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CropLife Europe

CropLife Europe is the association representing the crop protection industry in Europe.

Lobbying Activity

Meeting with Cristina Maestre (Member of the European Parliament)

27 Jan 2026 · Simplification Omnibus for Food and Feed Safety

Meeting with César Luena (Member of the European Parliament)

14 Jan 2026 · Food and Feed Safety Omnibus

Meeting with Gilles Pennelle (Member of the European Parliament)

14 Jan 2026 · Agriculture

Meeting with Flavio Coturni (Head of Unit Trade)

13 Jan 2026 · Exchange of views on the Omnibus regulation.

Meeting with Oliver Sitar (Director Agriculture and Rural Development)

16 Dec 2025 · Exchange of views on legal cases concerning crop protection

Meeting with Norbert Lins (Member of the European Parliament)

4 Nov 2025 · Simplification package for food and feed safety

Meeting with Almut Bitterhof (Head of Unit Health and Food Safety)

3 Nov 2025 · CLE asked E4 for a meeting for an exchange on the EFSA Strategy on Specific Protection Goals for Non-Target Terrestrial Organisms and on Principles for the Assessment of Environmental Risks Acceptability of PPPs

Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis) and European farmers and

28 Oct 2025 · Roundtable on Simplification for Agricultural Innovation

Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis)

15 Oct 2025 · simplification

CropLife Europe calls for faster approvals and reduced regulation

13 Oct 2025
Topic — EU regulation on plant protection products, biocides, feed additives and food hygiene.
Message — The organization requests streamlined approval processes for crop protection products, especially biopesticides, and reduced re-registration requirements. They want proportionate risk assessments aligned with real-world use, clearer timelines, and an agro-economic expert group to assess alternatives before withdrawals.1234
Why — This would speed market access for their products and reduce compliance costs.56
Impact — Environmental and consumer groups lose comprehensive safety assessments and faster withdrawal of harmful substances.78
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CropLife Europe urges flexibility for pesticide data requirements

9 Oct 2025
Topic — The consultation concerns revising data requirements for the approval of active pesticide substances.
Message — CropLife Europe requests clearer definitions for impurities and flexibility for seasonal bee testing. They suggest the two-generation reproductive study remain acceptable to ensure global alignment.12
Why — These changes would lower costs by avoiding redundant tests and unvalidated requirements.34
Impact — Environmental groups lose because surrogate testing may fail to protect specific bee species.5
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CropLife Europe Seeks Six-Year Transition for Co-Formulant Ban

8 Oct 2025
Topic — EU regulation adding fourteen unacceptable co-formulants to plant protection product restrictions.
Message — The organization requests a six-year transition period instead of the proposed timeline, arguing companies need time to reformulate products, develop alternatives, and obtain regulatory approvals. They also want the concentration limit for 2-pyrrolidone aligned with existing CLP regulation at 3%.123
Why — This would give them more time to reformulate products and reduce compliance costs.45
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Meeting with Elisabeth Werner (Director-General Agriculture and Rural Development) and Agrární komora České republiky and

8 Oct 2025 · Plant protection products - maintaining a competitive and resilient agricultural toolbox in the EU

Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur)

8 Oct 2025 · Biocontrol and NGTs

Meeting with Sandra Gallina (Director-General Health and Food Safety) and

8 Oct 2025 · Plant protection products - maintaining a competitive and resilient agricultural toolbox in the EU.

Meeting with Valérie Hayer (Member of the European Parliament)

8 Oct 2025 · Biocontrol, simplification, NGTs

Meeting with Pietro Fiocchi (Member of the European Parliament, Shadow rapporteur)

8 Oct 2025 · Omnibus VI

Meeting with Alexander Bernhuber (Member of the European Parliament, Rapporteur)

1 Oct 2025 · Biologische Pflanzenschutzmittel

Meeting with Aidan O'Connor (Head of Unit Health and Food Safety), Almut Bitterhof (Head of Unit Health and Food Safety)

29 Sept 2025 · Question on F2F Trends and SUD Audits

Meeting with Ana Vasconcelos (Member of the European Parliament)

24 Sept 2025 · NGTs

Meeting with Claire Bury (Deputy Director-General Health and Food Safety) and

17 Sept 2025 · EFSA’s performance evaluation

Response to European Innovation Act

11 Sept 2025

The Commissions ambition to strengthen the conditions for innovation within the EU must recognise agriculture as a strategic sector. Representing 25 companies and 32 national associations, our members develop pesticides, biopesticides, digital and precision agriculture tools and innovative crop traits using biotechnology. Innovation in agriculture has a direct impact on Europes competitiveness, food security and sustainability. The Innovation Act should create the right framework for agricultural innovation to thrive. Our sector has consistently been at the forefront of innovation, investing in R&D and delivering solutions that enable farmers to produce more with fewer resources. New crop protection technologies and digital tools ensure that products are applied in the right amount, in the right place and at the right time. New seed solutions allow farmers to choose the crops they need in their specific operations. All this reduces environmental impact while increasing productivity. It helps farmers adapt to climate change, manage resistant pests and diseases and safeguard yields while securing the position of Europe in the global scheme of interrelated economies. Agricultural innovation is therefore both an enabler of efficiency and an effective driver of Europes competitiveness in global food systems. Despite these advances, innovation in agriculture is often held back by regulatory fragmentation, limited opportunities for testing new technologies under real conditions and an absence of clear EU-level guidance on precision application methods. To unlock the potentials of biotechnology, AI, and other gamechangers, a stronger focus on regulatory sandboxes, harmonised approaches to precision technologies such as drones, and a framework that supports digital decision support systems would allow farmers to benefit more rapidly from these innovations. Embedding these tools in EU training platforms and demonstration farms would also accelerate uptake, especially among younger farmers. Adequate IP framework is necessary to enable innovation, simplified approval mechanisms for new solutions can lead to faster uptake of track setting innovations that put and keep Europe on the global map of innovation hubs. A transition to an outcome-based policy and regulatory framework is essential to stimulate innovation in agriculture. Such a framework creates an environment that enables innovation in effective biological, chemical, mechanical and digital tools, helping farmers improve the sustainability of their farming systems and the value chains they support, and provides innovators with creative freedom to find the best solutions to reach the desired outcomes. The specific crop protection regulations should be guided by the Innovation Principle, to ensure that any potential impacts on innovation are taken into consideration when regulatory decisions are made. Promoting responsible innovation in more sustainable plant protection solutions is key to controlling and reducing risks (pests diffusion, depletion of environmental resources, etc) while achieving the objectives of food security. If the European Innovation Act is to achieve its objective of creating a level playing field for innovation, it must include the agricultural sector. Our sectors innovation pipeline is delivering solutions that contribute to food security, competitiveness and environmental protection simultaneously. With the right regulatory and policy environment, the Act can ensure that these innovations are deployed within Europe rather than elsewhere. The European Innovation Act is an opportunity to reinforce Europes leadership in agricultural innovation. Recognising the strategic importance of our sector and ensuring that the Act fosters innovation in crop protection, biopesticides, biotechnology including the new genomic techniques, digital and precision agriculture will be vital for Europe to reap the long-term benefits for farmers and society as a whole.
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CropLife Europe urges port controls against illegal pesticides

28 Jul 2025
Topic — The consultation seeks to address security, competitiveness, and sustainability in European ports.
Message — The organization calls for harmonized inspection standards and stricter enforcement of movement bans on unauthorized pesticides. They propose using ports as hubs for screening samples and standardizing detection via an EU laboratory.123
Why — Tighter port enforcement protects industry market share by preventing counterfeit pesticides from entering Europe.45
Impact — Illegal traders and criminal networks lose profits from exploiting regulatory loopholes in port transit procedures.67
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Meeting with Carlo Fidanza (Member of the European Parliament) and A2A

2 Jul 2025 · legislative updates

Meeting with Flavio Facioni (Cabinet of Commissioner Olivér Várhelyi)

27 Jun 2025 · Food safety simplification

Meeting with Valérie Hayer (Member of the European Parliament)

23 Jun 2025 · biocontrol

CropLife Europe urges faster approval of innovative agri-tech tools

19 Jun 2025
Topic — This consultation explores solutions for a circular and climate neutral EU bioeconomy.
Message — They request a simplified approval package for biopesticides and digital farming tools. The group also pushes for a pragmatic framework for new genomic techniques.12
Why — Faster market entry would protect their fourteen billion euro investment in new technologies.34
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Response to Establishment of an expert panel on orphan and paediatric devices

16 Jun 2025

Dear colleagues, dear friends, Thank you for this very important information. I fully agree with the initiative to start the problem of procuring consumables for hemodialysis and peritoneal dialysis. As a pediatric nephrologist who has been doing HD and PD for years, I constantly for many years face the same problems of not having catheters of different sizes for children to perform HD and PD. I feel very frustrated and I'm constantly stressed about what to do if I have a small child and I don't have a catheter. I wonder what is the use of our knowledge, great education, when it cannot be applied in practice. Since I work at the tertiary level of health care and am a subspecialist in pediatric nephrology, it is normal that I do all kinds of dialysis techniques and plasmapheresis and that I have everything I need. Since the situation with consumables is terrible in the 21st century, I am forced to improvise just to save the lives of patients. I even thought that I would transfer children who require dialysis techniques or plasmapheresis to other countries, but I see that the situation is the same everywhere. Unfortunately, when you have difficult patients, you don't have time to organize transfers to other countries either. Dialysis techniques, plasmapheresis are needed not only by nephrology patients but by all other pediatric specialties. I agree with Prof.dr. Novljan that the opportunity to bring these challenges directly to the EU Health Commissioner is indeed unique and must be seized. The entire pediatric community, that is, the entire medical profession, parents, the state, etc., should be involved in this problem. I am available if I can help. Kind regards Danka Pokrajac Head of the Pediatric Nephrology Department Pediatric Clinics, University Clinical Center Sarajevo Bosnia and Herzegovina
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Response to Biotech Act

6 Jun 2025

CropLife Europe supports the objective of the European Biotech Act to strengthen the EUs global competitiveness in biotechnology. We believe the Act must address the major regulatory and perception barriers that limit the potential of agricultural biotechnology to contribute to EU food security, sustainability, and innovation. Biopesticides and genetically modified (GM) crops are essential tools in the transition to a more sustainable and innovative farming sector. CropLife Europe welcomes the European Commissions effort to streamline and improve regulatory frameworks, making them more agile and fit for purpose, while ensuring consistency and alignment across all relevant legislation. In the context of food and feed applications of biotechnology, CropLife Europe believes it is essential to streamline the authorisation process for GM imports and crop cultivation. This area clearly demonstrates both the regulatory complexity and the perception barriers faced by biotechnology, despite its proven benefits for the economy, society, and the environment. Today, bringing GM crops to the EU market is excessively burdensome. The authorisation process for EU imports takes, on average, five years - several times longer than in other jurisdictions - and costs around 20 million for single events, with substantially higher costs for stacked products. This is disproportionate and out of step with international practice. It also undermines EU supply chains, given the EUs reliance on imports to meet over 70% of its demand for high-protein feed. Regulatory simplification is urgently needed. Proportionate, science-based procedures can reduce cost and delay while maintaining high safety standards. CropLife Europe calls for alignment with global best practices by addressing the following priorities: minimising duplication in risk assessments for GM stacked events; eliminating unnecessary renewal requirements for GM imports; adopting a tiered, risk-based approach for animal feeding studies; and improving transparency in the derogation process for unnecessary data requirements. More details on each of these points, as well as other examples of streamlining opportunities, can be found in the attachment. For GM cultivation in the EU, the authorisation system is effectively paralysed: no new GM crops have been authorised in over 25 years, despite positive safety assessments. As a result, GM crops are not developed for cultivation in the EU, depriving EU farmers of tools that over 17 million farmers globally have been using for decades to address agronomic and environmental challenges. This puts EU agriculture at a competitive disadvantage, one that is only set to increase as biotechnology innovation accelerates. Based on past experiences in other countries, GM cultivation can drive agricultural R&D, creating highly qualified jobs in biotechnology, agri-tech companies, and public research programmes. It fosters innovation, interdisciplinary collaboration, and global competitiveness of the EU biotech sector. Central to the challenges faced by the import and cultivation of GM crops in the EU are misguided perceptions about this technology. In parallel with any regulatory simplification in this field, the EU must review how it communicates on agricultural biotechnology. Misinformation has fuelled distrust among consumers and farmers alike, stalling policy progress. A future European Biotech Act must aim to build public trust and improve the social licence of biotechnology in EU agriculture. Science-based, consistent communication on the safety record of GM products worldwide, as well as their role in supporting competitiveness, resilience, and sustainability in EU farming, is key to improving acceptance and, consequently, encouraging the development of solutions tailored for EU agriculture.
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Meeting with Almut Bitterhof (Acting Head of Unit Health and Food Safety)

2 Jun 2025 · Draft Regulation amending Annex III to Regulation (EC) No 1107/2009 (list of unacceptable co-formulants)

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen)

6 May 2025 · Exchange of views on the implementation of the Vision for Agriculture and Food and Simplification

Meeting with Almut Bitterhof (Acting Head of Unit Health and Food Safety)

30 Apr 2025 · Crop Life Europe requested a meeting to discuss different aspects related pesticide residues Maximum Residue Levels (MRL)

CropLife Europe urges faster approvals for agricultural biotech innovation

16 Apr 2025
Topic — This consultation seeks to improve the competitiveness of the European life sciences.
Message — CropLife Europe requests faster market access through "provisional authorisations" and a "future-proof definition" of biopesticides. They also advocate for "simplification proposals" for biotechnology, including "eliminating the renewal requirement" for proven imports. Finally, they seek to "unlock the potential" of digital tools in farming.123
Why — Faster approvals would reduce compliance costs and speed up product commercialization.45
Impact — Animal welfare groups may lose protections if "mandatory" toxicity studies are reduced.6
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Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair)

8 Apr 2025 · Pesticides and biocontrol

Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur)

31 Mar 2025 · NGTs and Biocontrol

Meeting with Flavio Facioni (Cabinet of Commissioner Olivér Várhelyi)

26 Mar 2025 · Priorities and challenges for the agri-food sector

CropLife Europe urges including agriculture in EU green taxonomy

24 Mar 2025
Topic — The initiative modifies EU sustainability reporting to be simpler and more cost-effective.
Message — CropLife Europe wants agriculture recognized as an eligible activity in the green taxonomy. They suggest farmers meet environmental standards simply by complying with existing pesticide regulations.12
Why — Pesticide and technology providers would gain easier access to sustainable investment capital.3
Impact — Environmental advocates lose if basic legal compliance is equated with green sustainability.4
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Meeting with Dimitris Tsiodras (Member of the European Parliament)

20 Mar 2025 · OSOA

Meeting with Irene Sacristan Sanchez (Head of Unit Health and Food Safety)

18 Mar 2025 · Regulatory simplification in plant biotechnology

Meeting with Jeannette Baljeu (Member of the European Parliament)

12 Mar 2025 · NGTs, biocontrol

Meeting with Aurelijus Veryga (Member of the European Parliament)

11 Mar 2025 · Key Priorities for European Agri-Food Policy

Meeting with Stefan Köhler (Member of the European Parliament)

11 Mar 2025 · Politischer Austausch

Meeting with Norbert Lins (Member of the European Parliament)

11 Mar 2025 · Vision for European agriculture and food

Meeting with César Luena (Member of the European Parliament)

10 Mar 2025 · New Genomic Techniques

CropLife Europe urges regulatory simplification for water resilience

3 Mar 2025
Topic — The European Commission strategy aims to achieve a water-resilient Europe by 2040.
Message — The group requests that the strategy aligns with laws to avoid regulatory duplication. They call for accelerated biopesticide authorizations and a pragmatic framework for biotechnology. Finally, they argue for proportionate regulations that avoid unnecessary precautionary measures.123
Why — Simplification would reduce the high costs and complexity associated with current EU water policy.45
Impact — Environmental organizations may face increased risks if precautionary rules are removed to lower costs.6
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Meeting with Eric Thévenard (Head of Unit Health and Food Safety)

25 Feb 2025 · PFAS in the context of Regulation (EC) No 1107/2009

Meeting with Gabriele Giudice (Cabinet of Executive Vice-President Raffaele Fitto)

24 Feb 2025 · Solutions for farmers operating in conventional pesticides, biopesticides, biotechnology, and digital and precision agriculture

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair) and BASF SE

13 Feb 2025 · The role of the plant protection industry in promoting affordability, food safety and sustainability in EU agriculture

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

13 Feb 2025 · Simplification

Meeting with Ondřej Krutílek (Member of the European Parliament)

13 Feb 2025 · The role of the plant protection industry in promoting affordability, food safety and sustainability in EU agriculture

CropLife Europe supports digital labels but rejects color-coded scheme

23 Jan 2025
Topic — Updated EU rules for labeling and risk communication of plant protection products.
Message — The group supports digital labels to improve risk management and user comprehension. They oppose a proposed color-coded scheme, claiming it causes confusion and lacks value. The organization requests a transition period longer than the proposed January 2026 deadline.123
Why — Avoiding the color scheme prevents rebranding costs and confusion with existing safety icons.45
Impact — Advocates lose a visual tool designed to help users choose less hazardous products.6
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Meeting with Elena Donazzan (Member of the European Parliament)

14 Nov 2024 · Incontro su tematiche industriali relative al settore agricolo

Meeting with Herbert Dorfmann (Member of the European Parliament)

13 Nov 2024 · Exchange of views over the future of European agriculture

Meeting with Jeannette Baljeu (Member of the European Parliament)

12 Nov 2024 · GMO objections, NGTs

Meeting with Silvia Sardone (Member of the European Parliament, Committee chair) and Competere - Policies for sustainable development

30 Oct 2024 · ENVI COMMITTEE

Meeting with Ana Vasconcelos (Member of the European Parliament)

17 Oct 2024 · Digital Farming and NGTs

Response to Commission Roadmap to phase out animal testing

15 Oct 2024

CropLife Europe (CLE) appreciates the EC's roadmap, which aims to inform future regulatory changes, progressively reduce reliance on animals for chemical safety assessment and foster introduction of New Approach Methodologies (NAMs)/Non-Animal Technologies (NATs). This initiative aligns with our values, reflecting societal demand for ethical alternatives in R&D. As an industry heavily relying on animal use, this is a significant step towards more sustainable safety assessment. CLE is sharing some perspectives for consideration. *Innovations Require Safety Testing: Readiness of NAMs/NATs Responsible protection of humans and environment is at the core of our innovation and benefits consumers, regulators and businesses. Our industry is committed to 3Rs, where NAMs/NATs reliably ensure human and environmental safety. Assessing context of use and readiness level are key implementation aspects. NAMs/NATs regularly developed in our industry have low regulatory acceptance, with little dialogue possible to understand gaps. NAMs/NATs recently developed from private/public research programs are useful to prioritize (data-poor) chemicals testing, but only partly address regulatory needs. Lack of robust validation prevents regulatory acceptance. Solutions recapitulating complex physiology/populations are missing and higher tier tests (e.g. animal studies), would be still needed for regulatory decisions. CLE advocates for a robust mapping of available solutions, including their readiness and relevance for different contexts of use (screening; regulatory applications, etc.) and supporting research gap identification. CLE recommends EC funding should cover new model development as well as robust validation of new/existing methods for ready regulatory uptake. We urge the EC to provide guidance on minimum validation standards acceptable for regulatory implementation of individual assays or their combinations under IATA/Defined Approaches, including transparent and harmonized assessment schemes, so that regulatory outcomes and higher tier triggers are predictable. *Regulatory Frameworks and Regulatory Decision Making We emphasize the need for a robust framework that considers all regulatory applications. Changes to information requirements must not compromise safety or efficacy across the farmers toolbox and should apply to newer agri-technologies (biological and plant biotech), integrated in a single safety paradigm. Specific input for plant biotechnology is provided as an attachment. Second, regulatory science interdependencies are key for products field used. Data beyond human and environmental safety tests (e.g. phys-chem, residues and e-fate) contribute to safety assessment in a non-siloed fashion (simple example: rodent data used for wild mammals). Therefore, long-term solutions should consider those interdependencies. Advocacy for globally harmonized regulatory requirements is essential to effectively reduce animal use and for this transition to be economically sustainable (unnecessary duplications). *Economic Considerations R&D investment planning requires clarity on the structure/pace of regulatory changes, such as phasing-in tiered approaches. NAMs/NATs (especially batteries) can be as costly as traditional tests (recent case example: in vitro DNT or thyroid batteries). Significant investment is essential, not only for methods development/validation but also to build expertise in regulators/industry ensure accessibility of assays providers to industry. CLE advocates for an impact assessment of costs, time and capability building, associated with a clear implementation plan for each phase of this transition. *Collaboration and Dialogue CLE advocates for a collaborative dialogue involving academia, regulators, industry, and NGOs, to share knowledge and ensure that NAMs/NATs are fit-for-purpose, validated and accepted by regulatory frameworks. CLE is a key stakeholder, looking forward to contributing to future consultations.
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Meeting with Eric Sargiacomo (Member of the European Parliament)

8 Oct 2024 · Agriculture

Meeting with André Rodrigues (Member of the European Parliament)

26 Sept 2024 · Iniciativas no âmbito da proteção das  plantas e da agricultura sustentável

Meeting with Krzysztof Hetman (Member of the European Parliament)

19 Sept 2024 · Agriculture policy of the EU

Meeting with Pekka Toveri (Member of the European Parliament)

18 Sept 2024 · The future of European agriculture

Meeting with Veronika Vrecionová (Member of the European Parliament, Committee chair)

18 Sept 2024 · Priorities of the AGRI committee in the 2024-2029 mandate.

Meeting with Christine Singer (Member of the European Parliament) and BASF SE and European Anglers Alliance

18 Sept 2024 · Austausch neue Legislaturperiode

Meeting with Valérie Hayer (Member of the European Parliament)

17 Sept 2024 · Pesticides, biocontrol and innovation

Meeting with Alexander Bernhuber (Member of the European Parliament)

17 Jul 2024 · SUR, NGTs, general political outlook

Meeting with César Luena (Member of the European Parliament)

16 Jul 2024 · NBT

Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

In the call for evidence on the application of the DNSH principle to the Social Climate Fund, the Commission stresses their aim to present a strategic policy reflection on consistently operationalising the DNSH principle across sectors. This goes beyond the Social Climate Fund as such and aims to take account of the risk of divergence of approaches in the application of DNSH in an increasing number of multifaceted Union funds. CropLife Europe (CLE) would like to take the opportunity and comment on the policy reflections. Overall, CLE welcomes the Commissions intention. Efforts to strengthen convergence in the interpretation of DNSH across funds and sectors will increase accessibility for investors, other financial actors and businesses, facilitating investments in taxonomy-compliant activities, as well as increase transparency and hence trust in the taxonomy for investors, businesses and the general public. The challenge to a uniform approach to DNSH across sectors is defining what constitutes significant harm, taking into account the degree of the positive contribution of an activity to one or more of the environmental goals of the taxonomy against the trade-off, i.e. degree of harm done to any of the other environmental goals. Sectors are facing trade-offs to a different degree and level of complexity. Unlike most other industries, agriculture does not only affect the environment, but actively works with/in nature to fulfil its purpose. This results in a complex web of trade-offs between various climate- and biodiversity-relevant pressures as well as services. CLE takes the view that principles of harmonisation and simplification of DNSH must duly take into account the need to address sector-specific trade-off matrices adequately to avoid paralysis of investments in activities that contribute to the goals of the taxonomy and the Green Deal.
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Meeting with Janusz Wojciechowski (Commissioner) and

15 May 2024 · The most pressing challenges facing agriculture today, including pest resistance, the impact of climate change and the need to increase productivity to meet the growing demand for food.

Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

8 Apr 2024

CropLife Europe (CLE) represents sustainable crop protection solutions. CLE acknowledge the critical role EFSA plays in the assessment of regulated products. In general terms, the implementation of the Transparency Regulation has considerably increased the administrative burden and complexity of submissions to EFSA, and the new system and processes resulted in longer timelines for dossier preparation for the applicants, for EFSA completeness check and the confidentiality assessment. While the introduction of pre-submission advice is a welcome step, its limited scope and mainly written format has not proven to be a useful tool to ensure the completeness of data supporting the risk assessment. In the crop protection sector, our members face long evaluation timelines, including delays at EFSA level that contribute to the overall delay in the assessment of new active substances including innovations for farmers. The procedures introduced through the revision of the General Food Law (GFL) have brought huge challenges to MS authorities and companies, particularly the IUCLID format where many companies especially SME companies are struggling due to the complexity of the process. Industry wants to work to implement GFL and we would appreciate more dialogue with EFSA and ECHA, especially due to the regular software updates which makes it challenging to bring new innovative solutions to the market for farmers. The need for alignment between different EU agencies extends beyond the IUCLID topic however. In the current public consultation on the draft regulation on the re-attribution of scientific and technical tasks among Union agencies in the area of chemicals, CLE has highlighted that we are supportive of the fact diverging scientific opinions between EU agencies will need to be minimised and if they exist, duly justified. As an example we can highlight that the expected consistency and predictability of ED assessments has not yet been achieved (e.g. absence or inconsistent application of both a weight-of-evidence (WoE) approach and a mode-of-action (MoA) analysis in ED evaluation). As part of our 2030 commitments, CropLife Europe member companies are investing 4 billion into innovation in biopesticides. To deliver timely those innovations on EU market we strongly encourage EFSA to build more expertise and have more dedicated resources in reviewing novel biological plant protection products - as the green teams organized in some Member States. Having predictability for registration of Biopesticides in EU will allow the industry to have a clear return of investment set-up, and we ask EFSA to support this. Predictability is equally important for innovative conventional pesticide registrations and further practical steps that can help encourage innovation would need to be considered. A guidance document feasibility check and periodic evaluation of already established guidance seems to be a key step, for which there is broad support amongst several stakeholders. General challenges concerning the current scientific evaluations remain, especially those having a significant effect on the timelines. Late re-opening of gaps or issues during the peer review process (not always mentioned until the final stage of assessment) are still encountered fairly often, and unfortunately dutifully addressing these concerns is not always possible by applicants (i.e. for ai renewals subject to Regulation 844/2012). In the GMO sector, the efficiency of the risk assessment can be further enhanced with a view to bringing timelines closer to the legally foreseen six months for EFSA review, which is more in line with risk assessment timelines for other international bodies. Risk assessment timelines are negatively impacted mainly by increasing data requirements or new interpretation of existing requirements by EFSA.
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CropLife Europe urges harmonized scientific opinions in chemical assessments

28 Mar 2024
Topic — Consultation on streamlining chemical safety assessments through better data access and agency coordination.
Message — The group seeks to resolve diverging scientific opinions between agencies. They advocate for a pragmatic study notification process and stricter reliability standards.12
Why — This would prevent market fragmentation and protect the competitive advantage of European companies.34
Impact — Independent researchers face more scrutiny and administrative barriers when submitting academic literature for assessment.5
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CropLife Europe calls for harmonized chemical safety data standards

28 Mar 2024
Topic — This initiative seeks to improve chemical safety by centralizing data and assessments.
Message — The association advocates for resolving diverging scientific opinions and ensuring academic data meets reliability standards. They also call for a pragmatic study notification system that safeguards intellectual property.123
Why — Harmonized assessments reduce market fragmentation and prevent competitors from accessing sensitive research.45
Impact — Academic researchers may face increased scrutiny and administrative requirements for their published studies.6
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Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič)

22 Feb 2024 · Sustainable food systems

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur)

19 Jan 2024 · Green Claims Directive

Meeting with Mercedes Bresso (Member of the European Parliament)

16 Jan 2024 · Plants obtained by certain new genomic techniques and their food and feed

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur)

19 Dec 2023 · SPC for Plant Protection Products (staff level)

CropLife Europe Urges End to Double Regulation for Pesticide Additives

18 Dec 2023
Topic — EU consultation on safety data requirements for chemicals used in plant protection products.
Message — The group wants safeners treated as new substances for ten years of data protection. They also seek to end overlapping regulations requiring tests under multiple chemical laws. Finally, they suggest extending market access if the official approval process is delayed.123
Why — This would shield their research from competition while reducing their regulatory compliance burden.45
Impact — Generic manufacturers lose the ability to compete until the ten-year data exclusivity expires.6
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Meeting with Ulrike Müller (Member of the European Parliament)

13 Dec 2023 · NGT

Meeting with Norbert Lins (Member of the European Parliament)

13 Dec 2023 · NGT

Meeting with Brando Benifei (Member of the European Parliament)

21 Nov 2023 · Exchange of views on SUR

Meeting with Marco Campomenosi (Member of the European Parliament)

16 Nov 2023 · Meeting on Sustainable Use of Pesticide Regulation

CropLife Europe urges swift adoption of New Genomic Techniques regulation

3 Nov 2023
Topic — EU regulation on plants obtained by targeted mutagenesis and cisgenesis techniques.
Message — The organization requests increasing the limit on genetic modifications allowed under category 1 from 20 to enable development of complex traits like drought tolerance. They want national authorities to handle verification questions without triggering EU-level procedures. They seek exemption of category 2 products from GMO traceability and labeling requirements when detection methods cannot be developed.123
Why — This would reduce regulatory costs and enable faster commercialization of plant breeding innovations.45
Impact — Organic farmers and consumers lose ability to identify and avoid NGT products.6
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Meeting with Christophe Clergeau (Member of the European Parliament, Shadow rapporteur) and European farmers and

26 Oct 2023 · Table ronde avec les représentants de l'industrie sur la proposition de règlement sur les nouveaux OGM

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur) and Bayer AG and Friends of the Earth Europe

24 Oct 2023 · New Genomic Techniques

CropLife Europe urges flexible standards for agricultural soil health

20 Oct 2023
Topic — The consultation addresses a new legislative proposal for monitoring and restoring soil health.
Message — They propose including a category for 'agricultural productive land' and a gradual soil health score. A toolbox of sustainable practices should replace mandatory lists to ensure management flexibility.12
Why — This would reduce compliance burdens and secure investments in new agricultural technologies.3
Impact — Regulators lose the ability to enforce uniform environmental standards through mandatory rules.4
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Meeting with Juozas Olekas (Member of the European Parliament)

4 Oct 2023 · SUR

Meeting with Franc Bogovič (Member of the European Parliament, Shadow rapporteur for opinion)

3 Oct 2023 · Meeting on SUR regulation

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur)

3 Oct 2023 · Sustainable Use of Plant Protection Products Regulation

Meeting with Herbert Dorfmann (Member of the European Parliament, Rapporteur)

25 Sept 2023 · NGTs

Meeting with Tiemo Wölken (Member of the European Parliament, Rapporteur)

15 Sept 2023 · SPC Plant Protection Products (staff level)

Meeting with Salvatore De Meo (Member of the European Parliament)

7 Sept 2023 · Various

Meeting with Nils Torvalds (Member of the European Parliament)

17 Jul 2023 · NGT

CropLife Europe warns against EU ban on hazardous chemical exports

14 Jul 2023
Topic — The EU is consulting on prohibiting the export of hazardous chemicals banned for domestic use.
Message — The group suggests strengthening existing regulations rather than implementing a total ban on manufacturing. They argue that farmers in third countries have unique needs due to specific climatic conditions. Proposed reforms include extending explicit consent requirements and harmonising digital documentation to track chemical usage.123
Why — Maintaining production allows European manufacturers to protect their global market position and industrial competitiveness.4
Impact — Farmers in tropical regions lose access to specific pest control tools required for their unique environments.5
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Meeting with Franc Bogovič (Member of the European Parliament, Shadow rapporteur for opinion)

12 Jul 2023 · Meeting on SUR regulation proposal

Meeting with Norbert Lins (Member of the European Parliament, Committee chair)

12 Jul 2023 · New Genomic Techniques Proposal

Meeting with Juozas Olekas (Member of the European Parliament)

12 Jul 2023 · New genomic techniques in plant breeding

Meeting with Paola Ghidoni (Member of the European Parliament, Shadow rapporteur for opinion)

11 Jul 2023 · The sustainable use of plant protection products and amending Regulation (EU) 2021/2115

Meeting with Alexander Bernhuber (Member of the European Parliament)

11 Jul 2023 · New Genomic Techniques

Meeting with Silvia Sardone (Member of the European Parliament)

11 Jul 2023 · Introductory meeting

Meeting with Clara Aguilera (Member of the European Parliament, Rapporteur for opinion) and Euroseeds and

4 Jul 2023 · Sustainable Use of Pesticides Regulation

Meeting with Mercedes Bresso (Member of the European Parliament)

23 May 2023 · Legislation on Plant Protection Products (PPPs)

Meeting with Irène Tolleret (Member of the European Parliament) and BASF SE and Bayer AG

10 May 2023 · Pesticides

Meeting with Franc Bogovič (Member of the European Parliament, Shadow rapporteur for opinion)

10 May 2023 · Meeting on SUR regulation proposal

CropLife Europe urges science-based agricultural sustainability criteria

2 May 2023
Topic — This initiative establishes a classification system for environmentally sustainable economic activities within Europe.
Message — The group wants criteria to be science-based and consistent with current EU regulations. They advocate for rewarding a wide selection of innovative tools and farming practices.12
Why — Applying existing risk assessments would allow their products to qualify as sustainable investments.3
Impact — Environmental groups lose if taxonomy standards do not exceed current pesticide safety regulations.4
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CropLife Europe demands scientific consistency in chemical classification rules

23 Mar 2023
Topic — The consultation seeks to update EU rules for classifying and labelling hazardous chemical substances.
Message — CropLife Europe urges consistency between European Regulations and asks that test data on substances takes priority. They also recommend making weight of evidence assessments mandatory for all chemical classifications.123
Why — Prioritizing substance-specific data prevents unnecessary restrictions that stem from assessing individual chemical components.4
Impact — Regulatory agencies face slower administrative processes by being required to perform manual substance reviews.5
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Meeting with Camilla Laureti (Member of the European Parliament)

15 Mar 2023 · ecological transiction

Meeting with Salvatore De Meo (Member of the European Parliament)

14 Mar 2023 · SUR

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur)

10 Mar 2023 · Sustainable use of plant protection products

Meeting with Camilla Laureti (Member of the European Parliament)

10 Mar 2023 · Dossier 2023 APA level

Response to New Agenda for Latin America and the Caribbean

9 Feb 2023

CropLife Europe believes that the new agenda is an opportunity to recognise the key role that trade can play in fostering food security, economic growth and development. Trade can act as a tool to reduce trade barriers and maintain positive relations between EU-LAC regions. The 'Drivers of Food Security' Staff Working Document recognises trade as a key factor for a resilient food system. Trade allows the flow of food from surplus countries to deficit countries. Additionally, trade liberalisation positively affects food prices and availability. Technical barriers and lack of harmonisation of standards can be an obstacle to trade. The new agenda could promote an open dialogue with parties looking for common standards and trade facilitation which can be achieved by strengthening bilateral relations through the EU-LAC regions and a common action in international fora. This will contribute to increasing the resilience of the food system of net importing countries and protecting the competitiveness of the European food value chain, especially food processing industries that depend on raw imports (e.g. coffee, cocoa processors) and livestock sector, which relies on import of vegetable protein crops. Considering the challenges this initiative aims to address, including poverty alleviation, the benefits of trade opening for local farmers (including smallholder farmers) in developing countries cannot be overlooked. As highlighted by the last WTO World Trade Report , Reducing trade barriers could also increase food availability in global markets and support efforts to overcome poverty. It could complement efforts to boost domestic farm productivity and help ensure that trade enables producers to respond to future demand growth. Reducing trade barriers would allow farmers to improve their wealth by facilitating the export of foodstuffs. The excessive disproportion between local and EU import standards is an obstacle for farmers, especially smaller ones who are unable to bear the costs of ensuring full compliance with high EU import standards. In this context, the promotion of harmonisation of standards regarding import criteria should be a priority. This can be achieved by establishing cooperation with the competent authorities, clarifying the import criteria definition is based on an understanding of the agricultural challenges and mutual needs of local producers and harmonised with global standards. MRLs/Import tolerance Open and trade-enabling policies help foster the development of agriculture in developing countries, a key sector to deliver on the UN Sustainable Development Goals of poverty eradication, zero hunger and economic growth. This is also the main objective of EU Development Policy and can be further supported by coherent policies on MRLs. Given that the EU is the largest common market in the world and the largest importer of fruits and vegetables, the implementation of EU policies that restricts use of critical to smallholder farmers tools and the challenges for the LAC countries to comply with the resulting modification of sanitary, phytosanitary or technical conditions of imported products raises specific concerns about the impact on small holder farmers who depend on agricultural exports for their incomes. Farmers around the world depend on access to all available technologies and tools to produce safe and affordable food for growing population in an environmentally sustainable way while preserving their livelihoods. These tools are especially critical to developing countries farmers, such as the ones in the LAC region, many of whom live in tropical and sub-tropical climates with higher pest and disease pressure and post-harvest losses due to the combination of heat and moisture. In many of the LAC countries, agricultural exports not only constitute an important source of national income and foreign exchange, but also provide income for many smallholders and employment for many other poor people. The agenda sho
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CropLife Europe urges science-based revision of water pollutant lists

8 Feb 2023
Topic — The Commission is reviewing the list of priority substances and groundwater pollutants.
Message — CropLife Europe accepts most pesticide standards but requests deleting unworkable total parameters. They urge aligning water legislation with existing science-based assessments for plant protection products.12
Why — This would prevent unjustified restrictions on the availability of crop protection products.34
Impact — Environmental advocates lose monitoring data on the cumulative impact of pesticide mixtures.56
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Meeting with Sylvia Limmer (Member of the European Parliament, Shadow rapporteur)

17 Jan 2023 · Verordnungsentwurf für die nachhaltige Verwendung von Pflanzenschutzmitteln und zur Änderung der Verordnung (EU) 2021/2115

Meeting with Franc Bogovič (Member of the European Parliament, Shadow rapporteur for opinion)

14 Dec 2022 · Meeting on agriculture related legislation

CropLife Europe backs harmonised pesticide rules while seeking longer transitions

14 Nov 2022
Topic — The EU is defining criteria to identify and ban hazardous co-formulants used in pesticides.
Message — CropLife Europe supports aligning pesticide co-formulant rules with existing chemical standards to simplify regulation. They request that evaluations include public consultations and that national lists be submitted without delay. They also propose extending transition periods to eleven years to allow for product reformulation.123
Why — Industry would avoid costly information requests while gaining a decade to replace banned substances.45
Impact — Environmental groups lose when hazardous substances remain on the market for eleven years.6
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CropLife Europe urges digital labels for pesticide record-keeping rules

3 Nov 2022
Topic — Common rules requiring professional users to keep electronic records of pesticide applications.
Message — CropLife Europe suggests Digital Labels to enable the immediate record of product use and facilitate document generation. They advocate for a commonly agreed data standard that supports interoperability across different systems and stakeholders. The group also warns against the risk to double count product uses when recording seed treatments.123
Why — Unified digital standards would simplify data management and lower technical barriers for product users.4
Impact — Environmental monitoring groups lose specific data on seed treatment locations if only sowing is tracked.5
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Meeting with Sylvia Limmer (Member of the European Parliament, Shadow rapporteur)

18 Oct 2022 · Verordnungsentwurf für die nachhaltige Verwendung von Pflanzenschutzmitteln und zur Änderung der Verordnung (EU) 2021/2115

Meeting with Veronika Vrecionová (Member of the European Parliament)

18 Oct 2022 · Sustainable Use of Pesticides

Meeting with Franc Bogovič (Member of the European Parliament) and Bayer AG

18 Oct 2022 · Meeting on agriculture related legislation

CropLife Europe seeks consistency in new chemical hazard classifications

14 Oct 2022
Topic — The European Commission is introducing new environmental and health hazard classes for chemicals.
Message — CropLife Europe strongly supports a Weight of Evidence approach for mobile substance classification. They encourage alignment with existing legal frameworks to promote consistency and the principle of one assessment. They also propose extending the transition period for mixtures to 60 months.123
Why — The organization would benefit from more predictable regulatory outcomes and lower administrative burdens.45
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Meeting with Alexander Bernhuber (Member of the European Parliament, Shadow rapporteur)

27 Sept 2022 · Sustainable use of Pesticides

Meeting with Michaela Šojdrová (Member of the European Parliament)

26 Sept 2022 · The import of GM crops into the EU

CropLife Europe calls for innovation-led pesticide framework over prescriptive cuts

13 Sept 2022
Topic — EU regulation on sustainable pesticide use, reduction targets, and integrated pest management.
Message — The organization requests that reduction targets account for local conditions and alternative availability, faster approval of innovative technologies including digital tools and biopesticides, and flexible IPM strategies adapted to regional needs. They warn against restricting existing tools while new product approvals remain slow.1234
Why — This would protect their €14 billion investment in new technologies and maintain market access for existing products.56
Impact — Environmental and public health advocates lose stricter controls on hazardous pesticide use.7
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CropLife Europe urges clear rules for chemical data access

16 Aug 2022
Topic — The initiative aims to improve chemical data access and transparency for safety assessments.
Message — CropLife Europe requests a distinction between using property data and requiring full ownership for market access. They demand that transparency rules protect confidential business information and avoid overinterpreting harvested data.123
Why — This would reduce the costs and administrative burdens of obtaining full study reports for market access.4
Impact — Companies owning the original research risk losing competitive advantages through potential commercial misuse.5
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Meeting with Irène Tolleret (Member of the European Parliament)

6 Jul 2022 · Sécurité alimentaire

CropLife Europe seeks clear "Farm Data" category in Data Act

13 May 2022
Topic — A legislative initiative to facilitate data access and ensure fairness in the EU.
Message — The organization requests a new "Farm Data" category to solve data classification dilemmas. They argue the law should only apply to raw data, excluding processed information.123
Why — Excluding processed data allows companies to protect high-value proprietary algorithms from reverse engineering.4
Impact — Tech competitors lose access to processed agricultural data needed for service innovation.5
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Response to A New European Innovation Agenda

10 May 2022

CropLife Europe member companies have adopted a set of ambitious commitments to support the EU Green Deal, including an investment of €14 billion in new technologies and more sustainable crop protection solutions and strategies by 2030. Successful implementation of the Farm to Fork strategy relies on innovative solutions arriving to the market, allowing farmers to protect their crops from pests and diseases while remaining competitive. Our industry believes that Innovation is at the cornerstone of the EU Green Deal’s success. The Innovation agenda should propel investment towards a green transition, it needs to be supported by an innovation-friendly regulatory framework for the next generation of crop protection solutions (i.e. pesticides, biopesticides or new application technologies involving digital and precision components) to arrive on the market and become a part of the farmers’ toolbox. The current policy timelines do not take into account that it takes 11 years to bring just one solution to the market. This means that many of the new products that are currently under development will arrive on the market only after 2030. Since 2011, the crop protection sector has submitted 108 applications, whereas only half of these applications have been approved. Innovative solutions are stuck in the regulatory pipeline creating a backlog, leaving EU farmers without safe, effective and vital solutions to protect their crops. Our members continuously commit a high level towards R&D investment, with companies investing 7%-10% of their turnover annually over the last 50 years (Phillips McDougall AgriService). We need a regulatory framework that enables innovation, instead of hindering it. This is particularly true for biopesticides - to unlock the potential of biopesticides, and to meet the demands of our citizens and policymakers alike, our industry calls on the EU institutions to ensure the current regulatory framework facilitates the placing of novel biopesticides on the EU market. Following the successful development of new requirements for microorganism based biopesticides, we encourage the European Commission to develop specific guidance for novel biochemicals. Exciting new solutions such as peptides and fermentation products are being developed and are already available for farmers in other parts of the world. Unfortunately, due to the lack of a clear regulatory pathway, European farmers are not able to access these new sustainable solutions putting them at a competitive disadvantage, while applicants are uncertain about the ability to secure registration in Europe. CropLife Europe recognises the importance and necessity of producing food in a more sustainable and environmentally-friendly manner. Our industry has committed to invest in new technologies such as biopesticides and precision and digital tools that will allow farmers to produce more food while using fewer natural resources. CropLife Europe members need a clear, predictable and science-based regulatory environment that embraces innovation in order to be able to continue investing in R&D in the EU.
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Meeting with Janusz Wojciechowski (Commissioner) and

5 May 2022 · Ukraine and Food Security

Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

12 Apr 2022

CropLife Europe would like to thank the European Commission for the opportunity to provide comments on this initiative. A document is attached with our views and suggestions.
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Response to Unitary Supplementary Protection Certificates (SPC) – creation and granting procedure

1 Apr 2022

Dear Sir/Madam, Supplementary Protection Certificates are an integral part of the process for protecting innovation in plant protection products. We therefore greatly appreciate the opportunity to participate in the call for evidence on a unitary SPC and/or single procedure for granting national SPCs. Please find attached CropLife Europe's feedback to this call for evidence. We look forward to further fruitful discussion with the European Commission and relevant stakeholders.
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Response to Application of EU health and environmental standards to imported agricultural and agri-food products

16 Mar 2022

CropLife Europe response to call for evidence: Application of EU health and environmental standards to imported agricultural and agri-food products. Summary: 1. Global environmental concerns are best addressed at the global level. 2. Different regions have different needs. Farmers need to have a broad toolbox available in support of climate change adaptation, mitigation and prevention. 3. Maximum Residue Levels (MRLs) for pesticides are trading standards that drive good agricultural practice and ensure a level playing field for EU and other farmers. They are not an appropriate tool to be used to tackle environmental challenges in other countries. 4. We call on European Union to avoid unjustified protectionism or barriers to trade in agricultural and food products that disrupt market access. Please find attached our full input.
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Response to Fight against counterfeiting

3 Mar 2022

CropLife Europe recommends (full feedback in pdf file attached): 1. Data sharing • Mapping the multiple data sets that already exist – e.g. shipping documents, loading manifests, customs declarations, postal declarations, postal VAT databases and fulfilment centre inventories and connecting those information with historical data on previous seizures and infringements. Data should be collected from right holders, companies that transport, import and distribute products, • Pursue analytical forensic data cleaning techniques (e.g. by OLAF or Europol) to allow for interoperability and thus connection of such data sets with law enforcement databases in the EU • Development of a shared digital platform permitting trans-European cooperation by enforcement authorities (customs, police and sectorial authorities – such as pesticides authorities and police) for sharing and receiving intelligence directly from supply chain intermediaries and industry about suspicious shipments. 2. Public sector collaboration • Better communication and collaboration between relevant authorities on national and international level, for example with ICAMA in China (Institute Control of Agrochemicals, Ministry of Agriculture, China). This is crucial as counterfeiters are operating cross-border. • Member States to improve collaboration between relevant enforcement agencies including for example setting Memoranda of Understanding. • Promotion of existing EU best practices in identifying and stopping counterfeit products such as in Rotterdam and Hamburg. This could be done by on-site trainings for relevant national authorities. 3. Private sector collaboration • Since counterfeiting has huge socio-economic effects on the economy, all private sector players involved in global trade must play their part in this fight. • Shipping companies, cargo airlines, freight forwarders and customs agents know – or ought to know – to whom they are providing services (Know Your Customer). Those intermediaries that both facilitate and profit from involvement in the supply chain must by any reasonable standard be expected to play their part. Delivery companies should have a reimbursement clause in contracts, in case of seizure. 4. Tools • Empowerment of customs officials to be able to stop products “in transit” based on false and/or incomplete documentation or strong suspicion of potential for illegal placement on the EU market, providing the needed time for product testing • Appropriate fines and penalties for distribution and sale of illicit products has to be taken to create deterrence and fake or illegal products need to be destroyed safely to prevent market re-entry and associated health and environmental risks. For the pesticide sector, a recent survey by DG Sante (regarding Article 72 of Regulation 1107/2009) indicates huge discrepancies between Member States in setting minimum fines for pesticides counterfeiters. • Awareness raising of risks of counterfeit & illegal to all parties in the supply – eg. danger to delivery company employees and means of delivery such as vessels, given the unknown chemicals are shipped by criminals.
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Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

13 Jan 2022 · VTC Meeting: Economic study on the impact of the 2030 Green Deal targets for crop production

CropLife Europe urges harmonized guidance for microbial pesticide approvals

23 Nov 2021
Topic — The consultation concerns updating approval criteria for microbial active substances in pesticides.
Message — The organization seeks tailored guidance to ensure consistent assessments by all Member States. They also request more resources and training for regulators to understand the unique characteristics of microorganisms.12
Why — Standardized rules and clearer procedures would help companies bring biological pesticides to market.3
Impact — Public health groups may lose if pathogenicity is only evaluated within specific usage scenarios.4
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CropLife Europe Urges Clearer Rules for Biological Pesticide Approval

23 Nov 2021
Topic — Consultation on tailoring data requirements for the approval of biological and microorganism active substances.
Message — CropLife requests tailored guidance and expert training for consistent EU-wide assessments. They also seek inclusion of technologies like peptides and antibodies.12
Why — Harmonized rules would prevent inconsistent national requirements and reduce costly regulatory delays.3
Impact — Bystanders face risks if expert judgment replaces quantitative data for measuring pesticide exposure.4
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CropLife Europe calls for clearer rules on microbial pesticides

23 Nov 2021
Topic — The EU is adapting data requirements for authorizing biological plant protection products.
Message — CropLife Europe seeks tailored guidance documents to ensure consistent assessments across Member States. They also request specialized training and funding to help regulators understand microbial characteristics.12
Why — Uniform guidance would reduce regulatory uncertainty and prevent inconsistent demands for additional data.3
Impact — Environmental groups lose if insufficient testing methods fail to protect non-target organisms.45
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CropLife Europe urges harmonized guidance for biological pesticide approvals

23 Nov 2021
Topic — The EU is updating evaluation rules for microorganisms used in plant protection products.
Message — The group requests tailored guidance to ensure a consistent assessment by all Member States. They call for sufficient resources and training programs to help national experts understand microorganisms. They suggest the framework should also consider technologies like peptides and antibodies.123
Why — Consistent rules would help companies deliver innovative pesticides to the European market.45
Impact — Environmental groups may worry that omitting certain studies reduces safety for non-target species.6
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Response to Sustainable food system – setting up an EU framework

25 Oct 2021

CropLife Europe welcomes the opportunity to comment on the Sustainable Food Systems roadmap. To increase the sustainability of food systems we believe it is necessary to address its three pillars: social, economic, and environmental. An impact assessment of the future framework should evaluate alternative routes to promoting all pillars of sustainability and have an independent overview of the trade-offs between them. Voluntary approaches and mechanisms to reinforce existing legislation should be explored in the same level of detail as the development of a new framework. We encourage the European Commission (EC) to evaluate the cumulative effect on food systems of the future policy options with the current policy ambitions described in the Green Deal, especially from the Farm to Fork and Chemical Strategy for Sustainability. Future policy should build on these achievements. We recall that many successful initiatives are in place to address sustainability. An example is the EU Code of Conduct on Responsible Food Business and Marketing Practices, an initiative that has CropLife Europe among its signatories. The involvement of interested stakeholders and the consideration of different approaches is key to bring about fit-for-purpose solutions. Sustainability analysis must be results-based The sustainability analysis of agricultural products should be based on an integrated approach that focuses on achieved impact. Sustainability considerations cannot be limited to single products, processes, or actions, but must instead acknowledge the complexity of food production that takes place in different environments, according to various practices. A results-based approach to sustainability, linked to science-based, clear criteria across the three pillars of sustainability, should be pursued instead of an ‘action-based’ approach, limited to rewarding isolated practices perceived as sustainable without measuring their resulting effect. Local authorities must be empowered to assess sustainability based on local realities. Ensuring predictable decision-making The constant refining of risk assessment processes for regulated products contributes to safer and more sustainable food production, distribution, and consumption. However, food safety and sustainability characteristics are conceptually different, and should not be conflated or handled within the same regulatory processes. To include complex sustainability analyses into product regulatory evaluations would increase the burden and the unpredictability of the EU decision-making process. The EC should explore the feasibility of a sustainability assessment from the point of view of ensuring predictability, transparency, objectivity, and consistency of future solutions. Global challenges require multilateral solutions We share the EU’s ambition to take action on global environmental issues. Global challenges are best addressed at global level. International fora provide the proper framework for multilateral discussions. We encourage the EC to prioritize multilateral agreements on global sustainability issues. Taking unilateral action can lead to the adoption of different standards by different countries and the further fragmentation of global governance. Unilaterally imposed sustainability requirements for imported commodities can be unfair and discriminatory, create trade frictions with partners, and impact EU food security. Third countries have their own environmental conditions and farming challenges that lead to different pathways of enabling sustainable food production. Multilateral negotiations should guide the EU’s Green Deal ambitions as opposed to unilateral measures that may amount to non-tariff barriers. The future impact assessment should evaluate the costs of potential distortions caused by new import requirements on the EU and its trade partners, in particular developing countries, and weight it against their real effectiveness in achieving sustainability objectives.
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CropLife Europe Urges Digital Labels to Simplify Chemical Information

20 Sept 2021
Topic — This consultation reviews simplification and digitalisation of labelling requirements for chemical products.
Message — CropLife Europe requests reducing information levels on labels by moving some content to digital formats. They argue against adding new hazard classes to avoid exacerbating information overload. They further suggest extending digital labelling to pesticides and biocides.123
Why — This transition would lower costs by reducing physical printing and the waste of obsolete labels.4
Impact — Health and environmental groups may lose if hazard information is simplified or moved online.56
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

14 Jul 2021 · Impacts of the Farm to Fork Strategy

Meeting with Janusz Wojciechowski (Commissioner) and

13 Jul 2021 · F2F cumulative impact assessment

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

CropLife Europe (CLE) welcomes the opportunity to provide feedback and makes the following comments: - New Hazard Classes Europe has been a leading player in the development of the GHS, bringing numerous benefits in terms of international harmonisation of safety standards and facilitation of trade. The Commission’s plan sends a clear message that the EU no longer believes in international cooperation. We strongly urge the Commission to engage with the UN GHS Subcommittee before introducing any new hazard class into CLP to maintain the high levels of international harmonisation. CLE is not convinced that the proposed new hazard classes as described in the CSS, are indeed hazards. For example, endocrine disruption is a mode of action which, if it leads to serious effects, would already lead to classification. PMT like PBT is aimed at risk assessment, rather than hazard communication and can be dealt with under REACH via an Annex. We are concerned that the additional hazard classes and pictograms would increase label complexity and could compromise hazard communication. - Introduce the possibility to submit proposals for and set harmonised environmental and safety values for some substances CLE understands this to be targeted at PNECs and DNELs that are typically part of a REACH dossier. Thus, CLE welcomes clarification on why this is envisaged to be part of CLP. Our view of these values is that they are more aligned with the risk-based approach of REACH rather than the hazard-based approach of CLP. - Extending the requirement to notify to Poison Centres (PCN) to include substances The recent introduction of harmonised information requirements for PCN for mixtures has resulted in increased information availability, especially for mixtures that were outside of the scope of previous national schemes. CLE does not see the benefit of extending the scope of PCN to include substances as poison centres already have access to comprehensive information via the published REACH Registration. - Mandate for Commission to request ECHA to develop CLH dossiers CLE requests further explanation behind this proposal, especially an explanation of the situation that it is intended to solve. If ECHA were to develop CLH dossiers, there is potential for conflicts of interest between the dossier development part of ECHA and the scientific opinion forming part of ECHA (RAC). The current arrangements prevent conflicts of interest because dossier creation and scientific opinion development are in separate organisations. If the 2 roles were within the same organisation, strong organisational measures would be required to ensure RAC’s continuing independence. - Multi-lingual labels and tailored labelling rules It can be challenging to fit all the required information onto a label, especially where the package is small or where multiple languages are required. CLE welcomes all practical solutions and recommends adoption of the solutions developed by the UN Subcommittee of Experts on the GHS. - Priority mechanism for harmonising the classification of certain chemicals CLE would appreciate further explanation of this proposal: what is the problem that it is intended to solve, what is meant by “certain chemicals”, would it relate to uses, compound classes or hazard properties? - Simplify and reduce administrative costs CLE welcomes measures to simplify processes and reduce administrative costs for all parties with relevant scientific and stakeholder involvement. However, it needs to be ensured that the high quality of assessment currently available due to engagement of all involved in the process needs to be kept. On the other hand, the introduction of new hazard classes will not add to simplification and cost reduction. - Preliminary assessment of expected impacts The impact assessment should not only consider impacts of classification and labelling in the REACH regulation but should include all downstream regulations that might be impacted by classifications.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

27 May 2021

CropLife Europe (CLE) welcomes the opportunity to provide feedback and wishes to make the following comments: Part A REACH is the most advanced knowledge base globally but there are still gaps in knowledge on many substances: A retrospective review by the US Environmental Protection Agency in 2013 (“A retrospective analysis of immunotoxicity studies”, February 2013, Health Effects Division, OPP, US EPA), was conducted into whether the results from 170 of the newly mandated immunotoxicity studies impacted the human health risk assessment. The conclusion was that they did not, and there is insufficient basis for checkbox-type testing on vertebrates. Waivers are granted in almost all cases in absence of triggers from standard studies. CLE strongly recommend that any testing for immunotoxicity under REACH remain case-by-case as currently permitted, when specific concerns are raised. The registrants’ safety assessments do not take combination effects of chemicals into account: The assessment of mixture toxicity (cumulative risk) for pesticide registrations is already an important requirement under plant protection product Regulations 1107/2009 and 396/2005. Recently conducted retrospective combination risk assessments conducted within the scope of this legislation have revealed no significant cases to date and confirmed safe uses (EFSA, 2020). This work has been conducted at great burden and cost, and confirms the high protectivity of the single substance-based risk assessment under the pesticide regulation. The communication in the supply chains is inefficient: Communication in the supply chain is widely acknowledged as inefficient, and CLE welcome any improvements in this direction. Further digitalisation should be explored rather than increasing regulatory requirements. The evaluation of registration dossiers and substances is too complex and insufficient: The complexity and time required to evaluate dossiers in part reflects the complexity and plethora of real-world uses of substances. Any simplification should take place without loss of the right to perform robust and scientifically justified risk assessments demonstrating continued safe use of substances. We believe procedural simplifications which do not impact the ability to rigorously justify safe use are to be welcomed and can also deliver faster processes. The current restriction process is too slow to sufficiently protect consumers and professional users against risks from the most hazardous substances: Professional users have well defined exposure scenarios, and thus allows more robust risk assessments to be performed. Furthermore, this is underpinned by the legal framework on the safety and health of workers at work, and the chemical agents at work Directives. Part B Revision of the registration requirements: Any increase in mandatory information requirements linked to registration must be carefully analysed for the degree to which the requested studies are fit-for-purpose, especially resultant false-positive and higher-tier testing triggers, when coupled with the approximately 25 000, and growing, registrations held in the ECHA database. Introduction of a Mixtures Assessment Factor (MAF): To avoid unnecessary socio-economic impact, any introduction of a MAF must be targeted to specific substances, variable in size (e.g. reflecting the tonnage manufacture), and robustly and scientifically justified as to have a common mode of action. Reforming the restriction process: The concept of essential use has enticing simplicity, but fails to recognise its inherently subjective nature. Introduction into legislative process will inevitably lead to challenge, and loss of regulatory predictability, with knock-on consequences for innovation and investment. Substances which target specific organs are inherently amenable to risk assessment, and there is no evidence that banning of these for consumers is warranted, nor the banning of these for professional users.
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Response to Agriculture - List of products and substances authorised in organic production

23 Apr 2021

Thanks for giving us the opportunity to comment. CropLife Europe comments: The co-existence of different farming systems is important as diversity is key to both food system resilience and sustainable development. There is no one-size-fits-all solution to the many sustainability and agronomic challenges farmers are facing. Stimulating sustainability should be focused on farm performance and biodiversity improvement outcomes, rather than on farming model. Organic farmers, much like their conventional counterparts, need effective solutions to protect their crops. Protection is also needed to control food safety risks from natural fungal infections that result in highly toxic mycotoxins, for which the EU rightly sets strict limits. We welcome a more open and transparent approach when revising the list of authorised pesticides for use in organic agriculture: pesticides in Europe have undergone one of the most strict assessment in the world and it remains unclear how so few solutions end up on this list. A more transparent process and clarity on the scientific criteria used are needed. New products with enhanced profiles keep being developed and placed on the EU market. Having a clear mechanism allowing continuous evaluation and update of this positive list to incorporate new tools would be contribute to the EU objectives regarding the development of areas under organic agriculture.
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Response to Statistics on Agricultural Input and Output

30 Mar 2021

CropLife Europe supports the EC's goal to update the rules on agricultural statistics including for inputs such as PPPs. Adequate data will contribute to achieving the aspirational targets set out in the F2F and Biodiversity Strategies. While a regulation on PPP statistics has been in place since 2009, a better indication of current PPP usage will be essential for measuring the progress made towards a more sustainable agricultural model. As indicated in the ECA report in 2020, this regulation should be substantially improved to deliver its desired outcome. We believe it would be beneficial for any framework to seek a feasible and practical approach towards PPP statistics collection, including developing guidance for MS and conducting regular reviews to ensure it is fit for purpose. In comparison to the existing framework limited to gathering use data for specific crops selected by each MS, the updated framework should be extended to cover additional crops, allowing for a more accurate reflection of the actual uses. The EC should consider all uses of PPPs as well as non-ag uses (e.g. Home and Garden, Amenity uses). The data collected would also be better and more fairly interpreted if related to the level of pressure (pests, diseases, weeds) exerted on crops in different MS, as this variable strongly influences the existing indices currently calculated (HRIs). This locally collected data would help evaluate the pressure levels and complement the agronomic advice given to farmers by advisors. We recommend that such data, including on IPM implementation, is made more broadly available and used in the analyses of PPP uses. As the current framework may lead to difficulties in the collection of data in some MS, the EC should look to successful cases of PPP data collection to improve the availability of data at EU level. As our industry provides farmers with solutions for both conventional and organic producers, we feel that it is also important to underline that statistical information should be collected for both production models. As these models are currently differentiated at EU level, we would welcome the creation of a specific model used for collecting data linked to organic agriculture, considering the very ambitious target to increase land farmed under organic agriculture to 25% by 2030. As with the spirit of the development of the HRIs, this indicator should allow for the EC to also collect data on PPP usage in organic agriculture, as many of the products represent significant volumes. Nevertheless, it should be underlined that the collection of data should in no way lead to further administrative burdens for farmers. CropLife Europe recommends that the EC explore using digital technologies to gather these data and to allow farmers to concentrate on their main role, to produce safe and high quality food. CropLife Europe is in the process of exploring the development of a tool that would enable creating a “digital twin” record of PPP use recommendations and actual use, which we refer to as ‘Digital Label Compliance’. We believe that such tools could be of great use to help simplify and relieve burdens for the collection of data on agricultural input use. Additionally, we believe the EC could look to smart application apps currently available on mobile phones that are able to help farmers use the right PPPs as well as the exact amount, but also store the data of the inputs used. Today, smart sprayers equipped with GPS technologies, linked with such smart apps, are making the collection and storage of data possible. Further uptake by farmers should be encouraged and the EC could look into developing a harmonized EU framework. We understand such frameworks raise new questions (use of geo-localization and the ownership of data, interface with private systems). Nevertheless, in 2018, CropLife Europe alongside other agri-food chain stakeholders jointly developed and signed the CoC on Agri Data sharing to address such questions.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

17 Feb 2021 · Sustainable food systems

Meeting with Janusz Wojciechowski (Commissioner) and

12 Jan 2021 · European Crop Protection Association/CropLife Europe 2030 commitments in support of the European Green Deal.

Response to Access to Justice in Environmental matters

10 Dec 2020

ECPA understands that the proposed revision of EU access to justice rules is necessary in order to address the findings of the Aarhus Convention Compliance Committee. Potential impact on EU administrative and judicial systems ECPA believes that the proposed changes could expose EU systems to numerous objections, some of which have potential to be vexatious, with potential to affect the smooth functioning of administration, operation of EU legislation or the proper functioning of remedies. In particular, it could be anticipated that the internal review mechanism might be triggered for acts concerning our sector, based on political rather than scientific grounds, or as an attempt to attract media attention. The review of acts related to the crop protection sector entails careful reconsideration of comprehensive scientific studies and dossiers by independent EU risk assessment agencies (EFSA and ECHA), followed by expert risk management judgments from the Commission and Member States in committee. Systematic requests for review would lead to an exponentially higher workload, requiring additional resources to ensure that the timeframes established in the Aarhus Regulation could be met and to an even higher workload in case of legal recourses. Whilst ECPA welcomes proper redress mechanisms being in place for any rare cases of maladministration in the environmental area that could occur, however, the proposed new rules might also be abused by some parties to the detriment of various industries. We therefore call on the Commission to ensure that any new redress procedures are implemented carefully to ensure the smooth functioning of approvals systems as laid down in EU law, underpinned and informed by the best available scientific evidence. Potential impact on the Crop Protection sector From research to approval, crop protection products are amongst the most rigorously regulated and tested products in the Union. As a consequence, it takes around 10 years from discovery to placing on the market of a new, safer and more sustainable & environmentally friendly active substance. Upon revision, the review provisions of the Aarhus Regulation may cover the vast majority of EU decisions for agri-tech inputs. The changes could clog the system, significantly affecting our ability to bring new sustainable technologies to the market, including those that could support elements of the Farm to Fork and Biodiversity Strategies. Regulatory procedures already suffer from considerable delays ranging from several months to years. The proposed changes could lead to significantly increased levels of legal uncertainty for the approval of substances and subsequent marketing of plant protection products. In turn this deters innovation and introduction of new solutions. Moreover, a high number of requests for internal review and subsequent legal actions against science-based regulatory decisions would cause significant adverse effects to the sector both in terms of economic costs and increased diversion of resources which would be required elsewhere. We urge the Commission and the co-legislators to ensure that the revised approach is agreed and implemented in a manner that prevents abuse of the system, avoiding unnecessary delays and ensuring timely and evidence-based decisions.
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Response to Clarification of requirements for the Registration, Evaluation, Authorisation and Restriction of Chemicals

14 Nov 2020

This comment on behalf of ECPA refers to amendment of Annex XI, point (5)(a)(i), page 9 Proposed amendment: Any data generated as from 1 June 2008 shall not be considered as existing data and shall not be subject to the general rules for adaptation laid down in this point (1.1).’; The amendment attempts to align the term “existing data” to Article 13(3) and (4) of the Regulation (EC) No 1907/2006. However, the amendment will exclude the use of existing data generated from 1 June 2008 in two cases 1) data published in academic journals and 2) data initially generated to comply with other non-EU regulatory regimes, but otherwise still fully meeting the requirements set out in Annex XI, point 1.1.1 and 1.1.2. As a result, such data could only be used as part of a weight-of-evidence argumentation to meet the formal Annex VII – X requirements, which could be challenging if they were the sole study available. This could potentially lead to repeated vertebrate testing. The proposed amendment would thus conflict with the EU strategy for minimizing animal testing, and the stated EU Chemicals Strategy for Sustainability goal to “ensure that relevant academic data is easily and readily accessible for safety assessments and is suitable for regulatory purposes” (see CSS, page 17). We propose the text should be modified to “Any data generated as from 1 June 2008 for the purposes of REACH registration shall not be considered as existing data and shall not be subject to the general rules for adaptation laid down in this point (1.1).” This comment is also submitted by means of an attached file, where some itallic and bold formatting has been included for additional clarity.
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Response to Action plan for the development of EU organic production

23 Oct 2020

The European Crop Protection Association (ECPA) very much welcomes the opportunity to provide feedback on the Organic Action Plan Roadmap. Please find attached our comments.
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Response to Amending of the rules governing the renewal procedure for active substances in view of new “Transparency Regulation"

30 Sept 2020

ECPA welcomes the opportunity to comment on the draft renewal regulation. Our detailed comments are in the attached document. ECPA continues to be supportive of the need for increased transparency and supports Commission and EFSA’s efforts to implement the GFL amended regulation in a robust way. However, we understand several essential steps of the future process will be further describe in the upcoming EFSA practical arrangements document (e.g. pre-submission meetings, notification of studies, etc.). We believe a proper consultation is also needed on those practical arrangements as they can have a major impact on applicants processes and resource planning. Regarding the data format and the planned use of IUCLID: we would like to express very clearly that it is not ECPA’s intention to hinder or unnecessarily delay its implementation. We remain supportive of IUCLID, for example by continuously providing scientific input and with our willingness to work on IUCLID pilots in parallel to our submissions. We simply expect and fear that the use of IUCLID as a Minimum Viable Product in 2021, with very limited time for training and experience gain is counter-productive to the overall goal of creating transparency and creates unnecessary effort for scientists and regulatory managers in companies and authorities. Hence, ECPA asks for the inclusion of a suitable transition period for its implementation.
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Meeting with Wolfgang Burtscher (Director-General Agriculture and Rural Development)

14 Sept 2020 · Farm to Fork targets and plant protection

Response to Intellectual Property Action Plan

14 Aug 2020

The European Crop Protection Association (ECPA) greatly appreciates the opportunity to provide its views on this roadmap. Whilst we support the overall content and the main objectives of the forthcoming IP Action Plan, we would like to focus on some specific points outlined in the roadmap - detailed position attached.
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Response to Sustainable use of pesticides – revision of the EU rules

16 Jul 2020

ECPA supports the improved implementation of the SUD, with a focus on IPM. The impact assessment should be evidence based. Any of the options must consider the trade-offs between policy goals to determine the most appropriate course of action for the EU. It will be essential to conduct the study in a manner that does not pre-judge the outcome to support unsubstantiated targets. There are a number of questions that we ask to be addressed (set out below). A. Context, Evaluation, Problem Definition and Subsidiarity Check a. Targets proposed by the F2F Strategy were not impact assessed and do not seem to be based on clear evidence of cause and effect. Any revision of the SUD should be fully impact assessed, with a clear understanding of trade-offs. All parties want to see more sustainable agriculture, biodiversity enhancement, food security and economic well-being for farmers, whilst the CAP budget is reduced. Proposals must be fully costed in environmental and economic terms to properly inform co-legislators. b. The Roadmap concludes the SUD should be strengthened, yet the EC shows that the application, implementation and enforcement of current rules is variable. It would seem prudent to consider better implementation of current rules, not just options for new legislation. The framework across the SUD, PPP Regulation, Official Controls Regulation and the MRL Regulation provides a coherent package of measures which requires that: • all pesticides have safe uses • authorised uses of pesticides have no unacceptable impacts on human health or the environment • any trace residues in food and feed (imported and EU) are within MRLs set with very high safety margins. EFSA routinely finds excellent compliance with MRLs • pesticides are only used as a last resort, when necessary The Commission REFIT report of the PPP & MRL Regulations found the level of protection was already high, has increased and will improve by 2025; the share of active substances with high hazard is just 2%, which will decrease due to existing measures. B. Objectives and Policy Options a. It is unclear what evidence justifies the reduction of the use and risk of pesticides containing active substances that are approved as safe for use. What is the evidence for an unacceptable risk to human health from pesticides or that pesticides are a significant problem for biodiversity? What is the impact compared to hedgerow removal, urbanisation, portioning of ecosystems, spatial planning policies, road development, aircraft noise etc. b. Why keep occupational health and environmental risks from alternative methods out of scope? How will ‘less hazardous and non-chemical alternatives’ for pest control be defined? Why is this limited to pest control, what about disease or weed control? c. What are the objectives based on? What will the pesticide targets achieve, both positive and negative consequences? Will it be possible to have a resilient food production system for Europe with a reduction in pesticides and use? What is the impact in the rest of the world e.g. on attainment of the SDGs if EU policies prevent market access for smallholders in high pest and disease pressure areas? C. Preliminary Assessment of Expected Impacts a. What is the basis for “A reduction in the use and risk of chemical pesticides could translate into some benefits for public health and associated benefits for worker productivity and reduced sick leave and healthcare costs”? Pesticides with unacceptable health effects are not allowed. b. What additional risks will arise? E.g. will safety be compromised if the EU is unable to control mycotoxins or invasive alien species and plants that are significant health threats e.g. giant hogweed or ambrosia? Also, crop failure risk and low yield impact due to reductions. c. What is the evidence for the “expected positive environmental impacts on biodiversity, the quality of water and soil”? PPPs are not allowed if there is unacceptable environmental risk.
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Meeting with Stella Kyriakides (Commissioner)

11 Jun 2020 · VC Meeting on Farm to Fork Strategy

Response to Statistics on Agricultural Input and Output

9 Apr 2020

ECPA supports the Commission’s goal to update the rules on agricultural statistics including for inputs such as pesticides. Having adequate data will contribute to achieving the goals of the Commission’s Green Deal and Farm 2 Fork Strategies. We support these goals and believe that a better indication of current pesticide usage will be essential for science based decision making. A regulation on the collection of pesticide statistics is already in place since 2009. As indicated in the recently report by the European Court of Auditors, this regulation should be substantially improved in order to deliver its desired outcome. We believe it would be beneficial for any framework to seek a feasible and practical approach towards pesticide statistics collection, including developing the related guidance for Member States, as well as conducting regular reviews to ensure it is fit for purpose. In comparison to the existing framework, currently limited to gather use data for specific crops selected by each Member States, we believe the framework should be extended to cover additional crops, allowing for a more accurate reflection of the actual uses. We would also recommend that the Commission considers all uses of plant protection products e.g. non-agricultural usage (e.g. Home and Gardens, Amenity uses). The data collected would also be more fairly interpreted if related to the level of pressure (pests, diseases, weeds) exerted on crops in the different Member States, as this variable strongly influences the existing indices being currently calculated (Harmonized Risk Indicators). This locally collected data would help evaluate the pressure levels and complement the agronomic advice currently given to farmers by advisors. We recommend that such data become more broadly available and used in the interpretation of PPP data. ECPA would be open to providing support in this direction. As the current framework may lead to difficulties in the collection of data in some MS, we would encourage the Commission to look at successful cases of PPP data collection as a possible means for improving data. As our industry provides European farmers with crop protection solutions for both conventional and organic producers, we feel that it is also important to underline that statistical information should be collected for both production models. As these models are currently differentiated at EU level, ECPA would welcome the creation of a specific model used for collecting data linked to organic agriculture. As with the spirit of the development of the Harmonized Risk Indicators by the Commission, this indicator should allow for the Commission to also collect data on pesticide usage in organic agriculture, as many of the products represent very significant volumes. Concerning the collection exercise, ECPA would like to underline that this should in no way lead to further administrative burden for European farmers. ECPA recommends that the Commission explore using the newest digital technologies to gather these data and to allow farmers to concentrate on their main role, to produce safe and high quality food for European citizens. The Commission could look to smart application apps currently available on mobile phones which are able to not only help farmers use the right pesticides and the exact volumes needed, but also to store the data of the inputs used. Furthermore, smart sprayers equipped with GPS technologies, linked with such smart apps, are currently already making the collection and storage of data possible. Further uptake by farmers should be encouraged and the Commission could look into developing a harmonized EU framework. We understand such frameworks raise new questions (use of geo-localization and ownership of data, interface with private systems). Nevertheless, in 2018, ECPA alongside other agri-food chain stakeholders jointly developed and signed the Code of Conduct on Agricultural Data Sharing to address such questions.
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Meeting with Catherine Geslain-Laneelle (Cabinet of Commissioner Janusz Wojciechowski)

30 Mar 2020 · To discuss the upcoming Farm to Fork Strategy.

Meeting with Anne Bucher (Director-General Health and Food Safety)

2 Mar 2020 · Farm to Fork: Significant reduction of use and risk of chemical pesticides; Measures to develop innovative ways to protect harvests from pests and diseases and the potential role of new innovative techniques to improve the sustainability of the food system; Concrete measures to be taken to increase organic farming in the EU. REFIT of 1107/2009: Status and potential improvement of its application

CropLife Europe calls for science-based targets and innovation support

27 Feb 2020
Topic — EU initiative for a sustainable food system through the Farm to Fork Strategy.
Message — The organization requests a baseline level made from the average index to measure pesticide reduction. They advocate for a science-based discussion that avoids fragmentation of the rules.12
Why — A specific historical baseline would make reaching pesticide reduction targets significantly easier.34
Impact — Organic farmers face increased administrative burdens and potential reputational damage from new indicators.56
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Meeting with Stella Kyriakides (Commissioner)

7 Feb 2020 · Discussion on food safety

Response to Co-formulants in pesticides

4 Feb 2020

Please see additional file attached with detailed comments. • ECPA emphasizes the critical importance that the relevant cut-off concentrations for those substances listed in Annex III also be based on the REACH / CLP regulatory cut-off concentrations of 0.1 % w/w in the final mixture. • As a pragmatic approach consistent with the objectives of REACH, co-formulants with CMR category 1A or 1B, PBT, vPvB or ED can be considered undesirable as co-formulant substances. • The limit of 0.01% for Annex III listed co-formulants found as impurities in a finished plant protection product is 10x too low, and should be the same as the cut-off used for classification under CLP: <0.1% w/w. There is no scientific or legal basis for selecting a value lower than that which is used for classification and reporting on safety data sheets. Significant business disruption and cost will be caused in the co-formulant chemical supply chain, with no benefit to safety. • ECPA highlights that a two year transition period and a grace period of maximum one year is insufficient to find alternative co-formulants, develop a product, generate new data and register it. This is especially true for substances which do not have a harmonized classification. • An impact assessment is requested to assess whether the draft Regulation is proportionate for both industry and Member State authorities, focusing on the following elements: o The impact of the arbitrary 0.01% limit on impurities in the final formulation on the co-formulant supply chain. o The loss and feasibility of replacing existing commercial products containing substances with no previous harmonized classification (e.g. crystalline silica) within two years. • Several natural minerals have been listed if they contain crystalline silica (beach sand) as an impurity >0.1% with a particle size <50 µm. These are: kaolin, quartz sand, and diatomaceous earth (kieselguhr). Since crystalline silica has no harmonized classification it should be removed from the Annex III list of unacceptable co-formulants, or at least the unacceptable limits for the three quartz polymorphs need to be changed to ≥1% with <10 µm particle size. o The European Commission has recently introduced a binding and strict Occupational Exposure Limit (OEL) of 0.1mg/m3 making additional regulatory action for the protection or workers unnecessary (Directive (EU) 2017/2398). o Crystalline silica does not have a harmonised classification in Europe for any of the criteria given in the draft legislation, and therefore an impurity should in any case not trigger listing in Annex III. o The recommended limit used for the non-classification of substances containing respirable crystalline silica impurities is <1% with <10 µm particle size. The recent 14th ATP to Regulation 1272/2008 uses “aerodynamic diameter equal to or below 10 µm” to define a respirable particle size. For consistency across EU legislation, the same definition of respirable particle should be used. o The health effects observed for crystalline silica exposure arise through prolonged (chronic) inhalation exposure to high concentrations. These conditions are unlikely to arise through intermittent application of plant protection products, where minimisation of operator inhalation exposure to active ingredients through risk management measures is also an objective, and chronic daily exposure to the same product is unlikely. o Because these minerals are of natural origin the crystalline silica is also of natural origin and cannot be removed from them. As a result, we do not believe that co-formulant suppliers can meet these needlessly tightened specifications, and the result would be potentially hundreds of needless reformulations. • Data quality of concern due to errors e.g. attapulgite is listed although it has no harmonized classification, is incorrectly labelled as Carc. Cat 1B instead of Cat 2, and misses critical fiber specification >5µm present in a Member State list
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Response to A new Circular Economy Action Plan

20 Jan 2020

European Crop Protection Association welcomes New Circular Economy Action Plan which aims at achieving the Sustainable Developments Goals. Our member companies contribute to achieve these goals: Food loss There is a public perception that food waste occurs only at consumer level, whereas in reality food wastage consists of two types of wastage: food losses and food waste. According to the UN Food and Agriculture Organisation (FAO): “Food losses refer to the decrease in edible food mass throughout the part of the supply chain that specifically leads to edible food for human consumption. Food losses take place at production, postharvest and processing stages in the food supply chain”. Crop protection products and other plant science innovations boost crop yields, minimise pre- and post-harvest losses and improve the efficient use of natural resources such as land, water and energy. These products ensure that safe, high quality, and affordable food reaches the consumer, and that health and the environment are safeguarded. We fully support measures that will further reduce both food losses and food waste. Container Management Another example of how the Crop Protection Industry contributes to the Circular Economy is its stewardship programme on container management in Europe and in many other regions in the world. Pesticide packaging plays an essential role in ensuring that crop protection products are safely delivered to the farmers. Once the product is used, empty packaging becomes waste and needs to be carefully managed to protect the health and the environment from unnecessary exposure. The industry is taking its responsibility and has established various programmes promoting a life-cycle approach to product management across all stage from product development to use and ultimately appropriate management of empty containers. This includes 11 established and 7 pilot schemes in Europe. In 2017 those collection schemes in Europe collected and recycled +60% of the total volume of containers introduced onto the market with some schemes recovering +85% of containers. The Crop Protection Industry fully support the EU approach to circular economy and an enabling policy framework that allows further development of these collection and recovery programmes without impeding the recycling of the collected polymers into safe and controlled end-use applications.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

ECPA welcomes the Commission evaluation of the EU biodiversity strategy to 2020 and the opportunity to provide comments. We appreciate the decision to tackle the Biodiversity emergency in its broader context and that it quite rightly points out that the Biodiversity Strategy is an integral element of the European Green Deal, as it makes the correct link to climate change. Equally we are pleased to note that the EU highlights the multifactorial causes of biodiversity loss as pointed out by IBPES. It is appreciated to see the inclusion in the strategy of all of the sectors whose actions may impact biodiversity, beyond the agricultural sector, hence enabling to identify effective and meaningful management decisions. We fully agree that in the agricultural area, current funding levels and capacities are insufficient to counter the main drivers of biodiversity loss. Farmers have a key role to play, but they must be funded for their efforts (value to society) either in terms of payments for maintaining natural capital and/or a complete change in the way we as society value/pay for the food we eat as citizens. We also believe there is a need to inspect the relation between biodiversity conservation and food production in Europe, and in relation to the impact any EU Policy will have on food production and biodiversity at the global level. Working on a science driven integration of these two policy objectives in the EU will need further research resources (e.g. on agronomy and ecosystem services). A productive agriculture needs a healthy environment and rich biodiversity that depends on good agricultural management practices. In addition, discussions on the best farming system should be put into perspective opposite sustainability borders of the planet which imply no further land use changes can occur to close the yield gap and to feed 11 billion people in the future in a sustainable way. Regarding pesticides and biodiversity, we would like to highlight that biodiversity protection is a key criteria embedded in the legislation for authorizing substances before they are placed on the market. The continuous improvement of test guidelines, data requirements and risk assessment schemes - taking into account new scientific findings - is continuously increasing the level of scrutiny for the potential effects on the environment and ensures only safe products are being placed on the market. The whole topic is complex, but should not be confused with complicated. Agriculture/Good Farming Practices/and crop production technologies that make production more efficient all have a key role to play as part of a holistic farming approach. Fields/farmers can and will in the future, farm for food, while integrating biodiversity, carbon sequestration, and other services. We urge the EU to come to inclusive biodiversity policy harnessing the strength of all technologies that are available to fulfill the biodiversity and other sustainable development targets. The current polarized debate on food and farming where certain valuable techniques are dismissed on intrinsic properties, assumed hazard or even ideological grounds is counterproductive. An open attitude towards all technologies is important. Transparency on biodiversity targets and the effectiveness of biodiversity measures is essential to improve the likelihood of success. It is a basis for sound scientific progress and an open dialogue and can be implemented by using precision agricultural tools not just for production but also for conservation purposes.
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CropLife Europe seeks extended deadlines for pesticide renewal dossiers

21 Nov 2019
Topic — This consultation covers aligning pesticide renewal procedures with harmonized chemical classification rules.
Message — The group wants to extend the 30-day response period to 90 days for addressing questions. They request two years' notice before timeline changes to protect planned research programs.12
Why — This would provide more time for compliance and prevent disruption of planned safety studies.34
Impact — Public health advocates may face delays in pesticide re-evaluations if industry response periods are tripled.5
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Meeting with Fredrik Beckvid Tranchell (Cabinet of Vice-President Cecilia Malmström)

29 Mar 2019 · SPS issues in Ukraine

Meeting with Anne Bucher (Director-General Health and Food Safety)

15 Feb 2019 · introductory meeting

CropLife Europe warns proposed pesticide risk indicators are misleading

18 Dec 2018
Topic — The Commission proposes harmonised indicators to measure risks from pesticide use.
Message — The industry argues that indicators based on sales fail to accurately measure risk. They want data to include farmer training and specific safety measures used onsite. They also reject using emergency pesticide authorizations as a metric for risk.123
Why — The industry could report risk reduction without necessarily decreasing pesticide sales volumes.45
Impact — Environmentalists lose scientific stringency if hazard weighting factors are lowered as requested.6
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Response to Establishing conditions concerning the authorisation for movement of quarantine pests & certain plants & plant products

2 Nov 2018

ECPA is supportive of the principle of the derogation laid down in Regulation 2016/2031, under which specified pests and plants and plant products, may be introduced into the EU for the purposes of official testing, scientific or educational purposes, trials, varietal selection or breeding. We also recognise the need for detailed rules to be laid down concerning the exchange of information between Member States and the Commission and also for procedures for granting the respective authorisations, as well as the requirements for monitoring compliance. We do however have concerns regarding the provisions proposed in Article 6 (Letter of authority following the authorisation) and the impact these may have on importing material for essential research. Article 6(2) of the proposal states that: “In the case of specified material originating in the Union, the letter of authority shall conform to the format set out in Part A of Annex II. It shall be officially endorsed by the Member State of origin, for movement of the respective specified material under quarantine or confinement conditions”. Article 6(3) further states that “In the case of specified material originating in third countries, the letter of authority shall conform to the format set out in Part B of Annex II. It shall be officially endorsed by the third country of origin, for introduction of the respective specified material under quarantine or confinement conditions”. While the above provisions may appear reasonable, in practice they have often been shown to be impractical for companies importing essential material intended for research (as listed in the Council Directive 2000/29). Research and development (R&D) in the field of crop protection is an essential component of the work of ECPA’s member companies to develop new innovation solutions for farmers and growers. Our members have informed us that they have previously encountered difficulties in obtaining an official endorsement, particularly from developing countries. In some of those cases it has not been impossible to obtain such an endorsement as required under the text of Article 6(3). We are concerned that the provisions in both Article 6(2) and Article 6(3) could unnecessarily lead to barriers on importing essential material for research on crop diseases and the methods for control. This could significantly disrupt the R&D activities of our members and reduce innovation in the development of novel crop protection solutions. We would therefore recommend that the provisions be amended so that the endorsement by the country of origin is made a preferred but not obligatory part of the letter of authority.
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CropLife Europe urges longer deadlines for endocrine pesticide data

12 Oct 2018
Topic — The consultation updates pesticide renewal procedures concerning new endocrine disrupting property criteria.
Message — The group requests extending data submission periods from 30 to 40 months. They suggest delaying specific documents until after initial safety evaluations.123
Why — Longer deadlines help companies manage laboratory shortages and reduce administrative costs.45
Impact — Health advocates lose because longer deadlines delay regulatory action on toxic substances.6
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CropLife Europe seeks global standards for endocrine disruptor policy

19 Jul 2018
Topic — The creation of a comprehensive EU policy framework for endocrine-disrupting chemicals.
Message — The group proposes managing technical issues like mixture effects under general chemical rules. They emphasize that test methods must be harmonized and accepted for global use. They also call for greater involvement from the Commission’s scientific committees.123
Why — This reduces compliance burdens by avoiding specialized, more stringent endocrine disruption requirements.4
Impact — Environmental groups lose specific safeguards against low-dose effects and mixture-related chemical risks.5
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Response to Evaluation of the EU Biodiversity Strategy to 2020

18 Jul 2018

ECPA welcomes the Commission evaluation of the EU biodiversity strategy to 2020. Regarding the questions for evaluation: on efficiency and cost-effectiveness, it would be interesting to get figures from both EU and National efforts. On the question of coherence with other policies, we believe there’s a need to inspect the relation between biodiversity conservation and food production in Europe. Working on a science driven integration of these two policy objectives in the EU will need further research resources (e.g. on agro and ecosystem services). Productive agriculture needs a healthy environment and rich biodiversity that depends on good agricultural management practices.
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Response to Transparency and sustainability of the EU risk assessment model in the food chain

25 Jun 2018

We support the overall objectives of the Commission’s proposal: increasing transparency in the EU risk assessment process can contribute to strengthening public trust in the system. This is why we committed globally to publish all information related to the safety of pesticide active substances (www.ecpa.eu/industry-data-transparency). The Commission’s proposal also looks to establish pre-submission meetings, places greater emphasis on risk communication, and increases the involvement of Member States in the governance of EFSA: we support these proposals and look forward to seeing them strengthened and refined by the co-legislators. We believe however that the provisions related to when non-confidential information will be made public (art. 38), how it should be disclosed (art. 38), and the definition and protection of confidential information (art. 39), can be improved. Amendments to these provisions are essential to strike the correct balance between ensuring greater and appropriate transparency in the risk assessment process and protecting legitimate confidential business information, which are essential to guaranteeing continued innovation and investment by our sector in Europe. • On the timing of disclosure, disclosing scientific information before EFSA reaches the conclusions of its risk assessment could cause delays to the assessment, or even lead to undue political pressure, thereby threatening EFSA’s independence; for this reason we believe that the information should be made public after the first approval at Member State level of the PPP containing the active substance. • On the procedure for disclosure, the current level of protection of the information to be made public is currently insufficient: the disclosure of information should be done in a controlled manner, to ensure the data provider is protected against loss of data compensation, and to protect against its commercial or regulatory use by competitors in other parts of the world. Proper sanctions for misuse should also be enforceable, which are currently not adequately foreseen in the proposal. • On the protection of confidential information, the Commission’s proposal reverses the burden of proof on the presumption of protection of confidential information: where information is deemed to be confidential, it should not be disclosed. The new threshold set for defining such confidential information (“verifiable justification”) sets a high threshold. Finally the fact that EFSA would act as sole decision-maker on what should be disclosed, particularly in cases of urgency, without any mechanism for appeal with suspensory effect, creates a clear risk for the protection of existing legal rights. Improving the above elements is essential to ensuring a workable proposal which strengthens public trust in the process while still protecting the industry’s capacity to invest and innovate. Our industry invests over €5 billion each year in research and development, and it now takes on average 11 years and €250 million to successfully bring a new active substance to market. Only a small number of new substances have been successfully commercialised since Regulation 1107/2009 entered in to force which makes it clear that the current evaluation process does not make it simple to bring a new product to market. Finally, ECPA believes that the responsibility for commissioning studies should remain with applicants, while the responsibility for independently evaluating their robustness and quality should remain with Member States and EFSA. Further steps could be taken to improve the governance for conducting studies, which could include greater EFSA involvement.
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Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

4 Jun 2018

The European Crop Protection Association welcomes the opportunity to provide feedback on the Roadmap – “Implementation of the Aarhus Convention by the European Union (EU) in the area of access to justice in environmental matters”. We look forward to being able to provide input during the public consultation in second term of 2018. In order to ensure full and effective examination on how the Convention is currently applied in the EU, it is critical, to take into account the whole EU legal order and institutional framework, including the jurisprudence of the Court of Justice of the European Union. Furthermore, ECPA supports a need for assessing the economic and social impacts of the way forward in implementation of the Aarhus Convention in the area of access to justice in environmental matters. The social & economic impact assessment should not only be limited to costs of case-handling or impact on individual NGOs but should also cover impact on all affected stakeholders.
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Response to Stocktaking of the Commission's 'better regulation' approach

30 May 2018

ECPA welcome this opportunity to provide feedback on the Better Regulation stocktaking roadmap. The Better Regulation guidelines and toolbox published in 2015, provided a welcomed clarity to stakeholders about how EU policies are designed and evaluated. The announced changes promoting transparency, engagement of stakeholders in all steps of decision making, reduction of regulatory burdens, quality assurance and improved procedures, met the needs of the stakeholders to a great extent and created expectations. It is unfortunate however that many provisions still lack clarity (e.g. what constitutes a “significant” impact that may lead to the decision to conduct an impact assessment) and consistency in their implementation (incoherent practices regarding transparency and limited stakeholder input for secondary legislation). It is regrettable that important provisions of the interinstitutional agreement on Better Law-making are not yet fully implemented (e.g. on the delineation of delegated and implementing acts, impact assessment, decreased burden, transparency and engagement). Overall we believe there are still improvements to be made, therefore we welcome the stocktaking exercise undertaken by the Commission with this roadmap. In particular, to make the PPP authorisation system more efficient and predictable, changes are needed especially with regards to: overlaps and duplication of legislation and of application evaluations, compliance with legislative timelines, lack of predictability and level playing field due to changing requirements or related to diverse interpretations, and limited involvement of the stakeholders in decision making. We look forward to being able to develop further our position on these key issues for our industry during the 12-week public consultation in June. Depending on the start date however, we would like the Commission to take into account the fact that this consultation will take place over the summer, to possibly consider extending the deadline. We welcome the fact that stakeholders’ position papers will be used as the basis for data collection, and the foreseen consultation of relevant interest groups. We would however expect more clarity as to what this consultation will consist of: we would suggest as a great proof of transparency and stakeholders involvement, that the Commission considers organizing two workshops with stakeholders to gather sufficient feedback and input of all concerned parties ahead of their finalization. For efficiency these could take place for the presentation and discussion on the draft preliminary results and then during drafting of the final report.
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and Fédération Européenne des Fabricants d'Aliments Composés and

17 May 2018 · Import tolerance, Commission's proposal on general food law, REFIT on pesticides

Response to Recast of Persistent Organic Pollutants (POPs) Regulation

19 Apr 2018

ECPA supports the recast of the POPs regulation, however clarity on the process of how ECHA will be involved in the process of evaluating an potential POP candidate substance still needs to be clarified, whether one of the existing ECHA scientific committees will have oversight and whether a public consultation be agreed to enable stakeholder the opportunity to comment on any POP proposal.
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

20 Feb 2018 · guidance documentation

Response to Transparency and sustainability of the EU risk assessment model in the food chain

17 Jan 2018

ECPA supports the Commission initiative to increase public confidence in the EU risk assessment process, including those actions intended to improve transparency. We recognise the legitimate societal demand for transparency in evaluation procedures. On the measures described in the roadmap, our feedback is as follows: • improve & clarify rules on transparency, especially scientific studies supporting the risk assessment; ECPA supports the principle of this objective. As noted in the Commission communication on the ECI on glyphosate a significant proportion of the data packages submitted by applicants are already made publicly available. However we are supportive of moves to provide greater public access to studies underlying the risk assessment. The correct balance does need to be struck between ensuring greater transparency and the need to protect those aspects that include legitimate confidential business information and intellectual property details (e.g. as described in Art 63(2), Reg 1107/2009). Consideration must be given on how best to ensure studies made publicly available are not misused for commercial purposes in the EU or in regions outside Europe. • increase guarantees of reliability, objectivity & independence of studies used by EFSA in risk assessment, in particular in authorisation dossiers; We concur with the Commission conclusion that the responsibility for commissioning studies should remain with applicants. However we support steps to strengthen the governance for conducting studies, including greater involvement of EFSA and Commission in the process of agreeing which studies will be performed, and independent auditing of GLP compliance or other measures to ensure studies are undertaken according to required regulatory requirements. • improve governance & strengthen scientific cooperation & involvement of Member States in EFSA; We support this objective and any steps to increase the engagement of experts from Member States in the risk assessment process, both academic experts and experts from competent authorities. This intention appears limited to scientific (risk assessment) cooperation; we would highlight the need for cooperation to extend to risk assessment and risk management, i.e. the initiative should aim to ensure greater cooperation between EFSA, Commission and Member State risk assessors and risk managers. • address limitations affecting long term scientific capacity of EFSA & its ability to maintain a high level of scientific expertise across different areas of the agri-food sector; taking also account of related financial & budgetary aspects; As above, we believe there is an opportunity to promote a system making better use of the collective expertise of Member States, e.g. via the pooling of and collaboration between experts to undertake evaluations. • develop more effective & transparent risk communication with public in collaboration with Member States: This is also an objective we would support. Many of the actions described above alone are unlikely to improve public confidence and understanding of the regulatory process, without greater engagement in risk communication. More effective risk communication will require improved cooperation between risk assessors and risk managers. Other comments: In preparing any legislative proposals we would anticipate that an analysis of the possible impacts of those proposals would be included as part of the policy development process. We also note the conclusion in the Commission staff working document of the REFIT evaluation: “Lengthy authorisation procedures in some sectors (e.g. feed additives, plant protection products, food improvement agents, novel foods, health claims) slow down the market entry process. This affects the innovation potential and the competitiveness of the EU food and drink industry as well as its capacity to address future challenges.” We hope in the ongoing work equal weight will be given to also addressing this shortcoming.
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Response to Export and import of hazardous chemicals

3 Aug 2017

This pesticide active substance 3-decen-2-one has recently been submitted with an updated dossier for approval under Regulation EC 1107/2009. The RMS is the Netherlands who should notify COM shortly that the dossier is considered admissible. On this basis the entry should be removed until a final decision on approval is made.
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Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

30 Mar 2017 · Latest Commission proposal on comitology

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

3 Feb 2017 · Business discussion

Meeting with Arunas Vinciunas (Cabinet of Commissioner Vytenis Andriukaitis), Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and

14 Dec 2016 · Dimethoate

CropLife urges risk-based approach for low-risk pesticide criteria

1 Dec 2016
Topic — Revision of criteria identifying low-risk substances under EU pesticide authorization regulations.
Message — The association suggests changing the terminology to “low hazard” to avoid public confusion. They request using existing standard triggers for persistence and removing specific toxicity criteria for aquatic life. Additionally, they propose clarifying that qualifying substances “shall be considered” low risk.123
Why — This would facilitate the approval of more chemical substances by lowering the regulatory threshold for low-risk status.45
Impact — Environmental groups lose if aquatic protection standards are reduced by removing hazard-based exclusion criteria.6
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

11 Oct 2016 · Introductory meeting

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and European Chemical Industry Council

28 Jun 2016 · Endocrine disruptors

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

12 Apr 2016 · Endocrine disruptors and pesticides

Meeting with Vytenis Andriukaitis (Commissioner) and

4 Apr 2016 · Endocrine disruptors

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)

24 Feb 2016 · Endocrine Disruptor Criteria (for pesticides and biocides)

Meeting with Xavier Prats Monné (Director-General Health and Food Safety)

21 Jan 2016 · Introductory visit

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

16 Nov 2015 · Cut-off criteria; classification proposal by EFSA

Meeting with Ladislav Miko (acting Director-General Health and Food Safety)

4 Aug 2015 · Organisation of an EU bee health workshop

Meeting with Tom Tynan (Cabinet of Commissioner Phil Hogan)

10 Jun 2015 · Application of the pesticide regulatory framework

Meeting with Ladislav Miko (acting Director-General Health and Food Safety)

27 May 2015 · Regulatory issues including endocrine and bees

Meeting with Vytenis Andriukaitis (Commissioner) and

2 Mar 2015 · EU POLICY ON PESTICIDES

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)

2 Feb 2015 · Meeting with European Crop Protection Association

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

8 Jan 2015 · Plant Protection Material