Organic Farming

1.- Introduction

The implementation of EC Regulation No. 1107/2009 [1, 2] initiated a number of new types of substances, compared to previous European pesticide regulations. Of these, 3 types of substances are of importance for organic farming: “basic substances”, “low-risk substances” and “candidates for substitution”. Quite recently, the two first categories were established in an effective way. Although we described the interest of the type “basic substances” in a previous paper [3], interest in the low-risk substances for organic farming has not been previously described.

There are currently 18 approved basic substances, with 12 authorized in organic production. Of the 6 others, 4 will be authorized from the next vote at the Regulatory Committee of Organic Production (RCOP). There are currently 11 approved low-risk substances, with 9 authorized in organic production. Of the 2 others, all will be authorized from the next vote at the Regulatory Committee of Organic Production (RCOP) and the next low-risk substance laminarin is already allowed in organic production.

The latest cited type, “candidates for substitution”, has yet to be seriously considered, since few substances allowed in organic farming are listed in the corresponding Annex including the copper compounds class. Of the 77 substances initialy enlisted as “candidates for substitution” 7 are already non-renewed.

The categories were created at the origin of the general EC Plant Protection Product Regulation No. 1107/2009 by corresponding distinct Articles, but have only recently been implemented: the first basic substance was approved in 2014, the first low-risk substance was approved in 2015 and the ‘‘candidates for substitution” list was only published in 2015. These categories are distinct and have no possibility of having substances in common at the same time.

These general EC plant protection product Regulation dispositions were taken without consideration of the status in Organic Production for the corresponding substances: some were already allowed in organic farming (i.e. micro-organisms, ferric phosphate or calcium hydroxide) and some not. Criteria for inclusion in the corresponding list of “candidates for substitution” did not consider the Organic Production allowance status.

2.- Low-Risk Substances

Recently created [1] by the Article 22 of the EC Regulation No. 1107/2009 [2], the “Low-risk Substances” category is now in operation with 11 approvals at the EU level [4]. Low-risk substances are regular active substance under EC Regulation No. 1107/2009 [2] with specific criteria for approval. Low-Risk substance status is granted during approval or renewal, most of them have no maximal residue limit (MRL) with a high potential for inclusion in the Organic Farming regulation (EC) No. 889/2009 [5] Annex II. Some of the low-risk substances are already allowed in organic production. Initial candidates described as low-risk during their approval renewal include ferric phosphate and the Isaria fumorosea strain Apopka 97; these were already allowed in organic production. A number of low-risk substances were approved later, due to the fact that most of them (8 out of the 11) were microorganisms, and are automatically allowed in organic farming. Bio-sourced and mainly plant defence enhancers used as crop protection are also obvious candidates for inclusion. Diverse biorational candidates have already been submitted and some have already been taken into consideration by the Expert Group for Technical Advice on Organic Production (EGTOP) [6]. Low-risk status is granted by the European commission. Originally, the same criterion was adopted for all types of active substances (chemical, micro-organism and semiochemicals). These specifications were established and listed in the point 5 of Annex II [2]. Starting (in) 2013, some modifications were discussed and adopted in 2017.

3.- Candidates for Substitution

Defined in Article 24 [2], candidates for substitution (77 substances) must meet one or more of the additional criteria laid down in point 4 of Annex II, and are active substances approved for a period not exceeding 7 years. Listed under separate regulations [19], these substances of concern with ADI, ARfD or AOEL significantly lower than those of the majority of the approved active substances within groups of substances/use categories - with two of the criteria (both toxicological and environmental) to be considered as bioaccumulative and toxic (PBT) substances or considered as persistent, toxic, neurotoxic, immunotoxic, carcinogen, toxic for reproduction or considered to have endocrine disrupting properties) - are encouraged to be substituted by a new substance of less concern.

4.- Discussion: Consideration by Organic Farming Sector

5.- Conclusion

“Low-risk substances” is clearly an expanding category of low concern crop protection products and most of them are of interest for plant protection in the organic production, as the recent reception by EGTOP demonstrates [6].

The number of “candidate for substitution” substances is not subject to increase since most newly or ongoing European approved substances are below the corresponding toxicological cut-off criteria. From this point of view, further impact on organic production is expected to be limited: no further substance allowed in organic production will be listed in the “candidate for substitution” list. However, the presence of the “copper compounds” substance in this list is problematic as the impact of the non-renewal of copper compounds could be disastrous for organic vine production.

Overall, these two new categories are beneficial developments for organic production because they provide a proof of an overall decline of the toxicity of the approved active substances.

Acknowledgements

Funding: The author wishes to thank the French Ministry of Ecology (MEDDE) (CP ITAB Urgence PBO, 2014-15), the French Ministry of Agriculture (MAAF) and ONEMA (Biocontrol Project, Action 17B, 2012-13; PARMA, 2014-2016; XP-BC 2017-2019) for financial support. The author would like to thanks Dr. Trevor M. Fenning of Forest Research (UK) for providing helpful advice on the editing and writing of the manuscript.