Document jmaEy7mwKp3meoNXOgeqmEBXR

Crop Protection socio economic argumentation - maintaining sufficient modes of action are fundamental to sustain weed management in important European agricultural cropping systems Table of Contents The role of fluorinated agrochemicals in resistance management ...................................... 1 The agronomic impact of a loss of fluorinated agrochemicals in the EU............................. 1 Cereal Herbicides .............................................................................................................. 2 Corn Herbicides ................................................................................................................. 3 Literature ........................................................................................................................... 4 The role of fluorinated agrochemicals in resistance management Fluorinated active substances cover different indications such as herbicides, insecticides/acaricides, fungicides and nematicides and offer potent modes of action that are critical in effective and complementary pest management. Resistance to chemical pesticides in all indications is considered extremely serious globally and is an increasing problem for food production. Therefore, an effective resistance management strategy is mandatory. Regardless of numerous research programs, only a few new modes of action have entered the market in the past 30 years. Maintaining and rotating, let alone reducing the limited pool of agrochemicals with different and new modes of action is therefore key to not significantly endanger the sustainability of agricultural productivity, as simply no alternatives might be available dependent on the pest control segment. Indeed, without adequate plant protection products, yield can be reduced already today by on average 16% by diseases, 18% by insects and 34% by weeds (Oerke, 2006). In addition, globalization and climate change are redrawing the landscape of plant pest distribution. For instance, 50 to 100% increase in pest-induced crop losses in European wheat should be anticipated even if countries meet their existing commitments to reduce greenhouse gas emissions (Deutsch et al. 2018; Ogawa et al. 2020) Adequate and sufficient pesticide mode of action options need to remain available to face this dynamic and to sustain agricultural productivity. The agronomic impact of a loss of fluorinated agrochemicals in the EU Loosing fluorinated agrochemicals would have a severe impact across all sectors of Crop Protection industry with the loss of key actives and Modes of Action (MoA), drastically reducing the resistance management options available for EU growers. The herbicide sector would see the loss of 15 active substances (AS), impacting the availability of substances in 7 MoA groups and the complete loss of 1 MoA. Expert judgement on the interaction between inherent resistance risk factors and resistance modifiers suggest that for plant protection product (PPP)/ target interactions considered medium risk at least 3 MoA are needed, whilst for scenarios considered high risk then a minimum of 4 MoA would be needed for sustainable pest 1 management (Rotteveel et al. 2011). Further losses of AS and MoAs would exacerbate the resistance risk much more on the remaining chemistries. The occurrence of weeds is a major constraint to agricultural production, causing significant agronomic damage and economic losses. In conventional cropping systems weed populations are most commonly managed with herbicides, although non-chemical methods are also an essential component of Integrated Weed Management (IWM) strategies (Bayer, 2016; Moss, Ulber and den Hoed, 2019). Repeated applications of herbicides with similar MoA cause a strong selection pressure on target weed populations with the consequence that numerous cases of herbicide resistance have evolved worldwide (Powles and Yu, 2010). By September 2023, resistance had been confirmed in 269 weed species in 99 different crop types in 72 countries, affecting the efficacy of 167 different herbicides from 21 known herbicide sites of action (Heap, 2023). The single active ingredients are assigned to their respective herbicide mode of action group (MoA group) as defined by the Herbicide Resistance Action Committee (HRAC). In their revised classification system, which is used in most countries worldwide, there are 34 different herbicide MoA groups (HRAC, 2023). The HRAC MoA groups, their individual active ingredients and mixtures can be classified by their resistance risk - high/medium/low/very low risk. Any loss of single active ingredients and/or complete MoA groups endangers a mid to long term sustainable agricultural production system. Cereal Herbicides Cereals, with a cropping area of ~740 mio ha (2021) worldwide, are the most important crops for the global food production. Different plant families appear in different regions and crop production systems. Most important and most difficult to control are Poaceae which evolved already 77 resistant species (Moss, 2017), with Lolium rigidum Gaudin (rigid rye-grass) the world's worst herbicide-resistant weed, exhibiting resistance to 12 different herbicide MoA in 12 countries (Heap, 2023). Only a few active ingredients from 4 MoA classes are available for effective weed management systems in winter cereals in Europe - 2(3) MoA (group 3, (5) and 15) for autumn use and 2 MoA (group 1 and 2) for spring use. The adoption of minimum tillage practices is one of the major pillars of regenerative agriculture and are required to mitigate climate change. These practices forced the pressure on the different weed management solutions with increasing weed coverage and increasing germination flushes of e.g., Lolium spp., Alopecurus myosuroides, Apera spica-venti, Bromus spp. etc. Such conditions need an effective weed management system of mixtures and sequence applications of different grass active MoAs, because herbicides resistances in rye-grass and blackgrass to group 1, 2, 3, 5 and 15 are already widespread in European countries. The complete loss of the inhibition of VLCFA (MoA group 15) mode of action in autumn would have a tremendous impact on the early autumn weed competition with cereal crops. Without reduction of an early grass weed infestation, the yield will be already negatively affected, and the effectiveness of available spring solutions reduced (Menne and Hogrefe, 2012; Menne et al., 2012). The complete loss of the inhibition of Phytoene Desaturase (MoA group 12) as MoA in autumn cereals would have an impact on overall dicot weed control strategies as this MoA is important for control of species which should not be left uncontrolled until spring (i.e., Matricaria spp, Papaver spp., Viola spp., Veronica spp.). The loss of the inhibition of Phytoene Desaturase MoA would dramatically impact the resistance management and control of these species and leave no effective autumn herbicides in markets with those dicots weeds. Important countries 2 include here e.g. France, Spain, Italy, Romania, Poland, and Germany. Only limited options would be left with auxine herbicides (MoA group 4) in spring, whereas a negative yield impact is already set due to early competition for water and nutrients. Corn Herbicides Corn as C4 plant is a spring growing crop which needs warm and sunny climate environments. The crop is sensitive to early weed competition for light, water and nutrients. The germination of a broad spectrum of grasses and dicot weeds, in several germination flushes, is the key challenge for effective weed management systems. Several active ingredients are available for weed control, however only from a limited number of MoA groups - 2 MoAs (group 5 and 15) for mainly soil and residual activity and 2 MoAs (group 2 and 27) for mainly leaf activity (Kuhlmann et al., 2020). The loss of any of these MoA groups increases the selection pressure on the remaining solutions. Without the important active substances of the MoA group 27 the pressure on the remaining acetolactate synthase (ALS) inhibiting products would increase to give broad spectrum post-emergence grass and dicot control. The selection of resistances to group 2 and 5 causes already increasing problems, especially for the control of e.g., Echinochloa crus-galli, Setaria viridis, Amaranthus retroflexus, Chenopodium album. The currently still available post-emergence diversity of 4-hydroxyphenylpyruvate dioxygenase (HPPD) inhibitors (group 27), ALS (group 2), and photosystem II (PSII) inhibitors (group 5) chemistries in corn, followed by chloroacetamides applied in pre-emergence, has largely kept resistance to a lower extent but is now also an increasing problem in Europe (Heap, 2023). The regulatory impacts on existing pre-emergence and post-emergence active substances and the PFAS restriction proposal could leave growers with very few options in future, in particular in important corn countries like France, Germany, Spain, Italy, Romania, Hungary and Poland. The two examples above illustrate, how complex sustainable weed resistance strategies are. Subsequently, the socio-economic impact of the PFAS restriction for active substances in crop protection would be very complex and may need to be performed on Member State level. It will be practically impossible to consider all these aspects under REACH as vertical legilsation. Furthermore, all individual uses of each active substance of plant protection products are evaluated under Regulation (EC) No 1107/2009 on national level. For authorization of active substances in plant protection products an extensive data package has to be generated. The risk assessment under Regulation (EC) No 1107/2009 addresses also the long-term environmental fate of each individual use. In case potential concerns by regulators would remain after a very thorough risk assessment process, a comparative assessment can be applied for each use in each crop on national level e.g., also evaluating the resistance risk and the option to replace a herbicide by mechanical weed control options. An additional PFAS restriction with subsequent evaluation of an essential use on the level of the active substance would not increase the protection level of the environment but result in workload-intensive parallel evaluations of REACH related authorities and 27 competent authorities in European Member State currently evaluating all individual uses of a plant protection product according to thorough environmental risk assessments under Regulation (EC) No 1107/2009. 3 Literature Bayer, 2016. Integrated Weed Management. Guideline Brochure. Deutsch, C.A., J. J. Tewksbury,, M.Tigchelaar, D. S. Battisti, & S. C. Merrill, Increase in crop losses to insect pests in a warming climate. Science 31 Aug 2018:Vol. 361, Issue 6405, pp. 916-919,DOI: 10.1126/science.aat3466 Y. Heap, I., 2023. The International Survey of Herbicide Resistant Weeds. http:// weedscience.org/, Accessed date: 19 September 2023. HRAC, 2023. Herbicide Resistance Action Committee. http://www.hracglobal.com/, Accessed date: 19 September 2023. Kuhlmann, J., Khler, L., Warnecke-Busch, G., Wolber, D., Jring, T., 2020. Strategies for weed control in maize in water sensitive areas. Julius-Khn-Archiv, 434, 471-476. Menne, H, Hogrefe, Ch., 2012. Impact of multiple resistance mechanisms in black-grass (Alopecurus myosuroides Huds.) populations on the activity of cereal herbicides. JuliusKhn-Archiv, 464, 65-74. Menne, H, Laber, B., Kerlen, D., Beffa, R., 2012. Effectiveness of flufenacet in controlling resistant black-grass (Alopecurus myosuroides Huds.) - comparison of glasshouse and field trial results. Julius-Khn-Archiv, 434, 401-408. Moss, S., Ulber, L., den Hoed, I., 2019. A herbicide resistance risk matrix. Crop Protection 115, 13-19. Oerke C.E., 2006. Crop Losses to pests. Journal of Agricultural Science (2006), 144, 31-43) Ogawa, Tokunaga, E., Kobayashi, O., Hirai, K., & Shibata, N.Current Contributions of Organofluorine Compounds to the Agrochemical Industry. iScience 23, 101467, September 25 (2020),202, 1-53 Powles, S.B., Yu, Q., 2010. Evolution in action: plants resistant to herbicides. Annu. Rev. Plant Biol. 61, 317-347. Rotteveel, T., L. N. Jorgensen and U. Heimbach 2011- EPPO Bulletin 41, 432-438. Resistance management in Europe: a preliminary proposal for the determination of a minimum number of active substances necessary to manage resistance 4