The final criteria that affect which active substances will be removed are still being defined - especially the term endocrine disruptors - but Adlam is still able to say that the effect of the proposals will be drastic for growers and garden centres.
"More than 40 products or around 80 per cent will be removed from the shelves of garden centres, leaving gardeners with very little control for the majority of garden pests and diseases," said Adlam. "The range of selective lawn weedkillers will also be lost, leaving gardeners with hand-weeding as the only means of controlling weeds in the lawn."
The "candidates of substitution" element of the legislation, he said, "will have an economic effect on growers who will find that the alternative products are often more expensive than the ones being lost".
Adlam admitted that in many respects the Thematic Strategy is "common sense" and progressive growers will find it has little effect on some of their current practices.
But he said that "it will, however, stifle new product development and place a higher emphasis on biological control on both outdoor and protected crops".
His main concern is that the legislation has been designed to have an impact on agriculture, and no thought has been given to the horticultural sector.
"Ornamental crops, which are not consumed, have not been taken into account. Growers in this sector use smaller areas and grow crops under protection.
"Aspects such as buffer zones, bystander notification, residue monitoring and the need to certify even a new knapsack sprayer will place disproportional burdens on ornamentals growers. Much of the Voluntary Initiative, which we have all willingly embraced, will suddenly become law," he added.
Adlam is also concerned that "in the flurry of current activity other crop protection issues of equal importance to ornamental growers have been overlooked".
These include the transfer of Long Term Arrangements for Extension of Use (LTAEU) to Specific Off-Label Approvals (SOLAs) and the Sustainable Use Directive, which aims to minimise or prohibit pesticide use in parks and other public spaces.
"Much of this legislation fails to take the differences of horticulture to agriculture into account, leaving ornamentals growers disadvantaged," Adlam concluded.
Users need to ensure that their paperwork is updated from 1 January, when up to 40 products that had LTAEUs will need SOLAs.
- Check the products list at www.the-hta.org.uk and download the SOLAs you need from www.pesticides.gov.uk.