Time has come to explain why it is my belief that AIPROM does not communicate the results of the SCAPA collection, not even upon request from MADR/NPA. When organising a collection system for environmental purposes, when collecting 58% of the total packaging on the market in 2012, after having started with 0.04% in 20017 and continued with 11.12% in 2008, you should have every reason to be proud of your accomplishments, to be very keen on communication and on receiving applause. And to publish all sorts of plans for how to get closer to 100%. That is why I think that the real reasons come from the internal organisation of the AIPROM members in charge of SCAPA, as well as from external factors, certain collaborators and contractors of AIPROM. Let start this analysis systematically:
A. What is the real quantity of packaging for plant protection products sent on the Romanian market annually?
No one knows and most probably no one will ever really know. And this is not about pharmaceutical measurements, grams etc, we are talking about industrial quantities, hundreds of tonnes. And Why?
- The Environment Fund, the only institution able to make this data available, receives statements from all Romanian companies which produce or import (and here we presume that everyone declares their obligations to the Environment Fund, which is untrue) and I do not think anyone from the Environment Fund has made a centralization of amounts paid by companies that have engaged in manufacturing and marketing of pesticides. To receive a truly correct answer on the total amount, it goes without saying that the Environment Fund inspectors thoroughly check all imports from the pesticide companies. Or to have the National Phytosanitary Authority hit by a sudden bolt of lightning and take responsibility for collaboration with the Environment Fund … In this context, the statement from AIPROM is that its members hold 80% of the pesticide market in Romania. That would mean there is a 20% not included in SCAPA, calculated, and this is extremely significant, at the value of the product and not at the weight of the actual packaging.
2. The members of AIPROM are sophisticated when it comes to reporting (or not) the packaging and paying (or not) whatever is due to SCAPA. That’s because not all members of AIPROM declare the packaging to SCAPA. Ever since 2008, the official amounts of packaging placed on the market, as declared by AIPROM / SCAPA did not included (at least until 2012) packages from the products which are member firms of AIPROM, which are only commercial subsidies (e.g. Dow, Chemtura, Arysta), they the commercial entities that do not have a legal obligation to report to the authorities or to SCAPA the amount of packaging bearing their logo and are available on the market. These obligations of declaration and payment of obligations to the Environment Fund are borne by those who introduce them to the market and subsequently distribute later. It is their excuse for not introducing in their budget packages recovery costs. An example: the representative of DOW is considered part of the 80% of market value, and is one of the largest companies by market share; there are many DOW products on the market and we used to find them often in SCAPA’s correct collection. That being said, DOW doesn’t declare and or pay anything to SCAPA (at least in the period between 2007 and 2012). Its products are collected by SCAPA because it was stated and declared as a participant, but the importers / distributors of DOW AgroScience products don’t declare the actual quantities, don’t take part in the in the collection and don’t pay collection costs to SCAPA. SCAPA don’t register the DOW quantities put on the market when they perform their annual reviews, but they still gather DOW packaging, increasing somehow falsely the percentage of collection.
3. Because some members of AIPROM and participants to SCAPA somewhat joggle with the quantities of packaging, with the significant fluctuations from one year to the next, providing justification with matters related to their portfolio. However, there is at least one case in which a company statement changed from one day to the next, when they were made aware of their percentage of payment and another case in which the statement was nullified due to the fact that the imports were done through other companies, even though they had plenty of activity to speak of. No one from the association has the capacity or the authority to control the real imports of the members, not even in the situation when the statements of paying members of SCAPA to SCAPA itself are corroborated with statements to the Environment Fund. To my knowledge, not even the Environment Fund could sanction a company that cheated the SCAPA partners out of their percentage, and the company declares, upon verification, the nominal and real quantity collected by SCAPA, provided they subsequently pay the differences. Obviously, the collection through SCAPA is more expensive than the official environmental tax.
4. Because there are Romanian companies who import/place on the market pesticides and some of them even deal with micro-packaging pesticides, thus producing a significant additional quantity of packaging. With some exceptions, such as CIG, Chemarj, Redoxim and Glissando who participate in SCAPA, this type of importers-distributors cannot be found on the lists of SCAPA participants. The exceptions which are part of AIPROM declare to SCAPA quantities which, in their total summation, don’t reach 10% of their total SCAPA quantities.
5. Quantities of plant protection products produced in foreign countries are smuggled into the country. Some of them are original products destined for other countries, others are counterfeited.
In fact, these are the main reasons why there are significantly more packages from plant protection products on the market than declared by SCAPA. Consequently, much less is being collected in terms of percentage, than comprised in the statements issued by AIPROM. And AIPROM, and all its members, know of this. When it comes into discussion what exactly is collected from the farms and what documents support the collection, I understand why they are so unwilling.
For the environment/business market in Romania, all this means that in fact there are many more packages left in nature, buried or burned. I know that other countries have the same issues and similar systems from other European countries. And in Romania AIPROM, and all its decision making members in SCAPA are very well aware of this. And after a moment they chose to no longer expose themselves submitting such information, reason why they don’t make data available.
In addition, the results of the SCAPA collection prove to be falsified in some of the years. And AIPROM, and all its decision making members in SCAPA are very well aware of this.