To the Members of the ENVI Committee
European Parliament
Sent via email
Brussels, 10 October 2017
Ref.nr.: 17.37820AB
Dear Madam/Sir,
On 15 February 2017, the European Parliament, as the only directly elected representation of the
European Union, virtually unanimously voted for a Resolution that urges the European Commission
to limitedly adapt Regulation (EC) No 1107/2009 so as to fasten and financially smoothen the access
to the European market of biological low-risk plant protection products (PPPs). Of course, low-risk
means that safety will in no way be compromised. The Resolution is all the more important because
agricultural innovation in the European Union is mostly in the hands of advanced small and medium
sized enterprises (SMEs). It is a cornerstone of the EU to strongly promote the success of SMEs both
as i o ators a d as e ployers of arou d % of Europe’s orkfor e.
At this very moment, 77 traditional chemical plant protection active substances categorised as
candidates for substitution are expected to be substituted when appropriate active substances
become available. But currently there are no alternatives available. Of the 493 active substances on
the market, only 9 are low-risk biological. After subsequent initial agreements betwee
the far ers’
association COPA-COGECA and the biocontrol PPPs manufacturers in IBMA at the one hand, and EU
Commissioner Vytenis Andriukaitis at the other hand, the European Commission gradually shifted its
position from an immediate action to a full review of this Regulation. During a meeting in the
Europea Parlia e t o Ju e
, the Co
issio er suggested that the Parlia e t’s Resolutio
to adapt Regulation 1107/2009 before the end of 2018 could be realised but within REFIT. If the
timeline were possible, it
ould fit ell, as REFIT’s for al defi itio i ludes a refere e to the
unburdening of SMEs that cannot sit out lengthy and costly procedures.
On Thursday, 5 October 2017, I had the privilege to chair an informal dinner with the
Phytopharmaceuticals - Legislation section of SCoPAFF (Standing Committee on Plants, Animals, Food
and Feed). After impressive presentations by Mr Pavel Poc (Vice-Chair of ENVI, please see video
here)
and David Cary (Executive Director of IBMA, please see Attachment 1), the Head of the Pesticides
Unit of DG SANTE stated
We share the opi io that the a aila ility of iologi al lo
-risk pesticides
should be increased. Nevertheless, I find your criticism regarding the regulatory process to be unfair.
We cannot act outside it. It is the normal process: we evaluate the Regulation, we draw conclusions
and, if necessary, we make a legislative proposal. In my 29-year experience with the Commission,
there is never a quick and easy fix. It always takes a lot of time, even for a small fix. [...] When it
o es to a legislati e proposal, e ha e to follo rules a d pro edures. I respo se, a Belgia
diplomat remarked that only political will determines the length of any procedure. From a purely
technical point of view, it can be established for a fact that Commissioner Vytenis Andriukaitis has
the power to set priorities and adapt a Regulation to the extent that the priority that Regulation
1107/2009 already gives to the use of low-risk PPPs is further elaborated mainly in a Communication
that simply explains how the stated priority must be realised in practice. For some reason, the
authors of 1107/2009 did not include this in the Regulation.