Proposals to Amend the  
New Zealand (Maximum Residue 
Levels for Agricultural Compounds) Food Notice 
 
 
New Zealand Food Safety Discussion  Paper  No: 2024/02 
 
 
 
Prepared for public consultation  
by New Zealand Food Safety  
  
ISBN No  978-1-991087- 56-0 (online)  
ISSN No: 2624- 0157 (online)  
 
 
  25 March  2024 
  
Disclaimer  
 While every effort has been made to ensure the information in this publication is accurate, the  
Ministry for Primary Industries  does not accept any responsibility or liability for error of fact, omission, 
interpretation or opinion that may be present, nor  for the consequences of any decisions based on  
this information.  
  This publication is also available on the Ministry for Primary Industries  website at  
http://www.mpi.govt.nz/news -and-resources/publications/
  
  © Crown Copyright - Ministry for Primary Industries   
i Contents  Page 
 
1 Request for submissions  1 
2 Introduction 2 
2.1 Establishing Maximum Residue Levels  2 
2.2 Summary of Proposed Amendments  5 
3 PROPOSALS  7 
3.1 Proposal to amend the MRLs for brodifacoum, bromadiolone, flocoumafen, and pindone, and to 
set MRLs for coumatetralyl, difenacoum, difethialone, and diphacinone  7 
3.2 Proposal to amend the Notice entry for dieldrin and aldrin  11 
  
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  1 1 Request for submissions  
New Zealand Food Safety  invites public comment on this discussion document, which outlines 
proposals to amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) 
Food Notice (Notice) . 
 
For each compound  you are commenting on, please clearly answer the following questions.  
 
Do you agree or disagree with the proposed addition, amendment or deletion?  
 
For compounds listed in Schedule 1, d o you agree or disagree with the proposed 
MRL (s)?  
 
For compounds listed in Schedules 2 or 3, do you agree or disagree with the listing or 
the conditions?  
 
Please feel free to include with your answers above, any supporting discussion, data or 
examples that you feel are relevant.  
 
Submissions close at 5  pm on 24 May 2024. Your comments should be sent to:  
MRL Amendments  
New Zealand Food Safety  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
Email: MaximumResidueLevels@mpi.govt.nz . 
Please include your name and address on your submission. If you are making comments on behalf of an organisation, also include your title and the name of the organisation.  
Please make sure your comments can be clearly read, as a number of copies of your submission may be made.  
 
The Official Information Act  
The Official Information Act 1982 (the OIA) states that information is to be made available 
unless there are grounds for withholding it. The grounds for withholding information are 
outlined in the OIA.  Submitters may wish to indicate any grounds for withholding information 
contained in their submission.  Reasons for withholding information could include that 
information is commercially sensitive or that the submitters wish personal information such as names or contact details to be withheld. The Ministry for Primary Industries  will take such 
indications into account when determining whether to release information.  Any decision to 
withhold information requested under the OIA may be reviewed by the Ombudsman.  
 
  
2 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice New Zealand Food Safety  2 Introduction  
Agricultural compounds are natural or synthetic substances used in the  direct  management of 
plants and animals, and include all agricultural chemicals ( e.g., fungicides, herbicides, and 
insecticides) , veterinary medicines, and other compounds used to maintain plant and animal 
health and productiv ity. Growers and farmers use these agricultural compounds to manage 
disease in animals and crops, protect the food supply, and maximise the quantity and quality 
of the food they grow.  
Agricultural compound  use can leave residues in the food harvested from treated crops and 
animals. To manage these residues, it is important to ensure that only the lowest  amount of 
an agricultural compound is used to consistently achieve its intended purpose. This will leave 
the smallest amount of residue practicable without compromising the compound’s efficacy. The set  of principles and methods used to manage that balance is known as good agricultural 
practice (GAP) . These principles apply to  the production of safe and good quality horticultural , 
agricultural,  and animal products.  Maximum residue levels (MRLs) are then established for 
each compound/food commodity combination by evaluating the residues left in food 
commodities as a result of the highest authorised GAP use (the ‘critical GAP’).  This value is 
compared against the health- based guidance value before a maximum level of agricultural 
compound residue allowable in that food commodity is set. How the MRLs are determined, 
and how they are used once they have been set, are explained in more detail below.   
MRLs are the maxi mum legal levels for residues of agricultural compounds permitted in food 
for sale in New Zealand. They are established based on domestic uses of a particular compound and are used to monitor GAP compliance in New Zealand while ensuring food 
safety. Because they are based on New Zealand authorised uses according to domestic GAP, 
MRLs may differ from those established overseas for a similar use because their GAP may be 
different.  However, as noted below, imported food can also comply with Codex MRLs.  
To meet  New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures (the SPS Agreement) , proposals for new and amended MRLs are 
notified to the World Trade Organization. Any country may choose to comment if they believe  
a proposed MRL represents a barrier to their trade.  
2.1 Establishing Maximum Residue Levels  
2.1.1 Regulatory Structure  
MRLs  are the maximum legal levels of agricultural compound residues permitted in food for 
sale in New Zealand and are set out in the Notice. The Notice is updated up to four times a 
year to reflect changes in the use of agricultural compounds in the production of food. The 
Notice is available from the Ministry for Primary Industries (MPI) New Zealand Food Safety 
website at: https://www.mpi.govt.nz/dmsdocument/19550- maximum -residue- levels -for-
agricultural -compounds .  
New Zealand Food Safety administers the Notice, with the final decision on any changes to 
the Notice resting with the Director -General of MPI. The Notice is issued under section 405 of 
the Food Act 2014. When setting or amending MRLs, the Director -General must follow, as far 
as practicable, international best practice on dietary intake assessment and setting of maximum residue levels.  The requirements for the content of the Notice are set out in Part 6 
of the Food Regulations 2015 (the Food Regulations), allowing for the setting of MRLs for 
agricultur al compounds as well as specifying compounds to which no MRL applies .  
In addition to establishing the requirements for domestically produced foods, Part 6 of the Food Regulations  also outlines the residue level compliance requirements for imported foods.  
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  3 Regulation 144 states that food must not contain residues of agricultural compounds  unless 
the residue level does not exceed : 
- the MRLs specified for that food in a notice set under the Food Act 2014 ( regulation  
144(1)(a)); or  
- the default MRL of 0.1 mg/kg ( regulation  144(1)(c)); or  
- for imported food, the current editions of either the Maximum Residue Limits (MRLs) 
and Extraneous Maximum Residue Limits (EMRLs) for Pesticides (Codex 
Pesticides Residues in Food Online Database), or the Maximum Residue Limits for 
Veterinary Drugs in Food (Codex Veterinary Drug Residue in Food Online 
Database) ( regulation 144(1)(d)).  
These provisions allow for New Zealand Food Safety to set MRLs for imported food 
commodities when such levels are required. As imported food commodities can comply with 
either a Codex MRL or a MRL established in the Notice, New Zealand’s obligations under the 
SPS Agreement are met.  
On the whole, the  Food Regulations allow for the management of residues in all foods 
consumed in New Zealand.  
2.1.2 Determining Maximum Residue Levels  
The first step in determining MRLs for an agricultural compound is establishing GAP for the 
use of the compound in the target species or crop. New Zealand Food Safety establishes GAP 
by evaluating efficacy, crop safety, and animal health and safety for the range of treatments 
and use patterns  approved and proposed for each compound . Once GAP has been 
established for an agricultural compound, the residues resulting from the highest authorised 
dose or application rate  and use pattern, which is likely to give rise to the highest residues (the 
‘critical GAP’)  is then used to determine the  MRLs in food commodities from  treated  crops  and 
animals.   
Although the primary function of MRLs is to ensure conformance with established New Zealand 
GAP, the MRLs also play a role in managing dietary exposure and risks to trade in food 
commodities. To ensure the MRLs will effectively manage residues related to those risks, a 
national estimated daily intake or NEDI calculation is conducted to evaluate consumption risk 
and a review of all international MRLs for the compound/commodity combinations being considered is completed to evaluate trade risk. If it is found that the MRL being considered 
may pose a food safety or trade risk, the proposed M RL is not progressed.   
Where it has been determined that MRLs can be set, those MRLs are proposed for inclusion 
in the Notice for approved or proposed agricultural compound uses . For veterinary medicines, 
MRLs may be proposed for animal products from a specific species (e.g., cattle, chicken) or a species group (e.g., mammalian, poultry) depending on the residue and metabolism profile of 
the agricultural compound being considered. Similarly, for agricultural chemicals, an MRL may 
be set for an individual cr op or crop product (e.g., avocados, wheat grains) or for a crop 
grouping (e.g., pome fruits). When it has been determined that assigning an MRL to a crop 
grouping is appropriate, the grouping used aligns with the Codex classifications of foods and 
animal f eeds.  
For agricultural chemicals used on a crop from which both food and animal feed commodities are derived, MRLs are proposed for both the food commodities intended for human 
consumption from the treated crop, and animal commodities for the species or species group 
to which the feed commodity is fed. If the compound for which the MRLs are set is also used 
as a veterinary medicine, all approved veterinary and agricultural chemical uses are 
considered when setting the animal commodity MRLs. If an agricultur al chemical is used on a  
4 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice New Zealand Food Safety  crop from which only animal feed is harvested (e.g., pasture, fodder crops), only animal 
commodity MRLs will be proposed.   
2.1.3 Estimating Chronic Dietary Exposure   
National estimated daily intake  
The objective of the  estimated chronic dietary exposure  is to determine whether residues in 
food commodities will pose an unacceptable risk to consumers as a result of the authorised 
use of an agricultural compound according to established GAP. This exposure is estimated by  
calculating the nati onal estimated daily intake (NEDI) in accordance with the Guidelines for 
predicting dietary intake of pesticide residues (revised) [World Health Organization, 1997] . 
The NEDI calculation uses the total residues in food derived from all New Zealand authoris ed 
uses of an agricultural compound, including all toxicologically significant residues, and regional 
dietary consumption data derived from the 1997 National Nutritional Survey for adults and the 
1995 National Nutrition Survey of Australia for children. The calculated NEDI is then compared 
with the health based guidance value (HBGV) associated with the compound; if the total 
residues derived from all uses of the agricultural compound is estimated to be less than the 
HBGV, the dietary exposure is unlikely to pose a health risk to consumers.   
Health Based Guidance Values  
The HBGV used in determining the estimated dietary exposure may be either a Potential Daily 
Exposure (food) (PDE (food)) or an Acceptable Daily Intake (ADI). The ADI and PDE (food) are 
largely equivalent as they are determined using the same set of toxicology data and through a 
very similar scientific process. Both values are reported as milligrams of compound per 
kilogram bodyweight per day (mg/kg bw/d).  
A PDE (food) is a value determined by a toxicological evaluation by the New Zealand 
Environmental Protection Authority (NZ EPA) as part of its responsibility for managing public 
health under the Hazardous Substances and New Organisms Act 1996.  A PDE (food) is the food-
specific part of a set of values for different exposure pathways comprising the NZ EPA’s assessment of acceptable daily exposure (ADE) for an agricultural compound. It provides  the 
threshold for the potential daily exposure to a substance that  a person may  be subject to via 
food.  
An ADI is defined by the World Health Organization (WHO) as “the daily intake which, during 
an entire lifetime, appears to be without appreciable risk on the basis of all the known facts at 
the time”. “Without appreciable risk” has  been further defined as: “the practical certainty that 
injury will not result even after a lifetime of exposure”. ADIs are established by the WHO and Food and Agriculture Organization (FAO) of the United Nations joint expert committees, which are made up of toxicologists and residue specialists. The ADI information from these joint 
committees also feeds into the Codex Alimentarius Commission (Codex), which sets international MRLs.  
New Zealand Food Safety uses the PDE
(food) set by the NZ EPA as the HBGV fo r the estimation 
of dietary exposure when one is available. If there is no PDE (food), the NEDI  is compared with 
an ADI set by the WHO/FAO joint expert committees, the Australian Pesticides and Veterinary 
Medicines Authority, the European Food Safety Author ity, or another regulatory authority. If 
none of these are available, the HBGV used will be a New Zealand Food Safety -determined 
ADI.   
2.1.4 International MRLs and Trade  
Because New Zealand MRLs are based on domestic GAP, they may differ from th e MRLs  
establis hed overseas  for the use of the same compound in the same target species or crop if  
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  5 the GAP used to set those MRLs are different. To ensure the New Zealand MRLs will not 
unduly impact trade, the MRLs set by Codex and a selection of other international regulatory 
bodies  are reviewed to evaluate trade risk.  
For animal commodities, the MRLs set by Australia, Canada, China, Codex, the European 
Union, Japan, and the U nited States  are commonly  reviewed and compared; for horticultural 
commodities, MRLs set by Codex and Australia are commonly  reviewed and compared. Other 
international MRLs  may also be reviewed and compared if there is a particular trade risk to be 
considered for those regions  for any exported commodity .  
Where there are relevant international MRLs to be considered in the trade assessment for the 
proposal, these are included in a table in the “Relevant International MRLs” section of each 
proposal entry. This table includes all MRLs for the agricultural compound/food commodity 
combinations for which new or amended New Zealand MRLs are being proposed; international 
MRLs for other commodities for which New Zealand MRLs already exist are not included. If 
there are no MRLs set by an international authority for a particular compound/commodity 
combination, the authority is not listed in the table.  
2.1.5 Agricultural Compounds for Which No Maximum Residue Level Applies   
Not all agricultural compounds require an MRL to manage their use in crops or animals . This 
may be because there are no residues present due to the  properties of the  compound such as 
rapid elimination from the plant, animal, or their environment,  or because there are no food 
safety or trade risk s associated with the residues that are present. Regulation 141 of the Food 
Regulations allow s for the listing of specified compounds that fit these criteria as agricultural 
chemicals or veterinary medicines for which no MRL applies. These compounds are lis ted in 
Schedule 2 and Schedule 3 of the Notice, respectively , and the conditions of listing can be set 
for a particular use, a particular animal or crop, or general use as an agricultural chemical or veterinary medicine.  
Agricultural chemicals and veterinary medicines being considered for listing as compounds for 
which no MRL applies undergo a similar scientific assessment of their use as that undertaken 
for MRL assessment. This assessment is done in accordance with international methodologies published by  the Organisation for Economic Cooperation and Development (OECD), 
International Cooperation on Harmonisation of Technical Requirements for Registration of 
Veterinary Medicinal Products (VICH), or FAO. It includes establishing the GAP use of the 
compound, the relevant metabolism and residue information, and the potential risks posed to 
public health and trade. The assessment may also include an assessment of dietary exposure 
when considered necessary to fully assess the risks.  
Where New Zealand Food Safety  has determined that an  MRL is not required, the compound 
is proposed for listing in Schedule 2  (for agricultural chemicals)  or Schedule 3 (for veterinary 
medicines) with conditions on their use to ensure the listing applies only to those situations 
that have been evaluated. If a compound listed in Schedule 2 or 3 is used in a way that does 
not meet the specified condition, the default MRL of 0.1 mg/kg will apply  to food derived from 
treated plants  or animals. Each proposal for inclusion in Schedule 2 or 3 includes a discussion 
of the rationale behind the considerations for listing , and a discussion of the assessed risks  
and proposed conditions .  
2.2 Summary of Proposed Amendments  
The proposed MRLs have been thoroughly assessed in accordance with international 
methodologies published by the O ECD,  VICH, or FAO . Information on the technical 
assessment of each proposal is included in this document (refer section 3) and covers:   
6 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice New Zealand Food Safety  • the new or amended entry proposed for inclusion in the Notice;  
• the rationale for the new entry or amendment being proposed ; 
• New Zealand good agricultural practice for the compound and target crop or species ; 
• the relevant residues information used in determining the proposed MRLs ; 
• a summary of the dietary risk and public health assessment ; and 
• the MRLs set by Codex and other authorities  that are relevant to the new or amended 
entry.  
Where an existing entry is proposed for revision, new or revised entry content is listed  in bold 
print, and content proposed for removal is  identified by a strikethrough.  
The MRL compliance and dietary risk assessment residue definitions are included in the 
residues information section of the proposal. The HBGV used to compare to the NEDI 
calculation and deter mine the potential public health risk is included in the dietary risk and 
public health assessment section of the proposal.  
2.2.1 Amendments to Schedule 1 : Maximum Residue Levels for Agricultural Compounds  
MPI proposes to make the following changes to Schedule 1 of the Notice:  
• An amendment to the e ntries for brodifacoum , bromadiolone , flocoumafen , and 
pindone, to set M RLs at  0.003 mg/kg for  pig edible offal (except liver) , and 0.004 mg/kg 
for pig liver ;  
• New entries for coumatetralyl , difenacoum , difethialone, and diphacinone,  to set 
MRLs at 0.003 mg/kg for  pig edible offal (except liver) , 0.004 mg/kg for pig liver, and 
0.001(*) mg/kg for any other food;  
• An amendment to the entry for dieldrin and aldrin , to remove the ‘any other food’ MRL.   
Note: (*) indicates that the maximum residue level has been set at or about the limit of 
analytical quantification.  
   
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  7 3 PROPOSALS  
3.1 Proposal to amend the MRLs for brodifacoum , bromadiolone, flocoumafen, 
and pindone, and to set MRLs for coumatetralyl, difenacoum, difethialone, 
and diphacinone  
It is proposed that  new and revised MRLs  are set  for the anticoagulant  vertebrate toxic agent 
(VTA) compounds brodifacoum, bromadiolone, coumatetralyl, difenacoum, difethialone, 
diphacinone,  flocoumafen, and pindone to better support the GAP use of these compounds on 
or near farms. The proposals will also serve to reinforce the controls on the use of these 
compounds, which prevent direct exposure of food- producing animals to VTAs.  
These changes are being presented as a single proposal since the same rationale for 
establishing these MRLs and their  proposed values apply to all eight compounds. The  new 
and revised entr ies in Schedule 1 of the Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum 
residue level applies  Food  Maximum Residue 
Level (mg/kg)  
Brodifacoum  56073- 10-0 Brodifacoum  Pig edible offal 
(except liver)  
Pig liver  
Any other food  
0.003 
0.004 
0.001(*)  
 
Compound 
Common Name  CAS#  Residue to which the maximum 
residue level applies  Food  Maximum Residue 
Level (mg/kg)  
Bromadiolone  28772- 56-7 Bromadiolone  Pig edible offal 
(except liver)  
Pig liver  
Any other food  
0.003 0.004 
0.001(*)  
 
Compound 
Common Name  CAS#  Residue to which the maximum 
residue level applies  Food  Maximum Residue 
Level (mg/kg)  
Coumatetralyl  5836- 29-3 Coumatetralyl  Pig edible offal 
(except liver)  
Pig liver  
Any other food   
0.003 0.004 
0.001(*)  
 
Compound 
Common Name  CAS#  Residue to which the maximum 
residue level applies  Food  Maximum Residue 
Level (mg/kg)  
Difenacoum  56073- 07-5 Difenacoum  Pig edible offal 
(except liver)  
Pig liver  
Any other food   
0.003 0.004 
0.001(*)  
 
Compound 
Common Name  CAS#  Residue to which the maximum 
residue level applies  Food  Maximum Residue 
Level (mg/kg)  
Difethialone  104653- 34-1 Difethialone  Pig edible offal 
(except liver)  
Pig liver  
Any other food   
0.003 
0.004 
0.001(*)  
 
Compound 
Common Name  CAS#  Residue to which the maximum 
residue level applies  Food  Maximum Residue 
Level (mg/kg)  
Diphacinone  82-66-6 Diphacinone  Pig edible offal 
(except liver)  
Pig liver  
Any other food   
0.003 0.004 
0.001(*)   
8 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice New Zealand Food Safety   
Compound 
Common Name  CAS#  Residue to which the maximum 
residue level applies  Food  Maximum Residue 
Level (mg/kg)  
Flocoumafen 90035- 08-8 Flocoumafen Pig edible offal 
(except liver)  
Pig liver  
Any other foods  
0.003 
0.004 
0.001(*)  
 
Compound 
Common Name  CAS#  Residue to which the maximum 
residue level applies  Food  Maximum Residue 
Level (mg/kg)  
Pindone  83-26-1 Pindone  Pig edible offal 
(except liver)  
Pig liver  
Any other food  
0.003 0.004 
0.001(*)  
 
3.1.1 Amendment Rationale  
The MRLs are being proposed to support the use of VTAs  on or near farms  for rodent control 
while ensuring residues in all animal commodities are minimised .  
The values proposed are based on a worst -case evaluation of brodifacoum, a second-
generation anticoagulant with the greatest potential for persistence in tissues, the low est 
HBGV, and the most significant acute toxicity profile of the group. T he mode s of action for the 
other anticoagulant compounds are similar to brodifacoum, but they present lower potential for 
toxicity and a generally shorter persistence profile and elimination half -life. Because of this, 
and because of the shared GAP across all anticoagulant VTAs , New Zealand Food Safety 
have proposed identical MRLs for all compounds to ensure secondary exposure to 
anticoagulant residues are effectively mitigated in all animal commodities.   
Because poisoned pest animals  can excrete the compounds and their metabolites after 
exposure, food- producing animals may occasionally be subject to secondary exposure to 
anticoagulants through contact with pest waste and/ or poisoned ca rcasses. This infrequent 
and discrete secondary exposure scenario can result in residues in some animals, requiring 
the application of MRLs in animal commodities to reinforce the requirement that food -
producing animals are not exposed to VTAs and to mitigate residue exposure . This is 
particularly  important in pigs given the sector’s reliance on grain- based feeds,  which is most 
likely to attract pest animals and lead to the highest potential likelihood of exposure to pest 
waste or poisoned carcasses.   
Anticoagulant VTAs have a high degree of persistence in liver and other offals and have the 
potential for accumulat ion in these tissues. The MRLs being proposed take this into account 
for the species most likely to be exposed to these compounds, while still ensuring residues 
remain well within what would be expected from a GAP perspective.  
3.1.2 Good Agricultural Practice  
Anticoagulant VTAs  are used in New Zealand to control rodents, possums, and other 
introduced mammalian pests that pose a serious threat to agricultural hygiene through vector -
borne diseases.  In farming situations, these compounds are used to control pests near grain 
stores to prevent feed contamination and loss, and direct human and animal exposure to pests and pest -borne diseases.   
GAP for all anticoagulant VTAs  is use only in areas that are not accessible by non- target 
species, and prevention of direct or primary exposure of food- producing species to the 
compound.   
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  9 3.1.3 Residue Information and MRL determination 
Unlike other agricultural compounds, r esidue evaluation for anticoagulant VTA exposure must 
be based on potential exposure pathways and the absorption, distribution, metabolism, and 
elimination profile of the compounds after exposure.  The exposure pathways and kinetics of 
each compound were reviewed, identifying that brodifacoum presented the greatest amount 
of biological persistence. As brodifacoum is also one of the most commonly used anticoagulant VTA compounds, assessment of brodifacoum as the model for exposure and residue potential 
was considered the most prudent approach to risk management.  
On evaluation of the exposure modelling and available data for brodifacoum, it was determined that use of brodifacoum according to GAP and all controls  should result in residues remaining 
below 0.004 in pig liver, 0.003 mg/kg in pig offal other than liver, and below the limit of 
quantification (0.001 mg/kg) in all other animal -derived food commodities.  As residues of 
anticoagulant VTAs are not expected to exceed the levels proposed for brodifacoum, and all 
eight compounds have the same limit of quantification, the same MRLs are proposed for 
bromadiolone, coumatetralyl, difenacoum, difethialone, diphacinone, flocoumafen, and 
pindone.  It is noted that the ‘any other food’ MRL remains unchanged for brodifacoum, 
bromadiolone, flocoumafen, and pindone for all commodities other than pig liver and other 
offals.  
The residue definitions for MRL compliance and dietary intake will be retained as parent 
compound for the four anticoagulants with existing entries in the Notice (‘brodifacoum’, 
‘bromadiolone’, ‘flocoumafen’, and ‘pindone’), and will be set as parent compound for the four 
new entries (‘coumatetralyl’, ‘difenacoum’,  ‘difethialone’, and ‘diphacinone’).  
3.1.4 Dietary Risk Assessment  
The HBGVs used in evaluating these compounds were 0.0005 mg/kg bw/d for brodifacoum, 
0.002 mg/kg bw/d for bromadiolone, 0.003 mg/kg bw/d for coumatetralyl, 0.0006 mg/kg bw/d for difethialone, and 0.001 mg/kg bw/d for flocoumafen. HBGVs could not  be determined for 
diphacinone, difenacoum, and pindone, but the toxicological analysis of these compounds concluded that they were less toxicological ly potent than brodifacoum.  
Based on the residue profile expected in food from animals treated with brodifacoum according to GAP and in accordance with all controls, the NEDI is estimated to be less than 
2% of the HGBV. As brodifacoum has the lowest HBGV of all eight compounds, this NEDI 
represents the worst case exposure for all anticoagulant VTAs. 
New Zealand Food Safety  has therefore determined that when  anticoagulant VTAs  are used 
in accordance with GAP, with the restrictions and controls in place on the use of these 
compounds in farm situations, and  applying the proposed MRLs, their use is unlikely to pose 
any health risks from authorised use.
  
3.1.5 Relevant International MRLs  
• Brodifacoum  
Authority  Food                                     Maximum Residue Level 
(mg/kg)  
European U nion All food commodities  0.01 
Japan Cattle, pig, and other terrestrial mammals, muscle  
Cattle, pig, and other terrestrial mammals, liver  
Cattle, pig, and other terrestrial mammals, kidney  
Cattle, Pig, and other terrestrial mammals, edible offal  
All other farmed terrestrial mammal commodities  0.0005  
0.0005 
0.0005 
0.0005 
0.001   
10 • Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice New Zealand Food Safety  • Bromadiolone  
Authority  Food                                     Maximum Residue Level 
(mg/kg)  
European U nion All commodities from swine and other farmed terrestrial 
mammals  and poultry  0.01 
• Coumatetralyl  
Authority  Food                                     Maximum Residue Level 
(mg/kg)  
European U nion All food commodities  0.01 
 
• Difenacoum  
Authority  Food                                     Maximum Residue Level 
(mg/kg)  
European U nion 
(from 12/08/24)  All commodities from swine and other farmed terrestrial 
mammals  and poultry  0.01 
 
• Difethialone  
Authority  Food                                     Maximum Residue Level 
(mg/kg)  
Australia  Listed in the Agricultural and Veterinary Chemicals (MRL Standard for Residues of Chemical 
Products) Instrument 2023 as a compound for which no MRL applies when used in baits as a 
rodenticide in situations where contact with crops, food products, or soil in which crops are grown 
will not occur.  
European Union  All food commodities  0.01 
 
• Diphacinone  
Listed in the Agricultural and Veterinary Chemicals (MRL Standard for Residues of 
Chemical Products) Instrument 2023 as a compound for which no MRL applies when 
used in baits as a rodenticide in situations where contact with crops, food products, or 
soil in which crops are grown will not occur.  
 
• Flocoumafen  
Authority  Food                                     Maximum Residue Level 
(mg/kg)  
Australia  Listed in the Agricultural and Veterinary Chemicals (MRL Standard for Residues of Chemical 
Products) Instrument 2023 as a compound for which no MRL applies when used in baits as a rodenticide in situations where contact with crops, food products, or soil in which crops are grown will not occur. 
 
European Union  All food commodities  0.01 
 
 
  
New Zealand Food Safety  Proposals to Amend the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice •  11 • Pindone 
Authority  Food                                     Maximum Residue Level 
(mg/kg)  
Japan All farmed terrestrial mammal and poultry commodities  0.001 
 
3.2 Proposal to amend the Notice entry for dieldrin and aldrin   
It is proposed that the following entry is amended in Schedule 1 of the Notice:  
Compound 
Common Name  CAS#  Residue to which the 
maximum residue level 
applies Food  Maximum Residue 
Level (mg/kg)  
Dieldrin and 
aldrin  60-57-1 and 
309-00-2 Sum of: HHDN and HEOD  
(MRLs cover dieldrin and 
aldrin singly or in 
combination) Cereal grains  
Citrus fruits  
Fats (except milk fats)  
Milk fats  
Any other food  0.02 
0.05 
0.2 
0.15 
0.1 
3.2.1 Amendment Rationale  
Dieldrin and aldrin are banned organochlorine insecticidal compounds and persistent organic 
pollutants for which soil residues continue to be mitigated through the application of MRLs. The deletion of the ‘any other food’ MRL is being proposed because all agricultural 
compound residues detectable in food commodities will be subject to regulatory limits at the 0.1 mg/kg default MRL or lower depending on the commodity, making a specific ‘any other 
food’ listing redundant. All other MRLs will be retained as previously set.