Session Overview:
The DEA “face to face” consultation held on the 8th of February proved to be both beneficial and positive from the perspective of CTFA members, the CTFA and the DEA. Ms Natalie Feltman: Director of Bioprospecting and Biodiversity Economy and Ms Lactitia Tshitwamulomoni; Deputy Director of BABS Policy Development and Implementation within the Department of Environmental Affairs (DEA) were on hand to provide guidance, feedback and listen to individual company concerns. The DEA graciously agreed to this interface with CTFA members, despite their tight schedules and the variation to their standard process. The DEA, CTFA and members agreed ta work together in keeping the lines of communication open to reach the required resolutions.
Some major aspects discussed were: responsibilities and regulatory requirements for each role player within the value chain, industry awareness on the inroads made by DEA on permitting and requirements with regards to specific industry-related cases, regulatory awareness and compliance, complexity of regulation and processes and the need for broader industry regulatory awareness.
The sessions also allowed DEA to share some key insights with members such as:
- Ensuring that raw materials are purchased from permitted suppliers (i.e., Suppliers in possession of either a Biotrade Permit or an integrated Biotrade and
Bioprospecting permit.) These are in cases where formulators or contract manufacturers do not engage with the communities directly, - Consulting the SANBI website- to identify plant materials that are indigenous to South Africa and additionally reference some basic information on the traditional uses of such plant materials. (www.plantzafrica.com)
- Specific new innovation concepts could require consultation with various role players to reach consensus and identify accountabilities,
- Telephone discussions with the DEA followed by mail correspondence-assist DEA for traceability and matter progression,
- The DEA accommodates company-specific meetings at their PTA Offices- to provide guidance on the process in order to ensure compliance with the BABS Amendment Regulations,
- DEA, Bioprospecting and Biodiversity Economy Directorate will inform the DEA Compliance and Enforcement team of companies that they are currently working with on achieving compliance,
- An umbrella permit application can be made for a number of plant materials and products falling within the same category,
- Permit validity in general would be for 5 years – dependent on type and nature,
- Other role players in the value chain such as contract manufacturers and brand owners could be accommodated by raw material suppliers in product utilisation via the set-up of inclusive BSA‘s (Benefit Sharing Agreements),
- DEA tools available on their website for industry guidance includes: BABS Guidelines, Posters, FAQ, BABS Regulations, Biodiversity Act, Application Forms, MTA template, BSA template, Community Resolution template and Consent Letter for Subsequent Biotrader template. (www.environment.gov.za)
A special thank you to members for their attendance and active participation.