Countries blocking listing of pesticides are undermining the objectives of the Rotterdam Convention

Guest blog: Fresh from his attendance at this year’s Conference of Parties to the Basel, Rotterdam and Stockholm Conventions in Geneva, CEJAD’s Fredrick Otieno expresses his disappointment over the failure to list hazardous pesticides under Annex III of the Rotterdam Convention.

CEJAD delegation at the Conference of Parties to the Basel, Rotterdam and Stockholm Conventions 2022
Fredrick (far right) at the Conference of Parties to the Basel, Rotterdam and Stockholm Conventions 2022

Every year, the Conference of Parties to the Basel, Rotterdam and Stockholm Conventions (BRS COPs) meet to discuss and pass resolutions on management of chemicals and wastes to protect humans, animals and the environment.

This year’s conventions took place in Geneva from the 6th to 17th June, including the 10th meeting of the Conference of Parties to the Rotterdam Convention.

The triple COPs

The three conventions, commonly known as the triple COPs, and are legally binding international instruments on chemicals management.

The Basel Convention promotes protection of human health and environment by controlling the transboundary movement of hazardous wastes.

The Rotterdam Convention promotes shared responsibility and transparency in the management of chemicals by facilitating information sharing on hazardous industrial chemicals and pesticides in the international trade.

Both of these require a prior informed consent procedure (PIC). This means that a country must first give their consent before any hazardous waste or chemical can be imported into their territory.

The Stockholm Convention, on the other hand, aims to eliminate the production and use of persistent organic pollutants (POPs) and minimize releases of these substances.

A failure to reach consensus

The Rotterdam Convention is particularly important for those of us concerned about the dangers of hazardous pesticides.

Although it has no power to ban pesticides, ‘listing’ hazardous pesticides in Annex III of the Convention helps Parties (nations) to make informed decisions as to whether they wish to import these chemicals.

However, the meeting was a huge disappointment in so far as listing of pesticides is concerned.

Four pesticides had been recommended for listing in Annex III by the Chemicals Review Committee (CRC), following a rigorous review process. They included acetochlor, carbosulfan, liquid formulations of paraquat Ddchloride at or above 276 g/l and fenthion (ultra-low-volume (ULV) formulations at or above 640 g active ingredient/L).

Although the above pesticides met the criteria under the Convention, Parties failed to agree on their listing to allow the process of information sharing to begin.

Unfortunately, this process was held back by only a few Parties. Under the Convention, a decision to list a chemical or severely hazardous pesticide formulation (SHPF) can only be made by consensus of all Parties.

The consensus approach was adopted to safeguard the interest of all Parties. However, some Parties have taken advantage of this procedure to block new listings, without any regard for the harm these chemicals pose to human health and the environment.

Parties discussing listing of chemicals and pesticides at the 10th meeting of the Conference of Parties to the Rotterdam Convention
Parties discussing listing of chemicals and pesticides at the 10th meeting of the Conference of Parties to the Rotterdam Convention

Four hazardous pesticides


Carbosulfan was recommended for listing on grounds that some of its degradation products could be toxic to the genetic system. There was also a high risk of exposure to children and adults through consumption of different crops treated with this pesticide.

In addition, environmental concerns were expressed on its potential to contaminate ground water as well as its toxicity to birds and mammals, aquatic organisms, bees and earthworms. These concerns have seen this pesticide withdrawn for use in the European Union and the Sahel region in Africa.

Despite these concerns, three successive COPs have failed to reach a consensus on listing this pesticide.


Acetochlor has been discussed twice without any breakthrough on its listing.

Notably, this pesticide was recommended for listing because its metabolite can harm the genetic system and has a high potential to contaminate both underground water and surface drinking water. Acetochlor is also highly toxic to all aquatic organisms, birds and non-target terrestrial plants.

Paraquat and fenthion

Discussions to list liquid formulations of Paraquat Dichloride at or above 276 g/l and fenthion (ultra-low-volume (ULV) formulations at or above 640 g active ingredient/L) were held for the first time.

The former was recommended for listing on grounds that it was associated with many poisoning cases under local conditions of use in Burkina Faso.

Vulnerable communities at risk

Evidence from Burkina Faso showed that vulnerable farmers could not read the label and did not have Personal Protective Equipment (PPE), hence safe use of paraquat could not be guaranteed.

Evidence from other countries has shown that the use of PPE among vulnerable farmers is limited because PPE is often expensive, unavailable or uncomfortable. These are realities in many countries, particularly for farmers in low-and middle- income countries.

Regrettably, there are low and middle-income countries that opposed the listing of this paraquat formulation, preventing information sharing about its characteristics and effects. This information could help to protect vulnerable people in their own communities, including women and children.

These Parties should be reminded that when they stop a pesticide from being listed, it is these groups of people who are most heavily impacted.

abandoned shoes in rural farming community

Setting a dangerous precedent

This failure by Parties to reach consensus on pesticides recommended for listing under the Rotterdam Convention on more than one occasion raises fundamental issues.

They are setting a very bad and dangerous precedent for future listing of chemicals.

For a third and second time, Parties failed to list carbosulfan and acetochlor respectively. This trend could have also contributed to the failure to list the newly recommended SHPFs of fenthion and paraquat dichloride.

All eyes are now focusing on the 11th meeting of the Conference of Parties to see whether a consensus can be reached.

Listing does not mean a global ban

The reasons and concerns fronted by Parties that opposed these listings had no relevance to the objectives of the Convention.

Some Parties alleged that listing of pesticides amounts to a global ban of these products, and that countries would therefore ban such pesticides from use.

However, listing of chemicals in Annex III does not in any way amount to an international ban, and neither does it invite any Party to restrict or ban such pesticides. It only facilitates information sharing to improve transparency in the international trade and ensure that importing countries have adequate information to make informed decisions regarding import of such pesticides.

Unfounded concerns over crop production

There were also concerns that listing pesticides would lead to crop losses, due to a reduced supply of pesticides arising from bans and a lack of viable alternatives.

While it is true that some countries are likely to ban or restrict pesticides listed in the Convention, to protect their citizens from highly hazardous pesticides, there is mounting evidence that banning the use of a pesticide does not reduce crop yields.

It is also important to note that, prior to listing a chemical or pesticide, the Secretariat undertakes capacity building activities on the alternatives.

If a Party fears that it will be seriously impacted, it should seek support in developing viable alternatives. However, it should not block the listing of a chemical that can harm human health and the environment.

Importing countries, vendors and users of these chemicals have a right to know about their hazards and risks to be able to make good risk management decisions.

Undermining the objectives of the Rotterdam Convention

More importantly, the failure by Parties to list chemicals and pesticides recommended for listing calls into question the need for the Chemicals Review Committee.

Why should the Convention continue to invest a lot of resource into the work of this committee if the Parties that formed it cannot respect its work and decisions? Parties should be sincere on why this important organ was formed under the Convention.

It is ironic that the few Parties that are blocking listing of chemicals are ready to import and use pesticides banned or restricted in other countries, but have no business with information about them, including information on their harmful effects.

This is simply undermining the objectives of the Convention.

It is time to rethink the rules of procedure, especially those on listing of chemicals and pesticides, and provide for voting where Parties cannot make a decision by consensus.

The current way of making decisions on listing of chemicals in Annex III is rendering the Convention ineffective.

Fredrick Otieno, Project Officer
Centre for Environment Justice and Development

Twitter: @onyangofredric8

The Centre for Environment Justice and Development (CEJAD) partners with CPSP to deliver work in southern and eastern Africa. Find out more about our global work.