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The European Union Green Deal (EUGD) and its accompanying farm to fork (F2F) strategy have been dominating several discussions in the agricultural community since its presentation just over two years ago, mostly because its objectives, although commendable, are considered by many to be unattainable in practical terms. In addition, the knock-on effect of some of the proposed policies could have a severely negative impact on agriculture and trade in developing countries, who are most at risk when it comes to food security.

The possible impacts of the EUGD on South African agriculture have not been deliberated amongst the various stakeholders in its entirety, and the need for sufficient data in order to understand the practical implications for South Africa became apparent. For this reason, CropLife South Africa initiated a discussion between the crop protection industry, grower groups, academia and government, to try and understand what the impacts could be, and how South Africa should prepare for it. The discussion took place in the form of a conference held in Cape Town on 24 November 2022 as a hybrid event with in-person and virtual speakers and attendees.

Rod Bell, CEO of CropLife SA opened the conference by welcoming everyone and was followed by Dr. Samira Amellel (director general of CropLife Africa Middle East) who aptly set the scene for the first session. Her message was clear, African farmers are on the frontline when it comes to dealing with the impacts of, for instance, climate change and they have the right to access the innovations and technologies available to address these challenges. In addition, the plant science industry needs a supportive environment to innovate the potential solutions that modern, science-driven farming offers in the fight against climate change and food insecurity.

She echoed that the time is now for all stakeholders involved in African agriculture to take responsibility and make their voices heard, or they will feel the impact in the next few years and have to the live with the consequences for even longer. South Africa has a key role to play as an agricultural powerhouse and is an important global voice. But in order to be heard, there needs to be concrete data, she therefore urged national researchers to cooperate with industry in quantifying the impacts of the EUGD on African production, exports and food sovereignty.

Prof. Alan Matthews, Professor Emeritus of European agricultural policy at the University of Dublin Trinity College, provided an overview of the EU’s sustainability agenda, which addresses all three pillars of sustainability namely environment, economic and social, and how the F2F strategy fits into this. Using different models, he showcased a few scenarios of the possible impact of the F2F strategy on EU agricultural production if the trend of following the EAT-Lancet diet continues, as is the current preference among EU consumers. The EAT-Lancet diet is in itself not an objective of the EUGD, however, it does show where EU consumers are heading, which is lowered consumption of animal products and increased consumption of fruits, nuts and vegetables.

All the models point to lowered agricultural production in the EU, meaning a significant increase in imports of agricultural products. Using the MAGNET full scenario model, one study showed an increase of as much as 11 times the current imports of fruits, vegetables and nuts. In other words, the first-round impacts of Green Deal policies will increase market opportunities for exporters such as South Africa, because compliance with higher EU sustainability standards will lower EU production. Of course, these opportunities can only realise if South African exporters are able to meet these same standards. Unfortunately, the lowered production in the EU will contribute to higher global food prices, with potential negative impacts on food-importing developing countries. In addition, EU imports could also result in environmental degradation or pollution or exacerbate social concerns in exporting countries.

The indirect impacts of requiring imports to meet higher sustainability standards is a non-tariff measure that will raise trade costs and reduce trade, but it could potentially improve environmental outcomes. Ultimately, discussions will need to focus on ensuring food systems that meet the triple challenge of ensuring food security, providing livelihoods while protecting health and the natural resource base on which future food production depends.

Dr. Tracy Davids, director and manager of commodity markets & foresight at BFAP, reiterated that the EUGD and F2F policies will likely relate to additional import demand from the region, resulting in opportunities for South African producers if they can comply with trade regulations. On the other hand, the changes in trade policy could present risks in retaining one of SA’s most important export markets. She noted that the EU has history of stringent SPS protocols and that it's a trade-off between the cost implications of new measures and the premium in the EU market. With the exception of grapefruit, citrus exports still increased since 2014 in spite of more stringent SPS measures and adjustments. She emphasised that the EUGD regulations will impose further technical measures, and that the industry has proven resilient to such measures in the past, but it comes at a significant cost to our producers. For example, the cost of Citrus Black Spot and False Codling Moth control across the value chain was estimated at R3 Billion in 2020 alone.

If South Africa decides to look elsewhere for its exports, the challenge arises that the country lacks preferential access to strategic markets when compared to its key competitors, therefore it makes sense to protect the EU as an export market.

Dr. Wibke Meyer, director of regulatory affairs at CropLife International explained that the EU will pursue the development of green alliances on sustainable food systems and that they want to promote their F2F objectives in international standards. The problem with these objectives doesn’t lie in the what, but rather how. It is generally agreed that sustainable food systems are needed, but how to achieve this requires further discussion.

Using Maximum Residue Levels (MRLs) as an example to illustrate this point, she explained that MRLs are a trading standard used to ensure that food is safe for consumption. Further, an import tolerance is a MRL that is set based on uses registered in foreign countries in order to allow the import of treated commodities from abroad and facilitate international trade. MRLs provide an easy tool to check if the pesticide was used correctly and if the food can be placed on the market.

However, the EU now wants to take environmental aspects into account when assessing requests for import tolerances for pesticide substances no longer approved in the EU. This is moving away from internationally agreed practices as MRLs are meant to facilitate trade and protect consumer health. Environmental impacts are already considered when the product is registered, in the country that it is used in and analysed by the competent authorities that understand the local agricultural conditions. An example of this was the lowering of MRLs for 2 neonicotinoids, clothianidin and thiamethoxam, to the Limit of Quantification (LOQ) due to the concern of their impact on the global population of pollinators. This will enter into force in quarter 1 of 2023 and sets the precedent, meaning other substances will follow.

She cautioned that MRLs are not an appropriate tool to be used to tackle environmental challenges in other countries, and that that global environmental concerns are best addressed at multilateral fora because different regions have different needs.

Rod Bell concluded the first session by providing a short overview of the regulatory challenges that are specific to South Africa and that contribute to the possible negative impacts of the EUGD. He stated clearly that the need for regulation within the plant science industry is not negotiable and that the EU has every right to implement legislation that is aimed at protecting its citizens and environment. The aim of the conference is not to challenge that, but rather to make all role players aware of the implications that various parts of the EUGD may have on SA farmers and the industry.

The loss of certain products from the toolbox of plant protection solutions would have a smaller impact if the loss of solutions was mitigated by the introduction of new technologies. Unfortunately, to bring a new plant protection solution to the market in South Africa takes up to 7 years or longer as the current backlog in the office of the Registrar adds an additional three years, perhaps more.

He explained that South Africa has unique crop-pest combinations that require molecules not necessary in other parts of the world, and that the country also needs to be attractive for product developers to bring new tools to the market.

He emphasised that industry is not just sitting in the corner complaining and explained how, through cooperation, sustainable improvements to the local regulatory processes are being identified to ensure a process that is transparent, timeous in its operation and predictable in its timeframe for delivering its mandated outcomes. This shows that both industry and government recognise the need for an improved regulatory process and that all parties are committed to working together to find a sustainable solution to the current hurdles.

The second session of the day entitled Other regulatory challenges that could impact South African agriculture commenced with Dr. Sarah le Grange, chairperson of the working group on substances of concern, providing an overview of the current situation with regards to the phasing out of hazardous chemical agents in South Africa. The reason for establishing the working group was because, ideally when substances are being phased out, the authorities provide clarity about which substances are being phased out and what the process is. But since receiving notification from the Registrar on 14 April 2022 of his intention to phase out active ingredients and their formulations that meet the criteria of 1A and 1B of the GHS by June 2024, this has not happened yet.

She provided a brief definition of how these chemicals came to be classified as such, namely that in 1992 the UN leadership development started the Globally Harmonized System of Classification and Labelling (GHS) which is implemented worldwide today. The aim of the GHS is to establish a single, worldwide system to classify and communicate hazardous properties of chemicals. These classifications are based on physical, health and environmental hazards of the chemical.

The working group was tasked to identify substances currently registered in South Africa that are likely to meet the criteria of CMR category 1A - known human carcinogen, mutagen or reproductive toxicant, largely based on human evidence – or category 1B - presumed human carcinogen, mutagen or reproductive toxicant, largely based on animal studies. The working group also set out to identify specific crop-pest combinations that will suffer a major impact by the loss of these agricultural remedies and assess the availability of suitable alternatives, or propose mitigating measures where alternatives are currently not available. The current aim is to have a final list by January 2023, subject to change, and to propose a realistic period for the phase out of CMR 1A and 1B co-formulants, as well as a reasonable registration period for new or changed formulations.

Prof. Andre Jooste from the department of agricultural economics at the University of Stellenbosch illustrated the significant difference between the support that EU farmers receive from government in terms of producer and general services support, versus what South African farmers receive, noting that the EU has 51 times more money per hectare to achieve their policy objectives.

He highlighted the time required and development costs to bring a new crop protection product to the market, emphasising that non-optimal regulatory systems will jeopardise investment in new industries and products, ultimately stifling innovation. Another risk is that, because of the high costs involved, the research and development will likely focus on major crops and smaller crops such as berries, nuts and vegetables could be neglected, with no new products being developed and the current available products no longer being suitable for use in export markets. Furthermore, should export farmers lose their competitiveness and the markets for export fruits dry up, farm employment will be negatively impacted. If new technologies do not reach the South African market, food security for the nation could be at serious risk as new pest outbreaks may need new plant protection solutions that might not be available.

In addition, policy harmonisation, both locally and internationally, and public private partnerships will need to remain firmly on the agenda if these risks are to be mitigated. However, the necessary investment and financial support to drive policy processes and implementation, must be realised.

Sbu Khumalo, deputy director of technical infrastructure at the Department of Trade, Industry and Competition, provided delegates with an overview of how South Africa approached the issue of setting MRLs and subsequent import tolerances based on environmental factors referenced in the previous presentations. He reported that South Africa had a two-pronged approach in submitting its written comments timeously while attempting to secure bilateral meetings with the EU to discuss the matter. In addition, South Africa attended the WTO committee on technical barriers to trade on 14 to 18 November where the countries resolved to table the measure to lower these MRLs by the EU to the WTO as a specific trade concern.

He noted that SA shares the EU’s goals for food systems transformation and a commitment to address climate change and biodiversity loss, however, South Africa recognises that countries have different sustainability objectives and challenges. The proposed measure to lower the MRLs for these two substances will have an adverse effect on SA agriculture and agrifood exports to the EU. Ultimately the proposed measure may restrict the trade of safe agricultural products, disrupt production and negatively affect the livelihoods of small and rural farmers.

South Africa supports transparency, science- and risk-based decision making driven by available data to enhance sustainability in agriculture and urges the EU to take cognisance of different climates, pest-crop matrices and socio-economic conditions of developing and developed countries. He confirmed that the discussion on the matter at government level is underway and he will take what has been presented by the speakers today and present evidence to the EU using the clauses and processes discussed.

Dr. Alan Hardacre, a consultant to CropLife Africa Middle East, provided some insights into the opportunities for advocacy in the region explaining that Africa has its own green transition initiatives and that it represents both a risk and an opportunity. He emphasised that this needs to be driven by African countries according to African needs. With regards to activism, the EUGD ship hasn’t sailed entirely and although the principles cannot necessarily be altered, the details of how and when it will be implemented can still be shaped. The US and Brazil are good at informing the EU of which policies they do not like and why they do not like it, and these countries could be approached for coalitions. However, if South Africa is to make its own voice heard, it will need facts and hard evidence of what EU policies will mean for South Africa, and this must be linked to food security.

In order to do this, there needs to be a focus on mobilisation within each country to get every national government active in, for instance, the WTO, African Union and African Regional Integration bodies. This advocacy approach needs to start urgently to feed into the live EU discussions, and South Africa has a key role to play, as it can lead other African countries in amplifying its impact.

During the panel discussion facilitated by CropLife SA’s stewardship and operations manager, Dr. Gerhard Verdoorn, it was mentioned that one of the biggest barriers to success for South Africa is that it constantly finds itself in a balancing act of debilitating phytosanitary regulations on the one hand, and regulations such as the EUGD’s limiting of pesticides on the other. Dr. Hardacre explained that the best way to approach this was to establish and define the priority areas and look for commonality across the continent so that these can be addressed first. Collaboration with other countries is key, but there has to be a basis of research and facts to build on first. As a closing remark, Dr. Verdoorn noted that South African farmers are not used to being subsidised, meaning they are innovative. South Africa needs to use this innovative mindset to find solutions to overcome the inevitable challenges that the EUGD will bring.

The third and final session of the day was initiated by Kobus Hartman from Agri Business Systems International, who provided some practical examples of what would happen if certain crop protection products could no longer be used. First, he gave an overview of the aims of integrated pest management (IPM) and cautioned that we are running out of suitable active ingredients faster than they are being replaced, which is going to become a major challenge in the prevention of resistance development.

For instance, Dimethomorph, a GHS category 1B product, is used in late season control of downy mildew on table grapes. It is used in mixtures to support the efficacy of other active ingredients in a number of high-ranking control agents such as folpet and mancozeb, and mixing these actives improves efficacy and delays resistance due to the different modes of action. If it were to be removed from the market, one of the only suitable alternatives would be copper salts, which carries a high phytotoxicity risk.

As a result of the EUGD and its proposed mirror clauses and subsequent loss of products, we can expect crop losses due to the limited ability to use effective compounds. We will have limited ability to control quarantine pests and diseases to a level of zero tolerance, as well as not being able to meet IPM requirements. And of course, there will be an increase in waste generation if export produce cannot meet the residue or cosmetic standards due to pest and disease damage. Other results could include monopolies in agricultural remedy marketing, higher cost of crop protection and production as well as a real threat to food security.

He reiterated that in order to offset some of these risks, we need effective and enabling regulatory processes that are agile and supportive, as well as sound research that can supply reliable and workable information to solve the issues of crop protection within the borders of IPM.

Paul Hardman, industry affairs manager at the Citrus Growers Association concluded the formal presentations of the day and gave some insights into the differences between the challenges and operations of European versus South African producers. He showed that the EU’s current Common Agricultural Policy (CAP), which runs until 2027, is worth approximately R6.4 trillion, which gets paid to European farmers. He reiterated that EU standards are not necessarily better and sometimes not relevant nor applicable on regional level and that European growers themselves are struggling to reach the set targets, which is why they require such large subsidies.

He stated that if the objectives of the EUGD are noble and the science solid, then the EUGD isn’t a problem. Unfortunately, however, the EUGD and F2F strategy is very much influenced by politics. Over the last decade there has been a fundamental shift in how processes like setting MRLs and pesticide authorisation, are followed. It now takes a political step, and has to go to parliament to be ratified, meaning decisions are not just science-based, but also influenced by politicians. He mentioned that some of the real challenges include that policy implementation is highly uncertain, especially as it extends to third countries, and that there are few opportunities to properly engage in the decision-making process with the European Union.

The day concluded with a panel discussion consisting of Dr. Elmé Coetzer Boersma from Global.G.A.P, Lindi Benic from Hortgro and Dr. Schalk Visser from SAMAC joining the third session speakers to discuss what the EUGD means on a practical level. One of the first issues that was highlighted when asked if the farmers are aware of the EUGD and its implications, is that there is still a lot of grey areas and uncertainty about what the actual EUGD will demand, and this makes the messaging to farmers very difficult. It also seems like the EUGD objectives are sometimes contradicting what is actually happening on ground-level, such as the push for organic farming, which in reality seems to be decreasing.

Another question that was posed is if the EU cares about the realities of farmers on the ground. The panel explained that South African growers have been navigating loss of products for a long time, and they are implementing IPM practices, but some of the new policies are going to make farming unsustainable. At the end of the day, the grower is the one who is absorbing the costs, and is already overburdened with regulations, which is a threat to farming as a career path.

Looking at the policies, reducing MRLs is not the only problem, the phasing out or banning of certain substances due to mirror clauses even if there is a way to meet the MRL requirements is also a concern. This loss of available products exacerbates the risk of farmers trying to find their own solutions or for opportunists to market their products as “safe” alternatives without the scientific backing and efficacy data.

Rod Bell summarised the day and concluded with a strong call to action in that we need collaboration across stakeholders and regions to ensure that the voice of South African agriculture is heard in the European Union.

The conference sessions can be viewed on our YouTube channel – CropLife South Africa or on the links below:

• CropLife Impact of the EU Green Deal on SA Agriculture - Full Session 1
  • Dr. Samira Amellal – Welcome
  • Prof. Alan Matthews - The European Green Deal in agriculture: Challenges and opportunities for South Africa
  • Dr Tracy Davids - The EU Green Deal: How will it impact South African agricultural exports?
  • Dr. Wibke Meyer - Future outlook for MRLs and the impact of EU policy on MRLs in South Africa
  • Rod Bell: Regulatory challenges and the Green Deal – Overview

• CropLife Impact of the EU Green Deal on SA Agriculture - Full Session 2
  • Dr. Sarah le Grange - Phasing out of hazardous chemical agents
  • Prof. André Jooste - Impact of the regulatory environment on getting new plant science technologies to South Africa
  • Sbu Khumalo - Progress report on South Africa and EU bilateral engagements regarding the revisions of the MRLs
  • Dr. Alan Hardacre - Advocacy: What more can we do?
  • Panel discussion

• CropLife Impact of the EU Green Deal on SA Agriculture - Full Session 3
  • Kobus Hartman - Practical examples: If products are removed from the market without acceptable replacements
  • Paul Hardman - EU Green Deal, its so-called ’mirror clauses’, and potential negative impact on SA growers
  • Panel discussion
  • Rod Bell: Summary and conclusion