A/HRC/45/12/Add.4
15.
The data is obsolete. It should be noted that the exclusion of several active
ingredient monographs by Anvisa, according to the original reference, dated July 31,
20193, was not taken into account. It means 47 active ingredients of pesticides have been
eliminated and are no longer authorized in Brazil. Anvisa adopted this measure due to the
absence of registered products based on these active ingredients.
16.
Besides, the survey did not point out that some monographs of substances authorized
in Brazil and considered prohibited in the European Union are allowed exclusively for use as
a household cleaning agent or wood preservative, not being classified as pesticides, that is,
they are not authorized for agricultural use in Brazil. The European information bank used in
the consultation presents results for substances used exclusively as pesticides. Therefore, the
updated information would be the one described below, in the right column, adopting the
literal translation of the term used by the European Commission (approved or not approved).
It is noteworthy that this is dynamic data and should be updated periodically.
Cited reference information
Information updated by Anvisa on 7/31/2020
Of the 353 active ingredients authorized in
Brazil:
Of the 393 active ingredients authorized in
Brazil:
- 194 (55%) are AUTHORIZED in the
European Union;
-277 (70%) are approved in the European
Union;
- 155 (44%) are FORBIDDEN in the EU.
- 116 (30%) are not approved in the EU.
- 22 (14,2%) of the forbidden substances are
BANNED in Europe.
Anvisa (2020).
17.
It is essential to clarify that the non-approval of an active pesticide ingredient in a
given country can be associated with several reasons, not necessarily resulting from a
restriction related to risks to human health. Local characteristics related to the type of
cultivation, the climate, and the pests faced in the field can be decisive to define the real
needs for agricultural practices in each country. Eventual environmental impacts can also
cause restrictions to minimize risks. Failure to comply with all legal requirements may
prevent the registration or renewal of the use of an active ingredient in a particular country.
18.
In this sense, it is noted that it is inappropriate, in technical terms, to mention the
information in item 30 of the draft without considering the entire context linked to such
mention.
19.
One must also consider the amount in which each of these active ingredients is being
marketed in Brazil.
20.
Data from the pesticide marketing report issued by Ibama for the year 2018 show that,
of the ten most commercialized active ingredients in Brazil, which correspond to about 71%
of the volume of pesticides sold in the country, all are approved in the United States, and
only three are not approved in the European Union. Of these, two were recently reassessed
by Anvisa and obtained a series of measures to mitigate health risks.
21.
In the last ten years, thirteen active ingredients of pesticides were reevaluated, of
which eight were banned in Brazil, and several restrictions have been established to mitigate
the identified risks. On August 26, 2019, Anvisa published a new list of pesticide ingredients
that will undergo the toxicological reassessment process. This list was defined through an
objective assessment, the score based on hazard and risk criteria, to identify pesticides with
reassessment priority.
22.
The list, drawn up with broad participation from society, was established based on
danger and risk to human health. The choice of criteria prioritized the risks to consumers and
rural workers.
3
4
https://contraosagrotoxicos.org/wp-content/uploads/2020/02/AGROTOXICOS-BRASIL-UE-JUL2019.pdf
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