IMPLICATIONS OF THIS EU LEGISLATION

Growers of tropical, sub-tropical and out-of-season fruit and vegetables are being particularly hard hit by the legislation because a disproportionately high number of relevant MRLs has been set at LOD; thus many of the most widely used active ingredients are likely to be phased out through the approvals review programme. This situation has arisen because:

• agrochemical companies are not likely to want to invest in generating and collating datasets to defend registration of, or set MRLs for, older, out-of-patent pesticides, yet these pesticides also tend to be cheaper and more widely available, and hence widely used, in developing countries.
• agrochemical companies have in general only been interested in generating data for establishment of MRLs for crops they classify as "major crops" i.e. crops of major economic significance. However, out of the fruit and vegetable crops exported by ACP countries, only bananas and citrus fruits are classified as "major crops";
• in some developed countries such as the UK, the fresh produce industry has worked with the government to generate data for establishment of MRLs for key crop/active ingredient combinations which were not being defended by agrochemical companies. However, most developing country governments and industries have until recently been poorly informed about the EU legislation and its implications, and often lack the technical expertise and resources to generate and compile the necessary dossiers.

In addition:

• Some importers may stop buying from countries where smallholder production is the dominant source of supply, due to concerns about effective control over pesticide use, unless effective remedial action is taken;
• Some exporters may also abandon smallholders (if they have alternative sources of supply), unless cheap and effective methods of monitoring smallholder production can be installed;
• Smallholders will need support from outside agencies to enable them to keep appropriate records of pesticide applications and other pest control measures used;
• Smallholders may not be able to afford alternative pesticides, and/or may not be able to get hold of them if they are not available or registered in-country.

Related Information: MRL Harmonization Programme; Pesticide Approvals; ACP Pesticides Initiative; Sanitary and Phytosanitary Measures