EUROPEAN UNION MRLS AND PESTICIDE POLICIES – SPECIFIC TRADE CONCERN 448:

EU MRLS FOR ALPHA-CYPERMETHRIN, BUPROFEZIN, CHLOROTHALONIL, CHLORPYRIFOS, CHLORPYRIFOS-METHYL, CYPERMETHRIN, DIFLUBENZURON, ETHOXYSULFURON, GLUFOSINATE,

The following submission, received on 2 July 2025, is the statement made by the United States of America at the 18-19 June 2025 WTO SPS Committee, and is being circulated at the request of the Delegation of the United States of America.

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1.  The United States, along with other WTO Members, remains concerned with the European Union's pesticide approval and renewal decisions and the systemic barriers to trade that result from the subsequent withdrawal or reduction of pesticide maximum residue levels, or MRLs, to the limit of quantification (LOQ) or the lower limit of determination (LOD) without a completed risk assessment.

2.  The United States reiterates our request that the European Union align with Codex Alimentarius MRLs rather than lowering MRLs to LOQ or LOD when EFSA is unable to finalize a full risk assessment.

3.  We remain concerned with notification _G/SPS/N/EU/788 on MRL reductions for dithiocarbamates, including mancozeb, and request the European Union reconsider the proposed mancozeb MRL reductions for agricultural products, including walnuts.

4.  The United States further requests that the mancozeb MRL for walnuts be maintained at the current EU level and, if it is changed, a 36-month transition period be granted to allow for walnuts to pass through the channels of trade given their long shelf life.

5.  The United States continues to ask that the European Union consider more flexible approaches to the enforcement of MRLs following their reduction to LOD or LOQ. Specifically, we request that the European Union extend the transition periods for MRLs for compounds for which the European Union had not identified a science-based food safety risk to consumers.

6.  We also remain concerned that EU approach to MRL enforcement does not address negative impacts on imported products, especially those with longer shelf lives that complied with EU MRLs in effect at the time that a pesticide was applied.

7.  The United States expects the European Union to take WTO Member comments into account prior to finalizing its draft measures. On numerous occasions, the European Commission has voted on draft regulations for active substance renewals and MRLs within days of a closed comment period. In such instances, it would appear as though the Commission did not have sufficient time to process comments, and was therefore unable to consider Members' comments and possibly revise draft measures as appropriate.

8.  The United States requests that the European Union retain existing MRL levels while import tolerances are under consideration. Recognition of science-based import tolerances is one of the few resources available to producers in third countries, and we encourage the European Union to continue to support and prioritize the process for establishing import tolerances.

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