Удължаването на разрешенията за активни вещества в пестициди в ЕС – нова съдебна рамка

Extending approvals of pesticide active substances in the EU — a new judicial framework

ByVia Pontica

In a judgment published on 19 November 2025, the General Court of the European Union ruled that the temporary extension of approvals for active substances used in plant protection productscannot be applied automatically or systematically. Curia+2PAN Europe+2

Context and legal framework

Under Regulation (EC) No 1107/2009, plant protection substances may be approved for a maximum of 10 years and may be renewed for a period not exceeding 15 years.Curia+1At the same time, the European Commission may grant a temporary extension where the approval period has expired and a renewal decision has not yet been taken.Curia

The cases (T-412/22, T-94/23 and T-565/23) challenged amendments to implementing regulations extending the approval periods of active substances such as boscalid, dimoxystrobin and glyphosate.Curia+2PAN Europe+2

The Court’s findings

The Court held that granting a temporary extension should be theexception, not the rule. An extension must be justified case by case, its duration calculated against what the renewal procedure actually requires, and it must not be used as a systematic mechanism for maintaining an approval outside the legal order.Curia+1

Furthermore, granting an extension is conditional on verifying whether the delay in the assessment was to a significant extent caused by the applicant for renewal itself — for example by submitting an incomplete data package, or through other delays attributable to the applicant.Curia+1

Significance for policy and practice

The judgment has several key implications:

  • First, it confirms that the extension regime must not become anautomaticinstrument for keeping active substances on the market without an up-to-date risk assessment.

  • Second, it strengthens the priority of human health, environmental protection and biodiversity over administrative or economic interests — in line with the precautionary principle.PAN Europe+1

  • Third, it directs national competent authorities and stakeholders (industry, NGOs, civil society) towards stricter discipline regarding data submission, deadlines and transparency in approval renewal procedures.

A message for Bulgaria and the Black Sea region

For Bulgaria, and in particular for the coastal ecosystems of the Black Sea, this judgment establishes an important framework:

  • Control over pesticide use must take into account that the extension of approvals cannot be treated as a routine or standard procedural step.

  • Every extension request should require clear reasoning: why it is necessary, which stages of the assessment remain, what interim conditions apply, and how long a period is allowed until the renewal is completed.

  • As an environmental organisation we can monitor renewal procedures for active substances, request public access to information and insist on accountability regarding the data submitted by applicants.

  • In the context of regional risks — for coastal waters, water bodies, coastal biodiversity and fishing communities — it is particularly important to ensure that no substances remain on the market whose assessment is outdated, incomplete or out of step with current scientific standards.

Conclusion

The General Court’s judgment sets a clear framework: the temporary extension of approvals for active substances must be strictly justified, limited in time and aimed at completing a genuine assessment — not an automatic mechanism. For Bulgaria and for regions sensitive to chemical and agro-industrial pressures, this is an opportunity to establish a policy based on scientific evidence, transparency and prevention.

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