Subject: FW: Food and Feed Safety Omnibus: critique and recommendations (in Science)
From: "Info - SOM" <[email-masked]>
To: "Info - SOM" <[email-masked]>
Date: Thu, 25 Jun 2026 16:27:47 +0300

_____

Saatja: Dimitry Wintermantel <[email-masked]>
Saadetud: teisipäev, 23. juuni 2026 10:59
Adressaat: Karmen Joller - SOM <[email-masked]>
Teema: Food and Feed Safety Omnibus: critique and recommendations (in
Science)

Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga.
Tundmatu saatja korral palume linke ja faile mitte avada.

Dear Karmen Joller,

We are writing to draw your attention to a Policy Forum article published
in Science (https://www.science.org/doi/10.1126/science.aeg8744), authored
by 35 researchers from various research institutions across Europe, in
which we assess the proposed amendments to EU pesticide regulation under
the Omnibus package X: Food and Feed Safety.

We conclude that many of the proposed changes would weaken protections for
human, animal, soil, and environmental health, and stifle rather than
foster innovation. We are particularly concerned about the following
issues:

*	 granting indefinite approval to most active substances would
eliminate the successful renewal cycle that has been instrumental in
identifying and regulating pesticides with unacceptable risks. Since 2011,
this cycle has led to 59 conventional active substances failing renewal on
health or environmental grounds, and a further 96 not seeking renewal
(likely in part because applicants anticipated non-renewal). By contrast,
ad hoc reviews removed only two harmful substances over the same period.
*	the integration of new independent knowledge generated after
authorisation would be hampered by removing the periodic renewal, as well
as by re-defining what “current scientific and technical knowledge”
constitutes in plant protection product authorisation. In practice, this
risks novel research results generated post-authorisation being
systematically disregarded.
*	extending grace periods to up to three years for substances that
have lost their approval — including those for which identified health or
environmental concerns were the reason for non-renewal — risks prolonging
the harm to people and the environment, and sending a problematic signal
on where the priorities reside.
*	removing the requirement for farmers to document their use of
biocontrol products would reduce monitoring capacity for a category of
substances whose environmental impacts are still poorly understood.
Furthermore, the overly broad definition of biocontrol substances proposed
by the Omnibus might encompass high-risk synthetic substances.
*	Finally, the proposal shifts the effective burden of acting on
scientific evidence toward public authorities, without clarifying how or
when scientific findings should trigger regulatory review, rather than
reinforcing the precautionary and prevention principles enshrined in the
Treaty on the Functioning of the European Union.

We fully support the overall aim to achieve greater efficiency in the
approval and control process, but this cannot come at the expense of
nature and people’s health. We therefore respectfully ask that you
consider our concerns and recommendations in your deliberations on the
Omnibus proposal. We recommend rejecting the Commission’s proposal. As we
outline in our paper, we are convinced that a more robust yet efficient
approach to pesticide regulation is achievable — one that can meet the
legitimate goals of simplification while maintaining the protections that
citizens and ecosystems depend on. Our paper offers a set of
recommendations that we believe could serve as a useful starting point for
such an approach.

We would be happy to provide additional materials in support of our
concerns or recommendations and are open to discussing these issues
further with interested policymakers.

Yours sincerely,

Dr. Dimitry Wintermantel
Prof. Ralf B. Schäfer
Prof. Denis Michez
Dr. Lindsey Hendricks-Franco
Prof. Robert Paxton
Dr. Guy Pe’er
Dr. Joachim R. de Miranda
Prof. Simone Tosi
Prof. Mark J F Brown
Dr. Claudia Ituarte-Lima
Dr. Annika Jahnke
Prof. Andreas Schäffer
Dr. Maj Rundlöf
Dr. Daniel Slunge
Prof. Fabio Sgolastra
Prof. Carsten Brühl
Prof. Adam Vanbergen
Prof. Alexandra-Maria Klein
Prof. Dave Goulson
Dr. Julia Osterman

--
Dr. Dimitry Wintermantel
University of Freiburg
Chair of Nature Conservation and Landscape Ecology
Stefan-Meier-Str. 76
79104 Freiburg