Europe’s farmers are being asked to deliver more: resilient production, sustainability outcomes and competitiveness in an increasingly challenging global context. To do so, they need access to a crop protection toolbox that is diverse, predictable and workable in practice.
The European Commission’s Food and Feed Safety Omnibus proposal is an important opportunity to address one of the most persistent shortcomings in the current system: the way Article 4.7 of Regulation 1107/2009 works in practice.
Article 4.7 allows derogations where substances are needed to address a serious danger to plant health. Yet in reality, it has never successfully safeguarded critical uses. The result is growing gaps in the farmers’ toolbox, even where products can be used safely and no viable alternatives exist.
Making Article 4.7 workable in the real world
The issue is not the intent of Article 4.7, but its practical application. Too often, decisions fail to reflect the agronomic and agro‑economic realities that determine whether alternatives are genuinely feasible on farms.
If Article 4.7 is to function as intended, implementation must include a structured agronomic and agro‑economic assessment. This should test the real‑world feasibility of alternatives, including their efficacy, scalability, cost, yield impacts, operational constraints, implications for integrated pest management and resistance management and theiruneven availability across crops and Member States.
This is essential to avoid losing essential tools where alternatives exist only on paper.
Importantly, such an assessment should reflect the full reality of EU agriculture by considering all registered uses across Member States, including minor uses, rather than focusing on a limited set of representative uses.
Flexibility that reflects how farming actually works
Crop protection conditions are dynamic. Scientific knowledge evolves, exposure mitigation measures change and pressures on crops can shift rapidly. That is why flexibility in how derogations are substantiated matters.
Allowing essential use and/or negligible‑exposure elements to be substantiated during approval or renewal would enable decisions to be taken when criticality is clearest and access is genuinely at risk. This would support timely, evidence‑based decision‑making while maintaining high safety standards and better reflecting conditions in the field.
Predictable transitions to avoid disruption
The Omnibus also proposes longer grace periods for substances that lose approval, with up to 12 months for sale and up to 24 months for use. Predictable transition timelines are essential for farmers planning cropping seasons, managing stocks and adapting crop protection strategies responsibly.
Conditioning grace periods on the “absence of alternatives”, however, risks creating added complexity and duplication by triggering assessments that resemble derogation evaluations. A more effective approach would be to apply extended grace periods systematically in cases of non‑renewal, except where withdrawals are based on serious human health or environmental concerns.
This would support an orderly and responsible phase‑out, without undermining food production or farm planning.
What this means in practice
To make Article 4.7 work as intended, implementation should:
- embed a structured agronomic and agro‑economic assessment into derogation decisions, testing whether alternatives are genuinely feasible at farm level;a
- allow greater flexibility in derogation submissions, so decisions reflect the point at which criticality is clearest;
- apply predictable grace periods systematically, ensuring orderly transitions and avoiding unnecessary disruption for farmers.
Done right, the Food and Feed Safety Omnibus can help deliver a regulatory system that is predictable, science‑based and aligned with real farming conditions. This would ensure that essential crop protection tools remain available where no viable alternatives exist.
To learn more about securing farmers toolbox, click here to read our position paper