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SERRPA

SERRPA is a consultancy specialized in regulatory and public affairs.

Lobbying Activity

Response to Revision of Regulation (EC) 648/2004 on Detergents

10 Jul 2023

AMAEE Strongly welcomes and support the inclusion of microbial-based products under the scope of the detergent Regulation, and fully supports that no pre-market authorisation would be required Appreciate the lack of usual chemical references for this range of ingredients Considers that the criteria proposed through the Annex II of the proposal are too restrictive, overdo or wrongly shape some aspects of the microbial detergents Offers support for the establishment of general requirements, to be associated to an implementation tool (Industry Code of practice) Proposes the attached preliminary proposal for modifying the Annex II (AMAEE is a cooperation initiative between European companies that are engaged in the production of microorganisms at industrial scale for other purposes than nutritional applications. Its membership is open to all sizes of operators whether they are involved in the production of the microorganisms or in their formulation for specific applications, including detergent applications. The aim of this cooperation is to support the development and recognition of these various applications. It is represented by SERRPA)
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Response to Feed additives - revision of EU rules

22 Jan 2021

SERRPA welcomes the Inception Impact Assessment on the revision of Regulation 1831/2003 and the opportunity to comment on it. This document is obviously based on a throughout and well-structured reflection, resulting in a very good analysis of various strengths and weaknesses of the current legislation, and providing sensible policy orientations towards the necessary evolution of this framework. In order to support this revision process, we would like to raise additional reflections and options on three topics: the efficacy part of the authorisation process, the framing of the assessment guidelines and the fate of some fermentation co-products (see attached document).
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Response to Fitness Check of the EU legislation on animal welfare

28 Jul 2020

• Over the last 20 years, the EU legislation has brought significant improvements to the animal welfare of animals grown in Europe, placing the EU at the forefront of practices. • So far, these improvements were mainly driven through the setting of minimum criteria (general and species-specific for some) that address the most fundamental aspects of animal well-being • Building on this basis, there is an opportunity for the next legislative cycle to bring additional dimension(s) on topics not addressed yet, both for animal kept for food (or other) productions and for companion animals • In this respect, it is worth looking further at housing conditions, besides the now classical aspects like space, light, ventilation, temperature, etc. In particular, the microbiological environment of the bedding and housing bears potentially important welfare dimensions. Among other direct welfare aspects, this has bridges with the Farm to Fork strategy: reducing the need for medication, preservation of biodiversity, having a neutral or positive environment impact, limitations- of antimicrobial resistance issues… • There are existing and innovative practices that can support this, for instance microbial-based solutions used in animal surrounding. Their impacts are ranging over multiple aspects, including the general sanitary status of the animal environment, reduction of odours, management of litter/organic matter, quality of bedding, etc. • It is suggested that the animal welfare legislation should have active consideration for the use of products and/or practices that bring this kind of value. Some of these solutions might require a specific animal welfare market access. • The existing approach through regulatory-fixed parameters might not be suitable to this matter and an additional mechanism should be added. As an adds on to the acquis, it is suggested that the new legislative framework should explore the possibility to set a BAT-system (Best Available Techniques) that would allow to introduce more elaborated and flexible solutions than the basic fixed-criteria approach allows. This might allow to reconcile high ambitions with pragmatism and necessary flexibility. The interest of such an approach would likely go beyond the only case of microbiological considerations. The present comments are provided by SERRPA on behalf of a consortium of companies active in the development and supply of microbial solutions for use in animal husbandry for other purpose than nutrition.
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Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

The Roadmap on planned update of the Bioeconomy strategy, puts the right highlight on the need to refocus the bioeconomy actions along current EU political priorities, in particular the SDGs, the action plan for circular economy and the renewed industrial policy. Its announced targets, to drive a system-wide approach addressing trade-off between sectors, strengthening circularity and sustainability and delivering jobs and growth fit to this agenda and open important perspectives for EU industrial operators if they are properly spelled out to deliver concrete moves Bioeconomy is an extremely wide concept and it seems important for the strategy, and even more for the plan, to be inclusive of its very diverse branches. Recognising the key position that industrial fermentation has taken in the EU economy, and is called to take further if provided with a positive development environment, we suggest that this segment should get some specific attention in this strategy and action plan. Along the listed targets to strengthen and upscale the bio-based sector, mobilise investments to scale up and roll out existing and new technologies, and support the creation of market for more sustainable/circular products through existing and emerging regulatory framework, there is an opportunity to work on the regulatory and political conditions surrounding the industrial fermentation industry. This encompasses e.g. the access to its raw materials (as highlighted in the contribution from EFG), sustainable valuation of its residual biomass, tailoring operations’ regulatory conditions to global competition and actual business dynamic, supporting attractive and predictable investment conditions, etc. We hope this plan can contribute to make the EU a fermentation-friendly area, supporting the global competitive position of its industry.
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