European Crop Care Association
ECCA
The associations goals are: - to inform its members about legislation and regulation in the EU and its Member States affecting their business; - to research into common solutions of any legal, financial, scientific and technical issues caused by community or national legislation or regulation, with the intention to improve or develop the members' economic activities; - to represent its members in all occurring situations towards the European Institutions and Memberstates; - to be the single point of contact of its members for regulatory authorities at any level with regard to the placing on the market of substances and products; - to organise meetings between its members, and/or with regulatory authorities, to distribute information, to develop, draft and distribute proposals on possible solutions for common problems to regulatory authorities, and to legally represent its members.
ID: 059443622722-41
Lobbying Activity
Response to Food and Feed Safety Simplification Omnibus
14 Oct 2025
The European Crop Care Association (ECCA) strongly supports the simplification of procedures under Regulation (EC) No 1107/2009, while ensuring that the high level of protection for human and animal health and the environment is fully maintained. Over the more than 14 years since its full entry into force, several issues and inefficiencies have been identified and experienced by our members. The purpose of our contribution is to help remove these regulatory bottlenecks and streamline the system, thereby enabling the economic benefits targeted by this initiative to be effectively achieved. Attached, we upload a document with our proposed amendments, and the background data supporting such proposals. ECCA stands ready to provide further data and evidence in support of its claims, should this be required.
Read full responseMeeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen)
15 Sept 2025 · Plant protection products
Response to Update of labelling obligations for plant protection products
30 Jan 2025
ECCA hereby provides his comments to the draft Commission Regulation on the labelling of Plant Protection Products, repealing Regulation 547/2011. While ECCA welcomes this proposal, it contains some elements that raise serious concerns. ECCA comments are in the attached document.
Read full response20 Dec 2023
ECCA wishes to comment that the draft Regulation is not in compliance with the requirements of Article 26 of Regulation (EU) No 1107/2009, since it does not include the establishment of measures to minimise animal testing, nor evaluation, assessment and decision-making procedures as required by that Article. In the attached document ECCA also points out inconsistencies in the proposed procedure for admissibility checking, which further underlines the need for establishing clear and unambiguous procedures. Furthermore, ECCA explains in the attached paper that the timelines of the draft Regulation can lead to a situation where authorisations may be lost for reasons beyond the control of applicants and/or authorisation holders. Finally, suggestions are made to amend the text of Article 9(2) of the draft Regulation, to avoid confusion regarding the future implementation of data protection for test and study reports submitted in the context of approval of safeners or synergists or for authorisation of products containing such safeners or synergists.
Read full responseResponse to Ensuring that hazardous chemicals banned in the European Union are not produced for export
26 Jul 2023
ECCA understands the underlying objectives set by this initiative. However, we believe the proposal will not have any significant impact on the use of Plant Protection Products (PPPs) in vulnerable countries and the final objectives of this initiative wont be meet. But while the final objectives wont be meet, damage to EU industry will result from the initiative. Summary of the reasons why ECCA disagrees with the legislative initiative being proposed: Export ban proposal is missing the objectives of the Chemical Strategy for Sustainability initiative it is ECCA believe that the export ban as it is being proposed, will not reach its objectives. In a globalized world the supply of such banned products will simply switch from European companies to companies form other geographies. The best way to achieve the initiative objectives would be through a reinforcement of the PIC Regulation and the cooperation with vulnerable countries. Relevance of EU risk assessment and ban the fact that an active substance is revoked in EU due to an unacceptable risk assessment, does not automatically translate into an unacceptable risk throughout the entire world. On one side the revoke of substances in EU may be due to a wrong choice of representative formulation and GAP or rigidity of the regulatory system, and on the other side, agroclimatic conditions and patter of use of the product in other geographic regions can be significantly different. Paternalistic EU position - a blanket export ban to the entire world will affect exports to vulnerable countries but also to countries with sound complex regulatory systems. Those countries having made a detailed risk assessment, with the conclusion that the risk posed by those banned substances is acceptable will perceive EU position as paternalistic. Impact over viability of several manufacturing plants in Europe this export ban will heavily impact economic viability of several production plants across Europe. A call is made to ensure that the impact assessment being made, really reflects the impact the measure will have over existing companies. Call for an in-depth impact assessment ECCA calls the Commission to include a cost/benefit analysis within the impact assessment, where cost is the impact over European companies, and benefit is a realistic assessment of the positive impacts (if any) that the export ban would really bring to vulnerable countries. A document further detailing on the reasons why ECCA disagres with this initiative proposal is uploaded.
Read full responseResponse to Sustainable use of pesticides – revision of the EU rules
19 Sept 2022
The “Harmonised Risk Indicators” in the draft SUR do not indicate the risk of pesticide use in any way. It is misleading, both to both farmers and to the public, to oblige Member States to establish legally binding targets based on meaningless indicators. Reduction of use, expressed as kilos, is not a useful target either. The IPM goals are meaningful and important, but the timelines are unrealistic, and the definition of IPM should be reconsidered.
ECCA does not support the policy of “use reduction” of pesticides, when the use is expressed in kilos of active substance. In the attached short paper we explain how the “use of pesticides” could be expressed in a more meaningful manner. The “risk reduction” of pesticides is a political goal, for which in principle meaningful indicators can be developed. The draft Regulation mentions that JRC is in the process of developing meaningful indicators. The current indicators however are meaningless, and to use them as the basis for legally binding targets in the Member States is misleading the public. Real indicators can be developed, but it will take time before they can be applied, because they will need detailed statistical information that will only become available if and when the upcoming SAIO Regulation provides for the collection of the required information. It would be morally correct to acknowledge that at this moment there is no information available at European level to measure the risk of pesticides in a meaningful manner.
ECCA does not support the indicators and mechanism proposed to mitigate the huge differences, on the intensity of use and starting points amongst countries. The indicators proposed, are based on kilos of active substance used per hectare. These are misleading indicators, providing information that doesn’t reflects the real situation of countries, since products can vary in the dose per hectare by several orders of magnitude. Again, real indicators can be developed, but it will take time before they can be used, since the relevant information would need to be collected first.
ECCA supports the implementation of IPM. The timelines in the Regulation however are unrealistic. It is good to motivate and push the Member States to facilitate and regulate the use of IPM, but setting unrealistic timelines leads only to investigations and reports later on, to explain why the timelines were not met. Moreover, the definition of IPM in the draft SUR diverges from the FAO definition, and aims to use pesticides “as a last resort”, rather than to integrate their use in a pest control system that minimises their use.
The use and risk of pesticides CAN be reduced, through the development and implementation of thorough IPM systems. The draft SUR in its current form does not provide a pragmatic and sustainable pathway to achieve the desired reduction.
The attached paper explains ECCA’s observations and reservations in detail.
Read full response1 Oct 2020
NOTE: this text is a shortened version of ECCA's comments. The complete comments are contained in the attached document.
In the SCoPAFF meeting of 16-17 July 2020, regarding this draft Regulation, “[t]he Commission announced that it intends to submit a draft Regulation for vote at the next meeting of this Committee”. The next meeting of the Committee takes place on 22-23 October 2020.
This feedback mechanism states: “Feedback will be taken into account for finalising this initiative”. With the commenting period under this feedback mechanism ending on 1 October 2020, this is simply not possible when a vote on a final version is planned to be taken by 22-23 October 2020. ECCA protests against this state of affairs and insists that comments from all stakeholders are taken into serious consideration before a final version of the draft Regulation is proposed to the Committee for voting.
The renewal process, governed by Regulation 844/2012, has been criticised by industry, competent authorities and societal organisations for various reasons. The Transparency Regulation introduced solutions to concerns from society. ECCA acknowledges those concerns and the need to introduce additional provisions. These new provisions come at a cost however: the process becomes even more complicated, increasing the time-pressure on applicants and competent authorities.
ECCA has expressed at many public events, as well as in direct communications with the Commission and the Member States its concerns about flaws in the process and shortcomings in the implementation of the Regulation.
Two major aspects are particularly important to the generic industry and to SMEs in general:
• the facilitation of joint submission of dossiers for the renewal of approval of active substances
• the proper implementation of the provisions of Regulation 1107/2009 with regard to “necessary studies”.
The current process allows applicants to fabricate technical barriers that make it difficult, costly or impossible for generic manufacturers and SMEs to enter or remain in the market. Provisions in Regulations 1107/2009 and 844/2012, designed to prevent this, are structurally ignored. The revision of Reg. 844/2012 should improve transparency not only for citizens, but also for direct stakeholders. A crucial part of the new process, the “pre-submission” phase, is particularly relevant.
The current draft Regulation does not touch upon the flaws in the system: it is a missed opportunity. Without further clarification of the procedures, responsibilities and requirements, the resources of the competent authorities will continue to be wasted by endless discussions on the necessity of studies, the need for “data matching studies”, the evaluation of duplicated studies and claims and waivers for data protection. Clarifications are essential to a correct implementation of the provisions of Regulation 1107/2009. They should be laid down in this Regulation, and not left to be decided unilaterally by EFSA in the Practical Arrangements or in Guidance Documents.
ECCA calls upon the Commission and the Member States to revise this draft Regulation, in particular paying attention to the following points:
• clear timelines and process for the submission of notification of studies intended to support a future application, public consultation and comprehensive advice (Art.3) and requests for pre-submission advice (Art.4);
• amending the Regulation, introducing an EFSA-initiated common pre-submission meeting as a first milestone in the renewal process, gathering potential applicants and sharing views on necessary studies for renewal;
• clear rules on the justification for necessary studies: insufficient, unfounded, or lacking justification must lead to non-acceptance of data protection claims or inadmissibility of the application.
In the attached document ECCA provides detailed comments on specific topics and Articles of the draft Regulation.
Read full responseResponse to Co-formulants in pesticides
13 Feb 2020
ECCA's complete comments are provided in the attached document.
ECCA's comments are summarised as follows:
1. the legal basis for the proposed Regulation is questionable, since it combines amendments that require a different Comitology process
2. the manner of selecting substances for listing in Annex III is questioned. Regulation 1107/2009 requires in Article 27(2) that "A co-formulant shall not be accepted for inclusion in a plant protection product where it has been established that (…) its use, consequent on application consistent with good plant protection practice and having regard to realistic conditions of use, has a harmful effect on human or animal health or an unacceptable effect on plants, plant products or the environment". This unequivocally calls for a risk-assessment based selection process, whilst the current list is based on hazard criteria.
3. the transitional provisions, allowing only two years for amending or withdrawing existing authorisations, create a technical impossibility for authorisation holders to adapt their product composition in case of non-compliance. Such adaptation requires developing a new formulation, testing this formulation under rigorous requirements, preparing a dossier, and waiting for national and/or zonal assessment after submission of that dossier, before an authorisation can be expected and the new formulation can replace the non-compliant one. While the proposed criteria are hazard based, they do constitute an established risk, and no actual urgency can therefore be claimed.
4. The unintentional and unavoidable presence of certain impurities in co-formulants should be treated in a consistent manner with any chemical substance and product. Therefore, the maximum level of unacceptable co-formulants in products, as the result of their presence as an unintentional impurity in a co-formulant, should be set at 0,1% instead of the proposed 0,01%.
5. The listing of the co-formulants aluminium silicate (kaolin), cristobalite, quartz, and tridymite should be removed from the list, irrespective of the content of crystalline silica. The proposed particle size fraction and permissible percentage of crystalline silica does not match the definition of respirable crystalline silica, which is the underlying reason for listing these substances. Respirable Crystalline Silica is a (group of) substance(s) well covered by existing Community legislation, designed for protecting workers. The introduction of these substances, especially with the erroneous and ambiguous specifications as proposed, in Annex III to Regulation 1107/2009 is unnecessarily complicated, causing the potential loss of valuable component for effective products that permit the use of active substances in an efficient manner, at the lowest possible dose-rate, without any positive effect on human health or environmental safety. Other, far more efficient, legal instruments are available to avoid risks from any presence of Respirable Crystalline Silica in pesticide formulations.
Read full responseResponse to Transparency and sustainability of the EU risk assessment model in the food chain
25 Jun 2018
ECCA would like to express its support for any initiative that improves clarity and transparency of the regulatory system for pesticides.
With regard to the current proposal, we have concerns with regard to certain parts, as expressed below:
CONFIDENTIALITY
The Commission proposal includes amendments to Article 39 of Regulation (EC) No 178/2002 and to Article 63 of Regulation (EC) No 1107/2009.
The explanatory memorandum states that “the proposal sets outs which type of information IS to be considered confidential”. The proposed new wording however appears to reduce significantly the predictability of confidential treatment of certain types of information. The current legislation (Regulation (EC) No 1107/2009) ensures that “Disclosure of the following information shall normally be deemed to undermine the protection of the commercial interests (…)”. The proposed new wording states that “confidential treatment MAY be accepted with respect to the following information, the disclosure of which MAY be deemed, upon verifiable justification, to significantly harm the interests concerned“. This wording is not in line with the explanatory memorandum: it replaces a clear text (what IS confidential) by a vague text (what MAY be accepted as confidential). Moreover, the new text moves away from the established wording “undermine the protection of commercial interests” to “significantly harm the interests concerned”, without justification for this apparently more restrictive definition.
Recent and on-going cases before the General Court and the European Court of Justice (Case C-673/13 P, Case T‐545/11 (/RENV)) have underlined the importance of clarity of the letter of the law. The current proposal does not improve this clarity.
Finally, the proposal confers on EFSA the full power to decide on the confidentiality of data. This power exceeds the remit of the Authority, whose primary task is to provide scientific assessments, not economic or commercial assessments.
UNION REGISTER OF STUDIES
The proposed establishment of a “Union Register of Studies”, in its current form, is a relatively vague concept, and relies for its further implementation entirely on the power conferred on EFSA to establish internal rules (Art. 32b.4). This power does not belong with EFSA, whose task is to assess risk on the basis of current scientific and technical knowledge, not to (potentially) reject scientifically valid studies for administrative reasons.
The proposal does not take into account the possibility that studies may have been commissioned in other parts of the world at a stage of development of a substance when approval in Europe was not part of the researchers’ outlook. Such studies would not have been notified to the Union Register. The proposal does not take into account that a scientifically perfectly valid study on vertebrate animals that, for whatever reason, was not notified with the Register MAY not even be repeated under the provisions of Regulation 1107/2009, leaving the applicant with no solution to fill a data requirement. Many other scenarios can be envisioned that require clear rules.
Setting the rules for the acceptance or rejection of studies for reasons other than scientific ones is to be regarded as a measure designed to amend non-essential elements of the Regulation; such rules should therefore be adopted in accordance with the regulatory procedure with scrutiny. This is not a task for EFSA.
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