Scope affected by the regulation and compensated should

Scope of the problemThe prospect of exit from the European Union (EU) faces the UK with additional challengesand uncertainties. To prominent into the sector of agricultural, it could be threat butsimultaneously opportunity for the country.It is believed by Ian Wright, Director General of the Food and Drink Federation (FDF), ‘thethree key parts of the Brexit decision that are most challenging are the labour market, theregulatory framework and the future of tariffs and trade’ (Authority of the House of Lord,2017).The aim of this policy briefing is to analysis the policy alternatives of the post-Brexitlegislation adjustment to the EU regulation (EC) No 1107/2009 of placing protectionproduction (PPPs) on the market in the European Union – to retain, modify or abolish.Context of the problemThe EU pesticide regulation (EC) No 1107/2009 is a legislation set out requirement,procedure and timeframe for the authorisation of Plant Protection Products (as referred to’pesticides’), it aims to approve the active substances inside the pesticides by the EuropeanCommission through implement acts and follow the risk assessment by the European FoodSafety Authority (European Commission, 2017).As the authorisation is operated by a zonal system, it divided the EU into three zones: North,Central and South. There are different types of applications depends on the uses of the PPPs,and under the EU rule, it could takes up to 1.5 years for an application to receive a result ofeither grant, amendment or withdrawal. Fees is charged for the application and it is varybetween the member states. In 2012, the EU pesticides data has contained 411 approvedactive substances and 780 non-approved substances ().To focus on the regulation’s distributional implications, NGOs such as Green Peace and foodretailers advocate to the regulation in responses to the public concern, both of them would3 (1522436)like the EU to further maximise the residue level and stricter the regulation. On the otherhand, famers and pesticide industries opponent to the legislation. As farmers claimed thattheir competitiveness would be affected by the regulation and compensated should be given ifpesticides uses is restricted in a certain areas whilst the further reduction of the number ofapproval pesticides might causes unemployment in the EU countries as the EU cropprotection industry employs more than 26,000 workers.The degree of the regulation’s stringent is based on the organisation’s perception, while theEU stated they has one of the most strictest pesticides control system in the world, Delreuxand Happaerls (2016) claimed the regulation would be difficult to enforce and have thehighest level of implementation deficit.Policy alternatives – Retaining /Modifying/ AbolishingRetaining1. For the UK trade and competitiveness – to maintain the trading relationship betweenthe UK and the EU after BrexitAs it stated by the UK Authority of the House of Lord’s report (2017), ‘once outside theEU, the UK must develop its own external tariffs, and may find itself subject to the highexternal tariffs applied by the EU to agriculture products – to the detriment of UK farmersand food manufacturers’. Moreover, the report also claimed that ‘the UK may also facenon-tariff barriers when exporting agriculture and food products to the EU, resulting indelays at ports and additional administrative cost’.Furthermore, since many PPPs approval holders already seen the EU is a small market,they might be reluctant to develop distinctive products purely for the UK. Also, a massivecost will be required to establish a new domestic pesticides authorisation in the UK, andthe re-assessment of the regulation might impact the trading in the PPPs that contain suchactive substances as the UK legislation might be more permissive compared that the EUregulation (Grant,2016).In addition, the UK is also highly dependent on the imported crop protection productsfrom the EU, as the Agriculture Industries Confederation’s (AIC) stated that ‘some 85%of the UK market is supplied with products manufactured elsewhere in the EU’.4 (1522436)2. For public safety and sustainability  – protect the public safety and the environmentalsustainabilityThe EU regulation provide a legal limit (Maximum Residue Level – MRL) for the foodproducers and manufacturers in its member states to comply as a result to protect thepublic health and safety (Food Standards Agency, 2017), and the legal limits are sets wellbelow the levels of the safety limits. A higher standard of legislation is more likely toprotect the health and safety for both human and the environment.As the UK could be shift from the EU’s ‘precautionary approach’ to a more ‘risk-based’approach following Brexit, which could likely be lower the standard of the regulation andit is very unlikely that government would agree and accept to lower the standards ofregulation (Carreno and Dolle, 2017). It is suggested by Pesticide Action Network (PAN)UK (2017), strengthen the current EU pesticide regime could make the UK a worldleader, but as they stated ‘the risk now is that the government will weaken pesticidelegislation in the UK post EU’. Also, the ‘risk-based’ approach will lead the public to agreater exposure of harmful pesticides, and higher levels of pesticides residues in theirdaily lifeFurthermore, Neonicotinoids have been banned on flower crops partially by the EU since2013 as a result of the negative impacts to the population of bees and other pollinators.The UK government opposed to the ban by claiming they had made all decisions onpesticides based on the science (Telegraph Reporters, 2017), and it is claimed byCarrington (2017), ‘most of the UK’s environmental protection derives from the EU andsince Brexit result many green groups have been concerned that these could be weakenafter Britain leaves the EU’.Modifying1. For the government popularities – to advocate the UK become a leading country inthe pesticide legislationIt is suggested by the Food Research Collaboration ‘Brexit creates a space to ‘do fooddifferently, to create new policies and systems to address the failing of the current foodsystem’. The UK will be moving from a ‘precautionary approach’ to a more ‘risk-based’approach (Authority of the House of Lord, 2017).5 (1522436)The UK Crop Protection Association (2017) suggested that ‘the use of hazard criteria forregulation of pesticides should not be retained by the UK following exit from the EU as itlimits the range of pesticides available to growers and farmers without any concomitantimprovement in protection of either human or the environment.’ The uses of pesticidesare not decreasing as a result of the current EU regulation and the effects of uses are notbeing improved by current measure.In addition, as the uses of biological products increasingly recognised as the future pestmanagement, the UK should modify its future pesticides regulation toward the promotionof the uses of biopesticides (Czaja, 2015). It is described by Cazja (2015), ‘in theregistration procedure of the EU, biopesticides are subject to the same regulations assynthetic active substances, this situations has resulted in need to introduce numerousnew provisions in the legislation.’ As the majority of biopesticides are counted as basic orlow-risk substances of a minimum risk level, it is unnecessary for the setting of the MRL.Moreover, the properties for the future plant protection products regulation should befocused on the acceleration of the approval process (Carreno and Dolle, 2017), as underthe current EU rules, it could take up to 2.5-3.5 years from the date of application to thepublication of a new approval active substance (European Commission, 2017).Furthermore, it is claimed by the PAN UK (2017) that ‘the UK’s pesticide action planwas particularly weak’ , and they recommended several suggestions for the post-Brexitpesticides policy modification, for examples, to introduce a clear quantitative target forreducing the overall uses of pesticides in agriculture, to introduce a strong penalties androbust enforcement for the pesticides contamination producers and to provide incentivesfor reducing the uses of pesticides and establish a proper monitoring system for pesticidesuse.Abolishing1. For the UK international partners and views of stakeholders – to benefit differentsectors in the economic perspectivesAs the EU is the UK’s single largest trading partner in agri-food products before Brexit,the abolishment of the regulation could improve and expand the UK agriculturalcompetitiveness in the world. The production cost of the food productions will be reducedas a result of the reduction of pesticides uses, and the food producers will be able to6 (1522436)compete with the other countries in a real race to the toxic bottom. ‘Harmonising’standard of the regulation would not only increases the opportunities of foodstuffs tradingwith the non-EU countries, but also make gain in the other sectors such as finances andmanufacturing in the country (PAN, 2017). The cuts of the pesticides regulation mayfavour the global trans-national corporations to corporate their businesses in the UK.Moreover, it would reduce the economic losses in the UK food production sectors thatcaused by the pesticides withdrawal as a result of the EU pesticides regulation. It isreferred by the magazine ‘Famers Guardian’ (2017), ’87 out of around 250 approvedpesticides in the UK could be lost to the farming industry as a result of the EU policiesand their implementation in the UK, while the wider food supply chain could seeeconomic losses of up to £2.5bn per year’. Farmers in the UK agreed with the de-regulation as I mentioned above, and they claimed that compensated should be given ifpesticides uses is restricted in a certain areas().2. From the likely responses of the public and the regulatees – the lack of evidence andalternativesThe UK had its own system of pesticides regulation before it joined the EU, and adomestic scheme for authorisation will be clearly one possible outcome to provideadvantages of local decision making based on assessment and evidence for specificallythe UK circumstances (Clarke, 2016). He stated that ‘The Chemicals RegulationDirectorate (CRD) is a government author of pesticides in the UK, which aligns withexperts in commercial, education and research organisation to give a huge body of well-respected knowledge in the UK for generating evidence, submitting and assessing productauthorisation’.Also, the current EU regulation is incomprehensive to be transferred into the UK laws, asit didn’t refer to the criteria of the endocrine disruption effects on the non-targetorganisms in the environment ((Regulation 1107/2009 Annex II, 3.8.2). Moreover, agreater risk will also be exposed as a result of the withdrawal of the certain types ofpesticides. The remaining groups will be more widely uses, resulting in increased risk ofthe pest resistance and might impact the biodiversity.7 (1522436)In addition, food production could also be produced by an alternative production systemsand the advanced of food technologies, although it would not be able to fully replace theuses of pesticides in present (The Andersons Centre, 2011)