Current EU pesticide regulation assesses active substances and products individually. This has created a harmonised approval system, but it does not fully address how pesticides affect the environment in practice.
In agricultural landscapes, impacts do not arise from one product in isolation. They arise from the combined pressure of multiple substances used across fields, farms and regions over time.
This is the structural gap addressed in a new policy brief from PollinERA, co-authored by Professor Christopher J. Topping, Special Consultant, PhD, Johan Axelman and researcher James Henty Williams from the Department of Agroecology at Aarhus University.
The proposal builds on the debate raised in the recent Science article, EU Omnibus proposal increases pesticide risks , which highlights concerns that the EU’s proposed Omnibus changes could weaken pesticide safeguards rather than strengthen science-based risk assessment.
But PollinERA goes a step further by proposing a new regulatory architecture. It offers an operational route to closing a widely acknowledged gap: substance-by-substance, binary safe/unsafe assessment cannot manage cumulative pressure at landscape scale.
The central idea is a regional pesticide budget. Each ecological region would receive an annual capacity for permitted pesticide pressure. Individual pesticide applications would then be managed within that regional capacity.
Products with lower environmental impact would use less of the budget, while more persistent or more toxic substances would use more. In this way, the system is intended to replace simple approve-or-ban decisions with graduated, capacity-bounded management.
According to the authors, this could align pesticide regulation more closely with EU environmental law, where many obligations already operate at the level of ecosystems, river basins and landscapes.
The proposal also changes the incentive structure.
Under the current product-by-product system, a broad-spectrum persistent product and a more selective, rapidly degrading product may both be approved and therefore appear equivalent from a regulatory perspective.
In a regional budget system, however, the lower-impact product would use less of the farmer’s seasonal entitlement. This gives farmers a practical incentive to choose lower-impact products and gives manufacturers a commercial incentive to develop more targeted and environmentally benign crop protection solutions.
The authors argue that the proposal would not require a completely new data system.
Active substances could be assigned toxic unit values based on ecotoxicological data already contained in current authorisation dossiers. Farmers would register intended pesticide applications through a digital notification system linked to land parcel data, and the system would calculate whether the application fits within the remaining regional budget.
The policy brief points to Denmark as a relevant proof of concept, because Denmark already has mandatory digital pesticide use reporting, detailed parcel-level agricultural data and extensive groundwater monitoring.
The proposal also addresses how a shared regional pesticide budget could be distributed fairly. Each farm would receive a baseline entitlement based on agricultural area and crop type. The system could also include limited carry-over of unused entitlement, holding caps, a regulated secondary market and a reserved allocation for new entrants and small farms.
The aim is to prevent large or early actors from monopolising regional pesticide capacity, while preserving flexibility for farmers facing pest or disease pressure.
The PollinERA policy brief argues that the Omnibus process should not only be seen as a debate about simplification or deregulation.
It is also an opportunity to modernise pesticide regulation architecturally. This reflects a broader scientific and policy discussion within the EU on how to address cumulative environmental impacts, where Aarhus University researchers contribute through several EU research projects.
By managing total pesticide pressure at regional level, the proposed system is intended to add an additional layer to current regulation, aimed at addressing cumulative environmental impacts while supporting farmer flexibility, resistance management and innovation in lower-impact products.
Read the Science article: EU Omnibus proposal increases pesticide risks
Read the PollinERA policy brief: Pesticide regulation and the Omnibus process: A systems-based regional management approach
Science
EU Omnibus proposal increases pesticide risks
18-Jun-2026