IBMA Press Release - 11th July 2016

IBMA Official response to the Implementation Plan on Acceleration of Sustainable Plant Protection as proposed by the Netherlands Ministry of Economic Affairs: Priority for low-risk plant protection products,as indicated in the Preamble (17) of Regulation (EC) 1107/2009, means prioritizing now.

IBMA, International Biocontrol Manufacturers’ Association, warmly welcomes the Netherlands’ initiative to address Sustainable Plant Protection during their recent EU Presidency. Furthermore, IBMA welcomes that they established a group representing 19 Member States, EFSA and EU COM and that they prioritised two areas: making low-risk Plant Protection Products more available to European farmers, and to encourage the practice of Integrated Pest Management (IPM). IBMA also congratulates both the Netherlands and the EU Sustainable Plant Protection Expert Group for their very effective and focused work over the last 6 months. A lot has been achieved and by engaging other Member States a broad commitment to achieving the agreed common goals has been attained.

The Implementation Plan - that you may read here - is broadly supportive of IBMA’s calls for both low-risk active substances within Reg. 1107/2009 and plant protection products and implementation of IPM as called for under the Sustainable Use of Pesticides Directive (SUPD). Many of the 40 recommendations call for best practice from all parties. IBMA welcomes Member States implementing such measures and will certainly work with its members to ensure well prepared dossiers are being submitted.

IBMA particularly welcome commitment in the areas of:

  1. Interest in inferring low-risk status on existing approved active substances
  2. Granting extended renewals or non-limited approvals of l-r active substances
  3. Proposing fast-track procedures  
  4. Granting provisional approvals
  5. Consideration of reduced fees for low-risk active substances and products
  6. Proposing zonal or 1 zone applications with a single fee
  7. Reduced efficacy requirements for low-risk PPPs using the proposed EPPO guidance
  8. Exclusion of attractants and repellents including semiochemicals from regulation
  9. Exclusion of substances with a physical mode of action from regulation
  10. Promotion of using dedicated expertise for handling and evaluating low-risk as and PPP applications
  11. Promotion of non-opening of low-risk as dossiers during authorisation of low-risk PPPs
  12. Consideration of label claims for low-risk status on low-risk PPPs
  13. IPM measures

However, based on the practical requirements of farmers, IBMA do have some issues and do not welcome and have concerns that:

  1. Provisional authorisation may be on a voluntary basis, and as experience has shown this will not remove uncertainty and will cause issues with harmonisation particularly at zonal level
  2. The proposed existing approved active substances low-risk listing may carry no official status as this limits any value of such listing
  3. Proposed changes are in the most part to be enacted during a lengthy REFIT programme commencing this year but not implemented for several years, and supports these initiatives being implemented on a more timely basis
  4. IBMA further question the need and impact of a review of 396/2005 as most substances expected to be granted low-risk status (biocontrol products in particular) will not be required to have MRLs set

In summary, IBMA congratulate the Netherlands Presidency on their achievements with low-risk Plant Protection Products and IPM, and the unanimous endorsement of the plan by the AGRIFISH Council. The fact that the EU Sustainable Plant Protection Expert Group will be maintained during the Slovakian Presidency should facilitate this. IBMA reiterates that the legislation needs immediate repair in order to have the required low-risk products accessing the market. No more time should be wasted: the changes foreseen by the Netherlands Presidency, the EU Sustainable Agriculture Group, IBMA and other stakeholders should be achieved as soon as possible.

Contact: David Cary, 0044 (0) 7775514840, david.cary@ibma-global.org

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