Great Britain and EU Maximum Residue Levels (MRLs) are likely to diverge once new pesticide and MRL review systems are in place. The new system offers opportunity for exporters to seek MRL harmonization in Great Britain.
The United Kingdom’s completion of the withdrawal from the European Union on December 31, 2020, had far reaching implications in all aspects of British life. This included the United Kingdom’s pesticide policies.
Bryant Christie’s Global Access division is closely monitoring pesticide and MRL reviews in the United Kingdom, which are expected to diverge from the EU’s standards in the coming years.
In November 2022, Bryant Christie Inc.’s Deputy Director for Global Access, Alinne Oliveira, traveled to York, United Kingdom to meet with officials from the Health and Safety Executive’s (HSE’s) Chemical Regulation Division. Alinne was one of the first U.S. agriculture stakeholders to meet with HSE on the topics of UK pesticide policies and MRLs. An overview of the current pesticide and MRL systems in Great Britain is below.
After leaving the European Union, the United Kingdom established its own regulatory review systems and standards. The new pesticide and MRL regulations only apply to Great Britain (England, Wales, and Scotland) and not to Northern Ireland, which will continue to follow EU regulations. Therefore, the new MRL system is for Great Britain, not the United Kingdom.
At Brexit, Great Britain adopted all established EU MRLs as their own as the foundation for the new Great Britain MRL system while a new review system is being developed. Soon, HSE will commence its own MRL reviews and adjust those initial EU adopted MRLs as needed, allowing for differences in MRLs between Great Britain and the EU moving forward. There is public pressure, however, to not diverge too far from EU MRLs as the EU remains a major market for Great Britain and differing MRLs could cause challenges when exporting.
The basics of the Great Britain system are:
For pesticide approval and renewals:
- All substances approved for use in the EU as of January 1, 2021 were adopted by Great Britain and will remain valid until Great Britain carries out its own reviews.
- All domestic pesticide approvals in Great Britain that were originally expected to expire before December 2023 have been automatically extended for three years to allow time to plan and implement the Great Britain review program.
- EU pesticide (non)approval/(non)renewal related changes after January 1, 2021 are not applicable to Great Britain unless a national review is carried out.
For Great Britain import tolerances and MRL reviews:
- Great Britain is accepting import tolerance applications. Data requirements are similar to those of the European Union.
- A MRL review system should be established by 2024. Until then, a limited number of MRL reviews are taking place, such as new import tolerances, MRL restrictions that are a result of consumer health concerns, or harmonization with Codex MRLs.
Great Britain and EU MRLs are likely to diverge once new Great Britain pesticide and MRL review systems are fully implemented. This new system will offer opportunities for exporters to Great Britain to seek MRL harmonization.
During the BCI meeting with the HSE Chemicals Regulation Division, BCI learned of likely policy changes that will impact exports to Great Britain, such as the transition time allowed before a new restrictive MRL goes into effect, the role environmental factors will play in Great Britain MRL reviews, and which MRL that will be applied for imported products that were legally treated when an MRL was in place but now longer have a MRL in Great Britain (the Channels of Trade issue).
Please contact BCI’s Global Access team at globalaccess@bryantchristie.com for additional information on these issues or Great Britain MRLs in general.
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Photo credit at top of page: Diliff, CC BY-SA 2.5 via Wikimedia Commons.
