Workshop Efficacy Requirements and Evaluation of Plant Protection Products based on Low-Risk Active Substances, Ede (NL), /07

Similar documents
Technical Guidance Paper drr - Part B Section 7 - Efficacy. Versie 1. (2015)

Efficacy for lowrisk. industry view, Efficacy workshop, Ede April David Cary, Executive Director of IBMA

PP 1/296 (1) Principles of efficacy evaluation for low-risk plant protection products

Principles of efficacy evaluation for microbial plant protection products

Guidance on requirements for efficacy data for zonal evaluation of a plant protection product in the Northern Zone

June, 2011 Guidance on requirements for efficacy data for zonal evaluation of a plant protection product in the Northern Zone

GUIDELINES FOR EVALUATION OF PESTICIDE BIO EFFICACY TRIAL REPORTS

Evaluation Manual for the Authorisation of Plant protection products and Biocides according to Regulation No 1107/2009

EPPO Workshop on Comparative Assessment in the framework of substitution Brussels, /07

OPEN QUESTIONS in the new system (1107/2009 EC)

Efficacy requirements for the

Principles of zonal data production and evaluation

Guidance on requirements for efficacy data for zonal evaluation of a plant protection product in the Northern Zone

Technical guidelines on the presentation and evaluation of plant protection product dossiers in the format of a (draft) Registration Report

REGISTRATION REPORT Part A Risk Management. Product code: Product name(s): ACTIOL. Southern Zone Zonal Rapporteur Member State: France

Importance of minor uses for the chemical industry and initiatives

DOSE EXPRESSION FOR VERTICAL CROPS IN BELGIUM PLANT PROTECTION. Guidance document

Guidance on the application of mutual recognition in Norway

COMPARATIVE ASSESSMENT AND SUBSTITUTION OF PLANT PROTECTION PRODUCTS IN SPAIN

Good Laboratory Practice (GLP)

Spanish Working Group on Dose Expression

ECPA Technical Guidance Paper No: 2012/1

Comparative assessment

DISCOVER OUR SEGMENT AGROCHEMICALS & BIORATIONALS

Harmonization of dose expression Dose conversion and adjustment

Value Assessment of Pest Control Products

REGISTRATION REPORT Part B. Section 7: Efficacy Data and Information

Minor uses and specialty crops: the voice of European farmers and their cooperatives

EUROPEAN COMMISSION HEALTH & CONSUMER PROTECTION DIRECTORATE-GENERAL. Safety of the food chain Chemicals, contaminants, pesticides

Sustainable plant protection. Dutch sustainable initiative and activities

EUROPEAN COMMISSION HEALTH AND CONSUMERS DIRECTORATE-GENERAL

Interpretation of Efficacy Trials The Need for Statistics. Jon Winfield Head Human Health Branch

Hungarian experiences Tőkés Gábor NÉBIH NTAI

Examples of regulatory expectations for analytical characterization and testing

Annual Biocontrol Industry Meeting. Lucerne, Switserland. Jeroen Meeussen 22 October 2007

IBMA WHITE PAPER NEW EU REGULATORY FRAMEWORK FOR BIOPROTECTION AGENTS. IBMA Vision on how to improve regulation in the European Union

An introduction to Article 43

EMERGENCY REGISTRATION PROTOCOL FOR AGRICULTURAL REMEDIES

Import tolerances in the European Union Can Import Tolerances be set for active substances impacted by the EU hazard-based criteria?

Report from the CMD(h) meeting held on 18 th, 19 th and 20 th June 2007

Concept paper on the development of a guideline on quality and equivalence of topical products

Low-risk Substances. Dr. Bernd Brielbeck Senior Manager Regulatory Affairs Agrochemicals and Biopesticides SCC Scientific Consulting Company, Germany

This template is to be used by companies willing to submit an overview of relevant

CHA 1526 Page 1 of 18. REGISTRATION REPORT Part A. Risk Management

AT Experiences with the Zonal Evaluation Process (2)

EUROPEAN COMMISSION HEALTH & CONSUMER PROTECTION DIRECTORATE-GENERAL. Safety of the food chain Chemicals, contaminants, pesticides

The Canadian Regulatory View of Insect Resistance Management Entomological Society of America Meeting, Indianapolis, Indiana December 2009

REGISTRATION REPORT Part A Risk Management. Product name(s): ISOMATE-CLR MAX. Southern Zone zonal Rapporteur Member State: France

Pharmabiotics: a Regulatory Hurdle in Europe

A Global CRO STRONGER TOGETHER

1225 Eye Street NW, Ste. 400 Washington, DC 20005

MRL Harmonization. Group C

WHO PQ dossier Module I. DCVMN Common Technical Document (CTD) Workshop Brazil, 18 to 20 June 2018 Dr. Nora Dellepiane

FINAVESTAN EMA. Page 1 of 15. REGISTRATION REPORT Part A. Risk Management

26/04/2016. Guidelines for emergency situations in plant protection

The Danish Green Growth Action Plan initiative for authorisation of more alternative plant protection products. Henrik F.

COMMITTEE FOR PROPRIETARY MEDICINAL PRODUCTS (CPMP)

Status of harmonization of dose expression in 3 D crops for the zonal efficacy evaluation of PPP (Plant Protection Product) in Europe

Efficacy and Crop Safety Data Development Issues

Implementation of Regulation 1107/2009, current issues and future challenges

PP 1/213 (4) Resistance risk analysis

REPORT OF EFSA. Public consultation on the existing Guidance Document on Persistence in Soil. Prepared by PPR Unit. Issued on 26 Jan 2009

EUROPEAN COMMISSION HEALTH & CONSUMER PROTECTION DIRECTORATE-GENERAL. Safety of the food chain Chemicals, contaminants, pesticides

Challenges and Considerations for Minor Uses in LATAM

REGISTRATION REPORT Part A Risk Management. Product code: ALB 019 Product name(s): FLAME. Southern Zone Zonal Rapporteur Member State: France

Implementing Regulation 1107/2009 Stage of Progress An Industry Perspective CEUREG Forum, Brno, 7 October 2010

10041/16 ADD 1 GSC/lt 1 DG B 2B

Guidance on the Biocidal Products Regulation

Pesticide Registration - processes and challenges

Global Residues & MRL s Harmonization

Position Paper. Regulation of Plant Biotechnology Products Containing Two or More Traits Combined By Conventional Plant Breeding

Legal and organisational conditions of applying Good Experimental Practice in the area of efficacy evaluation of plant protection products in Poland

Leveraging Health Canada s Regulatory Framework to Accommodate Accelerated Product Development for Biologic Drugs

Rose is a rose is a rose

OECD Guidance for Industry Data Submissions for Microbial Pest Control Products and their Microbial Pest Control Agents

WHO GUIDELINE Stability testing of active pharmaceutical ingredients and finished pharmaceutical products

How EU Regulation on authorization and Sustainable Use of Pesticide Directive contribute to IPM

Draft regional guidelines on stability testing of active substances and pharmaceutical products

BPR update: Union Authorisation, Families and Same Biocidal Product

APPLICATION FOR VARIATION TO A MARKETING AUTHORISATION

MEDICAL DEVICE. Technical file.

Cost Effectiveness Analysis document

Pediatric Drug Development:

Management of MRL applications submitted for active substances under Article 8 of Regulation (EC) No 1107/2009 and

DFG. Proposal Preparation Instructions. Clinical Trials Draft Proposals. DFG form /14 page 1 of 8

CLINICAL REQUIREMENTS FOR LOCALLY APPLIED, LOCALLY ACTING PRODUCTS, CONTAINING KNOWN CONSTITUENTS

Regula'on of Contracep'ves

GUIDANCE DOCUMENT ON WORK-SHARING IN THE NORTHERN ZONE IN THE AUTHORISA- TION OF PLANT PROTECTION PRODUCTS

(NEU 1170 H EC) FINALSAN POLYVALENT JARDIN Page 1 of 23. REGISTRATION REPORT Part A. Risk Management

(EFSA-Q ) 1 For the purpose of this document foods of animal origin are limited to fresh unprocessed products of animal origin.

The Role of the IR-4 Project in Pest Management for Horticulture Crops Grown in the United States

"PESTCIDE REGISTRATION SYSTEM IN POLAND - PROBLEMS EXPECTED IN THE LIGHT OF NEW EU REGULATION"

Post-approval Change Management Protocols - Current Status and Next Steps on the Way towards a Global Tool

Chin Koerner Executive Director US Regulatory and Development Policy

Plant Biostimulants: Emerging European legislative Scenario

THE BIOSIMILARS LANDSCAPE: STRATEGIES FOR CLINICAL AND COMMERCIAL SUCCESS

EMEA/CHMP WORKSHOP Draft guideline on requirements for first-in. in- man clinical trials for potential high-risk medicinal products

EUROPEAN COMMISSION DIRECTORATE-GENERAL ENVIRONMENT Directorate A Green economy ENV.A.3 - Chemicals

Report of the Second Global Minor Use Summit FOOD AND AGRICULTURE ORGANIZATION OF THE UNITED NATIONS, Rome, Italy February 21-23, 2012

Regulatory priorities/needs linked to Grouping (EU) Celia Tanarro ECHA Scientific Workshop - Grouping of Nanomaterials

Transcription:

Workshop Efficacy Requirements and Evaluation of Plant Protection Products based on Low-Risk Active Substances, Ede (NL), 2016-04-06/07 CONCLUSIONS and RECOMMENDATIONS On 6 th and 7 th of April 2016, more than 100 representatives from 20 countries representing industry, competent authorities and consultants discussed the efficacy requirements for plant protection products based on low-risk active substances. Efficacy has been a bottleneck for placing these products on the market in Europe because the efficacy requirements are similar to those for conventional chemical plant protection products. The overall conclusions and recommendations of the workshop are listed below. The individual conclusions and recommendations of the separate working groups can be found in Appendix 1. Overall conclusions: 1. An assessment of efficacy of plant protection products based on low-risk active substances is necessary. However, the requirements for efficacy can be lower compared to conventional plant protection products. The number of (field) trials may be reduced if data from other sources is available (literature, preliminary data, etc.). The evaluation should be simple and already existing flexibility should be used; 2. Lower and more variable effectiveness of plant protection products based on low risk active substances compared to the effectiveness of conventional plant protection products is acceptable. Any benefit of the product compared to the untreated control should be shown; 3. There is a strong need for harmonization of requirements with regard to efficacy evaluation of plant protection products based on low-risk active substances in order to accelerate the authorization of such plant protection products; 4. Extrapolation possibilities related to e.g. mode of action and the use of data from other EU or EPPO zones should be further explored and where relevant guidance should be developed; 5. Differentiated label claims for plant protection products based on low-risk active substances are a controversial issue and need further discussion. No consensus was reached during the workshop. Overall recommendations: 1. Guidance on efficacy requirements and evaluation of plant protection products based on low-risk active substances for Competent Authorities/NPPOs and applicants should be developed by EPPO; 2. A pre-pre- submission meeting of applicants with authorities where e.g. data requirements can be discussed in an early stage of product development is necessary and should be available in all Member States. Member States should be in close contact to achieve harmonization on data requirements; 3. A good description of the mode of action should be available and applicants should be critical (realistic) about their own data. At the end of the workshop the outcomes were presented to the EU Commission and EPPO.

APPENDIX 1: Individual conclusions and recommendations of the separate working groups Conclusions and recommendations of groups A-D 1. Acceptable effectiveness levels and types of label claims The required number of efficacy trials for plant protection products based on low-risk active substances can be reduced and need not necessary to be only GEP trials; There is a strong need for harmonization between Member States; Use of extrapolation possibilities related to the mode of action of the product should be optimized; Use of data from other (EU or EPPO) zones is acceptable; There was a major discussion, but no consensus reached on differentiated label claims. The label claim should be related to mode of action and description of optimal conditions for efficacy (such as temperature or relative humidity); There should be a difference with untreated control 1. Develop (EPPO) guidance on the acceptable level of effectiveness of products based on low-risk active substances to improve harmonization between Member States. 2. Dose justification To justify minimum effective dose, field trials may be not relevant/necessary depending on the mode of action. Instead dose can be addressed in preliminary trials or scientific reasoned cases. Develop (EPPO) guidance on data requirements for minimum effective dose depending on the mode of action. 3. Data requirement: what is the minimal amount of information required to carry out a meaningful efficacy evaluation? Trial data is necessary to be able to evaluate and demonstrate the effectiveness of products based on low-risk substances. GEP trials are preferred, but other trial data can be acceptable if it is scientifically sound and in line with relevant and available EPPO Standards. The applicant should give a clear justification for the use of alternative (trial) data. The number of (field) trials may be reduced if data from other sources is available (literature, preliminary data, etc.). Suggestions on number of trials were: 3-4 trials or minimum number of trials in EPPO Standard PP 1/226 Number of efficacy trials (Minor uses 3 (range 2 6)); A pre-pre-submission meeting of applicants with authorities where data requirements can be discussed is necessary; There is a need for an EPPO example on data requirements for plant protection products based on low-risk substances. 1 EPPO PP 1/214 Principles of acceptable efficacy: The primary criterion of acceptable efficacy is that the product should show results that are significantly superior to those recorded in the untreated control, i.e. that the use of the product is better than no use. The product should show a consistent, well-defined benefit to the user. 2

4. Extrapolation possibilities/ justification of extrapolation Depending on the mode of action of the product, extrapolation from data on one pest in one crop to the same pest in other crops and/or from one pest species to another pest species should be possible. Bridging or justification is necessary; Data from worst case circumstances (efficacy envelope 2 ) can be used for extrapolation to less critical situations; Good quality of data and science are key. Create one EU zone for products based on low-risk substances ; Create an efficacy envelope with zonal labels. 5. Quality of dossiers/ role of applicant A good description of the mode of action should be available; A good draft Registration Report (Concise summary) should be written. A pre-pre-submission meeting should be available in all Member States; Be critical (be realistic) about your own data; Training of applicants by the competent authority. 6. Usefulness of Value assessment New section 3 of the drr already gives room for additional (value) information, including benefits other than efficacy (e.g. under paragraph 3.5.3.). Guidance for evaluators on how to carry out value assessment is needed. Harmonized requirements on value assessment need to be established. There is a separate Registration Report format for micro-organisms available which is still section 7. This format should be updated in accordance with the format for conventional plant protection products. Conclusions and recommendations of group E (policy group) Is assessment of efficacy for plant protection products based on low-risk substances needed? Plant protection products based on low-risk substances can have lower requirements for efficacy compared to conventional plant protection products. Clear guidance on (data) requirements and what information may be included in the efficacy dossiers is needed. What should be demonstrated by the applicant to show efficacy for low-risk products? In the regulation it is indicated that a low-risk product should be sufficiently effective (Art 47, 1d). What is seen by policy makers as sufficiently effective? 2 Similar concept as the risk envelope approach, but needs further exploration. 3

The data package should show any benefit of the product; Sufficiently effective: when any benefit compared to the untreated control is demonstrated. Is the differentiated approach of Chemical Regulation Directorate (different levels of control indicated on the label) helpful, or wanted? What are the advantages and disadvantages of such a differentiated label. The main objective of a label claim is to manage expectations for the growers; Some member states already use this (DE, DK, LT, AT), it should be adopted across the EU; No consensus reached on type of label claim; further discussion needed. As label claims for plant protection products based om low-risk substances are a controversial issue, further discussion is needed. Could a Value Assessment as applied in Canada be a tool to execute a more appropriate efficacy assessment of products based on low-risk substances? Value Assessment as applied by some Member States, needs to be harmonized and applied at zonal level. Keep the efficacy evaluation simple and make use of existing flexibility; Develop a new EPPO Standard on principles on efficacy requirements and evaluation of plant protection products based on low-risk active substances, based on existing EPPO standards; Detail which other types of information can be used to support the claim (e.g. product performance, benefits, scientifically sound efficacy trials, laboratory trials, historic use, growers needs). A zonal evaluation of a plant protection product based on a low-risk substance should be finalised in 120 days. How can the efficacy evaluation contribute to shorten the assessment time? Improved dossiers for efficacy; Special expertise to evaluate plant protection products based on low-risk active substances products; Zonal co-operation/work-sharing. Countries should install green teams 3 if they have the capacity; Early pre-submission meetings help to develop good quality dossiers; Limit efficacy requirements (prove any benefit). Which tools are available to accelerate the introduction of plant protection products based on low-risk substances? One EU-zone for plant protection products based on low-risk substances. 3 A team of specialists on evaluation of plant protection products based on low-risk substances. 4

Other conclusions, not specific for plant protection products based on low-risk active substances: Minor crops and minor uses Revise the definition of minor use -> create a harmonized list of minor uses; One single assessment of minor use throughout EU; Harmonized crop grouping system/ extrapolation from major to minor and minor to minor. 5