EU’s Race to Zero Tolerance Risks Global Trade and Farmer Livelihoods

Whether it’s almonds from the United States, cocoa from Ghana, or rice from India, we enjoy eating good food from around the world. We expect it to be delicious and nutritious and we need to know that it is safe. That’s why trade in crops that have been produced using pesticides is regulated through the setting of import tolerances in the form of maximum pesticide residue levels (MRLs) – a trading standard to ensure all food is safe for our consumption. MRLs have a large built-in safety margin to protect consumer health.

In today’s globalized world where green beans can be harvested in Uganda one day and eaten by a consumer in Europe the next, it is important that MRLs are harmonized to avoid trade disruptions. But there is growing concern that the European Union is going in a different direction — banning crop protection products based on their hazardous properties (rather than real risk) and setting MRLs near to zero in response to campaign groups. If the trend continues, farmers will suffer because they cannot sell their product into Europe, while in the EU food prices will likely rise.

The EU is currently considering new regulation on chemicals that might interact with the human endocrine system. If politics overrules established science, the regulations will remove substances simply because they have a hazardous property. This unscientific approach is inconsistent with other global regulatory standards and could lead to delays in market access, act as a disincentive to innovate new products, and have a serious impact on trade.

Pesticides which fail the EU’s new criteria will be prohibited from use by Europe’s farmers. Meanwhile MRLs on imported food could be set to the ‘default’ level of 0.01mg/kg — which is so small it would be akin to a ban. To put it into context, soybean imports into Europe have a 20mg/kg limit on glyphosate residues. Europe’s biggest trade partners were rightly worried that the recently debated ban on glyphosate would prohibit these imports, and the unintended victim would have been Europe’s livestock farmers who rely on imported soy for animal feed.

According to some estimates the impact of the endocrine regulation on EU imports could be as high as €65 billion ($78.2 billion) if the MRLs for banned products are set to the ‘default’ 0.01mg/kg — as would be the preference from campaign groups. It is likely that farmers in developing world countries will suffer the most, with an estimated €8 billion impact on sub-Saharan Africa.

In Kenya, horticultural exports to the EU are a major business. The sector employs about 2 million people directly and 3.5 million people indirectly, and horticulture currently contributes around 10% to the nation’s GDP. Kenya joined 16 other governments at a recent World Trade Organization meeting to call for a strengthening of global harmonization of MRLs in a joint ministerial statement.

Globally MRLs are set by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO), under the Codex Alimentarius (Latin for ‘Food Code’). The ministerial statement calls to increase the capacity and efficiency of Codex to improve global harmonization on MRLs, give greater farmer access to pesticides for minor use crops, and remove trade barriers. As an industry, we support the call to strengthen Codex and encourage FAO/WHO to continue to advocate for predictable and science-based MRLs that ensure trade facilitation, particularly on agricultural exports of developing countries.

Food safety must be the number one priority for industry and regulators, but the arbitrary reduction of MRLs due to hazard-based assessments does not improve food safety. While the approach in Europe may have good intentions, it would have a substantial negative impact on farmer livelihoods and the production of, and trade in, safe food and agricultural products.

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