Position papers

Joint Statement: Comitology Reform Threatens Innovation

Read our joint statement on the planned comitology reform. 

We, European Associations representing a wide number of economic sectors affected directly or indirectly by comitology rules, re-iterate1 the request for timely, reliable authorisations of safe products, based on the best available science from the EU’s own risk assessment agencies. Such decisions are central for innovation, continued investments, jobs and growth, as well as consumer confidence and safety in the EU. Innovation, in turn, is critical to achieving the goals of the European Green Deal2 and the EU’s industrial strategy3.

We regret that the changes to the comitology system proposed by the Commission4 would not help on any of the above goals, nor are they likely to promote social acceptance of innovation. Instead, the proposed changes would make the processes for product authorisations even more complex and less predictable.

The Plenary of the European Parliament is expected to vote on 16 December 2020 on an amended version of the Commission’s proposal5 which would revert the logic from currently ‘approve when safe’ to ‘approve only when popular’. Concretely, amendments 5, 7, and 16 would enable a minority of Member States to block authorisations of products, even if their safety is confirmed by the risk assessment agencies. This would make authorisations of certain products de facto impossible and would undermine science-based decision-making processes.

Therefore, we disagree with the proposed comitology reform and urge decision-makers in particular to reject the legal affairs committee’s amendments 5, 7 and 16.


Comitology refers to a set of procedures through which EU countries control how the Commission implements EU law. Comitology procedures inter alia apply to pre-market product authorisations, and typically involve the Commission consulting a committee of experts from the Member States (Standing Committee) on draft implementing acts authorising products. If the Member States do not reach a qualified majority in favour or against, the Commission refers to the Appeal Committee. In case of no opinion even in the Appeal Committee, the Commission approves the product supported by the EFSA’s scientific opinion.

The Commission’s ‘comitology reform proposal’ from 20176 contains the following three main changes:

- Change of voting rules: At the Appeal Committee, abstaining Member States would be seen as “non-participating”. This would in some cases threaten the approval of safe but ‘politically sensitive’ products.

- Additional votes and delays: Introduction of up to two additional rounds of voting.

- Other proposed changes: Quorum of participating Member States; publication of Member States votes.

Amendments 5,7 & 16 adopted by the European Parliament’s legal affairs committee7:

The present comitology regulation provides for a rather science-based system: It essentially foresees that products should be authorised when proven safe. Vetoing the approval of a safe product requires the qualified majority of Member States (55% of the Member States representing 65% of the EU’s population).

The proposal by the EP legal affairs committee (especially amendment 16) essentially foresees that political opinions are more important than the extensive scientific evidence assessing the safety of products. According to the committee, products should only be authorised when they have political support by a qualified majority of Member States (55% of the Member States representing 65% of the EU’s population). This, in turn, means that a minority of Member States could block the approval of safe products.

1 See also Joint Statement of February 2017

2 Communication from the EU Commission: The European Green Deal, COM/2019/640 final

3 Communication from the EU Commission: A New Industrial Strategy for Europe COM/2020/102 final

4 Proposal for a Regulation amending Regulation (EU) No 182/2011 laying down the rules and general principles concerning mechanisms for control by Member States of the Commission’s exercise of implementing powers. COM (2017) 85 final, 14 February 2017.

5 Report adopted by the Committee for Legal Affairs, A9-0187/2020, 12 October 2020

6 As referenced in footnote 2

7 As referenced in footnote 3


Download the full statement below.