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 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.

_______________

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 to the limit of determination maximum residue levels (MRLs) for the two neonicotinoid insecticides clothianidin and thiamethoxam for environmental reasons associated with agricultural production in third countries.

2.  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.

3.  Nor does the EU's approach of using pesticide MRLs to pursue global environmental goals change the fact that the obligations of the Agreement on the Application of Sanitary and Phytosanitary Measures still apply when the measure relates to the protection of human, animal or plant life or health.

4.  The United States urges the European Union to adopt policies that support sustainable pest management globally rather than policies that unnecessarily restrict access to tools and leave farmers without viable alternatives.

__________