Simplifying European rules may be a legitimate objective, but it should not mean reducing health protection guarantees. This, in summary, is the message launched by ISDE Italia, the Associazione Culturale Paediatricians (ACP) and the European Confederation of Primary Care Paediatricians (EPCCP), who have written to the Italian and European institutions while the examination of the Food and Feed Safety Omnibus continues, in an initiative developed in coordination with PAN Europe.
The same appeal was also brought to an international level together with ISDE International, with a letter sent to the President of the European Commission Ursula von der Leyen and to the MEPs.
This is a legislative package presented by the European Commission on 16 December 2025 with the aim of simplifying and lightening some procedures and administrative burdens relating to food and feed safety, official controls, plant protection products and biocides.
And it is precisely the part relating to pesticides that worries health organizations. In the document entitled “Health before simplification“, the signatories identify four points which, in their opinion, risk weakening the European system of protection from exposure to dangerous substances. The principle from which their appeal starts is clear:
Simplifying procedures is a legitimate objective, but it must not mean reducing health protection or limiting the use of the best and most up-to-date scientific evidence.
What does European simplification entail?
To understand the issue we need to start from one point: the Food and Feed Safety Omnibus is not a new law on pesticides, but a package that simultaneously modifies various European regulations on food safety and the management of certain substances and products.
The Commission’s stated objective is to make the regulatory framework simpler and more efficient, eliminating procedures considered redundant and reducing administrative burdens, without lowering protection standards.
In the case of pesticides, however, the proposed changes also affect the way in which the substances are reviewed and the conditions that can allow them to remain on the market.
And this is where the appeal of doctors and pediatricians is concentrated.
What doctors and pediatricians ask
The first point raised concerns the possibility of eliminating the mandatory periodic reassessment of pesticides. In fact, the authorization of a substance does not mean that scientific knowledge about it necessarily remains unchanged over time. New evidence may change what we know about its effects and possible risks.
According to the signatory organizations:
Removing periodic reassessment of pesticides risks delaying the integration of new scientific knowledge into regulatory decisions.
The request is therefore to maintain the mandatory periodic reassessment of pesticides, so as to allow regulatory decisions to take into account the evolution of available scientific evidence.
The second point concerns possible exemptions for substances which, based on the danger criteria, should be excluded. In the document, the signatories contest in particular a modification to article 4.7 which could allow the use of some substances which should instead be excluded on the basis of criteria linked to their dangerousness to be extended for up to five years.
This is an important issue because, in the European system, the evaluation of pesticides does not only concern how much a person could be exposed to a substance, but also the hazard characteristics of the substance itself.
The associations therefore ask that exemptions not be introduced that could allow substances recognized as problematic to be kept on the market for longer.
Then there is another issue raised in the letter, which concerns the so-called grace periods. In fact, when a pesticide is banned, its exit from the market is not always immediate, there may in fact be periods during which stocks are disposed of or a transition is allowed.
According to the signatories, the changes contained in the Omnibus could allow these periods to be extended by up to three years even for already banned pesticides, including some endocrine disruptors. The request is therefore to reject tolerance periods considered excessively long for substances recognized as dangerous.
Science must guide decisions
Finally, there is a more general principle underlying the appeal. The organizations ask that, even after the initial authorization of a pesticide, authorities can continue to consider new scientific evidence. In other words, authorization today should not prevent a substance from being reconsidered tomorrow, if new and relevant data emerge in the meantime.
For the signatories, public health decisions should be made using the best and most up-to-date scientific evidence available at the time they are adopted, also applying the precautionary principle.
This is particularly important in the case of substances for which research continues to produce new knowledge on long-term effects.
In the document, an important part of the attention is devoted to endocrine disruptors, i.e. substances capable of interfering with the normal functioning of the hormonal system. The signatories recall that some pesticides may have endocrine-disrupting properties and that these substances have been associated with effects on the reproductive system, metabolism and neurodevelopment, as well as some hormone-dependent tumors.
This does not mean that exposure to a certain pesticide automatically causes one of these effects: the risk depends on the substance, dose, duration and method of exposure, as well as individual characteristics.
The reason why pediatricians and doctors ask for particular attention is above all linked to the critical windows of development. Pregnancy, fetal life, childhood and adolescence are periods in which some body systems are still developing and during which certain exposures can have lasting consequences.
The document also mentions the categories that may be more exposed to pesticides, such as farmers, agricultural workers and rural communities.
The European comparison is still open
The document arrives as the Food and Feed Safety Omnibus continues its process in the European institutions. It is precisely at this stage that the associations decided to turn to political decision makers, asking that the possibility of updating the assessments in light of new scientific knowledge be maintained in the changes to the legislation.
Their position is also shared by important international scientific societies such as the Endocrine Society, European Society of Endocrinology and European Society for Pediatric Endocrinology. The document also cites, as further supporting elements, an independent scientific analysis commissioned by the Dutch Parliament and contributions from researchers published on Science.
Beyond the conflict over the simplification of procedures, the appeal therefore poses a very concrete question, namely how to ensure that the rules on pesticides can continue to update when scientific knowledge changes.
Ultimately, the point is to ensure that simplification does not become an obstacle to the institutions’ ability to incorporate new evidence and strengthen protections, especially when the health of children and other more vulnerable groups of the population are at stake.
