G/TBT/W/661  
19 July 2019 
(19-4808) Page: 1/2 
Committee on Technical Barriers to Trade  Original:  Spanish  
 
  
EUROPEAN UNION – CHLOROTHALONIL (PESTICIDE ACTIVE SUBSTANCE)  
STATEMENT BY COLOMBIA TO THE COMMITTEE ON TECHNICAL BARRIERS TO TRADE  
20 AND 21 JUNE 2019  
The following communica tion, dated 1 8 July 2019, is being circulated at the request of the delegation 
of Colombia . 
 
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1.  Colombia wishes to express once again its concern at the approach adopt ed by the 
Europea n Union (EU) with regard to the regulation of pesticides  and, specifically , regarding  the 
measure notified through document G/TBT/N/E U/625  of 4 December  2018, relating to  the 
non-renewal of the approval of the active substance chlorothalonil . This substance is key to pest 
control for a wide range  of crops, and banana exports would be especially affected by the measure, 
since chlorothalo nil is used for the control of Black Sigatoka, a fungus known to devastate banana 
crops . 
2.   This matter has already been brought before this Committee in document G/TBT/W/600  and, 
since it is considered  of great importance  for the agricultural  sector in Colombia, we are grateful to 
the EU for taking our comments into consideration, in order to promote agricultural development 
and facilitate trade between the two parties.  
3.  Our country is the fifth largest banana exporter in the world . In 2017, ou r total banana production 
amounted to 1.87  million tonnes, with exports worth USD 850  million . A total of 80 % of exports go 
to the EU . Colombian banana producers are a major source of employment and wealth in rural areas . 
The main banana -producing regions in Colombia account for 35,000 direct and 100,000 indirect 
jobs. 
4.  The possible adoption of this measure is a source of concern, since the decision to withdraw 
marketing approval for the substance is based on a precautionary principle in response to concerns  
mainly relating to carcinogenicity classification and a lack of data on the magnitude and toxicity of 
metabolites.  
5.  The above is corroborated by Regulation (EC) No.  1272/2008 of the European Parliament, which 
indicates that no danger or risk has been deter mined for the metabolites concerned . Hence there is 
a need to request further information on the compound , complete the corresponding risk assessment 
and then take a decision regarding health risks.  
6.  Colombia considers that the classification decision shoul d be taken by the European Chemicals 
Agency (ECHA) as the competent EU authority in this field, whose opinion should be made available 
before Member States are asked to take a decision on the renewal of the approval of chlorothalonil.  
7.  Moreover, in view of the information gaps, it is impossible to establish criteria for acceptance or 
rejection of the compound . However, steps should be taken to seek additio nal information  before a 
ban is imposed . 
8.  In view of the above, we are faced with a violation of Article 2.2 of the TBT Agreement – which 
provides that technical regulations shall not be more trade -restrictive than necessary to fulfil a 
legitimate objective – since there is insufficient information to establish criteria for acceptance or 
rejection of the chlo rothalonil compound, its impact on health not having been clearly established in G/TBT/W/661  
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  scientific terms . Furthermore, the search for an alternative to this active ingredient for the banana 
industry in Colombia may take at least six months . We therefore consider that the time determined  
for withdrawing this active substance from the production of bananas and other products is not 
viable since there are currently no studies on possible replacements for it.  
9.  Without chlorothalonil, fruit pest control would be more di fficult and exports of Colombian 
bananas and other crops to the EU market would be adversely affected, which, in turn, would have 
a major social and economic impact in the producing regions . It should not be forgotten that this is 
a particular situation in  tropical agriculture, which is biodiverse in terms of pests, diseases and weeds 
and cannot be compared with agriculture in European latitudes . Seasonality alone makes European 
agriculture significantly different from our own agricultural reality.  
10.  In view of the above, Colombia requests the EU to maintain the registration of chlorothalonil in 
the EU, since it is a vital substance for managing resistance development and has been assessed for 
many years as suitable for use at the global level . It is impo rtant that the measures adopted are 
based on scientific evidence and international standards and also take account of the biodiverse 
agriculture of countries such as Colombia, which cannot be compared with that of European latitudes, 
where the climatic con ditions and seasons are very different . The foregoing is in accordance with 
the terms of the TBT Agreement, which provides that any measures established must not be more 
trade -restrictive than necessary or create unnecessary obstacles to trade.  
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