EUROPEAN UNION MRLS AND PESTICIDE
POLICIES – SPECIFIC TRADE CONCERN 448:
EU MRLS FOR ALPHA-CYPERMETHRIN, BUPROFEZIN,
CHLOROTHALONIL,
CHLORPYRIFOS, CHLORPYRIFOS-METHYL, CYPERMETHRIN,
DIFLUBENZURON, ETHOXYSULFURON, GLUFOSINATE,
IMAZALIL, IOXYNIL, IPRODIONE, MANCOZEB,
MOLINATE, PICOXYSTROBIN
AND TEPRALOXYDIM
SUBMISSION BY THE UNITED STATES OF AMERICA
The following submission,
received on 10 December 2025, is the statement made by the United States
of America at the 5-7 November 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 urges the European Union to align its MRL determination processes
with internationally recognized risk-based standards. A hazard-based "cut-off"
criteria that reduces MRLs to default levels without considering Codex or EFSA
risk assessments creates unnecessary trade barriers.
2. Notification
_G/SPS/N/EU/788 on MRL reductions for dithiocarbamates, including mancozeb, is
still a concern for the United States. We continue to request the European
Union to reconsider the proposed mancozeb MRL reductions for agricultural
products, including walnuts.
3. The
United States is also concerned by the EU's actions as notified in _G/SPS/N/EU/802 for MRLs of S-metolachlor on peanuts and chlorpropham on potatoes,
among others, which do not appear to be supported by a complete risk
assessment, and are therefore likely not the least restrictive measures
available.
4. We
also emphasize that a consistent and transparent regulatory framework is
essential for growers and exporters to plan production and trade with
confidence.
5. The
United States requests that the European Union adopt more flexible and
transparent transitional measures for MRL reductions. Agricultural exports that
were compliant at the time of production should remain eligible for entry into
the European Union, especially for products in long‑term storage and trade
channels such as processed commodities.
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