Summary

The CBS [Statistics Netherlands] conducted data exploration from October 2023 up to and including April 2024 for the purpose of setting up a possible monitoring system for the sale of biocides. The exploration was based on the following research assignment formulated by the Ministry of Infrastructure and Water Management (IenW): “Find the available sales figures for biocides and find out what conditions a national register would have to meet”. This report discusses the findings for five research questions about setting up a biocide register:

1. What biocide sales figures are included in the existing registers in Belgium and Germany?
2. What can we learn from the existing European statistical system for the sale of plant protection products?
3. How can the explored systems be adapted for the Netherlands? Can we include all product types right away, or would it be better to start off with a limited number?
4. What are the starting points for a data registry system, and which institutional setting would be preferable?
5. What scenarios can be used to set up a biocide sales register? The answers to these questions are briefly summarised below.

Approaches used in neighbouring countries

The first research question concerns the data, scope, classification and links used in the biocide registers in Belgium and Germany. The answers provided here are based on documentation and conversations.

Section 2.1 discusses the Belgian approach. Belgium has a requirement to register the sale of biocides (volumes per authorisation). A lot of information can be gleaned from the interactive annual reports that have been accessible since 2013. The Belgian system can be seen as an example of an existing national sales register. It provides yearly information about the amounts sold in Belgium by product type and main group, as well as by product name, active substance, and user category. This tells us which product types represent a large (or growing) share of biocide sales.

Section 2.2 describes the German approach. Germany set up a national register for biocide sales in 2022. Reporting biocide sales volumes is now mandatory. The German register has not been around long enough to provide the same information with the same level of detail for this report as the Belgian register.

Strategy for plant protection products

The second research question concerned the development of a plant protection products register in the Netherlands. Since plant protection products are similar to biocides, it is useful to include the information from this system in the recommendation. Section 2.3 explains what we can learn from the plant protection products system. For example, there is a basis under EU law for the registration of plant protection products, including the requirement for EU member states to provide sales figures. Biocides are not regulated at the European level (and only in a few cases at the national level: Belgium, Germany).

Second, we note that sales for plant protection products per kilogram of active substance are published annually, because these totals are relevant environmental information for the general public, policies and science. In light of this we can probably expect the publication of registered sales figures for active substances to become mandatory at some point as well.

And finally, the government is working with CropLife NL, an industry association that has been tasked with most of the data collection. To what extent this might also be useful for biocides is something that needs to be investigated further.

Lessons for the Netherlands

To answer the third research question, the lessons from the first two questions are restated in section 2.4 as a recommendation for a data exploration for a biocide sales register in the Netherlands. The sales data for two product types are currently available in the Netherlands as a result of an initiative by the Dutch Human Environment and Transport Inspectorate.

The recommendation is to always base a sales register on authorisations: without authorisation there is no basis on which to search the register for information. It would therefore make sense to have the authorising body manage the sales register, but this can also be done by an independent organisation that collects the information on behalf of the Ministry of IenW. There are national authorisations and international authorisations, granted by the Dutch Board for the Authorisation of Plant Protection Products and Biocides (Ctgb) and the European Chemicals Agency (ECHA), respectively. There is already a requirement that sales figures for authorisations must be included in the administration of the authorisation holders, but authorisation holders are not required to share these sales figures.

There appears to be little enthusiasm in the industry for a register that includes all product types. It is therefore advisable to provide a legal basis at some point for requests for information. It is advisable to start small with a pilot consisting of a few product types only. Section 2.4.12 lists considerations for selecting product types that would be appropriate for a pilot.

Practical aspects of setting up a register

The fourth research question concerns the practical aspects of a biocide sales register for monitoring purposes, and it is answered in Chapter 3 with a list of specifications for a well-designed register. This chapter includes recommendations for a description of the purpose, the target time frame, communication about the register, legal matters, data confidentiality, the structure of the register and quality control. The design of the register will depend on the legal requirements.

Planning stages

Chapter 4 includes a description of a pilot study conducted by an independent organisation. The study looked into practical experiences to find answers to unanswered questions and uncertainties in this report. The lessons from the pilot will also be used to determine the extent to which the planned register will become more comprehensive.