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International Biocontrol Manufacturers' Association

IBMA

IBMA represents over 230 biocontrol manufacturers globally, promoting biological pest control for sustainable agriculture.

Lobbying Activity

IBMA urges faster EU market access for biocontrol solutions

14 Oct 2025
Topic — The consultation aims to simplify EU food and feed safety regulations.
Message — IBMA requests a legal definition for biocontrol and the removal of re-registration procedures. They advocate for provisional authorizations and a priority lane to accelerate access.123
Why — This would lower compliance costs and speed up product commercialisation.4
Impact — Conventional chemical pesticide manufacturers would lose priority status in the regulatory queue.5
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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 Eric Sargiacomo (Member of the European Parliament)

3 Oct 2025 · Bioncontrôle

Biocontrol industry urges EU to exempt biologicals from chemical rules

2 Oct 2025
Topic — Updating evaluation and authorisation rules for plant protection products in the EU.
Message — IBMA requests exemptions for biocontrol from requirements designed for synthetic chemicals. They urge the Commission to recognize biological substances' unique properties.12
Why — Tailored rules would lower costs and prevent biological products from being unfairly blocked.3
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Response to Amendment of data requirements for applications for the authorisation of plant protection products

2 Oct 2025

IBMA would like to thank the European Commission for the opportunity to provide comments on the new Draft Data Requirements for applications for Plant Protection Products authorisation. Please find attached our general feedback together with the detailed commenting tables.
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Response to Amendment of data requirements for applications for the approval of active substances

2 Oct 2025

IBMA would like to thank the European Commission for the opportunity to provide comments on the new Draft Data Requirements for applications to approve active substances. Please find attached our general feedback together with the detailed commenting tables.
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Meeting with Cristina Maestre (Member of the European Parliament)

29 Sept 2025 · Biocontrol

Biocontrol Industry Urges Product-Level Assessment for Microbial Biostimulants

19 Sept 2025
Topic — Evaluation of the EU Fertilising Products Regulation regarding market effectiveness and safety.
Message — IBMA requests moving assessment to the product level for functional claims. They also suggest removing processing restrictions and updating unrealistic microorganism concentration tolerances.123
Why — This would lower regulatory barriers for biological products and boost market competitiveness.4
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Response to Listing existing safeners and synergists to be assessed in the work programme for their gradual review

8 Jul 2025

IBMA members experience difficulties when a biocontrol active substance (AS) is also included in the safener and synergist list. It is therefore important that safeners and synergists are clearly differentiated from active substances.
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Meeting with Flavio Facioni (Cabinet of Commissioner Olivér Várhelyi) and #SustainablePublicAffairs

2 Jul 2025 · Biocontrol solutions

Biocontrol industry urges EU to speed up biological pesticide approvals

23 Jun 2025
Topic — The EU is developing a strategy for a circular, regenerative, and competitive bioeconomy.
Message — IBMA requests a harmonized EU-wide legal definition to stimulate market demand for biocontrol. They also propose streamlining regulatory pathways to accelerate market access for biological innovations.12
Why — Faster approvals would shorten investment payback times and support growth for biocontrol SMEs.34
Impact — Traditional chemical pesticide producers lose market share as biological alternatives receive regulatory priority.5
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Meeting with Alisa Tiganj (Cabinet of Commissioner Christophe Hansen) and #SustainablePublicAffairs

18 Jun 2025 · Measures needed to accelerate the authorisation of biocontrol in the EU, including potential EFSA configurations to increase biocontrol's availability in the EU market

Biocontrol association urges EU to streamline green pesticide approvals

11 Jun 2025
Topic — The European Commission is consulting on legislation to accelerate biotechnology market transition.
Message — The association wants a broad scope covering diverse agri-food biological applications. They demand a harmonized EU-wide legal definition to stimulate market demand. They also request streamlined regulatory pathways.1234
Why — Streamlined rules would reduce investment payback times and foster industry growth.56
Impact — Conventional chemical pesticide producers face increased competition from faster-tracked biological alternatives.78
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Meeting with Benoit Cassart (Member of the European Parliament, Shadow rapporteur)

11 Jun 2025 · Biocontroles

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

19 Mar 2025 · Simplification

Response to EU Start-up and Scale-up Strategy

17 Mar 2025

IBMA welcomes the European Commissions upcoming EU Startup and Scaleup Strategy for 2025 to fully exploit the potentials of European SMEs and boost Europes productivity. Please find our feedback in the document attached.
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Meeting with Eric Thévenard (Head of Unit Health and Food Safety)

13 Mar 2025 · EFSA role in improving access to market for biocontrol

Meeting with Catherine Geslain-Laneelle (Director Agriculture and Rural Development)

11 Mar 2025 · Exchange on view on the Vision on Agriculture and Food

Response to Amendment of the list of products and substances authorised in organic production

4 Mar 2025

IBMA would like to provide comments on the proposed draft Commission Implementing Regulation amending and correcting Implementing Regulation (EU) 2021/1165 authorising certain products and substances for use in organic production and establishing their lists (and its Annexes). The input of IBMA can be found in the attached document.
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Meeting with Hildegard Bentele (Member of the European Parliament, Rapporteur) and EuropaBio and

27 Feb 2025 · Biotech

Meeting with Antonella Rossetti (Cabinet of Commissioner Christophe Hansen), Maxi Espeter (Cabinet of Commissioner Christophe Hansen)

27 Feb 2025 · Biocontrol legislation

Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra)

26 Feb 2025 · The role of biofertilizers and related products in the transition to climate neutrality

Meeting with Alvydas Stancikas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Confederation of Danish Industry and Novonesis A/S

4 Feb 2025 · Collect stakeholders input for the SMET project on authorisation of biosolutions

Biocontrol industry rejects EU labeling scheme, seeks recognition

3 Feb 2025
Topic — Revision of European Union rules regarding labeling obligations for plant protection products.
Message — IBMA requests a dedicated biocontrol label and the removal of a proposed color-coded hazard scheme. They also seek to delay digital labeling requirements until 2028.12
Why — This prevents biocontrol products from being stigmatized while providing extra time for technical compliance.34
Impact — Regulators and farmers lose a simplified visual tool for comparing pesticide hazards and environmental risks.5
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Biocontrol manufacturers urge faster EU single market approvals

31 Jan 2025
Topic — This consultation addresses the development of a strategy for the European single market.
Message — IBMA requests a unified definition of biocontrol to simplify trade. They want a new regulatory framework and a dedicated agency.123
Why — Companies would benefit from shorter authorisation timelines and lower administrative costs.45
Impact — National governments would lose their power to enforce specific local regulatory requirements.6
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Meeting with Eric Thévenard (Head of Unit Health and Food Safety)

30 Jan 2025 · Future regulatory activities regarding biocontrol products

Meeting with Majdouline Sbai (Member of the European Parliament)

16 Oct 2024 · Vision mandat

Meeting with Eric Sargiacomo (Member of the European Parliament)

4 Jul 2024 · Biocontrol

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

8 Apr 2024

IBMA International Biocontrol Manufacturers Association welcomes the EU Commission's initiative in launching a "Call for Evidence" allowing stakeholders to provide feedback for the evaluation of EFSA's performance from 2017 to 2024. IBMA has observed a noticeable increase in EFSA's willingness to engage with stakeholders, and we appreciate the significant steps made towards greater openness and transparency. IBMA has particularly noticed and valued the increase in stakeholders consultations, the creation of stakeholders discussion groups, the new open EFSA platform, and the implementation of multiple communication tools aimed at providing more information to applicants. As a registered stakeholder and member of a discussion group, IBMA is willing to further engage with EFSA. IBMA takes this opportunity to offer initial perspectives on key topics. We reserve more detailed comments for the Public Consultation scheduled for the third quarter of 2024. The safety or biocontrol products is the key priority for IBMA. We appreciate the important work of EFSA in assessing biocontrol, as thorough risk assessment fosters the acceptance of biocontrol products by farmers, the public, and society. However, over the past decade, we have experienced significant delays within EFSA conducting these risk assessments. We call for improved processes and sufficient resources to enhance the scientific soundness and input at EFSA. Specifically for natural substances, IBMA encourages EFSA to expand its expertise base and engage more often with stakeholders during the evaluation. IBMA has recently published a decision tree to streamline the evaluation of natural substances, which could assist in this process. We also call upon prioritization of new biocontrol substances including novel natural substances over, for instance, renewals at EFSA level. To deliver timely innovations to the EU market, EFSA should increase their expertise and have more dedicated resources available in reviewing novel biocontrol solutions. Some submissions for natural substances showed that a number of data requirements were not relevant, not appropriate or that it was not technically feasible to address these data points. This resulted in risks identified in the EFSA conclusion due to lack of evidence rather than a clear scientific based point of view. In addition, this resulted in EFSA choosing endpoints which may be overconservative for well-known natural substances. The pre-submission advice of EFSA is limited to regulations and guidance documents already available to the public. However, EFSA should provide helpful pre-submission advice for biocontrol submissions related to intended waivers or adjustments of test guidelines, when appropriate. We note that, in some cases, EFSA Conclusion on biocontrol substances can be misaligned with the RMS conclusion. This should be avoided as much as possible, for example by organizing pre-submission meetings. The complexity of the General Food Law/IUCLID/processes impacts innovation of new biocontrol substances. IBMA is of the opinion that the IUCLID-implementation happened too fast and at a rather immature stage, which led to error-proneness, and occurrence of "accidents" (e.g., erroneous publication of un-sanitised dossier versions), of which the possible damage for applicants can't be estimated. IUCLID is a major problem for biocontrol submissions and the limited dialogue with EFSA has impacted the implementation. IBMA is willing to work together with EFSA and Member States to improve implementation. Admissibility is a major problem: for new substances the 1-month deadline is often not respected. Also, it has to be considered that if EFSA asks for updating the dossier with the latest IUCLID version even when submission was done before the release, this can result in a very costly and resource consuming activity for applicants. To facilitate faster reviews of some substances the fast-track review option should be used mor
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Meeting with Lukas Visek (Cabinet of Vice-President Maroš Šefčovič)

12 Dec 2023 · Sustainable use of pesticides

Meeting with Maria Arena (Member of the European Parliament, Shadow rapporteur)

7 Sept 2023 · Biocontrol

Response to Amendment of the list of products and substances authorised in organic production

10 Aug 2023

IBMA supports the recommendation from the EGTOP to allow all low-risk active substances from plant and animal origin to be used in organic production without an additional evaluation by the EGTOP. IBMA recognises that this provision will provide a fast track for these substances and will facilitate the approval of additional solutions to expand the organic farmers toolbox. As an additional proposal, IBMA would also recommend the EGTOP to consider the removal of limitations for the use of pheromones and other semiochemicals. All uses approved for plant protection purposes should be allowed in organic production. Pheromones and other semiochemicals are currently limited to the use in traps and dispensers. This limitation refers to old agricultural practices and its removal could allow the use of additional pheromone solutions such as sprayable applications (e.g. microencapsulation technologies).
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Meeting with Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

18 Jan 2023 · VTC meeting on the proposal for a regulation on the sustainable use of plant-protection products (SUR)

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

16 Nov 2022 · Sustainable use of plant protection products

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

15 Nov 2022 · Sustainable use of pesticides

Biocontrol industry seeks specific metrics for electronic pesticide records

3 Nov 2022
Topic — This consultation establishes harmonised rules for electronic record-keeping of plant protection product use.
Message — IBMA requests including colony forming units as a standard concentration unit for microorganisms. They also suggest specifying application equipment types to prepare for future registers.12
Why — Standardized recording would better quantify the market share and usage of biocontrol products.3
Impact — Chemical pesticide manufacturers face scrutiny as new data monitors the reduction of their products.4
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Meeting with Sarah Wiener (Member of the European Parliament, Rapporteur)

10 Oct 2022 · staff only: role of biopesticides, SUR

Biocontrol industry urges 75% target in EU pesticide overhaul

21 Sept 2022
Topic — Revision of EU rules to reduce pesticide risks and protect human health.
Message — The industry requests a 75% positive target for biocontrol and wants these methods permitted in public parks. They also argue that biological controls should be prioritized over chemicals.12
Why — This would grant the industry guaranteed market share and provide legal certainty for investments.3
Impact — Chemical pesticide producers would see their products relegated to a last-resort option under the hierarchy.45
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Response to Protecting biodiversity: nature restoration targets

22 Aug 2022

IBMA, the International Biocontrol Manufacturers Association, welcomes this public consultation regarding the European Commission proposal for a Nature Restoration Regulation, a crucial matter for the future of the environment and the biodiversity, in line with EU objectives. As well underlined in the proposal: ´´Agriculture, forestry and fisheries are all sectors that depend on ecosystems in good condition´´ In particular, for our biocontrol solutions to work at their best, we need healthy and dynamic ecosystems, which allow farmers to work with nature towards a more sustainable resilient agriculture. This is why, as the biocontrol industry representatives, we welcome this future regulation which, among other important achievements, should allow to make agriculture more resilient to climate change and environmental risks. The use of biocontrol contributes to biodiversity-rich agricultural ecosystems and the environmental benefits of biocontrol are well shown in the IEEP report Exploring benefits of biocontrol for sustainable agriculture (here attached too). In addition, the Member States have to put in place ´´the restoration measures necessary to enhance biodiversity in agricultural ecosystems.´´ When it comes to agriculture and its impact on nature, this will only be possible in combination with a proper implementation of the Sustainable Use of Plant Protections Products Regulation (SUR). In this respect it is particularly important that as indicated in the SUR Integrated Pest Management (IPM) is largely applied and that the contribution from IPM to the EU Biodiversity Strategy for 2030 and the functioning of ecosystems and ecosystem services is acknowledged. Indicators for IPM such as the presence of pollinators and beneficial invertebrates can play an important role in this context. Providing the farmers as soon as possible with our biocontrol solutions via fast track procedures together with the appropriate training for all the actors along the agro chain is considered key. To know more how to speed up the approval of biocontrol solutions that are now stuck in the pipelines, please read here online our call to regulatory authorities to unlock the potential of biocontrol. (attached too). Together with ecosystems, agronomy, monitoring and mechanic tools, our biocontrol solutions are key to support nature restoration in agricultural lands.
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Response to Streamlining EU scientific and technical work on chemicals through the EU agencies

12 Apr 2022

IBMA, the International Biocontrol Manufacturers Association with its over 230 members of which 85% SMEs, welcomes this public consultation. It regards a crucial matter for the future, in particular when it comes to PPPs such as biocontrol solutions, and therefore for the transition to a future more sustainable agriculture using agroecological farming practices, as per the EU Green Deal and Strategies objectives. - IBMA welcomes the move towards “One Substance-One Assessment” and supports close collaboration between EU agencies and scientific bodies. If well implemented, both industry and authorities will benefit from the one substance one assessment approach. Clarity of process will increase predictability and help streamline resources on both sides. - Although this initiative is targeting on ‘chemicals’ IBMA want to stress that EU regulated biocontrol is currently covered under chemical legislation Regulation (EC) No 1107/2009 or Biocidal Products Regulation, Reg (EU) No 528/201. Therefore, a similar “one assessment” approach could also be taken for biologicals. Biocontrol regulated for plant protection or biocidal uses includes microbials, natural substances and semiochemicals. Biocontrol products themselves may be used for more than one purpose; for example, micro-organisms are used in the area of crop protection, but also as fertiliser or biostimulant under Fertilizer Product Regulation (FPR) Regulation (EU) No 2019/1009. The same micro-organism used in agriculture but subject to different regulatory frameworks and thus to different sets of data requirements and procedures. Ultimately this may lead to different and even contrary decisions: based on the same data package the same micro-organism may be authorised for one area of use (e.g. as a biostimulant), but may not be approved for another area of use (e.g. crop protection). - It is essential that hazard classification for any one substance is harmonized. - As data requirements, procedures and timelines for the same substance may differ under comparable legislation, IBMA questions the sentence “There is no need for an impact assessment as there is little discretion on the policy choices, and no significant economic, social or environment impact is expected”. - To make this system work it is recommended that evaluators/risk assessors from different regulatory bodies attend each other meetings thus ensuring consistency and avoiding duplication of work. IBMA recommends that procedures and transparency rules are also harmonized. - The initiative aims to consolidate in EU agencies the technical and scientific work on chemicals performed at EU level under, or in support of, EU legislation. In this respect IBMA recommend establishing within the EU a group of biocontrol experts. To start, microbial experts from Member States, EFSA, ECHA, and other relevant EU institutions that, in close cooperation with COM, will be responsible for all evaluations and assessments of microbial active substances submitted in the EU for approval. This would guarantee a consistent and scientifically sound approach that would considerably simplify and speed up procedures. This should then be extended to cover experts in natural substances and semiochemicals. - Implementation of measures as proposed in this initiative are important to reduce unnecessary delays and to deliver the goals of Farm to Fork. - A fit-for-purpose One Substance-One Assessment approach should lead to: • Increased efficiency and predictability; • Enhanced consistency of hazard assessments and their outcomes, carried out on the same dataset • Improved robustness of the hazard assessments • Involvement of the right biocontrol expertise at the right place at the right time • Provision of tailored risk assessments under specific legislations/uses if relevant • Optimal use of resources. IBMA supports the One Substance- One Assessment approach if it can deliver these above-mentioned benefits.
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Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

11 Mar 2022

IBMA, the International Biocontrol Manufacturers Association, welcomes this public consultation regarding a crucial matter for the transition to a future more sustainable agriculture using agroecological farming practices, as per the EU Green Deal and Strategies objectives. Soil health is absolutely key for the future of agriculture while it is now both in bad chemical and biological conditions, and as you well underlined: ´´ Most of the drivers of soil degradation are not projected to change favourably as it stands, so the remaining healthy soils will come even under more pressure in the future, leading to a further reduction in the provision of ecosystem services.´´ Our biocontrol solutions have a key role to play in the restoration of soil health and these policies like the soil one should also include support for the use of alternatives such as biocontrol ones. In fact, as well underlined in the IEEP report Exploring the benefits of biocontrol for sustainable agriculture (available online bit.ly/IEEPreport and here attached, page 21-22 focusing on benefits for Soil) ´´The positive interplay between biodiversity and soil health is an area where biocontrol can play a key role. The living organisms in the soil create a vital living ecosystem, which can, among other functions, filter potential pollutants and sustain healthy plant growth. The reviewed studies indicated benefits of biocontrol both in decreasing chemicals reaching the soil and creating favourable states for soil microbes…. When it comes to the pesticide levels in EU soil, biocontrol may be a crucial contributor to decrease levels of chemical contamination. Soil is subject to contamination from the overuse of chemical products, resulting in a harmful mixture of pesticide residues (Geissen et.al. 2021).´´ Furthermore, page 6 IEEP report, clearly stated: ´´ Drawing from the literature, biocontrol functions for plant protection and supports of biodiversity by significantly reducing the chemical pressure in the field. As a targeted measure, it has few adverse effects on non-targeted fauna and flora, thereby contributing to the maintenance and improvement of agricultural biodiversity. Soil quality and health equally benefit from decreasing harmful residues and contamination. The use of biocontrol can thereby contribute to a favourable status of microbial communities.´´
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

23 Feb 2022 · Reducing the use and risk of chemical pesticides

Meeting with Joanna Stawowy (Cabinet of Commissioner Janusz Wojciechowski), Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski)

16 Feb 2022 · Biocontrol and importance for sustainable agriculture

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

8 Dec 2021 · VTC Meeting: Revision of the Sustainable Use of pesticides Directive and biocontrols

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

7 Oct 2021 · Biopesticides

Response to Conversion to a Farm Sustainability Data Network (FSDN)

30 Jun 2021

IBMA, the International Biocontrol Manufacturers Association, welcomes this public consultation regarding a crucial matter for the transition to a future more sustainable agriculture using agroecological farming practices, in line with EU objectives. The Farm Accountancy Data Network (FADN) conversion into a Farm Sustainability Data Network (FSDN), with a view to collect farm level data addressing the above-mentioned targets and other sustainability indicators is an instrumental change to reach the CAP and EU Green Deal objectives. Since this initiative is clearly aiming at : ´´ add environmental and social dimensions to allow for a comprehensive assessment of the situation of farms and their performance´´ and ``reinforce the relevance of FADN/FSDN for policy-making, research, evaluation and policy analysis;´´ we would like to strongly suggest that more information, adhoc and detailed, are required in terms of alternative environmentally friendly input uptake use. Specifically measurement of the use of such as the products manufactured by our members the four types of bioprotection – biocontrol technologies which include : microbials, invertebrate biological control agents (macrobials), natural substances as well as semiochemicals. To measure this effectively an EU definition of biocontrol (bioprotection) is necessary (https://ibma-global.org/what-is-biocontrol) A definition of biocontrol allows separation of biocontrol from conventional PPPs which do not have the same environmental benefits (see IEEP report on Biocontrol benefits https://bit.ly/IEEPreport) such as protection of biodiversity and soil health. In fact, this would allow both monitoring a key variable on the environmental dimensions of farming and facilitating the use of farm-level data in farm advice (e.g.: for Farm Advisory Systems), benchmarking, training, research and innovation, hence providing tailored advisory services, two points that you pointed out as to be considered, which we deem crucial as IBMA in the context of the EU policies objectives. More generally, IBMA advocates an EU definition of IPM and bioprotection as well as the systematic monitoring and measurement of the adoption of IPM, using bioprotection/biocontrol as a relevant indicator of adoption as per our SUD position paper (here attached).
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Response to Agriculture - List of products and substances authorised in organic production

23 Apr 2021

IBMA, the International Biocontrol Manufacturers Association, established in 1995, represents the biocontrol industry, with over 220 member companies globally. (Biocontrol technologies are also known alternatives to control pests and diseases effectively in an environmental friendly way in agriculture, forestry, public spaces and gardens.) IBMA welcomes the improvements to the Organic Implementing Regulation in particular inclusion of additional natural substances, extension from pheromones to all semiochemicals and automatic inclusion of cell fragments. Please read our extensive comment of the EU Implementing Regulation authorising certain products and substances for use in organic production and the Annexes thereof within our uploaded document.
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Response to Statistics on Agricultural Input and Output

30 Mar 2021

IBMA, the International Biocontrol Manufacturers Association, welcomes this public consultation regarding a crucial matter for the transition to a future more sustainable agriculture using agroecological farming practices, as per the EU Strategies objectives. Farming statistics are instrumental since, as clearly mentioned in your proposal, ´´Agriculture also has an impact on the environment. This cannot be assessed without information on the input of nutrients and plant protection products.´´ This is why, besides the needed statistics on chemical inputs, we would like to strongly suggest that more information, adhoc and detailed, are required in terms of alternative sustainable input uptake such as the products manufactured by our members: bioprotection – biocontrol technologies which include microbials, invertebrate biological control agents (macrobials), natural substances as well as semiochemicals. First of all we need an EU level definition of biocontrol/bioprotection and then to integrate each of them in the statistics to have a better understanding of their use that enhance biodiversity and soil health, and fulfil the sustainability goals consumers demand. Therefore they are more than relevant for the Biodiversity and the Farm to Fork Strategies. With these statistics, we could also monitor their progress. More generally, IBMA advocates an EU definition of IPM and bioprotection as well as the systematic monitoring and measurement of the adoption of IPM, using bioprotection/biocontrol as a relevant indicator of adoption: In fact, as per IBMA SUD review position paper (available on our website www.ibma-global.org), measurement of IPM implementation requires relevant parameters. Bioprotection use is a relevant and measurable parameter once a bioprotection definition is established. More detailed appropriate measures are: • The percentage of EU and national plant protection use that is bioprotection - biocontrol technologies The current “all in one” PPP measurement system is not fit for purpose. Currently experts endeavour to quantify the use of microbial PPPs for statistics but expressing it in kg does not really allow for comparison with chemicals. A definition of bioprotection at EU level fixes interpretation and allows separating bioprotection from other PPPs, facilitating measuring them by counting methods appropriate to each technology. Measurement of chemical PPPs will allow monitoring of reduction and measurement of bioprotection will allow monitoring of growth in use as well as allowing use of appropriate units. • The percentage of crop uses covered by bioprotection Progress in terms of the number of uses (crop/pest/pathogen combinations) that are covered by bioprotection products can be measured (e.g. the French Ministry of Agriculture monitors this). • The number of hectares treated with bioprotection Hectares treated with active substance are recorded at farm level. These records can be linked to CAP eco-schemes and payments. • Recording the justification of management decisions taken within an IPM programme
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Response to Revision of EU marketing standards for agricultural products

10 Feb 2021

IBMA, the International Biocontrol Manufacturers Association, welcomes this feedback request on a roadmap regarding a crucial matter for the transition to a future more regenerative agriculture as per the EU Strategies. In particular the “Farm to Fork Strategy for a fair, healthy and environmentally-friendly food system”, includes a potential revision of marketing standards to provide for the uptake and supply of sustainable agricultural products. In fact, the need to stimulate sustainable food processing is essential and more appropriate marketing standards actually have to participate to that. Moreover, there is a growing expectation from consumers to know the origin of their foods and producers should be allowed to clearly communicate on their use of sustainable production method. Therefore, IBMA strongly support revised marketing standards that could, as per the roadmap, ´´set minimum requirements for how food is produced, packaged and stored’’ and ‘’could improve transparency for consumers by defining reserved terms that allow producers to clearly communicate on their use of sustainable production methods and exclude disloyal competition. In general, marketing standards could cover a wide range of environmental aspects (e.g. climate change, biodiversity, soil and water quality, food waste, emissions, and land use).’’ Among the sustainable production methods, bioprotection - biocontrol solutions are some of the main ones as alternatives to control pests and diseases effectively in an environmentally friendly way in agriculture. As matter of fact, bioprotection presents many benefits enhancing biodiversity and soil health, in particular when used within an agroecological IPM system. Therefore, in the marketing standards context as well as many others, bioprotection and its biocontrol technologies do need a definition at the EU level (as it already exists on the Member State level, in France) in order to ´´take into account sustainability considerations changing preferences of consumers as well as evolving technologies´´ such as ours. Furthermore, the Sustainable Use Directive (SUD) mandates the use of Integrated Pest Management (IPM) as a means to reduce the use and risk of pesticides, as well as to promote the use of non-chemical alternatives such as bioprotection. Marketing standards that represent adherence to a farm certification schemes can incentivise farmers to produce in a more sustainable way – including IPM, as per SUD requirements-. In fact, it would be both good from an environmental point of view and in order to inform consumers who will be able to recognize and support farmers evolving. Furthermore, IBMA supports the use of existing standards where they already exist, as the Global Standards organization covered by ISEAL Alliance, that covers a range of sustainable certification standards. In particular LEAF one is an example of a useful standard, being a more agriculture focused one, linking environment and farming. In addition, there are also existing national schemes such as the Haute Valeur Environnementale (HVE) one in France. These are two very good examples to be followed as they are two farm schemes that recognise the role of IPM in improved environmental outcomes. Finally IBMA is convinced that the use of this kind of standards (as the examples above) - truly supporting farmers in terms of making a profitable transition to more environmentally friendly farming practices - would seriously allow the revision to have a positive environmental impact by encouraging the production and consumption of more sustainable products.
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Response to Setting of nutrient profiles

2 Feb 2021

IBMA, the International Biocontrol Manufacturers Association, welcomes this public consultation regarding a crucial matter for the transition to regenerative agriculture as per the EU Strategies objectives. More specifically, in the context of the European Commission “Farm to Fork Strategy for a fair, healthy and environmentally-friendly food system” , the need to stimulate sustainable food processing and to further empower consumers is instrumental. Moreover, there is a growing demand from consumers to know the origin of their foods, including in particular how it is produced, using which methods or inputs. Therefore, since the initiative is expected to encourage a shift to more sustainable consumption patterns and help to reduce the food environmental impacts, IBMA strongly supports a food labelling that would include information about the agri-production methods – among others Biocontrol. In fact, Biocontrol solutions are alternatives to control pests and diseases effectively in an environmentally friendly way in agriculture, enhancing biodiversity and soil health, in particular when used within an agroecological IPM system. It is only by informing consumers clearly and transparently about the agri-production steps, that the label will respond to consumers demand to know and choose more sustainable and healthier food. In addition, informed consumers, becoming actors of the transition by their growing demand for more sustainable food, will also help the overall transition to a more sustainable resilient agriculture for the future.
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Response to Action plan for the development of EU organic production

23 Oct 2020

IBMA members develop effective biocontrol technologies with low impact on human health, the environment and biodiversity, allowing farmers to farm profitably. Bioprotection is fundamental to a resilient and regenerative agriculture. Bioprotection in horticulture is widespread. It is less common in arable. To achieve the transition of agriculture foreseen in EU Farm to Fork, the use of bioprotection needs to be facilitated particularly in arable crops for organic farming and for IPM programmes promoted by SUD. Many bioprotection products are in the regulatory system but market access is delayed due to (i) disproportionate regulation under EC 1107/2009 (ii) the time-consuming and complex process of positive listing for organic farming. To complement the organic regulation, a biological-specific PPP regulation is necessary to accelerate market access for these low-risk biological products so important in organic farming and part of the transition to agroecological farming for 2030.
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Response to Amending of the rules governing the renewal procedure for active substances in view of new “Transparency Regulation"

1 Oct 2020

1) IBMA welcomes the provisions to increase of transparency which can contribute to building trust. 2) Article 7 provides for the mandatory use of IUCLID for the submission of dossiers. We understand that harmonization with ECHA and accessibility of information guided EU Commission and EFSA in the choice. It must be noted that preparing dossiers in IUCLID format puts a new time and cost burden on the applicant. The additional workload, (estimated at least 300 hours for a microbial dossier and more than 800 hours to be expected for complex natural substances e.g. botanicals and semiochemicals, will result in significant costs and risks to dissuade bioprotection companies (SMEs) from applying for approval. Return on investment is key for industry and investors alike and without a timely and predictable date of market access, investment may not be viable. It is recognized that EFSA worked on adapting IUCLID for microbial substances but not withstanding this, bioprotection companies will need a transition period to familiarize with the software. Also, IUCLID still needs to be tested and adapted for complex active substances like botanicals and semiochemicals. 3) To avoid duplicating work and cost, it must be absolutely avoided that both IUCLID and CADDY have to be used in parallel for submission of one and the same dossiers. 4) Timelines for applicants to react on requests for information are generally too short (14 days), especially where a rationale must be developed. Holidays should be considered when setting deadlines. 5) IBMA welcomes the provision in article 13 (4) allowing the applicant to submit additional information to address critical issues or gaps identified in the EFSA draft conclusion. 6) It is very important to grant confidentiality for information on production and details on formulation. 7) IBMA appreciates the recommendation in article 16 to reduce fees for assessments of taxonomically similar microbial strains and structurally similar pheromones. 8) A schematic overview of the renewal process and timelines would be very helpful.
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Meeting with Stella Kyriakides (Commissioner)

16 Jun 2020 · VC Meeting on Farm to Fork Strategy

Meeting with Virginijus Sinkevičius (Commissioner) and

9 Jun 2020 · To discuss bioprotection and organic food production as an element of European Green Deal, possible actions towards the sustainable and restorative agriculture.

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

15 Apr 2020 · Green Deal

Response to Farm to Fork Strategy

10 Mar 2020

The Farm to Fork Strategy must include bioprotection to enable Europe’s shift to restorative agriculture. Bioprotection is a biological alternative to chemical crop protection with positive environmental, health and climate impacts for a sustainable food system. Bioprotection and biocontrol technologies, also described as bioprotectants or biologicals, are integral to holistic agricultural systems. Biologicals will help restore habitats, biodiversity and ecosystem resilience, enhance natural biological processes, and over time help rebuild ecosystems and restore soil biodiversity, supporting sustainable crop productivity and sustainable food systems. An enabling EU regulatory environment for biological pest control and agroecological integrated pest management requires scaling up application of biologicals. They are an effective and innovative alternative to chemical pesticides with lower health and environmental impacts, made from nature. 1. Regulatory certainty for bioprotection products: The EU must create an enabling regulatory environment so biological products can reach farmers faster. A new bioprotection specific regulation should cover microbials and other bioprotectants with a fast tracking approach such as provisional approvals for benign bioprotectants, while ensuring consumer and environmental safety. Capacity building for bioprotection assessment is needed within competent authorities at European and Member State levels, using the BTSF Better Training for Safer Food model. The REFIT of EU1107/2009 provides an opportunity to manage quick fixes (see attachment for how). 2. Support mechanism to enable farmers to transition to restorative systems: Farmers should receive financial incentives to adopt more ecological ways of farming. Changing to agroecology or IPM requires adaptation of farming systems to new norms based on observation and monitoring of soil, crops and animals, facilitated by digital techniques and new farmer skills, especially for the new generation. The process is gradual and occurs field by field. The farmer should be supported in making the transition. New networks led by farmers for farmers will facilitate farmer to farmer development and sharing of best practice. These new networks should be CAP funded. Farmer to farmer networks should benefit from experts, manufacturers and researchers to help build knowledge and provide state of the art solutions for immediate implementation. Farming is a business so any change to operations is a financial risk and potentially a social risk. The time needed to do each job or the sequencing of operations may change, which may cause stress and change the financials. Farming should promote agroecologically based IPM systems, such as organic, with biological control mechanisms that directly and indirectly help manage soil biodiversity and plant biodiversity. 3. Research fund to scale innovation in restorative arable systems: The EU should offer a multi-annual fund for field development into new ways of integrating biological approaches to pest and disease control and crop nutrition, to build resilience into agricultural cropping systems. Eventual demonstration of successful examples of biological based approaches should involve all members of the food value chain so that (i) practical implementation is effective and profitable for farmers (ii) wider benefits in food nutritional quality, biodiversity, water management and land use are recognised. Alignment across EU policies to boost regenerative agriculture: The SDG goals on food and nutrition require a resilient agricultural system, effective soil management and carbon sequestration through nutrient cycling. Investing in restorative agriculture and bioprotection technologies will benefit farmers, nature and biodiversity in Europe as well as support global climate and development ambition. - IBMA drives bioprotection innovation in Europe with 71 SMEs and 76 MicroEs among 165 members in 17 MS. -
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Response to EU 2030 Biodiversity Strategy

19 Jan 2020

IBMA – the International Biocontrol Manufacturers Association – welcomes the EU Biodiversity Strategy to 2030 initiative of the European Commission. Among other stakeholders, green agroindustry such as the biocontrol technologies one, should be at the heart of the next political and regulatory initiatives and measures when it comes to preserve and restore our ecosystems and biodiversity; knowing the negative impact of certain nowadays agriculture practices on them. In this context, quantified objectives and measures to promote the ´´sustainable use of agriculture´´ are essential. They should ensure that farmers have all the solutions and methods available in their toolbox, in order to work towards more sustainable agriculture, including IPM and organic ones. For the Organic agriculture in particular, there should be a timely addition onto the list of approved organic inputs as well as specific work on natural substances. More generally, in particular within IPM programs but not only, together with many other sustainable methods and tools, such as agronomic and mechanic ones already available, biocontrol technologies should be specifically considered and become available faster on the market for the farmers to use. This can be achieved by revised and proportionate regulation, farmers will be able to provide resilient food production, with minimal negative effects on the environment, in particular biodiversity and ecosystems. Moreover, this will allow farmers to protect and restore biodiversity and ecosystem services. These are essential steps of a more sustainable agriculture and therefore one of main work to be done within the European Green Deal.
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Meeting with Anne Bucher (Director-General Health and Food Safety)

28 Jun 2019 · Low-risk biological PPPs

Response to Establishment of Harmonised Risk Indicators to measure the reduction in risks and adverse impacts from pesticide use

21 Dec 2018

In principle, IBMA supports Commission’s initiative to establish EU-harmonised risk indicators in order to reduce risks and impacts of pesticide use on human health and the environment, in keeping with Directive 2009/128/EC. Harmonised risk indicators can be considered indeed as valuable tools to monitor progress made in risk reduction over defined time periods. The use of harmonised risk indicators can also be expected to encourage the development and introduction of integrated pest management and of alternative approaches or techniques such as biocontrol solutions in order to reduce dependency on the use of pesticides. IBMA welcomes Commission’s idea of categorising active substances in the endeavour of establishing harmonised risk indicators. In particular, providing for a specific approach to microorganisms by creating specific categories for them is a step in the right direction. In this context it should be considered that the calculation of quantities in kilograms does not make sense for microorganisms. Nevertheless, IBMA absolutely disagrees with Commission’s proposals for categories which are rather monolithic. Group 2 category D would include, undistinguished, semiochemicals e.g. pheromones and natural substances along with very diverse chemical substances which have completely different profiles and can lead to significantly different risks, particularly considering use patterns. The same is true for the intended category G for active substances not-listed in regulation (EU) No 540/2011. It would cover abandoned active substances with identified risk and hazard issues as well as new active substances with potentially low-risk profile. With regard to the proposed group 1 which would be created for low-risk active substances, we are concerned that a significant number of potentially low-risk substances, which are still in the ongoing renewal process for active substances (see: Draft Commission Notice concerning a list of potentially low-risk active substances approved for use in plant protection), would be ignored and thus not benefit from low hazard weightings if the proposed amendment came into force prior to the renewal for these substances. Article 53 derogation is unquestionably an important provision in regulation (EC) No 1107/2009 as it gives farmers access to tools allowing them to face emergency situations in plant protection but it is not always used as it should be. Reiterated use of the derogations for active substances which are not approved any more should not be encouraged where alternative, non-chemical solutions e. g. biocontrol products or beneficial organisms are available or where biocontrol substances are in an advanced stage of the EU approval process. Group G is far from a homogenous group when it comes to risk, and in consequence a more rational, science-based approach should be used when it comes to the hazard or risk weighting of active substances not yet approved. Furthermore, the number of authorisations granted under Article 53 must be seen as a qualitative indicator but does not permit reliably calculate and effectively quantify the risk.
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Response to Commission Implementing Regulation amending the criteria of low risk substances

1 Dec 2016

IBMA detailed comments have been compiled in an excel sheet. Since it is not possible to upload the excel, through this website, it has been sent by email to two relevant DG Sante officers.
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