G/TBT/W/696  
26 November  2019 
(19-8096) 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  
13 TO 15 NOVEMBER  2019 
The following communication, dated 13 November  2019, is being circulated at the request of the 
delegation of Colombia . 
 
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1.  Colombia  wishes to reiterate its concern  regarding the measure notified by the EU in  document  
G/TBT/N/EU/625  relating to the non -renewal of the approval of the active substance chlorothalonil . 
This substance is key to pest control for a wide variety of crops, particularly bananas, since it is used 
for the control of Black Sigatoka, a fungus that devastates banana crops.  
2.  In recent months, the EU has adopted a policy to r educe the use of products for the protection 
of plants, which is affecting the exports of its trade partners due to the suspended approval  of 
numerous active substances and the subsequent reduction of their maximum residue levels ( MRLs) 
to the minimum dete ction level, and the lowering  of the MRLs of substances that are still approved . 
These measures have been  taken without any sound scientific evidence and without any proof  that 
they effectively constitute less  trade-restrictive measures to ensure  an approp riate level of 
protection for consumers . 
3.  In Colombia and several  other Latin American countries, the use of certain active compounds , 
such as chlorothalonil, is indispensable in agricultural production for the protection of crops against 
pests and disease s, and for maintaining the quality and safety of products during storage, transport 
and distribution, before they reach  consumers on the European market.  
4.  Furthermore, it is important to indicate  that, regarding the  revision of MRLs, the European Food 
Safety Authority (EFSA) has published , as it has done more and more frequently,  reasoned opinions  
stating that, due to insufficient information, the risk assessment for active ingredients is 
inconclusive . This situation has been  wrongly interpreted by the Europ ean Commission (DG SANTE), 
which , as a precaution, has not renewed the approval of the substances . It is worth noting that, 
contrary to the provisions of the WTO TBT Agreement , the EU's decisions are not provisional and do 
not demonstrate any effort to obt ain the further information necessary to conduct a more objective 
risk assessment.  
5.  The foregoing constitutes a violation of Article 2.2 of the TBT Agreement, which stipulates  that 
technical regulations shall not be more trade -restrictive than necessary to fulfil a legitimate 
objective . As indicated, there is insufficient information to establish criteria for acceptance or 
rejection of the compound chlorothalonil , given that, from a scientific point of view,  its effect on 
health has not been clearly determin ed. 
6.  In light of the above, it is essential for the EU to use a risk assessment approach  in 
decision -making with regard to the application of this measure, since there is insufficient scientific 
evidence to determine the various toxicological aspects that m ay affect human health and the 
thresholds for safe use of the active substance chlorothalonil are unknown.  G/TBT/W/696  
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  7.  It is important that the measures adopted are based on scientific evidence and international 
standards and also take account of the biodiverse agricu lture of countries such as Colombia, which 
cannot be compared with that of European latitudes, where the climatic conditions and seasons are 
very different . The foregoing is in accordance with the terms of the TBT Agreement, which provides 
that any measure s established must not be more trade -restrictive than necessary  or create 
unnecessary obstacles to trade . 
8.  Given the above , Colombia once again requests the EU to maintain the registration of 
chlorothalonil in the EU . 
 
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