Commission implementing decision pursuant to Article 3(3) of Regulation (EU) No 528/2012 of the European Parliament and of the Council on monitoring traps containing attractants to insects
CEPA, representing the European associations of pest management, is highly concerned regarding the decision of the European Commission to consider monitoring traps with a pheromone attractant as:
“a biocidal product in accordance with Article 3(1)(a) of Regulation (EU) No 528/2012 and falling within product-type 19 as defined in Annex V to that Regulation”.
The purpose of monitoring traps, especially in the food industry, is only to act as an indicator of the presence of insects and thus avoid any treatment as long as there is no infestation. W0thout access to an attractant the probability of catching an insect is extremely low in the case of flying insects. However, not catching insects in monitoring traps without an attractant may not mean that they are not present. As a result, this will lead pest managers to resort systematically to more biocidal treatments.
We believe that a monitoring trap without an attractant is useless for flying insects. On the other hand, monitoring traps with pheromone do not have the capacity to control a population in case of an infestation and, moreover, will catch only males. As a result the function of a biocidal product nor the current biocide efficacy requirements cannot be met.
To consider monitoring traps with pheromone as a biocidal product PT 19 will lead to a very long and costly process with the following additional drawbacks:
• Those monitoring traps can no longer be used anymore during the process of authorisation, many years …
• The cost of products will probably become dissuasive. With no alternative it will conduct to systematic biocidal treatment…
• The size of the market will very likely discourage manufacturers to request an authorisation. With no alternative, it will conduct to systematic biocidal treatment…or to a development of internet sales from non-European distributors.
We sincerely hope that the European Commission can understand that monitoring traps without pheromone cannot be used effectively for monitoring (with no effective alternative) and traps with pheromone cannot efficiently control an infestation. The intended decision of the Commission would automatically conduct to less monitoring, less food safety and more biocidal treatments.