G/TBT/W/600  
14 March  2019 
(19-1582) 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  
6 AND 7 MARCH 2019  
The following communication, dated  14 March  2019, is being circulated at the request of the 
delegation of Colombia . 
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1.  On this occasion, w ith the aim of promoting agricultural development and facilitating foreign 
trade with the European Union (EU), we would like to draw the attention of the EU to a subject of 
great importance for the agricultural sector in Colombia . We would be grateful if you would take our 
comments into consideration.  
2.  Colombia wishes to express its concern regarding the measure notified by the EU through 
document G/TBT/N/EU/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 chlorothalonil  is used for the 
control of Black Sigatoka, a fungus known to devastate banana crops.  
3.  Our country is the fifth largest banana exporter in the world . In 2017, our total production 
amounted to 1.87 million  tonnes , with exports worth USD 850 million. A  total of 80 % of exports go 
to the EU, especially Belgium (575,000 tonnes), Italy (270,000 tonnes) and the United Kingdom 
(242,000 tonnes) . Colombian bana na producers are a major source of employment and 
development . The banana industry in the main producing regions of Urabá, Magdalena and Guajira 
accounts for 35,000 direct and 100,000 indirect jobs.  
4.  The possible adoption of this measure is a source of conc ern, since the decision to withdraw 
marketing approval for the substance, without maximum residue levels (MRLs) being affected for 
the moment, is based on a precautionary principle in response to  concerns mainly relating to 
carcinogenicity classification a nd 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 : 
"Additionally, chlorothalonil is classified as carcinogen category 2 in accordance with Regulation 
(EC) No. 1272/2008 of the European Parliament and of the Council while in the conclusion of the 
Authority it is indicated that chlorothalonil should be classified as carcinogen category 1B . For the 
representative uses considered, residue levels as referred to i n point (b) of Article 18(1) of 
Regulation (EC) No . 396/2005 could not be confirmed for plant and animal products due to lack of 
data on the magnitude and toxicity of metabolites that are included in the residue definition for risk 
assessment . Consequently , the requirement set out in Points 3.6.3 of Annex II to Regulation 
(EC) No. 1107/2009 is not fulfilled ." It is indicated that  no danger or risk has been determined for 
the metabolites concerned . Hence there is a need to request further  information and com plete the 
corresponding risk assessment and then take a decision regarding unacceptable health risks for 
potential consumer s. 
6.  Colombia considers that the classification decision should be taken by the European Chemicals 
Agency (ECHA) as the competent EU au thority 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.  G/TBT/W/600  
- 2 - 
  7.  In view of the information  gaps, it is impossible to establish criteria for accept ance or rejecti on 
of the compound . However , before imposing a ban, the EU should  be encouraged to  fill the 
information gaps and obtain  a risk assessment based on  data, not uncertainty.  
8.  In view of the above, we are fac ed 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, as demonstrated  above , there is insufficient  information to establish 
criteria for accept ance or rejecti on of the chlorothalonil compound , its impact on health not having 
been clearly established in scientific  terms . Furthermore, we wish to mention that any technical 
adoption of an alternative to this active ingredient for the banana industry in Colombia will require 
at least six months . We therefore consider  that the time defined  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.  It is impor tant to mention that the change in the regulations would also seriously affect other 
crops which are exported to the EU , such as : plantains (47,816 tonnes), cape gooseberries 
(5,863  tonnes) and cocoa (1,796 tonnes) (approximate quantities exported in 2018) . 
10.  Without chlorothalonil, fruit pest control would be more difficult 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 . Non-renewal of the approval of the 
active substance chlorothalonil restricts the range of chemical pesticides for use with agricultural 
products , a situation that is not compatible with  tropical agriculture , which is biodiverse in terms of 
pests, diseases and weeds  and cannot be compared with agriculture at  European latitudes . 
Seasonality alone makes European agriculture significantly different from our own agricultural 
reality.  
11.  It is therefore  essential that the EU uses the 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 may affect human health , and the thresholds for safe use of 
the active substance chlorothalonil are unknown.  
12.  In light 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 authorization and use at the global level . It is important 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 cann ot 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 measures established 
must not be more trade -restrictiv e than necessary  or create unnecessary obstacles to trade . 
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