English: Food & Feed Safety Omnibus

The European Commission presented the Food & Feed Safety Omnibus on 16 December 2025. With this package, the Commission aims to amend various regulations and directives in the field of agriculture and food. Although the package covers a wide range of dossiers, the most significant changes concern the regulations and directives related to the authorisation and use of pesticides.

Vewin considers that the proposals in this omnibus pose a risk to water quality, and in particular to the quality and protection of drinking water sources. It is essential that legislation concerning pesticides does not reduce, but instead strengthens, the consideration of water quality objectives and standards from the Water Framework Directive and the Drinking Water Directive. Vewin therefore proposes several amendments to the European Commission’s proposal.

Oppose the proposals in the Food & Feed Safety Omnibus that weaken legislation concerning the authorisation and assessment of pesticides, with negative consequences for the quality and protection of drinking water sources.

Vewin outlines its main concerns and proposed amendments below.

Authorisation and re-evaluation of substances

The European Commission proposes that the approval of active substances should, in principle, be granted for an unlimited period. In addition, the mandatory periodic re-evaluation of most active substances will be abolished. Re-evaluation will become risk-based (depending, among other things, on new information) and will be carried out through a work programme.

In the current situation, periodic re-evaluations are an important moment to incorporate new insights into water quality risks, which may lead to stricter conditions of use or non-renewal of approval. In the new situation, re-evaluation will depend primarily on the timely identification of new insights into the risks of substances, as well as on an ambitious work programme with the right priorities. This creates a significant risk that hazardous substances will remain approved and in use for too long, continuing to contaminate drinking water sources.

• Ensure that the approval of active substances continues to be granted for a defined period, combined with mandatory periodic re-evaluation. Ensure sufficient capacity to carry out these re-evaluations in a timely manner.
• Maintain Articles 5 and 18 of the current Regulation 1107/2009 and reject the new Commission proposal.

Phase-out period

For substances that are no longer approved, the so-called ‘grace period’ will be extended. This is the phase-out period during which products containing these substances may still be sold and used. The total period, including both sales/distribution and the additional use of existing stocks, will be extended from a maximum of 1.5 years to 3 years. This means that prohibited high-risk pesticides can remain on the market and be used for much longer, with negative consequences for water quality.

• Maintain the current maximum grace period of 1.5 years for substances that are no longer approved.
• Maintain Articles 20(2) and 46(3) of the current Regulation 1107/2009 and reject the new Commission proposal.

Latest scientific insights

The consideration of the latest scientific insights in authorisation or re-evaluation will become more centralised at European level. Member States will be required to base their assessments on jointly established scientific information used for the approval of active substances at EU level. However, under the omnibus proposals, substances will in principle be approved for an unlimited period. As a result, the scientific data used for their assessment may become outdated. In such cases, Member States will not have sufficient scope to use their own analyses and recent scientific insights when authorising products containing these substances. This means that new insights into risks may not be taken into account.

• Ensure that Member States retain the ability to incorporate the latest scientific insights when authorising pesticides.
• Maintain Article 36(3) of the current Regulation 1107/2009 and reject the new Commission proposal.

Mutual recognition

Mutual recognition of products will be simplified and made easier to apply for. Through mutual recognition, Member States can approve products that have already been authorised in another Member State. This allows applicants to obtain authorisation more quickly. However, simplifying mutual recognition means that products approved under different conditions in other countries can more easily enter the Dutch market. The scope for national, water quality-specific arguments in the authorisation phase will be reduced, as mutual recognition becomes the default. It will become more difficult to intervene at the authorisation stage, increasing the need for measures through use conditions.

• Ensure that Member States retain the ability to consider national-specific circumstances when authorising products. Simplification of mutual recognition must not limit these possibilities.
• Maintain Articles 40 and 42 of the current Regulation 1107/2009 and reject the new Commission proposal.

Drones

The Commission proposes to update the definition of ‘aerial spraying’ and to allow the application of pesticides using drones. The use of drones may increase emissions of substances to soil and water, for example through drift. The application of drones and their environmental impact must first be properly assessed.

• First investigate the effects of using drones for the application of pesticides on soil and water quality before expanding their use.
• Include this condition in Article 3(5) of Directive 2009/128/EC.