The regulation of BugOil: experiences from North America and the EU

Current popular opinion increasingly favours a reduction in the use of pesticides, lower residues and a move towards sustainable agricultural practice.

Achieving this goal needs change in two areas. Firstly, regulation needs to change to tighten up registration and use of existing agrochemicals. This is already well underway in the major markets.

Secondly, new products are needed – products with excellent efficacy, and a safe environmental profile. Safer products need not be natural (indeed many natural products are less safe than the best conventional agrochemicals!). Nevertheless safe natural products with efficacy to match the best conventional agrochemicals and a safe environmental profile are the kind that governments, consumers, NGOs and the food industry are keen to see being developed and introduced.

However, natural products are often chemically very different to the synthetic single active ingredient pesticides that they can replace. Therefore, the existing registration systems that are designed to ensure safe use of conventional pesticides are often fundamentally unsuitable to natural product registrations.

This can lead to a conflict. Governments rightly want to make existing conventional pesticides safer, and, in order to achieve this, need to increase their regulation of them in order to improve standards. Whilst this trend has undoubtedly led to a dramatic and welcome improvement in the environmental impact of conventional pesticides, it has also led to the less desirable outcome whereby environmentally friendly natural pesticides have also become increasingly difficult to register, slowing down or even preventing market entry of safer, sustainable products.

This situation must be addressed, or industry will be reluctant to invest in research programmes for development of natural pesticides. This will slow progress towards sustainability.

This article concentrates on a plant-derived pesticide (BugOil) derived from Plant Impacts patented chemistry. It looks at two different approaches to registration of the product (the USA and EU regulatory systems), and compares them. It then discusses how natural products are variable and that perhaps in future regulatory systems may need to be flexible in order to fast track the safe products, but be sufficiently robust on the less safe ones.