G/SPS/GEN/2144  
 
18 July 2023 
(23-4848) Page: 1/2 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
EUROPEAN UNION  MRLS AND PESTICIDE POLICIES – SPECIFIC TRADE CONCERN 448 : 
EU MRLS FOR ALPHA -CYPERMETHRIN, BUPROFEZIN, CHLOROTHALONIL , 
CHLORPYRIFOS, CHLORPYRIFOS -METHYL , DIFLUBENZURON,   
ETHOXYSULFURON, GLUFOSINATE, IMAZALIL, IOXYNIL,   
IPRODIONE, MANCOZEB, MOLINATE, PICOXYSTROBIN   
AND TEPRALOXY DIM 
SUBMISSION BY THE UNITED STATES  OF AMERICA  
The following submission, received on 14 July 2023, is the statement made by the United States of 
America at the 12-14 July 2023 WTO SPS Committee, and is being circulated at the request of the 
Delegation of t he United States of America . 
 
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1.  The United States along with a number of other Members continues to express concern with the 
European Union 's pesticide approval and renewal decisions and the systemic trade barriers that 
result from the subsequent withdrawal or reduction of pesticide maximum residue levels, or MRLs, 
to the Limit of Quantification on the basis of uncertainty and insufficient sci entific evidence.  
2.  We remind the European Union of the obligation that WTO Members only implement 
non-provisional SPS measures that are based on science and risk and are necessary to protect 
human, animal, or plant life or health, and to do so in the least trade restrictive manner possible. 
We urge the European Union to identify the least restrictive measures that accomplish their stated 
level of protection, and we repeat our reminder that the "ALARA" principle, or "As Low As Reasonably 
Achievable ", which ha s been mentioned by the European Union in this Committee, is neither relevant 
nor applicable to pesticide residues.  
3.  We request that the European Union maintain existing MRLs for active substances that do not 
pose known unacceptable food safety risks, compl ete a full risk assessment for each MRL prior to 
any proposed MRL reduction or withdrawal, and complete a science -based review of import tolerance 
applications based on consumer dietary risk in line with Codex guidance and standards.  
4.  We note that the conti nued use of emergency authorizations by EU member States gives farmers 
in the European Union access to active substances that are no longer approved for use in the 
European Union . Through these authorizations, both EFSA and member States consistently 
ackno wledge the lack of effective and economical crop protection alternatives as well as the real 
need to protect crops from harmful pest and disease pressure.  
5.  Farmers around the world rely on access to the full range of tools and technologies available for 
agricultural production, and these tools are essential to mitigate food security risks and to alleviate 
poverty. The European Union's systematic approach to M RL reductions based on uncertainty 
contradict the promotion of good agricultural practices, increase the risk of insect and disease 
resistance by limiting the ability of farmers to rotate pesticides, and ignore the impacts of evolving 
pest and disease pres sure in a time of increased climatic changes.  
6.  Access to a full range of pesticides that are thoroughly evaluated and permitted for use by 
competent national authorities is of critical importance to the promotion of resilient agricultural 
sectors and farmin g communities that can enhance yields and productivity while also limiting 
post-harvest losses and reducing unnecessary food waste. This access is necessary to promoting an G/SPS/GEN/2144  
 
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  adequate supply of affordable, safe food to meet the growing demands of global cons umers, many 
of whom also rely directly or indirectly on agriculture to sustain their livelihoods.  
7.  Our growers and processors are increasingly concerned that the European Union continues to 
implement transition measures that do not provide adequate time for  legally produced commodities 
to clear the channels of trade, and that appear to establish advantages for the European Union's 
domestic products over imported products.  
8.  Well-functioning, objective, and science -based regulatory systems protect consumers and  
establish the basis for fair trade. We have a shared interest in ensuring that pesticides are carefully 
evaluated and that pesticide residues do not pose an unacceptable risk to human health.  
9.  However, during these times of increasing global food insecurit y and unexpected global 
challenges related to changes in climate and disease, we urge the European Union to recognize that 
its regulatory approaches for pesticides are increasingly out of step with those of nearly every other 
Member of the WTO and strongly  consider the concerns that have been raised for years by many 
WTO Members in this Committee and others.  
 
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