What is the Multiple-Use Principle?


T his principle affirms that the same component could be used in different products that fulfill different functions and therefore may be regulated under different frameworks. This principle is logical when you think about the fact that copper can be found in chocolate, water pipes, and fertilizers but the concept of "active ingredients" sometimes leads regulators to look at single components out of context. The basic message of the multiple-use principle is that context matters.

EBIC has developed a position paper that advocates for the respect of the multiple-use principle and explains the clear difference between:

  • components (e.g. seaweed extracts, hydrolysed proteins, microorganisms, etc.)
  • a formulation that combines several components, and
  • a product that is applied to certain crops or crop parts at a certain rate, timing and mode of application to fulfill a function claimed on the label.

    The position also provides several examples of multiple-use components used in plant biostimulants and makes a reference to the Frequently Asked Questions (FAQ) document published by the European Commission on the Fertilising Products Regulation (FPR) [Regulation (EU) 2019/1009], which stresses that "if a fertilising product, which complies with all requirements set in the FPR, happens to contain a substance or microorganism known to have a pesticidal or other plant protection effect, it could still be covered by the FPR, as long as this fertilising product does not have a pesticidal or other plant protection function within the meaning of the PPPR".

    Being able to combine components in different formulations to fulfil different product functions is crucial for innovation in the plant biostimulants industry. To provide the predictability necessary for the market to function properly, it is critical that conformity assessment bodies, Member States, and other actors respect the multiple-use principle when considering products under the FPR and national rules.