Dear IBMA Member,
Thank you for comments on the Sustainable Use of Plant Protection Products Regulation (SUR) proposal for the public consultation. In particular, thank you to IBMA Germany and IBMA France for their comments as well as specific comments from the following members: CBC, Koppert, SBM, TimacAgro. These have been incorporated as far as practical.
We would like to receive your final comments by EOB Thursday 15 September so it can be submitted Monday 19 September latest as per the deadline.
Knowing that there will be many proposals for amendments from multiple stakeholders for this regulation, we need to agree the top IBMA priorities in the SUR.
Based on the feedback to date, the top 4 priorities we need to keep in the proposed regulation and where possible improve are as follows:
- Definition of biocontrol including the 4 categories with the addition of minerals
- Use of biocontrol in all sensitive areas
- The separation of biocontrol in the HRI (to have similar scoring to low-risk substances)
- Indicative targets for biocontrol to be ensured and where necessary made legally binding.
We look forward to your final comments on the SUR.
Jennifer and the IBMA Team