The future regulation of plant protection products (PPP)

The future regulation of plant protection products (PPP) is entering uncharted waters writes policy manager Jenny Brunton.

For most people, the regulation of chemicals is not something that they will often think about, but chemicals are found in pretty much everything - from hand gel to cosmetics.  Chemical manufacturing is a vital component of many other industries which is why active substances are so heavily regulated.

The chemicals industry currently faces a ‘double whammy’ with the threat of a no-deal or hard Brexit, and potentially diverging rules between the UK and the EU.  

Even if agreement on a trade deal is reached, from 1 January 2021 the UK will no longer participate in the EU’s Registration, Evaluation, Authorisation & Testing and Restriction of Chemicals (REACH) system and has instead established UK REACH under the Health and Safety Executive (HSE).

New applications for active substance approvals, PPP authorisations and Maximum Residue Levels (MRLs) will need to be separately submitted under the GB and EU regimes to gain access to both markets.  The cost to companies having to apply under these parallel systems has been estimated at £1bn1

The issue boils down to access to data.  The EU has spent decades collecting a huge databank of all authorised chemicals in the EU with evidence of safety based on extensive analysis and testing.  The loss of access to that data has the potential to damage highly integrated EU-UK supply chains built on years on information collection and exchange.

Pesticide regulation is complicated and contentious, and any changes - even the simplest - take time.  Whilst many hope that leaving the EU will eventually allow the UK to shift its policy away from the EU’s hazard-based approach towards one based on risk, changes to the UK system will not come overnight.  

There is also the added issue that under the Northern Ireland Protocol to the Withdrawal Agreement, the EU’s PPP regulations will continue to apply in Northern Ireland.

The UK Government has announced that EU active substance approvals expiring within 3 years of the end of the transition period, 31 December 2020, will each be extended for 3 years to allow time for the necessary GB evaluation work.  

HSE will however retain the power to review active substance approvals through UK REACH, at any time, should new evidence identify concerns to human health or the environment.

In theory the UK could approve the use of products and active substances which the EU may decide not to authorise.  However, depending on the trade deal reached, UK growers could inadvertently still be bound by EU regulations.  

The EU could restrict imports of goods which have been treated with a particular PPP by setting its MRL at 0.01 mg/kg unless an import tolerance was agreed.  

Although not on many radars, NFU Scotland will be keeping a keen eye on the important area of PPPs and future regulation.


Steve Elliott, CEO of Chemical Industries Association -

Author: Jenny Brunton

Date Published:

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About The Author

Jenny Brunton

Jenny Brunton joined NFU Scotland in early 2018 as Policy Manager for CAP Schemes and Post Brexit Agricultural Policy. Jenny is responsible for developing policy for both Pillar 1 and Pillar 2 schemes, ensuring the members are represented through NFU Scotland’s policy. Having been raised on her family’s mixed farm, Jenny studied History and Politics at University before travelling abroad, returning to work on a nearby farm in Fife. A keen member of her local Young Farmers Club, Jenny will also be responsible for the Next Generation Working Group and looks forward to engaging with the future leaders in Agriculture.

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