This summer, the European Commission's Joint Research Centre (JRC) published a study on the proposal to ban residues of some of the most dangerous pesticides in imported products, a measure currently discussed as part of the “food and feed” omnibus regulation. Several press articles noted that lowering maximum residue levels (MRLs) to the limit of quantification (LOQ) for certain substances banned in the EU would significantly raise the prices of certain products, specifically, a 332% increase in the price of coffee.

However, that is not what the JRC report says. That is why the Veblen Institute - together with CNCD-11.11.11, Humundi, Slow Food, and the FNH - is publishing an analysis of the JRC report on mirror measures on pesticides.

The JRC report represents a considerable and meticulous body of work. However, it focuses strictly on economic feasibility, commercial impacts, prices, and competitiveness associated with tightening import rules, while setting aside environmental and public health factors. Mirror measures should not be reduced to a mere instrument of agricultural protection or competitiveness: their environmental and public-health objectives - which fall outside the scope of the JRC's economic assessment - must be brought back to the centre of the debate. All the more so since, under WTO law, only environmental and public-health grounds can be invoked as justification — concerns about a level playing field in production conditions are not accepted.

Our analysis examines and challenges some assumptions and findings of the JRC report to provide evidence and arguments in favour of adopting more ambitious import requirements.

Main messages :

• The study covers 18 active substances classified among the most hazardous under the EU criteria used in the Food and Feed Omnibus proposal, and the impact of MRLs set at the limit of quantification. It therefore assesses the least ambitious demand level, and it does not examine the effects of the broader measure proposed in the latest compromise.

• The assumption of an abrupt halt in exports to the EU, resulting in a major inflationary economic shock—as modelled in the JRC's first scenario (S1)—is not only unrealistic: legitimising excessively high impact assumptions (S1 and S2) also undermines the prospects for more ambitious policy action.

• S1 should not be used as a central forecast, but only as an upper bound. For country–commodity pairs involving a targeted substance with an EU MRL above the LOQ and evidence of authorisation or residue detection, it applies the shock to the entire trade flow, without scaling exposure to actual use or detection rates. It also assumes exporters do not adapt at all, which is unrealistic given historical examples (chlorpyrifos (2020), tricyclazole in rice exported from India and Pakistan (2018), or the neonicotinoids clothianidin and thiamethoxam (2026)).

• The assumptions underpinning S3—which produces a limited inflationary impact—appear more relevant than those used in S2 and more consistent with the initial request to assess the effects of lowering MRLs to the limit of quantification for a small list of substances. S2 appears to overestimate both the share of trade flows potentially affected and the associated adaptation costs.

• The significant impacts on the European livestock sector are not a robust finding. They occur mainly under S1, while becoming negligible in the two scenarios that allow exporters to adapt.

• Additional historical case studies documenting how exporters have adapted, including potential spillover effects, would help provide a stronger evidence base on adaptation in exporting countries.

The report focuses on how a ban would affect EU employment, as well as the impacts on human health and the environment in importing countries. It concludes that stopping the export of EU-banned pesticides would neither endanger employment nor burden the EU economy. At the same time, a ban would positively impact people's health and the environment in importing countries.

While pesticides are banned in Europe because they are too hazardous for humans and/or the environment, European companies are still allowed to manufacture and export them in other parts of the world. This EU double standard poses a threat to human health and the ecosystems in importing countries, mainly Low- and Middle-Income Countries (LMIC). At the same time, the EU imports food grown using these substances, leading to exposure of EU consumers via residues in imported foods and also putting EU farmers in an unfair competition.

After committing to ban the export of these pesticides in 2020, the EU has been stalling, and even backtracking, under pressure from the industry, which fiercely opposes the adoption of an EU-wide export ban. The main argument used by the industry is that an export ban would harm the EU economy and create a massive job loss for pesticide producers while having no beneficial impacts for the protection of human health and the environment in importing countries. The thorough investigation presented in this report gives a completely different picture :

• A negligible economic cost for the EU. The total number of jobs potentially at risk as a result of a hypothetical EU export ban would be as low as 173 jobs in 2022. Based on the experience with the partial French export ban, the authors conclude that the total potential loss of employment would have accounted for 25 jobs in 2022 for the entire EU. In the end, no jobs might be lost at all as staff may be relocated or given different tasks.

• Positive impacts for importing countries. To this day, the EU remains the world's leading exporter of pesticides. Consequently, stricter rules on pesticide exports will have positive effects on chemical pollution globally. Halting exports of pesticides banned by the EU would reduce exposure and all associated risks for the health of agricultural workers, local populations, and the environment.

Based on these findings, the coalition of civil society organizations urges EU policymakers to act without further delay.

On 28 June 2019, the EU and Mercosur reached a political agreement towards a free trade agreement between the two regions, after 20 years of negotiations. In the ensuing period, the path to ratification has been fraught with internal and external challenges. The agreement was highly criticised for its potential environmental and social impacts.

Indeed, the EU-Mercosur agreement promotes trade flows of goods incompatible with the objectives set by the Paris Agreement, the European Green Deal, and the Farm to Fork Strategy. It poses significant risks for Mercosur countries, as it locks them into a role as agro-exporters, and worsens deforestation in the Amazon. Its implementation would also negatively affect EU countries, notably from a health perspective, as it would facilitate the entry of products produced using practices prohibited in the EU.

These obstacles prompt a critical examination of the viability and plausibility of ratifying the current agreement in its present state – from an environmental, social and democratic perspective, but also regarding the discrepancy in production standards between the two blocs, in the context of farmers' protests across Europe.

The report, authored by Veblen Institute, CISDL, E3G, FTAO and IEEP, coordinated under the Green Trade Network, and commissioned by the Greens/EFA group in the European Parliament, explores 4 scenarios for a fair and sustainable partnership between the EU and the Mercosur region :

• Alternative 1. Renegotiation of the deal : with key elements to consider such as, making tariff preferences conditional on effective compliance with sustainability criteria for all the most sensitive products from a climate and biodiversity point of view, compliance with environmental and climate commitments as well as core ILO conventions as an essential element of the EU-Mercosur Agreement, specific and measurable commitments in the TSD chapter, etc.

• Alternative 2. A bilateral partnership on sustainability issues without access to market (high level of cooperation, low level of market integration)

• Alternative 3. Targeted cooperation and integration: a bilateral partnership on sustainability with targeted market access

• Alternative 4. Targeted Bilateral Strategic Partnership(s) (on critical raw materials)

The Report also contains policy recommendations for decision-makers and negotiators on both sides to build future relations between the EU and Mercosur :

1. Any agreement or political partnership with Mercosur countries (as a bloc or individually) should be compatible with the Paris agreement and the Kunming Montreal framework in compliance with international human rights law, ILO Standards, WTO law and Public International Law.

2. Future cooperation vehicles between the two blocs should be based on dynamic assessments of the impacts of any market access measures on both ecosystems and local communities. They should include tailored roadmaps for addressing key environmental and social issues, combined with review and adjustment clauses.

3. Any EU-Mercosur partnership should be supported by a financial package that facilitates compliance with EU market access requirements and contributes meaningfully and sustainably to the Mercosur region's clean and circular economy transition, further linking the EU's trade policy with specific programmes such as the Global Gateway.

4. The future partnership should provide a series of assistance measures to ensure sustainable management of resources and a fair allocation of value as well as to raise the capacity of local actors to comply with the EU's environmental and labour regulations.

5. Parties should refrain from seeking to increase trade between the two blocs as a goal in itself, but primarily seek to improve commercial partnerships of products that are produced sustainably and are not easily available in the other bloc.

6. Market-opening provisions of such a partnership should focus on trade in sustainable products produced by companies abiding by the CSDDD and similar laws, favouring local and domestic products when possible. This shall also mean stopping the export of harmful substances that are banned in the EU (pesticides).

7. Any initiative for dialogue on standards should be aimed at increasing the level of protection for workers, consumers and the environment and not at facilitating trade (which may be an indirect benefit but should never be a condition for it).