EU farmers are asking a legitimate question: why should they be denied access to tools available to growers elsewhere, while products imported into the EU can be produced using crop protection solutions unavailable to them?
Trading partners and food businesses are asking an equally legitimate question: why should products that meet internationally recognised safety standards face new restrictions when entering the EU? Both concerns deserve consideration. But this should not become a choice between supporting European farmers and maintaining open trade.
At its core, the debate over maximum residue levels (MRLs) is about more than pesticide residues. It is about competitiveness, trade and the conditions under which products can access the European market.
Simplification means better regulation
The Food and Feed Safety Omnibus was presented as an opportunity to simplify legislation and improve regulatory coherence. That is welcome. But simplification should not simply mean more restrictions or fewer administrative steps. It should deliver better outcomes for farmers, consumers and businesses.
European agriculture faces rising costs, climate pressures, evolving pest and disease threats and increasing global competition. Farmers are expected to deliver food security and sustainability while remaining economically viable.
The test for any regulatory change should therefore be simple: does it make European agriculture more resilient and competitive without compromising food safety?
Science-based food safety
The EU has one of the world’s most robust food safety systems, and MRLs are an important part of it. They are established through scientific assessment to ensure food can be consumed safely. But MRLs are also fundamental trade standards; they provide farmers, exporters and food businesses with clear and predictable conditions for accessing the European market.
The evidence from the EU’s own monitoring shows that this system continues to deliver a high level of consumer protection. Year after year, The European Food Safety Authority (EFSA) concludes that food sold in the EU, whether produced domestically or imported, remains overwhelmingly compliant with legal requirements and safe for consumers. The issue now is whether the EU risks changing the function of that system. Where an imported product complies with an MRL that has been established as safe for consumers, lowering or removing that tolerance because of how it was produced changes the basis on which market access is determined.
That matters not only for food safety policy but also for trade. MRLs and import tolerances are part of the regulatory framework on which global agricultural trade depends. If they are increasingly used to pursue objectives relating to production methods, environmental policy or competitive conditions outside the EU, the consequences for trading partners and supply chains need to be recognised and assessed explicitly.
Those may be legitimate policy objectives. But the question is whether MRL policy is the appropriate instrument through which to pursue them and what happens to the predictability of the EU’s trade regime if a safety-based market-access standard begins to serve wider policy objectives.
Trade-offs matter
Europe’s food system depends on international trade. Farmers depend on export markets, while food manufacturers, livestock producers and consumers rely on predictable access to imported products and raw materials.
Changes to MRLs and import requirements can therefore have consequences well beyond the field. They can affect trade flows, production costs, food prices and relationships with trading partners.
Recent analysis by the European Commission’s Joint Research Centre suggests that some of the options currently under discussion could have implications for agricultural production, trade flows and consumer prices across a wide range of commodities and trading partners. The study also highlights that outcomes depend heavily on how producers adapt and that further assessment is needed.
Whether one agrees with every assumption in the modelling is not the point. The point is that potential consequences exist and cannot simply be assumed away.
That is why robust impact assessment is essential. Regulation should not be changed simply because it appears to reduce imports or increase domestic production.
More domestic production does not automatically mean greater competitiveness. Long-term competitiveness comes from productivity, innovation, investment and access to effective tools.
More tools, not barriers
The durable answer to concerns about competitive inequality is not simply to restrict what others can sell into Europe. It is also to address the growing gap in the tools available to European farmers. They need access to a broader toolbox, including crop protection technologies, biological solutions, precision agriculture, digital tools and new breeding techniques.
If the EU wants its farmers to compete on more equal footing, enabling innovation and ensuring timely access to effective solutions must be part of that response. Competitiveness cannot be built through market restrictions alone. At the same time, Europe needs to be clear about the trading partner it wants to be.
Does the EU want to be a predictable partner that sets high, science-based standards while engaging constructively with international markets? Or does it want to increasingly use access to its market to impose production requirements on farmers beyond its borders?
The EU cannot ask its trading partners to respect a rules-based international system while continually changing the conditions of market access without considering how those changes will be perceived abroad.
This is not an argument against Europe setting high standards. Nor is it an argument that concerns about fairness between EU and non-EU producers should be ignored. It is an argument for clarity about the objective being pursued and proper scrutiny of the consequences.
The system is not broken
This debate should not start from the assumption that Europe’s food safety system is broken. It is not. The EU already has a rigorous system for determining whether food is safe for consumers. If policymakers now wish to use market-access rules to pursue additional objectives relating to production standards or competitiveness, that is a policy choice that should be assessed on its own terms.
If proposed changes to MRLs and import requirements could affect trade, competitiveness, food prices, food security and supply chains, those impacts deserve rigorous assessment before decisions are taken. At a time of growing geopolitical uncertainty, Europe should be strengthening resilient supply chains and predictable trading relationships, not creating new barriers without first understanding where they lead.
The question for the Food and Feed Safety Omnibus is therefore not simply whether Europe can impose these new conditions. It is whether those conditions are necessary, proportionate and supported by evidence and, most importantly, what kind of trading partner Europe wants to be if it chooses to introduce them.
If this debate is no longer principally about food safety, it should be subject to the same transparency, evidence and robust impact assessment expected of any major trade or competitiveness decision. That is both the responsibility and the opportunity presented by the Food and Feed Safety Omnibus.
