A/HRC/43/44/Add.6 linguistic barrier, the overall environment of criminalization of migrants, the absence of a strong support for reintegration and the dire competition for the few available jobs, are underlying root causes that cannot be tackled with more criminalization.26 80. Bottom-up initiatives like the NO-CAP (No caporalato) label and ‘In Campo Senza Caporale’ (On the field without caporale) have to be applauded but strong public support needs to be provided in order to facilitate their scaling up and create the condition for accessible, just and organic food. 27 The Special Rapporteur looks forward to seeing the impact of the recent regional law of the Lazio Region (18/2019) on the fight against irregular labour and the exploitation of farmworkers through the institution of funds, and the establishment of an observatory and a digital system for the recruitment of farmworkers. It also establishes the identification of new criteria to define the appropriateness of payments and tasks. Comments: Figures included in paragraphs 81 and 83 are grossly exaggerated and not realistic. The text related to the use of pesticides is unacceptable. In fact according to official statistics from the Italian Ministry of Health and EU Commission data, the irregular presence of residues in food is only is 0.9% in Italy, i.e. a much lower rate when compared to the 2.5% average rate at EU level. Furthermore, it should be duly reflected that Italian standards with regard to pesticides and fruit preservatives are often stricter in Italy than in other European countries (several products are prohibited in Italy while allowed elsewhere in Europe). F. Use of pesticides and the Xylella fastidiosa disease 81. The annual report of environmental association, Legambiente, has shown that 0.6% of fruit and vegetable products marketed in Italy contain illegal levels of pesticide residues, equivalent to one for every 200 samples analysed. According to 2012 data, products which are contaminated by only one residue amount to 18.3%, while those having multi-residue are 17.1% and an increase in the number of different chemicals which are simultaneously present in a single sample is registered28. Nevertheless, in the latter case, very often the sample is declared to be regular, since the quantity of each residue respects the law limits, however, it could potentially be very damaging for the consumers’ health and the environment. Data points out to the need to develop new laws that address the alarming situation particularly in terms of products containing multi-residue. Preventive measures should be designed by the Government to guarantee the safe consumption of agricultural products by unaware consumers. Comments: This reference (legambiente, 2012) is quite old. We suggest the to refer to the last report (Legambiente, 2019) https://www.legambiente.it/wpcontent/uploads/dossier_stop_pesticidi_2019.pdf. We suggest to re-edit the whole paragraph on the basis of the new reference. We must stress anyway that Legambiente is a NGO and not a Public Body. This can influence the interpretation of complex phenomena like the ones related to the use of pesticides. Here we propose an alternative text based on the new report (2019): According to the annual report of environmental association, Legambiente (2019, in 2017 have been performed official controls of residues of plant protection products on 9,939 samples of food, of Italian and foreign origin, labeled as produced from non-organic agriculture. According to the Report, the analyzes show a low percentage of irregular 26 27 28 14 Amnesty International (2019) I sommersi dell’accoglienza. See http://www.nocap.it; http://www.terraonlus.it/in-campo/. Pesticidi nel Piatto – Legambiente 2012.

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