My secret exchange on neonics with the European Commission

See the French translation

Recently the Risk-Monger received an anonymous FOIA access to information request to see a 2014 email exchange between him and the European Commission regarding the DG Santé’s precautionary ban of three neonicotinoids in their contrived attempt to “save the bees”. While I do not find it acceptable to use the Ask the EU transparency tool anonymously, and expressed my view on that quite strongly, I felt that my correspondence should be made public, and not just to one privileged party hoping to use it for policy advantage (or in this case, likely not). So for the benefit of all people concerned with the consequences of the Commission’s tragic neonicotinoid blunder, this blog will release that famous secret letter between the Risk-Monger and the European Commission.

It will be revealing!

Setting the Scene

The European Commission was dragged down into the mud of the Draft Bee Guidance debacle and its contrived precautionary ban via the activist bias of the now retired Commission director, Eric Poudelet. Poudelet, an amateur beekeeper had long been vociferously anti-industry, keeping close contacts with the NGO lobbyists campaigning to ban pesticides. Quite convenient then that he was director of the Safety in the Food Chain Unit (that included pesticide management) in DG Santé (then Sanco) that had created a policy structure destined to ban safe, widely used crop protection products. The revision of the Pesticides Directive, for example, was a masterstroke in policy obstructionism (or rather: How to make European farming unprofitable). Poudelet knew how to abuse EFSA, to which unit in Parma to direct his question on bees and neonicotinoids, and how to maneuver a precautionary ban in the most efficient manner. He could go into his public service pension thinking he had left a legacy to match his dogma.

Director Poudelet being rather less than unbiased and open-minded

In the end, Poudelet’s legacy was a mess that the present European Commission has been suffering under, one risking to destroy EFSA’s risk assessment strategy and will likely lead to a decision in the courts that will embarrass and discredit DG Santé for the next decade. The only positive side I can find from this sorry story is that I’ll have a case study to use to teach my students on the value of integrity in public policymaking.

Under Poudelet was Michael Flüh, head of the DG Sanco Pesticides Unit with a scientific background. In other words, unlike his boss, he had some understanding of facts and basic reality. In an unguarded moment, Dr Flüh admitted at an event that the precautionary ban on neonicotinoids was not at all about saving the bees, but rather, to make the Commission look like it was doing something to address the issue.

Flüh acknowledged that the other problems actually behind the then suspected bee decline are so intractable (climate change, loss of habitats and biodiversity, viruses and diseases, monoculture farming practices …), the European Commission had to be seen to be doing something. A pesticide ban was the easy option … although … admittedly … entirely useless.

This view was later confirmed by the Commissioner Andriukaitis in front of the European Parliament: that the ban of the three important and efficient insecticides was not intended to save  the bees. Well, … OK! I know that, and … now … it seems … the European Commission knows that … so why the hell did they ban the most effective and safest pesticide class? I didn’t know hurting European farmers was an objective of DG Santé. Are millions of EU farmers less important than pleasing bloody Ségolène Royal??? Am I the only one who finds this terribly offensive to thinking people?

My letter to Michael Flüh

So as I was about to publish the third instalment of my BeeGate series in 2014, I thought I would give Dr Flüh a chance to clarify his position and perhaps, now that he had replaced Poudelet as the acting director of the Sanco Safety of the Food Chain Unit (that included pesticides and bee health), allow him to put DG Sanco back on a sound policy and scientific position.  My letter dated 11 December 2014 began with full transparency and a bit of background.

fluh-1Dear Dr Flüh,
I am writing to ask if I could have a quick phone conversation with you. I am an independent blogger writing under the name of the Risk-Monger and I have recently been looking into the practices of a group of scientists that have formed a taskforce within the IUCN to do a literature review of articles on systemic pesticides and bees. See for the first in a series of three blogs. For the third blog, I am looking into how certain activist scientists have found their way into EC working groups that may have influenced the decision-making process in 2013.

I thought it would be important to inform the European Commission of potential conflicts of interest in its agencies. Then I got to the meat of the issue – that we both agreed that the EU’s neonicotinoid precautionary ban was totally useless!

I want to refer back to a remark that has been attributed to you from earlier this year when you noted that the neonicotinoid ban was the most immediate action, but it was not going to be the solution for the bees given that there are so many other intractable problems that cannot be regulated (as reported in: While I find this refreshingly honest, I am curious if you would have anything to add given the recent OSR crop losses and derogations in the UK and elsewhere this year and the revelations on how some of the anti-pesticide bee scientists have been behaving.

This was important. Maybe Dr Flüh did not realise that his little policy “oops” was choking farmers. Maybe he would agree to follow up this issue and  try to instil some reason into EU post-Poudelet pesticide policy. Maybe I was being naive!  I closed understanding the seriousness of his situation:

I understand the sensitivity of this issue for you (you should see the state of my inbox and the number of horse-heads delivered to my door!) so please feel free to write your response if you prefer (although I plan to publish the blog by Sunday night or Monday morning).
Given that researchers in transparency groups like Corporate Europe Observatory will probably track every email I send to the Commission via Ask the EU, I would understand if you choose not to reply (so much for democracy!).
Looking forward to your response.

Now because of transparency morons abusing the Ask the EU process, I have to end all of my Commission exchanges with a crumb and a jab at their silly games and abuse of resources. I hope whomever made the anonymous Ask the EU request for this letter appreciates the irony! If they wish to come clean, a nice bottle of Merlot would be appreciated!

So that was the famous letter that shocked the world and provoked a freedom of information access to document request. But how did Michael Flüh reply. Did he ignore me? No, he replied the very same day (during the evening)! Did he say: “Oh my God, David, you are so right! Thank you! We’ll fix this right away!” I have lived in Brussels too long to expect that. Would he agree to talk to me to explain why my views are sadly mistaken and set me straight? No, it is pretty clear that my views are far from mistaken! Or would he pull out a famous Belgian bureaucratic waffle? You be the judge!


Yep! Waffle served with a syrup of stupid it was. And a sticky one at that! It must be painful for someone that smart to have to follow policy dictates that are so ridiculous!

I had also publicly written to Dr Flüh in a blog to get him to realise the consequences of his actions to farmers. I know he has read these messages and I can only assume that he remains trapped, not by the ideology of idiocy,  but rather by the idiocy of the bureaucratic system that will not allow common sense to fix bad policy decisions.

Personal Assessment

When I look at what happened, it mystifies me how a bad policy, that everyone recognises to be full of stink, can just sit there and be tolerated because no one has the courage to remove it. Farmers are suffering, the EU economy is suffering, agri-tech innovation is suffering … the only winners are activists campaigning for the organic food industry lobby and the cabbage stem flea beetle (a truly nasty creature) which is slowly getting out of control and making certain pollen-rich crops impossible to grow.

It has been established that:

  • EFSA has been deceived by activists with conflicts of interest and no moral compass;
  • the ill-conceived Bee Guidance Document will never be accepted by the Member States;
  • the EU’s precautionary ban of the three neonicotinoids was illegal;
  • the European Commission will lose a court-case based on Poudelet’s shenanigans and have to pay damages;
  • there was no crisis for the honeybees (DG Santé’s own research has proven that);
  • Santé’s highest officials have recognised that the ban would do nothing towards improving bee health (in fact it will likely weaken bees);
  • there have been significant economic and social costs on the rural community.

The highest level of management in DG Santé must be either incredibly stupid or incredibly frustrated.

This is not just about the lack of courage within the European Commission to fix a bad policy mistake (I used to have hope for Frans Timmermans until I came to the realisation that he was just an other bureaucrat), but rather, how this sorry story has come to reflect what is wrong with the present Commission leadership. They have merely expedience … no leadership.

One of the communities most outraged by this precautionary ban on an essential group of insecticides was the UK farmers. During last June’s Brexit vote, the rural British community voted strongly to leave (against the advice of the farming organisations). Frustration from British farmers at such irresponsible policymaking did have deeper consequences than mismanagement at the top of DG Santé – it likely swung the vote to the Leave camp in the Brexit vote.

What is wrong in DG Santé is reflected as what is wrong in Brussels. The neonicotinoid debacle is not just a mistake that can be wished away by unassuming civil servants – it is a disaster coming to symbolise the weakness of the European project. Why can’t EFSA’s Url and Santé Commissioner Andriukaitis act according to their potential? I often wonder who is stopping them from being reasonable?

It is not just about cowardice inertia. Mismanagement and corruption in the European Commission has consequences far outside of the Brussels Bubble. … and it might just come back and burst that Bubble.

4 Comments Add yours

  1. Jack Boyne says:

    Another great article, which cuts to the heart of the issue. Using “science” (or lack thereof) as a pretense for creating and defending a misguided and politicized policy has not only damaged farmers, but also threatens true scientific risk assessment over the long term. I wish I shared David’s belief that the courts will overturn this ban, but I fear it will not happen.


    1. riskmonger says:

      Unless the corporates mess up, it is a pretty open and shut case. The ban was based on the Bee Guidance Document the Commission had hoped would be accepted by the Council. It has not been (for obvious reasons), thus their precautionary decision was unlawful.
      My money is on EFSA retracting the Bee Guidance Document the night before the case begins leaving their advice as null and void, probably giving the Commission 18 months more to reconsider the now available data (extending the temporary ban to keep the NGOs and French happy). So the Commission will buy itself some time to appease the NGOs while not being seen to have lost a case. None of this is in any way acceptable to farmers, but this has never been about them.


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