Comparative assessment

Article 50 of Regulation (EG) 1107/2009 states that applications for plant protection products (PPP) containing an active substance marked as Candidate for Substitution (CfS) should undergo a Comparative Assessment (CA) in addition to the risk assessment. The aim of the Comparative Assessment is to eliminate use of products with a relatively high risk for health and environment, and substitute this with an alternative product or non-chemical method or measure for the same use with significantly lower risk. The alternative may have no significant practical or economic disadvantages, and after substitution, sufficient variation in PPP or alternative non-chemical methods and measures should remain available for the intended use.  

So, the information on these pages is only relevant to those applications based on an active substance that is marked as Candidate for substitution. For non-CfS active substances and low risk Active substances a CA is not part of the assessment (although Article 50.2 leaves an option for exceptions).   

Whether an active substance is marked as Candidate for Substitution (CfS) (Article 24 of Regulation (EG) 1107/2009) can be retrieved from the starting page for each active substance in the EU pesticide database. A CfS is an approved active substance but with a relatively high-risk profile for health and environment; e.g. high persistence, high bioaccumulation, high toxicity, etc. See also Annex II (4) of Regulation (EG) 1107/2009.   

The comparative assessment is performed for each individual major use intended for the candidate product (the product under application). A use is defined as application of the product in one specific crop (group) against a single specific disease/pest; e.g. for a claim against 3 different fungal diseases in a single crop; 3 comparative assessments must be performed. The same for a claim against a single disease in 3 different crops. The CA procedure consists of 2 main steps.  

Step 1: Agronomical comparison 

• 1a Which alternative products and non-chemical methods and measures are available for the applied-for use of the candidate product and do these alternatives represent sufficient variation in modes of action for the desired level of resistance management? 
• 1b If so, can any alternatives without significant practical or economic disadvantages be identified? 

Step 2: Comparison of risks  

• If 1A and 1B can both be answered with yes, can use of an alternative without significant practical or economic disadvantages be considered significantly safer than the candidate product for the specific crop-disease/pest combination?  

If all 3 questions can be answered with yes, use of the candidate product will be substituted by that of the alternative (for the specific crop-disease/pest combination). If none of the alternatives without significant practical or economic disadvantages is considered significantly safer, the use of the candidate product is not substituted. If 1a or 1b is answered with no, this may directly lead to the conclusion to stop the CA without substitution.