This position paper explains our position on securing competitiveness of farmers’ toolbox in the Food and Feed Safety Omnibus. Below are our key messages:
Make Article 4(7) workable by embedding a structured agronomic and agro-economic assessment: Decisions on derogations should systematically consider real-world feasibility of alternatives (efficacy, scalability, cost/yield, operational constraints, IPM/resistance and uneven availability), so essential uses are not lost where no viable options exist.
Improve flexibility in derogation submissions to reflect real farm realities: Allowing essential-use and/or negligible-exposure elements to be substantiated during approval or renewal enables timely, evidence-based decisions when criticality is clearest and when access is at risk while maintaining high safety standards.
Apply predictable grace periods to avoid disruption: Extended grace periods (up to 12 months for sale and 24 months for use) should apply systematically for non-renewals, except where withdrawal is based on serious human health or environmental concerns; conditioning grace periods on “absence of alternatives” risks duplicative, derogation-like assessments and added complexity.
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