Maximum Residue Limits

Codex Maximum Residues Limits

The Codex committee on pesticide residues (CCPR) develops and maintains acceptable pesticide Codex MRLs for food commodities in international trade. Although these form the basis of globally accepted standards, an increasing number of developing countries and economies in transition   set their own independent standards.

  • Industry supports the Codex Alimentarius Commission and the Committee on Pesticide Residues to establish Maximum Residue Limits CXLs for pesticides in food and feed commodities in in their objectives to set safe food safety standards and contribute to fair trade practices.
  • Industry support WHO and FAO in their role to take science based risk assessment decisions by submitting comprehensive data sets on human toxicology and pesticide residues in agricultural commodities.
  • The approval process for Codex MRLs is currently quite long, leading to unpredictable timelines. This is primarily due to the fact that the capacity of FAO and WHO appointed experts is not able to manage the workload.
  • A shortened process would allow an earlier adoption of CXLs especially in developing countries and facilitate trade while maintaining consumer safety standards.
  • The lack of acceptance of Codex MRLs by national governments leads to barriers in trade.

Background

The Codex Alimentarius Commission was created in 1963 by the FAO and WHO to develop food standards, guidelines and related texts such as codes of practice under the joint FAO/WHO Food Standards Programme.

The main objectives of this program are to protect consumer health, ensure fair food trade practices and promote coordination of all food standards work undertaken by international governmental and non-governmental organizations. You can see a list of the adopted Codex Classification of Foods and Crop Groups here.

Codex Committee on Pesticide Residues

The Codex Committee on Pesticide Residues (CCPR) develops and maintains acceptable pesticide Codex MRLs for food commodities in international trade. Via the so-called “Codex step procedure”, new MRLs are developed and agreed. Member State governments nominate compounds to be evaluated and independent experts appointed by FAO and WHO decide in  the Joint Meeting on Pesticide Residues (JMPR) whether the submitted information is sufficient to recommend toxicological endpoints such as the ADI and where necessary the ARfD and MRLs for the submitted uses. A pre-requisite for this assessment is the availability of product authorization and label for the submitted uses. Therefore JMPR can only begin with their evaluation after the end of national authorization processes. This is done in close cooperation with the manufacturers since they are the usual source of the necessary data.

One of the criteria for the acceptability of a nomination of a compound is measurable residues in internationally traded agricultural commodities; such residues are a legitimate matter of public health concern and could create problems in international trade unless properly regulated.  The compound/product to be evaluated must be registered in at least one Member State and be available for commercial use.

JMPR

The Joint FAO/WHO Meeting on Pesticide Residues (JMPR) consists of an international scientific expert group administered jointly by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO). It serves as an independent scientific advisory body to FAO/WHO and their member governments, as well as to the Codex Alimentarius Commission.  Advice on pesticides is provided to the Commission via the Codex Committee on Pesticide Residues (CCPR). In order to comprehensively understand the process of dealing with the CCPR and the JMPR, CropLife has developed “Working with the JMPR and CCPR – A Manual for the Agrochemical Industry

During the meetings, the FAO Panel of Experts reviews residue and analytical aspects of the pesticides under consideration, including data on their metabolism, fate in the environment and use patterns. The Panel also estimates the maximum residue limits that might occur as a result of the use of pesticides according to Good Agricultural Practice. The WHO Core Assessment Group is responsible for reviewing toxicological and related data and for estimating Acceptable Daily Intake (ADI) and the Acute Reference Dose (ARfD) for humans.

Acceptance of Codex MRLs

Under the Sanitary and Phytosanitary (SPS) agreement, the World Trade Organization (WTO) refer to Codex Limits as world-wide trading standards.

As a result, Codex Limits form basis for regional standards, e.g. ASEAN or the Gulf Cooperation countries. The 28 EU countries plus Norway and Iceland have a legal obligation to transpose CXLs into EU/national provided their risk assessment criteria are met and there is no conflict with national policies.

Other countries (about 30 mainly developing or countries with limited to resources) defer to Codex and other regional MRLs, such as MRLs from the EU or to US tolerances.

Several countries in the past used existing CXLs when they established their own MRL system, e.g. in form of positive lists. Some countries use CXLs in the absence of national MRLs. Updating such national MRLs is done from time to time, but timelines for that step are not predictable.

In the USA, the law states clearly that food is considered to be adulterated if pesticide residues exceed established US standards. The existence of a different Codex level does not influence this acceptability decision at the time of importation. However, if a Codex level already exists when a US tolerance is being set or modified, the Environmental Protection Agency (EPA) is obliged to consider an existing CXL and needs to justify when the CXL is not taken.

So far Codex MRLS are hardly ever used to settle trade disputes at WTO level, probably because of the administration hurdles and costs involved in filing a WTO complaint.

CropLife International and CCPR

The plant science industry supports the role of CCPR and JMPR in setting Codex. Codex Alimentarius set theirs standards based on sound science. CropLife International supports the adherence to the use of science- and risk-based methodologies and agreed criteria of CCPR/JMPR. At the same time CropLife International encourages FAO and WHO to review the current process which has not been changed for several decades to increase the effectiveness in decision making and to keep with the increasing  demand of the globalized trade of food and feed commodities.

The lack of acceptance of Codex MRLs by national governments and regional authorities reduces the value of MRLs as a tool for well-regulated international trade. As a consequence, food companies are forced to use national or import MRLs which devalues Codex MRLs as an international standard for public health. Also, growers are forced to comply with many different national MRLs instead of one internationally accepted standard. This increases costs for industry without increasing food safety.

CropLife International supports global science based standards as long as consumer safety is maintained.

  • We support global standards for pesticide residues on food commodities as a necessary condition for satisfying world food demand.
  • We support the WTO principle that acceptable pesticide residues on food commodities must be health-related and not used as a non-tariff barrier.
  • We strongly support the Codex Alimentarius and its Committee on Pesticide Residues (CCPR) in their objectives to develop science based food safety standards to maintain consumer health and to contribute to fair trade practices.
  • We support global standards that maintain consumer safety.
  • We support standardized systems for consistently and clearly communicating risk for products in international trade.