EU and GB MRL changes in 2024 (May– August 2024)

EU and GB MRL changes in 2024 (May – August 2024)

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 May – August 2024

The European Commission (EC) has recently published new regulations that change certain EU MRLs. These concern 15 substances (Table 1), including 7 that are of particular importance for ACP horticulture.

The following substances present MRLs changes for key crops entering into force in 2024 (Table 2):

• Deltamethrin (applicable from 11 December 2024)
• Metalaxyl (applicable from 11 December 2024)
• Thiabendazole (applicable from 11 December 2024)
• Trifloxystrobin (applicable from 11 December 2024)
• Chlorantraniliprole (applicable from 11 June 2024)
• Emamectin (applicable from 11 June 2024)
• Spiromesifen (applicable from 11 June 2024)

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.

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

Changes to GB MRLs during the period May – August 2024

No changes to GB MRLs wer published during the period May – August 2024.

Further Proposed MRL changes

A further 7 proposed (draft) MRL changes have recently been notified to the WTO (Table  3), of which 5 are key for ACP horticulture (thiacloprid, penconazole, acetamiprid, dithiocarbamates and methidathion).

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.

MRL changes for dithiocarbamates

Dithiocarbamates are commonly used as fungicides, herbicides, or insecticides. Several pesticides belong to this group, including maneb, mancozeb, metiram, propineb, thiram, and ziram. Therefore, changes to the MRLs for this group have a particularly important impact. Except for propineb, ziram and thiram, which have individual MRLs, current analytical methods do not allow specific MRLs to be set for the other dithiocarbamates. Changes to MRLs for this group therefore have a particularly significant impact, as they affect several substances simultaneously.

Ziram is approved in the EU until 15/03/2025. Metiram no longer approved in the EU (28/11/2023), with a grace period set for 28/11/2024 for its use. Maneb is no longer approved in the EU since 31/01/2017, propineb since 22/03/2018, thiram since 30/10/2018, and mancozeb since 04/01/2021.

Generally, the MRLs of active substances that are no longer approved in the EU should be lowered to the limit of detection (LOD) at the end of their grace period. However, since the MRLs of dithiocarbamates are grouped, they cannot be lowered individually without affecting the other substances in the group.

The European Food Safety Authority (EFSA 2023) has reviewed the MRLs of dithiocarbamates. For products where Codex MRLs (CXL) or import tolerances exist and are considered safe, the European Commission proposes to adjust the MRLs accordingly.

The deadline for commenting on the EU legislative proposal is set for September 20, 2024. WTO member authorities can submit their comments on the EU proposal (G/SPS/N/EU/788) by emailing the EU SPS Enquiry Point by this date.

These MRLs are expected to enter into force around August 2025. We will keep you informed as soon as the EU regulation is published.

We invite you to consult the AGRINFO record concerning the modifications of MRLs for dithiocarbamates for information on the impacted products.

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 that are planned to enter into application in 2024

Table 4 shows all new MRLs that should enter into application in 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.