# Karate Zeon: eight emergency authorisations in eight consecutive years.

EU rules permit emergency pesticide authorisations lasting no more than 120 days. Germany issued one for Karate Zeon on raspberries against Drosophila suzukii in every year from 2016 through 2023. Each was valid for exactly 120 days.

**What stays constant:** The product, active substance, holder, crop code and pest code. The national authorisation number changes every year.

## Seasonal file: Karate Zeon · lambda-cyhalothrin

Rubus idaeus (RUBID) · Drosophila suzukii (DROSSU). Germany.

| Year | Entry into force | Expiry | days | No. |
| ---: | --- | --- | ---: | --- |
| 2016 | 2016-06-24 | 2016-10-21 | 120 | 139417-1 |
| 2017 | 2017-06-15 | 2017-10-12 | 120 | 172205-2 |
| 2018 | 2018-06-15 | 2018-10-12 | 120 | 213884-1 |
| 2019 | 2019-06-13 | 2019-10-10 | 120 | 258163 |
| 2020 | 2020-06-30 | 2020-10-27 | 120 | 297074 |
| 2021 | 2021-07-19 | 2021-11-15 | 120 | 338513 |
| 2022 | 2022-06-15 | 2022-10-12 | 120 | 377387 |
| 2023 | 2023-06-15 | 2023-10-12 | 120 | 423852 |

The bars reproduce the entry-into-force and expiry dates in the database. Adding the windows does not measure actual use or exposure.

## The law opens a short window

Article 53 of Regulation (EC) No 1107/2009 allows a Member State, in special circumstances, to authorise the limited and controlled use of a plant-protection product. The period may not exceed 120 days, and the danger must be one that cannot be contained by other reasonable means.

Repetition alone does not establish unlawfulness. Paragraph 3 allows the Commission to decide whether, and under what conditions, a Member State may extend or repeat the measure. Commission guidance says repeats should generally be avoided and calls for a clearly explained, continuing emergency.

Each record presents a temporary decision. In sequence, the decisions describe an agricultural period that returns to the calendar.

## Eight numbers identify the same combination

The conservative match requires the same country, normalised trade name, active substance, holder, crop code RUBID and pest code DROSSU. All eight rows pass that test.

- **Product:** Karate Zeon
- **Active substance:** lambda-Cyhalothrin
- **Holder:** Fachgruppe Obstbau
- **Shared crop:** Rubus idaeus · raspberry · RUBID
- **Pest:** Drosophila suzukii · DROSSU
- **Country:** Germany · DE

The rows may cover additional crops. Raspberry is the crop present in all eight records and used in the strict match.

## Recurrence covers most of the analysed database

Karanasios and colleagues, authors of an external scientific report produced under an EFSA grant, analysed 4,761 grant records. Under their definition, 77.0% were recurrent. Repeats limited to one calendar year account for 0.9 percentage points; the two- to eight-year categories sum to 76.1%.

- **4,761:** authorisation records in the analysed database
- **77%:** classified as recurrent by the report authors
- **≈76%:** in recurrence spanning at least two years

The 77% figure belongs to the report authors and uses their broader definition. This project did not recreate the grouping of all 4,761 rows.

## Four sequences meet a stricter test

We required the same country, trade name, active substance, EPPO crop and EPPO target to appear in every year from 2016 through 2023. Records matching more than one equivalent code pair were counted once. Four sequences and 32 distinct rows remain.

| Country and product | Tracked pair | Annual evidence |
| --- | --- | --- |
| Germany · Karate Zeon | raspberry (RUBID) · D. suzukii (DROSSU) | 8 years · 8 rows · 8 distinct entries in the authorisation-number field |
| France · Exirel | Prunus domestica (PRNDO) · D. suzukii (DROSSU) | 8 years · 8 rows · 8 distinct entries in the authorisation-number field |
| Germany · CURATIO | pome fruit plants (NNNOK) · D. coronariae (DIPCML) | 8 years · 8 rows · 8 distinct entries in the authorisation-number field |
| Slovenia · CURATIO | quince (CYDOB) · V. inaequalis (VENTIN) | 8 years · 8 rows · 8 distinct entries in the authorisation-number field |

The test looks for continuity in an exact combination. It is not a new prevalence estimate and does not assess the grounds for any decision.

## The sequence shows an administrative rhythm

### What the data show

- Every database year from 2016 through 2023 contains a new German record for the strict Karate Zeon + RUBID + DROSSU combination.
- The eight entries in the authorisation-number field are distinct, and each displayed window spans 120 calendar days when both endpoints are included.
- In the external report's tables, 76.1% of records belong to recurring categories that span between two and eight years.

### What the data leave open

- the lawfulness or adequacy of an individual authorisation
- the amount used in the field, exposure, or any health or environmental effect
- the institutional reason for repetition and the availability of a reasonable alternative

A register organised around separate decisions leaves the temporal pattern in the background. A longitudinal view turns it into a precise public question: what continuing emergency supports the return, and what durable remedy is being pursued?

## An auditable match and its limits

The workbook is Appendix E to the external report and contains 4,761 data rows across 114 fields. We archived a local copy with the SHA-256 fingerprint below, then extracted only the rows needed for the four sequences.

The case study uses database years 2016–2023. Its 2016 records begin in June, while 2013, 2015 and 2024 are sparse in the snapshot. The page therefore says “every database year” and does not describe the interval as a complete census.

The expanded database used by the report also contains rows for the United Kingdom, Norway and Iceland. Each claim identifies the country of its case; the page does not treat all 4,761 rows as grants from current EU Member States.

The Commission warns that the database has no legal value, may be incomplete or inaccurate, and contains information for which Member States remain responsible. The rows are used here as a research source; the national acts remain the legally relevant documents.

Duration is calculated as expiry minus entry into force, plus one day. Some rows in the other strict sequences exceed 120 under that inclusive convention; this is a data-quality signal, with no legal inference. The displayed Karate Zeon case contains eight intervals of exactly 120 days.

- **Source:** Appendix E, Database sheet, range A1:DJ4762
- **Match:** country + normalised product + substance + crop code + target code
- **Continuity:** at least one row in every year from 2016 through 2023
- **Audit trail:** sheet rows, national references, dates, codes and executable checks
- **Fingerprint:** afb20a3d4fbde21edea00a03f2ce2443f15b18b84902338797335df6d6b94b70

## The register, the rule and the report

- [External scientific report](https://efsa.onlinelibrary.wiley.com/doi/10.2903/sp.efsa.2025.EN-9499): Karanasios and colleagues, 2025. Aggregate results and recurrence definition.
- [Appendix E · source workbook](https://efsa.onlinelibrary.wiley.com/action/downloadSupplement?doi=10.2903%2Fsp.efsa.2025.EN-9499&file=efs39499e-sup-0002-Appendix_E_Modified_database_v2.xlsx): Rows, dates, products, crops and pests used in the reconstruction.
- [Regulation (EC) No 1107/2009](https://eur-lex.europa.eu/eli/reg/2009/1107/2026-06-16/eng): Article 53, the conditions and time limit for emergency authorisations.
- [Commission guidance on Article 53](https://food.ec.europa.eu/system/files/2016-10/pesticides_aas_guidance_wd_emergency_authorisations_article53_en.pdf): Expectations for reasoning, a continuing emergency and repeat measures. The Commission currently marks it “under review”.
- [European Commission database](https://food.ec.europa.eu/plants/pesticides/eu-pesticides-database_en): The public access point for emergency plant-protection product authorisations.

The report is external scientific work produced under an EFSA grant agreement. The document states that it is not an output adopted by EFSA.

This page publishes derived factual analysis and links to its sources. It does not redistribute the complete workbook.

- [Derived data (JSON)](https://mariuscomper.uk/calendarul-de-120-de-zile/data/repeated-authorisation-series.json)
- [Ediția în limba română](https://mariuscomper.uk/calendarul-de-120-de-zile/)