DG Animals, Plants and Food
Service Pesticides and Fertilisers
BELGIUM COMMENTS ON BIOSTIMULANT
1) Distinction : fertilisers <> pesticides in Belgium
In theory : the distinction is based on the claims mentioned on the label.
PPP: any product for which an action against a disease, pest or weed is claimed or an
action on the life processes of plants is claimed.
FERTILISERS: any product for which a nutritive action, an action of soil improvement,
an action as soil or any specific action likely to promote the crop production is claimed.
Promoting crop production =
1) promotes the assimilation of nutrients (chelate) – possibly through a better root
development (humic acids, mycorrhizae, …)
2) promotes the formation of mycorrhizae (formonometine)
3) promotes the degradation of organic matter
4) improves nitrogen fixation (Azotobacter) – can be extended to micro-organisms
which release nutrients or include them in the next section
5) improves the physical, chemical and biological properties of the soil (referring to
bacteria, fungi, … and other things than soil amendments which are usually considered)
2)
Definition biostimulant
In Belgium, there is no distinction between « agronomic additives » (ex : mycorrhizae)
and « additives for fertilisers » (ex : chelate), but they are actually considered in our
vision of product action. We should therefore not seek to define the two of them
separately but we should integrate the two of them in the definition of biostimulant.
For example : A plant biostimulant is any substance or microorganism, in the form in
which it is supplied to the user alone or added to a fertiliser, soil improver,
growing medium, applied to plants, seeds or the root environment with the intention
to stimulate natural processes of plants benefiting nutrient use efficiency and/or
tolerance to abiotic stress and/or to improve the agronomic efficacy of the final
product and/or to modify the environmental fate of the nutrients released by
the fertilisers, regardless of its nutrients content, or any combination of such
substances and/or microorganisms intended for this use
Attention:
- if abiotic stress is caused by a modification of the life processes of the plant = PPP!
- The same goes for CO2 : if it is used as maturation hormone = PPP, if it is used as
‘nutrient’ = fertiliser.
- a point should be added in the regulation which excludes water.
3)
Definition of PPP <> biostimulant & « natural processes »
Concerning the proposed amendment of the PPP definition : the part of the definition of
‘active substance’ in the Regulation (EC) No 1107/2009 (art. 2.1.(b)) to be amended is
the following: “influencing the life processes of plants, such as substances influencing
their growth, other than as nutrient”. It should be noted that substances influencing the
growth are only given as an example of substances influencing the life processes of
plants (“such as…”). Other substances considered as active substances are also covered
by this point. This is for instance the case of the ‘elicitors’, i.e. substances which are
stimulating the self-defense mechanisms within the plant (and thus influencing the life
15/05/2014
Place Victor Hortaplein 40, Box 10 ● 1060 Brussels ● www.health.fgov.be
DG Animals, Plants and Food
Service Pesticides and Fertilisers
processes of the plants), and which are, to my understanding, not intended to be
considered as biostimulants. With the amendment as proposed during the meeting
(“influencing their growth other than as nutrients or stimulating natural processes to
benefit nutrient uptake, nutrient efficiency and/or tolerance to abiotic stress”), the
elicitors would no longer be within the scope of Regulation (EC) No 1107/2009, and this
cannot be the intention. Moreover, the wording “natural processes” is not very clear,
and seems to go beyond “life processes of plants”. These “natural processes” might be
understood as occurring in the soil layer, and this should certainly not be within the
scope of Regulation (EC) No 1107/2009. With the introduction of a clear definition of
“biostimulant”, the amendment of art. 2.1.(b) might simply be: “influencing the life
processes of plants, such as substances influencing their growth, other than as a
nutrient or biostimulant”. In this way you clearly exclude the biostimulants, without the
risk of deleting unintentionally any other type of substance from the definition of active
substance.
So two things are important :
- the definition of biostimulant
- the clear exclusion of certain substances (in an article, in the definition or in a
negative list): water, elicitor, …
4)
Negative list
Concerning the negative list : The proposal to exclude non-approved active substances
under the PPP Regulation cannot be supported. It is important to understand that there
can be very different reasons behind a decision for non-approval, such as:
a.
An existing active substance (i.e. a substance on the market on the date of
applicability of Directive 91/414/EEC) which was not supported in the context of the
review program of all existing active substances;
b.
An existing active substance for which the dossier submitted in the context of
the review program was considered incomplete;
c.
An active substance for which the risk assessment did not lead to the
conclusion that a safe use is possible.
Obviously, you cannot exclude a substance a priori as a biostimulant because one day it
has been used in a Member State as a pesticide active substance, and subsequently no
approval was sought in the context of the existing active substances review program.
Further, the data requirements in the context of the PPP legislation are very extensive,
and go far beyond what is intended to be requested for a biostimulant. A dossier
considered as incomplete in the context of the PPP legislation, and therefore deemed to
trigger a negative decision in this context, may very well be considered sufficient to
support the substance successfully as a biostimulant.
5)
Negative list for fertilisers
Specific example : Phosphite
Potassium phosphonates and disodium phosphonate are included in annex I of the PPP
regulation and MRLs have been set.
15/05/2014
Place Victor Hortaplein 40, Box 10 ● 1060 Brussels ● www.health.fgov.be