(Response) Open Consultation on the legislative proposal on Uniform Principles
- beelifeeu
- 4 hours ago
- 1 minuto de lectura
On 29 September 2025, we submitted our response to the European Commission’s open consultation on the legislative proposal for Uniform Principles—a key amendment to Commission Regulation (EU) No 546/2011 governing the evaluation and authorisation of plant protection products.
Our feedback highlights a crucial gap in the current draft: while it aims to safeguard biodiversity and food production, it overlooks equity between agricultural sectors. The proposal currently allows up to 10% loss in honey bee colony strength as an “acceptable risk.” This effectively places a disproportionate burden on beekeepers, while farmers are ensured full crop protection.
We believe pollinators are not only environmental indicators but also productive assets—essential to crop yields and agricultural sustainability. Ensuring fair risk distribution means protecting the livelihoods of all producers who share the same landscapes.
In our submission, we proposed:
Adding a new recital recognising pollinators as vital economic and ecological assets.
Strengthening Annex provisions to include comprehensive exposure assessments and post-authorisation monitoring.
Aligning with the One Health and ecosystem services approach for balanced agricultural resilience.
By integrating equity considerations into risk assessment, the EU can ensure that the protection of one sector does not come at the cost of another.


