Dear Commissioner Kyriakides,
In 2019, the European and Mediterranean Plant Protection Organization (EPPO) adopted a revised version of its standard PP 1/271 (3) Guidance on efficacy aspects of comparative assessment. As your DG is currently assessing options for “improving the effectiveness of comparative assessments of products containing candidates for substitution” (3rd recommendation of the REFIT report), we urge you to exclude any incorporation of this new guidance in the PPPs guidance’s umbrella. It not only undermines the core principle of substitution laid down in the PPPs Regulation, but also nips in the bud the 50% reduction target for the more hazardous pesticides by 2030 set in the Farm to Fork Strategy. Your commission claims to fulfill this objective “mainly” by having the candidates for substitution withdrawn from the market, but this can only be achieved if it stops obediently relying on EPPO standards.