Remarks on Commission's Roadmap on Pesticides Legislation REFIT

ClientEarth criticizes the European Commission's Roadmap for the REFIT Evaluation of pesticides legislation, claiming it overemphasizes implementation costs over benefits and fails to incorporate the precautionary principle. The organization highlights inconsistencies between this roadmap and other chemical legislation evaluations, specifically regarding risk management terminology and endocrine disruptor 'cut-off' criteria, and argues that separating the evaluation of pesticide use (Directive 2009/128) from pesticide placement (Regulation 1107/2009) makes the process incomplete.

• The Roadmap is perceived as biased toward a negative evaluation because it prioritizes the costs of implementation over the benefits. Specifically, three out of four questions under the 'efficiency' heading focus on negative impacts on administration and businesses, while only one addresses benefits.
• ClientEarth contends that the Commission is inappropriately questioning the legal basis and legitimacy of Treaty objectives by asking if the objectives of the Regulations are still pertinent to current needs.
• The Roadmap fails to include the precautionary principle as an element for evaluation, despite a European Ombudsman finding that the Commission breached this principle by using the confirmatory data procedure for approving active substances in pesticides.
• The evaluation scope is criticized for being incomplete because it treats Directive 2009/128 on the sustainable use of pesticides as a separate evaluation from Regulation 1107/2009, which ClientEarth argues is necessary for a complete assessment.
• There are inconsistencies between the Pesticides REFIT and other chemical legislation evaluations regarding terminology and endocrine disruptors. The Pesticides Roadmap uses 'hazard-based versus risk-based assessment' instead of the 'generic risk considerations' and 'specific risk considerations' terminology used in other chemical legislation roadmaps. Additionally, the roadmap's approach to 'cut-off' criteria for endocrine disruptors contradicts the Commission's own draft proposal on the subject.

APA

ClientEarth (2016). Remarks on Commission's Roadmap on Pesticides Legislation REFIT. https://www.clientearth.org/media/rhyptqve/clientearth-feedback-on-pesticides-refit-ce-en.pdf

Chicago

ClientEarth. Remarks on Commission's Roadmap on Pesticides Legislation REFIT. 2016. https://www.clientearth.org/media/rhyptqve/clientearth-feedback-on-pesticides-refit-ce-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Remarks on Commission's Roadmap on Pesticides Legislation REFIT |date=December 2016 |url=https://www.clientearth.org/media/rhyptqve/clientearth-feedback-on-pesticides-refit-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2016remarks, author = {{ClientEarth}}, title = {{Remarks on Commission's Roadmap on Pesticides Legislation REFIT}}, publisher = {ClientEarth}, year = {2016}, month = dec, url = {https://www.clientearth.org/media/rhyptqve/clientearth-feedback-on-pesticides-refit-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }