Until the future relationship with UK and the EU is determined, we need to remain aware of what is going on in Brussels with regard to any legislative changes that might affect the pest management sector.
Europe's Green Deal
The European Commission recently unveiled their Work Programme for 2020, outlining the ambitions of the Commission for the coming year.
The Work Programme focused heavily on the Green Deal, which highlights a "chemicals strategy for sustainability" which will be expanded upon later this year.
The strategy is set to include changes to legislation to reflect the latest scientific evidence on the risk posed by endocrine disrupting chemicals (EDCs), chemicals in articles, combination effects and very persistent chemicals.
The document insisted on the Green Deal as a guiding principle for all of the Commission's actions in the coming year.
While the detail is yet to be finalised, as a sector we need to be aware that challenges to the products we regularly use will continue.
As this happens we need to ensure that everything is done to support the need for products to be retained and we must also be ready for the loss or retraction of use of many products, as we have already seen happening.
Demonstrating that we are a professional sector - that needs these products in order to do a professional job - is vital.
That's why, working with CEPA, we have developed the Memorandum of Understanding.
The aim is to get as many signatories as possible, to build a consensus on what professional pest management looks like.
Chemical registration outside the EU
BPCA Technical Manager, Dee Ward-Thompson, attended a Health and Safety Executive (HSE) event about the future of chemicals after the Brexit transition period ends.
The UK Government has already expressed an aspiration for us to be a clean country, but without following the EU’s current processes.
What that trade deal with the EU looks like will determine what chemical regulation we will have next year.
What happens next will depend on any trade deal negotiated with the EU, which is set to go live on 1 January 2021.
What that trade deal with the EU looks like will determine what chemical regulation we will have next year.
Dee said, “The key message from the talk is that chemical regulation has to be different to the EU system; otherwise, what was the point of Brexit?
“The worst-case scenario seems to be UK-only Registration, Evaluation, Authorisation and Restriction of Chemicals (UK REACH).
“This means that all chemicals will have to go through a UK-specific registration programme to have access to our market.
“A chemical manufacturer in attendance has estimated that it will cost £70m for its products to go through UK REACH, even if it already has EU REACH.
“Key business decisions will have to be made by chemical companies and the pest management sector is relatively small.
“In short, we should plan for divergence.”
After 1 January 2020, Northern Ireland will stay aligned with the EU, while the rest of the UK won't. This in itself will potentially cause issues with the sale and use of chemicals.
Dawn Kirkby, Senior Regulatory Manager for member company Rentokil Initial was also in attendance. She said:
"Time is the biggest issue. The transition period is due to end in less than a year, and the negotiations are complex.
"For example, EU REACH took 10 years to negotiate and that is only one piece of regulation.
"Due to time constraints, there will be trade-offs: Are chemicals a priority?"
Movement of goods
Another big issue will be transportation; products can freely travel now, but it’s expected that from 2021 that won’t be the case.
This will have an effect on route planning and invariably, pricing.
Dee explains, “A lot of businesses have what’s called a just-in-time (JIT) supply chain; this is when a firm looks to cut costs by having limited goods or materials in stock, producing and delivering those goods just in time to be sold.
“Transport issues could cause delays, which will cause a large disruption in general but especially to those businesses operating on a JIT basis.”
Looking forward
The director of the Chemical Business Association expressed a concern about the future of chemicals and the cost for registration.
Dee says, “Individual companies will be making their preparations, however, it’s clear from the update from HSE that there is a significant drive for the system to be different to how it is now.
“This does not necessarily mean making it better and is likely to be very frustrating. UK REACH would be very expensive and potentially disruptive to our supply chain.
“There are questions to be asked. If you have EU REACH, will chemical manufactures bother with UK REACH as it’s such a small market?
“Ultimately, authorities are going to wait for a trade deal, so we probably won’t know what the changes are until very late in the day.
“It’s highly unlikely that the UK government will stop pest professionals from doing their work, however, we need to prepare for the very real possibility that the chemicals in the products you need might not be legal next year, depending on the trade deal.”
Dee continued, “The overall message is they don’t know what the future looks like. There are plenty of risks to our sector.
“There were speakers from BASF, Chemical Associations, those who export and import chemicals into in the UK and HSE.
“The UK has had no chemical strategy since 1999, and now they think they need a new one. They started this process last year and we should hear the progress of this in Summer 2020.”
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