Presented by Samuel Kyamanywa, Makerere University, at the Regional Experts Workshop on Development, Regulation and Use of Bio-pesticides in East Africa, Nairobi, Kenya, 22–23 May 2014

1. Current status of the development, regulation and use of
bio-pesticides in Uganda
Samuel Kyamanywa, Makerere University
Regional Experts Workshop on Development, Regulation and Use of
Bio-pesticides in East Africa, Nairobi, Kenya, 22–23 May 2014

2. Introduction
• BIOINNOVATE is supporting development of bio-technologies to
reduce the impact of biotic and abiotic production constraints in
crops, for the ultimate benefit of resource-poor farmers.
• Project 7 “Bio-pesticide Innovations for Bio-enhancement of Seeds
and Seedlings” has developed a biopesticides based Microbial
agents. This bio-pesticides is applied as seed treatment against
common pests and diseases.
• Although this approach is common in USA and Europe, little use
has been made of this technology in sub-Saharan Africa in spite of
its great potential for vegetable and cereal crops
• Hence the need to analyse the factors limiting adoption of this
technology.
• This report analyses the policy and regulative issues that may be
hampering adoption of the technology in Uganda.

3. Objectives
• To review the policies, regulations and
standards for bio-pesticides, and to identify
key actors and incentives and/or disincentives
affecting the adoption of bio-pesticides in the
country.

4. Methodology
• Under took a desk review of the existing pesticide
(including bio-pesticide) policies, regulations, standards
and other reports and literature associated with
pesticide development and use in the country
• conducted interviews with;-
– (i) regulatory authorities in Ministry of Agriculture Animal
Industry and Fisheries, Ministry of Environment and
Natural Resources,
– (ii) NGOs (iii) pesticide firms, (iv) Bio Pesticide firms
(Kinyara sugar works), (vi) farmers, and
– (vi) scientists involved in the development and use of bio-
pesticides.

5. Methodology
• Identifying the type of bio-pesticides currently in use or being developed in
the country;
• Identifying the relevant regulatory agencies for bio-pesticides management
in the country...
• Identifying government policies governing the process of registration; and
the extent to which management of bio-pesticides are included in national
and sectoral strategies and plans in the country;
• Identifying any incentives that are currently available for adoption of bio-
pesticides in the country.
• Establishing what is the private sector and civil society organizations were
doing to promote use of bio-pesticides in the country (use specific
examples). Identifying the constraints experienced in the promotion of bio
pesticide use and adoption

7. Findings
• Bio-pesticides as pesticides derived from natural materials
such as animals, plants, bacteria, and certain minerals.
Biopesticides are categorizes into:-
– Microbial pesticides: these consist of a microorganism (e.g., a
bacterium, fungus, virus or protozoan) as the active ingredient.
– Plant-Incorporated-Protectants (PIPs): these are pesticidal
substances produced by plants from genetic material that has
been added to the plant.. In this case the protein and its genetic
material are regulated, but not the plant itself.
– Biochemical pesticides are naturally occurring substances that
control pests by non-toxic mechanisms. include substances, such
as insect sex pheromones, that interfere with mating, as well as
various scented plant extracts that attract insect pests to traps
– The Control of Agricultural chemicals Act give a wider
definition of Bio pesticides to include macrobial/invertebrates
such as insects and nematodes and plants extract

8. Advantages Of Using Biopesticides
• Biopesticides are less toxic than conventional
pesticides.
• Biopesticides are target specific, in contrast to broad
spectrum, conventional pesticides which affect a
broad spectrum of organisms
• Biopesticides, when used as a component of
Integrated Pest Management (IPM) programs, can
greatly decrease the use of conventional pesticides,
while crop yields remain high.
• Thus promoting Biopesticide may minimise the
effects of indiscriminate use of pesticides human
health and wildlife populations

9. Bio-pesticides currently in use /or being
developed in the country

10. Bio-pesticides currently in use /or being
developed in the country
• Few Biopesticide registered; of the 567 agricultural
chemicals registered between 2007 and October 2013
only 11 were Biopesticide .
• In USA by 2014, EPA had more than 430 registered
biopesticide active ingredients and 1320 active product
registrations; Uganda has a long way to go in taking
advantage of Biopesticides
• More biopesticides on the market than those know by
the Department of Crop Protection.
• Some of these products may be faked or actual
conventional pesticides being sold as biopesticides

11. Bio-pesticides currently in use /or being
developed in the country
• Balton Uganda Ltd, is piloting marketing of Biopesticides
in Uganda; so far they have four products which include
Neemraz, Neemgold and Levo, and they were directly
selling to the final consumer.
• Website of Bukoola Chemical industries, indicate that they
are dealing in five bio products :- Nimbecidine, Bio-powder,
Bio-catch, Priority, Bionematon, Bio-cure-B&F, Green
Miracle, Bio-magic, Sting and Bacterimycine
• Kinyara sugar limited is registered to produce/manufacture
various biopesticides. They have a well establish
biopesticide production plant, which is supported, by an
advanced microbiology

12. Bio-pesticides currently in use /or being
developed in the country
• Other efforts to promote use of Biopesticides, are
at the National Agricultural Research Laboratory
(NARL) Kawanda where various biopesticides
are being developed and tested.
• Dr. Caroline Nankinga, a scientist at NARL has
developed Beauveria bassiana for control of
Banana weevil. She has developed the product up
level of commercialization.
• The problem has been lack of private investors to
take up the commercialization process.

13. Regulatory Agencies For Bio-Pesticides
Management InUganda.
• The National Environment Management Policy (1994): The policy
document calls for promotion of farming systems, land-use practices
and pest management systems that conserve and enhance land
productivity in an environmentally sustainable manner. This therefore
indirectly supports the use of Biopesticides.
• The National Land Use Policy (2007): The goal of the policy is ‘to
achieve sustainable and equitable socio-economic development
through optimal land management and utilization.’ This policy is
very relevant to and supports indirectly the use of biopesticides. In
NLU policy statement No.10, and No. 20, the policy pledges to
encourage judicious use of agro-chemicals in a way that does not
pollute the environment. ‘Encouragement of judicious use’ is a
strong statement that would help the utilization of biopesticdes if it is
spelt out in the Plant Protection act that Biopesticide are first priority
in controlling pests and disease in Uganda.

14. Regulatory Agencies For Bio-
Pesticides Management InUganda
• The National Bio-technology and Bio-safety Policy (2003)
• Biotechnology is a field of science It refers to the application of
scientific and engineering principles to the processing of materials
using biological agents to provide goods and services. On the other
hand, Bio-safety refers to the safe development, transfer and
application of biotechnology and its products. . It refer to the
mechanisms put in place to regulate or control potential risks that
biotechnology poses to human health, the environment as well as
their socio-economic impacts.
• Therefore Biopestices in the category of Plant-Incorporated-
Protectants would be regulated under this policy. Plant-incorporated
protectants act like pesticides and are produced and used by a plant
to protect it from pests, such as insects, viruses, and fungi..
• The biotechnology and biosafety policy however does not give clear
rules that deal with plant-incorporated protectants (PIPs). It does
not provide guidelines that would be followed in conducting
scientific evaluation for purposes of registration.

15. Regulatory Agencies For Bio-
Pesticides Management InUganda
• The Draft Uganda Organic Agriculture Policy (2009)
– OA seeks to minimise the use of external biological inputs, avoiding
the use of synthetic drugs, fertilizers, and pesticides. And it aims at
optimising the health and productivity of interdependent communities
of soil life, plants, animals and people.
– This objective has a negative impact on promotion of Biopesticides.
• The National Seed Policy (2009)
– The vision of the policy is: ‘competitive, profitable and sustainable,
market-led, regulated, and coordinated seed industry’. The mission
is: ‘to ensure the availability of adequate high quality and safe seed
on the market’.’. Consequently, Seeds treated with microorganism
will be partly regulated by this policy and partly by the Control of
Agricultural Chemicals act and the plant protection act.
– Similarly seed for Plant-incorporated protectants shall be regulated by
this policy.

16. Regulatory Agencies For Bio-
Pesticides Management InUganda
The Agricultural Chemicals (Control) Act, 2006
• The agricultural chemicals control Act of 2006 (Acts
supplement No.1) is an act to control and regulate the
manufacture, storage, distribution and trade in, use,
importation and exportation of agricultural chemicals and
other related matters.
• The Act interprets agricultural chemicals to include:
plant protection chemicals, fungicides, insecticides,
nematicides, herbicides, miticides, bactericides,
rodenticides, molluscides, avicides, fertiliser, growth
regulators, wood preservatives, biorationals, bio-
pesticides, bio-fertilisers or any other chemicals used for
promoting and protecting the health of plants, plants
products and by-products.

17. The Agricultural Chemicals (Control)
Act, 2006
• The act provides for a Board consisting of 13 members.
– Agricultural chemicals are duly registered in the country and are
used in a manner consistent with the rules made by the state.
– It regulate agricultural chemicals imports and advises the
government on matters related to enforcement of provisions of
the statute.
– It appoints an Agricultural Chemicals. Technical Committee
(ACTC) to advise the board on the technicalities of agricultural
chemicals. This committee is responsible for receiving
applications for registration of pesticides, technical analysis, and
verification of the efficacy of agricultural chemicals.
– The Agricultural Chemical Board and its technical committee
fall under the Ministry of Agriculture, Animal Industry and
Fisheries (MAAIF).

18. The Agricultural Chemicals (Control)
Act, 2006
• The regulations, among others, clearly spell out that:
• 1. No pesticide—whether imported or manufactured in Uganda—
shall be used, stored, distributed, or dealt in unless it is duly registered
in accordance with rules and regulations of the Agricultural
Chemicals Statute.
• 2. No person by way of business shall deal in pesticides unless the
same is registered as a fumigator or commercial applicator with a
certificate from the Agricultural Chemicals Board (ABC).
• 3. Any premise used in dealing in pesticides must be appropriate and
registered by the Agricultural Chemicals Board as indicated in the
statutory instrument of 1993.
• 4. Any person employed in the manufacturing, formulating, packaging
and applying of pesticides shall have his/her health monitored, and be
well protected with the appropriate equipment and safe practices.

19. Conditions For a pesticide to be
registered
• It must undergo official screening and testing to prove that it
is effective, safe, and not a danger to public health.
• It must be assessed by the Agricultural Chemical Control
Technical Committee for active ingredient purity, and for
toxicological, public health and environment acceptability.
• The ACB is responsible for appointing a researcher to test the
candidate pesticide following specific standards and
guidelines. The guidelines are currently under review to
conform to international standards.
• A fee of Uganda Shillings two million (2,000,000/=) shall be
paid by the registrant (pesticide manufacturer, reformulator,
re-packager, re-seller, etc.) to cover the cost of testing and
temporary registration

20. Conditions For a pesticide to be
registered
• The new pesticide shall be tested for a minimum of three
crop-growing seasons in different locations in Uganda, to
cover the appropriate agroecological zones.
• Approval shall be granted or denied to a pesticide within six
months from the end of the period required for testing.
Pesticides are registered on the basis of their efficacy.
• The company submitting the pesticide shall provide all
technical information necessary to guide the testing
process—that is, toxicity to humans and the environment, the
toxicity index (LD50), Maximum Residue Limits [MRLs]
and tolerance levels, and any other relevant information.
• A pesticide is (duly) registered on payment of (an additional)
fee

21. Conditions for registration as a
fumigator and/or commercial applicator,
• Submit certified copies of relevant documents
regarding the technical knowledge of the
applicant.
• Pay a fee of Uganda Shillings 500,000/= only
for a certificate of registration that remains
valid until suspended or canceled.
• A tested pesticide shall be recommended for
the control of specific pests on all host crops
rather than for specific crops.

22. Conditions for registration of a premise
as a pesticide seller or related business
• An application on Form F is submitted to the ACB by
the applicant.
• The pesticide business, in relation to the premise, must
be under immediate supervision of a registered
fumigator or commercial applicator.
• A fee of Uganda Shillings 500,000/= is paid to the ACB
for a certificate of registration.
• Registration is for a period of five years, after which a
new application must be made.
• Registration may be canceled by the ACB if any of the
provisions of the Agricultural Chemicals Statute are
contravened.

23. Storage, Labeling, Packaging, and
Transportation
• The agricultural chemicals regulation statutory instruments give
clear details of how storage, labeling, packaging, and
transportation of pesticides ought to be carried out safely. For
example it stipulates, among other things, that:
• No pesticide shall be imported, distributed, sold, or used without
a label; and that such a label should conform to FAO standards.
• There shall be no removal or alteration of the pesticide labels.
• Packaging and re-packaging shall be carried out on premises
registered by the ACB.
• Every manufacturer or distributor of a pesticide shall provide a
range of packaging sizes that can be used safely and
appropriately by small-scale farmers and other users in Uganda

24. Storage, Labeling, Packaging, and
Transportation
• .
• Premises on which pesticides are stored shall be a separate
building strictly for purpose of storage of agricultural
chemical and shall comply with specified requirement of
the statute.
• Pesticide stores and shops shall not be used for sitting or
sleeping.
• Food, feeds, and drinking water shall not be kept in
pesticide premises, and premises shall not be used as
sleeping places for human beings and livestock animals.
• There are shall be sufficient space for storing empty
containers, damaged containers, spills of pesticide, and out-
of-date stocks awaiting disposal.

25. Challenges in Bio-Pesticide
Regulation and Use
Regulatory Framework
• Registration of biopesticide follows the same registration
framework as conventional pesticides. This is a challenge
because biopesticide, by their very nature, are not consistent and
require slight modification system. Similarly biopesticides tend
to pose fewer risks than conventional pesticides, and would
therefore not require a lot of data for registration.
• Many other regulations and acts which impact on Biopesticide
use and registration, it will therefore be necessary to harmonise
how the demands of the various acts will be fulfilled.
• As observed by some members of the registering agency the
long-term solution is a separate regulation and standards for
handling Bio-pesticides within the Control of Agricultural
chemicals Act.

26. Challenges in Bio-Pesticide
Regulation and Use
• Inadequate inspection of manufacturing, storage
and selling premises and advertising and
promotional activities, inspection of farms.
– The legal duties of pesticide inspectors in MAAIF
should include monitoring all premises where
pesticides of any sort are handled or used. This
includes scrutiny for misuse, and for poor quality,
expired or fraudulent products. MAAIF however does
have enough human resource and financial resources
to handle these assignments adequately

27. Challenges in Bio-Pesticide
Regulation and Use
• Capacity of the MAAIF to conduct Biopesticide
evaluation trial
– Scientists can demonstrate that a particular biopesticide
controls the t pests, but not able to ascertain the a.i.
– Fear that some of the products on the market sold might be
conventional pesticides disguised as Biopesticides
– Efforts should be on confirming whether the Biopesticide
contains the appropriate a. i. and it viability.
– Establishing microbiology laboratories with good
analytical capacity. The laboratories should be certified.
• Maintained reference culture material and technical grade, and
• Conduct bio pesticide quality control analysis for purpose of
registration and for post-registration

28. Challenges in Bio-Pesticide Regulation
and Use
• Limited number of Companies applying for registration of pesticides
– there are very few companies submitting applications for registration of
biopesticides. If there is no owner to market the product then the
product is doomed to fail.
– That is the fate of the Biopesticides developed at the NAL Kawanda
and Makerere. There are very few companies interested in investing in
Biopesticides in Uganda (Commissioner of Crop Protection and Dr
Caroline Nankinga).
• Lack of infrastructure at farmers level to Handle Biopesticides
• Lack of Farmer and applicator training and extension programmes
• Post-registration controls – product stewardship

29. Encouraging and facilitating Biopesticide
registration
• The biopesticide are given similar incentives as those given
to any other agricultural chemical. “the only incentive given
to pesticides, including Biopesticides is the tax exemption;
otherwise the Department promotes all pesticides equally”
• Currently developing and promoting of Biopesticides is
mainly by researchers from NARI, and IARI (IITA) and
Makerere University.
• Dr. Nankiga at Kawanda developed Beauveria bassiana
microbial biopesticide up to commercial production. The
farmers had accepted the technology. Similarly IITA
developed Beauveria as an endophyte for managing banana
weevil; The technologies have not taken off because of lack
of linkage with private sector.

30. Encouraging and facilitating Biopesticide
registration
• The role played by private sector in promoting
BIopesticide. Although there are few companies involved
in biopesticide promotion, the coming on board of Kinyara
Sugar Limited to produce and promote the use of Biological
pesticides is a good sign for the future. The impact of
Kinyara in creating awareness among farmers is likely to
be faster because the company is applying the Biopesticide
both on its own sugar cane plantation and on those of out
growers.
• Companies currently using biopesticide are mainly flower
growing companies including Rosebud.
• Balton is currently promoting 4 bioinsecticide. While
Bukoola Chemical industry is also marketing over 5
biopesticide.

31. Recommendations
• Creating awareness of the importance of
Biopesticides in our agricultural production
system.
• Improve on the regulatory processes for
biopesticides- including integration of the various
acts and regulations that impact on biopesticides.
• Strengthening laboratories capacities.
• Nurture the private sector to invest in
biopesticides
• Using Biopesticide based on locally available
microbial agents

32. Expert opinion
• Thank You