CropLife Europe

The proposed Biotech Act recognises biotechnology as a strategic driver of EU competitiveness and economic security. CropLife Europe welcomes the provisions linked to the General Food Law that expand EFSA pre-submission advice to cover scientific aspects, fostering more effective dialogue and greater regulatory clarity for applicants.

CropLife Europe supports the objective of the European Biotech Act to strengthen the EUs global competitiveness in biotechnology. We believe the Act must address the major regulatory and perception barriers that limit the potential of agricultural biotechnology to contribute to EU food security, sustainability, and innovation.

CropLife Europe (CLE) welcomes the opportunity to provide feedback on the open EU COM public consultation on the Revision of the CLP and would like to draw attention to the following: - Multi-constituent substance and mixture classification rules: Multi-constituent substances shall be classified following the same classification, labelling, and packaging rules as mixtures.

CropLife Europe (CLE) welcomes the opportunity to provide feedback and makes the following comments: - New Hazard Classes Europe has been a leading player in the development of the GHS, bringing numerous benefits in terms of international harmonisation of safety standards and facilitation of trade. The Commission’s plan sends a clear message that the EU no longer believes in international cooperation.

Biotechnology is a strategic asset for EU competitiveness and economic security. The limited scope of Biotech Act I was a missed opportunity, and the limited initiatives across different packages (feed additives in Food and Feed Safety Omnibus, General Food Law in Biotech Act I, separate proposal on GMMs), risk only minor tweaks which fail to address the systemic regulatory barriers that constrain agricultural…

CropLife Europe welcomes the Commissions proposal on New Genomic Techniques (NGTs) which has the potential to enable all actors, including SMEs and public researchers, to bring more resilient and sustainable plants to the EU market. This supports investment in plant breeding innovation in the EU and enhances competitiveness and sustainability of European agriculture.

Category 2 NGT plants encompass diverse crop-trait combinations that do not inherently pose greater risks than Category 1 NGTs or conventionally bred plants (EFSA opinion of 11/07/2024). As acknowledged in Recital 37, their assessment requires a flexible, case-by-case, risk proportionate approach driven by clearly defined risk hypotheses.

CropLife Europe welcomes the Commissions Call for Evidence on the delegated act under Regulation (EU) 2026/1388. The success of the new framework for plants obtained by certain new genomic techniques will depend on the delegated regulation that provides legal certainty, is practical, proportionate, and supportive of innovation.

The Commissions ambition to strengthen the conditions for innovation within the EU must recognise agriculture as a strategic sector. Representing 25 companies and 32 national associations, our members develop pesticides, biopesticides, digital and precision agriculture tools and innovative crop traits using biotechnology.

CropLife Europe welcomes the objectives of the Data Act and believes this is a fundamental aspect for the long term success of digital and precision agriculture in Europe. We therefore greatly appreciate the opportunity to participate in this public consultation and look forward to further discussing with the EU Institutions and relevant stakeholders. Please find attached our detailed feedback on the proposal.

CLE welcomes the proposal for a Nature Restoration Regulation. The diversity of ecosystems, species and crop varieties is inherently valuable and needs to be protected. Farm performance benefits in many ways from biodiversity-based ecosystem services. The seeds farmers sow, pollination, the cycling of nutrients and water, and the effective control of pests and diseases are all connected to biodiversity.

CropLife Europe (CLE) welcomes the opportunity to provide feedback and wishes to make the following comments: Part A REACH is the most advanced knowledge base globally but there are still gaps in knowledge on many substances: A retrospective review by the US Environmental Protection Agency in 2013 (“A retrospective analysis of immunotoxicity studies”, February 2013, Health Effects Division, OPP, US EPA), was…

PUB/24/KH/37715 CropLife Europe key comments on legislative proposals linked to One Substance One Assessment CropLife Europe welcomes the opportunity to provide comment on the initiatives in the public consultation on “Chemical Safety – better access to chemicals data for safety assessments” and “Chemicals – making best use of EU agencies to streamline scientific assessments” Both comments on the draft regulation…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CropLife Europe (CLE) raises the following comments with regards to the Call for Evidence on Chemical safety – better access to chemicals data for safety assessments. Summary • The crop protection sector is typically a downstream user with respect to REACH, and is subject to more specific sectoral legislation.

ECPA understands that the proposed revision of EU access to justice rules is necessary in order to address the findings of the Aarhus Convention Compliance Committee. Potential impact on EU administrative and judicial systems ECPA believes that the proposed changes could expose EU systems to numerous objections, some of which have potential to be vexatious, with potential to affect the smooth functioning of…

•CropLife Europe welcomes the European Commission initiative on simplification and digitalisation of chemical labels and is pleased to share its initial thoughts. •Labelling requirements for Crop Protection products in Europe are defined in two regulations: the Classification, Labelling and Packaging Regulation (EC) No 1272/2008 and the Plant Protection Product Regulation (EC) No 1107/2009 which results in complex…

CropLife Europe is pleased to share its views on the proposal on the unitary Supplementary Protection Certificates (SPC) for Plant Protection Products (PPPs). Its key messages include: (i) The system to grant a unitary SPC for PPPs needs to align with the current procedures for PPP marketing authorisations; (ii) Pre-grant opposition proceedings create unnecessary delays; (iii) The unitary SPC should be adopted as…

Dear Sir/Madam, Supplementary Protection Certificates are an integral part of the process for protecting innovation in plant protection products. We therefore greatly appreciate the opportunity to participate in the call for evidence on a unitary SPC and/or single procedure for granting national SPCs. Please find attached CropLife Europe's feedback to this call for evidence.

CropLife Europe has been closely involved in the years-long stakeholder process to prepare the proposal, and accepts the approach followed for the majority of the pesticide quality standards that have been proposed. CropLife Europe supports the need to review the Directives to maintain consistency and alignment across water policy legislation.

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.

The European Crop Protection Association welcomes the opportunity to provide feedback on the Roadmap – “Implementation of the Aarhus Convention by the European Union (EU) in the area of access to justice in environmental matters”. We look forward to being able to provide input during the public consultation in second term of 2018.

CropLife Europe (CLE) represents sustainable crop protection solutions. CLE acknowledge the critical role EFSA plays in the assessment of regulated products. In general terms, the implementation of the Transparency Regulation has considerably increased the administrative burden and complexity of submissions to EFSA, and the new system and processes resulted in longer timelines for dossier preparation for the…

CropLife Europe (CLE) welcomes the opportunity to comment on the proposed revision of the data requirements for active substances used in plant protection products. CLE supports the Commissions aim of strengthening scientific quality and coherence with other EU legislation but considers that several provisions would benefit from clarification to ensure feasibility, proportionality, and global alignment.

CropLife Europe supports the EC's goal to update the rules on agricultural statistics including for inputs such as PPPs. Adequate data will contribute to achieving the aspirational targets set out in the F2F and Biodiversity Strategies.

ECPA supports the Commission’s goal to update the rules on agricultural statistics including for inputs such as pesticides. Having adequate data will contribute to achieving the goals of the Commission’s Green Deal and Farm 2 Fork Strategies. We support these goals and believe that a better indication of current pesticide usage will be essential for science based decision making.

Please see additional file attached with detailed comments. • ECPA emphasizes the critical importance that the relevant cut-off concentrations for those substances listed in Annex III also be based on the REACH / CLP regulatory cut-off concentrations of 0.1 % w/w in the final mixture.

ECPA supports the recast of the POPs regulation, however clarity on the process of how ECHA will be involved in the process of evaluating an potential POP candidate substance still needs to be clarified, whether one of the existing ECHA scientific committees will have oversight and whether a public consultation be agreed to enable stakeholder the opportunity to comment on any POP proposal.