Open Letter addressed to the European Council and the European Parliament
To: 2026 Council Presidencies and Rapporteur/Co-Rapporteur MEPs
From: Protein and Peptide Crop Protection Companies
Subject: Food Feed Safety Simplification Omnibus Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EC) No 1107/2009 (among others)
We urge the European Council, European Parliament, and the Commission to adopt the proposed biocontrol definition without revision, explicitly preserving the criterion “substances of biological origin or produced synthetically that are functionally identical and structurally similar to them”.
Context
As representatives of mostly SME protein- and peptide-based crop protection innovators, we welcome the Commission’s Food & Feed Safety Simplification Omnibus Proposal. The proposal aims to simplify Regulation (EC) No 1107/2009 and accelerate access to safe, effective biocontrol technologies while maintaining the EU’s high level of protection for human health, animal health, and the environment.
A core pillar of this package is the newly proposed definition of “biocontrol”. This definition determines which biocontrol solutions qualify for streamlined procedures, making it foundational to all other simplification measures.
Why the Definition Matters
1. Predictability and Harmonisation
Today, there is no regulatory definition for biocontrol which causes divergent categorization, delays, and administrative burden across Member States. A clear and inclusive definition would ensure predictable routing and reduces unnecessary pre-assessment disputes.
2. Science-Based and Future-Proof
The proposal includes substances structurally similar and functionally identical to those occurring in nature—a scientifically appropriate approach aligned with modern biocontrol technologies. Any change to this proposal requiring exact natural identity would:
• exclude innovative peptides, proteins, and enzymes with biocontrol-appropriate risk profiles;
• rely on incomplete natural sequence databases;
• weaken incentives for R&D;
• decrease the availability of biocontrol solutions to farmers.
3. Regulatory Integrity Remains Fully Intact
The definition affects procedural categorization only. All substances—regardless of origin or manufacturing method—remain subject to the full risk assessment standards of Regulation (EC) No 1107/2009, including hazard cut-offs, exposure assessment, environmental fate evaluation, and post-authorisation review.
4. Essential for Complementary Simplification Measures
The effectiveness of measures such as prioritised assessment, tacit mutual recognition, unlimited approval periods, provisional authorisations, and a single EU zone depends directly on having a clear and inclusive regulatory definition.
Conclusion
Therefore, we urge the European Council, European Parliament, and the Commission to adopt the proposed biocontrol definition without revision, explicitly preserving the criterion “substances of biological origin or produced synthetically that are functionally identical and structurally similar to them”.
This is essential to:
• ensure scientific consistency and future-proof regulation;
• support innovation and competitiveness of EU biocontrol SMEs and startups;
• deliver faster, predictable access to safe biocontrol tools for EU growers;
• reduce administrative burden for authorities and applicants;
• maintain the EU’s high protection levels for health and the environment.
A robust, inclusive definition is the keystone of the Omnibus package. Keeping it intact will modernize the regulatory framework, support sustainable agriculture, and strengthen the competitiveness of Europe’s biocontrol sector.
Thank you for your consideration, and we remain at your disposal for any clarification that may be required.
Best Regards,
MEDIA CONTACTS:
Steve Betz, VP Communications • (515).707.6096 • sbetz@vestaron.com
