ViNordic - Veterinary Industry Nordic
ViNordic
ViNordic – Veterinary industry Nordic – is the voice of the animal medicines industry in the Nordics.
ID: 908370536639-39
Lobbying Activity
Response to Organics production rules
25 Nov 2019
The veterinary industry in Denmark and Sweden is concerned about the implementing act on organic production rules and its MRL withdrawal periods for treatments of livestock and poultry with “chemically synthesised allopathic veterinary medicinal products”. Our concerns are:
1. Uncertainty regarding definition of veterinary medicinal products,
2. Interpretation re. vaccines,
3. Withdrawal-period for parasiticides
4. MRL / withdrawal period
1. UNCERTAINTY REGARDING DEFINITION OF VETERINARY MEDICINAL PRODUCTS
We wish for the European Commission to EITHER refer to the adopted definition of a veterinary medicine as per the New Veterinary Regulation OR clearly define “Chemically synthesized allopathic veterinary medicinal products”.
The New Veterinary Regulation defines a veterinary medicinal product as any substance or combination of substances which fullfils at least one of the following conditions:
• It is presented as having properties for treating or preventing disease in animals
• Its purpose is to be used in, or administered to, animals with a view to restoring, correcting, or modifying physiological functions by exerting a pharmacological, immunological or metabolic action
• Its purpose is to be used in animals with a view to make a medical diagnosis
• Its purpose is to be used for euthanasia of animals and a substance (any matter of the following origin: human – animal – vegetable – chemical)
2. INTERPRETATION RE. VACCINES
We ask the European Commission to please clarify that vaccines are not affected by the double withdrawal period or the 48-hour rule.
It is our assessment that the use of vaccines is not affected by the double withdrawal period or the 48-hour rule as Annex II Part 2 of Regulation 2018/848 differentiates between immunological veterinary medicinal product (article 1.5.1.2.) and a chemically synthesized allopathic veterinary medicinal product (article 1.5.1.3.).
3. PARASITICIDES
We suggest the European Commission to give the withdrawal period for parasiticides referred to in Annex II – Part II Livestock – Part 1.5 Health Care – article 1.5.2.5 the same special attention as in article 1.5.2.4 and to not apply the 48-hour withdrawal period.
Article 1.5.2.4 allows for vaccines, treatments for parasites, and compulsory eradication schemes to be excluded. These have been recognised as particularly sensitive and given special attention. As there are no precautionary biosafety measures that can be applied to avoid using parasiticides and that as a result, animals may need to be kept indoors to reduce the chances of getting infected, parasiticides should continue to benefit from a zero-day withdrawal period (when they so have).
4. MRL / withdrawal period
We implore the European Commission to ensure that regulation of use of medicinal products is based on science only.
Food from animal origin is safe and it is irrational to risk making consumers believe that further prolonged withdrawal periods for organic food products will improve consumer safety. Arbitrary and scientifically unjustified extended withdrawal periods will moreover lead to unnecessary waste of unmarketable milk and eggs. This contradicts the prudent use of limited resources on our planet and also entails a risk that farmers cannot treat animals (e.g. parasite infestation) for economic reasons, jeopardizing animal health and wellbeing.
The current regulatory principles of establishing MRL’s and setting withdrawal periods for food products are science based. Indeed, the built-in safety factors related to determination of the MRLs in the different food commodities of treated animals, the extreme high amount of animal food products considered for daily consumption in the EU food basket, and the very low percentage of residue findings in animal products together secure a very large margin for the safety of the consumer.
We trust the European Commission has the opportunity to address the above concerns.
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