Van: Martin Andermatt
[andermatt@biocontrol.ch]
Verzonden: maandag 16 mei 2005
17:13
Aan: Willem Ravensberg
Onderwerp: SANCO D3 working
document concerning 91/414
Dear Dr. Ravensberg
I would like to confirm my astonishment, that in
the Draft SANCO D3 working document concerning the Council Directive 91/414
"nematodes used in or as plant protection" shall be assimilated to
micro-organisms.
If nematodes-based products would have to be
registered according to the new 91/414, such products would disappear from the
market, because a return of the investments for a registration file by the
sales of these products is not possible (even if all European producers would
build a taskforce).
The absence of any problems on each level of the
sales chain and on the level of endusers of nematodes-based products in
Europe over the last 20 years should be regarded as a sufficient proof, that no
registration for indigenous nematodes is necessary (as it is also the case for
beneficials insects and mites).
Yours sincerely
Dr. Martin Andermatt
Geschäftsführer/Managing
Director
Andermatt BIOCONTROL AG
Stahlermatten 6
CH-6146
Grossdietwil
Tel. ++41 (0)62 917 50 05
Fax ++41 (0)62 917 50 06
www.biocontrol.ch