Comments on the call for evidence for simplification of the food and feed safety legislation

Pesticide Action Network Europe (PAN Europe) welcomes the opportunity to contribute to the call for evidence for the “Food and feed safety - simplification omnibus”’.

PAN Europe is a science-based organisation composed of toxicologists, legal experts and policy officers. We bring together more than 50 consumer, public health and environmental organisations, trades unions, women's groups and farmer associations from across Europe. Together, we work to eliminate the dependency on pesticides and to replace their use with ecologically sound and socially just alternatives. We have extensive expertise in European and national pesticide legislation and its implementation. Accordingly, our fact- and science-based contribution will address the related aspects of the initiative (Pesticides, Maximum Residue Levels (MRLs) and biocides).

First, we wish to remind the Commission of the broad public demand for stricter regulation to phase out synthetic pesticides, as well as support for farmers who have already stopped or are in transition to significantly reduce their use. This demand has been consistently expressed across the EU in recent years through consultations, barometers, opinion polls, and two successful European Citizens’ initiatives. The European Commission’s credibility and citizens’ trust towards the EU depend on respecting the outcomes of its own participatory processes, including in the context of this initiative.

We will structure our reply by addressing, point by point, the list of “problems that the initiative aims to tackle” compiled by the European Commission for pesticides and MRLs.

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Pesticide Action Network Europe (PAN Europe) gratefully acknowledges the financial support from the European Union, European Commission, DG Environment, LIFE programme. Sole responsibility for this publication lies with the authors and the funders are not responsible for any use that may be made of the information contained herein.