The National Action Plan on Pesticides: Does it go far enough?

After seven years of delay, the UK Pesticides National Action Plan 2025 (“NAP”) was finally published on 21 March 2025. Developed in partnership between the Department for Environment, Food and Rural Affairs (Defra), the Scottish Government, the Welsh Government, and the Northern Ireland Executive, the NAP sets out a strategy for managing and reducing the risks posed by pesticide use. Whilst the NAP appears to be an important step forward for increasing the uptake of non-chemical alternatives to pesticides by farmers, critics have argued that the NAP lacks ambition in its targets and should extend to urban and amenity spaces, such as public parks.

The NAP seeks to promote sustainable pesticide us to minimise their impact on the environment and human health, while also managing pests and pesticide resistance effectively and ensuring farmers have the tools needed for sustainable food production.

Why is this important?

The NAP cites a scientific review of 400 studies which identifies that pesticides not only adversely impact biodiversity (the review found that pesticides have a negative effect on 70.5% of biodiversity measures for soil invertebrates) but that these effects also have a knock-on impact on food security. The review notes that pollinators provide benefits of around £630 million per years’ worth of crop production in the UK, therefore any threat from pesticides to these pollinators should be of concern. The Food and Agriculture Organisation estimates that global pesticide use has increased by 91% since 1990 (based on 2020 levels).

What’s in the National Action Plan on Pesticides?

The NAP has three key objectives: inclusion of integrated pest management (“IPM”) systems; strengthening targets; and reaffirming best practice in safety compliance in the use and sale of pesticides.

• Objective 1 – Encouraging the uptake of IPM
  An IPM is an alternative approach to pest management. It includes crop rotation, cultivation and tillage practices, growing pest-resistant varieties, and encouraging natural predators. Several IPM techniques have been shown to improve factors like soil health and water quality. Nevertheless, farmers have been hesitant to implement IPM techniques, as many consider them to be financially high-risk compared to traditional crop protection methods, such as using pesticides. Over-reliance on individual products has been shown to be a key driver of pesticide resistance, which an IMP approach could address.
  The NAP outlines research and development efforts that are already underway. For example, Defra and Innovate UK have committed £127 million to the Farming Innovation Programme for research into projects like designing and testing robotic weeders to remove black-grass and developer slug-resistant wheat. The NAP also highlights existing support structures that are in place to promote the uptake of IPM in agriculture, such as the Sustainable Farming Incentive, which pays farmers to adopt and maintain sustainable farming practices with a specific focus on increasing knowledge and identifying opportunities for IPM approaches. While the NAP’s commitment to encouraging the use of non-chemical alternatives is promising, its success will ultimately depend on the level of resourcing and support provided.
• Objective 2 – Set clear targets and measures to monitor use of pesticide
  The UK has set a minimum domestic target to reduce all Pesticide Load Indicator (PLI) metrics by at least 10% by 2030 based on 2018 levels (this being a ‘typical’ year of pesticide use for the UK). A seemingly unambitious target, when considering that one of the central pillars of the European Green Deal aims to affect a 50% reduction in the use and risks associated with pesticides by 2030.
  There are two key metrics included in the NAP for assessing the risks posed by various pesticides: the potential harm metric and the behaviour metric. The potential harm metric relates to the PLI, which was developed as a multi-component indicator that looks at how different types of pesticide harm various species groups, how pesticides behave in the environment, and the quantity needed to be effective. In doing so, the potential harm metric assesses the short and long terms toxicity of specific pesticides and herbicides to a range of organisms that may not be the pesticides’ intended target. The behaviour metric focuses on how specific pesticides behave in the environment, considering how long they remain before degrading, how easily they move through water and soil, as well as their tendency to accumulate in plants or animals.
• Objective 3 – Strengthen compliance to ensure safety
  The third objective of the NAP focuses on increasing awareness and understanding of the legal requirements for those working in the sale and use of pesticides. It includes commitments to support through training, official-controls, and guidance on proper storage, handling, and disposal to protect both human health and the environment.

Does the NAP go far enough?

While the commitment to a reduction target is a step in the right direction, the 10% goal appears low. The PLI metrics are also currently only applicable to the agricultural arable sector, meaning that key areas, such as forestry, are not addressed. There are also no concrete commitments for phasing out pesticide use in urban areas such as public parks and street verges. The NAP does outline some examples of IPM approaches in the amenity sector, such as Cambridge City Council’s Herbicide Reduction Plan, which explored the use of specialised street-cleaning mechanical equipment and hot foam treatments as an alternative to herbicide use in public spaces, like highway verges and pavements. While this is a commendable example, it remains a case study rather than a commitment. It highlights good practice but falls short of allocating resources or outlining an actionable strategy. The NAP’s focus on environmental factors, also fails to acknowledge concerns for human health related to pesticide use.

Finally, the NAP relates wholly to the use of pesticides domestically, failing to acknowledge the UK’s pesticide exports, which will continue the lifespan of these harmful chemicals. This is despite alluding to UK’s international obligations under to the Kunming-Montreal Global Biodiversity Framework. A recent investigation by Greenpeace UK’s journalism project, Unearthed, last December, found that the UK exported 8,500 tonnes of pesticides that are banned in British farms because of the dangers they pose to human health and nature.

Sources:

1. “UK Pesticides National Action Plan 2025: Working for a more sustainable future” Department for Environment, Food and Rural Affairs (Policy Paper, 21 March 2025)
2. “Pesticides and plant protection”, European Commission (Agriculture and Rural Development) – https://agriculture.ec.europa.eu/cap-my-country/sustainability/environmental-sustainability/low-input-farming/pesticides_en
3. UK Pesticides National Action Plan finally published – our initial response”, Pesticide Action Network UK, (21 March 2025)
4. “Ultimate hypocrisy’: UK exported 8,500 tonnes of banned pesticides last year”, Crispin Dowler (8 december 2024, Unearthed) https://unearthed.greenpeace.org/2024/12/08/ultimate-hypocrisy-uk-exported-8500-tonnes-banned-pesticides/