G/TBT/W/712  
3 March  2020 
(20-1602) Page: 1/2 
Committee on Technical Barriers to Trade  Original:  Spanish  
 
  
EUROPEAN UNION – CHLOROTHALONIL (PESTICIDE ACTIVE SUBSTANCE)  
STATEMENT BY COLOMBIA TO THE COMMITTEE  
ON TECHNICAL BARRIERS TO TRADE  
26 AND 27 FEBRUARY 2020  
The following communication, dated 2 March  2020, is being circulated at the request of the 
delegation of Colombia . 
 
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1.  Colombia wishes to reiterate its concern regarding the measure notified by the EU in document 
G/TBT/N/EU/625  relating to the non -renewal of the approval of the active substance chlorothalonil . 
This substance is key to pest control for a wide variety of crops, particularly bananas, since it is used 
for the control of Black Sigatoka, a fungus that devastates banana crops.  
2.  In recent months, the EU has adopted a policy to reduce the approval of the u se of plant 
protection products, which is affecting the exports of its trade partners owing to the suspended 
approval of numerous active substances and the subsequent reduction of their maximum residue 
levels (MRLs) to the minimum detection level . These me asures are being taken without any sound 
scientific evidence and without any proof that they effectively constitute less trade -restrictive 
measures to ensure an appropriate level of protection for consumers.  
3.  In Colombia and several other Latin American cou ntries, the use of certain active compounds, 
such as chlorothalonil, is indispensable in agricultural production for the protection of crops against 
pests and diseases, and for maintaining the quality and safety of products during storage, transport 
and di stribution, before they reach consumers on the European market.  
4.  Furthermore, it is important to indicate that, regarding the revision of MRLs, the European Food 
Safety Authority (EFSA) has published, as it has done more and more frequently, reasoned opinio ns 
stating that, owing to insufficient information, the risk assessment for active ingredients is 
inconclusive . This situation has been wrongly interpreted by the European Commission (DG SANTE), 
which, as a precaution, has not renewed the approval of the s ubstances . It is worth noting that, 
contrary to the provisions of the WTO TBT Agreement, the EU's decisions are not provisional and do 
not demonstrate any effort to obtain the further information necessary to conduct a more objective 
risk assessment.  
5.  The foregoing constitutes a violation of Article 2.2 of the TBT Agreement, which stipulates that 
technical regulations shall not be more trade -restrictive than necessary to fulfil a legitimate 
objective . As indicated, there is insufficient information to establ ish criteria for acceptance or 
rejection of the chlorothalonil compound, given that, from a scientific point of view, its effect on 
health has not been clearly determined.  
6.  In light of the above, it is essential for the EU to use a risk assessment approach in 
decision -making with regard to the application of this measure, since there is insufficient scientific 
evidence to determine the various toxicological aspects that may affect human health and the 
thresholds for safe use of the active substance chlorotha lonil are unknown.  G/TBT/W/712  
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  7.  It is important that the measures adopted are based on scientific evidence and international 
standards and also take account of the biodiverse agriculture of countries such as Colombia, which 
cannot be compared with that of European lati tudes, where the climatic conditions and seasons are 
very different . The foregoing is in accordance with the terms of the TBT Agreement, which provides 
that any measures established must not be more trade -restrictive than necessary or create 
unnecessary ob stacles to trade.  
8.  In view of the above, Colombia once again requests the EU to maintain the registration of 
chlorothalonil in the EU.  
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