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In recent years we have witnessed the withdrawal of successive active substances of plant protection products across the EU; this no longer surprises anyone. In this post, however, I would like to focus on the situation in the cultivation of species from the genus Ribes, particularly black currant. As a grower, I am starting to look to the future with great concern, and I feel compelled to make at least a small contribution to drawing attention to this issue.

To better illustrate the state of plant protection, it’s worth beginning with a brief overview of the active substances withdrawn in recent years that were important for protecting Ribes species:

  • 2020 – Spirodiclofen (Envidor 240 SC): control of Tetranychus urticae, Cecidophyopsis ribis, Anthocoptes ribis Massee and Aculus masseei
  • 2021 – Mancozeb (Penncozeb 80 WP): control of fungal diseases
  • 2021 – Thiophanate‑methyl (Topsin M 500 SC): control of fungal diseases
  • 2024 – Abamectin (Safran 018 EC): control of Tetranychus urticae, Cecidophyopsis ribis, Anthocoptes ribis Massee and Aculus masseei (for greenhouse use only)
  • 2025 – Spirotetramat (Movento 100 SC): control of Tetranychus urticae, Tetranychus urticae, Cecidophyopsis ribis, Anthocoptes ribis Massee and Aculus masseei, aphids and Dasineura tetensi
  • 2025 – Acetamiprid (Mospilan 20 SP): control of aphids, Synanthedon tipuliformis, Dasineura tetensi, Resseliella ribis, Archips rosana and Pandemis cerasana

The rules of the game changed this year. In the case of acetamiprid, the issue was not a ban on the active substance itself in the EU, but a forced restriction on its use by lowering the Maximum Residue Level (MRL) to 0.01 mg/kg, which in practice makes even a single treatment impossible.

Council Regulation (EU) 2025/158 of 29 January 2025 amends Annex II to Regulation (EC) No 396/2005 by lowering the highest permissible residue levels of acetamiprid in many categories of plant products. For currants (black, red, and white) under code 0154030, the MRL has been reduced to the limit of quantification—0.01 mg/kg.

„(4)        The Authority identified an exceedance of the ARfD with the MRLs for currants, bananas, lettuces, escaroles/ broad-leaved endives, spinaches, and chards/beet leaves. The Authority consulted the Member States and requested them to report potential fall-back Good Agricultural Practices (‘GAPs’) authorised in Member States or third countries and already evaluated at Member State level that would not lead to an unacceptable risk for consumers. There were no fall-back GAPs reported. It is therefore appropriate to lower the MRLs for these commodities in Annex II to Regulation (EC) No 396/2005 to the relevant limit of determination (‘LOD’).” https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500158

A particularly telling excerpt is “There were no fall-back GAPs reported” which seems to have been the trigger allowing such drastic measures. The question is: why were such solutions not proposed, as they were for other crops? For example:

„(5)        The Authority further identified an exceedance of the ARfD with the MRLs for medlars, cherries, peaches, table and wine grapes, blackberries, raspberries, blueberries, cranberries, gooseberries, elderberries, table olives, tomatoes, aubergines, melons, pumpkins, watermelons, broccoli, cauliflowers, head cabbages, lamb’s lettuce, roman rocket, red mustards, asparagus, bovine liver, and bovine other edible offals. The Authority consulted the Member States and requested them to report potential fall-back GAPs authorised in Member States or third countries and already evaluated at Member State level that would not lead to an unacceptable risk for consumers. Fall-back GAPs that do not lead to exceedances of the ARfD were reported for these commodities. It is therefore appropriate to lower the MRLs for these commodities in Annex II to Regulation (EC) No 396/2005 to the values proposed by the Authority.”

In Poland’s case, black currant cultivation is of strategic importance: we are the world’s second-largest producer of these fruits, just behind Russia and ahead of Ukraine. Allowing this situation to develop is unacceptable—and yet it has happened.

So, what will be the consequences?

 

Changed “rules of the game.”

It’s no longer only the withdrawal of active substances from official circulation that we must fear, but also the tightening of permitted residue limits. Interestingly, the first official drafts of 2025 protection programmes—and even the product labels—still listed acetamiprid as allowed. In practice, however, it’s already impossible to use.

 

High risk of spray drift.

Few black currant plantations have sufficient spatial isolation from neighboring crops. The risk of spray drift is very high, which can jeopardize farm profitability through no fault of the plantation owner.

 

Loss of a systemic “weapon” against pests.

Acetamiprid based insecticides were crucial where systemic action was needed to control pests feeding inside shoots—such as the Synanthedon tipuliformis and Resseliella ribis. For the Synanthedon tipuliformis, pheromone traps and alternatives like Isonet Z (which uses pheromone baited dispensers to confuse males) are available. For the midge, no traps or dispensers yet exist—though traps for the Resseliella theobaldi suggest that solutions may follow, if time doesn’t run out. Effective use of these methods also requires cooperation among neighboring growers: only coordinated action across adjacent plantations can achieve high efficacy.

 

Increased pressure from other pests.

Without acetamiprid (and with spirotetramat also withdrawn), pests such as the Dasineura tetensi, Aphididae and Tortricidae are likely to become much more problematic than they were just a year ago.

 

Compounding environmental stresses.

Recent seasons have shown that black currant production is far from easy: hail, late frosts, poor pollination conditions, and plantations already weakened by internal feeding pests. Economic pressures led to reduced protection and fertilization, further weakening plants. Finally, the currant gall mite (Cecidophyopsis ribis), a vector of viral diseases like currant reversion, has compounded the damage.

 

All these factors combined open a straightforward path to disaster, and for many growers, finding the “brake” to avoid falling over the edge may prove impossible.