Pesticides Stakeholder Group minutes: April 2025

Attendees and apologies

Chair

• Jackie Hughes, Scottish Government

Attendees: 

• Gillian Reay, Scottish Government
• Katie Viezens, Scottish Government
• Debbie Kessell, Scottish Government
• Romy Strachan, Scottish Government
• Alison Knox, Scottish Government
• Calum MacLeod, Scottish Government
• Sacha White (Agiculture and Horticulture Development Board, AHDB)
• Andy Steven (Agrovista)
• Hazel Doonan (AIC)
• Miryana Mckay (Angus Growers)
• Ian Graham (Amenity Forum)
• Amy Geddes (Scottish VI and Cereal Farm Representative)
• Gaynor Malloch (James Hutton Institute)
• Alison Lees (James Hutton Institute)
• John Flanagan (NFUS)
• Greg Dawson (Scottish Agronomy)
• Darrell Crothers (SEPA)
• Dave Bell (Scottish VI)
• Neal Evans (Voluntary Initiative)
• Colin Palmer (Confederation of Forest Industries)
• James Nott (Scottish Forestry)
• Ian Ludgate (BALI)
• John Feege (Co-op)
• Kim Parker (Horticulture Crop Protection)
• Sarah Hathway (Soil Association)
• Gaynor Malloch (James Hutton Institute)
• Celine Delabre (Nature Scotland)
• Wayne Brough (Horticultural Trades Association)

Apologies:

• Jim Fairlie, Minister for Agriculture and Connectivity
• Jason Hubert (Scottish Forestry)
• Simon Conway (Horticulture Crop Protection)
• Teresa Dougall (Scottish Quality Crops)
• Fiona Burnett (SRUC)
• Tom Edwards (British Association of Landscape Industries)
• Devina Sankhla (British Retail Consortium)
• Grace Emeny (Horticulture Crop Protection)

Items and actions

Welcome

The Chair welcomed everyone to the meeting and gave apologies from Mr Fairlie, Minister for Agriculture and Connectivity.

It was noted that the main discussion for the meeting was to hear reactions to the UK Pesticides National Action Plan and that comments received will be passed on to the Minister and other relevant officials. 

Matters Arising 

The minutes from PSG12 (held on 5 December 2024) had previous been agreed and can be accessed at: Pesticides Stakeholder Group - gov.scot (www.gov.scot)

The updated Action Log was circulated to members prior to the meeting. In relation to Action PSG12-01 (the importance of metribuzin to crop sectors) the following comments had been received from the potato, wheat, and forest sectors: 

• the loss of use would mean more complex and expensive mixtures would have to be used in the potato sector. There would be an increase in the risk of resistance building up to the other actives by reducing the spectrum of herbicides that can be applied to potato crops and alternatives such as aclonifen may not always be an easy option for growers to work with.
• for wheat crops, removal would increase resistance pressure from weeds, with a particular concern in relation to blackgrass.
• for forestry, metribuzin is the most widely used residual herbicide in Christmas tree production, alternatives such as pendimethalin, isoxaben and metamitron may have poorer weed spectrums and require a tank mix with another herbicide, or a later post emergence herbicide.

Outstanding Action PSG12-02: the PSG Secretariat will contact colleagues from the Agriculture Reform Programme team to arrange attendance at a future meeting to discuss the Agriculture Reform Programme Tier II Enhanced.  

Scottish Government Updates

A Scottish Government written update was provided to the group in advance of the meeting. The following points were highlighted by the group in relation to this agenda item: 

• Metalaxyl-M: whilst the lifting of the restriction that limited use of Metalaxyl-M as a seed treatment only on seeds intended to be sown in greenhouses is encouraging, there are still no product authorisations that allow outdoor drilling of seeds treated with metalaxyl-M. Significant work is still required to demonstrate risk mitigation measures that would be acceptable for birds and mammals for a range of non-pelleted seed crops. HCP (Horticulture Crop Protection) is in contact with HSE to determine what mitigation measures (e.g. pelleting, precision drilling) and further data is required to demonstrate acceptable risk for certain vegetable crops, and how it can be generated. However, at the moment there will be a continuing need for Emergency Authorisations (EAs) for minor crops such as carrot, parsnip and red beet. 
• Flufenacet: Although at the time of the meeting, the EU results of voting on the non-renewal of flufenacet had not been published, it has been widely reported in the media that flufenacet would not be renewed. If, in future, the same decision was to be taken in GB, it was noted that this would cause significant impacts. It was noted that there is a lack of alternative pesticides in wheat, barley, and potato crops and those which are available are more expensive and less effective. In particular, loss of flufenacet would leave a significant control gap for grass weed control (particularly annual meadow grass) in cereals, including oats, an important crop for Scotland where options had been limited by previous EAMU changes. The resulting increased pressure on other herbicides would also heighten resistance issues, particularly in grass weeds. Flufenacet is used as a co-formulant in a range of pesticide products which would also be lost. AHDB has been doing some work on the potential loss of flufenacet in GB. There was no insight into the impact of potential loss of flufenacet in soft fruit production from members.
• Sivanto Prime (containing flupyradifurone) authorisation was welcomed. It was queried whether any information has been provided by Bayer (the manufacturer) regarding aphids which are resistant to neonicotinoids and potential cross resistance to this active substance.

ACTION PSG13-01: Group members invited to provide additional comments/information regarding the impact to their business sector (particularly flufenacet) to SG via the PSG secretariat.
ACTION PSG13-02: SG to contact HSE regarding any insight into potential resistance concerns with flupyradifurone during the authorisation process and report back to the group.  

UK Pesticides National Action Plan (NAP)

The Chair noted that SG has been reviewing media comments on the NAP since its publication and that it has been helpful to see initial views from organisations who attend the PSG. Generally, the document has been welcomed in relation to its main principals and sentiment. There are concerns from the farming sector regarding the balance of reducing environmental harms with actions to ensure sector competitiveness and address food security. The response from eNGOs has been positive with regards to the inclusion of a target and promotion of non-chemical control but also some concern on the ambition of the target and its focus being agriculture and not taking into account urban and amateur use, as well as not taking into account human health indices.  

It was noted that in the initial media reactions, there was a desire from all stakeholders to work together on the implementation on the NAP actions with this document being the start of the process and noting that cross-sector engagement is needed to achieve the actions in the NAP. For example, Defra will lead on the development of a UK-wide pesticide horizon scanning function, with input from a range of stakeholders. It will help identify pest control gaps and understand where alternatives are most needed, assess the impacts and identify mitigations. Scottish Government are keen that UK wide perspectives are fed in to this group and would welcome volunteers from the group to contribute to this work. 

The chair also highlighted that it is important to note that the NAP focusses on statutory obligations as set out in the Sustainable Use legislation and therefore does not cover regulatory reform. A review of the GB pesticide regime, including possible regulation reform options have been on-going, in parallel with the development of the NAP document, to consider ways in which the regime could work more efficiently and effectively as well as providing clarity and predictability for pesticide users and support better availability of crop protection tools.  

Many group members commented that they were disappointed that regulatory reform actions were not included in the NAP. More specifically, group members provided the following comments and reflections:

AIC commented

• more information would be welcomed on the vision for collaborating with stakeholders to deliver the eighteen actions in the NAP. Both delivery mechanisms and regulatory reform being elements that are missing from the current version of the NAP in comparison with the previous draft.
• regarding the UK Pesticide Load Indicator (PLI), there is a need to understand how it will drive forward change and what influence the PLI may have on future regulatory decisions. It was noted by the chair that the indicator itself was not a driver of change, but a measure of the impact of the actions in the plan.
• concern remained in relation to the monitoring and enforcement of buying of products on-line and how that could be improved in the amateur usage sector.  

ACTION PSG13-03: SG to invite colleagues working in the Defra pesticides evidence and analysis team to attend at a future PSG meeting to focus on the development and aim of the PLI.

Arable Farm Representative commented on

• concerns around how effective NAP progress monitoring would be with the PLI focus being solely on arable pesticide use and not considering other crop types or amenity/amateur use. SG gave assurance that work is already underway to consider whether data can be incorporated from other sectors but that, as arable pesticide usage accounts for 90% of pesticide use on crops, this data set currently had the greatest power to indicate statistically significant change over time.  
• concerns around lack of positivity of progress made by growers to date, and further losses of pesticide impacting on trade deals and potentially lower standard of imported crop being brought into UK. 
• concern about lack of funding sources for research for development of IPM practices and on farm measures from UK and Scottish Government to achieve the ambitions of the NAP. 

Scottish Agronomy highlighted

• the progress already made against some of the PLI metrics seemed to be mostly due to the withdrawal of actives, not an increase in IPM. If this was the forward assumption on target achievement it would present concerns whether environmental sustainability was achievable with the actions in the NAP.  The actions do not address the risks faced by industry around predicted control gaps for a number of pests and pathogens in some crops, particularly seed potatoes, where further pesticides losses will make crops uneconomic.
• disappointment at the non-inclusion of elements of regulatory reform. 
• in relation to enforcement of regulation, more support needed for growers, for example the need for HSE to providing additional guidance to growers when delivering enforcement notices for product disposal, in the absence of easily accessible disposal operators.
• the importance of retaining Plant Protection Products to ensure there are enough tools available to be sustainable. Biologicals are mentioned as an alternative however in broad acre/field scale arable production this has not proven to be a viable alternative to chemical control.
• if there are insufficient tools for conventional agriculture, there is an impact on the organic sector as resistance and disease prevalence increase. 

Agriculture and Horticulture Development Board (AHDB) commented 

• broadly welcome the NAP as it highlights areas such as progress made, the benefits of IPM, knowledge exchange, encouraging innovation and horizon scanning.
• regarding the role of biopesticides, it is recognised that there is potential, but significant work is required in relation to efficacy and utility in broad acre crops as well as encouraging growers to adopt biopesticides.  
• AHDB are planning to commission a piece of work relating to the use of biofungicides to control diseases in wheat (tender due to be published shortly).
• funding for applied research in these areas is extremely welcome important.
• Pesticide Load Indicator (PLI) was a positive and progressive step but noted a slight concern regarding how up-to-date the information was in the Pesticide Properties DataBase (PPDB).  
• IPM Plans – understand that the ability to implement IPM is a complex procedure. It would be helpful to be able to monitor the usage and implementation of IPM and understand how metrics would be measured in a more meaningful way beyond plan completion. 

Soil Association

• echoes the comments made regarding the ambitions and aim of the NAP, particularly in relation to the need to fund and support research, resistance solutions and the need for sustainable use of pesticides, as it is in everybody’s interest to drive a reduction in pesticide reliance.
• all farmers require the support and necessary tools to make them sustainable and profitable whilst delivering the NAP actions.
• NAP is a good start, but significant work and support on the actions needed in order to implement them.

Horticulture Crop Protection

• echoes the comments already made, particularly around the non-inclusion on regulatory reform.
• highlighted the importance of funding for applied research, which is currently limited in the horticulture sector and would aid the complex issue of implementing an effective IPM programme. 
• government investment needed to support industry, as in other EU countries, particularly France. Case studies overly simplistic. 
• decision support systems are valuable, but they need to be backed up by having crop protection tools in the tool-box. 

Voluntary Initiative

• echoes the comments already made particularly in relation to the omission of the role of the Voluntary Initiative and the Amenity Forum, both of whom were specifically mentioned in the previous NAP as drivers of IPM adoption. The current NAP does not reflect the work done over the last 15 years to drive IPM forward.
• closure of SFI to new applicants a barrier to progress in relation to adoption of IPM.

Amenity Forum 

• the sentiment of the NAP was welcomed however, there had been some disappointment within the amenity sector as it was hoped that amenity actions within the NAP would have been more substantial.  
• the reference to the importance of assurance schemes was welcomed but there remained a need for mandatory standards.
• management of existing products and alternatives must be carefully considered as these are important for an integrated system which is cost effective and efficient.
• the amenity sector would like to see more rigorous controls relating to clear mandatory standards and codes of practice.

Ornamental sector

• concerns relating to the availability of products. In 2025 70% of the products recommended for use were only available by EAMU which will be catastrophic for the industry if changes are made there. The sector has taken time and effort to working more effectively with other available products such as bio-controls and bio-pesticides.
• the Code of Practice for the Crop Protection for Plant Protection Use is approximately 20 years out of date and urgently requires to be updated.

Forestry sector

• has a low use of pesticides (rotation of between 40-100 years and only using pesticides as a spot treatment in the first couple of years). The sector is continuing to reduce its pesticide use.

Many members of the group raised the issue on the recent withdrawal of new entrant SFI applications in England and how, without this, delivery of IPM actions can be effectively supported. It was noted that as this is an England only scheme the SG are not able to comment.  

In response to a question about the Scottish Government position on gene editing and how that compared with the UK Precision Breeding Act: SG officials reported to the group that there had recently been a stakeholder meeting with the Minister and Cabinet Secretary in attendance. This initial conversation has allowed collation of a range of views that will be further discussed with Ministers.   

The Chair thanked members for their comments and stated that views would be shared with the Minister and colleagues in other governments across the UK.

Date of next meeting and close

The Chair thanked everyone for their participation and confirmed the next meeting will take place in June 2025 (date has now been confirmed as 5 June 2025). 

PSG Secretariat
April 2025