SBM COMPANY
SBM
SBM company is a manufacturer of plant protection products for the agricultural and garden markets.
ID: 598151429427-94
Lobbying Activity
Response to Update of labelling obligations for plant protection products
31 Jan 2025
We strongly align with the positions defended by CropLife Europe, (see attached file). In addition, to the points raised by CropLife, Europe we wish to highlight an additional point in the proposed draft Commission Regulation on labelling requirements for plant protection products, repealing Reg. (EC) No 547/2011: For us, the main objective of the label of a plant protection product is to bring clear and unambiguous information to the user on the conditions of use, any potential hazards and risks, and how they should handle the plant protection product. The colour scheme proposed in the legal text, in our opinion, fails to provide clear and honest information that is helpful to the end user (consumer): - The colour scheme is titled Plant Protection Product but only presents information on the active substance to the consumer, as point (15) mentions, on only the status of the most hazardous active substance on the preparation. - If the main objective of this colour scheme is ONLY to display information on the most hazardous active substance in the product, the categories used are inconsistent, being a mix between type of active substance, status of the active substance under regulation 1107/2009 and type of product: categories A and B are a mix of status of plant protection product and status of the active substance, category C is mainly about the type of active substance (micro-organism), type D and E are strictly on the status of the active substance under regulation 1107/2009. - The status of an active substance under regulation 1107/2009 should not the only factor to be taken into consideration when creating the classification of the product as it can lead to vastly different classification for a same product category, for example A product with no toxicological classification with a non-low-risk substance will be class as D, whereas a product classified H317 (May cause an allergic skin reaction) containing micro-organism will be in class C. In addition, a product with a low-risk substance but classified will be category B but a product with a standard active substance without a classification will be category D. For a consumer to understand this scheme it should be logical and help them follow all relevant mitigation methods. - Following the precedent points, without knowledge of the regulation 1107/2009 and this proposed draft, the colour scheme is not understandable for almost all consumers and can lead to real misunderstanding of the real risks they face and what they need to do in order to mitigate them. This is contrary to the purpose goal of the colour scheme.
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