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DG_SANTE_28th_Oct_2016_Residues_Workshop_Conclusions

cropprotection Nov 8th, 2016 125 Never
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  1. Conclusions of ECPA Residues workshop, 17 & 18 October
  2.  
  3. Dear Ms Juelicher
  4.  
  5. Following discussions at a Residues Workshop held on 17th & 18th October, ECPA would like
  6. to take this opportunity to highlight to you a number of important issues related to the
  7. implementation of Regulation 396/2005.
  8.  
  9. The workshop was organised to look at the implementation challenges linked to the
  10. regulation and we welcomed the active participation of DG SANTE and EFSA officials at the
  11. meeting. It was also attended by a broad range of stakeholders including participants from
  12. the crop protection industry, EU national authorities, third country Missions to the EU as well
  13. as farmers and food chain representatives from the EU and third countries.
  14. The following key points came from the workshop discussions:
  15.  
  16. Trade concerns
  17.  
  18. While the implementation of Regulation 396/2005 has led to significant improvements in
  19. ensuring harmonised EU MRLs, a number of sectors highlighted during the workshop that
  20. this issue is their biggest policy challenge at present, and is having a significant impact on
  21. predictability and on trade.
  22.  
  23. With regular MRL changes in the EU system, one significant challenge relates to shelf life of
  24. food products. Numerous examples were given where crops have been treated prior to
  25. legislative changes in the MRLs – and where these products can not comply with the
  26. amended EU MRL. This is an area that requires further consideration, to ensure that sensible
  27. MRL transitional periods are built into the process, in particular for raw and processed
  28. products that have a multi-year shelf life e.g. frozen or tinned foods.
  29. Transparency
  30.  
  31. Many stakeholders also requested greater transparency in the process of MRL reviews and
  32. early notice of subsequent outcomes. While the process may be very clear to those working
  33. within the system in the relevant authorities, the process remains very unclear for the
  34. regulated sectors. Additional steps need to be put in place to provide greater transparency in
  35. the MRL review process, in order to ensure that stakeholders are informed and can provide
  36. input where required. Providing transparency similar to that seen in other regulated sectors
  37. (e.g. biocides, REACH) requires further consideration and ECPA will provide further food
  38. chain suggestions on how this could be developed.
  39.  
  40. Developments in the evaluation of MRLs
  41.  
  42. A number of guidance documents are currently under development that could have a
  43. significant impact on the MRL setting and review processes in the EU and concerns were
  44. raised about the potential increase in complexity and the resources required to deal with
  45. these changes. The workshop noted in particular the possible revision of the JMPR guidance
  46. on the IESTI equation, and the EU discussions on Cumulative Risk Assessment (CRA) and
  47. Residue Definition for Dietary Risk Assessment.
  48.  
  49. For the guidance document on residue definition, it was highlighted that the adoption of the
  50. current guidance would have a significant impact, requiring additional data generation,
  51. greater resources in industry and authorities. It would also reduce the number of crop MRLs,
  52. and introduce a disconnect in the residue definitions between that in the EU and third
  53. countries. The unnecessary envisaged increase in animal testing was also highlighted;
  54. further refinements are therefore essential to ensure workable application of the residue
  55. definition guidance that minimises vertebrate testing in line with the EU’s animal welfare
  56. legislation.
  57.  
  58. The discussions on IESTI & CRA are on-going and it is hoped that progress can be made to
  59. ensure final guidance that is workable and realistic.
  60. Improving the EU legislative framework
  61.  
  62. With the planned review of Regulation 396/2005 and Regulation 1107/2009, which we
  63. understand will take place in 2017, a number of suggestions were discussed for future
  64. legislative improvements. Many of the workshop participants will actively contribute to this
  65. important legislative review and will highlight blockers in the current legislation and suggest
  66. improvements for the future.
  67.  
  68. While we believe that legislative improvements are required, we understand that this is a
  69. long term process; we will therefore work with policy makers to share and promote
  70. procedural improvements in the application of the current legislation. One key example is the
  71. faster setting of MRL to encourage innovation for new crops and uses into the EU market.
  72.  
  73. The workshop also discussed market issues such as private standards, brand management
  74. and the importance of training to ensure the highest level of compliance. All workshop
  75. presentations are available on the ECPA website
  76.  
  77. We would of course welcome the opportunity to discuss these conclusions with you in due course.
  78.  
  79. Yours sincerely
  80.  
  81. Euros Jones
  82. Director Regulatory Affairs
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