G/SPS/GEN/2006  
 
4 April  2022 
(22-2679) Page: 1/2 
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  28 March  2022, is the statement made by the United States 
of America at the 23-25 March 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.  The United States again echoes the concerns by other Members, including Colombia, Ecuador, 
Costa Rica, Paraguay, Uruguay, Brazil, Argentina, Guatemala, Canada, Panama, Peru, and Chile, 
on the EU's approach to establishing pesticide MRL policies.  
2.  Despite frequent and repeated int erventions by Members in this Committee, we remain 
disappointed that the European Union continues to apply its "precautionary principle", creating trade 
barriers which threaten the global food system.  
3.  For decisions based on incomplete risk assessments, we request that the European Union confirm 
that scientific data will be collected and analyzed to justify these measures. For example, the 
European Union recently notified in G/TBT/N/EU/827  the nonrenewal of indoxacarb because the 
European Food Safety Authority (EFSA) was not able to finalize a number of aspects of its risk 
assessment. The United States remains concerned that t he European Union continues to lower MRLs 
to the limit of detection without completing a risk assessment and urges EFSA to complete a 
risk assessment and consider all available scientific information and Codex MRLs before making any 
final decision on MRLs,  including indoxacarb.  
4.  We also note that EFSA recently completed its assessment of emergency authorizations granted 
by eleven EU member States for plant protection products containing active substances that are no 
longer approved for outdoor use in the Eur opean Union. 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.  Based on continued requests for emergency authorizations by EU member States, it is clear that 
producers in the European Union, like those in the United States, view these products as integral 
components of their integrated pest management programs and that EFSA has agreed 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 count ries 
equal access to these important and efficacious crop protection tools.  
6.  While the European Union enforces pesticide MRLs  at the time of importation for imported goods, 
the European Union enforces pesticide MRLs at the time of production for domestic goods. 
We highlight once more the importance of a consistent, science -based enforcement process to 
facilitate trade and protec t 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 G/SPS/GEN/2006  
 
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  at the time of production so as to allow products to move through the full channels  of trade and 
extend the transition period for all MRLs to the maximum term possible. As currently implemented, 
the European Union's approach is counter -productive and unsustainable to maintain the agricultural 
productivity and trade needed to ensure globa l food security.  
7.  Additionally, the United States is concerned about the European Union's statements to this 
Committee in November 2021 indicating that global environmental impacts may be considered in 
future EU  regulatory decisions. The United States requests the European Union to clarify how its 
proposed incorporation of considerations beyond its territorial boundaries will be consistent with 
WTO obligations and respect the national sovereignty and regulatory competence of WTO Members.  
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