EU and GB MRL changes in 2024 (August-November 2024)

NEWS
  • 01/12/2024
  • Posted by: Gaetan Dermien
  • Category: Uncategorized
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Changes to EU and GB pesticide maximum residue levels

COLEAD’s monitoring of pesticide regulations covers maximum residue limit (MRL) changes in both the EU and Great Britain (GB). Note that EU MRLs still apply in Northern Ireland (GB covers only England, Scotland, and Wales).

  • During the period August-November 2024, we have been highlighting significant changes to EU MRLs that affect 23 active substances, 12 of which are important for ACP export horticulture. During this same period, 10 changes to GB MRLs were published, 6 of which are important for ACP export horticulture.
  • During this period, the EU and GB did not notify the World Trade Organization (WTO) of additional proposed MRL changes.
  • Previously, the EU notified the WTO concerning its intention to lower MRLs for acetamiprid (G/SPS/N/EU/787), a widely used insecticide. A review by the European Food Safety Authority identified a lower acceptable daily intake (ADI) and a lower acute reference dose (ARfD), so for certain products lower MRLs are necessary to avoid health risks to consumers. The immediate implementation of the new ARfD caused significant market disruptions. The European Commission informed Member States that they should continue to apply the current MRLs and extended the grace period for implementing the new MRLs from 3 to 6 months. The new MRLs are now expected to come into force around August 2025.

 

How will ACP producers/exporters be affected?

Changes to EU/GB MRLs also apply to products that are exported to the EU/GB. Growers producing for export may need to adapt their practices to meet the new MRL or, if this is not possible, stop using these products and look for an alternative method of pest management.

 

What should ACP producers/exporters do now?

For each plant protection products (PPPs) and crop concerned, the Good Agricultural Practices (GAPs) in place will need to be verified and possibly adapted to ensure compliance with the new MRLs. The GAPs include dose rate, number of applications, and pre-harvest interval. In some cases, adaptations to the GAPs will allow the new MRLs to be met (see Crop Protection database). However, in many cases, especially where the level is reduced to the Limit of Determination (LoD), it may not be possible to meet the new MRL, and growers will have to look for alternative crop protection solutions. This is essential to avoid interception and destruction of exported produce at the EU/GB borders.

In case there is no available alternative, manufacturers can consider the option of requesting an import tolerance. The process for approving an import tolerance MRL in the EU can take time and may imply costs. It is recommended to contact the PPP manufacturer to assess the feasibility.

 

If you have any major concerns about these changes, and fear that you will be left without an effective and locally available alternative, please contact COLEAD at: network@colead.link.

In this news, ‘key active substances’ refer to those used/registered in one or more ACP country on horticultural crops that are frequently exported regionally or internationally. It is based on information extracted from the latest national lists of registered plant protection products made available by 34 ACP countries. To confirm if your country is included and the version of the list of registered products considered in this review, please refer to the list here. While COLEAD makes every effort to provide comprehensive information about relevant regulatory changes, it is possible that some Plant Protection Products (PPPs) or crops relevant to you are not included in our list of key substances/crops. We recommend therefore that you check the final section of this news, which details all the changes entering into application in 2024, to make sure that you are aware of any other changes that could affect you.

This news is a quarterly update designed to inform you of any changes introduced during the past five months. If you require more frequent updates on EU MRL changes, we invite you to visit our AGRINFO website and subscribe to the twice-monthly AGRINFO newsletter on EU regulations.

 

Changes to EU MRLs during the period August-November 2024

The European Commission (EC) has recently published new regulations that change certain EU MRLs. These concern 23 substances, including 12 that are of particular importance for ACP horticulture. These changes are presented in Table 1.

In addition, previous changes are also planned to enter into force in 2024. Overall, the following substances present MRLs changes for key crops entering into force during the period August-December 2024, or later (Table 2):

Clicking on the active substance names above will take you to the relevant AGRINFO records, where you will find more details on the changes and crops affected. Links to records are also provided in Table 1 and Table 2.

Table 2 presents new MRLs for crop-PPP combinations that are important for ACP horticulture entering into force during the period August to December 2024, or later.

 

Changes to GB MRLs during the period August-November 2024

During the period August to November 2024, the GB Health and Safety Executive (HSE) published changes to 10 active substances MRLs within Great Britain, including 6 that are of particular importance for ACP horticulture, see Table 3.

  • Flonicamid (applicable from 30 August 2024)
  • Isotianil (applicable from 30 August 2024)
  • Cyflufenamid (applicable from 7 October 2024)
  • Sulfoxaflor (applicable from 31 October 2024)
  • Methidathion (applicable from 05 May 2025)

In addition, previous changes are also planned to enter into force in 2024. Overall, Table 4 presents substances concerned by MRLs changes for key crops entering into force during the period August-December 2024, or later.

 

Further Proposed MRL changes

All draft regulations on MRL changes are notified to the World Trade Organization (WTO) under the WTO Sanitary and Phytosanitary Information Management System for a commenting period of 60 days. This obligation applies to all member countries of the WTO, as the lowering of MRLs might lead to trade barriers. This is an opportunity to be informed in advance of proposed changes, and to take any necessary action before the new regulation comes into force. It is also an opportunity to submit concerns about potential difficulties (trade barriers) that these changes could create. WTO member countries can submit comments via their WTO National Contact Point.

During the period August-November 2024, no further MRL changes from the EU or GB have been notified to the WTO.

MRL changes for acetamiprid

Acetamiprid is a widely used neonicotinoid insecticide for controlling sucking and chewing pests across a broad range of horticultural crops. It is extensively utilized in ACP countries, with over 600 registered products across 25 countries.

Following a request by the European Commission to review the toxicological properties and MRLs for acetamiprid, EFSA (2024) identified a lower acceptable daily intake (ADI) and a lower acute reference dose (ARfD). For products where the existing MRLs caused the new ARfD to be exceeded, EFSA suggested lower MRLs that present no health risks for the consumer, see Table 5.

In July 2024, the European Union notified the World Trade Organization Sanitary and Phytosanitary Measures (WTO SPS) Committee of its intention to lower the maximum residue levels (MRLs) for acetamiprid (G/SPS/N/EU/787).

However, the immediate implementation of the new ARfD following the SCoPAFF vote has caused significant market disruptions. Laboratories and producers have already begun applying the updated ARfD, resulting in numerous commodities being deemed non-compliant, even though the new MRLs have yet to take effect. The absence of transitional provisions for ARfD application has created challenges for growers, with lawful produce being prematurely classified as unsafe.

In response to industry concerns, the European Commission informed Member States that compliance assessments should continue to use the current MRLs. Member States have been asked to work with retailers and laboratories to ensure adherence to this guidance.

Additionally, the initial 3-month grace period for the new MRLs proved insufficient for the sector to adapt to the new MRLs. In response, the Commission extended the grace period for implementing the new MRLs from 3 to 6 months, with their entry into force now expected around August 2025.

We will provide updates as soon as the EU regulation is officially published.

Meanwhile, we encourage to monitor acetamiprid levels and good agricultural practices (GAPs) for crops such as apples, pears, quinces, apricots, sweet peppers, cucumbers, and courgettes. This will ensure that comprehensive data can be submitted to the Commission before February 2027, in preparation for the next scheduled review.

 

What should ACP producers/exporters do now?

For each plant protection products (PPPs) and crop concerned, the Good Agricultural Practices (GAPs) in place will need to be verified and possibly adapted to ensure compliance with the new MRLs. The GAPs include dose rate, number of applications, and pre-harvest interval. In some cases, adaptations to the GAPs will allow the new MRLs to be met. However, in many cases, especially where the level is reduced to the Limit of Determination (LoD), it may not be possible to meet the new MRL, and growers will have to look for alternative crop protection solutions. This is essential to avoid interception and destruction of exported produce at the EU/GB borders.

We invite you to consult COLEAD’s Crop Protection database which provides information on good agricultural practices. To date, it is one of the few sources of this information specifically dedicated to the horticultural sector in ACP countries. It includes the pesticide Maximum Residue Levels (MRLs) set by the EU and Codex Alimentarius for key horticultural crops in ACP countries. It also provides the GAPs (dose rate, interval between treatments, pre-harvest intervals) that ensure compliance with these MRLs. The GAP data for the use of specific PPPs has been obtained from a combination of sources including COLEAD field trials, data from the manufacturers, and scientific literature.

To prevent build-up of resistance, and to promote the use of low-risk substances, we recommend that users systematically check if alternative products are available. We recommend that you also access other databases and information sources, such as the CABI BioProtection Portal; this is a publicly available tool that provides information on registered biocontrol and biopesticides around the world. By specifying the country, crop, and/or pest/disease, users can easily discover a comprehensive list of registered products suited to their specific needs.

Before applying any Plant Protection Products (PPPs) in a given country, it is important to ensure that the product is registered for use by the national competent authorities.

In case there is no available alternative, manufacturers can consider the option of requesting an import tolerance. The process for approving an import tolerance MRL in the EU can take time and may imply costs. It is recommended to contact the PPP manufacturer to assess the feasibility.

 

All MRL changes published since the beginning of 2024

Table 6 shows all new MRLs that were published since the beginning of 2024. If any PPP that you use on crops for export to the EU or GB is listed here, we recommend that you check the regulation using the link provided. If you require additional information or face particular problems as a result of these changes, please contact COLEAD at: network@colead.link .

 

This publication has been developped by the Fit For Market Plus programme, implemented by COLEAD within the framework of Development cooperation between the Organisation of African, Caribbean and Pacific States (OACPS), and the European Union (EU).

This publication has been produced with the financial support of the EU and the OACPS. Its contents are the sole responsibility of COLEAD and can under no circumstances be regarded as reflecting the position of the EU or the OACPS.

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