15 November 2010 EMA/CVMP/EWP/324712/2010 Committee for Medicinal Products for Veterinary Use (CVMP) Overview of comments received on 'Guideline on veterinary medicinal products controlling varroa destructor parasitosis in bees' (EMEA/CVMP/EWP/459883/2008-CONSULTATION) Interested parties (organisations or individuals) that commented on the draft document as released for consultation. Stakeholder no. Name of organisation or individual 1 Danish Beekeepers Association 2 7 Westferry Circus ● Canary Wharf ● London E14 4HB ● United Kingdom Telephone +44 (0)20 7418 8400 Facsimile +44 (0)20 7418 8416 E-mail
[email protected] Website www.ema.europa.eu An agency of the European Union © European Medicines Agency, 2014. Reproduction is authorised provided the source is acknowledged. 1. General comments – overview Stakeholder General comment Outcome No. 1 The vast majority of beekeepers provide beeswax-foundation Indeed, some acaricides can lead to residues in honey. Honey always contains for their bees based on recycled beeswax from old comb. wax. Both water soluble and organic solvent soluble substances may end-up in honey. Some hydrophobic veterinary medicinal products or their metabolites may contaminate the beeswax and lead to In relation to the potential contamination of honey with residues transferred increasing levels by repeated recycles of beeswax from from wax it should be noted that the MRL set for honey does not distinguish treated colonies. The accumulation is dependent on the between residues incurred as a result of treatment and residues incurred as a stability of the compounds to the heat-treatment in the wax- result of transfer from wax. In addition, it is acknowledged that wax particles melting process.