Brussels, 4 December 2025
Subject: Serious concerns regarding the Food and Feed Safety Simplification Omnibus Package
Dear Ms Ursula von der Leyen, President of the European Commission
Dear Mr Olivér Várhelyi, Commissioner for Health and Animal Welfare
Dear Ms Teresa Ribera, Executive Vice President for Clean, Just and Competitive Transition
Dear Ms Jessika Roswall, Commissioner for Environment, Water Resilience and a Competitive Circular Economy
Dear Mr Christophe Hansen, Commissioner for Agriculture and Food
We write to convey our profound concern regarding the published “2025 Annual Progress Report on Simplification, Implementation and Enforcement (Health, animal health and welfare, plants and plant health, food and feed safety)” and the leaked draft proposal for amendments to Regulation (EC) No 1107/2009 concerning plant protection products as part of the forthcoming Food and Feed Safety Simplification Omnibus Package.
We are alarmed by certain provisions within the draft that fundamentally undermine the regulatory framework established to safeguard health and the environment. The proposal to grant unlimited approval to most active substances constitutes a dangerous departure from evidence-based regulation. The existing framework of periodic renewal was instituted precisely because scientific understanding advances, novel hazards emerge, and long-term environmental impacts become apparent over time. As acknowledged by the Commission in its 2020 REFIT of the Pesticides Regulation, “the expected impacts on society of this review process are continued high levels of safety for operators, bystanders and consumers, as well as a high level of protection of the environment”. Eliminating systematic review cycles would entrench outdated risk assessments and prevent the regulatory system from responding to emerging evidence concerning toxicity, endocrine disruption, or ecosystem degradation. Furthermore, the proposed removal of Member States’ obligation to consider the latest independent scientific evidence when conducting national assessments of plant protection products – requiring instead exclusive reliance upon potentially outdated EU-level assessments that may be years or even decades old – is fundamentally incompatible with evidence-based regulation and the precautionary principle enshrined in EU law.
We acknowledge that the current approval and authorisation framework suffers from certain deficiencies, principally stemming from insufficient human and financial resources within Member States’ competent authorities, which prevents adherence to regulatory deadlines for completing administrative procedures. This represents the key challenge that must be addressed. Nevertheless, we insist upon a fundamentally different approach that confronts the root cause of these deficiencies rather than dismantling safety standards. The solution to administrative delays cannot be the abandonment of systematic safety review and regulatory shortcuts that compromise the high level of protection of health and environment.
We fully recognize that European farmers face genuine challenges and need access to effective plant protection tools to ensure viable agricultural production and food security. Climate change is generating new pest pressures, and the transition to sustainable agriculture requires innovation and access to alternatives to hazardous chemical pesticides. However, access to plant protection products cannot be secured at the expense of public health, worker safety, and environmental integrity. Farmers merit a sustainable and accessible array of tools that protects both their livelihoods and their own health as primary users of these substances. Rushed and scientifically unfounded approvals and prolonged use of hazardous substances serve neither farmers nor society at large.
The leaked proposal of the Food and Feed Safety Simplification Omnibus appears designed to reduce administrative burden by lowering safety standards rather than addressing the underlying capacity constraints. This approach is unacceptable to the S&D Group and, we believe, to European citizens who consistently express strong support for high environmental and health protection standards.
We urge the Commission to review the current draft before presenting it and conduct a proper impact assessment that seriously examines a full range of policy options, as well as to ensure that genuine consultation process is conducted actively engaging the Council and the Parliament and a broad spectrum of stakeholders, including health and environmental stakeholders and Member States’ competent authorities. There is no concrete evidence of the pressing urgency claimed by the Commission which would necessitate foregoing these essential elements of the better regulation framework.
The European Parliament has consistently championed the precautionary principle and evidence-based policymaking. While the above-mentioned issue constitutes the most glaring example of ill-advised policy making in the leaked proposal, the package seems to contain a range of worrying elements. We will therefore scrutinize this proposal with the utmost attention, and we can affirm already now that we cannot and will not support measures that sacrifice public health and environmental protection under the guise of simplification.
We remain at your proposal for further exchange on this crucial matter.
Yours sincerely,
Iratxe García Pérez, S&D Group President
Christophe Clergeau, Vice-President, S&D Group
Tiemo Wölken, S&D ENVI Coordinator
Dario Nardella, S&D AGRI Coordinator