Each year, Australia’s Food Standards Australia New Zealand (FSANZ) opens the MRL harmonization request period to allow stakeholders the opportunity to request changes to Schedule 20 of the Code for Maximum Residue Limits (MRLs). During this request period, stakeholders can either propose new MRLs or request modifications to existing ones, at not regulatory cost. This harmonization request process aims to align Australian MRLs with international standards, such as those set by the Codex Alimentarius Commission, to facilitate trade and consumer safety. It is an essential part of FSANZ’s ongoing efforts to maintain a regulatory framework that reflects current agricultural practices, technological advancements, and global trade requirements. Though the time of year in which the harmonization period is open varies, the period is usually open for 4-6 weeks to allow interested stakeholders adequate time to compile the necessary information to submit a request.
Each year, before the harmonization request period opens, Bryant Christie Inc. (BCI) conducts an in-depth analysis of MRL needs for our clients. Once completed, we send a summary of the findings to clients to inform their decision on which MRLs are to be requested during the given period. BCI then compiles all the necessary information for the submission and in most cases, submits the request on the behalf of the client. Over the years, BCI has submitted numerous MRL harmonization requests on behalf of clients and has secured over 150 MRLs for their commodities.
All MRL harmonization requests must be accompanied by a cover letter with detailed information on the stakeholder submitting the request, which MRLs they are requesting, and the importance of harmonization. Further, all requests must have the following information:
- Information about the agvet chemical to be considered, including the relevant health-based guidance values.
- If there are no health-based guidance value established by the Australian Pesticides and Veterinary Medicines Authority (AMPVA) or the Joint Committee on Pesticide Residues (JMPR) it may not be possible for FSANZ to accommodate a harmonization request.
- A description of the food commodity as described by Codex and/or the Code.
- The specific MRL you are seeking and a reference to the legislation where the MRL is published.
- Information on the food commodity or commodities that are intended to be imported using this MRL.
- Evidence that the food is to be imported into Australia including volumes imported from the country with the source MRL, details on the size and nature of the Australian market, and cost impacts in the absence of a harmonized MRL, if available.
FSANZ makes their Application Handbook as well as the Guide to submitting requests for MRL harmonization proposals publicly available, and provides a harmonization request template to assist interested stakeholders with requests. Once a request has been submitted, FSANZ then reviews and assesses their safety, legitimacy, and justification for residues present in the commodity. After evaluation, FSANZ may initiate changes to the Code, following further consultations and public notifications. If MRL harmonization requests are approved, they are usually in place by the following year.
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