Sustainable Use Regulation – Comments for Public Consultation

On the 22^nd June 2022 the European Commission issued a proposal of the Regulation on the Sustainable Use of Plant Protection Products(SUR) and Annexes. This document is now open for public consultation. It is unusual to have a further public consultation at this stage, but IBMA will use this opportunity to develop our response and updated position with members. The European Commission timing during the summer holidays is not ideal for any of us but we want to give everyone the opportunity to comment. In particular, if you are short of time, please comment on the summary, which will form our advocacy priorities.

IBMA has prepared draft comments on the SUR proposal for review and further amendment by Members.

Below are the main conclusions, which have been developed with the Regulatory Advisory WG:

IBMA welcomes:

• The inclusion of a definition of biological control including the 4 categories
• IPM being defined as a hierarchy that puts biology first and chemistry as a last resort
• The inclusion of biological control adoption measures and indicative targets in National Action Plans (Article 9) including a list of the obstacles to biocontrol and the steps being taken to remove these obstacles
• Training in IPM and biocontrol for advisers and farmers

IBMA is keen to see the following amendments:

• Broadening of the definition of biological control to include substances such as peptides and minerals
• Allowing of biological control use in public areas which are currently defined as sensitive areas in which no PPP is allowed.
• Further rigour in the IPM definition to ensure a biology first mind-set is expressed supporting ecosystem approach and biodiversity
• HRI to be carefully considered to allow separation and measurement of biological control from chemical control

Online you will find the following documents:

• The European Commission proposal the Sustainable Use Regulation and Annexes
• The SUMMARY OF IBMA COMMENTS (PDF document) as prepared after discussions with the IBMA Regulatory Advisory WG on 23^rd and 24^th June 2022
• A DRAFT document IBMA Comments on the Regulation on the Sustainable Use of Plant Protection Products (Word document). This document contains the same information as the PDF document SUMMARY OF IBMA COMMENTS but the different bullet points have been grouped and some wording has been added to make coherent paragraphs.

The Sustainable Use Regulation proposal is now open for public consultation (by 19^th August 2022). The public consultation requests a maximum of 4.000 characters. The ‘Executive Summary’ is intended to be submitted as part of the public consultation.

Please comment on the Word document DRAFT document IBMA Comments on the Regulation on the Sustainable Use of Plant Protection Products by providing your remarks in track-changes. You should provide your comments at the latest by 16 August 2022 to Jennifer Lewis jennifer.lewis@ibma-global.org and Jeroen Meeussen Jeroen.Meeussen@erm.com. We intend to submit IBMA’s comments as part of the public consultation by the deadline of 19^th August 2022.

Thanks in advance for your contributions.

Best regards,

Jeroen and Jennifer