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Cases / Pesticides and agrochemicals · Belgium · 2022–2025

Chlorpyrifos: exports of an EU-banned pesticide

Nature's voice · report
No measurement of the harm done to me here is on record.
Did nature suffer? Not measured.
Not on record
  • The record does not name which of my species, waters, soils or forests were harmed.
What the record lacks: 4 none on record · 6 insufficient · 1 not measured · 1 disputed See the gaps

Chlorpyrifos, an insecticide the EU no longer allows, was still notified for export from Belgium and Denmark in the second half of 2022. It was listed for global elimination under the Stockholm Convention in 2025 with 22 exempted uses.

380+ tonnesEU-banned chlorpyrifos notified for export, second half of 2022
European companies notified more than 380 tonnes; 349 tonnes (91%) came from the Belgian company of India-based UPL (Unearthed, 28 March 2023).

Status As of May 2025: chlorpyrifos listed under the Stockholm Convention with 22 exempted uses; no fine or settlement on record.

What?
Export from Belgium and Denmark of a pesticide the EU does not allow, and a later global listing with exemptions. Unearthed (Greenpeace UK)
Where?
Exports from Belgium and Denmark to Algeria, Tunisia, Bangladesh, Pakistan and Costa Rica among others. Unearthed (Greenpeace UK)
When?
Second half of 2022; report of 28 March 2023; Stockholm listing in May 2025. Unearthed (Greenpeace UK)
Who?
Gained
Lost
None on record
Harmed
None on record
Why?
The sources reviewed do not state the exporters' commercial reasons beyond FMC's statement on hazard classification.
How?
Through export notifications filed by European companies under the EU export regime. Unearthed (Greenpeace UK)
6 of 6 questions answered from the record

What happened

The record, in order.

In the second half of 2022, European companies filed export notifications for more than 380 tonnes of chlorpyrifos products, according to an investigation published by Unearthed on 28 March 2023. Of that amount, 349 tonnes (91%) were notified by the Belgian company of India-based UPL. Recipients included Algeria, Tunisia, Bangladesh, Pakistan and Costa Rica. The investigation reported that the substance is banned in the EU, and that the EU had at the same time lowered the permitted residue of chlorpyrifos in imported food to the lowest measurable level.

A Danish exporter was owned by FMC, a United States company. FMC told Unearthed that the substance is not extremely hazardous under the criteria of the UN Food and Agriculture Organization (FAO).

The export of banned pesticides from the EU was broader than chlorpyrifos. EU countries exported about 122,000 tonnes of banned pesticides in 2024, a 50% increase on 2018. About three quarters went to low- and middle-income countries, and about 15,000 tonnes went to Brazil. The European Commission had promised in 2020 to bring forward a legislative proposal by the end of 2023; the promise was not met.

In May 2025 the Stockholm Convention on persistent organic pollutants added chlorpyrifos to its global elimination list, but the number of exempted uses was raised from the 7 recommended by experts to 22.

  1. 2020European Commission promises a legislative proposal on exports of banned pesticides by the end of 2023; the promise is not met
  2. 2022Second half: European companies notify more than 380 tonnes of chlorpyrifos exports; 349 tonnes from UPL's Belgian company
  3. 202328 March: Unearthed publishes its investigation into EU-banned pesticides exported to the Global South
  4. 2024EU countries export about 122,000 tonnes of banned pesticides, 50% more than in 2018
  5. 2025May: Stockholm Convention lists chlorpyrifos for global elimination, with 22 exempted uses

What was said

Claims, in the words of those who made them.

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Should an EU-banned insecticide be exported?
Press and investigations
Unearthed

European companies notified more than 380 tonnes of chlorpyrifos for export in the second half of 2022, while the EU limited residues in imported food to the lowest measurable level.

Unearthed (Greenpeace UK)
Company or project
FMC

The substance is not extremely hazardous under FAO criteria.

Unearthed (Greenpeace UK)
International bodies
Stockholm Convention

Listed chlorpyrifos for global elimination in May 2025, with 22 exempted uses instead of the 7 recommended by experts.

Company or project
UPL

No response on record.

How it looked

What was shown, beside what was recorded.

Shown

  • FMC said chlorpyrifos is not extremely hazardous under FAO criteria.
    FMC, owner of the Danish exporter · Unearthed (Greenpeace UK)

Recorded

  • More than 380 tonnes of chlorpyrifos products were notified for export from Europe in the second half of 2022; 349 tonnes (91%) came from UPL's Belgian company.
  • The EU lowered the residue limit for chlorpyrifos in imported food to the lowest measurable level.
  • The Stockholm Convention listing of May 2025 carries 22 exempted uses against 7 recommended by experts.

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: · Window: . All figures cover the same period. * Estimate built from cited figures.

Responses on record

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

No court case on record. No court has ruled on this case.

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Chlorpyrifos notified for export, H2 2022
380+ t
Of which UPL's Belgian company 349 t (91%)
Stockholm Convention exemptions
22 vs 7
Uses exempted at the May 2025 listing versus uses recommended by experts
Ecological harm data
Not on record
The sources reviewed give no measurement of harm to ecosystems from the exported amounts

What we don't know

Undisclosed, unproven, untried: recorded as data.

Nature

  • Not measured Harm to nature: No independent ecological evaluation is on record.

Court

Accounts

Record

  • Insufficient Reported but not independently verified: the EU did not renew its approval of chlorpyrifos in January 2020, citing concerns about genetic damage (genotoxicity) and brain development.
  • Insufficient Reported but not independently verified: a 2018 re-analysis found that changes in brain size in the raw data of a 1998 rat study by Dow were absent from the summary given to regulators.
  • Insufficient Reported but not independently verified: Corteva, the largest producer, said in 2020 that it stopped producing chlorpyrifos because of falling demand (National Observer, 9 February 2020).
  • Insufficient Reported but not independently verified: India was reported to have received a five-year production exemption under the Stockholm listing.
  • Insufficient Reported but not independently verified: the 2021 US ban was overturned by a court in 2023, and the US Environmental Protection Agency proposed in 2024 to keep use on 11 products.
  • Insufficient Reported but not independently verified: Dow gave USD 1 million to a US presidential inauguration, and the EPA's reversal on a chlorpyrifos ban followed a meeting on an official's schedule 20 days earlier; the EPA says that meeting was cancelled.
  • None on record No fine or settlement against any party concerning chlorpyrifos is on record in the sources reviewed.
  • None on record The sources reviewed give no response from UPL.

Did the harm stop?

Not established: the sources reviewed record exports in 2022 and a global listing in 2025 with exemptions, but no date on which exports of the substance from the EU stopped.

Who paid?

Not established in the sources reviewed; they record no fine, settlement or compensation.

Sources

Voices on record: — Company or project— Government and regulators— Courts✓ Press and investigations— Communities and civil society— Researchers

Press and investigations

  1. EU-banned pesticides exported to the Global South
    Unearthed (Greenpeace UK) · 2023-03-28
  2. Corteva to stop producing chlorpyrifos
    National Observer · 2020-02-09

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Institutions

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The US Environmental Protection Agency.

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