TOXIC TRADE - Sustain
TOXIC TRADEHow trade deals threaten toweaken UK pesticide standardsA report by PAN UK, Sustain and Dr Emily LydgateJune 2020
KEY ACRONYMSCACodex AlimentariusCACCodex Alimentarius CommissionCETAEU-Canada Comprehensive Economic and Trade AgreementCPTPPComprehensive and Progressive Agreement for roethaneEDCEndocrine disrupting chemicalEPAUnited States Environmental Protection AgencyEUJapan EPA - EU-Japan Economic Partnership AgreementFAOFood and Agriculture Organization of the United NationsFTAFree Trade AgreementFWSUS Fish and Wildlife ServiceGMOGenetically Modified OrganismHHPHighly Hazardous PesticidesMRLMaximum Residue LevelOPOrganophosphatesPPEPersonal Protective EquipmentSPSSanitary and PhytosanitaryTTIPTransatlantic Trade and Investment PartnershipUSMCAUnited States-Mexico-Canada AgreementUSTRUS Trade RepresentativeWHOWorld Health Organization of the United NationsWTOWorld Trade OrganizationTOXIC TRADEHow trade deals threaten to weaken UK pesticide standardsA report by PAN UK, Sustain and Dr Emily Lydgate2
TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsCONTENTS5Executive summary and key recommendations11Introduction – setting the scene15151520Key findings – the dataPesticides and food- Key finding 1: Amount of pesticides in food imported into UK could increase- Key finding 2: Type of pesticides in food imported into UK could become more toxic22 Pesticides approvals22 - Key finding 3: More toxic pesticides could be approved for use in UK22 Active substances of particular concern23 i ) Toxic to bees and pollinators23 ii ) Water contaminants24 iii ) Hazardous to human health2727303030Existing Free Trade Agreements and current negotiating objectives – what they tell usabout the risks posed to UK pesticides standardsUK-USUK-EUUK-AustraliaUK-India31Trade agreements offer limited options for safeguarding UK pesticides standards32The role of the World Trade Organization in maintaining UK pesticide standards33The politics of UK Free Trade Agreements35363839Country profiles – different approaches to regulating pesticides and how they comparewith the UKUSAustraliaIndia41Full recommendations to the UK Government42Annex: Upholding UK pesticides regulation through FTAs – language for UK negotiators43References3
TOXIC TRADE: How trade deals threaten to weaken UK pesticide standards4
TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsEXECUTIVE SUMMARY *While far from perfect, UK pesticide standardsare some of the strongest in the world in terms ofprotecting human health and the environment. UKsafety limits for the levels of pesticides allowed toappear in food tend to be more stringent than inthe majority of other countries outside the EU and,along with its European counterparts, the UK ismore likely to ban a pesticide due to concerns overthe harms it causes.allows almost double. The insecticide dimethoate isjust one example. This Highly Hazardous Pesticideis banned in the UK due to potential human healthrisks, but allowed to appear in food produced inthe US and Australia. Meanwhile, unlike the UK,the US and India continue to allow food to containresidues of the insecticide chlorpyrifos which hasbeen shown to negatively affect the cognitivedevelopment of foetuses and young children.As a result of these relatively high standards, futuretrade deals with non-EU countries with weakerpesticide protections present a considerable riskto the health of UK citizens and the environment.Trade partners attempting to secure access to theUK market for their food exports have listed UKpesticide standards as a key sticking point andmade it clear that weakening them is a priority.Any weakening of UK pesticide standards via tradedeals poses risks not just to human health butalso to the environment. Trade partners such asthe US and India have a history of challenging theEU’s relatively precautionary approach to whichpesticides are allowed for use, and the UK is alreadycoming under similar pressure. Australia, the USand India all allow the use of pesticides whichthe UK prohibits because they are highly toxic tobees and pollinators, including neonicotinoidswhich are notorious for driving massive declinesin bee populations. They also authorise pesticidesknown to contaminate groundwater and harmaquatic ecosystems, such as the herbicides atrazineand diuron. If the UK Government is to achieveits ambition to “leave the natural environmentin a better state than we found it” then it mustresist efforts by trade partners to push the UK toauthorise, or reverse bans on, pesticides whichharm wildlife and contaminate water and soil.What are the risks for UK health,environment and agriculture?If UK trade negotiators bow to their demandsthen the increased risk to human health couldbe significant. American grapes, for example, areallowed to contain 1,000 times the amount of theinsecticide propargite than their UK equivalents.Propargite has been linked to cancer and classifiedas a ‘developmental or reproductive toxin’, meaningthat it can negatively affect sexual function andfertility and can cause miscarriages. An Australianapple can contain 30 times the amount ofbuprofezin – an insect growth regulator classified asa possible human carcinogen – than a UK apple.As well as finding themselves exposed to higherlevels of pesticides in their diets, UK citizenscould soon have no choice but to consume foodcontaining pesticides that are currently bannedfrom appearing in UK food. The US allows the use ofalmost 1.5 times the number of ‘Highly HazardousPesticides’ (HHPs) - a concept which originatesfrom the United Nations - as the UK, while AustraliaThese risks also pose an economic threat to thefuture of UK agriculture. If UK food starts tocontain higher levels of more toxic pesticides thenBritish farmers will struggle to meet EU standards,thereby losing their primary export destinationwhich currently accounts for 60% of UK agriculturalexports. Equally concerning, British farmers couldbe undercut by a flood of imported crops grownmore cheaply on a larger scale and to lowerstandards. It’s crucial that the Government protectsBritish farming by defending pesticide standards,particularly in trade negotiations with agriculturalpowerhouses such as the US and Australia.* References all provided in body of report5
TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsWhat do UK citizens want?New YouGov polling published alongside thisreport reveals that the UK public is overwhelminglyopposed to any lowering of UK pesticide standardsto meet the demands of other countries’ tradenegotiators. 71% of respondents are ‘concerned’that a trade deal with the US in particular willincrease the amount of pesticides in the food theyconsume, with 43% of people ‘very concerned’. Thesame figure (71%) agree that the UK Governmentmust resist pressure in trade negotiations withthe US to overturn bans on pesticides, even if thismeans the “best” trade deal cannot be reached.Meanwhile, 79% are concerned about impacts tohealth resulting from a lowering of UK pesticidestandards with 77% worried about negative impactson the environment.1What do the negotiating objectives oftrade partners tell us?The key findings of this report present an alarmingpicture and a closer look at the negotiatingobjectives of the UK and its future trade partnersprovides little reassurance. The US’ objectives inparticular reveal a wide range of different tactics,all aimed at weakening UK pesticide standards tofacilitate US food exports. These include effortsto persuade the UK to adopt weaker standardsand abandon the Precautionary Principle – whichstates that action should be taken to prevent harmsto health or environment as long as there arereasonable grounds for concern – as the basis fordecision-making on pesticides.In what would arguably undermine the UK’s aimto take back control of its trade policy followingEU exit, US trade negotiators are also pushing forconditions which require the UK to consult withthe US Government and private sector (includingthe powerful US agrochemical industry) beforeintroducing any new regulations or bans, includingThe Precautionary Principle vs. the ‘science-based’ approachThe Precautionary Principle, which emerged in the 1970s, theoretically underpins all current UKdecison-making on pesticides. It allows regulators to adopt precautionary measures when scientificevidence about an environmental or human health hazard is uncertain and the stakes are high. Forexample, when evidence began to emerge that neonicotinoids were driving alarming declines in beepopulations the UK Government was able to support a ban on their use on the basis that here wassufficient cause for concern. They did not have to wait for the evidence to be definitive, an oftenunattainable goal.In contrast, many of the UK’s potential trade partners follow what is misleadingly termed ‘thescience-based approach’. Under this approach, instead of a pesticide manufacturer having todemonstrate that their product is safe, regulators must offer a very high level of scientific proof thata product is dangerous. However, evidence of harms may not emerge for many years and, in themeantime, some of the negative impacts caused – such as the development of malignant tumours orthe extinction of particular species – may be irreversible.The US Government in particular uses the term ‘science-based’ as a veiled and publicly palatableway through which to attack the Precautionary Principle. It’s vital that UK negotiators understandthe true meaning of ‘science-based ‘and are prepared to defend the vital role that the PrecautionaryPrinciple plays in protecting human health and environment from pesticides.6
TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsthose designed to better protect health orenvironment. Another of the US’ stated objectives, ifaccepted, would prevent the UK from requiring othertrade partners to raise their own pesticide standardsin case this has a knock-on effect on US exports.While the US is clear about what it hopes toachieve in a trade agreement, looking to the UKGovernment’s negotiating objectives reveals a moreconfusing picture. The UK objectives for a deal withthe US include vague, but welcome, statementscommitting to maintain “ our high environmentalprotection, animal welfare and food standards”.However, the objectives for the future relationshipwith the EU strike a very different tone and includesome major red flags, suggesting that the UKGovernment is planning to diverge considerably fromits current precautionary approach. Meanwhile,the EU has been clear from the beginning that itwill not allow imports of agricultural produce fromthe UK unless they meet its standards, includingon pesticides. At some point, the UK Governmentis going to have to make a fundamental choice –does it want to maintain current levels of pesticideprotections or bow to the US Government in tradenegotiations? If the UK chooses the latter thenconceding to similar demands in negotiations withother trade partners will be more likely, because theUK will have already set a precedent by wateringdown its domestic standards.In terms of other trade partners, the UK-IndiaJoint Working Group on Trade is yet to publishnegotiating objectives and a deal appears toremain some way off. Similarly, despite talk of aUK-Australia deal being imminent, neither sidehas published detailed negotiating objectives. Thevery limited information that is currently availablefrom the Australian Government talks about “ removing barriers to trade in goods” which canbe jargon for lowering standards, but it providesno further detail and makes no mention ofconsumer protection or environmental or humanhealth standards. However, Australia is Party tothe Comprehensive and Progressive Trans-PacificPartnership which follows the US’ approach toregulating pesticides, so could try to replicate thisin a UK deal.Hazard-based vs. risk- based approachesThe UK – along with the EU – currently follows what is commonly called the ‘hazard-based’approach to pesticide regulation (but is more accurately termed as a Generic Risk-Basedapproach). This means that if an active substance is judged to be intrinsically dangerous – forinstance by being able to cause cancer or persistent pollution – then it is too hazardous to beused safely and should be banned. This approach is highly effective at reducing pesticide-relatedharms and is relatively simple to operate, but can be criticised for reducing the range of pesticidesavailable to farmers.Other countries, like the US and Australia, follow the so-called ‘risk-based’ approach (or SpecificRisk-Based approach). This model places greater emphasis on assessing and managing risksand involves the deployment of specific checks and measures to keep risks below acceptablelevels. For example, if a pesticide is particularly harmful to human health, under a hazard-basedapproach it might be banned while a risk-based approach would introduce measures such asPersonal Protective Equipment (PPE) for users or instructions not to spray near residential areas.Ensuring a high level of protection under a risk-based approach requires the implementationand enforcement of multiple processes and systems to ensure that the controls are adopted andworking. This adds complexity and cost and if any of these systems break down, the potentialimpacts on human health and the environment are high.7
TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsHow does the current UK approach topesticides differ from that of futuretrade partners?There are a range of differences between theway the UK has chosen to govern pesticides andthat of future trade partners. Arguably the mostfundamental is that the UK currently takes anapproach based on the view that some pesticidesare intrinsically hazardous and therefore simply toodangerous to be in use. In contrast, non-EU countriesfollow an approach based on the belief that almostevery risk can be mitigated. There are manyexamples of countries attempting to use the guiseof ‘regulatory cooperation’ in trade negotiationsto attack what is commonly known as the EU’s‘hazard-based approach’. Whether the UK will beable to continue to withstand these attacks as it didpreviously as an EU member remains to be seen.The divergence in the approaches of differenttrade partners also relate to numerous proceduralaspects of the pesticide regime. For example, theUS allows ‘conditional registration’ which meansthat pesticides which haven’t been through afull risk assessment are allowed to be used. Atone point in 2012, more than 65% of pesticidesauthorised for use were conditionally registered.Meanwhile, Australia and India have no settime period for reviewing pesticide approvals,meaning that harmful pesticides can remain in useindefinitely once authorised. In contrast, underthe current UK system, pesticides are granteda maximum license of 15 years before havingto go through a risk assessment process to bereapproved. It is crucial that UK trade negotiators8understand these differences so they are able todefend aspects of the UK pesticide regime designedto protect human health and environment.How vulnerable is the UK to thedemands of trade partners?There has been much public uproar about the UKlowering its food standards via a trade deal with theUS to accept ‘chlorinated-chicken’. However, therisks related to pesticides are equally significant andconcerning. We know that weakening UK pesticidestandards is a key priority for many potentialtrade partners and the UK may be particularlyvulnerable due to political pressure to concludetrade agreements in order to recoup lost EU marketaccess. In addition, the process of bringing EUpesticide regulations over into UK law has handedUK Ministers significant discretionary powers towater down standards in order to meet tradepartners’ demands. Meanwhile, there is currentlyalmost no opportunity for parliamentary or publicscrutiny of trade agreements, making it much morelikely that countries with lower pesticide standardswill be able to force down UK pesticide protections.The UK Government’s 25 Year Environment Plan statesthat “We must protect people and the environmentfrom the risks that pesticides can pose”. There is nodoubt that, at this present time, trade deals pose thegreatest threat to UK pesticide standards. It’s crucialthat the UK Government remains strong in the faceof pressure from trade partners and chooses to standup for British consumers, farmers and wildlife byprotecting our hard-won pesticide protections.
TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsKey recommendations for the UK Government *66 Do not allow any weakening of UK pesticide standards via postBrexit trade agreements. This must include:»» Ensuring that no currently banned pesticides are allowed foruse in the UK»» Ensure that food containing detectable residues of currentlybanned substances cannot be imported into the UK»» Ensure that Maximum Residue Levels are maintained or reduced.66 Ensure a level-playing field for UK farmers by maintaining existingUK pesticide standards, thereby enabling them to continueexporting to the EU.66 Prevent UK farmers from being disadvantaged by cheap food importsproduced to weaker pesticide standards in non-EU countries.66 Maintain the Precautionary Principle as the basis upon whichall pesticide-related decisions are made and strengthen itsimplementation. This includes maintaining the so called ‘hazardbased’ approach to pesticide authorisations.66 Preserve the power for the UK to exercise its right to go above andbeyond the status quo and applicable international standards tocontinually strive for higher levels of consumer and environmentalprotection.66 Introduce additional legislative protections to ensure that any changeto food safety standards or environmental protections subsumed intrade agreements can only be introduced via primary legislation.66 Ensure that trade agreements are developed in the open with theopportunity for full democratic scrutiny.Please note: specific language for use in developing FTAs so thatpesticide standards are maintained is listed in the Annex on page 42.* See page 41 for full recommendations9
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TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsINTRODUCTION –SETTING THE SCENEEU exit will see the UK negotiate its own FreeTrade Agreements (FTAs) for the first time in fourdecades. The broad aim of these agreements willbe to enable as frictionless trade as possible andthey will inevitably involve elements of regulatorycooperation, whereby joint standards are agreedbetween trading partners which will then applyto all goods traded between them. Agriculturalproducts tend to be a key focus in FTAs andtherefore aligning differences in food standards,including on pesticides, will be an important topicin most, if not all, UK trade negotiations.These negotiations are taking place against abackdrop of rising global concern over pesticides.Recent reports have revealed that one millionspecies are at risk of extinction2 and a third ofinsects are now endangered3, with pesticidesidentified as one of the key drivers. Meanwhile,the body of evidence linking pesticides toserious diseases such as cancer and Parkinson’sis increasing. Public opposition to pesticides isgrowing and UK consumers, in particular, areincreasingly worried about pesticide residues intheir food.4While still suffering from many deficiencies, theEU has the strongest pesticide regime in the worldin terms of protecting human health and theenvironment. As a Member State, the UK playeda role in formulating these standards and hasbenefitted from the relatively high protections theyprovide. As a result, future UK trade agreementscould potentially pose major threats to UK pesticidestandards since all of the non-EU countriesprioritised for post-Brexit trade have significantlyweaker pesticide standards than the UK currentlyenjoys. Crucially, this applies both to whichparticular pesticides are authorised for use andwhat amount of a chemical is permissible to appearin food as a residue.However, beyond these more tangible aspects,there is also massive divergence in the coreapproaches taken to regulating pesticides. TheEU follows what is known as the ‘hazard-based’approach which asserts that some pesticides aresimply too dangerous to be in use and shouldtherefore be banned. It also, in principle at least,bases decisions on the Precautionary Principlewhich states that “When an activity raises threatsof harm to human health or the environment,precautionary measures should be taken even ifsome cause-and-effect relationships are not fullyestablished scientifically.”5 In contrast, the majorityof non-EU countries follow an approach based onthe belief that most risks can be mitigated (seepage 7 for more detail on hazard vs. risk).There are many examples of countries attemptingto use the guise of ‘regulatory cooperation’ intrade negotiations to attack the PrecautionaryPrinciple and fundamentally alter the way the EUgoverns pesticides. One of the key tactics used byboth governments and pro-pesticide lobby groupsis to classify higher standards as ‘non-tariff tradebarriers’ or ‘trade irritants’, and to try to eliminatethem by proposing aligning standards down tothose least protective of human health and theenvironment.The UK will almost certainly come under thispressure. In fact, we know that lowering UKpesticide standards is a key priority of some futuretrading partners, notably the US. Documents fromthe UK-US Trade and Investment Working Group(a precursor to official negotiations) leaked inNovember 2019 show the US complaining aboutthe EU approach to pesticide regulation andpushing for the UK to abandon it.6 In addition tocoming under fire from other governments, theUK is also facing pressure from the agrochemicalindustry and powerful, pro-free trade organisationspushing a deregulation agenda. Domestically, whilethe National Farmers’ Union (NFU) is vehementthat trade deals shouldn’t undermine the majorityof UK farming standards, they continue to pushfor a weakening of pesticide regulations7, despitethe potential impact on British farmers who wouldstruggle to export their produce to EU MemberStates (which currently account for 60% of the UKagriculture export market8). Moving away fromalignment with the EU could have a profoundlynegative effect on UK farmers who may have to find11
TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsnew export destinations for their produce whilefacing additional competition from imported cropsgrown to lower standards.Other potential impacts of a drop in UK pesticidestandards include:66 A weakening of laws on the use of carcinogensand other substances of high toxicologicalconcern; allowing the import of food withhigher residue levels;66 Reducing requirements for authorising activesubstances;66 Slowing or stopping efforts to regulateendocrine (hormone) disrupting chemicals;66 Blocking access to information that is vital todeveloping non-toxic alternatives to pesticides.9Wider related policies not covered in this report –such as agri-environment schemes which supportfarmers to reduce pesticide – may also come underthreat. They could be targeted directly based onarguments that they distort trade. They couldalso be undermined indirectly as their higherstandards of production render UK farmers unableto compete with cheap food imports producedin countries where farmers are able to use moreharmful pesticides.These threats are all the more concerning giventhat the rules governing trade in the UK offerno meaningful role for parliamentarians oropportunities for public scrutiny. Currently, no oneoutside the UK Government can even access thetext of an FTA until it is being ratified, let aloneamend it. The current lack of transparency makesit much more likely that countries with lowerpesticide standards will be able to force downUK pesticide protections. In addition, there is aquestion around whether the UK Government,which hasn’t negotiated an FTA since the 1970s,has the capacity or expertise to withstand attemptsto lower pesticide standards, especially giventhe political pressure to conclude agreementsquickly. In March 2020, it was reported that theUK Department for International Trade neededto fill job vacancies for 135 trade experts.10 Withthe perfect storm of inexperienced UK tradenegotiators, staff shortages, more powerful andwell-resourced negotiating partners and a shroudof secrecy enclosing the entire process, trade dealsare arguably the most likely route through whichthe UK’s pesticide standards will be undermined.There has been much public uproar about‘chlorinated-chicken’ and ‘hormone-fed beef’coming into the UK as a result of a tradeagreements with the US and, in response, we havehad verbal commitments from the UK Governmentthat food standards won’t be dropped (althoughsuch promises are in no way sufficient to stop UKmeat and animal welfare standards being put onthe table during trade negotiations). However,we have had no such government statements onpesticides, despite the risks being equally significantand concerning. If the UK Government is seriousabout its promise not to lower food standardsas part of future trading agreements, then itmust commit to maintaining current UK pesticidestandards as well as the ability to strengthen futurestandards as needed. Otherwise, UK citizens andwildlife will be exposed to more harmful chemicalsin higher levels and ultimately it is our health andenvironment that will pay the price.71% of people are concerned that a tradedeal with the USA will increase the amount ofpesticides in the food they consume.43% of people are very concerned.YouGov polling, 30th April - 1st May 202012
TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsThis report focuses on how future FTAs threaten to weaken UK pesticidestandards and ways in which this could increase pesticide-relatedharms to UK citizens, wildlife and the natural environment. It comparescurrent UK pesticide protections with that of two countries slatedas major priorities for post-Brexit Free Trade Agreements – US andAustralia – and a third country, India. In addition to being targets of theUK Government for immediate or future trade deals, these countrieshave been chosen because they are major agricultural producers andtheir significant lobbying strength increases the likelihood that they willbe able to force down UK pesticide standards during trade negotiations.The report explores issues around pesticides contained in foodimported into the UK and compares the amounts of residuespermissible under the UK’s current system with that of other countries.It then compares the number and type of active substances approvedfor use in the UK with the three focus countries listed above, with anemphasis on pesticides which are particularly hazardous to humanhealth and the environment. After presenting its key findings, thereport delves into existing FTAs and the stated negotiating objectives ofthe UK and its potential trading partners in order to identify where thegreatest risks to UK pesticide standards lie. Finally, it compares the UK’scurrent approach to regulating pesticides to those of the three focuscountries and, where information is available, provides a brief overviewof the extent of pesticide-related harms to both their citizens’ healthand the environment.13
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TOXIC TRADE: How trade deals threaten to weaken UK pesticide standardsKEY FINDINGS – THE DATAPesticides and foodArguably the most concerning aspect of anyweakening of pesticides standards via trade deals isthe impact on imported food. Food on UK shelvesmay soon be allowed to contain larger amountsof approved pesticides, as well as residues ofpesticides currently banned in the UK.Key finding 1: Amount of pesticides in foodimported into UK could increaseFor approved pesticides, the EU (like almost allother countries) sets what’s known as MaximumResidue Levels (MRLs) crop-by-crop. The followingsection provides a comparison of MRLs set by thethree focus countries’ for specific pesticides thatpose a high risk to human health, operator healthor the environment (and are therefore designatedas ‘Highly Hazardous Pesticides’)11. By comparingMRLs we are able to see where potential threats toconsumer protection and human health are likelyto emerge in the UK. The food items have beenselected because they are either already key UKimports or there is a likelihood that imports couldincrease under future trade deals.It should be noted that there are some cases whereEU MRLs are higher than those of other countriesor international standards. However, in general, theEU does take a more precautionary approach andthe MRLs it sets therefore tend to be lower thanelsewhere in the world.The MRL figures have been taken from the followingofficial government databases for the EU plus thethree focus countries; EU Pesticides Database12,USDA MRL Database,13 India Environment Portal14and the Australian Federal Register of LegislationMRL list15. Since the UK is likely to be pressuredin trade negotiations to revert to minimuminternational standards for MRLs (which come fromthe Codex Alimentarius16, a set of food standardsunder the UN’s Food and Agriculture Organizationand World Health Organization), these figures havealso been included. (See page 19 for more detail onthe Codex Alimentarius)Health issues related to pesticides – an explainerThe report lists the health issues associated to specific pesticide active substances. It is importantto note that if a substance is classified as a ‘Known Carcinogen’ (for example) it does not mean th
3 TOIC TRADE: How trade deals threaten to weaken UK pesticide standards 5 Executive summary and key recommendations 11 Introduction - setting the scene 15 Key findings - the data 15 Pesticides and food 15 - Key finding 1: Amount of pesticides in food imported into UK could increase 20 - Key finding 2: Type of pesticides in food imported into UK could become more toxic
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