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Food and feed safety  Simplification omnibus

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Food and Feed Safety – Simplification Omnibus Initiative, launched by the European Commission, represents an important opportunity to reflect on how existing systems work in practice, and how they could be improved without compromising safety.

 

We were pleased to contribute to this initiative by submitting our feedback to the Commission. Below, we explain what this initiative is about, why it matters, what outcomes it could deliver, and highlight some of the key points from our contribution.

What is the Food and Feed Safety Simplification Omnibus Initiative?

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The initiative is part of the Commission’s broader Better Regulation agenda, aimed at identifying opportunities to simplify EU legislation and its implementation. Rather than weakening safety standards, the focus is on:

  • Reducing unnecessary administrative burden

  • Improving efficiency and predictability

  • Supporting innovation, particularly for SMEs and startups

  • Ensuring regulatory systems remain science-based and future-proof

For food, feed, and related sectors, this is particularly relevant. Many regulatory requirements are well established and robust — but the way risk assessment is applied in practice can significantly influence costs, timelines, and innovation outcomes.

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Picture from: https://www.finance-watch.org/blog/better-regulation-an-introduction/?utm_source 

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Picture from: https://www.efsa.europa.eu/en/discover/infographics/risk-assessment-vs-risk-management-whats-difference?utm_source

Why this initiative matters for innovation

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Across global regulatory systems, safety goals are often aligned. What differs is how risk assessment is framed, communicated, and operationalised.

In the EU, applicants frequently interpret regulatory requirements as fixed checklists of studies, rather than as tools to test specific risk hypotheses. This can lead to:

  • Over-testing and high regulatory costs

  • Studies with limited relevance or inconclusive value

  • Extended approval timelines and uncertainty

  • Disproportionate impacts on startups and SMEs

These challenges are particularly acute for innovative biological solutions (e.g. biopesticides, microbial products, dsRNA), which do not fit neatly into chemical-centric assessment templates.

The simplification initiative matters because it opens the door to procedural and technical improvements that could deliver real impact without requiring major legislative reform.

What outcomes could this initiative deliver?

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If implemented effectively, the initiative could help to:

  • Improve the quality and relevance of submitted dossiers

  • Reduce avoidable delays and “stop-the-clock” procedures

  • Increase predictability for innovators and investors

  • Strengthen regulators’ ability to assess novel technologies

  • Accelerate access to safer, more sustainable solutions

In short, it can help ensure that innovation does not stall while safety remains fully protected.

In our submission, we focused on practical, implementable actions based on real-world experience supporting startups and SMEs navigating EU food and feed safety regulations. Some of the key proposals include:

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  • Improving early access to risk-assessment expertise

We proposed creating a public, non-endorsement roster of experienced regulatory consultants, hosted by authorities, to help applicants design fit-for-purpose testing strategies early on. This would reduce unnecessary studies and improve dossier quality from the outset.

 

  • Expanding assessment capacity through external experts

To address capacity constraints, especially for innovative products, we suggested allowing independent, conflict-free external assessors to support authorities with scoped technical reviews — while keeping decision-making firmly with regulators.

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  • Prioritising innovative and low-risk solutions

Introducing transparent, EU-wide prioritisation mechanisms could ensure that innovative biologicals are assessed earlier, while routine renewals are managed more efficiently.

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  • Investing in targeted capacity building

Risk assessment for novel technologies is becoming increasingly complex. We highlighted the need for specialised training and upskilling within authorities, building on existing EU tools such as BTSF-style programmes.

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  • Making regulator–applicant dialogue continuous and risk-focused

Moving beyond one-off pre-submission meetings towards structured, ongoing technical dialogue can significantly improve study design, reduce uncertainty, and shorten overall evaluation timelines.

These proposals aim to improve how risk assessment is conducted and communicated, rather than rewriting the underlying legislation.

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