Wild bees are vulnerable, the acceptable loss of them due to pesticide exposure should be 0%
BRUSSELS, BELGIUM, 1 April 2022
BeeLife European Beekeeping Coordination is urging the protection of wild pollinators against pesticides. Wild bees are playing an important role in the pollination of crops and the reproduction of wild plants. The diversity of pollinators is vital to secure the resilience of pollination ecosystem services and guarantee the best crop yields (Garibaldi et al, 2016) . Therefore the protection of wild pollinators is key to ensuring the EU’s food security and preserving biodiversity.
In January 2022, the European Food Safety Authority (EFSA) published a supporting document  to help risk managers (the Standing Committee on Plants, Animals, Food and Feed - SCoPAFF) set up Specific Protection Goals (SPG) for wild bees in the EU. In this document, EFSA claimed that the level of knowledge on wild bees is insufficient to define the SPGs based on background variability. EFSA made a series of statements based on the available data obtained from regulatory field trials. The problem with these field trials is that the ‘control fields’ are also treated with pesticides, which the pesticide industry, EFSA, and DG SANTE all accepted. As a result, EFSA is using data from potentially pesticide-contaminated fields to determine the background mortality of wild bees, which will serve to evaluate the unacceptable effects of pesticides.
BeeLife European Beekeeping Coordination requests to stop allowing the unscientific habit of spraying the control fields with pesticides in regulatory field trials. Following the objectives set up in the EU Biodiversity Strategy and the EU Pollinators Initiative to revert pollinators decline; and given the lack of knowledge and data resulting in the precautionary principle, the aim is to set SPGs at 0%. Exceptionally, and only for regulatory purposes, we could envisage testing protocols allowing detection of a 3% difference in wild bees between control and tested fields.
Why should only such a low percentage of loss be accepted? Due to the following reasons:
1. The pesticide cocktail (what is the reality in field conditions) is not tested in the regulatory process;
2. The pesticide exposure is not evaluated in the ‘real-world’ context (e.g.: when there is a lack of habitat, lack of nutrition, other stressing factors, etc.);
3. The testing is done only on some model species. It is highly probable that the test species are not the most sensitive ones, among the 1900 species of wild bees in the EU. EFSA considered in 2013  the intra-and inter-specific variations in toxicity, proposing some assessment factors of 5 (intra-specific) and 10 (inter-specific).
Noa Simón Delso, Scientific Director of BeeLife states "BeeLife requests a political commitment at a higher level, aiming for the highest protection of pollinators and making coherent political decisions. We can not revert the negative trends in pollinators if we continue accepting high levels of impact from pesticides. The diversity of pollinators should be considered as a production input."
The EU aim, to restore biodiversity as set up in the Biodiversity Strategy on one hand, and allow 10% loss of wild bee populations due to pesticide exposure, on the other hand, is not coherent and should not be accepted. Before the catastrophic state of biodiversity and without enough data on what can be considered ‘sustainable harm’ for wild pollinators, we urge the EU Member States to aim at 0% loss of bumblebees and solitary bees, but for a maximum of a 3% difference in wild bees between the control and the tested fields.
 Garibaldi et al, 2016: Mutually beneficial pollinator diversity and crop yield outcomes in small and large farms
 EFSA, 2022: Analysis of the evidence to support the definition of Specific Protection Goals for bumble bees and solitary bees
 EFSA, 2013: Guidance on the risk assessment of plant protection products on bees (Apis mellifera, Bombus spp. and solitary bees) https://www.efsa.europa.eu/en/efsajournal/pub/3295