Study on the impact of proposed ban on list of 27 pesticides from the perspective of all stakeholders

On August 19, 2013, the Ministry of Agriculture assigned the job of reviewing 66 pesticides to an Expert Committee under the chairmanship of Dr. Anupam Varma. Dr. Anupam Varma Committee (AVC) submitted its report in December 2015. After the Committee report was submitted, 18 pesticides were banned immediately and 27 were to be reviewed. AVC, divided the 66 pesticides reviewed by it into 4 groups, viz.,

  1. To be banned
  2. To be phased out
  3. To be a continued subject to review and
  4. To be continued

The list of these 27 pesticides comes under the third group, i.e., “to be continued and subject to review” which clearly meant that the AVC itself believed that these products were by and large safe, efficacious and useful for Indian agriculture and the AVC wanted these products to continue. Only some minor data was to be generated and submitted. Draft order called “Banning of Insecticides Order 2020”, Notification S.O. 1512(E) on May 18th, 2020 came wherein 27 pesticides are proposed to be banned for import, manufacture, sale, transport, and use. It is to be noted that on June 10, 2020 MoA & FW allowed the export of these pesticides. One of the main reasons for bringing this ban is non-submission of data by industries on various studies. According to J. C. Majumdar, Chief Scientific Advisor of CCFI, industries have submitted 90% of the data asked by CIB & RC by 10 December, 2019. While analyzing the cost & benefit associated with this ban, the cost that will have to be paid by the Farmers and Agro Chemical SMEs is enormous as compared to the benefit. The impact of this ban on farmers as well as the industries is as follows:

  • The 27 generic pesticides proposed to be banned accounts for over 35% of domestic market and 50% of exports from India. It also accounts for 40% of the generic product market.
  • The crops that will get affected by this ban are maize, wheat, rice paddy, cotton, grapes, potato, tobacco, citrus fruits, ground nut, green chili that may impact 60% of the land under agriculture and crops in India.
  • The proposed ban on 27 pesticides thwarts the Indian agrochemical industry’s growth and potentially wipes out around Rs 10,000-12,000 Crore of the Rs 45,000 Crore estimated total revenue.
  • Replacement products from China are already registered & approved for import into India. Cost per acre of replacement products is significantly higher than existing products. Cost to the farmer shall go up by INR 5,435 Crore approx. Additional INR 5,170 Crore approx. will be spent on foreign exchange to import from China.
  • These 27 generic molecules has around 130 pesticide formulations, so banning of this 27 pesticide molecules will question the survival of several Indian pesticides and manufacturing industries including 1500 + MSMEs.
  • The annual market value of 10 finished products out of 27 products subject to above notification is Rs. 4,200 crores. Finished products and all the intermediates are a major foreign exchange earner with exports of Rs. 15,000 crore annually.
  • It is estimated that, on an average even a small unit would have 20 to 25 people on their payroll including chemist, shifting charges, supervisors etc. Deployment of labor in season would be minimum 70 people for two shifts and 100 people for three shifts as these are specialized jobs. We see a possibility of at least over two lakh skilled and semi-skilled contractual labor being out of job because of non-operation of these plants, consequent to the proposed ban in case it is enforced.
  • The 27 products proposed for ban includes pesticides like Chlorpyriphos and Malathion which are recommended by Government of India and FAO for most threatening LOCUST CONTROL.

Though this draft order attempts to reduce the pesticides consumption in agriculture, it also clearly mentions alternatives for all the 27 pesticides. Thus, merely shifting from one molecule to another is not a sustainable way to promote sustainable agriculture among farmers. So our goal of achieving sustainable agriculture should not be focusing on finding one alternative pesticides for another, instead, our focus should be on how to manage pests and increase productivity in agriculture. According to Dr. G.V .Ramanjaneyulu, “only focusing on pest management is not enough to bring the desired goal (pesticide free agriculture), it requires a holistic approach i.e., the Agro Ecological approach which involves making availability of quality seeds, adaptive cropping system, renewing of quality nutrients etc. In short, creating an ecosystem where agro ecological approach of agriculture can be practiced. This requires investment in research”. Lockdown will not allow building an ecosystem among all farmers in the country which is suitable for the adoption of pesticide free farming. Even though alternatives are available, its indigenous large scale production will definitely get delayed, as they do not have the capacity to produce the proposed alternative in the immediate future as it always takes a minimum of 4-5 years for identifying alternate technologies, completing registration procedures, creating required infrastructure, finance etc. Thus there will be a problem of dis-equilibrium, i.e., supply not meeting the demand.

It should be noted that toxicity of both molecules and their formulations are computed, but for giving color codes of the product only the toxicity of the molecules are taken into considerations. Since the toxicity of formulations and their application are not same as the toxicity of molecules (as the molecules are used in a highly diluted form in the formulations and its application in the farm fields), there is no logic in considering only the toxicity of the molecule as a base for banning these 27 pesticides.

While taking any policy decision, it is important to be cognizant of its impact on all the stakeholders involved. Proper evaluation of factors and outcome of any policy is important before implementing any policy decisions and it should also ensure that they are in national interest. Thus, rather than banning a list of 27 pesticides at one go, creating awareness about their judicious use will be a better strategy to avoid their harmful effects as well as to save the agricultural economy of India.

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