Fic rEcommEndationS - Eurobank EFG

Content of the labels (declaration and instructions for use)
for plant protection products (PPPs) is regulated by two
rule books, the Rule Book on Classification, Labelling and
Marketing of Chemicals (Official Gazette of RS, No 59/2010)
and the Rule Book on Methods for Monitoring Pesticide
(Official Gazette, No 63/2001).
Producers and importers are required to classify, label and
pack all the chemicals, including PPPs, in accordance with
the existing regulation(s).
Rule Book on Classification, Labelling and Marketing of
Chemicals, stipulates that we must change all the labels by
1 October 2011, both for the newly imported or produced
chemicals, including PPPs, and the products that are already
on the market.
The Rule Book on Methods for Monitoring Pesticide states
in Article 37: “The declaration and instructions for use are
prepared in accordance with Article 69 of the Plant Protection
Act (Official Gazette of FRY No. 24/98) and must be
consistent with the certificate issued for placing products
on the market.”
In order to change the labels, we first need to change the
existing certificates issued by the Ministry of Agriculture
for about 900 PPPs that are registered in Serbia, which can
hardly be completed by October 2011.
After that, we should change both the declarations and instructions
for use for PPPs that have already been imported
and are in our warehouses or on the market. This is impossible,
given the number of distributors, agricultural pharmacies,
cooperatives and other entities.
Fic rEcommEndationS
We have to keep in mind that PPP labels are also required
to have:
A declaration, printed directly on the packaging or affixed
to it, and
Instructions for use, usually in the form of booklets, either
attached to the declaration or inserted into individual
cases together with the packaging.
Once a PPP is packed, any change of either declaration or
instructions for use is practically impossible, and would require
a repackaging of the PPP and destruction of the remaining
packaging.
PoSitiVE dEVELoPmEntS
The Ministry of Agriculture has posted the instructions for
amendments to the PPP Certificate on its website on 10
June 2011.
rEmaininG iSSUES
Relabelling packaging of PPPs that are already on the
market or in our warehouses or destroying the packaging
that could not be relabelled;
Destruction of already printed labels, currently on stock
at producers’ level;
Possible consequences if process of PPP certificates’
amendment not completed before the Ministry of Agriculture
and therefore there was no possibility to change
labels for products that we import after 1 October 2011.
Request the Ministry of Environment to extend the deadline for the adoption of the rule book in the case of PPPs,
due to the complicated procedure of labels’ change;
Request the Ministry of Agriculture to speed up the amendment of certificates, once they have been submitted.
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