20/10/2026
The Commission’s Omnibus X rewrites ten EU laws on food and feed safety in one go. The package comprises a proposal for a Regulation amending ten existing Regulations (COM(2025) 1030 final), a proposal for a Directive (COM(2025) 1021 final), and a targeted proposal on data protection under Article 95 of the Biocidal Products Regulation. In September, 573 scientists and doctors asked the European Parliament in an open letter to pause negotiations on the package until an independent impact assessment has been carried out.
Same procedure as before
We have already covered why the omnibus method is an instance of deregulation, not simplification. Omnibus X works the same way. It is the tenth package, and once again there was no impact assessment and little time for consultation. The European Ombudswoman has already found maladministration in earlier packages. Prof. Alberto Alemanno describes the pattern in The Omnibus Road to Constitutional Drift.
Omnibus X: what it changes and how it was made
The Commission proposed Omnibus X in December 2025. The measures include faster market access for biocontrol products, more targeted renewal procedures for pesticides, biocides and feed additives, and simpler lab accreditation. One change matters more than the rest. In the Commission’s text, most pesticide active substances would no longer need periodic renewal and would be reassessed only when concerns arise. BEUC, PAN Europe and foodwatch warn that the package also weakens authorisation procedures, residue limits and import controls.
The process of how it was made further raises concerns. As we reported in EU Deregulation Under Fire Again, the only consultation was a 1.5-page call for evidence, open for four weeks. It drew over 6,440 comments, and the proposal followed two months later, which is rather quick work for a ten-law package. In June, foodwatch filed a complaint with the EU Ombudswoman about how the Commission handled the file.
How it landed in the Parliament
A version of the draft report by Herbert Dorfmann (EPP, AGRI Committee) and Michele Picaro (ECR, ENVI Committee) leaked in June. The co-rapporteurs presented the official text to MEPs on 6 July. It goes further than the Commission: re-evaluating substances becomes optional and harder to trigger, and the three-year grace period for withdrawn products – which the Commission reserved for cases with no alternative – becomes the default. Foodwatch and PAN Europe both read this as a weakening of EU pesticide rules, stating that the rapporteurs drew only on agribusiness input.
After this, around 1,500 amendments followed. Just last week, Corporate Europe Observatory (CEO) published a report comparing the co-rapporteurs’ amendments with lobby documents, arguing that several seem to be demands made by chemical giants Bayer, BASF, CropLife Europe and a farm lobby called Copa-Cogeca.
The scientists’ letter
On 17 September, ecotoxicologist Martina Vijver sent an open letter to Roberta Metsola and the ENVI and AGRI chairs. It carried 573 signatures from researchers and doctors in ecology, toxicology, medicine, public health, physics and law. They asked to pause the process until an independent impact assessment exists. Their worry is that open-ended approvals make it harder to fix past decisions when new evidence arises.
The UN experts join in
The worry of the scientific community has reached UN experts as well. On 7th of October, five independent UN experts sent a letter to the Commission, Parliament and Council. The group consists of the chair of the Working Group on the rights of peasants and four Special Rapporteurs on the environment, food, health and hazardous substances.
They raise the same points as the scientists, but from a human rights perspective. The experts argue that unlimited approvals, longer grace periods, wider derogations and less room for fresh evidence are hard to reconcile with the precautionary principle. They also say farmers and rural workers were barely heard, and that children and other vulnerable groups, whom the current rules specifically protect, would bear the risk. For us, this is also a question of the rights of future generations: those who live with the consequences of a decision the longest have the least say in it.
The letter is a request for clarification. The experts say they are not prejudging the facts per se, they just want to know – among other things – whether the EU will carry out a full impact assessment.
Our take
An impact assessment is how evidence transforms knowledge into legislation, and the Court’s case law on proportionality expects it. Without this, nobody knows what ten rewritten laws do to health and the environment. That is why we keep asking for a Future Generations Impact Assessment in EU policymaking: the long-term effects of open-ended approvals should be weighed before the law changes, not after.
All these letters and expert opinions seem to have generated some movement. As a result, the vote scheduled for 5th of October was postponed until further notice. The letter may not be the reason, but a pause is what the scientific and expert community asked for.
We will keep following the file in our Deregulation Monitor.