The launch of the 4th Edition of the FPC Code of Practice for the Control of Pesticides has been an important step forward at a critical time for the produce industry.

As we have reported, of the 865 pesticides approved for use within the EU, 425 have already been withdrawn and we forecast that a further 200 are likely to be withdrawn leaving around 240 approved for use.

The fact that the EC will withdraw 665 pesticides from use within the EC does not mean that the rest of the world must do likewise. Indeed the EC have made it clear that overseas countries may continue to use these withdrawn pesticides as long as the resultant maximum residue level does not exceed zero.

Where a residue does occur the EC has introduced the possibility of creating an import tolerance. This is a residue level that would allow the third country to use a withdrawn pesticide and export the product to the EU. End of problem? - we don’t think so.

We are now testing the hypothesis that the reason for so many withdrawals is that the toxicological data packages required by the EC either don’t exist or are inadequate. Either way the cost to the agrochemical companies of rectifying this deficiency is quite prohibitive. As the EC will only allow an import tolerance to be set if the pesticide is supported by an appropriate data package this option may prove to be quite unrealistic.

Because of this when a pesticide is withdrawn by the EC it may not be possible to use it on crops destined for export to the EU.

This means either altering the approved label recommendations to get a zero residue or finding an alternative pesticide. It’s worth noting that the EC has allowed member states to set “temporary MRLs” but has not seen fit to allow third countries to set “temporary import tolerances”. One wonders what the WTO would think of that.