Editorial Article
The Pesticide Target Was Withdrawn. The Tonnage Fell Anyway.
<h2>The target was withdrawn. The tonnage fell anyway.</h2>
<p>On 27 March 2024 the European Commission formally withdrew its own Sustainable Use of Plant Protection Products Regulation. The instrument that was going to halve pesticide use across the Union no longer exists as a proposal. In the same period, the European Union sold 292,000 tonnes of pesticides in 2023 — the lowest quantity since Eurostat began the series in 2011, down 9% on 2022 and 18% on 2021.</p>
<p>Those two sentences together are the argument of this piece. The most ambitious pesticide-reduction law in the world was killed, and the tonnage fell anyway, because the law was never the mechanism doing the work. The mechanism is an annex.</p>
<h2>What was actually withdrawn, and why it matters that it was procedural</h2>
<p>The withdrawal appears in the Commission’s own notice of withdrawn proposals (C/2024/3117), approved at its 2488th meeting on 27 March 2024. The stated ground for withdrawing COM(2022)305 final is unambiguous, and it is not a change of policy: no agreement was foreseeable, “in view of the rejection of the proposal by the European Parliament (P9_TA(2023)0424) and the lack of progress of the discussions in the Council.”</p>
<p>That distinction matters commercially. A policy reversal would tell a supplier that the direction of travel had changed. A procedural death tells a supplier only that the instrument that would have measured them is gone — while every other instrument remains exactly where it was. The industry read the first thing. The second thing is what happened.</p>
<h2>The number that fell on its own</h2>
<p>Eurostat’s release of 13 May 2025 puts EU pesticide sales at approximately 292,000 tonnes in 2023. By category: fungicides and bactericides 39% of volume, herbicides, haulm destructors and moss killers 36%, and insecticides and acaricides 17% — which is 49,640 tonnes of insecticide and acaricide active ingredient sold across the entire bloc in a year.</p>
<p>The concentration is as you would expect of agricultural area: France 23%, Spain 18%, Germany and Italy 14% each. The direction across the series is not uniform. Between 2011 and 2023, of the 21 member states with data, 16 recorded lower sales volumes — the sharpest falls in Portugal and Italy (each −44%), then Ireland and Slovenia (each −38%). Five recorded higher volumes, led by Latvia (+55%), Austria (+52%) and Lithuania (+11%).</p>
<p>An 18% fall across two years in a bloc of 27 is not a rounding error and it is not a demand story. European agriculture did not shrink by 18% between 2021 and 2023.</p>
<h2>The instrument that does bind is a list of substances</h2>
<p>The Commission’s own advisory group was given the state of play for active substances on 16 May 2025, as at 1 May 2025. Three numbers in that deck describe the entire addressable chemistry of European crop protection:</p>
<ul>
<li><strong>244 active substances approved</strong> (Parts A and B of the Annex to Implementing Regulation (EU) 540/2011, excluding those on the substitution list), of which 36 are microbial — 14.75%.</li>
<li><strong>51 low-risk active substances</strong> (Part D of that Annex), of which 30 are microbial — 58.82%.</li>
<li><strong>42 candidates for substitution</strong> (Part E).</li>
</ul>
<p>Read the first two ratios against each other, because they are the most informative pair of numbers in the sector. Microbials are under 15% of the ordinary approval list and nearly 59% of the low-risk list. The fast lane and the biological lane are the same lane. That is not a marketing observation about consumer preference for “natural” inputs; it is an observation about where the Commission has made the dossier cheap enough to file.</p>
<p>The practical consequence is that a company building a European crop protection portfolio is not chasing the best molecule. It is chasing whichever molecules can be maintained across 27 competent authorities, and the maintenance burden is inversely related to the hazard profile.</p>
<h2>Part E is where the market stops being one market</h2>
<p>The 42 substances in Part E are the quietest and most consequential part of the regime. Being listed is not a ban. The list’s function is to make those substances the ones against which a national authority may weigh whether a materially less risky alternative is available before it grants an authorisation.</p>
<p>The moment that assessment exists, an approval in the Union stops being a Union status and becomes 27 national decisions with 27 different answers, taken against 27 different national crop profiles, 27 different resistance situations and 27 different political temperatures. A product can be authorised in Spain and unavailable in Denmark. A distributor’s catalogue stops being a catalogue and becomes a country-by-country permitted list.</p>
<p>This is the thing a reduction target could never have done. A target is a number the whole bloc moves toward together and can trade against. A comparative assessment is an administrative event that happens one substance at a time, in one country at a time, with no headline attached. The tonnage falls, the pesticide-reduction law is withdrawn, and nothing that anyone can point to as a policy explains the fall.</p>
<h2>What that does to the shape of a supplier</h2>
<p>Two structural consequences follow, and both are visible in who earns money in the category.</p>
<p><strong>A registration is a liability, not an asset.</strong> It has to be renewed, defended and, where a Part E listing applies, re-argued against alternatives that may be newer and lower-hazard than the incumbent. A portfolio of 244 possible substances across 27 jurisdictions is a maintenance cost that compounds, and it explains why consolidation in the sector has been driven by the ability to carry a dossier rather than by the discovery engine. The largest players are the ones who can amortise regulatory affairs across the widest product range.</p>
<p><strong>The growth category has an operating problem, not a regulatory one.</strong> A microbial active is a living organism. Its dossier is lighter because the hazard package is lighter, which is exactly why 30 of the 51 low-risk slots are microbial. But the product is alive: it has a shelf life, a viability curve, a field-consistency distribution and a fermentation supply chain whose capacity is not interchangeable with a chemical plant’s. Which pushes value out of the active and into formulation, stabilisation and distribution — and means the most defensible business in European pest control may well own no active substance at all.</p>
<h2>Where I am refusing a number, and why</h2>
<p>This article does not give a market size for insect pest control, and the omission is deliberate rather than an oversight. “Insect pest control” is at least four unrelated purchases: crop protection chemistry sold to a grower per hectare per season; public-health and vector control sold to a municipality as a programme; structural and turf pest control sold to a facilities manager as a recurring service; and household insecticide sold to a shopper as a can. Four buyers, four margins, four replacement cycles, four regulatory regimes. A single aggregate would be arithmetically valid and analytically useless, and it would conceal precisely the thing that matters — that the same molecule can be a regulated agricultural input in one of those markets and a consumer product in another.</p>
<p>Nor is the tonnage a proxy for pest control activity. Eurostat measures tonnes of active ingredient sold. It does not measure hectares treated, applications per season, or efficacy. Microbials and semiochemicals are typically applied at different rates and with different frequencies from the incumbents they replace, which means a falling tonnage and a stable treated area are entirely compatible — and quite likely.</p>
<h2>The point</h2>
<p>The 292,000 tonnes is not a reduction in pest control. It is a reduction in the weight of the chemistry used to do it, produced by an approval regime that no one voted for, no one announced, and no one can repeal in a single act. The pest pressure has not changed. The docket has.</p>
Frequently Asked Questions
Does the EU still have a binding pesticide reduction target?
No. The Commission formally withdrew the Sustainable Use of Plant Protection Products Regulation (COM(2022)305 final) in its notice of withdrawn proposals C/2024/3117, approved at its 2488th meeting on 27 March 2024, on the ground that no agreement was foreseeable after the European Parliament rejected the proposal and Council discussions stalled.
How much pesticide does the EU sell each year?
Around 292,000 tonnes in 2023, the lowest level since Eurostat's series began in 2011 — down 9% on 2022 and 18% on 2021. Fungicides and bactericides were 39% of the volume, herbicides 36% and insecticides and acaricides 17%, which equates to roughly 49,640 tonnes of insecticide and acaricide active ingredient.
How many active substances are approved for use in the EU?
244 as of 1 May 2025, of which 36 are microbial. A separate low-risk list holds 51 substances, of which 30 are microbial, and 42 substances are listed as candidates for substitution. The figures come from the Commission's own advisory group update of 16 May 2025.
Why does this article not give an insect pest control market size?
Because the phrase covers at least four unrelated purchases: crop protection chemistry sold per hectare to a grower, public-health vector control sold as a programme to a municipality, structural and turf pest control sold as a recurring service to a facilities manager, and household insecticide sold to a shopper. They have different buyers, margins, replacement cycles and regulators, so a single aggregate would conceal the thing that matters.