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The Simplified Authorisation Procedure for Seed Treatment Products – Enabling the Treatment of Seeds for Export into Non-EU Countries

Hans-Georg Kamann

EU seed producers who currently treat up to 90 percent of the seeds they export into non-EU countries with seed treatment products are suffering from a strict approach followed by national competent authorities who require a full authorisation under Article 28(1) of Regulation 1107/2009 irrespective of the fact that the seeds will not be cultivated within the EU and therefore the assessment scope for human, animal or environmental risk pertaining to cultivation lies outside its own jurisdiction. Against this background, this article analyses whether there are any legal ways to enable the treatment of seeds for export in the Member States in which the respective seed treatment products are not authorised and how the Commission could support national competent authorities to continue to authorise the treatment of seeds for export.

Prof. Dr. Hans-Georg Kamann, Partner, WilmerHale, Frankfurt/Brüssel, Honorary Professor at the University of Passau, Director of the Centre for European Law at the University of Passau. The article is based on a legal opinion the author provided to a leading seed producer.


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