides
Demonstrates due diligence on pesticide use in the supply chain to your customers
Identifies where to focus resources to tackle risks associated with illegal pesticides
Helps raise awareness of illegal/counterfeit pesticides amongst your suppliers which reduces the risk of these products being applied to crops.
By reducing risk of illegal/counterfeit pesticide use the risk of interruption of supply due to crop failures is reduced.
For more information on illegal/counterfeit pesticides, please contact: Rebecca.Carter@adas.co.uk
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Crop Protection Association (2014) Illegal pesticides [online]. Available at: http://www.pesticides.gov.uk/Resources/CRD/Migrated-Resources/Documents/P/PF_presentation_19_Feb_2014_Illegal_pesticides_Anne_Buckenham.pdf [accessed 14 April 2015].
ECPA (2011) The threat of illegal pesticides [online]. Available at: http://www.ecpa.eu/article/human-health/threat-illegal-pesticides [accessed 26 April 2015].
Europol (2011) OC-SCAN policy brief [online]. Available at: https://croplife.org/wp-content/uploads/2014/05/Europol-AC-Policy-Brief.pdf [accessed 11 April 2015].
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DG Sante (2015) Ad-hoc study on the trade of illegal and counterfeit pesticides in the EU: Executive summary DG SANTE Evaluation Framework Contract Lot 3 (Food Chain).