In this briefing note CropLife Europe sets out parameters of what an impact assessment should include.
Potential changes to the EU Maximum Residue Level (MRL) framework for non-approved active substances could have consequence far beyond residue policy. They may affect consumer confidence, food and feed supply, affordability, farmers’ competitiveness innovation, international trade, development objectives and the EU’s credibility as a science-based regulator.
For that reason, the European Commission announced it intended to carry out an Impact Assessment, which was broad in scope, evidence-based and cross-sectoral, in line with the EU’s Better Regulation 1.
This paper sets out why the assessment must go beyond a narrow competitiveness lens:
- why a narrow or purely competitiveness-driven assessment would be insufficient.
- which impact dimensions must be examined to allow an informed policy choice; and
- why alternative, less trade-distorting policy options should be assessed alongside any proposal to default MRLs to the limit of quantification (“technical zero”).