CropLife AME (CL AME) calls on the EU to base its MRLs setting system on evidence and science, which has proven to be very effective in ensuring consumers’ safety. MRLs setting should
be done according to the EU “Better Regulation” principle, which ensures evidence-based and transparent EU law-making based on the views of those who may be affected. More precisely:
The trend of decreasing maximum residue levels is a major threat to the achievement of the Sustainable Development Goals in the Africa Middle East region. CL AME believes that getting
the sustainable growth agenda right in agriculture is essential and therefore welcomes the ambitions of improved and more effective MRLs.
Using MRLs, however, as a tool to unilaterally drive environmental sustainability is not something we support. We believe that there is no ‘one size fits all’ approach when it comes to sustainability, and the means should therefore be tailored to a country’s agricultural specificities and trade needs. Therefore, considering the increasing tendency of the European Union (EU) to decrease MRLs and import tolerances, CL AME would like to recall the following:
The challenges that agriculture faces in Africa range from climate change, food security, water scarcity, inflation of fuel prices, trading and export uncertainties and restrictions (and many
more). These challenges are currently only being exacerbated by the impact, and likely future impact, of EU regulations.
By adopting a ‘one size fits all’ approach for sustainability the EU is not considering the climatic and agronomic conditions of the Africa Middle East region and the impacts that their changes will have. There exist many examples where it is necessary to use certain types of plant protection products (and in various quantities) to combat local pests and needs. The blanket approach discriminates against agricultural exports of products from many African and Middle Eastern countries.
A maximum residue level is the highest level of a pesticide residue that is legally tolerated in, or on, food or feed when pesticides are applied correctly (cf. Good Agricultural Practice). With
MRLs based on robust scientific assessment, authorities ensure that the amounts of residues found in foods are safe for consumers and are as low as possible. For example, according to
the European Food Safety Authority (EFSA) monitoring report on residues that is published every year, about half of all samples in the EU are free of detectable residue traces. In the remaining half (45%), residues found were within the legal limits (maximum residue levels or MRLs)1 ; such data shows that pesticides are applied according to Good Agricultural Practice and therefore that foods are safe because they are always below, or within, the MRLs set by EFSA.
Considering this lack of science-based evidence showing that such limits are not safe, it is unclear why there is a need to further decrease MRLs. More worryingly this is done with little
regard for how farmers should protect their crops going forward. It takes considerable time, work, research and resources to place new products on the market. Additionally, as farmers are the first line of defense in minimizing residues through good agricultural practices, the industry is taking responsibility by implementing and rolling out programs to train farmers in how to safely use pesticides. When used properly, pesticides are safe, and ensure that consumers have access to a safe supply of foods which are part of a healthy and balanced diet.
In addition to ensuring consumer safety, MRLs are in essence trading standards and the cornerstone of agricultural trade, as crops cannot be legally traded if they exceed MRLs. The
lack of globally harmonized MRLs is already a challenge for farmers, as they must comply with MRLs in both exporting and importing countries. It is key that MRLs are based on evidence and science and remain independent from political agendas.
CL AME is particularly concerned by the trend of ever-decreasing MRLs in the EU as part of the EU Green Deal. This is notably due to the possible deletion of existing MRLs for nonapproved active substances in the EU (so called ‘mirror clauses’) as well as the possible setting of MRLs with new data points such as environmental factors, especially when the latter is based on the use of the precautionary principle and not science or evidence-based2 .
CL AME notes that the environmental safety of pesticides is thoroughly assessed during the authorization processes; therefore, there is no necessity to do so in the setting of MRLs. Such
practices by the EU raise serious questions about the consistency of their measures. EU regulations are already more trade restrictive than necessary to fulfil a legitimate objective, as being based in essence on the precautionary principle. They also fail to consider Good Agricultural Practices (GAP) for legal uses in non-EU countries. The continued decrease of MRLs will cause further trade disruptions (contrary to WTO principles), a deterioration of relations with trading partners and additional administrative burden.
Finally, the decreasing trend of MRLs not only affects the agri-food exports to the EU, it also has a detrimental effect on the agricultural production of African and Middle East countries,
and consequently their food security and the region’s stability. CropLife Africa Middle East A.I.S.B.L is a non-for-profit industry association representing the leading global manufacturers of pesticides, seeds and biotechnology products in its territory. The regional association was registered in Brussels in November 2002 and represents today more than 20 national associations across its region. The association is legally fully y independent but maintains a strong link with the global CropLife network (www.croplife.org).