Resolution of the IV Congress of the All-Russian Public
organization "Industrial Beekeepers of Russia"
Participants of the IV Congress of the all-Russian public organization “Industrial Beekeepers of Russia” (hereinafter also referred to as the Organization) note the following. The organization, in accordance with the Charter and the resolution of the Third Congress of the Organization, carried out the following work during 2023.
During the period 2022 - 2023, within their competence, members of the Organization took an active, direct part in improving the legal framework for the beekeeping sub-sector. In total, six draft federal laws were developed, of which one became a Federal Law, two bills were submitted to the State Duma and accepted for consideration, one is under consideration by the Government of the Russian Federation, one was approved by the relevant committee of the legislative body of the Subject of the Russian Federation, one was sent to the senators of the Russian Federation and deputies of the State Duma, possessing the right of legislative initiative to consider the issue of introducing it to the State Duma.
These bills are aimed at regulating legal relations regarding beekeeping in the following part:
- clarification of the timing of notifying the population about pesticide treatments (the corresponding bill No. 222259-8 was introduced in 2022 by the Tyumen Regional Duma and became Federal Law No. 306-FZ);
- postponing the date of entry into force of Law No. 306-FZ to an earlier date (No. 500293-8 was submitted to the State Duma on November 30, 2023 by the Tyumen Regional Duma);
- clarification of the procedure for action by the owner of the apiary and public authorities in the event of poisoning of bees with pesticides (No. 518043-8 submitted to the State Duma by the Tyumen Regional Duma on December 22, 2023).
- strengthening penalties for violating the rules for the circulation of pesticides (the Tyumen Regional Duma adopted a resolution dated December 14, 2023 to be submitted to the State Duma after receiving feedback from the Government of the Russian Federation);
- clarification of the concepts of “apiary”, “bee colony” and objects subject to marking under the group accounting method (the specialized committee of the Kostroma Regional Duma made a decision dated January 12, 2024 to submit it to the Kostroma Regional Duma for consideration of the issue of introducing it to the State Duma);
- establishing rules for the use of the word “honey” and other words related to beekeeping in civil circulation (01/11/2024 sent on behalf of the Organization to senators of the Russian Federation and State Duma deputies who have the right of legislative initiative, to consider the issue of introducing it to the State Duma).
In addition to the development of federal laws, the Organization in 2023 took an active part in the discussion of a number of draft by-laws, including the draft Veterinary Rules for Labeling and Recording of Animals (Approved by Order of the Ministry of Agriculture of Russia dated November 3, 2023 No. 832, effective from March 1, 2024).
However, so far the consolidated position of the two public organizations has not been fully taken into account, including due to shortcomings in the formulation of the concepts of “apiary and “bee colony”” contained in the current version of the Federal Law “On Beekeeping in the Russian Federation.” The organization sent a proposal to include a representative of Industrial Beekeepers of Russia LLC in the Technical Committee for Standardization “Beekeeping” (TC 432).
Not the least role (along with appeals from scientific institutions and other public organizations) was played by the Organization’s appeals to the Ministry of Agriculture of Russia and Rosselkhoznadzor on the need to ban the import of bee packages from Uzbekistan, due to the systematic failure to comply with the Unified Veterinary (Veterinary and Sanitary) Requirements for Goods , subject to veterinary control, creates a threat of introduction into the territory of the Russian Federation and spread of especially dangerous diseases for bees on its territory.
Rosselkhoznadzor made a corresponding decision to suspend the import of bees into Russia from the Republic of Uzbekistan from April 28, 2023 until comprehensive measures are taken by the competent department of the Republic of Uzbekistan to ensure the registration of only those batches of bee packages that are sent to the addresses of actual consignees, where after import they will be quarantined in accordance with Requirements (Letter of Rosselkhoznadzor dated April 25, 2023 No. FS-KS7/10156).
In 2023, the most pressing problem in beekeeping continues to be the problem of bee poisoning with pesticides. The relevance of this problem is evidenced by the fact that on a direct line with the President of Russia V.V. On December 14, 2023, Putin received more than 30 thousand questions on the topic of solving the problem of the safe use of pesticides. According to the results of a survey conducted in December 2023 by the Organization among its members, 13% of industrial beekeepers in 2023 encountered bee poisoning with pesticides.
At the same time, the Organization believes that the widespread opinion that only compliance with existing regulations on the use of pesticides ensures their safety and is a solution to the problem requires a critical attitude.
This position does not take into account that the conditional safety of using highly hazardous pesticides can only be ensured by transporting bees to a distance of at least 10 km from the fields where such pesticides are used, or by isolating bees in a hive for a long period of time. Such methods of escape from poisoning cannot be considered acceptable, because the method of escaping pesticides by escaping or isolating bees in the hive always entails a shortage of products, lost profits or additional transportation costs. Accordingly, such methods violate the rights and legitimate interests of beekeepers, and in some cases cannot be carried out due to objective circumstances.
In order to obtain scientifically based recommendations for making management decisions, the Tyumen Regional Duma, on the initiative of members of the Organization, sent an appeal to the Ministry of Agriculture of Russia, the Ministry of Education and Science and the Academy of Sciences in 2023. The Appeal substantiated the need to include among the topics of research work carried out on government orders topics that would provide for a comparative assessment of the economic efficiency of using technologies using highly hazardous pesticides, on the one hand, and technologies using pesticides that are not dangerous to bees, on the other hand.
The Russian Academy of Sciences responded that it was interested in promoting this topic, and said that it would entrust it to the Research Institute of Agriculture of the Northern Trans-Urals, a branch of the Tyumen Scientific Center SB RAS. However, there was no confirmation of the Ministry of Education and Science’s readiness to finance these studies. In the current conditions, many members of the Organization, as well as other public organizations, are individually working with farmers to replicate the positive experience of using pesticides on rapeseed that are not dangerous to bees. For example, in Tatarstan in 2023, already 8% of the rapeseed area was treated with biopesticides; in 2024, the use of biopesticides is planned to increase.
Members of the Organization express confidence that the development of beekeeping in Russia and its transfer to an industrial basis will be possible only if the state takes a strategic course towards scientifically based replacement of highly hazardous pesticides with pesticides of biological origin, and the wider use of entomophages as plant protection products.
Considering the above, in accordance with the Charter of the Organization, the Congress
DECIDED:
1. Instruct the Council, Chairman and territorial branches of Industrial Beekeepers of Russia LLC:
1.1. Continue work to achieve the statutory goals, paying special attention to the following areas:
- participation, within its competence, in the preparation of legislative initiatives aimed at improving legislation on beekeeping;
- consulting beekeepers on issues of law enforcement;
- active interaction with public authorities at all levels when considering issues related to beekeeping;
- interaction with other public organizations of beekeepers and federal research centers in order to increase agricultural yields, the quality and quantity of domestically selected seeds obtained, the development of Russian production of fruit and berry crops by realizing the potential of using bees for pollination;
- import substitution of breeding material (imported queen bees and bee packages) through the creation of a network of domestic breeding beekeeping farms;
- taking actions aimed at including bee breeds used in domestic industrial beekeeping in the list of breeding achievements permitted for use on the territory of the Russian Federation;
- collection and dissemination of scientific data among farmers on the effect of pollination on crop yields;
- formation of public opinion on the need to ban the use of pesticides of classes 1 and 2 for bees on entomophilous crops during their flowering period (with their replacement with biopesticides and entomophages);
- building capacity for large-scale export supplies of honey through the development of a network of regional consumer supply, marketing and processing cooperatives in beekeeping;
- assistance in the promotion of Russian beekeeping products of guaranteed quality in foreign and domestic consumer markets;
- consideration of the issue of regular supplies of honey to government educational institutions, the army and navy;
- promotion of a healthy diet among the population with the mandatory inclusion of beekeeping products in the diet;
- collecting and sending honey as humanitarian aid to army units participating in a special military operation.
2. Recommend that Deputies of the State Duma of the Federal Assembly of the Russian Federation support the following draft federal laws:
- No. 500293-8 “On amendments to Article 3 of the Federal Law “On amendments to Article 15.2 of the Federal Law “On the Safe Handling of Pesticides and Agrochemicals” and Article 16 of the Federal Law “On Beekeeping in the Russian Federation” (in terms of clarifying the entry date by virtue of);
- No. 518043-8 “On amendments to the Federal Law “On Beekeeping in the Russian Federation” (in terms of clarifying the actions of the apiary owner and authorities in the event of bee poisoning with pesticides);
- “On amendments to Articles 3.5 and 8.3 of the Code of the Russian Federation on Administrative Offenses” (in terms of increasing penalties for violating the rules for handling pesticides and agrochemicals), (if it is submitted to the State Duma);
- “On amendments to Article 2 of the Federal Law “On Beekeeping in the Russian Federation” and Article 19.1 of the Law of the Russian Federation “On Veterinary Medicine” (in terms of clarifying the concepts of “apiary”, “bee family” and objects subject to labeling under the group accounting method) , (if it is submitted to the State Duma);
- “On amendments to the Federal Law “On Beekeeping in the Russian Federation” (in terms of establishing rules for the use of the word “honey” and other words related to beekeeping in civil circulation), (if it is introduced to the State Duma).
3. Express gratitude for the effective work in improving legislation on beekeeping: Tyumen Regional Duma; Kostroma Regional Duma.
4. Invite the Government of the Russian Federation to consider the following issues:
4.1. Supplement the Strategy for the Development of Agricultural and Fishery Complexes until 2030, approved by Order of the Government of the Russian Federation dated September 8, 2022 No. 2567-r, with target indicators that set guidelines for the development of beekeeping in the Russian Federation.
4.2. To supplement the State program for the development of agriculture and regulation of markets for agricultural products, raw materials and food, approved by Decree of the Government of the Russian Federation of July 14, 2012 No. 717, with the task of developing industrial beekeeping in the Russian Federation.
4.3. Supplement the Federal Scientific and Technical Program for the Development of Agriculture for 2017 - 2030, approved by Decree of the Government of the Russian Federation dated August 25, 2017 No. 996, with the following tasks: - instruct the Ministry of Education and Science of Russia to include in the list of scientific research work carried out on state assignments a topic involving comparison of the economic efficiency of technologies using pesticides of the 1st and 2nd classes of hazard for bees on entomophilous crops and technologies for using pesticides on such crops biological origin and entomophages. - supplement the task “creation and implementation of technologies for the production of pesticides and agrochemicals for use in agriculture” with the words “including pesticides of biological origin.”
4.4. Add clause 22 of the Government of the Russian Federation of June 30, 2021 No. 1067 (as amended on June 27, 2023) “On approval of the Regulations on federal state control (supervision) in the field of safe handling of pesticides and agrochemicals” with standards, allowing the inspector of Rosselkhoznadzor, during random control and on-site inspection, to take samples not only of solutions of pesticides and agrochemicals (their residues), soil, drainage water, waste associated with the use of pesticides and agrochemicals, plants, but also samples of dead bees and unsealed liquid honey in hives.
4.5. Amend the Decree of the Government of the Russian Federation of September 21, 2023 No. 1538 (as amended on December 27, 2023) “On the rates of export customs duties on goods exported from the Russian Federation outside the customs territory of the Eurasian Economic Union, and on amendments to the rates of export customs duties for goods exported from the Russian Federation outside the customs territory of the Eurasian Economic Union" in terms of establishing the customs rate for natural honey (group 04) at 0%.
4.6. Adopt a regulatory legal act establishing the composition, procedure for convening and work of the commission, which can be convened at the initiative of the owner of the apiary in order to record quantitative data necessary to determine the amount of damage, take samples of pathological material, establish the presumed cause of death of bees (establish a probable diagnosis), and also the form of the inspection report of the affected apiary, the methodology for calculating economic damage from the death of bees, the rules for diagnosing and preventing bee poisoning with pesticides.
4.7. Consider classifying the use of pesticides and agrochemicals as extremely high-risk control objects.
4.8. Consider the issue of re-establishing in the country a specialized state zootechnical service for beekeeping with branches in the constituent entities of the Russian Federation, by analogy with the Rospcheloprom that existed in the USSR, and (or) establishing a special department for beekeeping within the Ministry of Agriculture (by analogy with the Department of Fish Farming created in 2022).
4.9. In carrying out the President’s instructions on adjusting the Development Strategy of the agro-industrial and fishery complexes of the Russian Federation for the period until 2030 (approved by Order of the Government of the Russian Federation dated April 12, 2020 No. 993-r), the task of the Ministry of Agriculture of Russia, together with the All-Russian public organization “Industrial Beekeepers of Russia”, is to develop a program development of industrial beekeeping in the Russian Federation.
4.10. Develop and adopt a draft regulatory legal act on stimulating plant growers to use less toxic pesticides and biological plant protection products.
4.11. Develop and adopt a draft regulatory legal act providing for subsidizing part of the costs of agricultural producers to pay for the services of beekeepers for pollinating crops.
4.12. To supplement the list of professions for training in which educational organizations are provided with subsidies from the federal budget and budgets of constituent entities of the Russian Federation for the implementation of vocational training and retraining programs in order to provide agricultural producers with qualified specialists (Draft Resolution of the Government of the Russian Federation "On Amendments to Appendices No. 6 and 7 to the state program of the Russian Federation “Integrated development of rural areas”, project ID 01/01/03-23/00136457), profession “beekeeper”.
5. Recommend to the Russian Ministry of Agriculture:
5.1. To supplement the list of indicators of the risk of violation of mandatory requirements used in the implementation of federal state control (supervision) in the field of safe handling of pesticides and agrochemicals, approved by Order of the Ministry of Agriculture of Russia dated May 26, 2023 No. 530, in case of mass sudden death of bees.
5.2. Create a permanent working group under the Ministry of Agriculture of Russia to develop normative legal acts on beekeeping issues, including in it a representative of the All-Russian public organization “Industrial Beekeepers of Russia”.
5.3. When fulfilling the President's instructions to increase the volume of funding for the State Program for the effective involvement of agricultural land in circulation, consider the possibility of subsidizing the costs of local governments to preserve the fertility of municipally owned agricultural land plots that have found themselves unclaimed in civil circulation (not leased for a long time and not purchased at auction), by sowing perennial honey plants in such areas.
5.4. Create a state online resource accumulating all existing and planned developments in selection and breeding work in the country for all breeds of bees, led by the competent scientific center of the Russian Academy of Sciences.
5.5. Consider amending the Veterinary Rules for organizing work on the preparation of veterinary accompanying documents (approved by order of the Ministry of Agriculture of Russia dated December 13, 2022 No. 862), in terms of equating nomadic beekeeping with transhumance cattle breeding in terms of exemption from the obligation to prepare veterinary accompanying documents for movement within the territory of a constituent entity of the Russian Federation, adding subclause “d” of clause 21 of these rules , after the words “transhumance” with the words “nomadic beekeeping”.
6. Recommend to Rosselkhoznadzor:
6.1. Extend the regime restricting the import of bee packages from the Central Asian republics until 2024.
6.2. Ensure strengthening of state control (supervision) over compliance with regulations on the use of pesticides and agrochemicals;
6.3. To ensure strengthening of state veterinary control at checkpoints across the border of the Russian Federation in order to prevent the import of bees into the territory of the Russian Federation without accompanying veterinary documents, to ensure compliance with quarantine standards upon arrival at the destination.
6.4. It is mandatory to send to the authorized executive authorities of the constituent entities of the Russian Federation materials confirming the failure to eliminate offenses in the field of pesticide trafficking that resulted in harm to the environment, including the mass death of bees (clause 4 of article 6 of the Federal Law of July 24, 2002 No. 101-FZ “On the turnover of agricultural land”).
7. Recommend to Rospotrebnadzor:
Strengthen control over compliance by agricultural producers with the requirements of paragraph 4.3 of sanitary and epidemiological rules and regulations of SanPiN 2.2.1/2.1.1.1200-03 “Sanitary protection zones and sanitary classification of enterprises, structures and other objects” on the need to establish, by decision of the chief state sanitary doctor of a constituent entity of the Russian Federation, sanitary protective zones around industrial facilities and production of hazard classes III, IV and V (including around land plots with the type of permitted use “for agricultural production”).
8. Recommend to the Chief State Sanitary Doctor of the Russian Federation:
Consider amending SanPiN 2.1.3684-21 “Sanitary and epidemiological requirements for the maintenance of territories of urban and rural settlements, water bodies, drinking water and drinking water supply, atmospheric air, soils, residential premises, operation of industrial and public premises, organizations and carrying out sanitary and anti-epidemic (preventive) measures”, approved by the Decree of the Chief State Sanitary Doctor of the Russian Federation dated January 28, 2021 No. 3, providing for:
- increasing the distance from areas treated with hazard class 2 pesticides (for bees or humans) to populated areas, sources of drinking and cultural water use, places of recreation for the population, fishing, grazing areas, and beekeeping from 300 to 1000 meters.
- a ban on the use of pesticides of class 1 hazard for bees at a distance closer than 10 km from populated areas.
9. Recommend to government bodies of the constituent entities of the Russian Federation
9.1. Consider the following issues:
- on the possibility of subsidizing 50% of the cost of purchasing plant protection products to agricultural producers who have refused to use pesticides of classes 1 and 2 for bees (highly hazardous and moderately hazardous) on entomophilous crops, in favor of low-hazard and practically non-hazardous plant protection products (biopesticides and entomophages).
- on amendments to the regulatory legal acts of the constituent entities of the Russian Federation establishing the procedure for providing state support measures to agricultural producers, providing as a condition for such support that the applicant does not violate the procedure for the circulation of pesticides during the year preceding the date of filing the application for state support.
9.2. To formulate a law enforcement practice of going to court with a requirement to confiscate an agricultural land plot from its owner in the event that Rosselkhoznadzor receives materials confirming the failure to eliminate offenses in the field of pesticide trafficking, which resulted in harm to the environment, including the mass death of bees (subparagraph 3 clause 1, clause 5 of article 6 of the Federal Law of July 24, 2002 No. 101-FZ).
10. To local authorities:
In the event of an appeal from the owners of apiaries where a massive sudden death of bees has occurred, facilitate the convening of a commission in order to record the quantitative data necessary to determine the amount of damage, take samples of pathological material, and establish the suspected cause of bee death.
Source: https://vk.com/soiuzppts