Annual Report 2024
Preface
The year 2024 was characterised by a number of important innovations in our risk assessment process. These improvements were consistent with our multi-year strategy and our position as an autonomous assessment authority. The Ctgb primarily administers national and European regulations. However, as an autonomous administrative authority we can give shape to our assessment process so we can contribute as much as possible to the protection of people, animals and the environment. And we use that autonomy effectively.
In January 2024, for instance, we implemented an enhanced comparative analysis to accelerate the replacement of products on the EU list of 'candidates for substitution' with safer alternatives. We also opened the Sustainability Desk in early 2024. Products that contribute to enhanced sustainability are thus prioritised in our work process. In this Annual Report you can read about the first results of these innovations. In November 2024, we adopted a new approach to deal with substances that structurally exceed authorisation standards in surface water. In late 2024, the Ctgb also modified the assessment process by systematically including the latest knowledge on endocrine-disrupting substances in the assessment.
However, these innovations in our assessment process may lead not only to more work for the Ctgb, but also to restrictions on the use, or even the availability, of certain products. That is the consequence of assessing substances and products as best we can regarding their safety for humans, animals and the environment. This is our social mission.
The responsibility for the broad issue of plant protection products and biocidal products, which includes the safety of substances and products, their correct use, the regulation of their use (also in specific regions), efficient European procedures, and the availability of standard and environmentally-benign products, lies not only with the Ctgb, but is also shared by various parties. For example, users are responsible for using only authorised products and doing so according to the instructions. Compliance and enforcement deserve our full attention. The national government has an important policy-making role, on which the Ctgb relies. As early as 2023, for instance, the Ctgb requested the national government to provide a legal basis to implement the standards of the Water Framework Directive in our assessment process. We did this to avoid problems in the future. Other authorities can play an important role by making good use of the possibilities offered by Environmental Act and its area-specific provisions. This is a competence that some NGOs also called attention to recently. And industry can certainly play an important role by making a strong commitment to developing sustainable products.
In view of this dependence on all parties, we attach great importance to close cooperation and dialogue with all our stakeholders. In 2025 we will continue our commitment to this cooperation and dialogue. In 2024, Ingrid Becks stepped down as Secretary-Director and was replaced by Marcel van Raaij. The Board is very grateful to Ingrid for her many years of dedicated service for the Ctgb. Finally, I would like to express my sincere thanks to all Ctgb employees who have again made every effort to fulfil our complex and fascinating mission.
Rob van Lint, Board Chairman
Review of 2024 in a nutshell
The Board for the Authorisation of Plant Protection Products and Biocides (Ctgb) is the Dutch assessment authority for plant protection products and biocidal products. It is an autonomous administrative authority (ZBO) that assesses products and active substances based on the provisions in the EU Plant Protection Products Regulation and Biocidal Products Regulation, and other legislation in the Netherlands. These Regulations are based on the precautionary principle: a product should not be placed on the market until it has been demonstrated that its use does not lead to unacceptable risks.
For those risk assessments, Ctgb works closely at the EU level with the European Food Safety Authority (EFSA), the European Chemicals Agency (ECHA), and the competent authorities of the other EU Member States. For the same purpose, the Ctgb works together in the Netherlands with several ministries, the Dutch Food and Consumer Product Safety Authority (NVWA), the Environment and Transport Inspectorate (ILT), and research institutes such as the National Institute for Public Health and the Environment (RIVM) and Wageningen University & Research (WUR).
Guidance documents are developed as an elaboration of European regulations and are regularly updated according to the latest science and technology. The Ctgb actively contributes to this process. In doing so, we remain critical and vigilant, follow current developments, and are prepared for the requirements emerging from these developments. We also provide solicited and unsolicited advice to various ministries.
The Ctgb considers it important to be transparent and accountable. Authorisation decisions with the corresponding risk assessment can always be viewed via the authorisations database. In 2024, we also began reporting on rejected applications for authorisation. The reports of Board meetings that are published on the website state when a product based on a particular substance is not authorised. In early 2024, the Ctgb also started publishing the corresponding memoranda on policy decisions of the Board.
About 150 applications for product authorisations were submitted to the Board in 2024. These included about 80 applications for plant protection products, of which 16 (about 20%) were rejected entirely. About 70 applications for biocidal products were submitted, and eight (about 12%) were rejected.
A typical application usually involves multiple uses for the product. If the Ctgb authorises a product, this does not mean that all the uses applied for will also be authorised. Some of these uses are rejected or withdrawn by the applicant. This was the case for about 35% of plant protection products and about 11% of biocidal products.
The instructions for use were also tightened in a significant proportion of the authorisations before the decision. This was the case for 37% of plant protection products and about 63% of biocidal products. This is done to ensure that the use of these products does not pose unacceptable risks.
Enhanced sustainability
The Ctgb wants to promote the availability of sustainable plant protection products. A separate 'green team' has been established for this purpose. In 2024, this team submitted eight substances to the EFSA for the European Peer Review process. The 'green team' evaluates substances and products of natural origin, including micro-organisms, plant extracts and pheromones, but also peptides.
As a result, the Ctgb now accounts for a large share of these assessments in Europe. After these substances are approved, authorisations can be requested for sustainable products that are based on them.
The Ctgb established a separate 'Sustainability Desk' in early 2024. When submitted via this Desk, applications for plant protection products that contribute to sustainable agriculture will be given priority consideration. By 2024, four products were assessed and authorised via this route. At the end of the year, another six applications were pending. If larger numbers of applications from producers of sustainable products are submitted, the Sustainability Desk has sufficient capacity to process them quickly. The Ctgb is also trying to promote this development in the European context.
The Ctgb believes that biocidal products and uses should also be given more attention regarding innovation and enhanced sustainability. The Board therefore endorses the strategic framework for biocidal products as drafted by the Minister of Infrastructure and Water Management. In 2024, the Board held a special thematic session that included this topic. During one of its annual excursions, the Board acquired information on the use of fogging for biocides. This is a technique where the same concentration and therefore the same efficacy can be achieved with less water.
Stricter procedure for comparative assessments
Another contribution to the enhanced sustainability of the assortment of authorised products is a stricter approach to the comparative assessment, in which the Ctgb and NVWA work together. This assessment focuses on approved substances in plant protection products for which European legislation requires their replacement (where possible) by alternatives. These substances are on the list of 'candidates for substitution'. However, between 2016 and 2023, this process did not lead to the actual replacement of any products. The new approach makes the process more effective and efficient.
In 2024 it delivered the first tangible results. For two products, based on pendimethalin and methoxyfenozide, respectively, the comparative assessment led to changes. For one of the products, two uses were replaced by a safer alternative. The other product was removed entirely from the market in the Netherlands.
Intervention in case of structural violation of authorisation standards in surface water
In 2024 the Ctgb approved a policy decree that allows it to address substances in plant protection products that structurally exceed the authorisation standards in surface water. For this purpose, the Board looks at monitoring data from the Pesticides Atlas – in particular at the list of substances with the most severe exceedances. When there is a recurring pattern of exceedances, the Ctgb performs interim reassessments. This is also possible with a pending application.
Intervention can consist of various measures. These include prescribing additional drift-reducing measures, reducing the dosage or frequency of use, and withdrawing certain uses or the entire authorisation.
Importantly, the policy decree should adequately reflect the knowledge and experience of stakeholders. Therefore, the decision is preceded by a public consultation on the policy decree. Over 100 responses were received from 24 organisations, ranging from businesses to environmental organisations and drinking water providers.
Based on data from the Pesticides Atlas, the first seven norm-exceeding substances were specified in December of 2024. For products based on these substances, the need for reassessment will be considered in 2025. This is possible if new knowledge or methodologies have been developed since the original authorisation and no regular reassessment is ongoing.
Embalming products
In early 2024, for the first time, the Board authorised three biocidal products for embalming. Until that year, no products for embalming were formally authorised, but the products used were tolerated by enforcement agencies. The fluids (formaldehyde-based) are used to prevent bacterial growth in veins and thoracic and abdominal cavities, in the period between death and corpse delivery. As a substance, formaldehyde has not yet been approved at the European level. The authorisation of the three products was therefore based on national biocide legislation.
Ruling of the Court of Justice of the European Union
Two rulings by the CJEU in three appeals submitted by the Netherlands had implications for the Ctgb's assessment framework. Therefore, in the interest of society, we decided to change our mode of operation from 1 December 2024 to reflect the possibilities offered by this Court ruling. Henceforth, when evaluating a product, we look at whether there is recent, credible scientific and technical knowledge on endocrine disruption in humans. If so, we will take that into account.
The second ruling concerns being allowed to deviate from other Member States in the case of new and relevant information. A proposal on how to implement this ruling correctly is being drafted.
Legal affairs
In 2024, 50 objections were filed and 20 were settled. Objections were filed primarily by authorisation holders/applicants and non-governmental organisations (NGOs). More objections were filed than in previous years. A clear cause for this increase was not identified, although it could perhaps be attributed to the increasing legalisation trend that we see in other areas as well.
During the year under review there were about a dozen legal proceedings on the use of plant protection products that took place between ornamental crop growers or local authorities and NGOs and/or local residents. The Ctgb was not involved in these proceedings and was not called as an expert witness. However, we look at the rulings to see if they have implications for our policies or practices. These legal proceedings often refer to the Ctgb as the authority that authorises the products and ensures their safety.
Policy advice
The Ctgb is not only responsible for assessing plant protection products and biocidal products, but also provides advice – solicited and unsolicited – on these policy areas to the relevant ministries: Agriculture, Fisheries, Food Security and Nature and Infrastructure (LVVN) and Water Management (IenW). The Ctgb periodically advises on European proposals for the approval (or rejection) of active substances. In 2024, the Ctgb advised various ministries several times. The topics included the authorisation framework for plant protection products, legionella control, and the precautionary principle. Furthermore, the Ctgb answered questions on the significance of outcomes of new scientific research, and questions on media reports regarding plant protection products and biocidal products (particularly their risks).
Exemptions
In 2024, there was a lot of attention in politics and media about requested exemptions for insecticides in fruit crops. That concerned insecticides to control apple blossom weevil and the Suzuki fruit fly. When asked by the media, the Ctgb also explained the reasoning behind its advice. In doing so, we stressed that regular authorisation is always preferable.
In the midst of society
In particular, the assessment and use of plant protection products has attracted a lot of interest from society, politics and the media. In November the Ctgb chairperson and management provided a technical briefing to the Parliamentary Standing Committee on Agriculture. Subsequently, the Secretary-Director was one of the speakers in a round-table discussion on plant protection products held by the Lower House of Parliament. Topics included the cumulation of substances used, the risks of neurodegenerative diseases, and the discrepancy between authorisation standards and WFD standards. A widely shared conclusion was that more insight into usage data is desirable. A broader approach that includes more than the Ctgb's authorisation procedure was also discussed.
When answering questions and participating in discussions, in its communication policy the Ctgb wants to focus more on its own story. In 2024 an initial series of three podcasts was produced in which Ctgb employees explain various aspects of their work. These first three episodes include a general introduction and introductions to risk assessment of biocides and plant protection products.
Certain topics recur regularly in questions posed to the Ctgb. These are: PFAS, authorisation and risks of glyphosate, and need for exemptions and (legal proceedings against) pesticide use in flower bulb cultivation. On the latter topic, the province of Drenthe held an information evening. The Ctgb, together with the Ministry of LVVN, explained the assessment system, the basis of our decisions, and how our conclusions should be interpreted. The Ctgb also provided the province with a large number of answers to frequently asked questions.
In April, the Secretary-Director participated in a broadcast of the Zembla documentary series. This broadcast aimed at critically highlighting the re-authorisation of glyphosate in 2023. In October the Ctgb chairperson responded to an opinion article in the newspaper Trouw, which suggested that the Ctgb was not doing its work conscientiously.
Ctgb Client Contact Day on 'digitisation' in June
In 2024, the central theme of the Client Contact Day was 'digitalisation'. This focused on the opportunities and challenges of digitising a label or instructions for use, the possibilities in enforcement, and data ownership. In several presentations and workshops, speakers presented new developments, practical applications, and examples that can contribute to transparent and sustainable use of plant protection products and biocidal products. At the end of the day, the general conclusion was that data belongs to no-one, but if we share data, we can multiply knowledge, resulting in a leap forward for digitalization.
Podcast 'Products, people and the environment'
How are plant protection products and biocidal products assessed for their official authorisation? That question is often asked. Questions about an assessment usually concern a single substance or product, a specific use, or the risks to groups such as consumers and nearby residents or to certain animals or plants. The Ctgb thinks it is important to tell the whole story about the assessments it performs. This is done in the podcast 'Products, People and Environment', of which three episodes were produced in 2024. In these podcasts, Ctgb employees explain various aspects of their work. The podcasts are available on Spotify and Apple Podcasts. In 2024, they were downloaded about 2000 times. Preparations for the second season have started.
Social media and website traffic
The Ctgb website had more than 140,000 visitors in 2024, who viewed 660,000 web pages in more than 350,000 sessions. This was another slight increase on the previous year. One in four visitors viewed our website more than once. This percentage rose from 20% to 25%.
Visits to the authorisations database increased 11% in 2024. However, page views were down by 4%.
In social media, the Ctgb intensified the use of LinkedIn in particular. In 2024, the number of followers on LinkedIn increased by 30%. It is noteworthy that reports on policy decisions and reactions to media reports are read by more people than just the regular group of followers. For instance, there was above-average interest in notices about the Sustainability Desk and the policy decree on exceedances of standards in surface water. This also applied to reports in which the Ctgb responded to what was happening in the media.
The downward trend on X has continued. In particular, coverage on this platform coverage is decreasing. However, there were some positive outliers. These included posts on the opening of our Plant Protection Products Sustainability Desk, and our Chairperson's letter to the editor in Trouw in response to an opinion article on the effects of neonicotinoids on the bird population.
The number of readers of the Dutch-language newsletter decreased slightly, while the number of readers of the English-language editions remained stable. Five Dutch-language and four English-language editions were published in 2024.
Organisation and organisational development
In her 2024 New Year's address, Ingrid Becks-Vermeer announced that she would step down as Secretary-Director as of 1 July. She was succeeded by Marcel van Raaij, who previously worked at the RIVM and the ministries of VWS and LNV (now LVVN).
In 2023, the Ctgb initiated an extensive organisational development process aimed at improving the balance between substantive quality, time and money, strengthening internal processes, and reducing turnaround times. This process aims to make the organisation more flexible and agile. The focus is on multidisciplinary cooperation and sustainable employability of employees. Ministries made one-off contributions towards the costs of, among other things, absorbing 'loss hours' for implementing this organisational development, setting up a 'Green Team', and inducting new managers. An interim evaluation and employee sessions resulted in areas for improvement such as greater flexibility, harmonisation of work processes, better planning, and attention to culture and behaviour. These areas will be worked on in programme form over the next two years.
The number of employees has remained stable. However, the inflows and outflows of employees and coping with these changes have a direct effect on the balance between the various teams, leaving us vulnerable Increasing broad employability within teams and providing development opportunities remains essential to coping with changes and retaining employees.
The organisation-wide collaboration environment (OBSO) programme has been completed. The result is a new application landscape that enables collaboration and links systems together.
Financial aspects
The new collective labour agreement 2024-2025 includes a structural wage increase of 8.5%, one-off benefits, and an increase in the IKB budget to 16.5%. These changes, and the associated large financial impact, were not foreseen. This necessitated an interim increase in the hourly rate.
Despite this interim increase and the one-off contribution, the financial year ended with a negative operating result. There were insufficient billable hours to break even. The causes were high absenteeism, inflow and outflow of employees, induction and flexibility of employees, the impact of organisational development, and the implementation of a new application landscape.
Changing digital landscape (OBSO, SharePoint, ACM)
The migration and implementation of the final phase of the multi-year programme for the organisation-wide collaboration environment has been completed, and the new application landscape has been commissioned. Thus, the intended results have been achieved. These include: the delivery of an organisation-wide (ICT) collaboration environment (OBSO), a reduction of the outdated complex application landscape, and investments in new systems and applications. Existing applications, such as MST (Product Substances Authorisations), the planning tool and financial administration, are now linked to a case management system and SharePoint. This was done to avoid unnecessary and duplicate entries and to unlock the correct control information.
The establishment of a client portal is separate from the OBSO programme. Preparations for this have now started. This includes a new CRM (Customer Relationship Management) system, which is the basis for the client portal.
Trends in authorised products and active substances
The Ctgb reports every year on how many products are authorised in the Netherlands and how many different active substances they contain. The number of active substances for plant protection products shows a decreasing trend. For biocidal products, the number of active substances has remained stable, and the total number of products has continued to decrease slightly; see the figures below.
Authorised products and active substances
| Biocidal products | Plant Protection Products | Active subsances PPP | Active substances Biocides | |
|---|---|---|---|---|
| 2007 | 759 | 697 | 218 | 81 |
| 2008 | 799 | 699 | 226 | 79 |
| 2009 | 805 | 759 | 232 | 80 |
| 2010 | 829 | 766 | 238 | 83 |
| 2011 | 863 | 771 | 252 | 92 |
| 2012 | 997 | 777 | 269 | 128 |
| 2013 | 1188 | 800 | 268 | 136 |
| 2014 | 1404 | 845 | 272 | 153 |
| 2015 | 1476 | 907 | 279 | 156 |
| 2016 | 1508 | 916 | 282 | 156 |
| 2017 | 1559 | 941 | 280 | 159 |
| 2018 | 1654 | 1000 | 288 | 163 |
| 2019 | 1701 | 1039 | 280 | 168 |
| 2020 | 1779 | 1009 | 277 | 166 |
| 2021 | 1879 | 994 | 273 | 169 |
| 2022 | 1865 | 1031 | 270 | 165 |
| 2023 | 1826 | 1058 | 266 | 164 |
| 2024 | 1765 | 1038 | 253 | 167 |