The Pesticide Action Network Europe welcomes the EU Commission's initiative to harmonise maximum residue limits (MRLs). PAN Europe welcomes a limit of 0.01 mg/kg being set for pesticides which are non-authorized or not allowed in the European Union.
The proposal, however, contains significant deficiencies and ought to be revised and improved accordingly: Our main comments are:
- Good Agriculture Practice (GAP) should be defined as ICM (Integrated Crop Management) as a minimum standard to prevent environmentally less desirable methods of farming;
- Temporary MRLs could be harmful to consumers and are not necessary;
- Consumers should be protected against additive and synergistic effects of combined residues in total food and exposure from other environmental sources.
- Transparency and participation in evaluation and decision-making processes in MRLsetting should be secured.
In addition, PAN Europe believes that another objective must be to protect environment and human health – especially vulnerable groups such as foetuses, infants and children – according to the precautionary principle. MRL-setting at the lowest level possible can contribute to the protection of consumers and the environment at the same time. In this respect, there must be a coordination and coherence between the proposed regulation and the upcoming EC Thematic Strategy on the sustainable use of pesticides.