Delayed issuance of the state sanitary and epidemiological examination conclusions may lead to the disruption of the spring sowing campaign

28/ 10/ 2021

The European Business Association is extremely concerned about the situation with the issuance of the conclusions of the state sanitary-epidemiological examination of pesticides and agrochemicals, as well as other groups of goods, such as cosmetics and detergents, household appliances, etc. In recent months, the situation has become particularly critical, as due to the de facto suspension of this administrative procedure, approximately 250 CPPs (pesticides and agrochemicals) are unable to complete state trials and, consequently, gain access to the market. Despite the fact that under the law the conclusion must be issued within 10 days from the date of receipt of the application, as of today, the delays have already reached 100 days. This issue has been repeatedly discussed at meetings and in written communication, but to date, the issuance of conclusions is still blocked. Thus, the agrochemical business remains hostage to the situation despite its compliance with all procedures provided by law. Given the fact that obtaining a conclusion is only one of the stages of a complex and lengthy procedure for state registration of pesticides and agrochemicals, the spring sowing campaign appears to be under threat. Manufacturers of drugs may simply not have time to go through the entire procedure and deliver products before the start of the season. Given that the timely and proper use of drugs is the basis for a quality and safe harvest, such unjustified delays in permitting procedures can lead to both poor quality and reduced yields. It is worth reminding that from 20 to 40% of the crop is lost due to the invasion of pests as reported by the FAO. Accordingly, proper protection and nutrition of crops are the basis of the food security of the state. Other business industries also report significant delays in issuing conclusions. The business considers that the problems were caused by the reappointment of the leadership of the two Sanitary and Epidemiological Commissions, namely the Institute of Occupational Medicine of Y.I. Kundieva and the Center for Preventive Medicine of Public Administration, that are responsible for the protocols. Based on these protocols, the State Service of Ukraine on Food Safety and Consumer Protection signs the conclusions. As the consequence, 3000 sanitary and epidemiological conclusions were stuck for a long time in the State Food and Consumer Service with an uncertain status and were only recently returned for re-signing to the above-mentioned Commissions. This, in turn, led to the disruption of a number of contracts and economic damage for many companies, which could not get a sanitary-epidemiological conclusion in time and put certain products on the Ukrainian market. That is why the European Business Association appeals to the Prime Minister of Ukraine, the Minister of Economy of Ukraine, the Minister of Health of Ukraine, the Minister of Agrarian Policy of Ukraine, and the State Service of Ukraine on Food Safety and Consumer Protection to unblock the issuance of state sanitary and epidemiological examinations for pesticides and agrochemicals. The EBA emphasizes that it is important to speed up the procedure of signing 3,000 sanitary and epidemiological conclusions, which were recently transferred back to the Institute of Occupational Medicine of Y.I. Kundieva and the Center for Preventive Medicine of Public Administration. Moreover, such situations should not be repeated in the future. After all, for the normal operation of the business and the creation of a favorable business environment, it is critical to have a timely issuance of permits, as well as a simple and clear procedure. Be the first to learn about the latest EBA news with our Telegram-channel – EBAUkraine.

In recent months, the situation has become particularly critical, as due to the de facto suspension of this administrative procedure, approximately 250 CPPs (pesticides and agrochemicals) are unable to complete state trials and, consequently, gain access to the market.

Despite the fact that under the law the conclusion must be issued within 10 days from the date of receipt of the application, as of today, the delays have already reached 100 days.

This issue has been repeatedly discussed at meetings and in written communication, but to date, the issuance of conclusions is still blocked. Thus, the agrochemical business remains hostage to the situation despite its compliance with all procedures provided by law.

Given the fact that obtaining a conclusion is only one of the stages of a complex and lengthy procedure for state registration of pesticides and agrochemicals, the spring sowing campaign appears to be under threat. Manufacturers of drugs may simply not have time to go through the entire procedure and deliver products before the start of the season.

Given that the timely and proper use of drugs is the basis for a quality and safe harvest, such unjustified delays in permitting procedures can lead to both poor quality and reduced yields. It is worth reminding that from 20 to 40% of the crop is lost due to the invasion of pests as reported by the FAO. Accordingly, proper protection and nutrition of crops are the basis of the food security of the state.

Other business industries also report significant delays in issuing conclusions. The business considers that the problems were caused by the reappointment of the leadership of the two Sanitary and Epidemiological Commissions, namely the Institute of Occupational Medicine of Y.I. Kundieva and the Center for Preventive Medicine of Public Administration, that are responsible for the protocols. Based on these protocols, the State Service of Ukraine on Food Safety and Consumer Protection signs the conclusions. As the consequence, 3000 sanitary and epidemiological conclusions were stuck for a long time in the State Food and Consumer Service with an uncertain status and were only recently returned for re-signing to the above-mentioned Commissions. This, in turn, led to the disruption of a number of contracts and economic damage for many companies, which could not get a sanitary-epidemiological conclusion in time and put certain products on the Ukrainian market.

That is why the European Business Association appeals to the Prime Minister of Ukraine, the Minister of Economy of Ukraine, the Minister of Health of Ukraine, the Minister of Agrarian Policy of Ukraine, and the State Service of Ukraine on Food Safety and Consumer Protection to unblock the issuance of state sanitary and epidemiological examinations for pesticides and agrochemicals.

The EBA emphasizes that it is important to speed up the procedure of signing 3,000 sanitary and epidemiological conclusions, which were recently transferred back to the Institute of Occupational Medicine of Y.I. Kundieva and the Center for Preventive Medicine of Public Administration. Moreover, such situations should not be repeated in the future. After all, for the normal operation of the business and the creation of a favorable business environment, it is critical to have a timely issuance of permits, as well as a simple and clear procedure.

Be the first to learn about the latest EBA news with our Telegram-channel – EBAUkraine.