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Understanding international harmonization of pesticide Maximum Residue Limits (MRLs) with Codex standards:
A CASE STUDY ON RICESide event of the WTO Committee on Sanitary and Phytosanitary MeasuresNovember 5th 2020
Background For years countries have emphasized the difficulties encountered in the absence of Codex
MRLs for important pesticides used at national level.
Many concerns have been raised also with respect to trade problems linked to differences
in regulatory limits for pesticide residues imposed by different countries.
In 2017, FAO initiated a study to systematically assess the level of harmonization
between countries and Codex pesticide MRLs. The results showed:
a very low level of harmonization
that pesticide MRLs stricter than those recommended by Codex, tended to be applied especially
for commodities such as rice, chili pepper and spices
This highlighted the need to understand better the different dimensions of this
complex issue
Structure of the study (1/2)
PART A: Level of harmonization of rice pesticide MRLs with Codex and impact on trade
Pesticides used on rice and harmonization with Codex MRLs
What does this mean for trade?
Reasons behind different levels of pesticide MRL harmonization
Risk assessment methodology
Risk management considerations
PART B:
Structure of the study (2/2)
Commodity: RICE
• Staple food - plays a significant role in food security
• Developing countries account for more than 96% of global rice production and almost three quarters of global rice exports
• Appeared as subject to national MRLs stricter than Codex MRLs (FAO pre-study)
Countries/region:
1. Australia2. Bangladesh3. Brazil4. Cambodia5. Canada6. China7. European Union8. India9. Indonesia10. Iran 11. Japan12. Myanmar13. Pakistan14. Philippines15. Saudi Arabia16. Thailand17. United Arab Emirates18. United States of America 19. Viet Nam
Data availability constraints:
PART A (economic analysis): 17 economies
PART B (reasons behind): 5 countries/region
Level of harmonization of rice pesticide MRLs with Codex and impact on trade
PART A
Harmonization with Codex rice MRLs
Codex rice MRLs
PART A
Codex code Codex name Total # of MRLs
GC 0649 Rice (defined as “rice with husks that remain attached to kernels even after threshing: kernels with husks”)
25
CM 0649 Rice husked 18
CM 1205 Rice polished 13
GC 0655 Wild rice 1
GC 0080 Cereal grains (rice; wild rice) 25
82
National rice MRLsPART A
263
82 92 11 37
317
486
11965 50
288
82 82 29 62 29 82 99 65 820
50100150200250300350400450500
Tota
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mb
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RLs
National MRLs Codex MRLs
56 82 265 23
57 19 17 34 15 17 82 82
11
56 17 82 39 64
207
66
6 14
260
467
102 31 35
271
18
612
60 1
050
100150200250300350400450500
Tota
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mb
er o
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RLs
Codex MRLs
01020304050607080
Tota
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ce M
RLs
Aligned with Codex Higher than Codex Lower than Codex Codex MRLs but no national MRLs
Harmonization with Codex MRLsPART A
Codex MRLs missing at national levelPART A
Country/region Nat’l MRLs Enforcement procedure followed in the absence of national MRLs
Thailand Yes Defer to Codex
Brazil, Cambodia, Indonesia Yes Defer to Codex
Bangladesh, Myanmar No Defer to Codex
Saudi Arabia Yes Defer to Codex first - then MRLs of the EU or USA
United Arab Emirates No Defer to Codex first - then MRLs of the EU, then default limit at: 0.01 ppm
Pakistan No Defer to the lowest MRL among Codex, EU and USA
European Union, Japan, India
Yes Apply a default limit at: 0.01 ppm
Iran (Islamic Republic of) Yes Apply a default limit at: 0.05 ppm
Canada Yes Apply a default limit at: 0.1 ppm
Australia Yes Apply zero tolerance
United States of America Yes The crop is considered adulterated and may be seized
Philippines Yes Apply zero tolerance
China, Viet Nam Yes Not confirmed – it was assumed that in the absence of an official procedure, zero tolerance applies
PART A
01020304050607080
Tota
l nu
mb
er o
f ri
ce M
RLs
Aligned with Codex Higher than Codex Lower than Codex
Harmonization with Codex MRLs
What does this mean for trade?
Standards can affect trade in two ways
PART A
High consumer awareness of food safety in importing
markets
Standards can be trade-enhancing
More than 50% of the respondents in a household
survey in Georgia (United States of America)
perceived pesticide residues as serious or extremely
serious food safety threat already in the early 2000s
Food safety was identified as the most important
sustainability attribute for rice consumers in Nigeria
in a recent survey
Costs to comply with food safety standards in
export markets
Standards can be trade-impeding
Costs for stricter food safety management
incurred at all levels of the (export) supply
chain
Examples: Investment costs, expenses for
monitoring and certification, daily risk
management
Mixed effects found in the literature
PART A
Study Method Main results
Li and Beghin (2012) Meta-analysis SPS regulations tend to impede exports from developing countries
Santeramo andLamonaca (2019)
Meta-analysis Stricter MRLs tend to favour trade
Chen et al. (2008) Gravity model MRLs on the insecticide chlorpyrifos reduce China’s exports of vegetables
Melo et al. (2014) Gravity model MRLs reduce Chile’s exports of fresh fruits
Kareem et al. (2018) Gravity model EU MRLs on tomatoes reduce exports from African countriesEU MRLs on citrus fruits enhance exports from African countries
Drogué and DeMaria(2012)
Gravity model Increasing the similarity of MRLs among countries increases trade of apples and pears
Winchester et al. (2012) Gravity model Stricter pesticide MRLs for plant products in onecountry relative to other countries reduce exports to that country
Xiong and Beghin (2014) Gravity model Pesticide MRLs by OECD countries are associated with more trade; divergence of regulations between importer and exporter impedes trade
PART AAverage MRLs on rice by importer/exporter
0.0
1.0
2.0
3.0
Australia Canada China EuropeanUnion
Indonesia Japan Saudi Arabia UnitedStates ofAmerica
MR
L in
dex
Rice in the husk Husked (brown) rice Rice, semi-milled or wholly milled Rice, broken
0.0
0.5
1.0
1.5
2.0
2.5
3.0
MR
L in
dex
Importers: Average MRLs tend to be stricter than Codex
Exporters: Average MRLs aligned with Codex in 50% of the cases
PART AEffects on trade in rice
-1.0-0.50.00.51.01.52.0
MRL Importer MRL Divergence
Effe
ct o
n t
rad
e
Likelihood to trade Intensity of trade
Importers: Stricter MRLs are
associated with relatively more rice
imports, possibly reflecting strong
consumer awareness of food safety
Exporters: Stricter MRLs of the
importer relative to those of the
exporter are associated with
additional costs and may impede
exports
Many other factors that influence
trade between two countries
Likelihood to trade Intensity of trade
Production of exporter + +
Trade in 1995 + +
Rice variety + +
Colonial relationship +
Tariff of importer - -
Distance - -
Development status - -
Reasons behind different levels of pesticide MRL harmonization
PART B
Reasons behind different levels of harmonization
In collaboration with the JMPR Secretariat, key issues that could lead to divergent
decisions concerning MRLs have been identified :
1) Differences in risk assessment processes
2) Differences in risk management policy/decisions
Interested countries/region were approached to gather their views.
This analysis focuses only on five countries/region: Australia, Canada, the European
Union, Japan and the United States of America
PART B
There is considerable variation in how countries are aligned with the JMPR and Codex process for the
development and establishment of pesticide MRLs.
Many of the observed differences in risk assessments do not seem to have a significant impact on the
overall outcome of the pesticide safety evaluations.
Some of the major differences in MRLs and residue definitions are due to the presentation of different
data to the various countries/region.
Harmonization also depends on national authorities supplying updated consumption data to FAO/WHO,
via the GEMS and CIFOCOss databases.
Many of the guidance/procedural documents related to MRLs and human health risk assessments of
pesticides were initially drafted 10 to 20 years ago. Consideration could be given to an update process that
can be agreed internationally.
PART B
Risk Assessment methodologyFindings
Automatic harmonization with Codex MRLs is not the norm. For non-registered MRLs, common practices are to set a default value (usually at the limit of quantification) or to not establish any tolerance/MRL.
In the absence of a national MRL, an application can be made to have an MRL established, which is termed an import tolerance.
During the Codex step-process, active notification whenever a Codex MRL is not going to be adopted and the scientific rationale for that decision is only rarely provided.
Differences in the time of MRL adoption at Codex and at national level may entail changes in the scientific data packages evaluated by the different authorities.
There is great inconsistency among the commodity descriptions across different countries.
PART B
Risk Management considerationsFindings
Conclusions and recommendations (1/2)
Lack of Codex MRLs: addressing the need for more Codex MRLs should be further considered.
Missing national MRLs: deferral to Codex MRLs when national MRLs do not exist could be considered as
a default practice, as also recommended by the SPS Agreement: “the importing Member shall consider
the use of a relevant international standard as the basis for access until a final determination is made”.
Food classification: consistency could be improved to reduce the potential confusion over multiple MRLs
for different forms of a single pesticide/crop combination.
Improving harmonization: critical areas such as residue definitions, classification, etc. need to be further
considered.
PART A PART B
Conclusions and recommendations (2/2)Transparency: it would be important that countries actively notify Codex whenever they have any reservation and are not in the position to adopt a newly established Codex MRL, providing a science-based rationale.
Capacity development: consideration should be given to developing countries’ needs for better and more active participation in the Codex standard-setting process and to the needs of those countries when developing new MRLs.
Dual effect of MRLs on trade:
Balance between high food safety requirements on the importing side and the higher market access costs incurred by exporting countries
Increase developing countries’ capacity to comply with food safety standards in both their export and domestic supply chains
PART A PART B
Thank you!