Pesticides used in agriculture can contain many ingredients that are not well known and may be unsafe to humans and the environment.
Proposed Ministerial Order to Prohibit 30 Substances of in Pesticides
Mr. Tetsuro Nomura, Minister of Agriculture, Forestry and Fisheries
To: Agricultural Safety Management Division, Consumption and Safety Bureau, Ministry of Agriculture, Forestry and Fisheries
20 October 2022
From: Consumers Union of Japan (CUJ)
Co-Chairperson: Ado Kameyama
Co-Chairperson Miyoko Sasaki
Co-Chairperson Martin Frid
Regarding the Proposed Ministerial Ordinance to list and ban the use of 30 auxiliary ingredients of agricultural chemicals in the Standards for Refusal of Registration under the Agricultural Chemicals Control Law:
We, Consumers Union of Japan, are a consumer organization working for the safety of food and agriculture, and the safety and security of our daily lives. We believe that there are several problems with the Ministerial Ordinance to Provide for Cases Specified by Ordinance of the Ministry of Agriculture, Forestry and Fisheries and the Ministry of the Environment under Article 4, Paragraph 1, Item 11 of the Pesticide Control Act (12 October 2022), which was presented by the Ministry and for which public comments were solicited.
We hereby petition for reconsideration and improvement as follows:
1. Proposal to Include 30 Auxiliary Ingredients of Agricultural Chemicals in the Criteria for Refusal of Registration
(1) CUJ is opposed to the proposal to include 30 auxiliary ingredients of pesticides in the Criteria for Refusal of Registration if they account for 0.1% or more of the total weight of the pesticide. We demand that none of them shall be detected and that their use in small quantities also be prohibited.
(2) CUJ opposes the enforcement date of 1 October 2025. If the law comes into effect three years later, some of the pesticides (preparations) currently on the market will contain these 30 auxiliary substances, and they will still be on the market. This could lead to a “rush to market” by manufacturers and distributors, and the continued use of pesticides even though it is known that they contain toxic auxiliary ingredients. The ministerial ordinance should be enforced immediately after its enactment.
(3) In addition to including these 30 auxiliary ingredients in the Standards for Refusal of Registration, we demand that the Standards for Refusal of Registration be applied to pesticides containing these ingredients that are currently being sold and used, and that all pesticides containing these 30 substances be promptly suspended or prohibited from use. This should result in their immediate recall from the market, and the cessation of their use, including in farmers’ inventories. It is unacceptable for pesticides containing toxic auxiliary ingredients to continue to be released into fields and the environment (It is well known that pesticides cause air pollution, soil contamination, and pollution of rivers, lakes, marshes, and the sea). A total ban on the use of pesticides (preparations) containing these auxiliary ingredients themselves should be promptly adopted.
(4) CUJ is opposed to the transitional measures that will allow registration until the enforcement date, that will allow the registration of pesticides using these banned auxiliary ingredients, as well as their sale and use until their expiration date (generally said to be 5 years). Under the five-year grace period, pesticides containing 30 carcinogenic and other toxic ingredients will continue to be sold and used for almost five years. It cannot be denied that these 30 auxiliary ingredients are carcinogenic, chronically toxic, and having toxic effects known as endocrine disrupters or environmental hormones even at trace amount levels. They should be enforced immediately without transitional measures.
(5) CUJ demands that the trade names of the pesticides (formulations) currently on the market (including farmer-retained products) that use the 30 auxiliary ingredients be listed and made public immediately. The current labeling on pesticide containers and packaging only lists type and amount of auxiliary ingredients. With descriptions such as “surfactant” or “emulsion” as the type, it is not possible to determine whether these 30 toxic chemicals are included or not. The “right to know”, “right to choose”, and “right to be safe” of users, consumers, and citizens who may be exposed to pesticides when using them, such as farmers, users in non-farming areas, home gardeners, and residents living near areas where pesticides are sprayed, should be ensured.
(6) CUJ demands that all applicable pesticides (formulations) be required to display a warning label with product names.
(7) CUJ demands that administrative guidance to encourage the recall and suspension of the use of these products be thoroughly strengthened as mentioned above.
2. Future Criteria for the Refusal of Registration and Review of Agricultural Chemicals
(1) The 30 auxiliary ingredients of pesticides proposed this time are substances with extremely high toxicity, such as carcinogenic substances, which will be included in the Standards for Refusal of Registration based on scientific data, and their use will be prohibited. We request that the toxicity of auxiliary ingredients other than the 30 substances be promptly investigated and that substances with relatively high or moderate toxicity be promptly included in the Criteria for Refusal of Registration.
(2) In the Materials to be submitted in applications for registration of agricultural chemicals (17 August 2021), the materials to be submitted as Test Results on Effects on Humans are still mainly related to active ingredients of the pesticide ingredients, and the overall toxicity of the pesticide (preparation) is not included. Thus the overall toxicity of the pesticide (formulation) is limited to acute toxicity. Test results for auxiliary ingredients are not required to be submitted. In the future, we request that test results on chronic toxicity, carcinogenicity, neurotoxicity, developmental neurotoxicity, etc. of pesticides (preparations) be included in the submission materials, paying attention to the toxicity of auxiliary ingredients as well.
(3) We should not use chemicals that require gas masks in the cultivation process of producing food. On the other hand, with regard to many pesticides, such as neonicotinoid pesticides and organophosphorous pesticides, for which there is already scientific evidence showing health effects and a ban on their use has been suggested, the precautionary principle should be proactively adopted. CUJ is of the opinion that highly hazardous pesticides and substances that may be endocrine disrupters should be promptly banned.
Original post (in Japanese):