Proposals to Amend (No.2) the 
New Zealand (Maximum Residue 
Limits of Agricultural Compounds) Food Standards 2013
 
 
MPI Discussion Paper  No: 2014/10 
  
 
Prepared by the Biosecurity, Food and Animal Welfare Directorate of 
the Ministry for Primary Industries  
  ISBN No: 978- 0-478-42351 -8 (online ) 
ISSN No: 2253- 3907(online)  
 
 
  
February 2014   
 
 
Disclaimer  
 
Every effort has been made to ensure the information in this document is accurate.  
 
MPI does not accept any responsibility or liability whatsoever for any error of fact, omission, 
interpretation or opinion that may be present, however it may have occurred.  
Requests for further copies should be directed to:  
 
Publicat ions Logistics Officer  
Ministry for Primary Industries  
PO Box 2526  
WELLINGTON 6140 
 
Email: brand@mpi.govt.nz  
Telephone: 0800 00 83 33  
Facsimile: 04 -894 0300 
 This publication is also available on the Ministry for Primary Industries  website at  
http://www.mpi.govt.nz/news -resources/publications.aspx  
 
 © Crown Copyright -  Ministry for Primary Industries   
i Contents  Page 
 
1 Submission  1 
2 Introduction 2 
3 Background  2 
3.1 Summary of Proposed Amendment  3 
4 Proposals  4 
4.1 Proposals to set MRLs for chlorpyrifos  4 
4.2 Proposals to set MRLs for kasugamycin  6 
4.3 Proposals to set MRLs for pirimiphos- methyl  7 
4.4 Proposals to set MRLs for propiconazole  9 
4.5 Proposal to exempt benzalkonium chloride from MRLs  10 
4.6 Proposa l to exempt chlorine dioxide from MRLs  12 
4.7 Proposal to exempt Fatty acids of 8 carbons or more in their chains, and their salts from 
MRL  13 
4.8 Proposal to exempt Harpin protein from MRL  14 
4.9 Proposal to exempt oxalic acid from  MRL  15 
4.10  proposal to exempt potassium bicarbonate from MRL  17 
4.11  Proposal to exempt soya bean oil f rom MRL  18 
4.12  Proposal to exempt synthetic latex from MRL  19 
  
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 1 1 Submission  
The Ministry for Primary Industries (MPI) invites public comment on this discussion 
document which outlines proposals to amend the New Zealand (Maximum Residue Limits of 
Agricultural Compounds) Food Standards.  
 The following points may be of assistance in preparing comments:  
• Wherever possible, comment should be specific to a particular section in the 
document.  All major sections are numbered and these numbers should be used to link 
comments to the document.  
• Where possible, reasons and data to support comments are requested.  
• The use of examples to illustrate particular points is encouraged.  
• As a number of copies may be made of your comments, please use good quality type, 
or make sure th e comments are clearly hand -written in black or blue ink.  
 
Please include the following information in your submission:  
• the title of the discussion document;  
• your name and title (if applicable);  
• your organisation’s name (if applicable); and  
• your address.  
 Please submit your response by 5:00pm on  25 April 2014.   Your comments should be sent to:  
 MRL Amendments  
MPI Food Policy  
PO Box 2835  
Wellington  
 
Email: FoodPolicy@MPI.govt.nz  
Fax: (04) 894 2530  
 
The Official Information Act  
 
Everyone has the right to request information held by government organisations, known as 
“official information”. Under t he Official Information Act 1982 (the OIA) , information is to 
be made available  to requestors unless there are grounds for withholding it. The grounds for 
withholding information are outlined in the OIA.   
 
If you are submitting on this discussion document, you may wish to indicate any grounds for 
withholding information contained in your submission.  Reasons for withholding information 
could include that informati on is commercially sensitive or that the submitters wish personal 
information such as names or contact details to be withheld.  MPI will take such indications into account when determining whether or not to release information.   
 Any decision to withhold information requested under the OIA may be reviewed by the 
Ombudsman.  
 
For more information please visit 
http://www.ombudsman.parliam ent.nz/resources -and-
publications/guides/official -information -legislation -guides   2 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries  2 Introduction  
The term Maximum Residue Limit refers to the maximum legal limits for residues of 
agricultural compounds and veterinary medicines in any food for sale in New Ze aland..  
 
Maximum residue limits (MRLs) are used to minimise risks to public health by ensuring that 
chemical residues in food are as low as practicable, without compromising the ability of the 
chemical to successfully do what is intended.  
 MRLs are also a tool for monitoring the use of agricultural compounds in accordance with 
good agricultural practice. G ood Agricultural Practice or GAP  is not explicitly defined or 
regulated, but is the generally accepted means for producing safe primary produce,  in a 
particular location  and taking account of climate, pests or diseases and other environmental 
factors.  
 
3 Background  
 
MRLs are set out in the ‘ New Zealand (Maximum Residue Limits of Agricultural 
Compounds) Food Standards ’ otherwise known as the MRL Standards.  
 
The MRL Standards are amended a number of times each year to reflect changes in the use of 
agricultural compounds in the production of food. The y are available from the Ministry for 
Primary Industries (MPI) Foodsafety website at: 
http://www.foodsafety.govt.nz/elibrary/industry/register -list-mrl-agricultural -compounds.htm  
 MPI administers the MRL Standards, but the final decision on any changes  made  to the se 
standards rests with the Minister for Food Safety.  
 
Under section 11E and 11L of the Food Act 1981, when amending or issuing the MRL 
Standards, the Minister must take into account the following:  
• The need to protect public health.  
• The desirability of avoiding unnecessary restrictions on trade.  
• The desirability of maintaining consistency between New Zealand's food standards and those applying internationally.  
• New Zealand's obligations under any relevant international treaty, agreement, 
convention, or protocol, and, in particular, under the Australia -New Zealand Joint 
Food Standards Agreement.  
• Such other matters as the Minister considers appropriate.  
 
Possible public health implications are considered during toxicological and dietary risk 
assessments.  The Estimated Dietary Intake of the residue is compared with a Potential Daily 
Exposure 
(food) (PDE (food)). Where there is no PDE (food), the estimated dietary intake is 
compared with the Acceptable Daily Intake (ADI). PDE (food) and ADI are described below.  
 
A PDE (food) is a value determined by the Environmental Protection Authority (EPA)  through 
a toxicological evaluation . The EPA unde rtakes this  as part of its responsibility for managing 
public health under the Hazardous Substances and New Organisms Act 1996 (the HSNO 
Act).  A PDE (food) gives the potential daily exposure a person may be subject to from a 
substance, via food.   
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 3 An ADI i s defined by the World Health Organization (WHO) as:  
  
“the daily intake which, during an entire lifetime, appears to be without appreciable 
risk on the basis of all the known facts at the time”.  
 The term “without appreciable risk” is further defined as:  “the practical certainty that injury 
will not result even after a lifetime of exposure”.   
ADIs are established by the WHO and Food and Agriculture Organization of the United 
Nations joint expert committees . These Committees  are made up of toxicologists and residue 
specialists. The ADI information from these joint committees also feeds into the Codex Alimentarius Commission (Codex), which sets international MRLs.  
 As required by the HSNO Act, MPI uses a PDE 
(food) where it is available, rather than the  
internationally -determined ADI . The ADI and PDE (food) are largely equivalent, as they are 
determined using a very similar scientific process and the same set of toxicology data.  
 
3.1 SUMMARY OF PROPOSED AMENDMENT  
The proposed MRLs have been thoroughly assessed i n accordance with international 
methodologies such as those used by the expert committees described above .  
 Information on the technical assessment of each proposal is included in this document (refer 
section 2) and covers the following:  
• rationale;  
• chemic al information;  
• good agricultural practice;  
• residues information;  
• dietary risk assessment;  
• toxicological/public health assessment; and  
• International MRLs.  
 
MPI has reviewed the estimated dietary exposure assessments for the proposals in this 
discussion paper. MPI has determined that the residues associated with the proposed MRLs 
do not present any public health and safety concerns.  
3.1.1 New MRLS  
MPI proposes to add the following new MRL to the MRL Standards:  
• 0.01 mg/kg for chlorpyrifos when used as a insecticide  in potatoes  
• 0.01 mg/kg for kasugamycin when used as a bactericide in kiwifruit  
• 0.01 mg/kg for propiconazole when used as a fungicide in avocados  
3.1.2 Exempt from MRLS  
MPI proposes to exempt the following substances from MRL s: 
• Extend the current exem ption for benzalkonium c hloride  to use on avocados and use 
as bactericide on kiwifruit  
• Extend the current exemption for chlorine dioxide to use as a bactericide  
• Extend the current exemption for f atty acids of 8 carbons or more in their chains, and 
their sa lts to use as a plant growth regulator  
• Harpin protein when used as a plant elicitor on horticultural crop  
• Oxalic acid when used in beehives  4 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries  • Extend the current exemption for potassium bicarbonate to use as plant growth 
regulator  
• Soya bean oil when used as a fungicide  
• Synthetic latex when used as an anti pod shatter.  
3.1.3 Other Amendments  
• Pirimiphos -methyl - Change pome fruits to apples and pears.  
4 Proposals  
4.1 PROPOSALS TO SET MRLS FOR CHLORPYRIFOS  
It is proposed that an MRL is set for chlorpyrifos  when used on potatoes . The current entry 
for chlorpyrifos  in Schedule One of the MRL Standards is:  
Compound Common 
Name  CAS#  Residue to which the 
maximum residue 
limit applies  Food Maximum Permitted 
Residue Level 
(mg/kg)  
Chlorpyrifos  2921 -88-2 Chlorpyrifos  Bananas  2 
   Fruit (except 
bananas, grapes, 
kiwifruit and stone 
fruits)  0.2 
   Grapes  
Kiwifruit  
Maize  
Onions  
Sheep fat  
Stone fruits  
Tomatoes  1 
2 
0.02 
0.1 
1.5 
1 
0.2 
 
The revised entry for chlorpyrifos  in Schedule One of the MRL Standards will therefore read:  
 
Compound 
Common Name  CAS#  Residue to which the 
maximum residue 
limit applies  Food Maximum Permitted 
Residue Level (mg/kg)  
Chlorpyrifos  2921 -88-2 Chlorpyrifos  Bananas  2 
   Fruit (except 
bananas, grapes, 
kiwifruit and stone 
fruits)  0.2 
   Grapes  
Kiwifruit  
Maize  
Onions  
Potatoes  
Sheep fat  
Stone fruits  
Tomatoes  1 
2 
0.02 
0.1 
0.01(*)  
1.5 
1 
0.2 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
4.1.1 Amendment Rationale  
The proposed MRL represents the expansion of use of a currently registered active ingredient. 
The proposed MRL will manage the use of chlorpyrifos  as an insecticide on potatoes  and in 
accordance with the application rates and withholding periods that are p roposed as good 
agricultural practice (GAP) in New Zealand.   
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 5 4.1.2 Chemical Information  
Common name of compound  Chlorpyrifos  
Use of compound  Insecticide  
Chemical Abstract Services (CAS) Registry number  2921 -88-2 
Type of compound  Organophosphate  
Administration  method  Spray  
4.1.3 Good Agricultural Practice  
Chlorpyrifos  is proposed for use as a n insecticide  in potatoes . Application is at maximum rate 
of 500 gai/ha , to be applied to treat potato tuber moth at first sighting then at 2 weeks 
intervals, to treat tomato/potato psyllid with four ‘back to back’ applications  at 7 day interval s 
with a 14 day withholding period.  
4.1.4 Residue Information 
The residue data for t he crops supports an MRL of 0.01  mg/kg for chlorpyrifos  in potatoes  
when the last treatment is 14 days prior to harvest. An MRL of 0.01 mg/kg in potatoes  is 
proposed to support GAP.  
4.1.5 Dietary Risk Assessment  
The PDE (food) of 0.003 mg/kg bw/d was considered appropriate for use in the assess ment . The 
proposed MRL is; potatoe s – 0.01 mg/kg.  
 
The chronic dietary exposure to chlorpyrifos  is estimated by the National Estimated Dietary 
Intake (NEDI) calculation encompassing all registered uses of the chemical and food consumption data based upon the 1997 National Nutritional Survey for adults and the 1995 
National Nutrition Survey of Australia, for children. The NEDI calculation is made in 
accordance with Guidelines for predicting dietary intake of pesticide residues (revised) 
[World Health Organization, 1997].  
 Based on the proposed MRLs, the NEDI  for chlorpyrifos  is equivalent to 87 % of the 
PDE
(food) so the chronic dietary exposure and the risk is acceptable.  
4.1.6 Toxicological/Public Health Assessment  
The use of chlorpyrifos  as an insecticide  for potatoes  according to the GAP specified above is 
very unlikely to pose any health risks from consumption of treated produce.  
4.1.7 Other International MRLs  
Country  Food Maximum Residue Limit 
(mg/kg)  
Australia  Potato  0.05 
European Union  Potatoes  0.05(*)  
Japan  Potato  0.05 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
 Under clause 6(3)(b) of the MRL Standards , imported food may contain residues of 
agricultural compounds no greater than the MRLs specified for that food in the current editions or supp lements of the FAO/WHO Codex Alimentarius Commission publications 
Pesticide Residues in Food or  Residues of Veterinary Drugs in Foods . 
 
Therefore,  New Zealand  can meet its  obligations under the Agreement on the Application of 
Sanitary and Phytosanitary Measures , the proposed MRL will be notified to the World Trade 
Organization. Any country may choose to comment if they believe the proposed MRL 
represents a barrier to their trade.  6 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries  4.2 PROPOSALS TO SET MRLS  FOR KASUGAMYCIN  
It is proposed that an MRL is set for kasugamycin when used in kiwifruit.  
 
The final entry for kasugamycin in Schedule One of the MRL Standards will read:  
Compound 
Common Name  CAS#  Residue to which the 
maximum residue 
limit applies  Food Maximum Permitted 
Residue Level (mg/kg)  
Kasugamycin  19408 -46-9 Kasugamycin  Kiwifruit  0.01(*)  
     
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
4.2.1 Amendment Rationale  
The proposed MRL represents a use of the new active ingredient. The proposed MRL will 
manage the use of kasugamycin  as a bactericide in kiwifruit  in accordance with the 
application rates and withholding periods that are proposed as good agricultu ral practice 
(GAP) in New Zealand.  
4.2.2 Chemical Information  
Common name of compound  Kasugamycin  
Use of compound  Bactericide  
Chemical Abstract Services (CAS) Registry number  19408 -46-9 
Type of compound  Aminoglycoside antibiotic  
Administration method  Spray  
4.2.3 Good Agricultural Practice  
Kasugamycin  is proposed for use as a bactericide in kiwifruit . Application is at rate of 60 – 
100 gai/ha, to be applied pre -flowering or after harvest  at a maximum of 4 applications per 
season.  
4.2.4 Residue Information 
The residue data for the crops supports an MRL of 0.01 mg/kg for kasugamycin in kiwifruit. 
The MRL  is proposed to support GAP.  
4.2.5 Dietary Risk Assessment  
The PDE (food) of 0.0 8 mg/kg bw/d was considered appropriate for use in t he assessment. The 
proposed MRL  is 0.01 mg/kg.  
 
Based on the proposed MRLs, the NEDI for kasugamycin  is equivalent to less than 1 % of the 
PDE (food). It is therefore concluded that the chronic dietary exposure is small and the risk is 
acceptable.  
4.2.6 Toxicological/Public Health Assessment  
The use of kasugamycin as a bactericide for kiwifruit  according to the GAP specified above, 
is very unlikely to pose any health risks from consumption of treated produce.  
  
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 7 4.2.7 Other International MRLs  
Country  Food Maximum Residue Limit 
(mg/kg)  
Japan  Kiwifruit  0.04 
 
Under clause 6(3)(b) of the MRL Standards , imported food may contain residues of 
agricultural compounds no greater than the MRLs specified for that food in the current editions or supplements of the FAO/WHO Codex Alimentarius Commission publications  
Pesticide Residues in Food or  Residues of Veterinary Drugs in Foods . 
 
To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the proposed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the proposed MRL represents a barrier to 
their trade.  
4.3 PROPOSALS TO SET MRLS  FOR PIRIMIPHOS -METHYL  
It is proposed that the current MRLs for pirimiphos -methyl in pome fruits and persimmons  
are amended to reflect the inclusion of persimmons in the pome fruit crop group .  
 The current entry for pirimiphos -methyl in Schedule One of the MRL Standards is:  
Compound Common 
Name  CAS#  Residue to which the 
maximum residue 
limit applies  Food Maximum 
Permitted Residue 
Level (mg/kg)  
Pirimiphos -methyl  29232 -93-7 Pirimiphos -methyl  Beans  0.2 
   Berries and other 
small fruits  
Brassica vegetables  
Cereal grains  
Citrus fruits  
Fruiting vegetables  
Kiwifruit  
Leafy vegetables  
Persimmons  
Pome fruits  1 
 
2 
5 
1 
1 
2 
10 
0.5 
1 
     
 
The revised entry for pirimiphos -methyl in Schedule One of the MRL Standards will 
therefore read:  
Compound 
Common Name  CAS#  Residue to which the 
maximum residue 
limit applies  Food Maximum Permitted 
Residue Level (mg/kg)  
Pirimiphos -methyl  29232 -93-7 Pirimiphos -methyl  Beans  0.2 
   Berries and other 
small fruits  
Brassica vegetables  
Cereal grains  
Citrus fruits  
Fruiting vegetables  
Kiwifruit  
Leafy vegetables  
Persimmons  
Pomefruit except 
persimmons  1 
 
2 
5 
1 
1 
2 
10 
0.5 
1 
     8 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries  4.3.1 Amendment Rationale  
The proposed changes reflect the new Codex classification for persimmons which is now 
included in the pome fruit group.  New Zealand adopts the Codex crop grouping system. There 
are no other changes to  the currently approved use pattern which are considered  good 
agricultural practice in New Zealand.  
4.3.2 Chemical Information  
Common name of compound  Pirimiphos -methyl  
Use of compound  Insecticide  
Chemical Abstract Services (CAS) Registry number  29232 -93-7 
Type of compound  Organophosphate  
Administration method  Spray  
4.3.3 Good Agricultural Practice  
No changes  
4.3.4 Residue Information 
No changes  
4.3.5 Dietary Risk Assessment  
No changes  
4.3.6 Toxicological/Public Health Assessment  
The use of pirimiphos -methyl  as an insecticide for pome fruits  according to GAP , is very 
unlikely to pose any health risks from consumption of treated produce.  
4.3.7 Other International MRLs  
Country  Food Maximum Residue Limit 
(mg/kg)  
European Union  Apples, Pears, Persimmon  0.05(*)  
Japan  Apples, Pears, Japanese 
persimmon  1 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
 
Under clause 6(3)(b) of the MRL Standards imported food may contain residues of 
agricultural compounds no greater than the MRLs specified for that food in the current 
editions or suppl ements of the FAO/WHO Codex Alimentarius Commission publications 
Pesticide Residues in Food or  Residues of Veterinary Drugs in Foods . 
 
To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the propo sed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the proposed MRL represents a barrier to their trade.   
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 9 4.4 PROPOSALS TO SET MRLS FOR PROPICONAZOLE  
It is proposed that an MRL is set for propiconazole  when used on avocados .  
 
The current entry for propiconazole in Schedule One of the MRL Standards is:  
Compound Common 
Name  CAS#  Residue to which the 
maximum residue 
limit applies  Food Maximum Permitted 
Residue Level (mg/kg)  
Propiconazole  60207 -90-1 Propiconazole  Apples  0.01(*)  
   Barley  0.02(*)  
   Mushrooms  
Oats  
Olives  
Wheat  0.05(*)  
0.02(*)  
0.01(*)  
0.02(*)  
     
 
The revised entry for propiconazole in Schedule One of the MRL Standards will therefore 
read:  
Compound Common 
Name  CAS#  Residue to which  the 
maximum residue 
limit applies  Food Maximum Permitted 
Residue Level (mg/kg)  
Propiconazole  60207 -90-1 Propiconazole  Apples  
Avocados  0.01(*)  
0.01(*)  
   Barley  0.02(*)  
   Mushrooms  
Oats  
Olives  
Wheat  0.05(*)  
0.02(*)  
0.01(*)  
0.02(*)  
     
4.4.1 Amendment Rationale  
The proposed MRL represents the expan ded use of a currently registered active ingredient. 
The proposed MRL will manage the use of propiconazole  as a fungicide to anthracnose  on 
avocados  and in accordance with the application rates and withholding  periods that are 
proposed as good agricultural practice in New Zealand.  
4.4.2 Chemical Information  
Common name of compound  Propiconazole  
Use of compound  Fungicide  
Chemical Abstract Services (CAS) Registry number  60207 -90-1 
Type of compound  Triazole  
Administration method  Spray  
4.4.3 Good Agricultural Practice  
Propiconazole is proposed for use as a fungicide in avocados. Application is at rate of 
7.5gai/100L , to be applied at two monthly inte rvals from flowering to harvest and 60 days 
withholding period.  
4.4.4 Residue  Information 
The residue data for t he crops supports an MRL of 0.01  mg/kg for propiconazole in avocados  
when the last treatment is 60 days prior to harvest. An MRL of 0.01 mg/kg in avocados is  
proposed to support GAP.  10 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries  4.4.5 Dietary Risk Assessment  
The pot ential daily exposure via food (PDE (food)) is used for dietary intake calculation where a 
value has been set.  An appropriate acceptable daily intake (ADI) is used in the absence of a 
PDE (food). The ADI of 0.04 mg/kg bw/d was considered appropriate for use  in the assessment 
and is consistent with overseas reputable regulatory bodies. The proposed MRL is; avocado –  
0.01 mg/kg.  
 The chronic dietary exposure to propiconazole is estimated by the National Estimated Dietary 
Intake (NEDI) calculation encompassing all registered uses of the chemical and food 
consumption data based upon the 1997 National Nutritional Survey for adults and the 1995 
National Nutrition Survey of Australia, for children. The NEDI calculation is made in 
accordance with Guidelines for predi cting dietary intake of pesticide residues (revised) 
[World Health Organization, 1997].  
 
Based on the proposed MRLs, the NEDI for propiconazole is equivalent to less than 1 % of 
the ADI. It is therefore concluded that the chronic dietary exposure is small and the risk is 
acceptable.  
4.4.6 Toxicological/Public Health Assessment  
The use of propiconazole  as a fungicide for avocados  according to the GAP specified above, 
is very unlikely to pose any health risks from consumption of treated produce.  
4.4.7 Other International  MRLs  
Country  Food Maximum Residue Limit 
(mg/kg)  
Australia  Avocado  0.02(*)  
European Union  Avocado  0.05(*)  
Japan  Avocado  0.05 
USA Avocado  10 (Section 18)  
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
Section 18 – Time -limited tolerances. Expires on 31/12/13  
 Under clause 6(3)(b) of the MRL Standards imported food may contain residues of 
agricultural compounds no greater than the MRLs specified for that food in the current 
editions or su pplements of the FAO/WHO Codex Alimentarius Commission publications 
Pesticide Residues in Food or Residues of Veterinary Drugs in Foods . 
 
To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the proposed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the proposed MRL represents a barrier to 
their trade.  
 
4.5 PROPOSAL  TO EXEMPT BENZALKONIUM CHLORIDE FROM MRL S  
It is proposed that the current MRL exemption for benzalkonium chloride be extended for as a fungicide on avocado and bactericide on kiwifruit.  
 The current  entry in Schedule Two of the  NZ (MRL) Standards 2013 is as follows:  
Compound  CAS#  Condition  
Benzalkonium chloride  8001 -54-4 When applied as a fungicide prior  to the end of flowering on 
kiwifruit , olives  and as a fungicide applied prior to the end of 
December on pome fruits  
  
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 11 The resulting entry for benzalkonium chloride in Schedule Two will be : 
Compound  CAS#  Condition  
Benzalkonium chloride  8001 -54-4 When applied prior to the end of flowering on kiwifruit and 
olives, from flowering on avocados and prior to the end of 
December on pome fruits  
4.5.1 Amendment Rationale  
The proposed MRL exemption represents an extension o the cur rent use patterns for 
benzalkonium chloride to include treatment of avocados and use as bactericide on kiwifruit.  
4.5.2 Chemical Information  
Common name of compound  Benzalkonium chloride  
Use of compound  Fungicide , Bactericide  
Chemical Abstract Services (CAS) Registry number  8001 -54-4 
Type of compound  Quaternary ammonium  
Administration method  Spray  
 
4.5.3 Good Agricultural Practice  
Benzalkonium chloride is proposed as fungicide for avocados and bactericide for kiwi fruit.  
4.5.4 Residue Information 
As benzalkonium chloride is also used safely in many cleaning products and medicinal 
products such as eye drops and mouth washes , the management of GAP through the 
establishment of MRLs has been deemed unsuitable.  There are too many other variables 
present to judge whethe r an MRL breach would represent misuse, including its presence in 
exempt agricultural chemicals and in surface sanitizers.  
4.5.5 Dietary Risk Assessment  
No acceptable daily intake (ADI) has been set for benzalkonium chloride. Trace amounts of 
benzalkonium may be  consumed with no incident through accidental contamination of food 
and water with surface cleaners and dishwashing liquids. No dietary risk is expected through 
the use of benzalkonium on avocados and kiwi fruit . 
4.5.6 Toxicological/Public Health Assessment  
The exemption of benzalkonium chloride from an MRL to the conditions specified above is 
very unlikely to pose any health risks from consumption of the harvested commodities.  
4.5.7 Other International MRLS  
 
There are no other international MRLs for benzelkonium chlo ride. 
 To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the proposed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the proposed MRL rep resents a barrier to 
their trade.  12 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries  4.6 PROPOSAL TO EXEMPT CH LORINE DIOXIDE FROM MRL S  
It is proposed that the current MRL exemption for chlorine dioxide  to include as bactericide.  
 
The current entry in Schedule Two of the  NZ (MRL) Standards 2013 is as follows:  
Compound  CAS#  Condition  
Chlorine dioxide  10049 -04-4 When applied as a fungicide to fruit and vegetables at a 
concentration not exceeding 10ppm.  
 
The resulting entry for chlorine dioxide in Schedule Two of the NZ (MRL) Food Standards 
2013 will be : 
Compound  CAS#  Condition  
Chlorine dioxide  10049 -04-4 When applied as a n agricultural chemical  to fruit and 
vegetables at a concentration not exceeding 10ppm.  
4.6.1 Amendment Rationale  
The proposed MRL exemption represents an extension o f the current use patterns for chlorine 
dioxide to include use as bactericide on fruits and vegetables.  
4.6.2 Chemical Information  
Common name of compound  Chlorine Dioxide  
Use of compound  Fungicide, Bactericide  
Chemical Abstract Services (CAS) Registry number  10049 -04-4 
Type of compound  Halogen oxide  
Administration method  Spray  
 
4.6.3 Good Agricultural Practice  
Chlorine dioxide  is proposed for use as a  bactericide for fruits and vegetables.   Application 
may be at a concentration of up to 10 ppm chlorine dioxide.  
4.6.4 Residue Information 
Chlorine dioxide rapidly decompos es in the environmen t, breaking down to chloride ions and 
oxidised products of organic media. Given the low rate of application and the rapid 
decomposition it would not be expected that residues will rem ain on food at the time of 
consumption. Chlorine dioxide is also used in a range of processing aid roles and in some drinking water treatment.  
4.6.5 Dietary Risk Assessment  
No ADI has been set for chlorine dioxide however it was assessed by New Zealand’s Environmental Risk  Management Authority to represent a negligible risk to human health . 
Chlorine Dioxide is used already for treatment of drinking water and as a processing aid it is 
unlikely to represent a dietary risk.  
4.6.6 Toxicological/Public Health Assessment  
The exemption of chlorine dioxide from an MRL to the conditions specified above is very 
unlikely to pose any health risks from consumption of the harvested commodities.   
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 13 4.6.7 Other International MRLS  
There are no other international MRLs for chlorine dioxide.  
 
To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the proposed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the proposed MRL represent s a barrier to 
their trade.  
4.7 PROPOSAL TO EXEMPT FATTY ACIDS OF 8 CARBONS OR MORE IN THEI R 
CHAINS, AND THEIR SA LTS FROM MRL  
It is proposed that the current MRL exemption for fatty acids with 8 carbons or more in their 
chains and their salts  to include use a s plant growth regulator . 
 
The current entry in Schedule Two of the NZ (MRL) Standards 2013 is as follows:  
Compound  CAS#  Condition  
Fatty acids of 8 carbons or 
more in their chains, and 
their salts  n/a Used as herbicides, insecticides or fungicides  
 
The resulting entry for fatty acid in Schedule Two of the NZ (MRL) Food Standards 2013 
will be : 
Compound  CAS#  Condition  
Fatty acids of 8 carbons or 
more in their chains, and 
their salts  n/a When used as an agricultural chemical  
4.7.1 Amendment Rationale  
The proposed MRL exemption represents an extension o f the current use patterns for fatty 
acid to include use to enhance maturity of white grapes.  
4.7.2 Chemical Information  
Common name of compound  Fatty acids of 8 carbons or more in their chains, 
and their salts  
Use of compound  Fungicide, Plant growth regulator  
Chemical Abstract Services (CAS) Registry number  n/a 
Type of compound  Fatty acid  
Administration method  Spray  
 
4.7.3 Good Agricultural Practice  
Fatty acids of 8 carbons or more in their chains, and their salts  are proposed for use as a plant 
growth regulator for grapes, to be applied post veraison.  
4.7.4 Residue Information 
Fatty acids of 8 carbons or more in their chains, and their salts  are common and essential part 
of the human diet . They are naturally occurring i n the environment, readily and rapidly 
metabolised and degraded by micro -organisms. It is expected that additional input of fatty 
acids to the environment resulting from use as agricultural chemicals will be indistinguishable 
from naturally present fatty acids. T herefore it is proposed that fatty acid  be exempted from 
an MRL . 14 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries  4.7.5 Dietary Risk Assessment  
No ADI has been set for f atty acids of 8 carbons or more in their chains, and their salts . Fatty 
acids are an essential component in all living organisms . There fore the use of the compound  
as a fungicide presents no dietary risk.  
4.7.6 Toxicological/Public Health Assessment  
The use of fatty acid  as a plant growth regulator  for use on grapes , in accord ance with  the 
good agricultural practice specified above, is very unl ikely to pose any health risks from 
consumption of the harvested commodity.  
4.7.7 Other International MRLS  
Country  Compound  Food Maximum Residue Limit 
(mg/kg)  
Australia  Potassium salts of fatty 
acids  Grapes  Exempt when used as a 
fungicide on grapevines  
  Fruit, vegetable ,cotton  Exempt when used as a n 
insecticide on fruit, 
vegetables and cotton  
EU Fatty acid C7 – C20 All food  No maximum residue levels 
are required (Annex 4)  
USA C12 -C18 fatty acid 
potassium salts  All raw commodities  Exempt from the 
requirement of a tolerance for residues  in or on all raw  
commodities when used in accordance with approved label rates and good 
agricultural practice  
 
Under clause 6(3)(b) of the MRL Standards , imported food may contain residues of 
agricultural compounds no greater than the MRLs specified for that food in the current editions or supplements of the FAO/WHO Codex Alimentarius Commission publications 
Pesticide Residues in Food or  Residues of Veteri nary Drugs in Foods . 
 To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the proposed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the p roposed MRL represents a barrier to 
their trade.  
4.8 PROPOSAL TO EXEMPT H ARPIN PROTEIN FROM MRL  
It is proposed that an MRL exemption is set for harpin αβ protein  when used as an agricultural 
chemical . 
 It is proposed that Schedule Two of the MRL Standards be amended by adding the following:  
Compound  CAS#  Condition  
Harpin αβ protein  n/a The source(s) of the harpin αβ protein must be non -
pathogenic or non-toxic to human.  The extracted Harpin αβ 
protein must be purified and be free of any bacterial cells.  
 
4.8.1 Amendment Rationale  
The proposed MRL exemption represents a new use pattern in New Zealand for harpin αβ 
protein . It is not suitable to be managed against a chemical concentration limit  as it degrades 
rapidly in the field and because of its very low toxici ty, human health risks are expected to be 
minimal.   
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 15  
Chemical Information  
Common name of compound  Harpin αβ protein  
Use of compound  Plant elicitor  
Chemical Abstract Services (CAS) Registry number  n/a 
Type of compound  Protein molecule  
Administration method  Spray  
 
4.8.2 Good Agricultural Practice  
Harpin αβ protein is proposed for use as a plant elicitor  on horticultural crops to improve 
plant health, vigour and yield.  
4.8.3 Residue Information 
Harpin αβ protein degrades rapidly in the field . Therefore, it is not appropriate to be regulated 
against an MRL.  
4.8.4 Dietary Risk Assessment  
Harpin αβ protein degrades rapidly in the field and it has very low toxicity . Therefore the use 
of harpin αβ as a plant elicitor presents no dietary risk.  
4.8.5 Toxicological/Public Health Assessment  
Human health risks posed by harpin αβ are expected to be minimal. No toxic effects were 
observed in the available mammalian toxicity data . Therefore, exemption of harpin αβ from 
an MRL to the conditions specified above will not pose any health risks from the 
consumption of the treated crop . 
4.8.6 Other International MRLS  
Country  Food Maximum Residue Limit 
(mg/kg)  
USA All food  Exempt . Must meet specified 
physiochemical and 
toxicological criteria when 
used as biochemical 
pesticides   
 
Under clause 6(3)(b) of the MRL Standards imported food may contain residues of 
agricultural compounds no greater than the MRLs specified for that food in the current 
editions or supplements of the FAO/WHO Codex Alimentarius Commission publications 
Pestici de Residues in Food or  Residues of Veterinary Drugs in Foods . 
 To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the proposed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the proposed MRL represents a barrier to 
their trade.  
4.9 PROPOSAL TO EXEMPT O XALIC ACID FROM MRL  
It is proposed that an MRL exemption is set for oxalic  acid when used as an agricultural 
compound in bee  colonies . 
 It is pr oposed that Schedule Two of the MRL Standards be amended by adding the following:  
Compound  CAS#  Condition  
Oxalic acid  144-62-7 Used as a pesticide in bee colonies  16 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries   
4.9.1 Amendment Rationale  
The proposed MRL exemption represents a  new use pattern in New Zealand for oxalic  acid. 
Oxalic  acid is a common substance in food, with reported levels of about 0.5 – 2%, up to 12% 
in spinach . Oxalic residues in honey will vary considerably, depending on the nectar source, 
and the proposed use is n ot likely to contribute significantly to the inherent levels. It is also a 
natural constituent of honey and is found normally in the range of 1mg/kg to 800 mg/kg. It 
exhibits low volatility and is not fat soluble, thus unlikely to migrate into wax or becom e 
widely dispersed throughout treated hives.  Therefore, it is not suitable to be managed against 
a chemical concentration limit.  
4.9.2 Chemical Information  
Common name of compound  Oxalic  acid 
Use of compound  Insecticide  
Chemical Abstract Services (CAS) Registry number  144-62-7 
Type of compound  Organic dicarboxylic acid  
Administration method  Trickling  
 
4.9.3 Good Agricultural Practice  
Oxalic acid is proposed for use as an insecticide to control varroa mites in honeybee colonies 
after honey supers have been removed.  
4.9.4 Residue Information 
Oxalic  acid is a common substance in food, with reported levels of about 0.5 – 2%, up to 12% 
in spinach . Oxalic residues in honey will vary considerably, depending on the nectar source, 
and the proposed use is not likely to contribute significantly to the inherent levels. It is also a 
natural constituent of honey and is found normally in the range of 1mg/kg to 800 mg/kg. It 
exhibits low volatility and is not fat soluble, thus unlikely to migrate into wax or become 
widely disp ersed throughout treated hives. Therefore, it is not appropriate to be regulated 
against an MRL.  
4.9.5 Dietary Risk Assessment  
Oxalic acid is a natural constituent of honey and is found normally in the range of 1 mg/kg to 
800 mg/kg. The proposed use of oxalic ac id is not likely to contribute  significantly to these 
levels.  
4.9.6 Toxicological/Public Health Assessment  
Oxalic acid is corrosive to the eyes and skin . It is a natural constituent of honey and is found 
normally in the range of 1 mg/kg to 800 mg/kg and is very  unlikely  the proposed use pattern 
will significantly increase the natural contents. Therefore, exemption of oxalic acid from an 
MRL to the conditions specified above will not pose any health risks from the consumption of 
honey or any other food containing honey.   
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 17 4.9.7 Other International MRLS  
Country  Food Maximum Residue Limit 
(mg/kg)  
European Union  Honey bees  Exempt  
 
Under clause 6(3)(b) of the MRL Standards imported food may contain residues of 
agricultural compounds no greater than the MRLs specified for that food in the current 
editions or supplements of the FAO/WHO Codex Alimentarius Commission publications 
Pestici de Residues in Food or Residues of Veterinary Drugs in Foods . 
 To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the proposed MRL will be notified to the World Trade Organization. 
Any country ma y choose to comment if they believe the proposed MRL represents a barrier to 
their trade.  
4.10 PROPOSAL TO EXEMPT POTASSIUM BICARBONATE  FROM MRL  
It is proposed that the current MRL exemption for potassium bicarbonate to include use as 
plant growth regulator . 
 The current entry in Schedule Two of the NZ (MRL) Standards 2013 is as follows:  
Compound  CAS#  Condition  
Potassium bicarbonate  298-14-6 When used as a fungicide for fruit and cucurbits . 
  
The resulting entry for potassium bicarbonate in Schedule Two of the NZ (MRL) Food 
Standards 2013 is:  
Compound  CAS#  Condition  
Potassium bicarbonate  298-14-6 When used as an  agricultural chemical  
4.10.1 Amendment Rationale  
The proposed MRL exemption represents an extension o the current use patterns for potassium bicarbonate to include use to enhance maturity of white grapes . 
4.10.2 Chemical Information  
Common name of compound  Potassium bicarbonate  
Use of compound  Fungicide, Plant growth regulator  
Chemical Abstract Services (CAS) Registry number  298-14-6 
Type of compound  Bicarbonate salt  
Administration method  Spray  
 
4.10.3 Good Agricultural Practice  
Potassium bicarbonate is proposed for use as a plant growth regulator for grapes , to be applied 
post veraison.  18 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries  4.10.4 Residue Information 
Potassium bicarbonate rapidly decomposes after use to form potassium carbonate, water and 
carbon dioxide. These are all naturally occurring in the environment. It is not expected that 
levels of potassium bicarbonate resulting from treatment of fruit and cucurbits will be 
distinguishable form the natura lly occurring levels of potassium and bicarbonate ions in the 
plant or environment. It is therefore proposed that potassium bicarbonate be exempted from an MRL  
4.10.5 Dietary Risk Assessment  
No ADI has been set for potassium bicarbonate. Levels of potassium bicar bonate in harvested 
fruit and cucurbits will not exceed levels of potassium bicarbonate present  
in its use as a food additive and through the natural presence of potassium and bicarbonate 
ions. Therefore the use of potassium bicarbonate as a fungicide presents no dietary risk.  
4.10.6 Toxicological/Public Health Assessment  
It has been determined that the use of potassium bicarbonate as a plant growth regulator  for 
grapes , according to the good agricultural practice specified above, is very unlikely to pose 
any hea lth risks from consumption of the harvested commodity.  
4.10.7 Other International MRLS  
Country  Food Maximum Residue Limit 
(mg/kg)  
Australia  All foods  Exempt when used as a 
fungicide  
Canada  Food and feed crops  Exempt  
USA All foods  Exempt when applied as a 
fungicide or post -harvest 
fungicide in accordance with 
good agricultural practices  
 
Under clause 6(3)(b) of the MRL Standards imported food may contain residues of 
agricultural compounds no greater than the MRLs specified for that food in the current 
editions or supplements of the FAO/WHO Codex Alimentarius Commission publications 
Pesticide Residues in Food or Residues of Veterinary Drugs in Foods . 
 
To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measu res the proposed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the proposed MRL represents a barrier to their trade.  
4.11 PROPOSAL TO EXEMPT SOYA BEAN OIL FROM MRL  
It is proposed that an MRL exemption is set for soya bean oil  when us ed as a fungicide.  
 It is proposed that Schedule Two of the MRL Standards be amended by adding the following:  
Compound  CAS#  Condition  
Soya bean oil  8001 -22-7 Used as a fungicide  
  
Ministry for Primary Industries   Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 • 19 4.11.1 Amendment Rationale  
The proposed MRL exemption represents a new use pattern in New Zealand for soya bean oil . 
Soya bean oil is a common ingredient in food . Soya bean oil contains saturated and 
unsaturated fatty acids. Therefore, it is not suitable to be ma naged against a chemical 
concentration limit.   
4.11.2 Chemical Information  
Common name of compound  Soya bean oil  
Use of compound  Fungicide  
Chemical Abstract Services (CAS) Registry number  8001 -22-7 
Type of compound  Vegetable oil  
Administration method  Spray  
 
4.11.3 Good Agricultural Practice  
Soya bean oil  is proposed for use as a  fungicide  to control Botrytis cinerea  and powdery 
mildew in grapes. It will be applied from pre -bunch closure to veraison with 2 to three 
applications.  
4.11.4 Residue Information 
Soya bean oil is a  common ingredient in food. It contains saturated and unsaturated fatty 
acids . Therefore, it is not appropriate to be regulated against an MRL.  
4.11.5 Dietary Risk Assessment  
Soya bean oil is an  ingredient in food . It is one of the most widely consumed cooking oil. The 
proposed use is not likely to contribute significantly to the levels  normally found in food .  
4.11.6 Toxicological/Public Health Assessment  
Soya bean oil exhibit s low toxicity . It is a common ingredient in fo od. Therefore, exemption 
of soya bean oil  from an MRL to the conditions specified above will not pose any health risks 
from the consumption of the treated commodities . 
4.11.7 Other International MRLS  
There are no other international MRLs for soya bean oil . 
 
To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the proposed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the proposed MRL represents a barrier to 
their trade.  
 
4.12 PROPOSAL TO EXEMPT SYNTHETIC LATEX FROM MRL  
It is proposed that an MRL exemption is set for synthetic latex  when used as an agricultural 
chemical.  
 It is proposed that Schedule Two of the MRL Standards be amended by adding the foll owing:  
Compound  CAS#  Condition  
Synthetic latex  n/a Used as an anti pod shatter   
 20 • Proposals to Amend (No.2) the New Zealand MLA Food Standards 2013 Ministry for Primary Industries  4.12.1 Amendment Rationale  
The proposed MRL exemption represents a new use pattern in New Zealand for synthetic 
latex . The proposed use (applied to prevent pod from splitting open and losing the seeds) and 
difficulty in determining any residues, synthetic latex is suitable to be exempted from the 
requirement of an MRL.  
4.12.2 Chemical Information  
Common name of compound  Synthetic latex 
Use of compound  Anti pod shatter  
Chemical Abstract Services (CAS) Registry number  N/A 
Type of compound  Polymer  
Administration method  Sticker  
 
4.12.3 Good Agricultural Practice  
Synthetic latex  is proposed for use as an anti -pod shatter sticker in oil seed , rape and other 
brassica seed crops.  
4.12.4 Residue Information 
Synthetic latex consists of multiple components. Due to the large number of components in 
the compound, it is difficult to determine an appropriate marker residue that would be 
consistent for al l sources of the latex.  
 The compound is a polymer . Polymer s are ubiquitous as they are used in all different type of 
applications. As such, analysis of residues in food resulting from the use of synthetic latex 
will not be accurate. On this basis setting  an MRL will not be appropriate.  
4.12.5 Dietary Risk Assessment  
Synthetic latex is not applied directly onto the seed . Therefore there is limited potential for 
dietary consumption.  
4.12.6 Toxicological/Public Health Assessment  
Generally polymers have low toxicity as the y have limited bioavailability. This is because 
they are macromolecules thus cannot pass through biomembranes . Therefore, exemption of 
synthetic latex  from an MRL to the conditions specified above will not pose any health risks 
from the consumption of treated commodities . 
 
4.12.7 Other International MRLS  
There are no other international MRLs for synthetic latex.  
 
To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures the proposed MRL will be notified to the World Trade Organization. 
Any country may choose to comment if they believe the proposed MRL represents a barrier to their trade.