Food and Feed Safety Omnibus: simplification, scrutiny and proportionality
A challenge by a coalition of European public health, environmental and consumer organisations led by Pesticide Action Network (PAN Europe) over recent developments in EU chemicals and product legislation have once again brought into focus a familiar but unresolved tension: how do you strike an appropriate balance between regulatory efficiency and maintaining high standards of protection for human health and the environment?
A recent open letter to the Cyprus Presidency of the Council of the EU from a coalition of public health, environmental and consumer organisations highlights growing concern about the direction of travel on the Food and Feed Safety Omnibus proposal, including amendments to Regulation (EC) No 1107/2009 on plant protection products.
The proposal sits within the Commission’s broader simplification agenda, aimed at improving efficiency and reducing administrative burden in food and feed legislation. However, the concerns raised in the letter illustrate how contentious that objective can be in practice.
Key issues raised
The signatories argue that the proposal could significantly alter the pesticide approval regime by:
making unlimited approval periods for most synthetic pesticides the norm
extending this approach to product authorisations
shifting the burden of proof towards public authorities
proceeding with simplification changes without a formal impact assessment
They suggest that a number of widely used substances, including glyphosate and acetamiprid, could effectively remain on the market indefinitely under the proposed system. They also raise concerns about the pace of negotiations, arguing that this limits scrutiny and meaningful expert input. Importantly, the letter points to alternative approaches, including measures associated with EFSA such as increased resourcing and stricter handling of industry dossiers, which could address current backlogs without removing periodic review.
A question of balance
The Commission’s rationale is perfectly understandable. The existing system faces well-documented delays, driven in part by resource constraints, which create uncertainty and inefficiency. Against that backdrop, simplification and prioritisation are legitimate objectives. The difficulty lies in deciding how far those changes should go. For some stakeholders, time-limited approvals are a core safeguard, ensuring that decisions keep pace with evolving scientific evidence. For others, the current system has become overly complex and no longer proportionate to the risks it is intended to manage.
This is ultimately a debate about proportionality.
Simplification is not inherently problematic, but it carries a risk of removing safeguards that serve an important function. Equally, maintaining existing processes without question can entrench inefficiency and delay.
More broadly, this debate reflects a familiar dynamic in EU regulation. Measures framed as simplification are often seen by others as deregulation, particularly in areas where the precautionary principle is central. But regulatory systems do need to evolve. The challenge is ensuring that changes are both effective and credible, and that they maintain confidence in the overall level of protection.
For public authorities, walking that tightrope is far from simple. EU regulation almost always tightens over time, but moments like this raise a more difficult question: whether, and how, regulation can occasionally loosen its grip without losing trust.
Further information: PAN Europe letter https://www.env-health.org/wp-content/uploads/2026/05/Open-letter-to-Cyprus-Presidency-of-the-EU-Council.pdf