Revision of Plant Protection Products Regulation: the Promised Land for Europe’s Sustainable Agriculture Agenda?

Adam Sebesta, Associate Director, Food & Agriculture, Substance Advocacy Lead

With its review of Regulation (EC) No 1107/2009 – the main legislation governing the approval and safe use of pesticides in the EU – the Commission is signalling its intent to bring crop protection innovation to European farmers faster. But it also presents an opportunity to improve the EU’s overall regulatory framework for pesticides.

As we await the adoption of the revised regulation, here are the key elements we are looking out for.

A Stitch in Time Saves Nine: Regulatory Review to Reduce Administrative Burden

As most stakeholders in the agriculture industry have noted, the current pesticide evaluation process is very time-intensive. It consists of two main phases: first, an EU-level approval of the so-called active substance (the main ingredient responsible for the effects of the product). Second, a national level product approval, which typically is undertaken in all countries where the use of the product is foreseen.

The approval process requires arduous scientific, regulatory, legal, and often advocacy inputs. For smaller companies, acquiring resources for all this is almost impossible, forcing them to partner up with bigger conglomerates.

This process is rightly considered by many to be the most rigorous in the world, helping Europe maintain the highest safety standards globally. But with the new generation of safer, nature-derived substances, a consensus has been politically reached to allow for a slightly less stringent approach. And given the recent wave of farmers’ protests, leading to what can be called a ‘pro-farmer’ approach from the new European Commission, the momentum has finally arrived.

Hence, the upcoming targeted revision of Regulation (EC) No 1107/2009 — the main legislation governing the approval and safe use of pesticides in the EU — could finally enable nature-based innovations to enter the market much more quickly. But this moment also offers a broader opportunity: to improve the entire pesticide approval system in the EU.

Provisional Authorisation: A Promising Fast-Track Tool

In the revised regulation, any newly developed product would rapidly reach farmers through a fast-track authorisation pathway — a stark contrast to today’s approval process, which can take up to nine years.

Spoiler alert: while the product may reach the market faster under a so-called provisional authorisation (currently an exceptional procedure expected to be redesigned in a targeted revision of EU pesticide rules by the end of 2025), the standard full approval process would still have to be launched in parallel. Furthermore, only biological pesticides would be eligible for this fast-track route.

The Path Forward: Three Areas to Watch
The Commission’s ambitions with the regulatory review are well-intentioned, and could lead to impactful change in the market. But what are the indicators of success?

To ensure efficient system reform, we will be watching out for developments in what we consider to be three key areas:

• Resourcing of pesticide authorities. To ensure efficiency gains, adequate staffing with relevant expertise at the Member State level will be a pre-requisite.

• Education, education, education. Technical expertise takes years to acquire. A pipeline of talent into the sector will therefore be fundamental to the success of the revision.

• Encourage entrepreneurship. Awards and grants to stimulate young, business-minded researchers can drive innovation in the sector.

Contributing to Europe’s Competitiveness
The European Union has identified strengthened food security, self-sufficiency, and strategic autonomy as key priorities. Driving innovation through faster approval of biological solutions is a smart path forward. But regulation without implementation will not lead anywhere.

This regulatory review carries a lot of promise for Europe’s farmers. It can support Member States in boosting their capacity to evaluate crop protection innovations and help ensure these reach farmers faster through an improved approval process.

Finally, when the revised regulation is adopted, it will be the industry’s job to hold the regulators accountable for success in its implementation. Remaining proactive in advocating for the changes to come alive in the day-to-day implementation will be an important next step.