Public Consultation on Proposed control of Chlorpyrifos, Paraquat and Paraquat salts

National Environment Agency

Consultation Period: 27 Feb 2025 - 27 Mar 2025

Status: Closed - Summary of Responses

Consultation Outcome

NEA’S Responses to Comments received from the Public Consultation on the Proposed Control of Chlorpyrifos, Paraquat and Paraquat salts

1. The National Environment Agency (NEA) has concluded its public consultation on the proposed control of Chlorpyrifos, Paraquat and Paraquat salts, which are currently under review for listing under the Stockholm and Rotterdam Conventions. The 4-week consultation exercise was open for public comments from 27 Feb 2025 to 27 Mar 2025.

2. NEA received 28 responses from this consultation exercise. Overall, the majority of the respondents supported the proposed control of Chlorpyrifos, Paraquat and Paraquat salts as Hazardous Substances (HS) under the Second Schedule of the Environmental Protection and Management Act and the Schedule of the Environmental Protection and Management (Hazardous Substances) Regulations. The respondents acknowledged the potential harmful effects of these chemicals on the environment and public health, and were generally supportive of implementing the Prior Informed Consent (PIC) requirements under the Rotterdam Convention and the proposal to ban Chlorpyrifos under the Stockholm Convention.

3. One respondent raised concerns regarding the proposed ban of Chlorpyrifos.  NEA’s response to this feedback is detailed below.

4. NEA would like to thank all stakeholders who participated in the consultation exercise. We look forward to your active participation again in our future public consultation.

Detailed Description

Aim

1. The National Environment Agency (NEA) is seeking feedback on the proposed control of Chlorpyrifos, Paraquat and Paraquat salts at all concentration levels and in all preparation forms as Hazardous Substances (HS) under the Second Schedule of the Environmental Protection and Management Act (“EPMA”) and Schedule of the Environmental Protection and Management (Hazardous Substances) Regulations (“EPM (HS) Regs”)¹. NEA is also seeking feedback on

   1. requiring all transboundary movements of Chlorpyrifos, Paraquat and Paraquat salts to be subjected to the Prior Informed Consent procedure under the Rotterdam Convention, and

   2. a potential ban on Chlorpyrifos under the Stockholm Convention.

This consultation will last 4 weeks from 27 Feb 2025 to 27 Mar 2025.

 Background

2. Singapore is Party to the Rotterdam Convention (RC), which aims to promote shared responsibility among Parties in the international trade of certain hazardous chemicals through the Prior Informed Consent (PIC) procedure. Singapore is also a Party to the Stockholm Convention (SC), which aims to eliminate and restrict the production and use of persistent organic pollutants. NEA, as the Competent Authority for the RC and the SC, controls chemicals listed under the respective Conventions to ensure that the international obligations are complied with. The 12th Conference of the Parties (COP-12) to the RC and SC is scheduled to be held back-to-back from 28 Apr to 9 May 2025.

 Proposed Control on Chlorpyrifos, Paraquat and Paraquat Salts under RC

3. In Sep 2024, the Chemical Review Committee (CRC) of the RC assessed that Chlorpyrifos, and Paraquat and Paraquat salts met the criteria for listing in Annex III to the RC under the pesticide category. The proposals for listing Chlorpyrifos, Paraquat and Paraquat salts will be discussed at COP-12 to the RC, and if adopted, the PIC procedure may need to be implemented as early as Oct 2025.

 Proposed Control of Chlorpyrifos under SC

4. In Sep 2024, the Persistent Organic Pollutants Review Committee (POPRC) of the SC also determined Chlorpyrifos to be a persistent organic pollutant that is very toxic to aquatic invertebrates in the environment and can potentially cause adverse effects in mammals. At COP-12 to the SC, the POPRC will likewise be recommending the listing of Chlorpyrifos in SC’s Annex A for the elimination of its production and use, with specific exemptions for certain pest and crop control applications (refer to the following table). If adopted, the elimination of Chlorpyrifos’ production and use would have to be implemented as early as May 2026.

 Controls under the EPMA and EPM (HS) Regulations

5. NEA intends to regulate these chemicals at all concentration levels and in all preparation forms as HS. These chemicals are currently regulated as HS under the EPMA and the EPM(HS) Regs, with exclusions for certain concentrations and preparation forms. Hence, the key amendments to the EPMA and EPM(HS) Regs will involve the removal of all existing exclusions and to list Chlorpyrifos separately as a specific HS instead of grouping it under phosphorus compound.

6. With the proposed control, the manufacture, import, export, purchase, sale, use, transportation and storage of the chemicals will require a HS Licence or Permit, which is to be obtained from NEA. With a valid HS Licence or Permit from NEA, companies can continue to manufacture, import, export, buy, sell, use, transport, and/or store these chemicals after they are regulated as HS.

7. NEA intends to gazette the regulatory changes by May 2025. This would be followed by a six-month transitional period before the changes come into force by Oct 2025.

 Request for Feedback

8. In anticipation of these developments, NEA is seeking feedback on the potential impacts of:

 (i) the controls of these chemicals under the EPMA and EPM(HS) Regs as HS at all concentrations and preparation forms and the removal of exclusions, which are proposed to take effect in Oct 2025. (Nevertheless, with a valid HS Licence or Permit from NEA, companies can continue to manufacture, import, export, buy, sell, use, transport, and/or store these chemicals after they are regulated as HS);

 (ii) the requirement for Prior Informed Consent (PIC) for the transboundary movement of Chlorpyrifos, Paraquat and Paraquat salts, if this procedure is adopted by the RC; and

 (iii) a future ban of Chlorpyrifos, if this measure is adopted by the SC.

9. Comments received during the consultation exercise will be reviewed and may be considered in the development of the final measures.

10. In order to ensure that the consultation is productive and focused, respondents are requested to adhere to the following guidelines when providing their feedback. Respondents should

    • Identify themselves as well as the organisations they represent (if any) so that NEA can follow up in seeking clarifications on any issues raised if necessary.

    • Be clear and concise in their comments.

    • Focus comments on the proposal and how it can be improved.

    • Substantiate points with illustrations, examples, data or alternative suggestions.

¹ More information on the licensing regime under EPMA and EPM(HS) Regs can be found at https://www.nea.gov.sg/our-services/pollution-control/chemical-safety/hazardous-substances/management-of-hazardous-substances