Candidates for Substitution

A plant protection product (“pesticide”) is a formulation composed different components, including one or more active substances working against pests and plant diseases. In the EU, all those active substances must be subject to a risk assessment and approval decision at European level prior their incorporation in plant protection products. Those later are regulated at Member State level.

Candidates for substitution (CfS) are one of the four categories¹ of active substances which was introduced in 2009 in Regulation 1107/2009 on the placing of plan protection products on the market (“PPP Regulation”)². It regroups the EU-wide approved active substances, which due to their intrinsic hazardous properties, are identified as the most harmful of all for human health and the environment. These substances present risks in terms of acute toxicity (ARfd, AOEL, ADI23), carcinogenic or reprotoxic properties 1A or 1B pending their exclusion, endocrine disruption for humans or at least 2 PBT criteria (Persistence, Bioaccumulation and Toxicity)³.

Because their conditions of use are assumed safe, these toxic substances can be approved once for a period of 7 years. During this period, their use in pesticide products is supposed to be limited as much as possible through their substitution by safer alternatives at national level.

The adoption of this category of CfS in 2011 was the outcome of a balanced consensus that should ensure a smooth transition (7-year period), while protecting European citizens and the environment as much as possible (substitution principle at national level whenever possible). But ultimately, these more harmful pesticides, benefiting thanks to this CfS status from a temporary grace, were meant to be phased out.