G/SPS/GEN/2041  
 
28 June 2022 
(22-5000) Page: 1/1 
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 TEPRALOXYDIM  
SUBMISSION BY THE UNITED STATES  OF AMERICA  
The following submission, received on  24 June 2022, is the statement made by the United States of 
America at the 22-24 June  2022 WTO SPS Committee, and is  being circulated at the request of the 
Delegation of the United States  of America . 
 
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1.  Despite frequent and repeated interventions by many Members in this Committee, the 
European  Union continues to apply the precautionary principle in its pesticide decision making 
processes, which creates trade barriers that undermine food security, result i n food waste, and 
threaten the global food system.  
2.  The United States and other Members have repeatedly sought to engage the European  Union  
about the impacts that its pesticide policies have on global agricultural supply chains. However, the 
EU's responses to date only refer WTO Members to existing EU regulations rather than directly 
addressing the urgent problems facing agricultural producers and exporters whose pesticide options 
are increasingly limited by EU policies.  
3.  Based on the continued use of emergency authorizations by EU member States, it appears that 
even farmers in the European  Union  do not have viable alternatives to certain active substances that 
are no longer approved for use in the European  Union  despite th e clear need for plant protection 
products.  
4.  In November 2021, EFSA published eleven technical reports with the evaluation of emergency 
authorizations for the use of clothianidin, imidacloprid, thiamethoxam and/or thiacloprid in sugar 
beet from Belgium, Cro atia, Denmark, Finland, France, Germany, Lithuania, Poland, Romania, 
Slovak Republic and Spain. EFSA concluded that in all 17 cases the emergency authorizations were 
justified, either because no alternative products or methods – chemical or non -chemical – were 
available or because there was a risk that the pest could become resistant to available alternative 
products.  
5.  EFSA's own review acknowledges that either no effective alternatives are available or that there 
is a risk of insect resistance to alternative products. Accordingly, we request that the European  Union  
also afford producers in third countries the same and e qual access to important and efficacious crop 
protection tools.  
6.  We highlight once more the importance of a science -based enforcement process to facilitate trade 
and protect plant and human health. The United States calls for the European  Union  to take the least 
restrictive trade actions and apply its MRLs for both imported and domestic goods at the time of 
production so as to allow products to move through the full channels of trade and to extend the 
transition period for all MRLs to the maximum term possib le. As currently implemented, 
the EU approach is counter -productive and unsustainable to maintain the agricultural productivity 
and trade needed to ensure global food security.  
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