EU consultation
38 submissions from 38 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 144 submissions on this file. Shown here: the 38 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
30 submissions from industry — companies and their trade associations — against 5 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 6 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 3 Feb 2025 — it ran from 6 Jan 2025.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
38 positions · showing 25
· · filed 3 Feb 2025 · source
Certis Biologicals, a division of Certis USA L.L.C, supports the view of the Biocontrol Industry Association (IBMA) regarding the revision of the Labeling Regulation for PPPs. In particularly, being the company with the highest number of Microorganisms strains registered as Active Substances under the Reg.
· · filed 3 Feb 2025 · source
CLE - Key General Comment 1 Whereas (18), Article 8 (2) Article 9 Article 10 (new article specifically on digital label) However the type of machine-readable digital coding has to specified, which exact type of specified digital code has to be used in uniform way across EU members states to provide uniformity, harmonization, transparence, traceability, synchronization and similar EU wide effects.
As a “startup” company dedicated to biocontrol innovation, we support the positions explained and argued by IBMA International regarding Regulation EU 547/2011. Thierry Merckling – Head of Regulatory Affairs and Partnerships.
Filed in French · English published by the European Commission
· · filed 3 Feb 2025 · source
LUPJ (Union of Enterprises for the Protection of Gardens and Public Spaces) brings together companies that manufacture and market products intended for amateur gardeners or professionals in public spaces on the French market JEVI (Jardins, Espaces Verts, Infrastructures), including plant protection products (PPPs).
Filed in French · English published by the European Commission
The Pesticide Action Network Europe (PAN Europe) welcomes the European Commission's draft Regulation aimed at updating labelling obligations for plant protection products. This update is essential to ensure consistency in plant protection product labelling across Member States and enhancing risk communication for end users.
· · filed 3 Feb 2025 · source
FNSEA thanked the European Commission for the opportunity to give its opinion on this draft amendment to the Regulation on the labelling of plant protection products. In the preamble, FNSEA wishes to reiterate its concerns about the continuous withdrawal of key active substances, which reduces the availability of effective solutions for farmers and places certain sectors in low technical situations.
Filed in French · English published by the European Commission
Generations Futures welcomes the European Commission’s proposal to harmonise and update the labelling requirements for plant protection products (PPPs), and considers that greater transparency and information is essential to protect public health and the environment. We support some EC proposals for these new labels, but would like to see even more progress on some points.
Filed in French · English published by the European Commission
Evergreen Garden Care would like to make the following comments on the proposed draft for repealing Commission Regulation (EU) No 547/2011 of 8 June 2011 implementing Regulation (EC) No 1107/2009 of the European Parliament and of the Council with regards to the labelling requirements for plant protection products (please refer to the attached statement).
Associazione Filiera Italia is the Italian organization that unites the entire Italian agri-food supply chain - from agricultural production, with the Italian processing industry to final distribution, with the aim of representing through a single voice, at both national and international level, the integrated and sustainable model of Italian agri-food system.
The German Social Security Fund (DSV) welcomes in principle the European Commission’s initiative to further harmonise labelling requirements for plant protection products and to improve communication in the field of risk prevention and reduction to end-users of these products.
Filed in German · English published by the European Commission
Coldiretti, the largest farmers' organization in Italy and among the largest in Europe with more than 1.5 million members, welcomes the opportunity to present its comments on the draft Regulation on the Labeling of Plant Protection Products, which amends the Commission Regulation (EU) No.
The Finnish Crop Protection Association and The Central Union of Agricultural Producers and Forest Owners of Finland want to draw The Commission's attention to risks related to modifying the regulation text on application dose rates. Adding a minimum dose rate as a condition of use could hinder farmers from implementing good agricultural practices such as integrated pest management.
· · filed 3 Feb 2025 · source
1. Date of application too restrictive (1 January 2026) Unsuitable timelines: The date has been brought into line with Regulation (EC) No 2023/564 on the electronic register of farmers, but the revision of Regulation (EC) No 547/2011 is still under discussion, making this deadline unrealistic. Impacts on the supply chain: Industry and farmers should quickly adapt to significant label changes (e.g.
Filed in Italian · English published by the European Commission
· · filed 3 Feb 2025 · source
Copa and Cogeca appreciate the opportunity to provide feedback on the proposed Commission Regulation repealing Commission Regulation (EU) No 547/2011. We acknowledge the Commissions intent to update labelling provisions in line with recent developments in plant protection product (PPP) use, risk assessment, and the Farm to Fork strategy.
Annex V, clause 2. SPo 3: Not all fumigants are activated by ignition. For instance, in the case of aluminium phosphide, the reaction begins when the product is exposed to ambient moisture. Therefore, we propose to substitute ignit-ing by a more general term, like applying or activating.
· · filed 3 Feb 2025 · source
The Federal Association of German Plant Breeders (BDP) brings together the interests of its around 130 members with more than 5500 employees from breeding and seed trading. It is committed to optimising the framework conditions for breeding and seed management, as well as to promoting plant research and new technologies.
Filed in German · English published by the European Commission
Artemis, the association for producers and distributors of plant protection products of natural origin in the Netherlands, appreciates the opportunity to provide feedback on the draft regulation on labelling requirements for plant protection products for better interpretation and harmonisation. However, we believe that this draft regulation is not suitable for the application of organic plant protection products.
Regarding the proposed regulation to revise Regulation (EU) n° 547/2011, Alliance Biocontrôle welcomes the Commission's initiative to harmonize the various provisions within the Member States but would like to express some reservations or requests for clarification on the provisions listed below: - clarification of label update deadlines between physical and digital labels, - deletion of the colour scheme, -…
1. ASCENZA understand that the Digital labelling (DL) can be connected to the authorization, i.e., within the authorization the DL should be accessible on Ministries web sites. This would allow short connection between the registration conditions approved or revised, avoiding wrong versions available and most important gross mistakes.
· · filed 31 Jan 2025 · source
Andermatt France, a French distributor of Biocontrol products, IBMA Global’s position and its recommendations regarding the labeling requirements for PPPs. These requirements must be adapted and specifically appropriate for Biocontrol products. Andermatt France, a French distributor of biocontrol products, supported the position of IBMA as a whole and its recommendations on PPP labelling requirements.
Filed in French · English published by the European Commission
ANOVE fully supports the comments on this consultation submitted by Euroseeds (labelling requirements for PPPs, repealing Regulation (EC) No 547/2011) as set out in the attached document. As a general comment, it should be noted that seeds as plant reproductive material are already a product regulated by European legislation on the marketing of this material.
Filed in Spanish · English published by the European Commission
Please find attached the contribution of the Union Française des Seminers (UFS). LUFS is the professional organisation representing around a hundred seed companies established in 62 French departments. Their activities include plant improvement, production and marketing of seeds for agriculture, gardens and landscapes.
Filed in French · English published by the European Commission
IBMA Belgium supports the Commission's initiative to update, improve, and harmonize the labelling of plant protection products. However, we believe that this draft regulation introduces additional complexities for biocontrol products rather than simplifying labelling for both users and manufacturers. Therefore, IBMA Belgium fully aligns with the feedback provided by IBMA Global.
As a provider of biocontrol solutions to the European market, Rovensa Next supports any initiative aimed at improving and harmonizing communication with users of our products. However, the proposed draft Commission Regulation on labelling requirements for plant protection products, repealing Reg. (EC) No 547/2011, does not adequately consider the unique characteristics of biocontrol solutions.
On behalf of BioFirst Group, we appreciate the opportunity to provide feedback on the draft regulation concerning labelling requirements for Plant Protection Products. After reviewing the proposed changes, we are concerned that they introduce additional complexities rather than simplifying labelling for users and manufacturers.
· · filed 31 Jan 2025 · source
The transitional measure as it is presented in article 14 of the proposed draft Commission Regulation on labelling requirements for plant protection products, repealing Reg. (EC) No 547/2011, as we understand it, will make this new regulation mandatory only for products that receive their authorization or their trade permit after the application date of 1 January 2026.
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.
For the following reasons, the anticipated change to biocontrol solutions will be slowed down with this new label regulation: - The updated label regulation does not include information if a product is suitable for organic farming or not - The proposed graphic scheme with the letters A-E leads to, that most biocontrol solutions are in category C and D, which will discourage the use of these products.
ECCA hereby provides his comments to the draft Commission Regulation on the labelling of Plant Protection Products, repealing Regulation 547/2011. While ECCA welcomes this proposal, it contains some elements that raise serious concerns. ECCA comments are in the attached document.
We broadly support the concept of a digital label (not electronic but digital) and, in particular, the application of this requirement to newly authorised plant protection products, but we believe that a reasonable transitional period should be granted for the implementation of this requirement. Article 4 and Annex VI of the draft Regulation contain a requirement for products to be labelled with a colour scheme.
Filed in Lithuanian · English published by the European Commission
Koppert comments on the draft proposal repealing (EU) No 547/2011 We welcome the proposal to update the labelling requirements for plant protection products. Koppert believes that plant protection product labels should be clear to assure the safe and effective use of the products, within the scope of the authorisations obtained after evaluation of the risk assessment.
The Industrieverband Agrar e.V. represents the interests of producers of inputs for sustainable crop production in Germany. The 47 member companies are active in plant protection, plant nutrition, plant breeding, biostimulants and pest control.
Filed in German · English published by the European Commission
· · filed 27 Jan 2025 · source
On behalf of, Vice president of the Input Agri Romania Association In order to avoid the relabeling of a plant protection product, in the case of expanding the scope, which implies additional administrative and financial activities for the holder of the authorization (which can later be found in the price of the product), for this situation we propose 2 options, leaving it to the discretion of the legislator to…
CropLife Europe would like to comment on the proposed draft Commission Regulation on labelling requirements for plant protection products, repealing Reg. (EC) No 547/2011 - We refer to the compiled comments on both the core text as on the annexes in the attached file.
· · filed 15 Jan 2025 · source
Annex V (4) states "SPe 2: Do not apply if the wind speed is higher than (wind speed to be specified)". Units of the wind speed to be commonly used should be indicated. Annex V (7.2) states: - "Sss 4: To protect (environmental compartment, group of organisms or species to be specified), the sowing equipment has to ensure a high level of soil coverage and the reduction to a minimum of airborne dust emission during…
· · filed 15 Jan 2025 · source
Annex I (r) states that the use before data of a PPP containing microorganisms depends (only) on efficacy/safety studies. However, physical-chemical properties (Section 1 of the OECD-format) may also have influence on storage stability / the use before date.
From Association Européenne des indépendants du Conseil en Agriculture , aeica.eu 1) About : annexe 1 "Dose rate including the minimum and maximum rate per application and the maximum number of applications ...." We ask for : The number of applications authorized on an annual crop per campaign still does not take into account ultralocalized treatment devices, even if the plot has been treated only partially several…
Comment to Article 10: We recommend the information for the digital label should also be accessible via API. Benefits: 1) Farm Management Software (FMS) can access the information and use it to assist the farmer in compliant use of the products, help mix spray tanks correctly, give warnings prior to violation of label requirements, and so on.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.