A survey of stakeholders in the zonal authorisation procedure was conducted. The survey102
sought stakeholders’ views on the zonal authorisation procedure, seeking in particular their
101 ‘Complete’ means all questions relevant to the respondent CA were answered. Most incomplete surveys were missing only one or two answers.
opinions on the functioning of the zonal system, the consistency in application of the principles of precaution, substitution and sustainability and the level of CA independence and transparency. These questions were developed on the basis of the same desk-based research on which the Member State survey was based. An additional step was taken involving review of the original questions in light of the responses of CAs to the Member State survey. Like the Member State survey, the stakeholder survey contained a mixture of closed and open-ended questions; the former designed to enable swift provision of information and the latter designed to encourage reflection and the expression of opinions. This tool provided primarily for opinions (subjective perceptions) to be collected.
Selection of stakeholders
Two categories of relevant stakeholders were identified: those with legal obligations under the Regulation and those without such legal obligations but with a legitimate interest in the achievement of the objectives of the Regulation or the implementation of the Regulation and its impacts. Within the first category fell industry, i.e. manufacturers of PPPs.103 Within the
second category fell PPP users and health and environment stakeholders. Stakeholders were selected on the basis of web-based research into their activities.
In the case of industry stakeholders, there exist both European (and international) level industry associations and individual PPP manufacturers. Only the former were approached.104
This was primarily because these associations were regarded as providing a reliable voice of industry/individual PPP manufacturers on the matters covered in the survey due to their fulfilling the following criteria: operation at a European level, large membership and significant influence and expertise in the area of plant protection and zonal authorisation procedures. Wherever two or more EU level industry associations were found to represent similar sections of the PPP market but only one focused exclusively on PPPs, that one was chosen. At least one industry association representing, at EU level, the manufacturers of synthetic PPPs (including generic PPPs) and biological PPPs was approached; three associations, in total.
With respect to PPP users, there exist European (and international) level associations representing large numbers of smaller member organisations operating at a national level. Only the former were approached for the same reason as above,105 i.e. that these associations
were regarded as providing a reliable voice of their members on the basis of the following criteria: operation at a European level, large membership, significant influence and expertise
103 CAs also have legal obligations but were approached in the Member State survey. 104 Except where no European level association existed, in which case the international level organisation was approached. It was specified in the invitation that the individual members of the selected associations would also be welcome to fill in the survey.
105 It was specified in the invitation that the individual members of the selected associations would also be welcome to fill in the survey.
in the area of plant protection and zonal authorisation procedures. Three, in total, were approached.
With respect to health and environment stakeholders, there exist both pan-European and national NGOs. The latter NGOs tend to be members of one or more of the former NGOs. A selection of both106 were approached in order to gather a range of views and experience at both
European and national level and on the basis that European-level NGOs might not be able to speak directly to zonal authorisation procedures in individual Member States. Stakeholders in this group were selected on the basis of the following criteria: highest interest in the achievement of the objectives of the Regulation, highest level of concern regarding the environmental and health effects of PPPs, expertise in the area of plant protection and a specific focus on PPP or a declared interest in being consulted. In total, six pan-European NGOs, and ten national NGOs were approached.
Finally, one international level organisation with a membership comprising EU Member States, was approached. In total, 23 stakeholders were approached.
The survey also took the form of a self-completion questionnaire but in this case was constructed and distributed using the online EU survey tool from mid-December 2017 to 22 January 2018. It was distributed to four stakeholders with legal obligations under the Regulation, of whom one responded; and 19 stakeholders with an interest in the achievement of the objectives of the Regulation, of whom none responded. As mentioned above, stakeholders were informed that their members were welcome to complete the survey too. Such members were invited to request access if they wished to do so. However, no additional stakeholders completed the survey. In total therefore, one response to this survey was received, from an industry association. This response was complete. It is unclear why only one response was received. Although the survey was open for over four weeks, it is possible that the timing (over Christmas) combined with its length deterred at least some stakeholders from responding. While a single response is clearly nowhere close to representative of the class of stakeholder to which the respondent belongs (or indeed stakeholders, generally), it did contain valuable information and perspectives on the zonal authorisation procedure, as presented below. Respondents were informed that their answers would not be linked directly to them, thus there is no attribution of information or quotes to individual organisations by name. The respondent stakeholder is referred to below as ‘the Stakeholder’.
106 It was specified in the invitation that the individual members of the selected associations would also be welcome to fill in the survey.