Some plant protection products and biocidal products are based on low-risk active substances. The corresponding assumption is that using these products entails few risks for humans and the environment. Based on health and environmental considerations, these products are therefore preferable. However, it is challenging to include the concept of ‘low-risk products’ in legislation. This is because the assumption that the use of the product entails few risks must be converted into a decree stating that this is actually the case. The decree must therefore clearly indicate which products are low-risk and which are not.
The EU Regulation for Plant Protection Products and the EU Regulation for Biocidal Products both contain provisions for the authorisation of ‘low-risk products’. These two regulations have taken different approaches.
Besides these EU regulations, the Pesticides Exemption Scheme (RUB) is still in force in the Netherlands. The RUB specifies low-risk products that can be placed on the market in the Netherlands without regular authorisation. Few of these products have undergone a risk assessment. As a result, the RUB no longer complies with European legislation. To place plant protection products and biocidal products on the market, risk assessments must now be performed on these products in accordance with current EU regulations. As a result, the RUB can be withdrawn.