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Pesticides Update

10 September 2008

Extension of deadlines for third and fourth phase of pesticides review program

The European Commission (EC) has extended the deadline for finalising the review of third and fourth list compounds under Directive 91/4141.

Article 8(2) of Directive 91/414 directive provides for a 12-year transitional period for the review of active substances used in plant protection products that were on the EU market on or before 25 July 1993. This programme was launched in 1992. At that time, more than 900 existing active substances were identified as being on the market in the EU and around 400 of those substances where subject to detailed scientific assessment.

As it has not proven possible to take a decision on all active substances included in the third and fourth stage of the review programme within the initial deadline, the EC issued several regulations and a decision extending this deadline.

Last July a new Commission Regulation amending the time period referred to in article 8(2) of the pesticides directive was voted on and accepted by the Standing Committee on the Food Chain and Animal Health. This Regulation was published on 29 August 2008 and entered into force on 5 September 2008, extending the deadline for review to 31 December 2009.

This extension of the deadline is not meant to grant companies more opportunities to complete their dossier or fill data gaps.  Its objectives are to allow the Commission more time to adopt the remaining Annex I listing directives (or non-inclusion decisions), and to ensure that Member States have a legal basis to maintain plant protection product registrations until the end of next year.

This extension follows a period of one year during which the Commission, in order to meet its administrative deadlines, did not accept new data from industry and adopted a series of non-inclusion decisions, which resulted in many Court cases lodged by the industry. Also, approximately one year ago the Commission adopted two regulations aimed at encouraging companies to voluntarily withdraw and resubmit their dossiers, with a view to accelerating decision-making and meet the December 2008 deadline for the review programme.

At present, the Commission allows itself more time to finish its own decision-making for list three and four assessments, however, without giving the industry more opportunities for discussion. This approach is difficult to reconcile with the Commission’s earlier position that administrative deadlines were the cornerstone of decision-making. It remains to be assessed what will be the legal impact of this new regulation on notifiers and ongoing Court cases.

For further information, please contact Claudio Mereu.

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Footnotes

1 Council Directive 91/414/EEC of 15 July 1991 concerning the placing of plant protection products on the market, Official Journal, L230, 19/8/1991, 1–32

Contacts

Claudio Mereu

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