Regulation of carbofuran and its use to poison wildlife in the European Union and the rest of Europe - Carbofuran and Wildlife Poisoning: Global Perspectives and Forensic Approaches - page 135

a total grace period of two years is issued, providing one year for retailers to empty their stocks, and
another for end-users to fi nish their supplies (Swedish Chemicals Agency, personal communication,
2011). In some cases, in the interests of 'good customer relations and stewardship', manufacturers
will take back remaining stocks of their product. In other places (i.e., the Republic of Ireland, see
Chapter 6) the product must be disposed of as hazardous waste at the expense of the owner.
Elsewhere e.g., Malta, if prohibited compounds are not used up by the grace period, the local
importer and the authorisation holder discuss between them what decision to take, whether to
destroy the products (as hazardous waste) or return them to the authorisation holder who may then
opt to export them to countries outside the EU (Foodstuffs, Chemicals, Cosmetics and Pesticides
Unit (Malta), personal communication, 2011). As such, the Regulatory Affairs Directory there lea-
ves this decision to the importer/authorisation holder, because their responsibility is to ensure that
prohibited products are not placed on the market (although their responsibility does extend to ensu-
ring that prohibited products are disposed of appropriately).
All such discrepancies will be regulated under the new Pesticide Regulation 1107/2009, which
enters into force 14 June 2011 and replaces Council Directive 91/414/EEC. Article 20.2 (Renewal
Regulation) stipulates that, if approval of an active substance is not renewed:
Where the reasons for not renewing the approval do not concern the protection of
health or the environment, the Regulation referred to in paragraph 1 shall provide for
a grace period not exceeding six months for the sale and distribution, and in addition a
maximum of one year for the disposal, storage, and use of existing stocks of the plant
protection products concerned. The grace period for the sale and distribution shall
take into account the normal period of use of the plant protection product but the total
grace period shall not exceed 18 months. In the case of a withdrawal of the approval
or if the approval is not renewed because of the immediate concerns for human health
or animal health or the environment, the plant protection products concerned shall be
withdrawn from the market immediately.
Regulation 1107/2009 is particularly timely, given that despite Directive 2007/416/EC (regarding
the ban), carbofuran-related wildlife mortality continues to be reported throughout the EU and the
rest of Europe. In this chapter, accounts of such incidents are provided from the Czech Republic, the
Netherlands, Austria, Spain, Hungary and Croatia. They reveal a cross-section of social, economic
and geopolitical conditions which have all contributed to the extent of the use of carbofuran to
poison wildlife. Indirectly, they also illustrate how the discrepancy between registration periods
and revocations throughout Europe (see Table 5.1) has nourished illegal stockpiles of the product.
Finally, these accounts also very effectively convey that local wildlife poisonings are undermining
national conservation initiatives, that continued monitoring and vigilance is required, and that the
enaction of stringent legal procedures and penalties is essential.
5.2 Intentional poisoning of piscivorous species and other wildlife
with carbofuran in the Czech Republic
Lukáš Poledník, 1 Kateˇina Poledníková, 1 Jitka Vˇtrovcová, 2
Václav Hlavácˇ 2
1 ALKA Wildlife, o.p.s. Lidéˇovice 62, 380 01 Daˇice
2 Agency for Nature Conservation and Landscape Protection of the Czech Republic
(AOPK CR), Nuselská 39, 140 00 Praha 4