Politicians from all sides are being urged to fix the mess surrounding plant protection products (PPPs) and seed trade between Great Britain and Northern Ireland to prevent irreparable harm to its small but important crop production sector.

There is a feeling in Northern Ireland that the political decisions surrounding Brexit were made with little regard for the potential impacts on agriculture.

See also: The rules for legal storage of pesticides on farm

One person who is unhappy about this dereliction of duty is Bruce Steele, an agronomist and former owner of merchant DBS Farm Supplies.

He is deeply concerned about the dwindling access to pesticides and seed for his client base.

Bruce says regulatory divergence with GB and more complicated processes bringing PPPs into NI – compounded by its ag-chem market representing just 1.3% of UK sales – is already resulting in fewer products for its crop producers.

“I’m aware of some cereal herbicides no longer being offered to Northern Ireland growers, and there are rumours that some fungicides won’t be coming to Northern Ireland in the near future either,” says Bruce.

“It’s the perceived hassle of offering such a small amount of product to our region that is causing it, particularly if the timing of EU registration or re-registration does not coincide with products coming to the GB market.”

Bruce Steele © Adam Clarke

Regulatory divergence

Janet Williams, Bayer’s senior regulatory science manager for the UK, Ireland, and Nordics, tells Farmers Weekly that it is the increasingly different timelines and processes that are causing the most hassle for manufacturers.

Currently, there is no active substance renewal programme for GB that reviews existing PPP active substances periodically, unlike the EU’s regulatory system, which is functioning, although with significant delays.

If and when an active substance is reapproved in the EU, end points – conclusions made by the regulator – often change.

This means manufacturers must submit an Article 43 renewal application for any product containing the active substance to take account of the new end points and maintain market access.

As Northern Ireland remains within the regulatory orbit of the EU, its use of crop protection products must comply with any active substance or product amendments made in Brussels.

This means UK regulator HSE-CRD – the body responsible for approvals for Great Britain and NI – is having to grant separate approvals for GB, NI, and some cases, combined GB and NI approvals where there is alignment.

When a product requires an NI-only product approval to stay compliant with the EU, it must have a separate label.

“As a company, we can’t simply have a separate line for Northern Ireland, as the additional costs and more complicated logistics for such a small market aren’t viable,” notes Janet.

Crop assurance

Theoretically, growers could fill product gaps by shipping from the Republic of Ireland, and this has been suggested as a solution by EU officials.

But with crop assurance schemes in NI requiring growers to use products with an HSE-CRD-granted MAPP number, a grower could potentially fall foul of compliance rules by doing so.

Integrated pest management (IPM) has long been promoted by organisations like the Voluntary Initiative, which Bruce champions in NI, and is now embedded in farm support payments as a way of reducing reliance on PPPs.

However, he points out that in some seasons – particularly in NI’s damp maritime climate – non-chemical techniques might not be sufficient, so maintaining strong PPP availability is key to an economic IPM approach.

“It cannot be achieved without the use of the proper tools. Plant protection products must work in partnership with IPM goals and objectives,” he adds.

Bayer, along with other manufacturer members of the industry body CropLife UK, warned of the potential issues related to PPPs in the wake of the 2016 Brexit referendum, but those warnings largely fell on deaf ears.

CropLife UK members continue to work hard to find a solution, and one action could be a separate text box on product labels detailing any specific NI-only conditions of use.

This would help manufacturers overcome the current problems at little extra cost, resulting in the smooth supply of products from GB to NI, as was the case before the UK left the EU.

“As an industry and as individual companies we are constantly challenging HSE to try to maintain access to PPPs in Northern Ireland,” says Janet.

Seed problems

And it isn’t just PPP availability that is causing headaches for NI arable producers.

The more complicated and bureaucratic task of importing seed from GB is starting to limit variety choice, particularly for winter crops, and is a significant part of why Bruce sold his merchant business two years ago.

Before Brexit, he would speak to his GB supplier – who he had been dealing with for almost 30 years – at harvest, discussing winter barley and winter wheat variety performance in the field and AHDB trials.

He would then make a list of the best varieties for his growers, choose seed treatments, and once the seed crops were harvested, they would be processed, bagged, and shipped to Belfast.

The whole process took about six days.

Now, under Organisation for Economic Co-operation and Development (OECD) rules, a shipped tonnage must be agreed in June or July before the supplier can apply for an OECD seed lot number.

Only one or two varieties of each crop are now offered.

Seed inspection

Once the seed is harvested, processed, and bagged, only then can the supplier apply for an Animal and Plant Health Agency Phytosanitary Certificate, which requires an inspection.

Samples from the inspection are then sent to Niab in Cambridge for testing and a hard copy of results sent back to the seed processing plant.

The supplier then applies for the second stage of the Phytosanitary Certificate, along with a second layer called the Northern Ireland Plant Health Label, which guarantees that the material will stay in NI.

When arranging haulage, the receiving party must also submit a Common Health Entry Document for plants and plant products (CHED-PP) ahead of the seed arriving in Belfast.

After the seed finally arrives at its destination and is put into storage, the customer then has to submit a supplementary customs declaration.

Increased bureaucracy

As well as adding multiple layers of bureaucracy, the whole process – from initial discussions with the GB supplier to delivery in NI – now takes three to five weeks, instead of the six days pre-Brexit.

With seed required within days of fields being cleared of the previous crop, it has become almost impossible to rely on the delivery of fresh certified seed from GB for autumn sowing within the current system.

Some merchants are gambling on purchasing seed stock early without a guarantee of sale, and some are even storing seed over the year to ensure supply the following autumn, but this has obvious impacts on seed health and germination.

Unlike with PPPs, growers in Northern Ireland are free to source seed from the Republic of Ireland, but Bruce points out that NI growers are AHDB levy payers and want to take advantage of the Recommended List system they buy into.

“What I find galling about all this bureaucracy is that the EU’s standards on plant health, including germination and foreign species such as wild oats, are all lower than the UK’s seed certification scheme.

“Indeed, for years, my customers preferred me to source seed from GB seed houses rather than from the Republic of Ireland, as it was a widely held perception that weed seed contamination in seed from the Republic was more likely,” he explains.

Restricted choice

The consequence is that NI growers are severely restricted in the varieties they import and grow from GB, with one seed supplier seeing NI sales slip from 10% to 2% of its total sales since 2021.

Bruce says the PPP and seed restrictions that are being placed on farmers and associated businesses could make NI crop production unviable, particularly smaller areas of field veg and horticultural crops.