Committee on Sanitary and Phytosanitary Measures - European Union import tolerances for certain pesticides to achieve environmental outcomes in third countries - Specific trade concern 534 - Submission by the United States of America

EUROPEAN UNION IMPORT TOLERANCES FOR CERTAIN PESTICIDES

TO ACHIEVE ENVIRONMENTAL OUTCOMES IN THIRD

COUNTRIES – SPECIFIC TRADE CONCERN 534

SUBMISSION BY THE UNITED STATES OF AMERICA

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 remains disappointed with the European Union's lack of substantive engagement with Members relating to Commission Regulation 2023/334, which reduced maximum residue levels (MRLs) for the neonicotinoid insecticides clothianidin and thiamethoxam for environmental reasons associated with agricultural production in third countries.

2.  The United States is also disappointed that the European Union has not reconsidered its approach or provided a substantive response to the legitimate concerns raised in this Committee, including clarification of the requirements to approve import tolerance requests.

3.  Clothianidin and thiamethoxam are critically important to produce crops that are exported to the European Union from the United States and other WTO Members, and we are concerned that the reduction of MRLs for imported products is simply an attempt to address the concerns of European farmers who are no longer authorized to use these insecticides within the European Union and are concerned about competing with foreign producers.

4.  The European Union has unilaterally imposed on all WTO Members its own approach to improve pollinator health. However, the United States notes the European Union has not yet provided empirical evidence to substantiate that there is "no alternative to the lowering of the MRLs of clothianidin and thiamethoxam".

5.  The United States urges the European Union to refrain from using pesticide MRLs to achieve domestic policy objectives unrelated to food safety and, instead, limit the use of MRLs to their intended purpose, which is to allow regulators to monitor the lawful applications of pesticides and to ensure food safety for their consumers.

6.  The United States also wishes to reiterate that the 2018 European Food Safety Authority (EFSA) scientific review of clothianidin and thiamethoxam determined MRLs that were safe for consumers. We, therefore, repeat our request for the European Union to restore prior MRLs for clothianidin and thiamethoxam and refrain from additional attempts to use pesticide MRLs to achieve global environmental outcomes.

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