FRANCE: Provisional balance for 2019 PPPs sales

The Ministries of Ecological Transition and Agriculture have released a provisional balance for the sales of plant protection products in 2019. These figures come from annual declarations by distributors of plant protection products as part of the tax on diffuse pollution. These data still need to be consolidated by the autumn, in particular to refine their analysis as regards the different uses (herbicide, fungicide, insecticide), the types of products (CMR, biocontrol), and to complete by other indicators.


These provisional data show that:

– The total quantities of active substances sold in agricultural uses, excluding biocontrol products, decrease by 44% between 2018 and 2019 (- 28 078 tonnes), after an increase of 18% between 2017 and 2018 (+ 11 870 tonnes);

– The total quantities of products of very high concern sold (carcinogenic, mutagenic and reprotoxic – CMR) decrease by more than 50% in 2019 compared to 2018 ;

– The quantities of glyphosate sold decrease by 35% (- 3 358 tonnes) between 2018 and 2019 after an increase of 11% (+ 999 tonnes) between 2017 and 2018;

– The proportion of biocontrol products continues to increase, illustrating a progressive and continuous substitution of the most hazardous substances by these products.


However, the quantities of active substances sold do not reflect neither the quantity applied nor the period of application of the treatments. Indeed, the year 2019 was affected by climatic conditions that were particularly less favourable to the development of crop diseases compared to 2018, but also by the increase of the tax on diffuse pollution on 1 January 2019. Farmers therefore tended to stock plant protection products at the end of the previous year in order to anticipate this increase.

It is nevertheless important to note that the decreasing trend in the market for plant protection products and the increase in the market for products suitable for use in organic farming demonstrate the reality of the ongoing agricultural transition and the wish to substitute the most hazardous substances.


To download: 

Press release: Action Plan on Plant Protection Products and a less pesticide-dependent agriculture: significant drop in sales in 2019 (in French)


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FRANCE: Increase of the tax on the sale of Plant Protection Products

Further to the publication of the Order of 27 February 2020 repealing the Order of 09 March 2016, the rate of the tax applied to the sale of plant protection products is increased. Thus, for plant protection products which were the subject of an Authorisation or a parallel trade permit on 01 January of the tax year, the tax rate is increased from 0.2% to 0.9% of sales revenues for conventional products and is maintained at 0.1% for the products of the official biocontrol list.

This increase is the result of the raising of the rate ceiling set by the law 2019-1446 for the 2020 social security financing.

This tax is assigned to ANSES to finance the phytopharmacovigilance as well as the compensation fund for victims of pesticides.


To download: 

Arrêté du 27 février 2020 fixant le taux de la taxe sur la vente de produits phytopharmaceutiques (in French)

See also our previous articles: 

FRANCE : Tax on the sale of Plant Protection Products (Order 09 March 2016)


Lynxee consulting’s team is at your disposal to answer your questions.

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FRANCE: Order as regards the experimental use of pilotless aircrafts for pesticides spraying

The French Order regarding the implementation of the experimental use of pilotless aircrafts  for pesticides spraying was published on 08th October 2019 pursuant to Article 82 of the Agriculture and Food law, also called EGalim.

This Order sets the conditions of implementation of the trials performed as part of this experiment planned for maximum 3 years.


To download: 

Order regarding the experimental use of pilotless aircrafts for pesticides spraying (In French)


Our previous articles: 

FRANCE: Experimental use of pilotless aircrafts for pesticides spraying


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FRANCE: Experimental use of pilotless aircrafts for pesticides spraying

The agriculture and food law, also called EGalim law authorises the experimental use of pilotless aircrafts, for a 3-year period (October 2018 – October 2021), for aerial spraying of plant protection products authorised in organic farming or within in certified farms, authorised for aerial spraying,and limited to crop areas with a slope equal to or higher than 30% (article 82).

This experiment aims at assessing the benefits of the use of pilotless aircrafts for the limitation of work-related accident  and for the application of pesticides.

It should be implemented in accordance with the French regulation as regards pilotless aircrafts, in particular Orders dated 18 May 2018 and 17 December 2015.

The EGAlim law sets that the experiment should be assessed by Anses. The law also sets that the conditions and modalities of this experiment should be defined by a joint order signed by the ministers of environment, agriculture and health, to ensure that there is no unacceptable risk for the Health and for the Environment.


The draft Order was proposed for public consultation from 26 June to 17 July 2019. The public comments (in French), the synthesis of the consultation (in French) and the reasons for decision (in French) have just been published.


At the same time, after being seized on 23 May 2019 by the Managing Director for food, the Managing Director for Health and the Managing Director for the prevention of risks, Anses has published a scientific and technical support note as regards « the implementation of experimental use of pilotless aircrafts for plant protection products spraying » (in French).

In this note, Anses indicates which guidelines should be considered and also which key data should be collected so that the experiment could achieve its goals:

A – Work-related accident Risk assessment when using pilotless aircrafts for spraying.

B – Operator and other actors exposure assessment during the mixing, loading, spraying and cleaning phases.

C – Spray drift assessment with the material used and assessment of the environmental exposure.

D – Other relevant criteria in the framework of the experiment and its goals, such as spray quality and efficacy.


References :

Public consultation: Draft Order as regards the implementation of experimental use of pilotless aircrafts for pesticide spraying (in French)


Order of 18 May 2018 as regards the requirements applicable to pilots using pilotless aircrafts for purposes other than leisure (in French)

Order of 17 December 2015 as regards the use of airspace by pilotless aircrafts (in French)

Order of 17 December 2015 as regards the pilotless aircarft design, conditions of use and abilities of people who use them (in French)


Our previous articles:

FRANCE: New Agriculture and Food law published


Lynxee consulting’s team is at your disposal to answer your questions.

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LYNXEE launch a Newsletter: Regulatory News on Plant Protection Products!

Many of you appreciate our posts on regulatory news and we are delighted of it. Therefore we decided to go even further by publishing a monthly newsletter compiling all our posts.

The newsletter is in English but you can always find our articles in French on our blog.

So, if you want to:

  • keep up-to-date on French and European regulatory news,
  • easily inform your French- and English-speaking colleagues and partners,

Have a look at the 2 Newsletters already published:


FRANCE: UIPP launches a new website against stereotypes!

The UIPP (Union of Plant Protection Companies) has launched a new website entitled “ABC of crop protection” :

It aims to fight against stereotypes and misperceptions concerning plant protection products.

The UIPP proposes a complete and accessible primer and numerous articles which raise the main issues of plant protection products: environment, consumers, farmers, sectors…

A nice website!


EUROPE: PPPAMS, a new system to apply for authorisation of a PPP

Applicants who wish to have a PPP authorised in the EU must now submit their applications to Member States via the Plant Protection Products Application Management System (PPPAMS). 

This online system manages the workflow of applications and will populate an EU wide public database of authorised PPPs.

Dossiers are NOT submitted via the PPPAMS. The system does not replace other manual processes in Member States; it works alongside the other electronic and manual processes that Member States operate. Fees are also still paid at MS level.

The PPPAMS manages the workflow of applications, enabling applicants and Member States to communicate with each other through the application process, primarily by changing the status of the application.

The system can also send notifications for information and action based upon status changes through the application process.

For now, PPPAMS is only enabled for first authorisation of products and mutual recognitions.


Useful link: PPPAMS 


Lynxee consulting’s team, as a consultant, can take care of your applications on PPPAMS.

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EFSA: Data collection on exposure assessment scenarios for operator exposed to pesticides

EFSA issued in October 2014 a Guidance Document on the assessment of exposure of operators, workers, residents and bystanders in risk assessment for plant protection products (EFSA Journal 2014;12(10):3874). In this Guidance, new approaches are proposed to be used to calculate the exposure to PPPs. In addition, a way to assess resident exposure has been proposed according to the new requirements in the legislation. However, even though considering the most up to date available data for the assessment of non-dietary exposure to pesticides, many uncertainties still remain due to the complexity of this type of assessment and the scarcity of data. Therefore, it will be helpful for EFSA and the Member States to have available a comprehensive database of the non-dietary exposure assessments performed so far at EU level for the substances peer reviewed by EFSA, including all the key parameters, in order to: 1) identify critical issues not covered by the Guidance (e.g. use scenarios), 2) test the Guidance, and 3) identify the need of further research.

A compilation of a comprehensive MS Excel database with technical data from non-dietary exposure assessments performed at EU level for operators of PPPs was thus performed. The database as compiled contains information for 179 substances. The scientific report and the Excel database were published by EFSA on 24 July 2015.]

In the current project the work was focused on operator exposure assessments. However, due to the nature and structure of the database, the database can be easily adapted and expanded to also include worker and resident/bystander exposure assessments.

With regard to possible data gaps and needs for future research, the scientific report gives an overview of intended used labelled as ‘unusual’ with regard to their application method and/or application equipment for which NO exposure assessment was made based on one or more of the exposure models. Future research could focus on gathering exposure data/studies for these methods and or new model developments. The most frequent listed ‘unusual’ application methods concern seed treatment, soil injection/incorporation, gassing and fumigation.

Lynxee consulting’s team can adapt and develop exposure models for your intended uses not covered by standard models.

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Sanco 12184 (14 July 2015) on emissions of PPP from protected crops to environment

On 14 July 2015, the Standing Committee on Plants, Animals, Food and Feed agreed to postpone the application date of Guidance Document on clustering and ranking of emissions of plant protection products and transformation products of these active substances from protected crops (greenhouses and crops grown under cover) to relevant environmental compartments from (initially) 1 May to 1 December 2015 (Sanco/12184/2014 rev 5.1).

The full guidance, published in March 2014  (EFSA Journal 2014;12(3):3615), can be downloaded directly on EFSA website.

Moreover the new Greenhouse Emission Model (GEM) has been made available at

Lynxee consulting’s team is at your disposal to conduct the risk assessments of your products intended for protected crops.

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EFSA: Statement on the FERA guidance proposal (2012) on how aged sorption studies for pesticides should be conducted, analysed and used in regulatory assessments

The European Food Safety Authority (EFSA) Panel on Plant Protection Products (PPR) prepared a scientific opinion on the Food and Environment Research Agency (FERA) guidance proposal ‘Guidance on how aged sorption studies for pesticides should be conducted, analysed and used in regulatory assessments’ (2012).

The potential for the strength of soil sorption of a substance to increase over time (‘aged sorption’) is one of the phenomenon considered by applicants and notifiers when developing higher-tier approaches for leaching risk assessment. However, the procedures used to derive parameters to allow the inclusion of aged sorption as a higher-tier refinement for regulatory submissions are currently very uncertain, as demonstrated by the variety of different approaches employed for different substances.

FERA draft guidance was drafted in that context, based on the FOCUS (2009) guidance.

The review of the draft guidance by the Panel revealed that the experimental and modelling approaches described are reasonable compromises between the required effort and what is desirable from a theoretical point of view. However, the Panel has concerns about the interpretation of the experiments and how the results of the experiments should be used in the leaching assessment. The Panel investigated options for improvement, but could not complete its evaluation on these two topics because underlying data to test these options were not made available to the Panel. For this reason, the Panel prepared a statement instead of a scientific opinion. Therefore, the Panel cannot recommend the use of the guidance for the time being.

The Panel recommends an update of the current FERA draft guidance document, taking into account the conclusions and recommendations provided in its statement.

The Panel noted that the draft guidance document did not systematically review uncertainties arising from the use of aged sorption data in regulatory leaching assessments. Uncertainties may result from, for example, the experimental procedure (extraction procedures), the conceptual model and the quality of the fitted parameters. It is recommended that a systematic review of uncertainties is carried out when updating the draft guidance document.

This updated guidance document could be resubmitted to the Panel, together with supporting data, so that the Panel can finalise its review.