Stockholm University

Speaking as a filmmaker and as an associate professor and researcher on new media, my take is that generative AI is the most important shift in the creative field in at least a generation. The European film industry is struggling and shift toward digitalization didn't really liberate creativs in the way that it promised in the 1990's.

Stockholm University welcomes and supports the Commission´s initiative for ‘one substance – one assessment’ and better access to chemicals data for safety assessments. Access to data is fundamental for health and environmental assessments and for the transition to a toxic-free circular economy. Improved access to data has the potential to reduce delays and redundancies in chemical regulation.

Stockholm University is grateful for this chance to contribute to the evaluation of the EU regulation No 511/2014. Our input is based on accumulated experiences at the research support office which supports researchers conducting non-commercial research involving the utilization of genetic resources from other countries than Sweden.

Thank you for providing the opportunity to give feedback regarding an update of the data requirements for active substances in plant protection products. We appreciate new provisions regarding clarification that companies must submit all studies, and a new requirement for developmental neurotoxicity (DNT) testing. We provide specific suggestions to further strengthen these points.

Based on own academic work, analyses, and observations, in my opinion, the current implementation of GLP in the EU does not effectively prevent misleading data analyses, exclusion of datasets from study reports, and withholding of entire studies, and does not stringently follow up on bad practices when these are detected. Also, there is a lack of transparency regarding GLP violations.