IBMA would like to underline the following points:
- IBMA appreciates that the weight of evidence approach can replace the systematic use of animal studies to address toxicity and pathogenicity end points.
- Biology and ecology are considered the basis for the risk assessment decisions, which is a key adaptation for effective microbial risk assessment,
- These revised Data Requirements are a crucial part of the Farm to Fork strategy implementation but alone cannot speed up the delivery of micro-organisms/microbials to the farmers.
- The authorization process of 1107/2009 needs to be implemented in a way that allows authorization and placing on the market in Member States within 1-3 years of initial submission as seen for biocontrol in other countries such as USA and Brazil. Timescales for a product to reach the market following submission in the European Union range from 4 years to 10 years.