FAQ: Exceptional Use Policy version 1.7

The relationship between the Rainforest Alliance's exceptional use policy and the European Union (EU) ban on Highly Hazardous Pesticides (HHPs) is significant, especially in the context of sustainability and compliance with international regulations in agriculture. 

Rainforest Alliance Pesticide Lists: The Rainforest Alliance has a strict policy regarding the use of pesticides to ensure that certified agricultural practices are sustainable and safe for both workers and the environment. The Rainforest Alliance has its own list of banned pesticides, which includes active ingredients considered hazardous to human health and the environment. This list is based on the guidelines provided by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO) for HHPs. These guidelines include the definition of HHPs according to eight criteria: 

1. WHO Category 1A, Extremely Hazardous to human health, or 1B, Highly Hazardous to human health. 
2. Globally Harmonized System of Classification and Labelling of Chemicals, Known or Suspected Carcinogens (Categories 1A and 1B); 
3. Globally Harmonized System of Classification and Labelling of Chemicals, Known or Suspected Mutagenic (Categories 1A and 1B); 
4. Globally Harmonized System of Classification and Labelling of Chemicals, Known or Suspected Reproductive Toxicants (Categories 1A and 1B); 
5. Montreal Protocol, Ozone-Depleting Substances. 
6. Rotterdam Convention (contained in Annex III of the Convention and subject to the Prior Informed Procedure process); 
7. Stockholm Convention, Persistent Organic Pollutants; 
8. Severe effects, where the pesticide's active ingredients and formulations have demonstrated a high incidence of serious or irreversible adverse effects on human health or the environment, including pollinators. 

EU ban on HHPs: The EU has established a list of pesticides that are banned or severely restricted due to their negative effects on human health and the environment. Since many agricultural products are exported to the EU, this ban has a significant effect on global agricultural practices. Farmers in other regions must comply with these regulations to access the European market. The Rainforest Alliance is in line with EU efforts to eliminate these chemicals from agriculture and encourages farmers to adopt more sustainable practices and to rely less on dangerous chemicals. 

Recommendations from other agencies: The Rainforest Alliance also aligns itself with the recommendations of organizations such as the Food and Agriculture Organization of the United Nations (FAO) and the Pesticide Action Network (PAN). These organizations promote the reduction and elimination of Pesticides globally, emphasizing the transition to agroecology and integrated pest management. Rainforest Alliance participates in the IPM Coalition, to promote the adoption of safer and more sustainable agricultural practices worldwide. 

Our collaboration with CABI: CABI is a nonprofit intergovernmental development and information organisation which focuses primarily on agricultural and environmental issues in the developing world. It facilitates the creation, curation, and dissemination of scientific knowledge. We have a memorandum of understanding with CABI to investigate and promote alternatives to toxic pesticides, and we are sponsors of their BioProtection Portal.

The Rainforest Alliance's primary goal regarding the use of highly toxic pesticides is to eliminate or minimize their use in agriculture, to ensure social and economic sustainability as well. The Rainforest Alliance seeks to promote sustainable agricultural practices that protect human health, biodiversity, and the environment.

We prohibit Highly Hazardous Pesticides (HHPs) to promote safer and more sustainable farming practices. However, we allow exceptions under an Exceptional Use Policy when Rainforest Alliance approved practices and agrochemicals are unable to sufficiently manage certain pests and/or diseases, as is the case with certain chemicals like Mancozeb.

These exceptions are necessary to help farmers manage significant pest and disease challenges in monocrop systems, especially where research into alternatives is still ongoing or where alternatives are much more expensive and threaten economic sustainability of producers. While we strive to reduce HHP use, the transition requires time, guidance, and support. We encourage integrated pest management practices and are committed to supporting research and pilot projects that aim to find safer, effective solutions.

The Exceptional Use Procedures and Emergency Exceptional Use Procedures for the use of pesticides included in the List of Prohibited Pesticides in Annex Chapter 4 are designed to manage situations where certified producers are forced to use pesticides that would normally be prohibited or restricted under the certification standards, due to exceptional or emergency circumstances.

Exceptional Use Procedure: This procedure applies when a producer needs to use a pesticide that is prohibited or restricted under Rainforest Alliance standards but has no viable alternatives to HHPs due to exceptional circumstances, or where alternatives are much more expensive and threaten economic sustainability of producers. At the same time, we require producers to take steps to mitigate and compensate for the negative impacts of these pesticides have on people and the environment. To apply for an exceptional use, the producer must formally request the exception and provide evidence that they have explored all possible alternatives and that the use of the pesticide is temporary. The Rainforest Alliance will evaluate the application and, if approved, will allow the use of the pesticide under strict conditions and for a limited period.

Emergency Exceptional Use Procedure: This is applied in serious emergency situations, such as: pest or disease outbreaks that threaten to destroy a large part of the crop, natural disasters, or extreme weather events that increase the vulnerability of crops to pests. In this case, the producer can receive a faster and more flexible authorization for the use of pesticides that would otherwise be prohibited. The use of these pesticides is strictly regulated and allowed only during the emergency period. As with the Exceptional Use Procedure, the goal is to restore compliance with normal standards as soon as possible. This authorization is limited to the area registered by the certificate holder. 

General Requirements for both procedures: producers must document the use of the exceptional pesticides, implement measures to mitigate environmental and health impacts, and work to minimize the need for future exceptional uses. In addition, the Rainforest Alliance may conduct audits and assessments to ensure that procedures are followed properly and that established deadlines and conditions are met.

We extended the policy to 2028 because the shift towards using fewer chemicals and more biological alternatives hasn't yet produced the necessary solutions for farmers. Without concrete research and viable and economically competitive alternatives, it's challenging to move away from certain chemicals entirely. 

By extending the policy now, we aim to create a more collaborative approach, empowering local teams to coordinate closely with farmers and provide specific, actionable guidance. This extension allows time to develop and implement a clear plan for finding, field-testing and adopting sustainable alternatives and practices, ultimately reducing the reliance on Highly Hazardous Pesticides, leading to a higher adoption to IPM. This will be critical, because we do not plan to further extend this phase-out timeline in the future.

The Rainforest Alliance offers a variety of training programs to farmers and workers to promote the safe use of pesticides, reduce the use of Highly Hazardous Pesticides (HHPs) and encourage sustainable alternatives. These trainings focus on several key aspects:

•  Integrated Pest Management (IPM): farmers are trained in Integrated Pest Management practices, which includes techniques to reduce reliance on chemical pesticides. This encompasses biological, cultural and mechanical methods to control pests/diseases, thus minimizing the reliance on HHPs. 
• Alternatives to HHPs: The Rainforest Alliance provides training on the use of safer and more effective alternatives to HHPs. Farmers learn to identify and use biological products and other less toxic options that are allowed under local regulations and the organization's standards.
•  Health and safety education: Part of the training includes proper and safe handling of pesticides, with a focus on protecting the health of farm workers and the environment. This includes the use of personal protective equipment (PPE), safe application techniques and proper pesticide residue management.
•  Ongoing updates: The Rainforest Alliance regularly updates its pesticide use policy and provides ongoing training to farmers to keep them abreast of best practices and regulatory changes. This ensures that growers are trained to meet the latest sustainability standards. 

These trainings are critical to help farmers make the transition to more sustainable methods and ensure that farming practices are safe for both people and the environment.

The Rainforest Alliance has implemented several measures to ensure the safety of farmers and workers in situations where Highly Hazardous Pesticides (HHPs) are still in use. These efforts focus on minimizing exposure, promoting safer practices, and encouraging the transition to less harmful alternatives:  

• Strict Safety Protocols: Farmers and workers are trained to follow stringent safety protocols when handling HHPs. This includes the proper use of Personal Protective Equipment (PPE), safe application methods, and restricted entry for periods after pesticide application. These measures are designed to minimize direct exposure to hazardous chemicals.
• Education and Training: Continuous education and training programs are provided to ensure that all workers who handle pesticides are aware of the risks associated with HHPs and know how to handle them safely. This training also covers the correct procedures for storing and disposing of pesticides to prevent environmental contamination and reduce health risks.
•  Monitoring and Compliance: the Rainforest Alliance regularly monitors compliance with safety standards through audits and inspections. They also work with certified farms to implement corrective actions if any safety violations are found. This ensures that the farms adhere to the strict guidelines set by the organization, which are often more rigorous than local regulations.
• Support for Transition to Safer Alternatives: the Rainforest Alliance encourages and supports farmers in transitioning away from HHPs by providing access to information on less hazardous alternatives and assisting with the adoption of Integrated Pest Management (IPM) practices. This reduces the reliance on dangerous chemicals and promotes a safer working environment.
• Policy of Exceptional Use: In cases where HHPs are still used under exceptional circumstances, the Rainforest Alliance requires farmers to implement additional safety measures to protect workers. This includes enhanced monitoring, use of protective barriers such as Personal Protective Equipment and ensuring that any application of HHPs is justified by the absence of viable alternatives. The organization also mandates that any such use be gradually phased out as safer options become available. 

These initiatives reflect the Rainforest Alliance’s commitment to safeguarding the health and well-being of farmers and workers while promoting sustainable agricultural practices.

There is still extensive pesticide use in banana farming due to several factors. In tropical regions, crops and pests grow year-round without a dormant season, leading to continuous pest pressure. Diseases like Black Leaf Streak, a pervasive fungus, thrive in these conditions and have developed resistance to some chemical controls due to overuse and misuse. The practice of monoculture further exacerbates this issue, as vast areas of genetically similar banana plants create an ideal environment for pests and diseases to adapt and proliferate.

Climate change has also disrupted traditional weather patterns, increasing humidity and creating conditions that favor diseases. Additionally, the stringent cosmetic standards for bananas in markets like the U.S. and EU necessitate the use of pesticides to prevent cosmetic damage and ensure compliance with import regulations. Finally, limited resources for research and development as well as regulatory challenges in some countries hinder the adoption of newer, safer alternatives.

Mancozeb is a fungicide still relied upon because, unlike other fungicides which have resulted in disease resistance, it remains effective against certain diseases. It is particularly effective in preventing resistance when used in combination with other fungicides. Despite its hazards, the lack of viable alternatives has necessitated its continued use under strict conditions.

The harms of Mancozeb are significant, including long-term health impacts on humans and environmental contamination. Research has shown its accumulation in the food chain and adverse effects on wildlife and human health. However, the structural limitations of current auditing practices and inconsistent enforcement of safety protocols complicate its phase-out.

We allow an extension for Mancozeb use because it's currently a critical tool for farmers, but we are committed to enhancing oversight, fostering dialogue, and supporting the development of safer alternatives.

Throughout the evolution of our agricultural standard, our approach has consistently been to support farmers in using agrochemicals only when necessary and in a safe, rational way. Our approach integrates regenerative agriculture, climate resilience, and water efficiency, aligning with both EU policies and initiatives like the Ethical Charter Initiative in the U.S., which focuses on social aspects. Our standard often sets higher benchmarks than local legislation, serving as a catalyst for change and helping farmers adopt best practices, often ahead of regulatory requirements.

The Rainforest Alliance supports farmers in reducing pesticide use, including Highly Hazardous Pesticides (HHPs), through a variety of strategies and resources:

• Promoting Integrated Pest Management (IPM): the Rainforest Alliance trains farmers in Integrated Pest Management techniques, which seek to reduce reliance on chemical pesticides by combining biological, cultural and mechanical practices. This helps farmers control pests/diseases more sustainably and with less use of hazardous chemicals.
• Evaluation and Continuous Improvement: The organization conducts continuous on-farm evaluations to identify areas for improvement in pesticide management. Through regular audits and follow-up, the Rainforest Alliance ensures that producers are implementing sustainable practices and moving toward the reduction and eventual elimination of HHPs.
• Supporting the Adoption of Alternatives: The Rainforest Alliance not only educates farmers about less hazardous alternatives, but also facilitates access to these alternatives. This includes the use of biopesticides, crop rotation, and the introduction of natural enemies of pests as part of a broader IPM strategy. 
• Access to the Homologa® Database: To assess whether viable alternatives to banned products exist, the Rainforest Alliance uses the Homologa® database, which provides detailed information on registered pesticides and maximum residue limits globally. This tool allows the Rainforest Alliance and farmers to understand the options available in different regions and to assess the feasibility of replacing HHPs with safer alternatives. These actions reflect the Rainforest Alliance's commitment to sustainability and safety in agriculture, supporting farmers in the transition to safer and more environmentally friendly methods.

When producers face emergencies or a lack of alternative substances to those excluded from the Exceptional Use Policy or our standard, we support them with our Exceptional Emergency Use Procedure. This is applied in serious emergency situations, such as: pest or disease outbreaks that threaten to destroy a large part of the crop, natural disasters or extreme weather events that increase the vulnerability of crops to pests.

In cases such as those mentioned above, the producer can receive a faster and more flexible authorization for the use of pesticides that would otherwise be prohibited. The use of these pesticides is strictly regulated and is allowed only during the emergency period. This authorization is limited to the surface area registered by the certificate holder.

These temporary, urgent requests are handled outside the Exceptional Use Policy. To submit an emergency request, the certificate holder must submit its request through the following online form: Emergency Request / Solicitud de emergencia. This form will request, amongst other data, the details about the need, the context, and the period in which the substance is needed.

Adherence to Rainforest Alliance’s pesticide requirements, including the ban on certain Highly Hazardous Pesticides (HHPs), is audited through a combination of practices. During audits, inspectors follow the Auditor Verification Protocol, which involves interviewing workers, observing pests and pesticide storage, and reviewing documents to track IPM strategy and pesticide use.

At least one audit during the certification cycle occurs during pesticide application periods, but auditors typically do not take samples for testing. If banned pesticides are found to be used, certification may be denied or cancelled, as outlined in rule 4.2.21 of the Certification Rules.

The decision to permit certain pesticide molecules for use against a specific disease or pest in one country or on one crop, but not in another, is influenced by several factors:

• Regulatory Standards and Environmental Conditions: Different countries have varying regulatory frameworks that dictate the approval/ registration of pesticides. These frameworks are influenced by national environmental policies, public health concerns, and ecological conditions. For example, a pesticide might be approved in a country with a specific pest problem or environmental condition that justifies its use, but it might be not registered in another country where the same pesticide poses a greater environmental or health risk due to different climatic conditions or agricultural practices.
• Pest Resistance and Crop Sensitivity: Certain crops are more sensitive to specific pests or diseases, and some regions might experience higher levels of pest resistance to treatments. This can lead to the approval of a pesticide in one context where it is deemed necessary for effective pest control, while it may be unnecessary or even harmful in another context where different crops are cultivated or where the pest pressure is lower.
• Availability of Alternatives: The decision to allow or ban a pesticide molecule also depends on the availability of safer or more effective alternatives in the region. In some cases, alternatives may be readily available and effective, leading to a ban on more hazardous options. In other regions, the lack of viable alternatives may necessitate the continued use of a particular pesticide under strict controls. 
• International Trade and Compliance: Countries also consider international trade regulations and compliance with global agreements, such as those under the Rotterdam or Stockholm Conventions, which can influence whether a pesticide is permitted or banned. Some countries may allow the use of certain pesticides to maintain crop production for export markets, while others may prohibit them to align with international safety standards. Additionally, some governments may require the use of certain pesticides as a way of managing the quarantine of pests. 

In the end, the decision to permit or prohibit a pesticide molecule is multifaceted, involving a combination of regulatory, environmental, agricultural, and economic considerations specific to each country or crop.