Our new report Toxic Trade compares current UK pesticide protections with that of two countries slated as major priorities for post-Brexit Free Trade Agreements – US and Australia – and a third country, India. Co-authored with Sustain and trade expert Dr Emily Lydgate, the report focuses on how trade deals with these countries threaten to weaken UK pesticide standards. It also looks at ways in which these deals could increase pesticide-related harms to UK citizens, wildlife and the natural environment.
The UK is in the process of negotiating trade deals in the wake of its exit from the EU. While far from perfect, UK pesticide standards are some of the strongest in the world in terms of protecting human health and the environment. UK safety limits for the levels of pesticides allowed to appear in food tend to be more stringent than in the majority of other countries outside the EU and, along with its European counterparts, the UK is more likely to ban a pesticide due to concerns over the harms it causes.
As a result of these relatively high standards, future trade deals with non-EU countries with weaker pesticide protections present a considerable risk to the health of UK citizens and the environment. Trade partners attempting to secure access to the UK market for their food exports have listed UK pesticide standards as a key sticking point and made it clear that weakening them is a priority.
Published alongside the report is new YouGov polling which reveals that the UK public is overwhelmingly opposed to any lowering of UK pesticide standards to meet the demands of other countries’ trade negotiators. 71% of respondents are ‘concerned’ that a trade deal with the US in particular will increase the amount of pesticides in the food they consume, with 43% of people ‘very concerned’. The same figure (71%) agree that the UK Government must resist pressure in trade negotiations with the US to overturn bans on pesticides, even if this means the “best” trade deal cannot be reached. Meanwhile, 79% are concerned about impacts to health resulting from a lowering of UK pesticide standards with 77% worried about negative impacts on the environment.
Larger amounts of pesticides in UK food
If the UK agrees to weaken its pesticide standards during a trade negotiation then food on UK shelves may soon be allowed to contain significantly larger amounts of highly hazardous pesticides. Here are a few examples:
- American apples are allowed to contain 400 times the level of the insecticide malathion than UK apples. Malathion has been linked to cancer and can impair the respiratory system and cause confusion, headaches and weakness.
- Compared to UK grapes, American grapes are allowed to contain 1,000 times the amount of the insecticide propargite that can affect sexual function and fertility, and has been linked to cancer and miscarriages.
- Australian wheat is allowed to contain ten times the amount of the insecticide carbaryl than UK wheat. For Indian wheat the figure is four times that of UK wheat. Carbaryl has been linked to cancer and classified as a suspected endocrine disruptor. It is also a developmental or reproductive toxin which means it can have adverse effects on sexual function and fertility and can cause miscarriages.
More toxic pesticides in UK food
Food consumed in the UK is not currently allowed to contain residues of pesticides that have not been approved at the EU level. If the UK bows to the demands of trade partners to lower standards, then pesticides that have been banned due to concerns over their impact on human health could once again appear in UK food. Examples include:
- Chlorpyrifos is allowed to appear in food produced in the USA and India. Chlorpyrifos was banned by the EU due to concerns over its negative impact on the brains of foetuses and young children. Multiple studies have revealed the links between exposure to chlorpyrifos and low IQ and delayed mental and motor skill development in young children.
- In the US and Australia, food is allowed to contain residues of dimethoate. Dimethoate was banned by the EU for reasons which include the potential risk posed to consumer health through long-term exposure via diet.
- Iprodione is allowed to appear in food produced in US and India. Iprodione was banned by the EU over uncertainties as to its impact on consumer health. It has been linked to cancer and is classified as a suspected endocrine disruptor which means it can interfere with hormone systems and can cause birth defects, developmental disorders and reproductive problems such as infertility.
More harmful pesticides allowed to be used in the UK
Potential trade partners such as the US approve many more pesticides than the UK. These trade partners have made it a priority to drive down UK standards in order to allow more toxic substances to be used in British agriculture, urban areas, homes and gardens. A brief look at the numbers reveals the extent of the risks posed to the health of UK citizens and the natural environment.
Harmful to bees and pollinators
A range of pesticides which are banned in the UK due to their toxicity to bees and other pollinators are allowed for use in the US, Australia and India. These include fipronil and neonicotinoids, which are notorious for driving alarming declines in bee populations.
The UK has banned a number of pesticides due to their high potential to pollute water and damage aquatic life. The list includes atrazine and diuron, both of which are authorised for use in the US, Australia and India.
Harmful to human health
The UK has tended to take a more precautionary approach than non-European countries to protecting human health from pesticides. As a result there are a wide range of pesticides banned in the UK due to health concerns that are still allowed elsewhere. The list includes paraquat, a pesticide with one of highest documented human fatality rates which is banned in over 40 countries but remains in use in the US, Australia and India.
A closer look at a group of insecticides called organophosphates reveals some major differences in approaches. Organophosphates are known to be particularly toxic to humans and have negative impacts on children’s cognitive development. They were responsible for the poisoning of hundreds of UK sheep farmers in the 1970s and 80s.
What needs to happen?
The UK Government must not allow any weakening of UK pesticide standards via trade deals. This must include maintaining current safety limits for the amount of pesticides permitted in food, and making sure that food containing residues of currently banned pesticides cannot be imported into the UK. The Government must also refuse to weaken the UK approvals system in order to reauthorise any pesticides that are currently banned due to health or environmental concerns. For a full list of recommendation please see the Toxic Trade report.
There is currently almost no opportunity for parliamentary or public scrutiny of UK trade agreements. This makes it all too easy for the UK Government to trade away our hard-won protections behind closed doors. It’s therefore crucial that the public, journalists and MPs start calling attention to the significant risks posed to health and environment by toxic trade.
Frequently Asked Questions
A trade deal is an agreement between countries designed to remove restrictions on goods and services traded between them.
The key area where trade and pesticides intersect is around the global trade in food which totals roughly $2 trillion per year. Countries set different safety limits for how much of a particular pesticide is allowed to appear in an item of food (this safety limit is known as a Maximum Residue Level).
Along with its European counterparts, the UK has tended to take a relatively precautionary approach to protecting human health from pesticides and so has set more stringent safety limits than other countries such as the US and Australia. As a result, much of the food produced in these countries contains pesticide residues which are too high to meet UK standards. This prevents companies from these countries exporting their produce to the UK. Trade partners therefore have much to gain by pressuring the UK to allow food imports containing higher levels of more toxic pesticides.
In recent years, trade deals have increasingly been used to push for ‘regulatory cooperation’, whereby joint standards are agreed between trading partners. Under this guise, the agrochemical industry and countries such as the US have made concerted attacks on the European approach to regulating pesticides and lobbied hard for it to be weakened. The UK is already under considerable pressure to take a laxer approach to which pesticides it authorises for use. If the UK Government bows to these demands, then pesticides banned in the UK due to evidence that they impact negatively on human health or the environment could soon be used again in our farms and gardens.
While far from perfect, UK pesticide standards are some of the strongest in the world in terms of protecting human health. However, these relatively high standards prevent other countries from exporting food to the UK and governments therefore push to weaken UK protections.
If UK trade negotiators give way to their demands then the increased risk to human health could be significant. American grapes, for example, are allowed to contain 1,000 times the amount of the insecticide propargite than their UK equivalents. Propargite has been linked to cancer and classified as a ‘developmental or reproductive toxin’, meaning that it can negatively affect sexual function and fertility and can cause miscarriages. An Australian apple can contain 30 times the amount of buprofezin – an insecticide classified as a possible human carcinogen – than a UK apple.
As well as finding themselves exposed to higher levels of pesticides in their diets, UK citizens could soon have no choice but to consume food containing pesticides that are currently banned from appearing in UK food. The US allows the use of almost 1.5 times the number of highly hazardous pesticides as the UK, while Australia permits almost double. As just one of many examples, unlike the UK, the US and India continue to allow food to contain residues of the insecticide chlorpyrifos which has been shown to negatively affect the cognitive development of foetuses and young children.
Any weakening of UK pesticide standards via trade deals poses risks not just to human health but also to the environment. Trade partners such as the US and India have a history of challenging the EU’s relatively precautionary approach to which pesticides are allowed for use, and the UK is already coming under similar pressure. Australia, the US and India all allow the use of pesticides which the UK prohibits because they are highly toxic to bees and pollinators, including neonicotinoids which are notorious for driving massive declines in bee populations. They also authorise pesticides known to contaminate groundwater and harm aquatic ecosystems, such as the herbicides atrazine and diuron.
If the UK Government is to achieve its ambition to “leave the natural environment in a better state than we found it” then it must resist efforts by trade partners to push the UK to authorise, or reverse bans on, pesticides which harm wildlife and contaminate water and soil.
A drop in UK pesticide standards as a result of a trade deal would also pose a significant economic threat to the future of UK agriculture. If UK food starts to contain higher levels of more toxic pesticides then British farmers will struggle to meet EU standards, thereby losing their primary export destination which currently accounts for 60% of UK agricultural exports. Equally concerning, British farmers could be undercut by a flood of imported crops grown more cheaply on a larger scale and to lower standards.
It’s crucial that the Government protects British farming by defending pesticide standards, particularly in trade negotiations with agricultural powerhouses such as the US and Australia.
So far, the UK Government has sent very confusing signals about its intentions.
On the one hand, the 2019 Conservative Party manifesto stated clearly that in trade negotiations “…we will not compromise on our high environmental protection, animal welfare and food standards”. The UK’s negotiating objectives for a US trade deal, published in February 2020, contain similarly vague but reassuring statements such as “Any trade agreement with the US must work for UK consumers, farmers and companies…”. However, the UK Government has resisted numerous attempts to enshrine these promises into law, calling into question to what extent these statements are genuine.
The UK’s objectives for trade negotiations with the EU which were published in March 2020 have only added to these concerns. They include some major red flags indicating that the UK Government is planning to move away from the EU’s precautionary approach to regulating pesticides in order to adopt a much weaker system.
With the EU calling for the UK to maintain close alignment with the European pesticide regime, and the US pushing for the UK system to be weakened, it remains to be seen who the UK’s trade negotiators decide to side with.
The US is particularly significant since negotiations have progressed the furthest and the US has emphasised that moving away from the EU’s precautionary approach to regulating pesticides is a key requirement for a deal.
Looking at the Trump administration’s negotiating objectives reveals attempts to weaken UK pesticide standards in a wide range of ways including:
- Pushing for US food exports containing higher levels of more toxic pesticides to be allowed into the UK. For a UK trade deal, the US aims to ‘establish a mechanism to remove expeditiously unwarranted barriers that block the export of U.S. food and agricultural products’. This language clearly signals a commitment to pursue the weakening of UK pesticide standards.
- Pushing the UK to adopt weaker international standards. In negotiations with the EU, the US has attempted to build in international standards as a way of weakening EU standards.
- Establishing rules that prevent the introduction of future regulations. This alignment with US standards would last long into the future, obstructing the UK from bringing in stronger protections even if new evidence emerged showing pesticide-related harms to human health or the environment.
- Requiring the UK to consult with the US Government and private sector on upcoming regulations. This would provide the opportunity for lobby groups, including the powerful US agrochemical industry, to apply pressure directly to UK regulators to (for example) approve new pesticides that exporters want to use, or to raise safety limits for residues in food.
Calling for the UK to accept the ‘equivalence’ US standards. The US argues that the UK’s current approach is not actually safer for consumers but is in fact non-scientific and designed to keep out imported products. They claim that the US approach actually achieves an equivalent level of protection and call for the inclusion of obligations for trade partners to recognise the equivalence of each other’s regulations.
Yes! The UK’s current pesticide standards offer better protection for human health and the environment than those of any non-EU country. Trade negotiations with all non-EU countries therefore pose a significant threat to UK pesticide standards as countries push to gain access to the UK market for their agricultural exports.
In the Toxic Trade report, in addition to the US, we chose to look at the pesticide standards of another country slated as a major priority for a post-Brexit trade deal – Australia – and a third country, India. In addition to being targets of the UK Government for immediate or future trade deals, these countries were chosen because they are major agricultural producers and their significant lobbying strength increases the likelihood that they will be able to force down UK pesticide standards during trade negotiations.
In addition to allowing larger amounts of more toxic chemicals to appear in UK food, there are also a range of important differences between the way the UK has chosen to govern pesticides and that of future trade partners. Arguably the most fundamental is that the UK currently takes an approach based on the view that some pesticides are intrinsically hazardous and therefore simply too dangerous to be in use. In contrast, non-EU countries follow an approach based on the belief that almost every risk can be mitigated.
The divergence in the approaches of different trade partners also relate to numerous procedural aspects of the pesticide regime. For example, Australia and India have no set time period for reviewing pesticide approvals, meaning that harmful pesticides can remain in use indefinitely once authorised. In contrast, under the current UK system, pesticides are granted a maximum license of 15 years before having to go through a risk assessment process to be reapproved.
It is crucial that UK trade negotiators understand these differences so they are able to defend aspects of the UK pesticide regime designed to protect human health and environment.
The Precautionary Principle, which emerged in the 1970s, theoretically underpins all current UK decison-making on pesticides. It allows regulators to adopt precautionary measures when scientific evidence about an environmental or human health hazard is uncertain and the stakes are high. For example, when evidence began to emerge that neonicotinoids were driving alarming declines in bee populations the UK Government was able to support a ban on their use on the basis that here was sufficient cause for concern. They did not have to wait for the evidence to be definitive, an often unattainable goal.
In contrast, many of the UK’s potential trade partners follow what is misleadingly termed ‘the science-based approach’. Under this approach, instead of a pesticide manufacturer having to demonstrate that their product is safe, regulators must offer a very high level of scientific proof that a product is dangerous. However, evidence of harms may not emerge for many years and, in the meantime, some of the negative impacts caused – such as the development of malignant tumours or the extinction of particular species – may be irreversible.
The US Government in particular uses the term ‘science-based’ as a veiled and publicly palatable way through which to attack the Precautionary Principle. It’s vital that UK negotiators understand the true meaning of ‘science-based ‘and are prepared to defend the vital role that the Precautionary Principle plays in protecting human health and environment from pesticides.
No! Trade deals are designed to remove restrictions on the trade in goods and therefore aren’t the place to secure better standards.
A closer look at the EU’s existing trade deals reveals the limited prospects for the UK to ‘export’ a more stringent approach to pesticide regulation. These deals don’t actively promote the EU’s precautionary approach to pesticides, in fact it largely goes unmentioned. Through its trade deals the EU has actually subjected itself to some new pressures to deregulate pesticides by creating structures which allow other countries to push for weaker pesticide protections. This is something that UK negotiators should avoid.
The UK is particularly vulnerable to weakening its pesticide regulation through trade deals. This is due to a combination of political pressure to conclude trade deals in order to recoup lost EU market access and ‘make a success’ of Brexit, pressure from some UK lobby groups, and the fact that EU exit has led to a ‘governance gap’ in terms of UK institutions, systems and staff.
In addition, the UK regulatory system is already in flux and subject to fewer checks and balances than the EU provided. So, rather than having a settled domestic regulatory framework as its starting point, the UK Government is scrambling to bring EU rules into the UK lawbooks. In doing so, it has replaced a system of EU checks and balances with discretionary powers for UK Ministers to amend, revoke and make regulations. This makes it much easier for the UK to change its pesticide regulations to accommodate trade partners.
This is particularly concerning as the UK Parliament already has a weak influence on UK trade negotiations as compared to, for example, the EU or US. The rules governing trade in the UK offer no meaningful role for parliamentarians or opportunities for public scrutiny. Currently, no one outside the UK Government can even access the text of a trade deal until it is being ratified, let alone amend it.
The current lack of transparency makes it much more likely that countries with lower pesticide standards will be able to force down UK pesticide protections. In addition, there is a question around whether the UK Government, which hasn’t negotiated a trade deal since the 1970s, has the capacity or expertise to withstand attempts to lower pesticide standards, especially given the political pressure to conclude agreements quickly.
In March 2020, it was reported that the UK Department for International Trade needed to fill job vacancies for 135 trade experts. With the perfect storm of inexperienced UK trade negotiators, staff shortages, more powerful and well-resourced negotiating partners and a shroud of secrecy enclosing the entire process, trade deals are arguably the most likely route through which the UK’s pesticide standards will be undermined.
Here are our key recommendations for the UK Government. For the full list of recommendations, see page 41 of the Toxic Trade report:
- Do not allow any weakening of UK pesticide standards via post-Brexit trade agreements. This must include:
- Ensuring that no currently banned pesticides are allowed for use in the UK
- Ensure that food containing detectable residues of currently banned substances cannot be imported into the UK
- Ensure that Maximum Residue Levels are maintained or reduced.
- Ensure a level-playing field for UK farmers by maintaining existing UK pesticide standards, thereby enabling them to continue exporting to the EU.
- Prevent UK farmers from being disadvantaged by cheap food imports produced to weaker pesticide standards in non-EU countries.
- Maintain the Precautionary Principle as the basis upon which all pesticide-related decisions are made and strengthen its implementation. This includes maintaining the so called ‘hazard-based’ approach to pesticide authorisations.
- Preserve the power for the UK to exercise its right to go above and beyond the status quo and applicable international standards to continually strive for higher levels of consumer and environmental protection.
- Introduce additional legislative protections to ensure that any change to food safety standards or environmental protections subsumed in trade agreements can only be introduced via primary legislation.
- Ensure that trade agreements are developed in the open with the opportunity for full democratic scrutiny.
There has been much public uproar about the UK lowering its food standards via a trade deal with the US to accept ‘chlorinated-chicken’. However, the risks related to pesticides are equally significant but the issue isn’t getting public attention so the Government doesn’t feel under pressure to protect standards.
US/UK trade talks are ongoing so it’s crucial that we start making noise about this issue now.
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“A clear and central objective of US negotiators is for the UK to lower its pesticide standards. The current picture in the UK of intense political pressure coupled with a lack of parliamentary and public scrutiny means the risk of this happening is very high.”
Dr Emily Lydgate, Senior Lecturer in Environmental Law at the University of Sussex