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ClientEarth argues that the Council's position on the SAIO reform will prevent the EU from meaningfully monitoring its 2030 pesticide reduction targets. The briefing claims the Council is undermining the European Commission's proposal by delaying implementation until 2026, maintaining infrequent five-year data collection, and relying on voluntary surveys rather than mandatory professional records. Furthermore, the Council is accused of limiting the scope of 'agricultural activities', excluding non-approved active substances, and removing transparency guarantees related to the Aarhus Convention. ClientEarth asserts there are no legal grounds for the Council's reluctance to mandate the electronic collection of professional users' records.

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  • The Council's position would make it impossible to monitor the Farm to Fork Strategy's 50% pesticide reduction target by 2030 because the necessary data will not be available.
  • The Council proposes to maintain the current data collection frequency of every five years and use vague reference periods ('Year' instead of 'Calendar Year'), opposing the Commission's proposal for annual collection.
  • The Council intends to keep the old pesticide statistics system (Regulation (EC) No 1185/2009) in place until January 2026, delaying the new system's entry into force by at least three years.
  • The Council's position limits the scope of data collection by restricting the definition of 'agricultural activities' and excluding active substances that are not approved, even if they are used under 'emergency' authorizations.
  • The Council seeks to limit the geographic detail of the data to the national level, eliminating the possibility of requiring data at the NUTS2 level.
  • The Council proposes deleting Recital 31 of the Commission proposal, which ClientEarth argues is an attempt to create barriers to public access to environmental information and undermine the Aarhus Convention.
  • ClientEarth rejects the legal argument from some Member States (such as Austria and Lithuania) that the obligation to collect professional users' electronic records must be created under sectoral laws rather than the SAIO statistics framework.

Cite the original document

APA
Bernard, A. (2022). Time to fill the data gap on the use of pesticides. ClientEarth. https://www.clientearth.org/media/gngjmto0/clientearth-analysis-of-council-position-saio-february-2022.pdf
Chicago
Bernard, Alice. Time to fill the data gap on the use of pesticides. ClientEarth, 2022. https://www.clientearth.org/media/gngjmto0/clientearth-analysis-of-council-position-saio-february-2022.pdf.
Wikipedia
{{cite report |last1=Bernard |first1=Alice |title=Time to fill the data gap on the use of pesticides |publisher=ClientEarth |date=February 2022 |url=https://www.clientearth.org/media/gngjmto0/clientearth-analysis-of-council-position-saio-february-2022.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@techreport{bernard2022time, author = {Bernard, Alice}, title = {{Time to fill the data gap on the use of pesticides}}, institution = {ClientEarth}, year = {2022}, month = feb, url = {https://www.clientearth.org/media/gngjmto0/clientearth-analysis-of-council-position-saio-february-2022.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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