MONTREAL PROTOCOL

ON SUBSTANCES THAT DEPLETE

THE OZONE LAYER

UNEP

REPORT OF THE

TECHNOLOGY AND ECONOMIC ASSESSMENT PANEL

VOLUME 3

MAY 2014

EVALUATION OF 2014 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE 

INTERIM REPORT

MBTOC 2014 CUNs: Interim Recommendations – May 2014 iii

UNEP

MAY 2014 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

EVALUATION OF 2014 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE

INTERIM REPORT
iv MBTOC 2014 CUNs: Interim Recommendations – May 2014

Montreal Protocol

On Substances that Deplete the Ozone Layer

Report of the

UNEP Technology and Economic Assessment Panel

May 2014

EVALUATION OF 2014 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE 

The text of this report is composed in Times New Roman.

Co-ordination: Methyl Bromide Technical Options Committee

Composition of the report: Co-chairs Ian Porter, Marta Pizano, Mohammed Besri

Reproduction: UNON Nairobi

Date: May 2014

Under certain conditions, printed copies of this report are available from:

UNITED NATIONS ENVIRONMENT PROGRAMME

Ozone Secretariat, P.O. Box 30552, Nairobi, Kenya

This document is also available in portable document format from

http://ozone.unep.org/new_site/en/assessment_panels_main.php

No copyright involved. This publication may be freely copied, abstracted and cited, with 

acknowledgement of the source of the material.
MBTOC 2014 CUNs: Interim Recommendations – May 2014 v

Disclaimer

The United Nations Environment Programme (UNEP), the Technology and Economic Assessment 

Panel (TEAP) Co-Chairs and members, and the Methyl Bromide Technical Options Committee 

(MBTOC) Co-Chairs and members, and the companies and organisations that employ them do not 

endorse the performance, worker safety, or environmental acceptability of any of the technical options 

discussed. Every industrial operation requires consideration of worker safety and proper disposal of 

contaminants and waste products. Moreover, as work continues - including additional toxicity 

evaluation - more information on health, environmental and safety effects of alternatives and 

replacements will become available for use in selecting among the options discussed in this document.

UNEP, TEAP Co-Chairs and members, and the MBTOC Co-Chairs and members, in furnishing or 

distributing this information, do not make any warranty or representation, either express or implied, 

with respect to the accuracy, completeness, or utility; nor do they assume any liability of any kind 

whatsoever resulting from the use or reliance upon any information, material, or procedure contained 

herein, including but not limited to any claims regarding health, safety, environmental effect or fate, 

efficacy, or performance, made by the source of information.

Mention of any company, association, or product in this document is for information purposes only 

and does not constitute a recommendation of any such company, association, or product, either 

express or implied by UNEP, TEAP Co-Chairs and members, and the MBTOC Co-Chairs and 

members or the companies or organisations that employ them.

Acknowledgement

The Technology and Economic Assessment Panel and its Methyl Bromide Technical Options 

Committee acknowledge with thanks the outstanding contributions from all of the individuals and 

organisations who provided support to Panel and Committee Co-Chairs and members. The opinions 

expressed are those of the Panel and the Committee and do not reflect the reviews of any sponsoring 

or supporting organisation.

The TEAP thanks the UN Multilateral Fund Secretariat in Montreal, Canada, for hosting the 

TEAP meeting, 5-9 May 2014, where the final elements for this report were discussed and 

decisions were taken how to finalise the report.

Methyl Bromide Technical Options Committee:

MBTOC Co-Chairs: Mohammed Besri (Morocco), Marta Pizano (Colombia), Ian Porter (Australia). 

MBTOC Technical Members: Jonathan Banks (Australia); Chris Bell (UK); Fred Bergwerff 

(Netherlands); Aocheng Cao (China); Peter Caulkins (USA); Ricardo Deang (Philippines); Raquel 

Ghini (Brazil); Ken Glassey (New Zealand); Alfredo Gonzalez (Philippines); Michelle Marcotte 

(Canada ); Takashi Misumi (Japan); David Okioga (Kenya); Christoph Reichmuth; (Germany); Jordi 

Riudavets (Spain); John Sansone (USA); Sally Schneider (USA); Johannes (Stappies) Staphorst 

(South Africa); Akio Tateya (Japan); Robert Taylor (UK); Alejandro Valeiro (Argentina); Ken Vick 

(USA); Nick Vink (South Africa); Chris Watson (UK); Jim Wells (USA); Eduardo Willink 

(Argentina);.Suat Yilmaz (Turkey)
vi MBTOC 2014 CUNs: Interim Recommendations – May 2014

Foreword

The May 2014 TEAP Report

The May 2014 TEAP Report consists of six volumes:

Volume 1: May 2014 TEAP Progress Report

Volume 2: May 2014 TEAP Essential Use Nominations Report

Volume 3: May 2014 TEAP Critical Use Nominations Report

Volume 4: TEAP XXV/5 Task Force Report on information on alternatives to ODS 

Volume 5: TEAP XXV/6 Report on TOC appointment processes, future configurations and the 

streamlining of annual (progress) reports

Volume 6: TEAP XXV/8 Task Force on the funding requirement for the 2015-2017 replenishment of 

the Multilateral Fund for the Implementation of the Montreal Protocol

 Volume 1 contains the TOC progress reports and a chapter “Other TEAP matters”, discussing the 

status of (re-) nominations and challenges to the participation of experts, as well as an annex with 

the list of TEAP and TOC members, status May 2014 

 Volume 2 contains the assessment of the 2014 essential use nominations by the CTOC and the 

MTOC

 Volume 3 contains the assessment of the 2014 critical use nominations by the MBTOC 

 Volume 4 is the report of the TEAP Task Force responding to Decision XXV/5 on information on 

alternatives to ODS in the refrigeration and air conditioning, foams, medical uses, fire protection 

and solvent sectors

 Volume 5 contains a description by the TEAP on the TOC appointment processes and their future 

configurations and the streamlining of the annual (progress) reports in response to Decision 

XXV/6

 Volume 6 is the report of the TEAP Task Force responding to Decidion XXV/8 on the funding 

requirement for the 2015-2017 replenishment of the Multilateral Fund for the Implementation of 

the Montreal Protocol.

This is Volume 3 on the assessment of critical use nominations by the MBTOC.

The UNEP Technology and Economic Assessment Panel (TEAP):

Lambert Kuijpers, co-chair NL Jose Pons-Pons VEN

Bella Maranion, co-chair USA Ian Porter AUS

Marta Pizano, co-chair COL Miguel Quintero COL

Paul Ashford UK Helen Tope AUS

Mohammed Besri MOR Dan Verdonik USA

David Catchpole UK Ashley Woodcock UK

Marco Gonzalez CR Masaaki Yamabe J

Sergey Kopylov RF Shiqiu Zhang PRC

Kei-ichi Ohnishi J Jianjung Zhang PRC

Roberto Peixoto BRA
MBTOC 2014 CUNs: Interim Recommendations – May 2014 vii

MAY 2014 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

EVALUATIONS OF 2014 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE

INTERIM REPORT
viii MBTOC 2014 CUNs: Interim Recommendations – May 2014

UNEP

MAY2014 REPORT OF THE

TECHNOLOGY AND ECONOMIC

ASSESSMENT PANEL

MBTOC INTERIM CUN REPORT – MAY 2014

Common Acronyms

1,3-D 1,3-dichloropropene

A5 Article 5 Party

ASD Anaerobic soil disinfestation

CUE Critical Use Exemption

CUN Critical Use Nomination

DOI Disclosure of Interest

EC European Community

EMOP Extraordinary Meeting of the Parties

EPA Environmental Protection Agency

EPPO European Plant Protection Organisation

IM Iodomethane

IPM Integrated Pest Management

IPPC International Plant Protection Convention

ISPM International Standard Phytosanitary Measure

LPBF Low Permeability Barrier Film (including VIF films)

MB Methyl Bromide

MBTOC Methyl Bromide Technical Options Committee

MITC Methyl isothiocyanate

MOP Meeting of the Parties

MS Metam sodium

OEWG Open Ended Working Group

Pic Chloropicrin

QPS Quarantine and Pre-shipment

SF Sulfuryl fluoride

TEAP Technology and Economics Assessment Panel

TIF Totally Impermeable Film

VIF Virtually Impermeable Film

VOC Volatile Organic Compounds
MBTOC 2014 CUNs: Interim Recommendations – May 2014 ix

2014 Evaluations of Critical Use Nominations for Methyl Bromide and 

Related Matters – Interim Report

Table of Contents

1.1 SCOPE OF THE REPORT ..............................................................................................................1

1.2. CRITICAL USE NOMINATIONS FOR METHYL BROMIDE ................................................1

1.2.1. MANDATE ..................................................................................................................................1

1.2.2 FULFILMENT OF DECISION IX/6 ..................................................................................................2

1.2.3 REPORTING OF MB CONSUMPTION FOR CRITICAL USE ...............................................................2

1.2.4 TRENDS IN METHYL BROMIDE USE FOR CUES SINCE 2005........................................................3

1.2.5 DISCLOSURE OF INTEREST..........................................................................................................3

1.2.6 ARTICLE 5 ISSUES ......................................................................................................................3

1.2.7 CONSIDERATION OF STOCKS, DECISION EX.1/4 (9F) ...................................................................4

1.3 EVALUATIONS OF CUNS – 2014 ROUND FOR 2015 AND 2016 EXEMPTIONS.................10

1.3.1 CRITICAL USE NOMINATIONS REVIEW......................................................................................11

1.3.2 ACHIEVING CONSENSUS............................................................................................................11

1.4 MBTOC SOILS: INTERIM EVALUATIONS OF 2014 CRITICAL USE NOMINATIONS FOR 

METHYL BROMIDE FOR 2015 AND 2016......................................................................11

1.4.1 CRITICAL USE NOMINATION ASSESSMENT................................................................................11

1.4.2 ISSUES RELATED TO CUN ASSESSMENT FOR PREPLANT SOIL USE ...........................................12

1.4.3 GENERAL COMMENTS ON THE ASSESSMENT FOR PREPLANT SOIL USE .....................................13

1.4.4 REGISTRATION OF ALTERNATIVES FOR PREPLANT USES - DECISION EX I/4 (9I) AND (9J).........13

1.4.5. DECISION XXV/4.....................................................................................................................13

1.4.5.1 Regulations impacting use of alternatives by country ..........................................................13

1.4.5.2 Health effects of MB use and environmental acceptability ..................................................14

1.4.6 SUSTAINABLE ALTERNATIVES FOR PREPLANT USES .................................................................15

1.4.7 STANDARD PRESUMPTIONS USED IN ASSESSMENT OF NOMINATED QUANTITIES......................15

1.4.8 ADJUSTMENTS FOR STANDARD DOSAGE RATES USING MB/PIC FORMULATIONS .....................17

1.4.9 USE/EMISSION REDUCTION TECHNOLOGIES - LOW PERMEABILITY BARRIER FILMS AND 

DOSAGE REDUCTION ................................................................................................................17

1.5. INTERIM EVALUATION OF CUNS: STRUCTURES AND COMMODITIES .........................36

1.5.1 STANDARD RATE PRESUMPTIONS ..............................................................................................36

1.5.2. DETAILS OF THE EVALUATION..................................................................................................36

1.6 REFERENCES: ................................................................................................................................39

ANNEX 1: DECISION IX/6 ......................................................................................................................44

ANNEX II - PART A: HISTORIC TRENDS IN PREPLANT SOIL NOMINATIONS AND 

EXEMPTIONS FOR MB USE ............................................................................................45

ANNEX III– PART B: HISTORIC TRENDS IN STRUCTURAL AND COMMODITY 

NOMINATIONS AND EXEMPTIONS FOR MB USE ....................................................52

MBTOC 2014 CUNs: Interim Recommendations – May 2014 1

2014 Evaluation of Critical Use Nominations for Methyl Bromide and 

Related Matters 

1.1 Scope of the Report

The 2014 interim report provides evaluations by MBTOC of Critical Use Nominations (CUNs) 

submitted for methyl bromide (MB) for 2015 and 2016 by six Parties: three non-A5 (Australia, 

Canada and USA) and three A5 (Argentina, China and Mexico). One additional A5 Party (Malaysia) 

submitted a CUN, but later informed the Ozone Secretariat and MBTOC that it was withdrawing the 

nomination. As per provisions set out in Decision IX/6 (Annex I, MOP16), CUNs were submitted by 

the Parties to the Ozone Secretariat in accordance with the timetable shown in paragraph 1 of Annex I, 

Decision XVI/4. Given that January 1st, 2015 is the deadline for phasing-out methyl bromide in A5 

Parties, these Parties are now able to submit CUNs according to provisions set out in the Protocol.

This report also provides 1) interim recommendations for the CUNs for which the Parties provided 

information as per the timelines set at the 25th Meeting of the Parties; 2) information from Parties on 

stocks (Decision Ex.1/4 (9f)); 3) partial information on actual MB consumption for critical uses (in 

accordance with Decision XVII/9) and 4) apparent adoption rates of alternatives, as evidenced by 

trend lines on reduction of MB CUNs (in accordance with Decisions XIX/9, XX/5). It is noted that 

trend lines on adoption may not necessarily indicate true adoption rates for alternatives, as the use of 

stocks of MB that may have been available to the same sector or areas of production may have 

increased or fallen within the sector due to a range of circumstances. MBTOC notes that stock 

volumes have significantly decreased in recent years. 

Standard presumptions used in the 2014 round were the same as those used in the 2013 evaluations of 

the CUNs. These standard presumptions are subject to continual review. However, any changes 

proposed by MBTOC are required to be approved by the Party’s in the MOP preceding the year of 

assessment based on a draft Decision presented to the MOP in accordance with paragraph 2 in Annex 

1 to the report of MOP16. 

1.2. Critical Use Nominations for Methyl Bromide 

1.2.1. Mandate

Under Article 2H of the Montreal Protocol, Parties not operating under Article 5(1) are required to 

phase-out all production and consumption (defined as production plus imports minus exports) of MB 

after 1 January 2005. The same requirements apply to Parties operating under Article 5(1) after 1 

January 2015. However, the Parties agreed to a provision enabling exemptions for those uses of MB 

that qualify as critical. Parties established criteria, under Decision IX/6 (see Annex 1 of this report) of 

the Protocol, which all critical uses need to meet in order to qualify for an exemption. TEAP and its 

MBTOC have provided guidance to the Parties on recommendations regarding critical use exemptions 

in accordance with Decisions IX/6, Annex I of Decision XVI/2 and a number of subsequent decisions 

(XVI/2; XVII/9, XVIII/13, XIX/9, XX/5, XXI/11, XXII/6, XXIII/4, XXIV/5 and XXV/4). 

Decision XXIV/5 differed from past decisions in that it reinforced that Parties ‘take all reasonable 

steps to explore further the possibility of transitioning to technically and economically feasible 

alternatives... and to ensure that the Methyl Bromide Technical Options Committee is fully aware of 

these efforts’.

Decision XXV/4 requests Australia and Canada to submit, by the 36th OEWG, the available results of 

their research programmes on alternatives to MB to the TEAP for its consideration. It is anticipated 

that TEAP will consider the progress by Parties to this decision when making its final 

recommendations. This same Decision further requests TEAP to analyse the impact of national, 

subnational and local regulations and law on the potential use of methyl bromide alternatives, to 

report annually on the status of re-registration and review of methyl bromide uses for the applications 

reflected in the CUNs, including any information on health effects and environmental acceptability 
2 MBTOC 2014 CUNs: Interim Recommendations – May 2014

and to report annually on the status of registration of alternatives and substitutes for methyl bromide, 

with particular emphasis on possible regulatory actions that will increase or decrease dependence on 

methyl bromide. 

MBTOC considers that any chemical or product registered for a particular use has been through the 

rigours of the national local regulatory authorities and accepts that these fall within guidelines for 

health effects and environmental acceptability. MBTOC particularly takes note of those products, 

which are generally listed in any CUN application. 

1.2.2 Fulfilment of Decision IX/6

Decision XVI/2 and Decision XXI/11 directed MBTOC to indicate whether all CUNs fully met the 

requirements of Decision IX/6. When the requirements of Decision IX/6 are met, MBTOC can 

recommend critical uses of MB. Where some of the conditions are not fully met, MBTOC can 

recommend a decreased amount depending on its technical and economic evaluation, or determine the 

CUN as “unable to assess” and request further information from the Party. When the information is 

submitted, MBTOC is required to re-assess the nomination, following the procedures defined in 

Annex 1 of the Sixteenth Meeting of the Parties. 

MBTOC recommended less methyl bromide that requested in a CUN when technically and 

economically feasible alternatives were considered to be available or, when the Party failed to show 

that there was no technically and economically feasible alternative. In this round, MBTOC did not 

recommend two nominations as important information essential to the assessment had not been 

supplied and the nomination did not meet the requirements of Decision IX/6. Also, in this round of 

CUNs, as in previous rounds, MBTOC considered all information provided by the Parties, including 

answers to questions requested by MBTOC up to the date of the evaluation. 

Now that technically and economically feasible alternatives have been identified for virtually all 

applications of methyl bromide, regulations on the use of these alternatives often determine their 

availability to the end users. In addition, comparative information on the economic 

feasibility/infeasibility of the use of alternatives compared to MB is critical to the outcomes of present 

and future CUNs. In particular, MBTOC needs annual updates of the economics information 

evaluating the costs of alternatives. 

1.2.3 Reporting of MB Consumption for Critical Use

A number of decisions (Ex. I/3(5); XVI/2(4); XVII/9(5)), XVIII/13(6), XIX/9(7), XX/5(7), 

XXI/11(6), XXII/6(5), XXIII/4(4), XXIV/5 and XXV/4 set out provisions which request Parties to 

submit by 1st February each year information on how criteria in IX/6(1) is met when licensing 

permitting or authorizing CUEs. Decision XVII/9 of the 17th MOP specifically requests TEAP 

and its MBTOC to “report for 2005 and annually thereafter, for each agreed critical use 

category, the amount of methyl bromide nominated by a Party, the amount of the agreed 

critical use and either: 

(a) The amount licensed, permitted or authorised; or 

(b) The amount used

Since the start of the CUN reviews in 2003, MBTOC has provided tables of the historic amounts of 

MB nominated and agreed for each critical use (Annexes III and IV). Additionally Parties provide 

accounting frameworks on amounts used for critical uses and stocks as required under Dec Ex.1/4 

(9f). (Table 1-3).

In 2013, the Meeting of the Parties authorised Australia to use 29.760 tonnes of MB for strawberry 

runners and 1.187 t for use on rice. The Party exempted 32.134 tonnes and 31.521 t was reportedly 

used for the critical uses in 2013. For Canada, the Meeting of the Parties in 2013 authorised 13.109 

tonnes for strawberry runners. In the accounting framework the party reported that 12.867 t was used 

for critical uses in 2013. For the United States, the MOP authorised 562.326 tonnes for a wide range 
MBTOC 2014 CUNs: Interim Recommendations – May 2014 3

of crops and commodities in 2013 (Annex III and IV). In their allocation regulation for 2013 critical 

uses, the Party reported that 562.326 tonnes had been approved for pre-plant soil uses and postharvest 

uses (Federal Register 78, July 22, 2013).

This is the first year that A5 Parties are able to submit CUNs. Under Decision Ex1/4. (9f) those A5 

Parties which are granted critical use will need to provide accounting frameworks for these uses in 

forthcoming years.

1.2.4 Trends in Methyl Bromide Use for CUEs since 2005

The nominated amounts and the apparent rate of reduction in MB or adoption of alternatives achieved 

by Parties are shown in Table 1-5, as well as Figures 1-1 and 1-2. It is noted that for those non-A5 

countries that have pre-2005 stocks of MB that are being drawn down, the reductions in CUEs from 

year to year cannot be taken directly as evidence of adoption of alternatives since pre-2005 stocks 

may have been used (or may still be used) in the same sectors. Tables 1-9 and 1-11 in particular show 

the amounts nominated by Parties for soil uses, and structures and commodity uses and the final 

recommendations for ‘Critical Use’ in 2015 and 2016. 

Decision XVII/9 requires TEAP to show trends in the phase out of the critical uses of MB by the 

Parties (Fig 1-1 and Fig 1-2, Annexes III and IV). Since 2005, there has been a progressive trend in 

the reduction of methyl bromide for CUNs by all Parties for both soil and post- harvest uses, although 

this has occurred at different rates. Figs 1-1 and 1-2 show reduction trends in amounts 

approved/nominated by Parties for ‘Critical Use’ from 2005 to 2016 for all the remaining soil and 

structures and commodity uses. The complete trends in phase out of MB by country, as indicated by 

change in CUE, are shown in Annexes III and IV.

1.2.5 Disclosure of Interest

As in past reports, MBTOC members were requested to update their disclosure of interest forms 

relating specifically to their level of national, regional or enterprise involvement for the 2014 CUN 

process. The Disclosure of Interest declarations for 2014, updated in March 2014 can be found on the 

internet at http://ozone.unep.org/new_site/en/disclosure_of_interest.php?body_id=6&committee_id=6

and a list of members in Annex I to the 2014 TEAP Report, Volume One. As in previous rounds, 

some members withdrew from or abstained to participate in a particular CUN assessment or only 

provided technical advice on request, for those nominations where a potential conflict of interest was 

declared. 

MBTOC co-chairs further briefed members of recent updates introduced by the Parties to the Terms 

of Reference (TOR) of the TEAP/TOC, as per recent Decisions XXIV/8 and XXV/6. 

1.2.6 Article 5 issues

Methyl bromide is due to be fully phased out in A5 Parties by January 1, 2015, 10 years after full 

phaseout by non-A5 Parties. In both cases, uses for feedstock and QPS are exempted from phase out 

under the control measures described in Article 2H. There is also provision for exemption from phase 

out for uses deemed ‘critical’ according to Article 2H, as complying with Decision IX/6.

Presently, approximately 85% of the controlled consumption in A5 Parties has been phased out, ahead 

of the 2015 deadline. This has been achieved largely as a result of investment projects implemented 

by the Montreal Protocol agencies, with MLF funding, bilateral cooperation and also national 

funding. The large majority of A5 Parties still consuming MB have agreements in place with the 

Executive Committee for full phaseout of methyl bromide by 1st January 2015 at the latest, sometimes 

earlier. These are usually accompanied by a commitment from the Party in question to put in place 

policy packages to restrict consumption of MB for controlled uses after the phase-out. MBTOC notes 

that all A5 Parties submitting CUNs in this round have received funding from the MLF for complete 

phaseout of MB in their countries by 1st January 2015 at the latest, sometimes earlier.
4 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Article 5 Parties may submit nominations for Critical Use Exemptions (CUEs) for uses they consider 

appropriate for the year 2015 and possibly subsequently. The first CUNs by non-A5 Parties were 

made in 2003 for CUEs to be in place in 2005. Four A5 Parties submitted CUNs in this round for 

extended use of MB in 2015; one of these – Malaysia – later withdrew its CUN. 

1.2.7 Consideration of Stocks, Decision Ex.1/4 (9f)

One criterion for granting a critical use is that MB “is not available in sufficient quantity and quality 

from existing stocks of banked or recycled methyl bromide” (paragraph 1 (b) (ii) of Decision IX/6). 

Parties nominating critical use exemptions are requested under decision Ex.I/4(9f) to submit an 

accounting framework with the information on stocks. MBTOC has not reduced its recommended 

amount of methyl bromide in consideration of stocks held by the Party and has instead relied on 

Parties to take this into consideration when approving the amounts recommended by TEAP for each 

nomination. To assist the Parties with their consideration of stocks, and in accordance with Decision 

XVIII/13(7), a summary of the data on stocks as reported by the Parties in the first year for accounting 

in 2006, and then reports submitted in 2012 and 2013 are summarized in Tables 1-1 to 1-3 below. 

Parties may wish to consider this information in the light of Decision IX/6 1(b) (ii) when authorising 

methyl bromide for critical uses.

Efficient functioning of commerce requires a certain level of available stocks and additional stocks to 

respond to emergencies. Additionally, stocks may be held on behalf of other Parties or for exempt 

uses (feedstock and QPS uses). The correct or optimal level of stocks for virtually every input to 

production is not zero. In addition, stocks are privately owned and may not be readily available for 

critical uses, or there may be national regulations preventing the transfer of stocks. Despite these 

restrictions, Parties may wish to ensure that stocks are used wherever possible in order to minimize 

the quantity of MB that need to be produced each year for critical uses. Tables 1-1 to 1-3 report the 

quantities of MB ‘on hand’ at the beginning and end respectively of 2005, 2012 and 2013 as required 

under Decision XVI/6. The earlier CUN reports identified stocks for the other years.
MBTOC 2014 CUNs: Interim Recommendations – May 2014 5

Table 1-1. Quantities of MB (metric tonnes) ‘on hand’ at the beginning and end of 2005, as first 

reported by Parties in 2006/2007 under Decision XVI/6.

Party

Critical use 

exemptions 

authorized 

by MOP for 

2005

Quantity of MB as reported by Parties (metric tonnes)

Amount on 

hand at 

start of 

2005

Quantity 

acquired for 

CUEs in 2005 

(production 

+imports)

Amount 

available 

for use in 

2005

Quantity 

used for 

CUEs in 

2005

Amount 

on hand at 

the end of 

2005

Australia 146.6 0 114.912 114.912 114.912 0

Canada 61.792 0 48.858 48.858 45.146 3.712

EU 4 392.812 216.198 2 435.319 2 651.517 2 530.099 121.023

Israel 1 089.306 16.358 1 072.35 1 088.708 1 088.708 0

Japan 748 0 594.995 594.995 546.861 48.134

New Zealand 50 6.9 40.5 47.4 44.58 2.81

USA(a) 9 552.879 7 613 not reported 7 170 443

Additional information on stocks was reported on US EPA website, September 2006: MB inventory held by USA 

companies: 2004 = 12,994 tonnes; 2005 = 9,974 tonnes.

Table 1-2. Quantities of MB ‘on hand’ at the beginning and end of 2012, as reported by Parties in 

2012 under Decision XVI/6. 

Party Critical use 

exemption 

authorized by 

MOP for 2012

Quantity of MB as reported by Parties (metric tonnes)

Amount 

on hand 

at start of 

2012

Quantity 

acquired for 

CUEs in 

2012 

(production 

+imports)

Amount 

available 

for use in 

2012

Quantity 

used for 

CUEs in 

2012

Amount 

on hand 

at the 

end of 

2012

Australia 33.413 0 32.593 32.593 32.593 0

Canada 16.281 1.455 12.186 13.641 12.725 0.916

Japan 219.609 9.726 155.902 165.628 174.708 2.709

USA 1023

[760 t 

authorization and 

263 t critical stock 

allowances]

? (c)

1249(a)

759 2008 759 ?

(c)

627(b)

(a) Amount of pre-2005 stocks available at the start of 2012 

(b) Amount of pre-2005 stocks available at the end of 2012

(c) Amount of post 2005 stocks are not reported.
6 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Table 1-3. Quantities of MB ‘on hand’ at the beginning and end of 2013, as reported by Parties in 

2013 under Decision XVI/6.

Party Critical use 

exemption 

authorized by 

MOP for 2013

Quantity of MB as reported by Parties (metric tonnes)

Amount 

on hand 

at start 

of 2013

Quantity 

acquired for 

CUEs in 2013 

(production 

+imports)

Amount 

available 

for use in 

2013

Quantity 

used for 

CUEs in 

2013

Amount 

on hand at 

the end of 

2013

Australia 32.134 0 31.521 31.521 31.521 0

Canada 13.109 0.916 11.951 12.867 11.460 1.407

Japan 3.317 0.816 1.190 2.006 1.667 0.339

USA 562 ?

(c)

627(a)

562 1189 562 ?

(c)

357(b)

(a) Amount of pre-2005 stocks available at the start of 2013

(b) Amount of pre-2005 stocks available at the end of 2013

(c) Amount of post 2005 stocks are not reported 
MBTOC 2014 CUNs: Interim Recommendations – May 2014 7

Figure 1-1. Amounts of MB nominated and exempted for CUE uses in nominated preplant soil 

sectors from 2005 to 2016. Blue lines indicate the trend in CUN MB nominated and 

the red lines the amount of CUE MB approved by the Parties
8 MBTOC 2014 CUNs: Interim Recommendations – May 2014

 

Figure 1-2. Amounts of MB nominated and exempted for CUE uses in dry cure pork (smokehouse 

hams) from 2005 to 2016. Blue lines indicate the trend in the CUN MB nominated and the red 

lines the amount of CUE MB approved by the Parties

 

 
MBTOC 2014 CUNs: Interim Recommendations – May 2014 9

Table 1-4. Summary of Critical Use Nominations and Exemptions of Methyl Bromide (tonnes) 

Quantities Nominated Quantities Approved

Interim 

rec.

Party 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2005

(1ExMOP 

and

16MOP)

2006

(16MOP+

2ExMOP+

17MOP)

2007

(17MOP + 

18MOP)

2008

(18MOP

+

19MOP)

2009

(19MOP)

2010

(20MOP

+

21MOP)

2011

(21MOP)

2012

(22MOP)

2013

(23MOP)

2014

(24MOP)

2015 

(25 MOP)

2016

Australia 206.950 81.250 52.145 52.900 38.990 37.610 35.450 34.660 32.164 30.947 29.79 29.79 146.600 75.100 48.517 48.450 37.610 36.440 28.710 31.708 32.134 30.947 29.79 29.79

Canada 61.992 53.897 46.745 42.241 39.115 35.080 19.368

+3.529

16.281 13.444 10.305 5.261 5.261 61.792 53.897 52.874 36.112 39.020 30.340

+3.529 19.368 16.281 13.109 10.305 5.261 5.261

EC1

5754.361 4213.47 1239.873 245.00 0 0 0 0 0 0 0 0 4392.812 3536.755 689.142 245.146 0 0 0 0 0 0 0 0

Israel 1117.156 1081.506 1236.517 952.845 699.448 383.700 232.247 0 0 0 0 0 1089.306 880.295 966.715 860.580 610.854 290.878 0 0 0 0 0 0

Japan 748.000 741.400 651.700 589.600 508.900 288.500 249.420 221.104 3.317 0 0 0 748.000 741.400 636.172 443.775 305.380 267.000 239.746 219.609 3.317 0 0 0

New 

Zealand

53.085 53.085 32.573 0 0 0 0 0 0 0 0

0

50.000 42.000 18.234 0 0 0 0 0 0 0 0 0

Switzerland 8.700 7.000 0 0 0 0 0 0 0 0 0 0 8.700 7.000 0 0 0 0 0 0 0 0 0 0

USA 10753.997 9386.229 7417.999 6415.153 4958.034 3299.490 2388.128 1181.779

+ 6.339

691.608 442.337 377.170 234.78 9552.879 8081.753 6749.060 5355.976 4261.974 3232.856

+2.018

2055.200 993.706 562.328 442.337 377.170 234.780

Argentina - - - - - - - - - - 245 - - - - - - - - - - [0]

China - - - - - - - - - -- 120 - - - - - - - - - - [114]

Mexico - - - - - - - - - - 140 - - - - - - - - - - [84.957]

TOTALS 18704.241 15617.837 10677.552 8297.739 6244.487 4044.380 2928.142 1460.163 740.533 483.589 917.191 266.561 16050.089 13418.200 9160.714 6990.039 5,254.838 3572.183 2343.024 1261.304 610.888 483.589 412.221 +

[198.957]

[266.561]

 

* Not yet available. 

1Members of the European Community which had CUNs/CUEs included: 2005 – Belgium, France, Germany, Greece, Italy, Netherlands, Poland, Portugal, Spain, and the United Kingdom; 2006 – Belgium, France, Germany, Greece, Ireland, 

Italy, Latvia, Malta, Netherlands, Poland, Portugal, Spain, and the United Kingdom; 2007 – France, Greece, Ireland, Italy, Netherlands, Poland, Spain, and the United Kingdom; 2008 – Poland, Spain
10 MBTOC 2014 CUNs: Interim Recommendations – May 2014

1.3 Evaluations of CUNs – 2014 round for 2015 and 2016 exemptions

Parties requesting CUNs in 2014 sent information to the Ozone Secretariat generally by the January 

24, deadline. The Secretariat forwarded them to MBTOC co-chairs, who in turn provided the 

information to MBTOC for their consideration for preliminary assessment to ensure information had 

been provided as per Decision IX/6 and Annex 1 of the 16th MOP. Where some evidence was missing, 

MBTOC requested further information of the Parties prior to the interim assessment. Detailed interim 

assessments of all CUNs were made by MBTOC at a meeting in Stellenbosch (South Africa) from 

March 31 to April 4 2014. The meeting was attended by twenty MBTOC members with expertise in 

soils, SC and QPS applications of methyl bromide. MBTOC worked as a single body, not in subcommittees. The three co-chairs appointed working groups to address the different tasks assigned to 

MBTOC including CUNs, but also others as included in its Progress Report. Recommendations were 

discussed and signed off in plenary and by consensus. Comments made by members not attending the 

meeting were considered during evaluations. This scheme allowed members with specific expertise 

to make contributions where they were most useful and for all the committee to fully participate in the 

decision making process. 

During the meeting, MBTOC held a teleconference with the US delegation with participation of 

experts from the USA on alternatives for the ham sector. MBTOC also conducted a field visit to the 

Dept. Agriculture, Forestry and Fisheries Quarantine Station in Stellenbosch and two commercial 

field producers (a strawberry producer and a vegetable farm) who were still using methyl bromide. 

Pest control applicators and commercial growers that attended the meetings were surprised to hear 

that South Africa was reporting zero consumption and was concerned that this situation be rectified 

with the regulatory authorities in South Africa. 

For soils CUNs, Australia and Canada submitted similar amounts to the previous rounds highlighting 

difficulties with phase out of MB for the strawberry runners sector in particular. In the USA the only 

soil CUN submitted was for strawberry fruit production. 

With respect to A5 Parties, Argentina submitted CUNs for the strawberry fruit (open field), tomato 

and pepper sectors (protected), China for both protected and field production of ginger and Mexico 

for raspberry and strawberry runners produced in the open field. 

For the postharvest sector only one CUN was received from the USA, for dry cure pork. Malaysia 

initially submitted a CUN for structures concerning flourmills, ship holds and aircraft fumigation, but 

later withdrew this nomination.

The total nominated amount for all countries for 2015 was 917.191 tonnes; of these, 412.191 t by nonA5 Parties (representing a 14.8% reduction with respect to the nominated amount in 2013 for 2015) 

and 505 tonnes by A5 Parties. For 2016, non-A5 Parties have nominated 315.005 tonnes, a reduction 

of 34.6% with respect to the previous year. MBTOC has recommended 198.957 tonnes for A5 Parties 

for 2015 and 266.561 tonnes for non-A5 Parties for 2016. The grounds used for these 

recommendations are given in detail for the relevant CUNs in Tables 1-9, 1-10 and 1-11. 

In general the CUNs were submitted due to the following alleged issues: regulatory restrictions that 

did not allow partial or full use of alternatives, difficulties in the scale-up of alternatives and that all 

alternatives were considered uneconomical, insufficiently effective and/or were unavailable. In 

paragraph 20 of Annex 1 referred to in Decision XVI/4, Parties specifically requested that MBTOC 

explicitly state the specific basis for the Party’s economic statement relating to CUNs. Tables 1-9, 

1.10 and 1-11 provide this information for each CUN as prepared by the MBTOC economist. 

MBTOC notes the economic information supplied by the nominating Parties continued to improve in 

this round.
MBTOC 2014 CUNs: Interim Recommendations – May 2014 11

1.3.1 Critical Use Nominations Review

The meeting was held as required in accordance with the time schedule for the consideration of CUNs 

provided in Annex I referred to in Decision XVI/4. In considering the CUNs submitted in 2014, as in 

previous rounds, MBTOC applied as much as possible the standards contained in Annex I of the final 

report of 16 MOP, and, where relevant, the standard presumptions given below. In particular, 

MBTOC sought to provide consistent treatment of CUNs within and between Parties while at the 

same time taking local circumstances into consideration. The most recent CUE approved by the 

Parties for a particular CUN was used as baseline for consideration of continuing nominations, except 

in the case of A5 Parties, this being the first time that they have submitted CUNs. In that case, 

however, historical MB use provided with the nomination, was taken into account. In evaluating the 

CUNs for soil treatments, MBTOC assumed that the presence of a technically feasible alternative to 

MB would need to provide sufficient pest and/or weed control for continued production of that crop to 

existing market standards. 

For commodity and structural applications, it was assumed that technically and economically feasible 

alternatives would provide disinfestation to a level that met the objectives of a MB treatment, e.g. 

meeting infestation standards in finished product from a mill. The outcome of evaluations of CUNs 

for the soil and structural treatments are presented in Table 1.9, 1.10 and 1.11 below.

1.3.2 Achieving Consensus

In accordance with decision XX/5(9) and similar subsequent decisions (XXI/11(4), XXII/6(4) and 

XXIII/4(3)) and XXIV/5 and 8 the Parties have indicated that MBTOC ‘should ensure that it develops 

its recommendations in a consensus process that includes full discussion among all available 

members of the Committee and should ensure that members with relevant expertise are involved in 

developing its recommendations’.

In keeping with recent Decisions as well as the new working scheme put in place by the co-chairs, all 

members were given access to the information and were able to discuss issues related to all 

nominations (either in person or by electronic means), but only those members able to physically 

participate in the meeting formed consensus. All views were discussed fully in plenary and issues 

debated until a consensus position was reached. No minority positions arose during the meeting 

Several members recused from recommendations on nominations as required by MBTOC’s working 

procedures. These included Jim Wells (US Strawberry Fruit, Mexican strawberry and raspberry 

runners, Argentina strawberry fruit and tomato and peppers), Alejandro Valeiro (Argentina strawberry 

fruit and tomato and pepper), Aocheng Cao (China ginger), Eduardo Willink (Argentina strawberry 

fruit and tomato and pepper) and Ian Porter (Australian Strawberry nurseries). The recusals took 

place either as a result of a member’s disclosure as per MBTOC's guidelines or members may have 

chosen to self-recuse to avoid any perceived conflict of interest.

1.4 MBTOC Soils: Interim Evaluations of 2014 Critical Use Nominations for 

 Methyl Bromide for 2015 and 2016

1.4.1 Critical Use Nomination Assessment

Table 1.5 identifies the quantities recommended by MBTOC after consideration of all the information 

provided by the Parties. In summary, the Australian, Canadian and US nominations were 

recommended in full as the Parties gave sufficient substantiation that alternatives were economically 

infeasible or impacted by regulatory issues. The USA has indicated this will be the last year they will 

submit a CUN for strawberry fruit. The Argentinean nominations were not recommended because 

MBTOC believes that alternatives, which are available and effective, could be used for the 

nominations and the Party did not provide information demonstrating that this is not the case under 

the particular circumstances of these nominations. The CUNs submitted by China and Mexico were 

only partially recommended after adjustments related to MBCTOC’s standard presumptions or 
12 MBTOC 2014 CUNs: Interim Recommendations – May 2014

because MBTOC believes that alternatives are available and effective for part of the nominations. In 

one case, the committee considered that contingency amounts were being requested for a future 

scenario and this was not supported. The detailed descriptions can be found in Table 1-5.

Table 1-5. Summary of the interim recommendations (in square brackets) for CUE’s for preplant 

uses of MB (tonnes) submitted in 2014 for 2015 and 2016

Country and Sector Article 5 Parties Non A5 Parties

Nomination 

by Party for 

2015

Interim 

Recommendation 

for 2015

Nomination 

by the Party 

for 2016

Interim 

Recommendation 

for 2016

1. Australia

Strawberry runners 29.760 [29.760]

2. Canada

Strawberry runners 5.261 [5.261]

3. USA

 Strawberry fruit 231.540 [231.540]

4. Argentina

 Tomato and pepper

 Strawberry fruit

145

100

[0]

[0]

5. China

 Ginger, open field

 Ginger, protected

90

30

[90]

[24]

6. Mexico

 Strawberry runners

 Raspberry runners

70

70

[43.539]

[41.418]

TOTAL 505 [198.957] 266.561 [266.561]

1.4.2 Issues Related to CUN Assessment for Preplant Soil Use

Key issues which influenced assessment and the need for MB for preplant soil use of MB in the 2014 

round were:

i) An increase in the chloropicrin dosage rate allowed in California was a key issue related to 

the further reduction made in the US nomination. 

ii) Continued adoption of a new formulation of 1,3-D/Pic (‘Pic-Clor 60’) in the USA, which 

increases the area that may be treated with 1,3-D in regions affected by township caps in 

California.

iii) More effective disease control obtained with shank applied fumigants than drip applied 

fumigants will influence the practices being adopted for existing and future CUE sector.

iv) The USA has indicated that this will be the last year that they will submit a CUN for 

strawberry fruit. Canada noted that it intends that 2016 is the final year for use of methyl 

bromide for strawberry runner production . 

v) The Mexican raspberry and strawberry runner sectors developed recently and were 

incorporated into the MB phase-out project at a late stage. Only preliminary results from 

trials with alternatives are thus available at this time.

vi) The only chemical alternative available in China for ginger is chloropicrin. Initial results with 

this fumigant are encouraging, but time is needed to implement integrated control programs 

for the key pathogen Ralstonia solanacearum. 
MBTOC 2014 CUNs: Interim Recommendations – May 2014 13

MBTOC has noted more specific issues related to requests for CUNs below and also in the CUN text 

boxes (Table 1.9).

1.4.3 General Comments on the Assessment for Preplant Soil Use

MBTOC continues to encourage Parties to consider a review of regulations covering the registration, 

use and adoption of alternatives, particularly those regarding barrier films to reduce dosage rates of 

MB and its alternatives, and associated emissions. MBTOC is aware that regulations now allow high 

barrier films (VIF) to be used with MB in California. MBTOC also notes that a large proportion of 

MB has been nominated for uses where regulations or legislation prevent reductions of MB dosage. 

For several cases, the mandatory use of MB is specified at a high dosage, in some cases for treatment 

of certified propagation material. Also regulations on the use of alternatives or lack of registration of 

them, are preventing their uptake for a substantial proportion of the remaining CUNs for preplant soil 

use. 

1.4.4 Registration of Alternatives for Preplant Uses - Decision Ex I/4 (9i) and (9j) 

Decision Ex. I/4 (9i) requires MBTOC, “To report annually on the status of re-registration and 

review of methyl bromide uses for the applications reflected in the critical-use exemptions, including 

any information on health effects and environmental acceptability”. Further, Decision Ex I/4 (9j) 

requires MBTOC “To report annually on the status of registration of alternatives and substitutes for 

methyl bromide, with particular emphasis on possible regulatory actions that will increase or 

decrease dependence on methyl bromide”.

Where these have impacted a nomination, the party or MBTOC may have adjusted quantities to allow 

for effective use of the alternative. A description of any changes has been made available in the CUN 

text boxes (Tables 1.9 and 1.11).

Any future nominations submitted by Australia, Canada and the US should include information on 

expected rates of adoption of alternatives following registration, in accordance with paragraphs 34-35 

of Annex 1 of the MOP16, as this information would assist MBTOC in its evaluation of these CUNs. 

1.4.5. Decision XXV/4

In response to Decision XXV/4 from the 25th MOP, MBTOC notes that all of the non-A5 

nominations contained a discussion of national, subnational or local regulations impacting the 

potential use of alternatives to MB. In addition, both Non-A5 and A5 nominations contained 

information on the status of the registration of alternatives and substitutes for MB. These comments 

are summarized below for each Party. 

1.4.5.1 Regulations impacting use of alternatives by country 

 Australia: Methyl iodide has been withdrawn by the registrant from Australia and is no longer 

available to the strawberry runner industry. BOC/Linde ceased funding research on 

Ethanedinitrile (EDN) for strawberry runners. Future development of EDN is uncertain. Nordiko 

is no longer pursuing registration of recaptured methyl bromide due to inconsistency of 

formulation. Meanwhile trials to generate registration data for an 80:20 mix of chloropicrin/1,3-D 

are underway. Australia has a certification program in place to assure the sanitation of strawberry 

runners. Only certain fumigants and rates are approved for use by the authorities. Three years of 

studies have not demonstrated bioiequivalency between 20g/m2of MB and standard rates of 

25g/m2, so registration of the lower rate is not proceeding. PicPlus®, while registered in Australia 

and part of an active research program, is not approved for use for certified runners at this time.

 Canada: Strawberry runners produced on Prince Edward Island are primarily exported to North 

Carolina in the USA. The runners must meet the phytosanitary requirements of Canada, the 

United States government and the North Carolina Department of Agriculture. Chloropicrin is still 

not permitted on Prince Edward Island and so is not available for use in strawberry runner 

production there. A protocol has been developed for a chloropicrin groundwater study. 
14 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Depending on the results of the study, chloropicrin may be allowed for use on PEI in the future. 

1,3-D was de-registered in Canada after December 31, 2011. Re-evaluation of MITC generators 

is ongoing. A groundwater warning statement is currently on Canadian labels, which prevents the 

use of these products on PEI.

 USA: Allyl isothiocyanate (AITC) is registered as a preplant soil fumigant for several crops in the 

US in September, 2013.The registrant has expressed interest in registering AITC products in 

California, but has yet to submit an application. In accordance with California Department of 

Pesticide Regulation (CDPR) policy, a full risk assessment will be conducted prior to the 

registration of any new fumigants in California. CDPR has announced that there will no longer be 

exceptions to the 90,250 lb. township cap for 1,3-D products in high use strawberry townships, 

until the completion of an on-going risk assessment of 1,3-D, at which time a decision will be 

made whether to further limit or expand 1,3-D use in California.

 China: The only registered alternative to MB for ginger in China is chloropicrin and there are no 

mixtures of fumigants with chloropicrin registered, including MB.

 Argentina: Chloropicrin is not registered as a stand-alone product in Argentina, but combinations 

of 1,3-D/pic products are registered. Dazomet is not registered for edible crops.

 Mexico: Chloropicrin alone, 1,3-D/Chloropicrin mixtures, metham sodium and dazomet are 

registered in Mexico. Dimethyl disulfide (DMDS) is not registered in Mexico at this time.

1.4.5.2 Health effects of MB use and environmental acceptability

Over the past two decades numerous studies have characterized the health hazards resulting from 

exposure to methyl bromide. Its acute and chronic toxicities are very high and in many countries it is 

classified as “toxicity class I”. It is known as a developmental, neurologic and respiratory toxin 

(Gemill et al., 2013, de Souza et al., 2013, Bulathsinghala et al., 2014). Other known target organs are 

the heart, adrenal glands, liver, kidneys and testis (Gemill et al., 2013). 

Accidental exposure to high concentrations of MB has been reported in many instances including 

fumigation of museums in Japan (Yamano and Nakadate, 2006), when handling the fumigant in a 

manufacturing facility in India (de Souza et al., 2013) and when opening imported freight containers 

(Baur et al., 2010). 

Recent research findings suggest links between exposure to MB and health problems, including 

increased risk of developing prostate cancer, derived from occupational and community exposure 

(Budnik et al., 2012, Alavanja et al., 2013, Cockburn et al., 2011). In another study (Gemill et al., 

2013), a correlation was found between impaired foetal growth during the third trimester and 

exposure to methyl bromide in residential areas

Risk of exposure is especially high when small disposable canisters (i.e. 500 to 750g) are used for MB 

fumigation for pre plant soil under plastic sheets (Yamano et al., 2001). Canister applications have 

been eliminated for soil use in all non-Article 5 and in many A5 countries as this application is 

considered to be less efficient than other methods for the control of soil borne pathogens. Besides, this 

treatment is considered to be more dangerous to workers than injection methods, because trained 

contractors are not generally involved in MB application. This practice is not considered as effective 

for pathogens’ control as use of MB/Pic mixtures and also can lead to high emissions of methyl 

bromide as the gas is released immediately beneath the plastic sheets. MBTOC notes with concern 

that canister use is still allowed for preplant use and quarantine uses in a number of A5 countries e.g. 

China, Egypt Jordan, Mexico.

The environmental acceptability of methyl bromide is handled by national regulatory authorities in 

each country
MBTOC 2014 CUNs: Interim Recommendations – May 2014 15

1.4.6 Sustainable Alternatives for Preplant Uses

MBTOC urges Parties to consider the long term sustainability of treatments adopted as alternatives to 

MB. The combination of chemical and non-chemical alternatives in an IPM program provides 

excellent results in the longer term. Decision IX/6 1(a)(ii) refers to alternatives that are ‘acceptable 

from the standpoint of environment and health’. MBTOC has visited various regions where successful 

non-chemical alternatives e.g. soil less culture, grafting, solarisation, steam, biodisinfestation and 

anaerobic soil disinfestation, are used as sustainable alternatives to MB. Several Parties consider these 

techniques as viable alternatives, particularly when an integrated approach that combines different 

options is adopted. 

MBTOC recognizes the potential benefit of the recent establishment of a California DPR “Strawberry 

Non Fumigant Workgroup” to evaluate and adopt further chemical and non-chemical technologies 

such as: anaerobic soil disinfestation; soilless substrate systems and steam (CalDPR, 2013).

1.4.7 Standard Presumptions Used in Assessment of Nominated Quantities.

The tables below (Tables 1-6 and 1-7) provide the standard presumptions applied by MBTOC for this 

round of CUNs for preplant soil uses. These standard presumptions were first proposed in the 

MBTOC report of October 2005 and were presented to the Parties at 17th MOP. Studies and reports to 

support them have been provided in previous reports and were revised for some sectors after 

consideration by the Parties at the 19th MOP. The rates and practices adopted by MBTOC as standard 

presumptions are based on maximum rates considered acceptable by published literature and actual 

commercial practice. 

As in the evaluations in previous years, MBTOC considered reductions to quantities of MB in 

particular nominations to a standard rate per treated area where technical evidence supported its use. 

As a special case, MBTOC continues to accept a maximum rate of 200 kg/ ha (20 g/m2) in MB/Pic 

formulations with high Pic-containing mixtures with or without barrier films for certified nursery 

production, unless regulations prescribe lower or higher rates. However, MBTOC notes that studies 

have shown that rates of 200 kg/ha (20g/m2) or less of MB: Pic 50:50 are effective with barrier films 

for production of ‘certified’ nursery material and urge Parties to consider regulations which permit 

these lower rates. MBTOC also notes that certified runner production may involve regulations which 

specify the mandatory use of a fumigant such as MB or an alternative, in order for the runners to be 

“certified runners”.

The indicative rates used by MBTOC were maximum guideline rates, for the purpose of calculation 

only. MBTOC recognises that the actual rate appropriate for a specific use may vary with local 

circumstances, soil conditions and the target pest situation. Some nominations were based on rates 

lower than these indicative rates.
16 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Table 1-6. Standard Presumptions Used in Assessment of CUNs for Preplant Soil Use of MB 

Comment CUN adjustment Exceptions

1. Dosage rates Maximum guideline rates for 

MB:Pic 98:2 are 25 to 35 g/m2 with 

barrier films (VIF or equivalent); for 

mixtures of MB/Pic are 12.5 to 17.5 

g MB/m2for pathogens and 

nutsedge respectively, under barrier 

films depending on the sector. All 

rates are on a ‘per treated hectare’ 

basis.

Amount adjusted to maximum 

guideline rates. Maximum rates 

set dependent on formulation and 

soil type and film availability. 

Higher rates accepted if 

specified under national 

legislation or where the 

Party had justified 

otherwise.

2. Barrier films All treatments to be carried out 

under low permeability barrier film 

(e.g. VIF, TIF)

Nomination reduced 

proportionately to conform to 

barrier film use. 

Where barrier film 

prohibited or restricted by 

legislative or regulatory 

reasons

3. MB/Pic 

Formulation: 

Pathogens 

control

Unless otherwise specified, MB/Pic 

50:50 (or similar) was considered to 

be the standard effective formulation 

for pathogen control, as a 

transitional strategy to replace 

MB/Pic 98:2. 

Nominated amount adjusted for 

use with MB/Pic 50:50 (or 

similar).

Where MB/Pic 50:50 is not 

registered, or Pic (Pic) is not 

registered

4. MB/Pic 

Formulation: 

Weeds/nutsedge 

ass control

Unless otherwise specified, MB/Pic 

67:33 (or similar) was used as the 

standard effective formulation for 

control of resistant (tolerant) weeds, 

as a transitional strategy to replace 

MB/Pic 98:2.

Nominated amount adjusted for 

use with MB/Pic 67:33 (or 

similar).

Where Pic or Pic-containing 

mixtures are not registered

5. Strip vs. 

Broadacre

Fumigation with MB and mixtures 

to be carried out under strip 

Where rates were shown in broad 

acre hectares, the CUN was 

adjusted to the MB rate relative to 

strip treatment (i.e. treated area). 

If not specified, the area under 

strip treatment was considered to 

represent 67% of the total area. 

Where strip treatment 

was not feasible e.g. 

some protected 

cultivation, emission 

regulations on MB, or 

open field production 

of high health 

propagative material 

Table 1-7. Maximum dosage rates for preplant soil use of MB by sector used since 2009 (standard 

presumptions).

Film Type

Maximum MB Dosage Rate (g/m2) in MB/Pic mixtures (67:33, 50:50) 

considered effective for:

Strawberries and 

Vegetables

Plant 

Nurseries*

Orchard Replant Ornamentals

Barrier films -

Pathogens

12.5 15 15 15

Barrier films –

Nutsedge

15.0 17.5 17.5 17.5

No Barrier films 

– Pathogens

20 20 20 20

No Barrier films

- Nut sedge

26 26 26 26

* Maximum rate unless certification specifies otherwise
MBTOC 2014 CUNs: Interim Recommendations – May 2014 17

1.4.8 Adjustments for Standard Dosage Rates using MB/Pic Formulations

As in previous assessments, one key transitional strategy to reduce MB dosage has been the adoption 

of MB/Pic formulations with lower concentrations of MB (e.g. MB/Pic 50:50, 33:67 or less). These 

formulations are considered to be equally as effective in controlling soilborne pathogens as 

formulations containing higher quantities of MB (e.g. 98:2, 67:33) (Porter et al., 2006; Santos et al., 

2007; Hamill et al., 2004; Hanson et al., 2006). MBTOC notes that reported use of MB/Pic 

formulations in the US shows that formulations with greater amounts of MB (CalDPR, 2012a) are still 

being used in California and the Party is urged to consider even lower dosage rates of MB for the 

remaining CUN. This includes rates as low as 75 kg/ha (7.5 g/m2) with mixtures of 30:70 or 33:67 

mixtures (at 250 kg/ha or 25 g/m2) or 100 kg/ha (10 g/m2) of MB in 250 kg/ha (25 g/m2) of 50:50 

MB/Pic mixtures in conjunction with barrier films (Table 1-8).

Table 1-8. Actual dosage rates applied during preplant fumigation when different rates and 

formulations of MB/Pic mixtures are applied with and without barrier films. Rates of 

application reflect standard commercial applications rates.

Commercial application rates 

(kg/ha) of MB/Pic 

formulation

MB/Pic formulation (dose of MB in g/m2)

98:2 67:33 50:50 30:70

A. With Standard Polyethylene Films 

400 39.2 26.8 20.0 12.0

350 34.3 23.5 17.5 10.5

300 29.4 20.1 15.0 9.0

B. With Low Permeability Barrier Films (LPBF)

250 24.5 16.8 12.5 7.5

200 19.6 13.4 10.0* 6.0

175 17.2 11.8 8.8 5.3

* Note: Trials from 1996 to 2008 (previous CUN reports) show that a dosage of 10g/m2 (e.g. MB/Pic 50:50 at 

200kg/ha with low permeability barrier Films) is technically feasible for many situations and equivalent to the 

standard dosage of >20g/m2 using standard PE films 

1.4.9 Use/Emission Reduction Technologies - Low permeability barrier films and dosage 

reduction

Decision XXI/11 (para 9) requested further reporting on Decision IX/6 to ensure Parties adopted 

emissions controls where possible. For preplant soil use, this includes the use of barrier films or other 

mitigation strategies such as high moisture sealing and the lowest effective dose of MB with mixtures 

of chloropicrin. Other methods include deep shanking and use of ammonium thiosulphate and 

different irrigation technologies (Yates et al., 2009). These latter technologies have not been reported 

or adopted widely by Parties.

In southeast USA the reported use of barrier films in vegetable crops, which expanded rapidly to over 

20,000 hectares in 2009 has continued to increase. A recent change in the regulations – presently 

allowing use of VIF in California - should lead to an increase in the adoption of barrier films in that 

State. MBTOC notes that barrier films particularly more recently developed totally impermeable 

(TIF) films can be used with alternatives and this is consistently improving the performance of 

alternatives at lower dosage rates (Driver et al. 2011; Fennimore and Ajwa, 2011)]. Effectiveness at 

lower dosages can allow for greater areas to be treated with 1,3-D under township cap regulations. 
18 MBTOC 2014 CUNs: Interim Recommendations – May 2014

As of December 1, 2012, EPA issued new set of soil fumigant product label changes, implementing 

important new protections for workers and bystanders. In the frame of these changes, the State of 

California now allows the use of VIF films for fumigation with MB, which were formerly prohibited 

(Cal DPR, 2012b & c; EPA, 2013). MBTOC is at this time unclear on the impact this change could 

have in terms of potential reduction of dose rates of MB and emission control. Studies continue to 

show the advantages of barrier films and other technologies for reducing emissions and improving 

efficacy of alternatives as well as MB (Quin et al. 2013; Chellemi et al. 2013).
MBTOC 2014 CUNs: Interim Recommendations – May 2014 19

Table 1-9. Interim evaluation of CUNs from non A5 Parties for preplant soil use submitted in 2014 for 2016

Country Industry CUE for 

20051

CUE for

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

2014 10

CUE for 

201511

CUN for 

2016

MBTOC 

interim 

rec for 

2016 

Australia Strawberry 

runners

35.750 37.500 35.750 35.750 29.790 29.790 29.790 29.760 29.760 29.760 29.760 29.760 [29.760]

MBTOC interim recommendation for 2016:

MBTOC recommends 29.760 tonnes for MB use in this sector in 2016. This is on the understanding that funding for research has been restored and efforts to find alternatives 

continue. MBTOC notes that mixtures of existing fumigants, and new formulations of fumigants with PIC (i.e.TF80 and TF60), are being trialled, and if effective, expect these to be 

adopted and registered. 

Nomination by the Party for 2016:

The quantity requested for this CUN is 29.760 tonnes, an amount that has remained unchanged for this industry since 2009. 

Circumstances of the nomination by the Party:

The Party states that the key pests affecting strawberry runner production are fungi (Phytophthora, Pythium, Rhizoctonia and Verticillium spp.) and weeds (S. arvensis, 

Agrostistenuis sp, Raphanus spp., Poa annua, Cyperus spp). The nomination is based on a particular soil and temperature situation: very high clay and organic matter content 

soils requiring fumigation treatments under cold temperatures.

In its CUN the Party argues that runner production in these kind of conditions, treated with MB:Pic (50:50 at a MB dose of 25 g/m2) is needed to meet the certification standards. 

The Victorian runner industry only produces runners in soils treated with MB:Pic, and is not using any other methods other than substrates for the foundation stock production 

stage . Some non-chemical alternatives are not feasible. Plant resistance is unreliable as an alternative to MB:Pic for delivering certified runners (Fang et al. 2012). Integrated soil 

disinfestation with combinations of existing, registered fumigants is now considered the most likely and quickest approach for delivering a viable alternative to MB for the runner 

industry.

Although MB rates used exceeds MBTOC’s standard presumption of 20 g/m2, the lower rate is still unregistered in Australia. According to the Party, three years of trials with lower 

MB rates do not support bioequivalency of these rates.

The Party insists that soil-less systems are not yet technically and economically feasible for adoption into generations beyond the foundation stock.

A significant change since the last nomination is the fact that in December 2013, the federal government agency, Horticulture Australia Limited, confirmed co-funding for a new 3-

year research program into MB alternatives for strawberry runners.

MBTOC interim assessment for MB use in this sector in 2016:

MBTOC acknowledges that the Party has provided an economic analysis supporting their assertion that the expansion of the use of soilless substrates beyond the foundation 

stock is not economically feasible. 
20 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Country Industry CUE for 

20051

CUE for

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

2014 10

CUE for 

201511

CUN for 

2016

MBTOC 

interim 

rec for 

2016 

The nomination indicates that funding for the R&D program has been confirmed in 2013, so the Party is back in accordance with Decision IX/6 (b) (i) and (iii). MBTOC notes that 

the Party is required to report the available results of its research programme to the Technology and Economic Assessment Panel for its consideration to the 36th OEWG as per 

Decision XXV/4. While MBTOC once more recognizes the Party’s past efforts in research and development of MB alternatives (Mattner, 2012), these efforts have not resulted in 

significant commercial uptake of alternatives. Furthermore, there have been essentially no significant reductions made for this production region since 2005 and no reduction in 

use rate as this is regulated by certification rules. 

MBTOC is aware that soilless production is technically suitable for at least some part of the nomination, as it is in other parts of the world i.e. Belgium (Robe 1997, 1998), Poland 

(Trader et al. 2007), France (Hennion et al. 1997) and A5 countries e.g. Brazil (Janisch et al. 2012, Oliveira et al. 2010), Uruguay (Giménez et al. 2008), and Paraguay 

(Nacimiento and Lopez- Medina, 2009). The nomination ratifies that industry does not consider further expansion of soil-less systems for the production of mother and certified 

runners as it is considered economically infeasible and reports technical problems on the foundation generation. 

MBTOC still considers that soil-less culture is a technique used widely throughout the world for production of strawberry runners and is technically and economically suitable for 

some of the certified nursery production system as well as stock plants resulting in healthy nursery material (López-Galarza et al., 2010, Rodríguez-Delfín, 2012).

MBTOC notes that after more than eleven years there is no action plan to phase out MB for this sector. 

MBTOC comments on economics in 2014 for 2016:

 A comprehensive economic analysis shows that while foundation stock can be done in a soil-less system, Mother and Certified stock cannot. The selling prices of Mother and 

Certified stock would have to increase almost 7 fold (from A$0.34 per runner to A$2.03 and A$2.00 per runner respectively to break even.

 Both operating and capital costs are about five times higher with a soilless system than open field production.

 The main reason is the capital cost of setting up the soilless system and a yield loss of around 18%. Prices are assumed to stay the same for the two procedures.

 These differences do not include the compliance costs with municipal regulations, or the costs of waste treatment, but note that the costs of use of methyl bromide do not 

include the real cost of damage to the ozone layer.

 Soilless systems are more labour intensive, and labour costs in Australia are very high. With MB/Pic pre-plant soil treatment harvesting is done by machine, while with a 

soilless system it will be done by hand. The additional labour cost is already included in the operating costs and is a large reason for the difference in operating costs.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission Reduction: No, but the Party states that standard films perform the same as VIF for the reduction of emissions in the cold temperatures and 

heavy wet soils typical for strawberry runner production in Victoria. Party also states that use of VIF did not improve the efficacy of reduced rates of MB to an 

acceptable level for the strawberry runner industry.

 Dec. IX/6 b(iii) Research Program: An approved and funded research program is currently in place at the time of this nomination. 

 Dec. IX/6 b(iii) Appropriate Effort: Research effort is adequate - funded research program currently in place at the time of this nomination
MBTOC 2014 CUNs: Interim Recommendations – May 2014 21

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410 

CUE for 

201511

CUN for 

2016

CUE for 

2016

Canada Strawberry 

runners 

(PEI)

6.840 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.261 5.261 5.261 5.261 [5.261]

MBTOC interim recommendation for 2016:

MBTOC recommends the nominated amount of 5.261 tonnes for use in this sector in 2016. MBTOC notes that the Party in its response to questions noted that it intends that 2016 

is the final year for use of methyl bromide for strawberry runner production in Prince Edward Island, although this might depend on the outcomes of the Pic 100 groundwater study.

Nomination by the Party for 2016:

The Party has nominated 5.261 t of MB, which was similar to the CUE granted for 2015 and the previous year’s CUEs since 2011. It is for use for multiplication on runners on 

26.3ha of land, which includes the two final stages of multiplication of plants exported from PEI. The nomination is based on a reduced rate of MB of 20 g/m2 under high barrier 

films for the entire fumigated area (26.3 ha) which is consistent with MBTOC’s standard presumptions. 

Circumstances of the nomination by the Party:

The Party has attempted to replace MB with 1,3-D in the past, but it was banned for use in Prince Edward Island in January 2003 due to ground water contamination. Chloropicrin 

(PIC 100) is registered, but the PEI authorities have denied a permit for its use until further groundwater testing has been conducted. Long awaited studies on potential 

groundwater contamination of Pic 100 have finally been commenced in December 2013 and are anticipated to continue for two years. The Party is however required to report 

preliminary results to the 36th OEWG as per Decision XXV/4. The company at PEI has tested organic production from 2006 - 2009 with different varieties, but found that significant 

reductions in yield resulted, ranging from 40% to 70%. Only one variety using the organic production system compared favourably to conventional production. MB:Pic 67:33 at 

500 kg/ha is the only formulation and rate registered for use in strawberry runners in PEI, and although this exceeds MBTOC’s standard presumption of 200 kg/ha, the grower 

petitioned PMRA to use a lower rate under barrier films. PMRA, in the absence of a formal label amendment, granted permission to use a lower rate, but at the grower’s own risk 

and liability. The CUN for 2016 is based entirely on a reduced rate for MB of 200 kg/ha for the entire critical area (26.3 ha).

The Party noted that at this time greatest effort is concentrated on the groundwater study with chloropicrin, as it is currently considered the most feasible alternative for the grower. 

The Party has also sought advice on soilless systems to reduce dependency on chemical fumigants. 

MBTOC interim assessment for MB use in this sector in 2016:

After thorough review of the information provided by the Party, MBTOC now understands that the use of micro-propagated plants from USA and the scale up into soilless 

substrates for the first stage of multiplication of runners at PEI to produce approximately 60,000 runners have replaced or avoided the use of methyl bromide in stages for which 

MBTOC believes there are effective alternatives. The nomination is requesting MB for the final two multiplication stages. Canada considers the first stage of this field production 

and multiplication as foundation stock, however this is different nomenclature to other countries and this has caused some confusion in past years. Whilst soilless production is 

technically feasible for the later stages of production, MBTOC agrees from the information on economics that the use of soilless culture for the remaining runners is uneconomical 

and impractical. For this reason MBTOC agrees with the Party that the focus should be to find suitable alternatives for soil disinfestation and urges the Party to complete the 

groundwater studies to adopt chloropicrin either alone or in combination with other alternatives as soon as possible. MBTOC notes that metam sodium, metam potassium and 
22 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410 

CUE for 

201511

CUN for 

2016

CUE for 

2016

dazomet are also registered in Canada and could be considered for use in PEI under permit. MBTOC suggests that future programs for runners at PEI consider these alternatives 

as it is unclear from the nomination whether these products are being considered as replacements to MB at PEI. MBTOC requested a copy of the review conducted by Canada on 

soilless production systems, but this has not been provided. This is important, particularly as soilless systems are evolving rapidly and future systems may be more economical. 

MBTOC also notes that MB formulations containing Pic (67:33) are used in PEI under permit without groundwater contamination apparently occurring and suggests a similar 

situation should be possible for Pic alone, which is not currently permitted.

MBTOC comments on economics in 2014 for 2016:

While the CUN is submitted on technical grounds, an economic argument is provided in response to MBTOC ́s recommendation of a 50% transition to soilless culture as 

a technically feasible alternative. Such a transition would imply high capital costs, but at a very small reduction (8%) in the required amount of MB. Production cost under 

the current practice is $0.135 per second generation plants. Total cost under a soilless system is $0.425 per second generation plant. Revenues stay the same as the 

price is the same (no improvement in quality is expected) and yields are not assumed to decline (unlike the Australian case). While MBTOC has recommended a cheaper 

soilless system, the party finds that the Australian alternative recommended by MBTOC is three times more expensive than the Haygrove system analysed in the CUN 

and therefore is still uneconomic.

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission Reduction: Yes, uses barrier films with a reduced application rate of MB conforming to MBTOC’s presumptions

 Dec. IX/6 b(iii) Research Program: A research program is proposed based on groundwater studies for Pic, a review has been conducted on the evaluation of soilless 

methods to improve feasibility and consideration of improvements in the production processes.

 Dec. IX/6 b(iii) Appropriate Effort: The Party has demonstrated now that it is engaged in an active research program and is implementing groundwater studies. The 

party has also engaged a consultant to assist with full evaluation of any potential alternatives to MB.
MBTOC 2014 CUNs: Interim Recommendations – May 2014 23

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410 

CUE for 

201511

CUN for 

2016

CUE for 

2016

United 

States 

Strawberry 

(field)

2052.846 1730.828 1476.019 1349.575 1269.32 1007.477 812.709 678.004 461.186 415.067 373.660 231.540 [231.540]

MBTOC interim recommendation for 2016:

MBTOC recommends the nominated amount of 231.540 tonnes for use in this sector for 2016. MBTOC acknowledges that the Party reduced the nomination by 38% from the 

amount approved for 2015. MBTOC also acknowledges the Party ́s statements, which align with Decision XXV/4, that this will be the final nomination for this sector in order to 

complete its intended transition from critical uses for methyl bromide by the end of 2016. 

Nomination by the Party for 2016:

The Party nominated 231.540 t of MB for use in 2016 on 1,362 ha at a dosage rate of 170 kg/ha. The Party indicated that the proportion of total crop area to be treated with MB 

was 9.0%. 

Circumstances of the nomination by the Party:

The CUN requests MB specifically for areas: 1) where a transition period is needed for the use of broadcast 100% chloropicrin in fields with high pest pressure, in particular, with 

Macrophomina and Fusarium and 2) where 1,3-dichloropropene (1,3-D) is limited by township caps. 

MBTOC interim assessment for MB use in this sector in 2016:

MBTOC agrees with the Party that alternatives are available for this nomination and respectfully acknowledges the Party has stated that this is the final year for transition. MBTOC 

endorses that alternatives are available for 100% of the nomination and notes that a recent meta-analysis in this sector supports this and previous findings (Belova et al., 2013, 

Porter et al., 2006). MBTOC also acknowledges the industries push to find more sustainable non chemical alternatives as reported recently by Fennimore et al., 2013. Key 

chemical alternatives include shank applied 1,3-D/Pic as well as other similar Pic mixtures, Pic alone or Pic in sequential application with MITC generators (KPam, Vapam, 

Dazomet) coupled with disease tolerant varieties of strawberries would be suitable to address a significant proportion of one or more of the 3 issues raised by the Party as a 

reason for the nomination (Belova et al., 2013, Medina-Minguez 2012, Noling and Cody 2011, Porter et al., 2006, Zveibel et al., 2012). MBTOC also notes that formulations with 

chloropicrin are the key chemical alternative effectively adopted in other regions of the world. MBTOC notes that the Party has accepted that the technical expertise required for 

application of 100% chloropicrin already exists in California and uptake of this method will be feasible by the end of 2016. 

MBTOC also notes that as of December 1, 2012, a new set of label changes went into effect for soil fumigant products, fully implementing important new protection for workers

and bystanders. In light of these changes, the State of California now allows the use of barrier films (VIF and TIF) for MB fumigation, which was formerly prohibited (Cal DPR, 

2012b & c; EPA, 2013). Studies continue to show the advantages of barrier films and other technologies for reducing emissions and improving efficacy of alternatives as well as 

MB (Qin et al., 2013; Chellemi et al., 2013; Luo et al., 2013) and anticipate that the Party will continue to consider their adoption where feasible for this sector, either with the 

remaining MB use or with alternatives to minimise the environmental and health effects of their use as required in Decision XXV/4. 
24 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Country Industry CUE for 

20051

CUE for 

20062

CUE for 

20073

CUE for 

20084

CUE for 

20095

CUE for 

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE for 

201410 

CUE for 

201511

CUN for 

2016

CUE for 

2016

MBTOC comments on economics in 2013 for 2015:

 The CUN is based on the need for a transition period to move to 100% chloropicrin and regulatory (township cap) issues. 

 Economic data are provided and show that steam and chloropicrin b0oth result in net revenues that are slightly higher than that of methyl bromide application

 Total phase-out is planned for the 2017 season

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission Reduction: In California (high barrier) films are now allowed for use with MB and with alternatives and although they appear not to be used with MB, 

rates are below MBTOC’s standard presumptions. Further emission reduction may be possible with their adoption for any remaining uses of MB. 

 Dec. IX/6 b(ii) Research Program: Yes, there is an ongoing research program, but specific data justifying CUN requests need to be provided.

 Dec. IX/6 b(iii) Appropriate Effort: California has extensive research programs being conducted and continual regulatory reviews on the use of MB and other fumigant 

alternatives in the State. MBTOC is unaware from the CUN application what efforts are being made to register some alternatives registered and being used in other areas of 

the USA (eg. Pic-Clor 60 and 80, DMDS in combination with Pic).

1

1ExMOP and 16MOP; 216MOP+2ExMOP+17MOP; 3MOP17+MOP18; 4MOP18+MOP19; 5MOP19+MOP20; 6MOP20+MOP21; 7MOP21+MOP22; 8MOP22, 9MOP23, 10MOP24,11MOP25
MBTOC 2014 CUNs: Interim Recommendations – May 2014 25

Table 1-10 Interim evaluation of CUNs from A5 Parties for preplant soil use submitted in 2014 for 2015.

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

Argentina Tomato and

Pepper

145 [0]

MBTOC interim recommendation for 2015:

MBTOC does not recommend this nomination for 2015. 

Nomination by the Party for 2015:

MBTOC does not recommend 145 tonnes of methyl bromide nominated by Argentina for critical uses for tomato and pepper production in protected cultivation in the critical 

regions of Mar del Plata and La Plata. MBTOC requested disaggregation of this CUN (separate nominations for tomatoes and peppers) but the Party explained that this is not 

possible as these two crops are grown simultaneously or sequentially on the same land and fumigation applies to both. The key pests are nematodes, fungi (Rhizoctonia, 

Sclerotinia, Phytophthora spp.), and weeds (Cynodon and Cyperus spp.). Rates of MB vary between 350 kg/ha to 500 kg/ha and MB/Pic70:30 formulations are used. 

Circumstances of the nomination by the Party:

The Party states that 1,3-D/Pic does not provide sufficient control of key pests in the critical areas, mainly due to soil types, which are heavy clay soils and soil temperatures (5 to 

23C). Chloropicrin is not registered alone and does not control weeds. Metam sodium shows erratic and insufficient performance for weed and disease control most possibly also 

due to soil type and weather conditions. Dazomet is not registered for edible crops and does not control nematodes. Steam boilers are not commercially available and are costly. 

Steam was trialled as an alternative through the MLF funded projects and found to be efficient but economically infeasible.

MBTOC interim assessment for MB use in this sector in 2015: 

The Party has not provided substantiation to support its claim that 1,3-D/Pic or other alternatives (ie metam sodium) are not effective under the particular circumstances of the 

nomination. 1,3-D/Pic is reported as a successful alternative in some regions of Argentina (Agüero y Borquez 2007; Adlercreutz, E.G.A. y A. Szczesny, 2010), however no 

evidence of its lack of efficacy in the critical areas relating to the nomination was provided. MBTOC was unable to recommend without this information. Trials and results showing 

that non-chemical alternatives are not technically or economically feasible have also not been provided. MB also notes that the dose rate used by the Party appears to be 24.5 to 

35.0 g/m2(350 to 500 kg/ha) and this exceeds MBTOC’s standard presumptions for these crops. 

MBTOC notes that the Party has been supported by the MLF with 2 demonstration and 4 technical assistance projects since 1997 and that many alternatives have been trialled 

(MLF, 2014a). The funding received from the MLF also supported two investment projects (one consisting of six tranches), which committed the Party to phase out its whole MB 

consumption for controlled uses by the end of 2014 (MLF 2014 ab).

Different types of alternatives have been adopted to replace MB in tomatoes and peppers in many developed and developing countries around the world, in different climates and 

soil types. For example, grafting tomatoes and peppers onto resistant rootstocks is effective and in use in many A5 countries such as China, Egypt, Lebanon, Mexico, Morocco, 

Romania, Tunisia and Turkey (MBTOC, 2011). The Party acknowledges that grafting is a promising alternative and has conducted preliminary trials with excellent results, when 

combining grafted plants and biofumigation (Garbi et al. 2013). 1,3-D/Pic is reported to provide excellent results and has been adopted as a key alternative in many countries 

(MBTOC, 2011). The performance of metam sodium has been shown to be enhanced when applied with a spading machine (Slusarski et al., 2012) 
26 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

MBTOC comments on economics in 2014 for 2015:

The CUN assumes a substantial yield reduction in both tomatoes and peppers while prices and costs remain the same for both treatments (MB and the alternative) for both crops. 

Revenue reduction of 28% results from the use of alternatives. The reduction in revenue is partly due to a smaller drop in yield on the early crop, but mostly due to the 

impossibility of a late crop because of the waiting time between applications and planting.

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission Reduction: Low impermeable films are not adopted but have been trialled through the projects

 Dec. IX/6 b(iii) MLF Assistance/Adoption of Effective Alternatives: Trials and research have been conducted through the MLF projects implemented in Argentina and also 

directly by INTA (Argentinean Institute of Agriculture) and various universities. No reference related to the research in Argentina was provided with the nomination.

Dec. IX/6 b(iii) Appropriate Effort: MBTOC assumed considerable research has been conducted during the MLF funded projects but was unable to assess the research effort 

as no references or reports were provided of local R and D.

Argentina Strawberry 

Fruit 

100 [0]

MBTOC interim recommendation for 2015:

MBTOC does not recommend this nomination.

Nomination by the Party for 2015:

The Party nominated 110 tonnes of methyl bromide for a critical use for strawberry fruit on 1,000 ha, which represents a MB rate of 110 Kg/ha. This rate is lower that the reported 

used rates (350-500 Kg/ha) in three key production regions, (Lules, Mar del Plata, Buenos Aires). The key pests are fungi (Phytophthora, Verticillium, Fusarium), and weeds 

(Cyperus). MB rates vary between 350 kg/ha to 500 kg/ha and a 70/30 formulation is used. 

Circumstances of the nomination by the Party:

The Party states that 1,3-D/Pic does not control the entire pest spectrum and that metam sodium provides erratic results. According to the Party, challenges to the adoption of 

alternatives are mainly related to low soil temperatures and heavy rainfall at the time when fumigation needs to be performed. Chloropicrin alone is not registered and does not 

control weeds. Dazomet is not registered for edible crops. Steam was evaluated as an alternative through various projects and was found to be technically effective but unsuitable 

for large, open field areas and economically infeasible. 

MBTOC interim assessment for MB use in this sector in 2015:

MBTOC requested clarification from the Party on soil temperatures and these were provided. In the absence of further information from the Party, the range of temperatures 

provided, 6-23o C, are not considered by MBTOC low enough to impact performance of fumigants such as 1,3-D/Pic. Further, the Party has not provided any additional information 

to substantiate that 1,3-D/Pic or other alternatives (ie metham sodium) are ineffective under the particular circumstances of the nominated areas. MBTOC was unable to 
MBTOC 2014 CUNs: Interim Recommendations – May 2014 27

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

recommend without this information. 1,3-D/Pic is reported as a successful alternative for strawberry in other regions of Argentina (Del Huerto-Sordo, 2013). No evidence of lack of 

effectiveness in the critical areas related to the nomination was provided, however MBTOC found references indicating positive results with alternatives such as metam 

ammonium, 1,3-D/Pic, metam sodium and metam potassium in the critical regions (Jaldo et al.,2007; INTA, 2008; 2007; Bórquez et al., 2007; Aguero and Bórquez, 2007; Bórquez 

y Mollinedo, 2009, 2010; Adlercreutz and Szczesny, 2008, 2010). Trials with soil-less culture in the same sector have shown encouraging results in Tucuman (Villagra et al., 

2012). MBTOC is unclear why these results have not been transferred to the regions nominated. MBTOC notes that the Party has been supported by the MLF with 2 

demonstration and 4 technical assistance projects since 1999 and that many alternatives have been trialled (MLF, 2014a). The funding received from the MLF also supported two 

investment projects (one consisting of six tranches), which committed the Party to phase out its whole MB consumption for controlled uses by the end of 2014 (MLF, 2014b).

MBTOC comments on economics in 2014 for 2015:

For the Mar del Plata region:

 Assumes a yield reduction from 93 to 62 t/ha using 1.3-D + Pic because of heavy clay soils and low soil temperatures.

 From the yield reduction calculates a decline in gross revenue of one third as prices are assumed to be the same for the two treatments. 

 Argues that operating costs for the two treatments are similar, but these are not shown. However, the CUN then contradicts and argues that weed control costs of 1.3-D Pic 

would be greater than for methyl bromide, as will conversion to a one year production system. In this case yields are still assumed to be lower (15-20%) and the costs of 

fumigants, tarps and transplants will be higher. However, these costs are not given.

For the Lules region:

 Provides data on the movement in prices from the early harvest to late harvest. Prices start at $6/kg and end at <$1. 

 Argues that weed control is insufficient with 1.3-D Pic, that the planting time is short because of soil temperature and rainy conditions and prolonged plant back time. As a 

result, the strawberries miss the market window and are sold at the high-season price rather than the early-season price. 

 In this case, yield is expected to increase with 1.3-D Pic, but despite this, the fall in prices results in a loss in revenue of around 50%.

 The “with methyl bromide” price is taken as $1.69/kg and the “with 1.3-D Pic” as $0.72/kg.

 Again, costs of production are expected to be similar for the two treatments, in this case without the caveats.

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission Reduction: Low impermeable films are available and have been trialled through the projects but are not yet adopted. A reference to lack of 

registration of TIF is made

 Dec. IX/6 b(iii) MLF Assistance/Adoption of Effective Alternatives: Trials and research have been conducted through the MLF projects implemented in Argentina and also 

directly by INTA (Argentinean Institute of Agriculture) and various universities. No reference related to the research conducted in Argentina was provided with the nomination.

 Dec. IX/6 b(iii) Appropriate Effort: MBTOC assumed considerable research has been conducted during the MLF funded projects but was unable to assess the research 

effort as no references or reports were provided by the Party of local R and D.
28 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

China Ginger Open 90 90

MBTOC recommendation for 2015:

MBTOC recommends the requested amount of 90 tonnes of MB for this use in 2015. 

Nomination by the Party for 2015:

China nominated 90 tonnes of methyl bromide for critical uses for open air ginger production on 229.59 ha at the rate of 40g/m

2

for use in 2015 .The target pests are, Ralstonia 

solanacearum, Pythium spp. Meloidogyne spp and Cyperus rotundus. MB is used in regions where soil-borne pathogen pressure is high and this only represents a small 

percentage (0.29%) of the total ginger area. The request is only for ginger grown in the Shandong region where ginger is grown continuously and where pressure from the target 

pests is high. 

Circumstances of the nomination by the Party:

China is using small disposable canisters of MB (681 g/canister), using standard polyethylene films. MB is applied in canisters (98:2), as cold gas at a rate of 400 kg/ha, which is 

below the rate registered in China. According to the Party, chloropicrin is the only chemical alternative registered in China for this sector. Chloropicrin did not provide effective 

control of Meloidogyne spp and Cyperus rotundus. In addition, chloropicrin causes phytotoxicity and needs longer fumigation time obliging farmers to postpone the planting time 

which affects yield, quality and marketing. However a recent study confirms that chloropicrin is a promising alternative with good efficacy against Ralstonia solanacearum, which 

can be used successfully in integrated pest management programmes in China (Mao et al., 2014).

In spite of their proven efficacy, the other chemical alternatives, 1,3-dichloropropene, dazomet, iodomethane, metam sodium, dimethyl disulfide and sulfuryl fluoride are not 

registered for use on soilborne pathogens in this sector in China. SF however has been shown to control root-knot nematodes and to reduce the levels of key soil pathogens in 

research trials (Aocheng et al. 2014). Chloropicrin and 1,3 D have been formulated in capsules for trial work. Trials with Pic are encouraging (Mao et al., 2014). The tested 1,3-

D/Pic capsule formulation provides a promising method for soil pest and disease control and reducing environmental emissions and potential human exposure in greenhouse 

vegetable cultivation (XiaoXue et al., 2013). Telone C-35 is an excellent MB alternative and has provided acceptable weed control efficacy (XiaoXue et al., 2013), but this 

formulation is not registered.

According to the Party, non chemical alternatives (crop rotation, bio-fumigation, solarization, steaming) are not technically and economically feasible. Barrier films (VIF and TIF) 

are produced in China, but are not used for ginger production due to their high cost and low efficacy under low temperatures. MB is applied every year during early spring or late 

autumn.

MBTOC interim assessment for MB use in this sector in 2015:

MBTOC accepted the Party ́s information that alternatives are not available for this nomination, particularly as 1,3-D is unavailable for use in China. MBTOC however notes that 

other countries which applied MB using canisters on a small scale basis have phased out for this sector (eg Japan). In China the registered MB application rate varies between 

500 and 750 kg/ha (Aocheng, 2014). Although the amount requested is based on a use rate of 40g/m2(without VIF or TIF), the application is based on the use of canisters of MB 

which are less efficient than soil injection methods and thus the rate proposed is considered appropriate. This rate is higher than the rates used for ginger before in Japan , but the 

target pests in China, also include Ralstonia and nutgrass (Cyperus), which are more difficult to control. MBTOC considers that in the absence of effective alternatives MB/Pic 
MBTOC 2014 CUNs: Interim Recommendations – May 2014 29

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

50:50 can be suitable for this sector, but China would need to develop technology to formulate and apply this formulation. MBTOC considers that barrier films should be used in 

future and urges the Party to consider accessing these films. MBTOC is also aware that chloropicrin combined with dimethyldisulphide or chloropicrin with fosthiazate have shown 

promising results (Aocheng, pers. comm.).

MBTOC notes that the Party has been supported by the MLF with one demonstration project, three project preparation grants and one investment project consisting of eight 

tranches since 1994 and that many alternatives have been trialled. The funding received from the MLF was support for investment projects and committed the Party to phase out 

its whole MB consumption for controlled uses by the end of 2014 (MLF, 2014 ab).

MB canisters are used because they provide small-scale farmers with an easy application method and the ability to apply targeted amounts of MB to small areas where injection 

machinery may be difficult to use (TEAP 2008). However, they have been eliminated for soil use in many Article 5 countries as this application is considered to be less efficient for 

the control of soil-borne pathogens than injection methods. Use of canisters is also considered to be more dangerous to workers because trained contractors are not involved in its 

application. This practice also leads to high emissions of MB. 

Even though the Party did not present any management strategy, it stated that they hoped to register more alternatives for ginger by 2018 to possibly be able to phase out by 

2018. According to reports presented to the ExCom, satisfactory pest and disease control has been obtained in ginger crops with the combination of high dosages of chloropicrin, 

improved application methods of this fumigant and dazomet, and use of other chemicals and biological nematicides, in an IPM approach. PIC is used for soil fumigation in areas 

where the main ginger soil-borne pathogens Pythium spp. and Ralstonia solanacerum are main pests.

MBTOC comments on economics in 2014 for 2015:

 Ginger prices have been increasing, so more farmers wish to produce it. Chloropicrin is the only registered alternative, but requires a long fumigation period and damages the 

ginger when applied in low temperatures. Besides, it does not control root-knot nematodes. With chloropicrin, planting time must therefore be postponed, and this affects 

yields, quality and time to market, resulting in a significant loss in net revenue.

 Non-chemical alternatives include crop rotation, but land in China is scarce. Soilless systems require capital investment and trained farmers. Steam, is expensive. Other 

alternatives (soil disinfection, bio-fumigation) are technically infeasible given the particular growing conditions.

 The Party argues that the price of ginger will be lower with chloropicrin (Methyl bromide: $9.02/kg; chloropicrin: $6.89/kg) because of the root-knot nematodes impact on the 

product quality

 Yield with methyl bromide is 96.45 tonne/ha, while with chloropicrin is 86.22 tonne/ha, again because of the effect of root-knot nematodes.

 Gross revenue with chloropicrin is 44% less than that of Methyl Bromide (because of the yield and price difference)

 Net revenue is 25% of that of methyl bromide; put another way, net revenue has declined by well over two thirds.

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission Reduction: VIF and TIF are produced in China, but are not used for ginger production due to very high cost and low efficacy under low 

temperatures. MB is applied every year during early spring or late autumn. 

 Dec. IX/6 b(iii) MLF Assistance/Adoption of Effective Alternatives: Research has been conducted on chemical alternatives (chloropicrin + DMDS, chloropicrin + 

fosthiazate and chloropicrin + avermectins). It is expected that some chemicals will be registered by 2018. China is trying also to develop the flame sterilization technology.

 Dec. IX/6 b(iii) Appropriate Effort: Yes considered appropriate as experiments are being conducted to register chemical alternatives by 2018. 
30 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

China Ginger 

Protected

30 [24]

MBTOC recommendation for 2015:

MBTOC recommends a reduced amount of 24 tonnes of MB for this use in 2015. 

MBTOC considers that the same rate of 40g/m2that is used for open field production of ginger in China should be feasible for ginger production in protected cropping as the pests 

are identical. MBTOC also considers that China produces and has trialled barrier films and that these films may be available in the future to further reduced dosage rates, and 

urges the Party to consider their adoption. China’s current position is that these films do not provide an advantage in the cool soils used for ginger production in the Shandong 

region, however the barrier films do offer a means to further reduce emissions.

Nomination by the Party for 2015:

China nominated 30 tonnes of MB for Ginger production in protected cultivation (61.2 ha) at the rate of 50g/m2for use in 2015. This represents 12.24 % of the total ginger 

protected area. MB is applied annually. The target pests are similar to the open field production, i.e. Ralstonia solanacearum, Pythium spp. Meloidogyne spp and Cyperus 

rotundus. The request is only for ginger grown in the Shandong region where ginger is grown continuously and thus pressure from the target pests is high. 

Circumstances of the nomination by the Party:

China is using small disposable canisters of MB (681 g/canister) for this use, using standard polyethylene films. It is applied as a cold gas (98:2), at a rate of 500 kg/ha. In China 

the registered MB application rate for canister use varies between 500 and 750 kg/ha (Aocheng, 2014). According to the Party, chloropicrin is the only chemical alternative 

registered in China for this sector. Chloropicrin did not provide effective control of Meloidogyne spp and Cyperus rotundus,. In addition, chloropicrin causes phytotoxicity and needs 

longer fumigation time obliging farmers to postpone the planting time which affects yield, quality and marketing. However, a recent study confirms that it is a promising alternative 

with good efficacy against Ralstonia solanacearum, which can be used successfully in integrated pest management programmes in China (Mao et al., 2014)

In spite of their proven efficiency, the other chemical alternatives 1,3-dichloropropene, dazomet, iodomethane, metam sodium and dimethyl disulfide and sulfuryl fluoride are not 

registered in China. Sulfuryl fluoride can be used as a soil fumigant to control root-knot nematodes and to reduce the levels of key soil pathogens (Aocheng et al. 2014). 

Chloropicrin and 1,3 D have been formulated in capsules, with Pic providing encouraging results (Mao et al., 2014) The tested 1,3-D/CP gel cap formulation provides a promising 

method for soil pest and disease control and reducing environmental emissions and potential human exposure in greenhouse vegetable cultivation (XiaoXue et al., 2013). Telone 

C-35 is an excellent MB alternative and has provided acceptable weed control efficacy (XiaoXue et al., 2013).

According to the Party, most of the reported non-chemical alternatives (crop rotation, bio-fumigation, solarization, steaming) are not technically and economically feasible.

VIF and TIF are produced in China, but are not used for ginger production due to very high cost and low efficacy under low temperatures. MB is applied every year during early 

spring or late autumn. 
MBTOC 2014 CUNs: Interim Recommendations – May 2014 31

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

MBTOC interim assessment for MB use in this sector in 2015:

MBTOC accepted the Parties information that alternatives are not available for this nomination, particularly as 1,3-D is unavailable for use in China. MBTOC however notes that 

other countries which applied MB using canisters on a small scale use have phased out for this sector and have identified alternatives (eg Japan). MBTOC considered that a use 

rate should be brought in line with the outdoor ginger production as the target pests are similar i.e. 40g/m2(without VIF or TIF). MBTOC notes that the rate is higher than the rates 

used for MB applied by canisters for ginger in Japan before they phased out MB. MBTOC considers that in the absence of effective alternatives MB/Pic 50:50 would be suitable for 

this sector, but China would need to develop technology to formulate and apply this MB/Pic formulation. MB considers that barrier films should be used in future for this use and 

urge the Party to consider accessing these films. MBTOC is also aware that chloropicrin combined with dimethyl disulphide or chloropicrin with fosthiazate have shown promising 

results (Aocheng, pers. comm.).

MBTOC notes that the Party has been supported by the MLF with one demonstration project, three project preparation grants and one investment project consisting of eight 

tranches since 1994 and that many alternatives have been trialled (MLF, 2014a). The funding received from the MLF was support for investment projects and was committed to 

phase out its whole MB consumption for controlled uses by the end of 2014 (MLF, 2014b).

As noted for the ginger open field nomination, use of canisters of MB have been eliminated for soil use in many Article 5 countries as this application is considered to be less 

efficient for the control of soil-borne pathogens than injection methods. Use of canisters is also considered to be more dangerous to workers because trained contractors are not 

involved in its application. This practice leads also to high emissions of MB. Canisters are used because they provide small-scale farmers with an easy application method and the 

ability to apply targeted amounts of MB to small areas where injection machinery may be difficult to use (TEAP 2008). 

Even though the Party did not present any management strategy, the Party stated that they hoped to register more alternatives for ginger by 2018 to possibly be able to phase out 

by 2018. According to reports presented to the ExCom , satisfactory pest and disease control has been obtained in ginger crops with the combination of high dosages of 

chloropicrin, improved application methods of this fumigant and of dazomet and use of other chemicals and biological nematicides, and IPM. PIC is used for soil fumigation in 

areas where the main ginger soil-borne pathogens Pythium spp. and Ralstonia solanacerum. In many countries, soil less culture has proven to be an excellent alternative to MB 

for ginger in protected cultivation e;g. Hawaii, USA (Maine), Mauritus and India (Hayden et al., 2004, Hepperly et al. 2004, Kratky 1998, Mamta and Shraddha 2013, Sato 1999, 

Sayed 1984, Singh and Singh 2012, Suhaimi et al. 2012). MBTOC considers that this alternative should be considered in China for areas where MB is used for in ginger, 

especially in protected cultivation. The initial capital investment is not considered to be high because greenhouses are already available. Ginger farmers may also have available 

locally the basic systems of plastic bags, local substrate and adequate fertigation/ irrigation systems for setup of these systems. Training for a centralized region is also 

considered not to be prohibitive. During the MBTOC meeting an overview of soil less culture for ginger production was presented and is available to the Party.

MBTOC comments on economics in 2014 for 2015:

 Ginger prices have been increasing, so more farmers wish to produce it. Chloropicrin is the only registered alternative, but requires a longer period for fumigation time, and 

damages the ginger when applied in low temperatures and does not control root-knot nematodes. With chloropicrin, planting time must therefore be postponed, and this 

affects yields, quality and time to market, resulting in a significant loss in net revenue.

 Non-chemical alternatives include crop rotation, but land is scarce and ginger is profitable, or soilless, which requires capital investment and more experienced farmers; or 

steam, which is expensive. Other alternatives (soil disinfection, bio-fumigation) are technically infeasible given the particular growing conditions.

 Argues that the price of ginger will be lower with chloropicrin (Methyl bromide: $9.02/kg; chloropicrin: $6.89/kg because of the quality impact of root-knot nematodes.

 Yield with methyl bromide is 96.45 t/ha, while with chloropicrin it is 86.22 t/ha, again because of the effect of root-knot nematodes.

 Gross revenue with chloropicrin is 44% that of Methyl Bromide (because of the yield and price difference.

 Net revenue is 25% of that of methyl bromide; put another way, net revenue has declined by well over two thirds.
32 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission Reduction: VIF and TIF are produced in China, but are not used for ginger production due to very high cost and low efficacy under low 

temperatures. MB is applied every year during early spring or late autumn.

 Dec. IX/6 b(iii) MLF Assistance/Adoption of Effective Alternatives: Research trials within the MLF-funded investment project commenced in this sector in 2008 and will 

be completed in 2014. Promising results have been obtained. Additionally, active research is being conducted on chemical alternatives (chloropicrin + DMDS, chloropicrin 

+ fosthiazate and chloropicrin + avermectin). It is expected that some chemicals will be registered by 2018. China is trying also to develop the flame sterilization technology.

 Dec. IX/6 b(iii) Appropriate Effort: Yes, considered appropriate as experiments are being conducted to register chemical alternatives by 2018 

Mexico Raspberries 70 [41.418]

MBTOC interim recommendation for 2015:

MBTOC recommends 41.418 t tonnes of MB for use in raspberry nurseries for 2015. This amount does not allow for the contingency amount requested for projected growth of the 

industry in 2015. MBTOC based the decision on the actual amount of MB reportedly consumed in the most recent full year of consumption in 2012 as 2013 data has not been 

reported. MBTOC acknowledges that past historic data may not have been complete as only two out of three growers reported their use of MB in 2012. This recommendation has 

been made as trials have only recently been initiated and there is reportedly insufficient data provided to the Party to evaluate the performance of alternatives for this relatively new 

industry. MBTOC considers that if results show feasibility that rapid adoption will follow.

Nomination by the Party for 2015:

The quantity requested for this CUN is 70 tonnes, for use in raspberry nursery stock production in the Jalisco and Michoacan States. MB formulations applied are 50:50, 

broadacre, in dosages of 200 kg/ha, once a year and normally not under VIF. This rate however conforms with MBTOCs standard presumption for nursery material.

Circumstances of the nomination by the Party:

The raspberry nursery industry in Mexico is evolving, and small low/medium technology production systems now coexist with large “professional” nursery producers similar to 

those found in California. The industry previously sourced transplants from California for many raspberry growers in Mexico. The transition includes confronting many of the same 

challenges facing California and the EU to produce raspberry nursery stock that meets the high health standards demanded by the marketplace. Trials of methyl bromide 

alternatives were recently initiated in 2012. 

This new industry is growing rapidly and the land area requiring methyl bromide is expected to continue to increase while the additional field trials are on-going. The party is 

requesting increased methyl bromide in anticipation of the expanded acreage for this industry. 

The Party states that the key pests affecting strawberry runner production are the fungi Phytophthora, Pythium, Fusarium, Rhizoctonia, Verticillium, Colletotrichum, and weeds 

such as Cyperus spp and Malva neglecta. 

Available alternatives -according to the nomination- cannot control target pests adequately to meet “market standards”, although no certification thresholds are established or 
MBTOC 2014 CUNs: Interim Recommendations – May 2014 33

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

required by regulation. However, a research program was put in place in 2012 and showed promising results especially with 1,3D + chloropicrin; and chloropicrin + metam sodium, 

followed by metam sodium alone. A new round of trials began in 2013/14 to obtain additional data about the efficacy of the alternatives (López Aranda et al.; 2012; Cotero et al., 

2013; SEMARNAT – UNIDO; 2013). The Party anticipates that soilless systems would be expensive and require a significant investment as infrastructure does not exist.

MBTOC interim assessment for MB use in this sector in 2015:

MBTOC acknowledges that an active research program was recently initiated and recognizes that additional time is needed to conduct trials to gain confidence in the efficacy of 

the alternatives under Mexican conditions. 

MBTOC accepts that a quantity of MB is required for this industry at present and has used the most recent usage for the recommendation. MBTOC however considers the 

request for increased methyl bromide in anticipation of a potential increase in acreage to be a contingency request, rather than a request based on the current circumstances of 

the nomination. MBTOC does not recommend contingency requests. MBTOC notes that some parties have adopted a policy that they will not nominate methyl bromide for the 

purpose of increasing the acreage of a specific industry. MBTOC encourages this party to consider adopting a similar policy.

MBTOC notes that the Party has been supported by the MLF with 2 demonstration and 2 technical assistance projects plus 4 project preparation grants, and one investment 

project also funded bilaterally by Italy and Canada since 1998, and that many alternatives have been trialled across a range of sectors (MLF, 2014a), although trials for this sector 

started only recently (SEMARNAT-UNIDO, 2014). The funding has been received from the MLF to support Mexico with the phase out its whole MB consumption for controlled 

uses by the end of 2013 (MLF, 2014b).

MBTOC comments on economics in 2014 for 2015:

 Because Methyl bromide alternatives are not yet used commercially for raspberry nurseries in Mexico, there is still limited information on their cost and feasibility, especially 

because nursery production requires cleaner plants than fruiting fields. 

 Data on the production costs with methyl bromide are however provided for future comparison.

 For strawberries the cost of application of chloropicrin and 1.3D-Pic is roughly comparable to that of methyl bromide, while application of metam sodium is around a third of 

the cost

 For raspberries only the cost of methyl bromide application is available.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission Reduction: Most growers do not use barrier films (VIF or TIF), although some growers are beginning to try it. The research program includes low 

permeability films. The formulation of MB/Pic is 50:50, which contributes to emission reduction.

 Dec. IX/6 b(iii) MLF Assistance/Adoption of Effective Alternatives: Trials in an MLF project commenced in this sector in 2011/2012 and will be completed in 2014. 

Promising results have been obtained. 

 Dec. IX/6 b(iii) Appropriate Effort: Research effort is adequate.
34 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

Mexico Strawberries 70 [43.539]

MBTOC Recommendation for 2015:

MBTOC recommends 43.539 t of MB for use in strawberry nurseries for 2015. This amount does not allow for the contingency amount requested for projected growth of the 

industry in 2015, and has based the decision on the actual amount of MB reportedly consumed in 2013. MBTOC also notes that some Parties have adopted a policy that they will 

not nominate MB for the purpose of increasing the acreage of a specific industry. Also, that the use for strawberry nurseries commenced after 2005 when consumption was 

capped at 80%. A recommendation has been proposed, as trials have only recently been initiated and there is reportedly insufficient data provided to the Party to evaluate the 

performance of alternatives for this relatively new industry. MBTOC considers that if results show feasibility that rapid adoption of alternatives will follow.

Nomination by the Party for 2015:

The quantity requested for this CUN is 70 tonnes, for use in strawberry runner production in the Jalisco and Michoacan States. MB formulations applied are 50:50, broad acre, in 

dosages of 200 kg/ha, once a year and normally not under VIF.

Circumstances of the nomination by the Party:

The strawberry nursery industry in Mexico is evolving, and small low/medium technology production systems now coexist with large “professional” nursery producers similar to 

those found in Spain and California that were previously the source of transplants for many berry growers in Mexico. This transition includes confronting many of the same

challenges facing Spain, California, Australia, and Canada to produce strawberry runners that meet the high health standards demanded by the marketplace. Trials of methyl 

bromide alternatives were recently initiated in 2012. 

This new industry is growing rapidly and the land area requiring methyl bromide is expected to continue to increase while the additional trials are ongoing. The party is requesting 

increased methyl bromide in anticipation of the expanded acreage for this industry. 

The Party states that the key pests affecting strawberry runner production are the fungi Phytophthora, Pythium, Fusarium, Rhizoctonia, Verticillium, Colletotrichum, and weeds 

such as Cyperus spp and Malva neglecta. Nematodes and Macrophomina were specifically excluded as problems, for the moment, in the Party ́s responses to MBTOC.

Available alternatives -according to the nomination- cannot control target pests adequately to meet “market standards”, although no certification thresholds are established or 

required by regulations. However, a research program was put in place in 2012 and showed promising results especially with 1,3D + chloropicrin; and chloropicrin + metam 

sodium, followed by metam sodium alone. A new round of trials began in 2013/14 to obtain additional data on the efficacy of the alternatives (López Aranda et al.; 2012; Cotero et 

al., 2013; SEMARNAT – UNIDO, 2013). The Party anticipates that soilless systems would be expensive and require a significant investment as infrastructure does not exist.

MBTOC interim assessment for MB use in this sector in 2015:

MBTOC acknowledges that the active research program was recently initiated and recognizes that additional time is needed to conduct trials to determine the efficacy of 

alternatives under Mexican conditions. MBTOC notes that although the nominating industry is recent and uses more sophisticated management approaches, there are traditional 

nurseries in the country that do not use MB fumigation at all (INIFAP; 2011).
MBTOC 2014 CUNs: Interim Recommendations – May 2014 35

Country Industry CUN 

for 

2015

MBTOC interim 

recommendation for 

2015

MBTOC considers the request for increased methyl bromide in anticipation of a potential increase in acreage to be a contingency request, rather than a request based on the 

current circumstances of the nomination. MBTOC does not recommend contingency requests and has adjusted the recommendation to remove the contingency amount of methyl 

bromide. MBTOC notes that some Parties have adopted a policy that they will not nominate methyl bromide for the purpose of increasing the acreage of a specific industry. 

MBTOC notes that the Party has been supported by the MLF with 2 demonstration and 2 technical assistance projects plus 4 project preparation grants, and one investment

project also funded bilaterally by Italy and Canada since 1998, and that many alternatives have been trialled across a range of sectors (MLF, 2014a), although trials for this sector 

started only recently (SEMARNAT-UNIDO, 2014). The funding has been received from the MLF to support Mexico with the phase out its whole MB consumption for controlled 

uses by the end of 2013 (MLF, 2014b).

MBTOC comments on economics in 2014 for 2015:

The nomination was not based on economic arguments.

Comments Requested in Dec. XX1/11 (para 9):

 Dec. IX/6 b(i) Emission Reduction: Most growers do not use VIF or TIF, although some growers are beginning to try it. The research program includes low permeability 

films. Formulation is 50:50 which contributes to emission reduction.

 Dec. IX/6 b(ii) MLF Assistance/Adoption of Effective Alternatives: Trials in an MLF project commenced in this sector in 2011/2012 and will be completed in 2014. 

Promising results have been obtained. 

 Dec. IX/6 b(iii) Appropriate Efforts: Research effort is adequate.
36 May 2011 TEAP Report on 2011 CUNs: Interim Report

1.5 Interim evaluation of CUNs: Structures and Commodities

A group of MBTOC members, appointed by the co-chairs, assessed the single remaining CUN in the 

SC sector submitted in 2014 for 2016 (US dry cure pork). Discussion was later held in plenary to 

discuss the proposed recommendation and reach consensus. Information provided during the bilateral 

discussion held via teleconference with the US delegation and experts on alternatives to MB for cured 

ham were considered in the course of the assessment. 

1.5.1 Standard rate presumptions 

MBTOC assessed the SC CUN for appropriate MB dosage rates and deployment of MB emission/use 

reduction technologies, such as appropriate sealing techniques. 

Decision IX/6 requires that critical uses should be permitted only if ‘all technically and economically 

feasible steps have been taken to minimise the critical use and any associated emission of methyl 

bromide’. Decision Ex.II/1 also mentions emission minimisation techniques, requesting Parties “...to 

ensure, wherever methyl bromide is authorised for critical-use exemptions, the use of emission 

minimisation techniques that improve gas tightness or the use equipment that captures, destroys 

and/or reuses the methyl bromide and other techniques that promote environmental protection, 

whenever technically and economically feasible.”

With the beginning of the CUN process in 2005, MBTOC published its standard presumptions for 

structures (20g m-3) and indicated that the European Plant Protection Organization’s (EPPO) 

published dosage rates for commodities should be considered standard best practice for fumigation 

worldwide. Since that time all Parties submitting CUNs stated their adherence to those practices. The 

EPPO dosage rates for commodity treatment vary by commodity, sorption rate and environmental 

conditions. They can be found in annexes to the MBTOC 2006 Assessment Report (MBTOC, 2007). 

Where possible, reduced dosages, combined with longer exposure periods, can reduce MB 

consumption, while maintaining efficacy (MBTOC 2007).

1.5.2. Details of the evaluation

The total MB volume nominated in 2014 for post-harvest uses in 2016 was 3.240 tonnes. MBTOC 

recommended 3.240 tonnes (Table 1.11 and 1.12). Table 1-12 provides the MBTOC-SC interim 

recommendation for the CUN submitted.

Table 1-11. Summary of the interim recommendations for a CUE for postharvest uses 

of MB (tonnes) for 2016 submitted in the 2014 round. 

Country and Sector Nominated in 2014 (tonnes) Recommended for 2016 

(tonnes)

United States - Dry cure pork 3.240 [3.240]

Total 3.240 [3.240]
MBTOC 2014 CUNs: Interim Recommendations – May 2014 37

Table 1-12. Interim evaluation of CUNs from non A5 Parties for structures and commodities submitted in 2014 for 2016

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE 

for 

201410

CUE 

for 

201511

CUN for 

2016

MBTOC 

Rec. for 

2016

United 

States

Dry Cure 

Pork

67.907 40.854 18.998 19.669 18.998 4.465 3.73 3.730 3.730 3.730 3.240 3.240 [3.240]

MBTOC interim recommendation for 2016:

MBTOC recommends 3.240 tonnes, the amount nominated by the Party for use in US Southern dry cure pork in long storage in 2016. 

Nomination by the Party for 2016: 

The Party nominated 3.240 tonnes, the same amount granted by the Parties for this use in 2015. 

Circumstances of the nomination:

Presently, there is still no commercially effective and economically feasible alternatives to methyl bromide for the specialised disinfestation of ham houses containing 

Southern dry cure pork, a unique regional, traditional product, that is stored (cured) for long periods. Previous reductions in methyl bromide consumption have been 

achieved through improvements in fumigation practice, reduced curing time and reduced frequency of fumigation. The nomination states that there is no further scope for 

reduction through similar changes. The pests of this product are the red-legged ham beetle (Necrobia rufipes) and the ham mite (Tyrophagus putrescentiae), with the mite 

being particularly difficult to control to US food hygiene standards (nil tolerance on inspection). Many ham houses using short curing times do not now use methyl bromide 

fumigation.

There is an ongoing multi-university, multi-state research program which is focused on improving processing sanitation, IPM and pest control through a variety of possible 

fumigants and physical processes (Amoah et al., 2012; Phillips, 2013a, b). The Party has previously reported processors and researchers were trying steam cleaning, use 

of approved disinfectants with acaricidal properties, dips and coatings, to protect hams in store. The results of investigations with various alternative fumigants and 

nonchemical treatments on the ham mite Tyrophagus putrescentiae have not yet been fully successful (e.g. Abbar et al., 2012; 2013; Zhao et al., 2012a, b). Recently, a 

commercial trial was carried out with phosphine applied as magnesium phosphide for mite control (Phillips, 2013c). While this was successful in controlling the mites, 

corrosion damage to exposed electronics in the houses was unacceptable. 

Southern dry cure pork processors only fumigate when the pests, or signs of the pests, are present. 

MBTOC interim assessment for MB Use in this sector in 2016:

The US has a continuing and robust research program into methyl bromide replacement for this specific situation and commodity. A number of promising lines of 

investigation have been identified. These include various dips, some insecticide formulations and sulfuryl fluoride fumigation with added heat. No effective and viable 

replacements on a commercial scale have been identified at this time, though use of phosphine appears most promising with some modifications in application technique. 

MBTOC notes that there are well-known techniques for preventing phosphine-related corrosion, including sealing and other protection of the susceptible components. 
38 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Country Industry CUE for 

20051

CUE for 

20062

CUE for

20073

CUE for

20084

CUE for

20095

CUE for

20106

CUE for 

20117

CUE for 

20128

CUE for 

20139

CUE 

for 

201410

CUE 

for 

201511

CUN for 

2016

MBTOC 

Rec. for 

2016

There appears to be scope for further reduction in frequency of treatment through better pest monitoring and fumigation techniques. MBTOC notes that recapture is not 

currently used for reduction of emissions in the absence of alternatives and that there are recapture units commercially available.

MBTOC comments on economics in 2014 for 2016:

The CUN rests on technical infeasibility, so no economic analysis was conducted.

Comments requested in Dec. XX1/11 (para 9)

 Dec. IX/6 b(i) Emission Reduction: The CUN states that improvements in sealing and fumigant containment have been made.

 Dec. IX/6 b(iii) Research Program: There is an ongoing program testing and trialling promising alternatives

 Dec. IX/6 b(iii) Appropriate Effort: see above 
MBTOC 2014 CUNs: Interim Recommendations – May 2014 39

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ANNEX 1: Decision IX/6

1. To apply the following criteria and procedure in assessing a critical methyl bromide use for 

the purposes of control measures in Article 2 of the Protocol:

(a) That a use of methyl bromide should qualify as “critical” only if the nominating Party 

determines that:

(i) The specific use is critical because the lack of availability of methyl bromide for that 

use would result in a significant market disruption; and

(ii) There are no technically and economically feasible alternatives or substitutes 

available to the user that are acceptable from the standpoint of environment and 

health and are suitable to the crops and circumstances of the nomination;

(b) That production and consumption, if any, of methyl bromide for critical uses should be 

permitted only if:

(i) All technically and economically feasible steps have been taken to minimise the 

critical use and any associated emission of methyl bromide;

(ii) Methyl bromide is not available in sufficient quantity and quality from existing stocks 

of banked or recycled methyl bromide, also bearing in mind the developing countries’ 

need for methyl bromide;

(iii) It is demonstrated that an appropriate effort is being made to evaluate, 

commercialise and secure national regulatory approval of alternatives and 

substitutes, taking into consideration the circumstances of the particular nomination 

and the special needs of Article 5 Parties, including lack of financial and expert 

resources, institutional capacity, and information. Non-Article 5 Parties must 

demonstrate that research programmes are in place to develop and deploy 

alternatives and substitutes. Article 5 Parties must demonstrate that feasible 

alternatives shall be adopted as soon as they are confirmed as suitable to the Party’s 

specific conditions and/or that they have applied to the Multilateral Fund or other 

sources for assistance in identifying, evaluating, adapting and demonstrating such 

options;

2. To request the Technology and Economic Assessment Panel to review nominations and make 

recommendations based on the criteria established in paragraphs 1 (a) (ii) and 1 (b) of the present 

decision;

3. That the present decision will apply to Parties operating under Article 5 and Parties not so 

operating only after the phase-out date applicable to those Parties.

Para. 2 of Decision IX/6 does not assign TEAP the responsibility for determining the existence of 

“significant market disruption” specified in paragraph 1(a)(i).

TEAP assigned its Methyl Bromide Technical Options Committee (MBTOC) to determine whether 

there are no technically and economically feasible alternatives or substitutes available to the user that 

are acceptable from the standpoint of environment and health and are suitable to the crops and 

circumstances of the nomination, and to address the criteria listed in Decision IX/6 1(b).
MBTOC 2014 CUNs: Interim Recommendations – May 2014 45

ANNEX II - Part A: Historic Trends in Preplant Soil Nominations and Exemptions for MB Use

List of nominated (2005 – 2015) and exempted (2005 – 2014) amounts of MB granted by Parties under the CUE process for each crop. 

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Australia Cut Flowers –

field 40.000 22.350 18.375 22.350

Australia Cut flowers –

protected 20.000 10.425

Australia

Cut flowers, 

bulbs – protected 

Vic

7.000 7.000 6.170 6.150 7.000 7.000 3.598 3.500

Australia Strawberry Fruit 90.000 67.000

Australia Strawberry 

runners

35.750 37.500 35.750 35.750 29.790 29.790 29.790 29.790 29.760 29.760 29.760 35.750 37.500 35.750 35.750 29.790 29.790 23.840+ 

5.95 29.760 29.760 29.760

Belgium Asparagus 0.630 0.225 0.630 0.225

Belgium Chicory 0.600 0.180 0.180 0.180

Belgium Chrysanthemums 1.800 0.720 1.120

Belgium Cucumber 0.610 0.545 0.610 0.545

Belgium Cut flowers –

other 6.110 1.956 4.000 1.956

Belgium Cut flowers –

roses

1.640

Belgium Endive (sep from 

lettuce) 1.650 1.650

Belgium Leek & onion 

seeds 1.220 0.155 0.660
46 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Belgium Lettuce(& 

endive) 42.250 22.425 25.190

Belgium Nursery

Not 

Predictabl

e

0.384 0.900 0.384

Belgium Orchard pome & 

berry 1.350 0.621 1.350 0.621

Belgium Ornamental 

plants 5.660 0.000

Belgium Pepper & egg 

plant 5.270 1.350 3.000 1.350

Belgium Strawberry 

runners

3.400 0.900 3.400 0.900

Belgium Tomato 

(protected) 17.170 4.500 5.700 4.500

Belgium Tree nursery 0.230 0.155 0.230 0.155

Canada Strawberry 

runners (PEI) 14.792 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.596 5.261 5.261 (a)14.792 6.840 7.995 7.462 7.462 7.462 5.261 5.261 5.261 5.261

Canada Strawberry runners (Quebec) 1.826 1.826 (a) 1.826 1.826

Canada Strawberry runners (Ontario) 6.129 6.129

France Carrots 10.000 8.000 5.000 8.000 8.000 1.400

France Cucumber 85 revised 

to 60 60.000 15.000 60.000 60.000 12.500

France Cut-flowers 75.000 60.250 12.000 60.000 52.000 9.600

France Forest tree 

nursery

10.000 10.000 1.500 10.000 10.000 1.500

France Melon 10.000 10.000 7.500 6.000
MBTOC 2014 CUNs: Interim Recommendations – May 2014 47

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

France

Nursery: 

orchard, 

raspberry

5.000 5.000 2.000 5.000 5.000 2.000

France Orchard replant 25.000 25.000 7.500 25.000 25.000 7.000

France Pepper

Incl 

in.tomato 

cun

27.500 6.000 27.500 6.000

France Strawberry fruit 90.000 86.000 34.000 90.000 86.000

France Strawberry 

runners

40.000 4.000 35.000 40.000 40.000 28.000

France

Tomato (and 

eggplant for 

2005 only)

150(all 

solanaceo

us)

60.500 33.250 125.000 48.400

France Eggplant 27.500 33.250 48.400

Greece Cucurbits 30.000 19.200 30.000 19.200

Greece Cut flowers 14.000 6.000 14.000 6.000

Greece Tomatoes 180.000 73.600 156.000 73.600

Israel Broomrape 250.000 250.000 125.000 12.500 12.500 250.000 250.000 125.000 12.500

Israel Cucumber - protected new 2007 25.000 18.750 18.750 12.500 25.000 18.750 - 15.937

Israel Cut flowers –

open field 77.000 67.000 80.755 53.345 42.777 42.554 23.292 77.000 67.000 74.540 44.750 34.698 28.554

Israel Cut flowers –

protected 303.000 303.000 321.330 163.400 113.821 72.266 52.955 303.000 240.000 220.185 114.450 85.431 63.464

Israel Fruit tree 

nurseries 50.000 45.000 10.000 50.000 45.000 7.500
48 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Israel Melon –

protected & field 148.000 142.000 140.000 87.500 87.500 87.500 35.000 125.650 99.400 105.000 87.500 87.500 70.000

Israel Potato 239.000 231.000 137.500 93.750 75.000 239.000 165.000 137.500 93.750 75.000

Israel Seed production 56.000 50.000 22.400 56.000 28.000 NR

Israel Strawberries –

fruit (Sharon) 196.000 196.000 176.200 64.125 52.250 47.500 28.500 196.000 196.000 93.000 105.960 42.750

Israel

Strawberries –

fruit (Sharon & 

Ghaza)

57.063

Israel Strawberry 

runners (Sharon) 35.000 35.000 20.000 15.800 13.570 13.500 35.000 35.000 28.000 31.900 15.825

Israel

Strawberry 

runners and fruit 

Ghaza

87.875 67.500 67.500 34.000 47.250

Israel

Strawberry 

runners (Sharon 

& Ghaza)

22.320

Israel Tomatoes 90.000 22.750

Israel Sweet potato 95.000 20.000 20.000 111.500 95.000 20.000

Italy Cut flowers 

(protected) 250.000 250.000 30.000 250.000 187.000 30.000

Italy Eggplant 

(protected) 280.000 200.000 15.000 194.000 156.000

Italy Melon 

(protected) 180.000 135.000 10.000 131.000 131.000 10.000
MBTOC 2014 CUNs: Interim Recommendations – May 2014 49

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Italy Pepper 

(protected) 220.000 160.000 67.000 160.000 130.000 67.000

Italy Strawberry Fruit 

(Protected) 510.000 400.000 35.000 407.000 320.000

Italy Strawberry 

Runners 100.000 120.000 35.000 120.000 120.000 35.000

Italy Tomato 

(protected) 1300.000 1030.00 418.000 871.000 697.000 80.000

Japan Cucumber 88.300 88.800 72.400 68.600 61.400 34.100 29.120 26.162 88.300 88.800 72.400 51.450 34.300 30.690 27.621

Japan Ginger – field 119.400 119.400 112.200 112.100 102.200 53.400 47.450 42.235 119.400 119.400 109.701 84.075 63.056 53.400 47.450

Japan Ginger –

protected 22.900 22.900 14.800 14.800 12.900 8.300 7.770 6.558 22.900 22.900 14.471 11.100 8.325 8.300 7.036

Japan Melon 194.100 203.900 182.200 182.200 168.000 90.800 77.600 67.936 194.100 203.900 182.200 136.650 91.100 81.720 73.548

Japan Peppers (green 

and hot) 189.900 200.700 169.400 162.300 134.400 81.100 68.260 61.101 187.200 200.700 156.700 121.725 81.149 72.990 65.691

Japan Watermelon 126.300 96.200 94.200 43.300 23.700 15.400 13.870 12.075 129.000 98.900 94.200 32.475 21.650 14.500 13.050

Malta Cucumber 0.096 0.127

Malta Eggplant 0.128 0.170

Malta Strawberry 0.160 0.212

Malta Tomatoes 0.475 0.594

New 

Zealand Nursery material 1.085 1.085 0

New 

Zealand Strawberry fruit 42.000 42.000 24.78 42.000 34.000 12.000
50 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

New 

Zealand

Strawberry 

runners

10.000 10.000 5.720 8.000 8.000 6.234

Poland Strawberry 

Runners 40.000 40.000 25.000 12.000 40.000 40.000 24.500

Portugal Cut flowers 130.000 8.750 50.000 8.750

Spain Cut Flowers –

Cadiz 53.000 53.000 35.000 53.000 42.000

Spain Cut Flowers –

Catalonia 20.000 18.600 12.840

17

20.000

15.000 43.490

(+Andaluci

a)

(+Andaluc

ia)

Spain Pepper 200.000 155.000 45.000 200.000 155.000 45.000

Spain Strawberry Fruit 556.000 499.290 80.000 556.000 499.290 0.0796

Spain Strawberry 

Runners 230.000 230.000 230.000 215.000 230.000 230.000 230.000

UK Cut flowers 7.560 6.050

UK Ornamental tree 

nursery

12.000 6.000 6.000 6.000

UK

Strawberry (& 

raspberry in 

2005)

80.000 63.600 68.000 54.500

UK Raspberry 

nursery

4.400 4.400 54.500

USA Chrys. 

Cuttings/roses 29.412 29.412 0

USA Cucurbits – field 1187.8 747.839 598.927 588.949 411.757 340.405 218.032 59.500 11.899 1187.800 747.839 592.891 486.757 407.091 302.974 195.698 59.500
MBTOC 2014 CUNs: Interim Recommendations – May 2014 51

Party Industry

Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

USA Eggplant – field 76.761 101.245 96.48 79.546 62.789 34.732 21.561 6.904 1.381 76.721 82.167 85.363 66.018 48.691 32.820 19.725 6.904

USA Forest nursery 

seedlings 192.515 157.694 152.629 133.140 125.758 120.853 106.043 192.515 157.694 122.032 131.208 122.060 117.826 93.547

USA Ginger 9.2 9.2 0

USA Orchard replant 706.176 827.994 405.415 405.666 314.007 226.021 203.591 18.324 6.230 706.176 527.600 405.400 393.720 292.756 215.800 183.232 18.324

USA Ornamentals 210.949 162.817 149.965 138.538 137.776 95.204 70.178 48.164 48.164 154.000 148.483 137.835 138.538 107.136 84.617 64.307 48.164

USA

Nursery stock -

fruit trees, 

raspberries, roses

45.789 64.528 12.684 51.102 27.663 17.954 7.955 1.591 0.541 45.800 64.528 28.275 51.102 25.326 17.363 7.955 1.591

USA Peppers – field 1094.782 1498.53 1151.751 919.006 783.821 463.282 212.775 28.366 1094.782 1243.542 1106.753 756.339 548.984 463.282 206.234

USA Strawberry fruit 

– field 2468.873 1918.40 1733.901 1604.669 1336.754 1103.422 1023.471 753.974 531.737 415.067 373.660 2052.846 1730.828 1476.019 1349.575 1269.321 1007.477 812.709 678.004 415.067 415.06

7

USA Strawberry 

runners

54.988 56.291 4.483 8.838 8.837 7.381 7.381 3.752 3.752 54.988 56.291 4.483 8.838 7.944 4.690 + 

2.018 6.036 3.752

USA Tomato – field 2876.046 2844.985 2334.047 1840.1 1406.484 994.582 336.191 54.423 10.741 737.584 2476.365 2065.246 1406.484 1003.876 737.584 292.751 54.423

USA Turfgrass 352.194 131.600 78.040 52.189 0 131.600 78.04 0

USA Sweet potato 224.528 18.144 18.144 18.144 14.515 8.709 18.144 18.144 14.515 11.612

USA Research 2.768 2.768
52 MBTOC 2014 CUNs: Interim Recommendations – May 2014

ANNEX III– Part B: Historic Trends in Structural and Commodity Nominations and Exemptions for MB Use

List of nominated (2005- 2015) and exempted (2005 - 2014) amounts of MB granted by Parties under the CUE process for each commodity. 

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Australia Almonds 1.900 2.100 1.900 2.100

Australia Rice 

consumer 

packs

12.300 12.300 10.225 9.200 9.2 7.82 5.66 3.653 2.374 1.187 1.187 6.150 6.150 9.205 9.200 7.820 6.650 4.870 3.653 1.187 1.187

+1.8

Belgium Artefacts and 

structures

0.600 0.307 0.590 0.307

Belgium Antique 

structure & 

furniture

0.750 0.199 0.319 0.199

Belgium Churches, 

monuments 

and ships' 

quarters

0.150 0.059 0.150 0.059

Belgium Electronic 

equipment

0.100 0.035 0.100 0.035

Belgium Empty silo 0.050 0.043 0.050 0.043

Belgium Flour mill see 

mills below

0.125 0.072 See mills 

below

0.072

Belgium Flour mills 10.000 4.170 9.515 4.170

Belgium Mills 0.200 0.200 0.200 0.200

Belgium Food 

processing 

facilities

0.300 0.300 0.300 0.300
MBTOC 2014 CUNs: Interim Recommendations – May 2014 53

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Belgium Food 

Processing 

premises

0.030 0.030 0.030 0.030

Belgium Food storage 

(dry) structure

0.120 0.120 0.120 0

Belgium Old buildings 7.000 0 .306 1.150 0.306

Belgium Old buildings 

and objects

0.450 0.282 0 0.282

Belgium Woodworking 

premises

0.300 0.101 0.300 0.101

Canada Flour mills 47.200 34.774 30.167 28.650 26.913 22.878 14.107 11.020 7.848 5.044 5.044 (a)47 34.774 30.167 28.65 26.913 22.878 14.107 11.020 5.044 5.044

Canada Pasta 

manufacturing 

facilities

(a) 10.457 6.757 6.067 4.740 4.740 2.084 (a) 10.457 6.757 6.067 4.740 3.529

Canada Commodities 0.068

France Seeds sold by 

PLAN-SPG 

company

0.135 0.135 0.100 0.135 0.135 0.096

France Mills 55.000 40.000 8.000 40.000 35.000 8.000

France Rice 

consumer 

packs

2.000 2.000 2.000 2.000

France Chestnuts 2.000 2.000 1.800 2.000 2.000 1.800

Germany Artefacts 0.250 0.100 0.250 0.100
54 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Germany Mills and 

Processors 

45.000 19.350 45.000 19.350

Greece Dried fruit 4.280 3.081 0.900 4.280 3.081 0.450

Greece Mills and 

Processors 

23.000 16.000 1.340 23.000 15.445 1.340

Greece Rice and legumes 2.355 2.355

Ireland Mills 0.888 0.611 0.888

Israel Artefacts 0.650 0.650 0.600 0.650 0.6500

Israel Dates (post 

harvest)

3.444 3.444 2.200 1.800 2.100 3.444 2.755 2.200 1.800 2.100 1.040

Israel Flour mills 

(machinery & 

storage)

2.140 1.490 1.490 0.800 0.300 2.140 1.490 1.040 0.312 0.300

Israel Furniture–

imported

1.4220 1.4220 2.0420 1.4220 0

Italy Artefacts 5.500 5.500 5.000 5.225 0 5.000

Italy Mills and 

Processors

160.000 130.000 25.000 160.000 65.000 25.000

Japan Chestnuts 7.100 6.500 6.500 6.300 5.800 5.400 5.350 3.489 3.317 7.100 6.800 6.500 6.300 5.800 5.400 5.350 3.489

Latvia Grains 2.502 2.502

Netherlands Strawberry runners post 

harvest

0.120 0.120 0.120 0 0.120

Poland Medicinal 

herbs & dried 

mushrooms as 

dry 

commodities

4.000 3.560 1.800 0.500 4.100 3.560 1.800 1.800
MBTOC 2014 CUNs: Interim Recommendations – May 2014 55

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

Poland Coffee, cocoa 

beans

(a) 2.160 2.000 0.500 2.160 1.420 1.420

Spain Rice 50.000 42.065

Switzerland Mills & 

Processors

8.700 7.000 8.700 7.000

UK Aircraft 0.165 0.165

UK Mills and 

Processors

47.130 10.195 4.509 47.130 10.195 4.509

UK Cereal processing plants 8.131 3.480 (a) 8.131

UK Cheese stores 1.640 1.248 1.248 1.640 1.248 1.248

UK Dried 

commodities 

(rice, fruits 

and nuts) 

Whitworths

 2.400 1.256 2.400 1.256

UK Herbs and 

spices

0.035 0.037 0.030 0.035 0.037

UK Mills and 

Processors 

(biscuits) 

2.525 1.787 0.479 2.525 1.787

UK Spices 

structural 

equip.

1.728 1.728 0 0.479

UK Spices stored 0.030 0.030 0

UK Structures 

buildings 

(herbs and 

spices)

3.000 1.872 0.908 3.000 1.872 0.908
56 MBTOC 2014 CUNs: Interim Recommendations – May 2014

Party Industry Total CUN MB Quantities Total CUE Quantities

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

UK Structures, 

processors 

and storage 

(Whitworths)

1.100 0.880 0.257 1.100 0.880 0.257

UK Tobacco 

equipment

0.523 0.050

UK Woven 

baskets

0.770 0.770

USA Dried fruit 

and nuts 

(walnuts, 

pistachios, 

dried fruit and 

dates and 

dried beans)

89.166 87.719 91.299 67.699 58.912 19.242 10.041 2.419 0.822 0.740 0.310 89.166 87.719 78.983 58.921 45.623 19.242 5.000 2.419 0.740 0.740

USA Dry 

commodities/ 

structures 

(cocoa beans) 

61.519 61.519 64.028 52.256 51.002 61.519 55.367 64.082 53.188

USA Dry 

commodities/ 

structures 

(processed 

foods, herbs 

and spices, 

dried milk and 

cheese 

processing 

facilities) 

NPMA

83.344 83.344 85.801 72.693 66.777 37.778 17.365 0.200 83.344 69.118 82.771 69.208 54.606 37.778 17.365

USA Smokehouse 

hams (Dry 

cure pork 

products) 

(building and 

product)

136.304 135.742 40.854 19.669 19.699 4.465 3.730 3.730 3.730 3.730 3.730 67.907 81.708 18.998 19.699 18.998 4.465 3.730 3.730 3.730 3.730

USA Mills and 

Processors 

536.328 505.982 401.889 362.952 291.418 173.023 135.299 74.51 25.334 22.800 483.000 461.758 401.889 348.237 291.418 173.023 135.29

9

74.510 22.80

0

22.80

0

USA Research 0.159 0.159