G/SPS/GEN/1807  
6 July 2020 
(20-4638) Page: 1/2 
Committee on Sanitary and Phytosanitary Measures  Original:  Spanish  
 
  
MODIFICATION OF EURO PEAN UNION MRLS FOR PLANT PROTECTION PRO DUCTS 
− CHLORPYRIFOS (G/SPS/ N/EU/360)  
COMMUNICATION FROM E CUADOR  
The following  communica tion, rec eived on  6 July 2020, is being circulated at the request of the 
delegation of Ecuador . 
 
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1.  Chlorpyrifos and chlorpyrifos -methyl are substances used worldwide for many strategic crops, 
including those produced by Ecuador and imported by the European Union such as, for example, 
bananas, broccoli, pineapples, coffee, lemons, tree tomatoes and cocoa . These compounds are 
crucial for pest management and crop resistance because, due to the tropical climate in countries 
like Ecuador, pest and disease behaviour follow p atterns that are very different from those prevailing 
in countries with four seasons such as those in the European Union, meaning that their use is vital 
for agricultural production.  
2.  Ecuador recognizes the importance of protecting human health and the envi ronment, which is 
why we have begun work on the domestic front on sustainable and viable production proposals . 
These require more time and major efforts by all stakeholders in the production chain and, primarily, 
substantial financial resources for, inter alia, research and management.  
3.  However, Ecuador considers that regulatory decisions made on the basis of hazard -based criteria 
are inconsistent with international risk -assessment practices, as no considered analysis has been 
made of the impact on human hea lth of exposure to these compounds.  
4.  Ecuador notes the efforts of the European Union to clarify its policy for managing import 
tolerances for substances that trigger maximum residue limits − hazard -based MRLs ; however, it 
recommends that the products, where  these substances are used, be analysed on a case -by-case 
basis in order to determine import tolerances . While the EU takes into account legitimate factors and 
the precautionary principle, this would not address Members' concerns and would create 
considera ble uncertainty for applicants and producers, with a consequent impact on international 
trade in agricultural products.  
5.  Setting MRLs for these active substances at predetermined levels of 0.01 parts per  million  (ppm) 
would have negative trade implications for Ecuador's agricultural exports to the EU and would have 
an impact on European consumers, as the exportable supply of our products would be reduced . 
Furthermore, this measure could have a significant negative impact on the "popular and solidarity 
econom y" and agricultural trade in our country.  
6.  Ecuador urges the EU to ensure that its sanitary and phytosanitary measures are prepared in 
accordance with Article 2.2 of the WTO SPS Agreement, which provides that SPS measures must be 
based on scientific princip les, and with Articles 5.2 and 5.3 of the WTO SPS Agreement, which 
provide that, in assessing risks, Members should take into account current international standards 
and relevant economic factors.  
7.  For this reason, Ecuador requests the EU to take into accou nt the MRLs established in the 
Codex  Alimentarius, so as to ensure that the regulation implemented by the EU is not more 
trade -restrictive than required to achieve its appropriate level of protection.  G/SPS/GEN/1807  
- 2 - 
  8.  Furthermore, the six months normally granted by the EU following notification of its SPS 
measures is an insufficient period, especially for the registration of alternative substances, taking 
into consideration that there are internal processes that have to be undertaken, including protocol 
approvals, conduc ting efficacy trials, validating methodologies for post -registration control, and the 
issuance of official statements by a number of institutions prior to their registration . Ecuador 
therefore requests the EU to consider extending the transition periods fo r the implementation of new 
tolerance levels (MRLs), to a period of 36 months, which will allow for the necessary adaptations to 
be made.  
 
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