Proposals to Amend the 
Maximum Residue Levels for 
Agricultural Compounds Food Notice 2018
  
 
MPI Discussion  Paper  No: 2018/12 
  
 
Prepared for public consultation  
By the Assurance Directorate of the Ministry for Primary Industries  
  ISBN No: 978- 1-77665 -973-9 (online)  
ISSN No: 2253- 3907 (online)  
 
 
  
September  2018 
 
 
Disclaimer  
 
While every effort has been made to ensure the information in this publication is accurate, 
the  
Ministry for Primary Industries does not accept any responsibility or liability for error of fact, 
omission, interpretation or opinion that may be present, nor for the consequences of any decisions based on  
this information.  
 
Requests for further copies should be directed to:  
 Publications Logistics Officer  
Ministry for Primary Industrie s 
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 -and-resources/publications/   
 
 
© Crown Copyright -  Ministry for Primary Industries   
i Contents  Page 
 
1 Submissions  2 
2 Introduction  3 
2.1 Background  3 
2.2 Summary of Proposed Amendments  6 
3 Proposals  8 
3.1 Proposal to amend terminology in the notice  8 
3.2 Proposal to amend the MRLs for clethodim  8 
3.3 Proposal to set MRLs for dicamba 10 
3.4 Proposal to amend the MRLs for fludioxonil  12 
3.5 Proposal to amend the MRLs for halauxifen- methyl  14 
3.6 Proposal to amend the MRLs for lambda- cyhalothrin  15 
3.7 Proposal to amend the MRLs for metamitron 17 
3.8 Proposal to amend t he residue definition for lignocaine  18 
3.9 Proposal to amend the residue defintion for xylazine  20 
3.10  proposal to exempt paraffin oils  21 
3.11  Proposal to amend the exemption for Formic acid  21 
3.12  Proposal to amend the exemption for oxalic acid  22 
3.13  Proposal to amend the exemption for thymol  22 
 
  
2 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018  Ministry for Primary Industries  1 Submissions  
The Mini stry for Primary Industries (MPI) invites public comment on this discussion 
document, which outlines proposals to amend the New Zealand (Maximum Residue Levels 
for Agricultural Compounds) Food Notice.  
 
 
For each compound you are commenting on, please clear ly answer the following questions. 
Any additional comment is welcome, along with supporting discussion, and data or examples 
to illustrate particular points.  
 
On balance, do you oppose any of the commodity MRLs proposed for this compound?  
 
Do you oppose an MRL being set at all  for this compound for the commodity?  
 
If an MRL is to be set for this compound for the commodity, do you disagree with the 
particular level proposed? If so, why do you disagree?  
 
Submissions close at 5pm on 18 November 2018 . Your com ments should be sent to:  
 
MRL Amendments  
ACVM Programmes and Appraisals  
MPI Assurance Directorate  
PO Box 2526  
Wellington 6140  
 
Email: ACVM.Consultation@mpi.govt.nz . 
 Please include your name and address on your submission. If you are making comments on 
behalf of an organisation, also include your title and the name of the organisation.  
 
Please make sure your comments can be clearly read, as a number of copies of your 
submission may be made.  
 
The Official Information Act  
The Official Information Act 1982 (the OIA) states that information is to be made available 
unless there are grounds for withholding it. The grounds for withholding information are 
outlined in the OIA.  Submitters may wish to indicate any grounds for withholding information 
contained in their submission.  Reasons for withholding information could include that 
information 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.   
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 3  
2 Introduction  
Maximum residue levels (MRLs) are the maxi mum legal levels for residues of agricultural 
compounds and veterinary medicines permitted in food for sale in New Zealand. MRLs are 
primarily a tool for monitoring the use of agricultural compounds in accordance with good 
agricultural practice (GAP).  
In terms of agricultural compound use, GAP can be defined as the set of principles and 
methods that ensure the production of safe and good quality horticultural and animal 
products at any stage of production, storage, transport, and distribution. GAP is established 
for each compound and its uses by taking into account public health, crop and animal safety, 
and occupational and environmental safety considerations for a range of treatments up to the 
highest authorised use. This ensures that the compounds are use d in a manner that leaves 
the smallest amount of residue practicable without compromising the ability of that compound 
to achieve the intended beneficial effect, and thereby ensuring that the GAP use is 
sufficiently protective of consumer health when compared to the health based guidance 
value (HBGV) to determine the national estimated dietary Intake (NEDI).  
The New Zealand MRLs are established based on domestic uses of a particular compound, and are used to monitor GAP compliance in New Zealand. Because they are based on New Zealand authorised uses according to domestic GAP, they may differ from MRLs established 
overseas for a similar use because their GAP may be different.  However, as noted below, 
imported food can also comply with Codex MRLs.  
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.  
Note that the presentation of this proposal document has changed. When an entry in 
Schedule 1 has been revised in previous proposal documents, this was presented by including a copy of the existing entry followed by the revised entry. This will now be 
presented as a single edited entry, with new and amended content added in bold, and 
removed commodities struck through. This will allow for a more clear and concise 
presentation of the information and changes being proposed.   
2.1 BACKGROUND  
MRLs a re set out in the New Zealand (Maximum Residue Levels for Agricultural 
Compounds) Food Notice. The MRL Food Notice is amended a number of times each year 
to reflect changes in the use of agricultural compounds in the production of food. The MRL 
Food Notice  is available from the Ministry for Primary Industries (MPI) Food Safety website 
at: http://mpi.govt.nz/document -vault/11329 .  
MPI administers the MRL Food Notice, with the final decision on any changes to the Notice resting with the Director -General of MPI. The Food Notice is issued under section 405 of the 
Food Act 2014. When setting or amending MRLs, the Director -General must take into 
account:  
• 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;   
4 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018  Ministry for Primary Industries  • New Zealand’s obligations under any relevant international treaty, agreement, 
convention, or pr otocol, and, in particular, under the Australia- New Zealand Joint 
Food Standards Agreement; and 
• such other matters as appropriate.  
 
The requirements for the content of the MRL Food Notice are set out in Part 6 of the Food 
Regulations 2015, allowing for the promulgation of MRLs for agricultural compounds as well 
as the promulgation of exemptions from compliance with MRLs. In addition to establishing 
the requirements on domestically produced foods, Part 6 of the Food Regulations also 
outlines the residue level compliance requirements for imported foods. Clause 144 states 
that imported food must contain residues of agricultural compounds:  
- no greater than the MRLs specified for that food in a notice set under the Food 
Act 2014 (section (1)(a)); or  
- the default MR L of 0.1 mg/kg (section (1)(c)); or  
- the current editions of either the Maximum Residue Limits (MRLs) and 
Extraneous Maximum Residue Limits (EMRLs) for Pesticides (Codex Pesticides 
Residues in Food Online Database), or the Maximum Residue Limits for 
Veteri nary Drugs in Food (Codex Veterinary Drug Residue in Food Online 
Database) (section (1)(d)).  
 
As imported food commodities can comply with either a Codex MRL or a MRL established in 
the MRL Food Notice, New Zealand’s obligations under the Agreement on the Application of 
Sanitary and Phytosanitary Measures are met.  
On the whole, the Regulations allow for the management of residues in all foods consumed 
in New Zealand.  
2.1.1 National Estimated Dietary Intake  
The chronic dietary exposure to a substance is estimated by the NEDI calculation, 
encompassing all authorised uses of the agricultural compound, and using 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]. The NEDI calculation provides an estimation of the potential chronic 
exposure to toxicologically relevant residues in all food derived from crops/livestock treated 
with the agricultural compound according to the authorised use (GAP).  
The possible implications for consumer health are considered during the toxicological and 
dietary risk assessments, by comparing t he NEDI with a HBGV. Provided the estimated 
dietary exposure of all toxicologically relevant residue components in all fresh and processed 
food is less than the HBGV, the use of an agricultural compound according to GAP is unlikely 
to pose a health risk to consumers.  
2.1.2 Health Based Guidance Values 
The HBGV used in determining the estimated dietary exposure may be either a Potential 
Daily Exposure (food) (PDE (food)) or an Acceptable Daily Intake (ADI). The ADI and PDE (food) 
are largely equivalent, as they are determined using the same set of toxicology data and 
through a very similar scientific process. HBGVs are reported as milligrams of compound per kilogram bodyweight (mg/kg).  
A PDE
(food) is a value determined by a toxicological evaluation by the New Zealand 
Environmental Protection Authority (EPA) 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 s ubstance, via 
food.   
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 5 An ADI is 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”. “Without appreciable risk” has be en 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 (FAO) of the United Nations joint expert committees, which 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 in New Zealand, MPI uses the PDE
(food) set by the EPA as the 
HBGV for the estimation of dietary exposure when one is available. If there is no PDE (food), 
the estimated dietary exposure is compared with the ADI, set by the WHO/FAO joint expert 
committees, the Australian Pesticides and Veterinary Medicines Authority (APVMA), the European Food Safety Authority (EFSA), or another regulatory authority. If none of these are 
available, the HBGV used will be an MPI -determined ADI.   
2.1.3 International MRLs and Trade  
The “Relevant International MRLs” table listed in each entry is a summary of the MRLs set by 
Codex and a selection of other international regulatory bodies reviewed to evaluate trade 
risk. For animal commodities, the MRLs set by our major trading partners (Australia, Canada, 
China, Codex, the European Union, Japan, and the United States) are reviewed and 
compared; for horticultural commodities, MRLs set by Codex and Australia are reviewed and 
compared. Other international MRLs are reviewed and reported in the table if there is a 
particular trade risk to be c onsidered for those regions. If a particular international body or 
regulator does not have MRLs set for the species or crop for which a New Zealand MRL is being proposed, that international body or regulator is omitted from the “other international 
MRLs” s ection of the entry.  
  
6 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018  Ministry for Primary Industries   
2.2 SUMMARY OF PROPOSED AMENDMENTS  
The proposed MRLs have been thoroughly assessed in accordance with international 
methodologies published by the Organisation for Economic Cooperation and Development 
(OECD) or FAO. Information on the t echnical assessment of each proposal is included in this 
document (refer section 3) and covers:  
 
• rationale;  
• chemical information;  
• good agricultural practice;  
• residues information;  
• dietary risk assessment;  
• toxicological/public health assessment; and  
• MRLs se t by Codex and other relevant authorities (e.g. Australia, Canada, China, EU, 
Japan, USA)  
 
Where an existing entry is proposed for revision, new or revised MRLs are highlighted in bold print, and MRLs proposed for revocation are identified using a strikethrough.  
 
MPI has reviewed the estimated dietary exposure assessments associated with all 
authorised and proposed uses according to what has been established as GAP for New 
Zealand, compared them with the appropriate HBGV (the PDE
(food) or an ADI), and has 
concluded that residues arising from these uses are unlikely to present any public health or food safety concerns.  
2.2.1 Amendment to terminology used in all parts of the Notice  
 
MPI proposes to amend all references to “MRL exceptions” to “MRL exemptions” in the Introduction, Part 1, and Schedules 1- 3 of the Notice.  
2.2.2 Amendments to Schedule 1: New  and Amended MRLs  
MPI proposes to add new MRLs to the Food Notice, and/or amend the existing entries for the following compounds:  
 
• Clethodim: 0.2 mg/kg in mammalian meat ; 0.2 mg/kg in mammalian offal; and 0.05 
mg/kg in milk.  
• Dicamba: 0.05 mg/kg in mammalian fat (except milk fat); 0.5 mg/kg in mammalian 
kidney; 0.1 mg/kg in mammalian liver; 0.02 mg/kg in mammalian meat; and 0.1 mg/kg 
in milk.  
• Fludioxonil : 7 mg/kg in pineapples for import.  
• Halauxifen- methyl: 0.01 mg/kg (*) in mammalian meat; 0.01 mg/kg (*) in mammalian 
offal; and 0.01 mg/kg (*) in milk.  
• Lambda- cyhalothrin: 0.5 mg/kg in mammalian fat; 0.02 mg/kg in mammalian offal ; 
0.01 mg/kg in mammalian meat; and 0.05 mg/ kg in mammalian milk.  
• Metamitron: 0.01 mg/kg (*) in pears.  
Note: (*) indicates that the maximum residue level has been set at or about the limit of analytical 
quantification.   
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 7 2.2.3 Other Amendments to Schedule 1  
• MPI proposes to amend the residue definition for  lignocaine.  
• MPI proposes to amend the residue definition  for xylazine.   
2.2.4 Amendments to Schedule 2: New and Amended Ex emptions  from Maximum Residue 
Levels for Agricultural Chemicals  
• MPI proposes to add an exemption for  paraffin oils , when used as an agricultural 
compound,  to the list of agricultural compounds in Schedule 2 of the Food Notice, for 
which no maximum residue levels apply.  
• MPI proposes to amend the current entry for formic acid in the list of agricultural 
compounds in Schedule 2 of the Food Noti ce, for which no maximum residue levels 
apply. The entry will be moved from Schedule 2 to Schedule 3, and revised to be 
more specific to control of Varroa  mite as per the current exemption for thymol.  
• MPI proposes to amend the current entry for  oxalic acid  in the list of agricultural 
compounds in Schedule 2 of the Food Notice, for which no maximum residue levels 
apply. The entry will be moved from Schedule 2 to Schedule 3, and revised to be 
more specific to control of Varroa mite as per the current exemption for thymol.   
2.2.5 Amendments to Schedule 3: Exemptions from Maximum Residue Levels for Veterinary 
Medicines 
• MPI proposes to amend the exemption for thymol  in the list of agricultural compounds 
in Schedule 3 of the Food Notice, for which no maximum residue levels apply. The 
entry is to be amended to broaden the substance definition to extracts of Thymus 
vulgaris (thyme) containing thymol, to allow for the use of thyme extracts such as 
thyme oil as agricultural compounds exempt from MRLs. The condition of exemption 
is also being revised to specify that the use as an agricultural compound for the 
control of Varroa mite  is specifically derived from  the presence of thymol.     
8 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018  Ministry for Primary Industries   
3 Proposals  
3.1 PROPOSAL TO  AMEND TERMINOLOGY IN THE NOTICE  
It is proposed that the Notice is amended to change the terminology used to reference 
agricultural compounds to which no maximum residue levels apply from “exception” to 
“exemption.” This will allow for a better understanding of the content of the Notice by using 
the terminology commonly us ed to describe such compounds.  
Although this change will administratively affect content in the Background and Document 
History sections, as well as the titles and content of Schedules 2 and 3, there is no change to 
the meaning or intent of the technical information previously referred to as “exceptions” in 
any part of the Notice.  
3.2 PROPOSAL TO AMEND THE MRLS FOR  CLETHODIM  
It is proposed that MRLs for clethodim  are amended to include animal commodity MRLs to 
support the GAP use of the compound on fodder and sugar beet.  
The revised entry with changes shown in bold for clethodim in Schedule 1 of the Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum residue l evel applies  Food Maximum Residue 
Level (mg/kg)  
Clethodim  99129 -21-2 Sum of:  
Clethodim and its metabolites 
containing  
5-(2-ethylthiopropyl)cyclohexene- 3-
one and 5- (2-ethylthiopropyl) -5-
hydroxycyclohexene- 3-one moieties 
and their sulphoxides and sulphones  
Expressed as:  
Clethodim  Brassica vegetables  
Fruiting vegetables  
Leafy vegetables  
Legume vegetables  
Mammalian m eat 
Mammalian offal  
Milk 
Stem vegetables  1 
1 
1 
1 
0.2 0.2 
0.05 
1 
3.2.1 Amendment Rationale  
The animal commodity MRLs are being proposed to support a new use for clethodim in 
accordance with the  application rates and withholding peri ods that are proposed as GAP in 
New Zealand.   
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 9 3.2.2 Chemical Information  
Common name of compound  Clethodim  
Use of compound  Herbicide  
Chemical Abstract Services (CAS) Registry number  99129- 21-2 
Type of compound  Cyclohexene oxime  
Administration method  Spray  
3.2.3 Good Agricultural Practice  
Clethodim is used as a herbicide on fodder and sugar beet at a rate of 61- 480 gai/ha to 
control annual and perennial grass weeds, and up to 720 gai/ha for couch and paspalum, 6- 8 
weeks after sowing. Use of clethodim in fodder and sugar beet crops attracts a pre- grazing 
and pre- harvest withholding period of nine weeks.  
3.2.4 Residue Information 
The residue data for the use of clethodim on fodder crops are sufficient to conclude that, 
when applied as per the proposed GAP use pattern, resi dues of clethodim and its 
metabolites  should not exceed 0.05 mg/kg in milk, 0.1 mg/kg in meat, and 0.2 mg/kg in liver, 
kidney, and fat from animals exposed to clethodim after the treatment of fodder or sugar beet 
crops.   
The proposed MRLs of 0.2 mg/kg in mammalian kidney, 0.2 mg/kg in mammalian liver, 0.2 
mg/kg in mammalian meat, and 0.05 mg/kg in milk are therefore sufficient to support GAP for 
the use of clethodim on fodder and sugar beet animal feed crops.   
3.2.5 Dietary Risk Assessment  
The HBGV  of 0.005 mg/k g was considered appropriate for use in the assessment.  
Based on the residue profile expected in food from crops treated with clethodim, as well as in animal products from livestock that consume to treated feed, the NEDI for clethodim is 
estimated at less  than 74% of the HBGV when the compound is used according to existing 
and proposed GAP uses.  
MPI has therefore determined that the use of clethodim  on fodder and sugar beet crops 
intended for animal consumption, according to the GAP specified above, is unlikely to pose 
any health risks from authorised use.
   
10 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018 Ministry for Primary Industries  3.2.6 Relevant International MRLs  
Country                                                                    Food  Maximum Residue  
Level  (mg/kg)  
Australia  
(As Sethoxydim)  Edible offal (Mammalian)  
Meat [mammalian]  
 0.05 
0.05 
0.05 
Canada  Meat of cattle, goats, horses, and sheep  
Meat byproducts of cattle, goats, horses, and sheep  
 0.2 
0.2 
0.05 
Codex  Edible offal (mammalian)  
Meat (from mammals other than marine mammals)  
 0.2 
0.2 
0.05 
European Uni on 
(As Sethoxydim)  Cattle, goat, horse, and sheep muscle  
Cattle, goat, horse, and sheep fat  
Cattle, goat, horse, and sheep liver  
Cattle, goat, horse, and sheep kidney  
Cattle, goat, horse, and sheep edible offals (other than liver 
and kidney)              
    0.2 
0.2 
0.2 
0.2 
 
0.2 
0.05 
United States  Cattle, goat, horse, and sheep meat  
Cattle, goat, horse, and sheep by products  
Cattle, goat, horse, and sheep fat  
Cattle, goat, horse, and sheep kidney  
Cattle, goat, horse, and sheep liver  
  0.2 
0.2 
0.2 
0.2 
0.2 
0.05 
3.3 PROPOSAL TO  SET MRLS FOR  DICAMBA  
It is proposed that MRLs are set for animal commodities to support the GAP use of dicamba 
on plantain.  
There is currently no entry for dicamba in Schedule 1 of the Notice.  
The new entry for dicamba in Schedule1 of the Notice will read:  
Compound 
Common Name  CAS#  Residue  to which the maximum 
residue level  applies  Food Maximum Residue 
Level (mg/kg)  
Dicamba  1918 -00-9 Sum of dicamba and DCSA, 
expressed as dicamba  Mammalian fat 
(except milk fat)  
Mammalian kidney 
Mamm alian liver  
Mammalian meat  
Milk  
0.05 
0.5 
0.1 
0.02 
0.1 
3.3.1 Amendment Rationale  
The MRL is being proposed to support a new use for dicamba on plantain in accordance with 
the application rates and withholding periods that are proposed as GAP in New Zealand.   
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 11 3.3.2 Chemical Information  
Common name of compound  Dicamba  
Use of compound  Herbicide  
Chemical Abstract Services (CAS) Registry number  1918- 00-9 
Type of compound  Benzoic acid  
Administration method  Spray  
3.3.3 Good Agricultural Practice  
Dicamba is used as a herbicide on pasture plantain at a rate of 300 gai/ha to manage broad-
leaf weeds. It is applied when the plantain has at least two to four true leaves, and before 
weeds reach the four -leaf stage. Use of dicamba on pasture attracts a pre- grazing 
withholding period of 14 days.  
3.3.4 Residue Information 
The residue data for the use of dicamba on pasture plantain are sufficient to conclude that, 
when applied as per the proposed GAP use pattern, residues of dicamba and the 3,6-
dichlorosalicylic acid (DCSA) metabolite should n ot exceed 0.08 mg/kg in milk, 0.02 mg/kg in 
muscle, 0.09 mg/kg in liver, 0.4 mg/kg in kidney, and 0.04 mg/kg in fat when grazed on or fed 
treated plantain.  
The animal metabolism studies demonstrated that the primary residues for dicamba in 
animal commodit ies were parent dicamba and the DCSA metabolite. The 5- OH dicamba 
metabolite did not accumulate significantly enough to consider it as part of the GAP 
compliance or dietary intake residue definitions. This is consistent with the assessment 
conducted by the Joint FAO/WHO Meeting on Pesticide Residues (JMPR) which informed 
the Codex definition for both dietary intake and MRL compliance for animal commodities: the 
sum of dicamba and DCSA, expressed as dicamba. This residue definition is considered 
appropriate to adopt for promulgation of New Zealand MRLs for this compound.  
3.3.5 Dietary Risk Assessment  
The HBGV  of 0.015 mg/kg was considered appropriate for use in the assessment.  
Based on the residue profile expected in food from crops treated with dicamba, as well as in animal products from livestock that consume treated feed, the NEDI for dicamba is less than 
6% of the HBGV when the compound is used according to existing and proposed GAP uses.  
MPI has therefore determined that the use of dicamba  on plantain intended for animal 
consumption, according to the GAP specified above, is unlikely to pose any health risks from authorised use.
   
12 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018 Ministry for Primary Industries  3.3.6 Relevant International MRLs  
Country                                                      Food  Maximum Residue  
Level  (mg/kg)  
Austral ia Edible offal (Mammalian)  
Meat [mammalian]  
Milks                                     0.05 
0.05 
0.1 
Codex  Edible offal (mammalian)  
Mammalian fats (except milk fats)  
Meat (from mammals other than marine mammals)  
Milks                         0.7 
0.07 
0.03 
0.2 
European Union  Cattle muscle          
Cattle, deer, sheep, goat, and horse fat  
Cattle, deer, sheep, goat, and horse liver  
Cattle, deer, sheep, goat, and horse kidney  
Cattle, deer, sheep, goat, and horse edible offals (other than 
liver and kidney)      
Deer, sheep and equine muscle  
Cattle milk                 
Other milk                0.5 
0.07 
0.7 
0.7 
 
0.7 
0.05 
0.5 
0.2 
United States  Cattle, goat, horse, and sheep by products  
Cattle, goat, horse, and sheep fat  
Cattle, goat, horse, and sheep kidney  
Cattle, goat, horse, and sheep liver  
Cattle, goat, horse, and sheep meat  
Milk                                      3 
0.3 
25 
3 
0.25 
0.2 
3.4 PROPOSAL TO AMEND THE MRLS FOR  FLUDIOXONIL  
It is proposed that MRLs for fludioxonil are amended to set a MRL for use of the compound 
on imported pineapples.  
The revised entry with changes shown in bold for fludioxonil in Schedule 1 of the Notice will 
read:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food  Maximum Residue Level 
(mg/kg)  
Fludioxonil  1313 41-86-1 Fludioxonil  Blackcurrants  
Blueberries  
Bulb onions  
Grapes  
Pineapples 
Strawberries  0.8 
0.5 
0.01(*)  
1 
7 
1 
 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
 
3.4.1 Amendment Rationale  
The MRL is being proposed to support the importation of pineapples to New Zealand. The 
current application of the default 0.1 mg/kg MRL is considered to be too low to support trade 
when the overseas use patterns considered to be GAP for pineapple crops are taken into 
account. Sufficient information has been provided to establish that the proposed MRL will be 
appropriate to facilitate trade while still supporting the GAP use of fludioxonil in New Zealand 
and on imported produce.   
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 13 3.4.2 Chemical Information  
Common name of compound  Fludioxonil  
Use of compound  Fungicide  
Chemical Abstract Services (CAS) Registry number  131341- 86-1 
Type of compound  Phenylpyrrole 
Application method  Spray/Seed treatment in New Zealand; post -
harvest treatment of imported pineapples  
3.4.3 Good Agricult ural Practice 
In New Zealand, fludioxonil is used as a spray to treat fungal disease in grapes, bulb onions, 
black currants, blueberries, and strawberries, and as an antifungal seed treatment. 
Fludioxonil is also used overseas as a post -harvest treatment f or the control of saprophytic 
surface moulds on pineapples at a rate of 32 fluid ounces/100 gallons water (0.61 g 
fludioxonil per litre of water). Trials conducted using this application rate were evaluated to 
determine the appropriate import MRL for New Z ealand.  
3.4.4 Residue Information 
The residue data for the use of fludioxonil on pineapples from the United States were  
sufficient to conclude that, when applied as per the established overseas GAP use pattern for post -harvest treatment, residues should not exc eed 2.84 mg/kg. The European Food 
Safety Authority (EFSA) evaluated these same data, and applied an import MRL of 7 mg/kg; 
it is considered that adoption of this MRL is appropriate for New Zealand.  
The proposed MRL of 7mg/kg is therefore sufficient to sup port the overseas GAP for the use 
of fludioxonil on pineapples.  
3.4.5  Dietary Risk Assessment  
The HBGV  of 0.0165 mg/kg was considered appropriate for use in the assessment.  
Based on the residue profile of fludioxonil expected in food from crops treated with t he 
compound according to domestic and overseas GAP uses, the NEDI for fludioxonil is 
estimated at less than 12% of the HBGV.  
MPI has therefore determined that setting an import MRL for pineapple that has been treated 
with fludioxonil as a post -harvest treatment for mould, according to the GAP specified above, 
is unlikely to pose any health risks from authorised use.   
3.4.6 Relevant International MRLs  
Country                                                      Food  Maximum Residue  
Level  (mg/kg)  
Canada Pineapples             20 
European Union  Pineapples             7 
United States  Pineapple               20 
  
14 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018 Ministry for Primary Industries  3.5 PROPOSAL TO AMEND THE MRLS FOR  HALAUXIFEN- METHYL    
It is proposed that MRLs for halauxifen- methyl  are amended to include animal commodity 
MRLs to support the  GAP use of the compound on fodder brassicas.  
The revised entry with changes shown in bold for halauxifen- methyl in Schedule 1 of the 
Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food Maximum Permitted 
Resi due Level (mg/kg)  
Halauxifen -methyl  943831 -98-9 Plant commodities:  Halauxifen -
methyl  
 
Animal commodities: 4- Amino -
3-chloro- 6(4-chloro- 2-fluoro- 3-
hydroxphenyl) -pyridine -2-
carboxylic acid, expressed as 
halauxifen -methyl  Barley grain  
Mammalian meat  
Mammalian  offal  
Milk 
Triticale grain  
Wheat grain  0.01(*)  
0.01(*)  
0.01(*)  
0.01(*)  
0.01(*)  
0.01(*)  
 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
3.5.1 Amendment Rationale  
The MRL is being proposed to support  a new use for halauxifen- methyl on fodder brassicas 
intended for animal consumption in accordance with the application rates and withholding 
periods that are proposed as GAP in New Zealand.  
3.5.2 Chemical Information  
Common name of compound  Halauxifen- methyl  
Use of compound  Herbicide  
Chemical Abstract Services (CAS) Registry number  943831- 98-9 
Type of compound  Arylpicolinate  
Administration method  Spray  
3.5.3 Good Agricultural Practice  
Halauxifen- methyl is used as a herbicide on fodder brassicas at a rate of 5 gai/ha to manage 
broad- leaf weeds post -emergence. The compound is applied to actively growing crops at the 
3-4 leaf stage (BBCH 13 -14), as soon as possible after weed emergence. Use of halauxifen-
methyl on fodder brassica crops attracts a pre- grazing and pre- harvest withholding period of 
14 days.  
3.5.4  Residue Information 
The residue data for the use of halauxifen- methyl are sufficient to conclude that, when 
applied as per the proposed GAP use pattern and complying with the 14 day withholding 
period, residues of t he4-Amino -3-chloro- 6(4-chloro- 2-fluoro -3-hydroxphenyl) -pyridine- 2-
carboxylic acid metabolite of halauxifen- methyl should not exceed 0.01 mg/kg in all 
commodities from animals fed treated fodder brassicas.  
The proposed MRLs of 0.01(*) mg/kg in mammalian fat, kidney, liver, meat and milk are 
therefore sufficient to support GAP for the use of halauxifen- methyl on fodder brassicas.   
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 15 A separate residue definition is proposed for animal commodities to regulate the primary 
metabolite in those commodities as eviden ced in the residue data, and to align with the 
residue definition used overseas.  
3.5.5  Dietary Risk Assessment  
The HBGV  of 0.0406 mg/kg was considered appropriate for use in the assessment.  
The NEDI for halauxifen- methyl is estimated at less than 0.3% of the H BGV. This is based 
on the residue profile of halauxifen- methyl in plant commodities, and 4- Amino -3-chloro- 6(4-
chloro- 2-fluoro- 3-hydroxphenyl) -pyridine -2-carboxylic acid expected in animal products from 
livestock exposed to feed treated according to existing and proposed GAP uses.  
MPI has therefore determined that the use of halauxifen -methyl on fodder brassicas , 
according to the GAP specified above, is unlikely to pose any health risks from authorised use.
  
3.5.6 Relevant International MRLs  
Country                                                                      Food  Maximum Residue  
Level (mg/kg)  
Australia  Edible offal (Mammalian)  
Meat (mammalian)  
Milks                                    0.01 
0.01 
0.01 
European Union  Muscle, all species  
Fat, all species        
Liver, all species     
Kidney, all species  
Edible offal (other than liver and kidney), all species  
Milk, all species       0.02 
0.02 
0.02 
0.02 
0.02 
0.02 
 
3.6 PROPOSAL TO AMEND THE MRLS FOR  LAMBDA- CYHALOTHRIN  
It is proposed that MRLs for lambda- cyhalothrin are amended to include animal commodity 
MRLs to support the GAP use of the compound on plantain and plantain/clover swards.  
The revised entry with changes shown in bold for lambda- cyhalothrin in Schedule 1 of the 
Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum 
residue limit applies  Food Maximum Residue 
Level (mg/kg)  
Lambda -
cyhalothrin  91465 -08-6 Lambda -cyhalothrin  Citrus fruits  
Grapes  
Kumara  
Maize  
Mammalian fat  
Mammalian offal  
Mammalian meat  
Milk 
Onions  
Potatoes  
Pumpkins  
Sweetcorn  
Winter squash  0.01(*)  
0.01(*)  
0.01(*)  
0.01(*)  
0.5 
0.02 0.01 
0.05 
0.01(*)  
0.01(*)  
0.01(*)  
0.01(*)  
0.01(*)  
 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
  
16 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018 Ministry for Primary Industries  3.6.1 Amendment Rationale  
The MRL is being proposed to support a new use for lambda- cyhalothrin on plantain and 
mixed plantain/cover pasture in accordance with the application rates and withholding 
periods that are proposed as GAP in New Zealand.  
3.6.2 Chemical Information  
Common name of compound  Lambda- cyha lothrin  
Use of compound  Insecticide  
Chemical Abstract Services (CAS) Registry number  91465- 08-6 
Type of compound  Synthetic pyrethroid  
Administration method  Spray  
3.6.3 Good Agricultural Practice  
Lambda- cyhalothrin is used as an insecticide on plantain and plantain/clover swards for the 
control of plantain moth. The compound is applied at a rate of 5 gai/ha as soon as 
caterpillars are noticed when clover is not in flower, and repeated as necessary avoiding the 
flowering period. Use of lambda- cyhalothrin on pl antain pasture attracts a pre- grazing 
withholding period of 14 days.  
3.6.4  Residue Information 
The residue data for the use of lambda- cyhalothrin are sufficient to conclude that, when 
applied as per the proposed GAP use pattern and complying with the 14 day pr e-grazing 
withholding period, residues of parent compound lambda- cyhalothrin in animal commodities 
should not exceed 0.01 mg/kg in meat, 0.02 mg/kg in liver  and kidney , 0.5 mg/kg in fat, and 
0.05 mg/kg in milk.  
The proposed MRLs of 0.01 mg/kg in mammalian meat, 0.02 mg/kg in mammalian offal, 0.5 
mg/kg in mammalian fat, and 0.05 mg/kg in milk are therefore sufficient to support GAP for 
the use of lambda- cyhalothrin on plantain and plantain/clover swards.   
3.6.5 Dietary Risk Assessment  
The HBGV  of 0.0004 mg/kg was  considered appropriate for use in the assessment.  
Based on the residue profile expected in food from crops treated with lambda- cyhalothrin, as 
well as in animal products from livestock that consume treated feed, the NEDI for lambda-
cyhalothrin is less th an 59% of the HBGV when the compound is used according to existing 
and proposed GAP uses.  
MPI has therefore determined that the use of lambda -cyhalothrin  on plantain and 
plantain/clover swards , according to the GAP specified above, is unlikely to pose any health 
risks from authorised use.    
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 17 3.6.6 Relevant International MRLs  
Country                                                          Food  Maximum Residue L evel 
(mg/kg)  
Australia  Cattle milk                           
Edible offal (Mammalian)  
Meat [mammalian]  0.01 
0.7 
0.05 
Canada  Fat of goats, horses, cattle, and sheep  
Meat byproducts of goats, horses, cattle, and sheep  
Meat of goats, horses, cattle, and sheep  
Milk                                    
Milk fat                                   5 
0.2 
0.2 
0.5 
12 
Code x Kidney of cattle, goats, pigs, and sheep  
Liver of cattle, goats, pigs, and sheep  
Meat (from mammals other than marine mammals)(fat)  
Milks                                    0.2 
0.05 
3 
0.2 
European Union  Muscle, all mammalian species  
Fat, all mammalian species  
Liver, all mammalian species  
Kidney, all mammalian species  
Edible offals (other than liver and kidney), all mammalian species  
Milk                                      0.5 
0.5 
0.5 
0.5 
0.5 
0.05 
United States  By products, all mammalian species  
Fat, al l mammalian species  
Kidney, all mammalian species  
Liver, all mammalian species  
Meat, all mammalian species  
Milk                                       0.2 
3 
0.2 
0.2 
0.2 
10 
3.7 PROPOSAL TO AMEND THE MRLS FOR  METAMITRON  
It is proposed that MRLs for metamitron are amended to support the GAP use of the 
compound on pears.  
The revised entry with the change shown in bold for metamitron in Schedule 1 of the Notice 
will read:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food Maximum Perm itted 
Residue Level (mg/kg)  
Metamitron  41394 -05-2 Metamitron  Apples  
Pears 0.01(*)  
0.01(*)  
 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
 
3.7.1 Amendment Rationale  
The MRL is being proposed to sup port a new use for metamitron on pears in accordance 
with the application rates and withholding periods that are proposed as GAP in New Zealand.   
18 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018 Ministry for Primary Industries  3.7.2 Chemical Information  
Common name of compound  Metamitron  
Use of compound  Plant Growth Regulator  
Chemical Abstract Services (CAS) Registry number  41394- 05-2 
Type of compound  Triazinone 
Administration method  Spray  
3.7.3 Good Agricultural Practice  
Metamitron is used as a plant growth regulator for fruitlet thinning at a rate of 165 to 330 
gai/ha when fruitlets are 8- 14 millimetres in diameter. The compound is to be applied no later 
than 30 days after full bloom.  
3.7.4  Residue Information 
The residue data for the use of metamitron are sufficient to conclude that, when applied as per the proposed GAP use pattern, residues of  parent compound metamitron should not 
exceed the 0.01 mg/kg limit of detection in pears from treated trees.  
The proposed MRL of 0.01(*) mg/kg in pears is therefore sufficient to support GAP for the use of metamitron on pear trees.  
3.7.5 Dietary Risk Assessment  
The HBGV  of 0.015 mg/kg was considered appropriate for use in the assessment.  
Based on the residue profile of metamitron expected in food from crops treated according to 
existing and proposed GAP uses, the  NEDI is estimated at less than 1% of the HBGV.  
MPI has therefore determined that the use of metamitron on pears , according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.   
3.7.6 Relevant International MRLs  
There are no Codex or Australian MRLs for metamitron.   
3.8 PROPOSAL T O AMEND THE RESIDUE DE FINITION FOR LIGNOCAINE  
It is proposed that the residue definition for lignocaine is amended to support the GAP use of 
the compound in the harvest of deer velvet.  
The revised entry  with the change shown in bold for lignocaine in Sched ule 1 of the Notice 
will read:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food Maximum Permitted 
Residue Level (mg/kg)  
Lignocaine 
(lidocaine)  137-58-6 Lignocaine  Deer Velvet  5 
3.8.1 Amendment Rationale  
The change to the residu e definition is being proposed following a review of the use of 
lignocaine and xylazine in the harvesting of deer velvet, and the residues present in velvet as 
a result. It is considered that revision of the residue definition to parent compound lignocaine  
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 19 is sufficient to manage use of the compound according to GAP and regulatory compliance 
with the MRL, which is the purpose of the MRL listed in the Notice. The metabolite 2,6-
dimethylaniline, which will be removed from the regulatory compliance residue def inition, will 
still be considered in the dietary intake calculations for the compound.  
3.8.2 Chemical Information  
Common name of compound  Lignocaine  
Use of compound  Anaesthetic  
Chemical Abstract Services (CAS) Registry number  137-58-6 
Type of compound  Amide  
Administration method  Injection as a local anaesthetic  
3.8.3 Good Agricultural Practice  
There is no change to GAP for lignocaine as previously established. Current GAP for the use of lignocaine in deer for the purposes of harvesting velvet requires the applica tion of a 
tourniquet, followed by administering lignocaine as a local anaesthetic. The lignocaine is 
administered by the ring block technique at a rate of 20 mg lignocaine per centimetre of 
antler pedicle circumference, at the base of the antler between th e top of the head and the 
tourniquet. This use does not attract the need for a withholding period for lignocaine in the harvested velvet.   
3.8.4  Residue Information 
The residue data for the concurrent use of lignocaine and xylazine in the harvesting of deer velvet confirmed that 2,6 -dimethylaniline , also known as 2,6- xylidine, comprised no more 
than 0.003 mg/kg of the total recovered residue. The metabolite, which is common to both 
lignocaine and xylazine, is necessary for the complete evaluation of dietary int ake, and 
therefore will be retained in the dietary intake residue definition for this compound.  
The residue definition listed in the Food Notice however is used for regulatory MRL compliance, to ensure use of the compound conforms to the dose rate and use pattern 
established as GAP in New Zealand. Given that the 2,6- dimethylaniline metabolite can be 
expected to comprise less than 0.1% of the total lignocaine residue, its inclusion in the 
regulatory compliance limit is not required. As such, a residue definition that includes only 
parent compound lignocaine as the target compound is considered sufficient to manage the 
use of lignocaine in deer velvet harvest as per established GAP.  
3.8.5 Dietary Risk Assessment  
The dietary risk associated with the use of lignocai ne in the harvesting of deer velvet has not 
changed; the dietary risk assessment will still be based on the sum of lignocaine and 2,6-
dimethylaniline and a HBGV  of 0.021 mg/kg.  
The NEDI for the concurrent use of lignocaine and xylazine for deer velvet har vesting is 
equivalent to less than 40% of the HGBV for the sum of parent compound lignocaine, parent 
compound xylazine, and their common 2,6- dimethylaniline metabolite. MPI has therefore 
determined that the use of lignocaine for deer velvet harvesting,  according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.   
3.8.6 Relevant International MRLs  
There are no international MRLs for lignocaine (or lidocaine) in deer velvet.   
20 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018 Ministry for Primary Industries  3.9 PROPOSAL TO AMEND THE RESIDUE DE FINTION FOR XYLAZINE  
It is proposed that the residue definition for xylazine is amended to support the GAP use of 
the compound in the harvest of deer velvet.  
The revised entry for xylazine in Schedule 1 of the Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maxi mum 
residue limit applies  Food Maximum Permitted 
Residue Level (mg/kg)  
Xylazine  7361 -61-7 Xylazine  Deer Velvet  0.5 
3.9.1 Amendment Rationale  
Like the proposed change to the residue definition for lignocaine in section 3.8 of this 
document, a change is also pro posed for the residue definition for xylazine. This is due to the 
lack of significant 2,6 -dimethylaniline residues following the GAP use of xylazine in deer 
velvet harvesting that would require the compound’s inclusion in the regulatory compliance residue definition. The metabolite will still be considered in the dietary intake calculations for 
xylazine’s use as a veterinary medicine.   
3.9.2 Chemical Information  
Common name of compound  Xylazine  
Use of compound  Sedative and analgesic  
Chemical Abstract Services (CAS) Registry number  7361 -61-7 
Type of compound  Alpha -2 agonist  
Administration method  Systemic injection  
3.9.3 Good Agricultural Practice  
There is no change to GAP for xylazine as previously established. Current GAP for the harvesting of deer velvet is the a dministration of up to 0.75 mg/kg xylazine, with the harvest 
commencing after the animal has been determined to be sufficiently sedated. This is then 
followed by administration of the local anaesthetic lignocaine according to GAP (section 3.8.3 
of this proposal). The use of xylazine as a sedative in food- producing animals does attract a 
withholding period for meat and milk, but there is no withholding period for deer velvet.   
3.9.4  Residue Information 
The residue data associated with the concurrent use of xylaz ine and lignocaine for deer 
velvet harvest is discussed in section 3.8.4 of this document. Further to that information, data evaluating the residue profile of xylazine alone confirmed that residues of parent compound 
xylazine did not exceed 0.2 mg/kg when used as per GAP, and residues of 2,6 -
dimethylaniline stemming solely from the administration of xylazine remained less than 0.00056 mg/kg. As such, the regulatory compliance residue definition, which is used to confirm the use of xylazine according to GAP,  does not require the retention of the 2,6 -
dimethylaniline metabolite.  
3.9.5  Dietary Risk Assessment  
The dietary risk associated with the use of xylazine in the harvesting of deer velvet has not changed; the dietary risk assessment will still be based on the s um of xylazine and 2,6-
dimethylaniline and a HBGV
 of 0.021 mg/kg.  
The NEDI for the concurrent use of lignocaine and xylazine for deer velvet harvesting is 
equivalent to less than 40% of the HGBV for the sum of parent compound lignocaine, parent 
compound x ylazine, and their common 2,6- dimethylaniline metabolite. MPI has therefore  
Ministry for Primary Industries   Proposals to Amend the Maximum Residue Levels for A gricultural Compounds Food Notice 2018  • 21 determined that the use of xylazine for deer velvet harvesting,  according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.   
3.9.6 Relevant Internatio nal MRLs  
There are no international MRLs for xylazine in deer velvet.  
3.10 PROPOSAL TO EXEMPT PARAFFIN OILS   
It is proposed that paraffin oil be included in Schedule 2 of the Notice, to establish it as an 
agricultural chemical compound for which no MRLs apply .  
Paraffin oils are chemically inert substances with a low toxicity profile. When used as an 
agricultural compound, they are not considered to be of toxicological concern and do not 
require an acceptable daily intake to manage exposure. The quality and pur ity of the paraffin 
oils used as agricultural compounds are evaluated as part of the technical assessment of the 
chemistry of trade name products at registration, ensuring that any food safety risks 
associated with potential impurities are appropriately ma naged.  
It is considered that paraffin oils fall outside the scope of the existing exemption for C9- C16 
alkanes because they can be cyclic, therefore requiring their own exemption for agricultural compound use.  
There is currently no entry in Schedule 2 for paraffin oil.  
 
The proposed entry in Schedule 2 will read:  
Substance CAS#                                      Condition  
Paraffin oils  64742 -46-7; 72623 -86-0; 
8042 -47-5; and 97862 -82-3 When used as an agricultural compound.  
3.11 PROPOSAL TO  AMEND THE  EXEM PTION FOR FORMIC ACI D 
It is proposed that the exemption from compliance with an MRL for formic acid is removed 
from Schedule 2 of the Notice and added to Schedule 3, and its condition revised. This will 
allow for it to be positioned with the similar exempt ions for oxalic acid (see entry 3.12) and 
thyme extracts (see entry 3.13), and align its condition of exemption with those entries.  
 
The entry in Schedule 2 will be removed.  
 
The revised entry in Schedule 3 will read as follows:  
Substance CAS#  Condition  
Formic acid  64-18-6 When used as an agricultural compound for the control of 
Varroa  mite ( Varroa destructor ) in beehives  
 
This amendment will better align the similar exemptions with each other, and position them in 
the Schedule that addresses the treat ment of food- producing animals. It also allows for a 
more specific condition associated with the compound’s use as an agricultural compound.   
22 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice 2018 Ministry for Primary Industries  3.12 PROPOSAL TO  AMEND THE  EXEMPTION FOR OXALIC A CID 
It is proposed that the exemption from compliance with an MRL for oxalic acid is also 
removed from Schedule 2 of the Notice and added to Schedule 3, and its condition revised.  
 
The entry in Schedule 2 will be removed.  
 
The revised entry in Schedule 3 will read as follows:  
Substance CAS#  Condition  
Oxalic acid  144-62-7 When used as an agricultural compound for the control of 
Varroa  mite ( Varroa destructor ) in beehives  
 
This amendment will better align the similar exemptions with each other, and position them in 
the Schedule that addresses the treatment of food -producing animals. It also allows for a 
more specific condition associated with the compound’s use as an agricultural compound.  
3.13 PROPOSAL TO  AMEND THE  EXEMPTION FOR THYMOL  
It is proposed that the exemption from compliance with an MRL for thymol in Schedule 3 is 
revised to better reflect the compound, and similar extracts of thyme, in both substance 
definition and use.  
 
The revised entry in Schedule 3 will read as follows:  
Substance CAS#  Condition  
Extracts of Thymus vulgaris  (thyme) 
containing thymol  N/A  When us ed as an agricultural compound for the control of 
Varroa  mite ( Varroa destructor ) in beehives  where the primary 
mode of action derives from the presence of thymol  
 
This amendment will allow for the use of thyme oil and other extracts of the thyme plant for 
the control of Varroa mite in beehives, when such extracts rely on the presence of thymol to 
derive its efficacy. It is considered that these extracts of thyme will have the same risk profile 
as its derivative thymol.