Resource Library

1. CropLife Europe wishes to caution that the rushed adoption of the PMT criteria may result in a regulation not fit for purpose. As the newly introduced hazard classes will be referred to across the regulatory landscape, a clear understanding of the practical consequences affecting all types of chemicals in scope of CLP Regulation is necessary prior to a legislation proposal being introduced.
2. Leachability defined as percentage of a chemical that can reach drinking water sources represents the best parameter to define the mobility criterion (M). Croplife Europe proposes categorisation based on the M criterion:

o Confirmed PMT (Category 1) based on leachability

o Suspected PMT (Category 2) based on KOC
P and T criteria would remain unchanged (i.e., confirmed only).

3. CLE does not support a separate hazard class for vPvM nor the expansion of the T criterion to terrestrial toxicity due to lack of sufficient scientific evidence.

• New Genomic Techniques (NGTs) can contribute to the Green Deal objectives by enabling and accelerating the development of resilient plant varieties for sustainable food production.
• In the EU, the regulatory framework for NGT products is not fit for purpose. The current rules hinder the development and availability of NGT products for European farmers, and negatively impact EU innovation and competitiveness.
• CropLife Europe calls on the European Commission and EU policymakers to drive forward an enabling and science-based regulatory framework for plants developed through NGTs by establishing a process to determine their regulatory status on a case-by-case basis.

• Sustained imports of protein-rich GM crops are central for the EU feed value chain. Delays in the authorisation process may result in trade disruptions and uncertainty for value chain operators.
• GM crops have a long history of safe use. To be authorised on the EU market they undergo strict assessment by EFSA on any possible risks posed to human and animal health, as well as to the environment.
• CropLife Europe calls for an efficient and timely authorisation process for the import of GM crops into the EU, respecting legally foreseen deadlines.

1. The EU regulatory framework needs to be predictable: Political considerations should be informed by independent expert risk assessment and respect particularly the role of scientific evidence in decision making. Trust in the rigor and independence of the EU system needs to be enhanced.
2. EU farmers need access to crop protection tools and EU trade partners need confidence in our system: Blocking the setting of such trade standards, when no concerns have been identified by the risk assessors, limits the access of EU farmers to crop protection tools and erodes trade partner confidence in the objectivity and predictability of the EU risk assessment system.
3. MRLs are trading standards and are required to avoid trade disruptions: The impacts on European consumers, farmers and the food industry that arise from blocking certain MRLs or ITs can be significant. Trade disruption is not in the interest of EU citizens, businesses, or our trade partners. Such disruptions can have long-lasting negative consequences for food availability and development.