IV Encuentro de la almendra y la avellana Reus 24 de abril 2018

Content About FRUCOM EU pesticide policy relevant for our sector FRUCOM project on pesticides

1. About FRUCOM European Federation of the Trade in Dried Fruit, Edible Nuts, Processed Fruit & Vegetables, Processed Fishery Products Represents EU importers in main EU countries Also producers in third countries: Azerbaijan; Australia; Chile; Georgia; Iran; USA; Turkey Active Working Group on Dried Fruit and Nuts Member of pesticide co-ordination platform of Embassies to the EU

2. EU pesticide policy relevant for our sector

Two main legal texts Regulation 1107/2009 on plant protection products Regulation 396/2005 on maximum residue levels (MRLs) MRLs are the upper levels of pesticide residues that are legally permissible in or on food Procedure for MRL setting & reviewing Annexes Annex I: List of commodities for which MRLs are established Annex II and Annex III: List of MRLs Annex IV: Active substances exempted from setting MRLs Annex V: List of default values Annex VI: processing factors (not established)

Database on EU MRLs

Some problems Pesticide dossier is recognised as the major concern for the trade: European Chemicals Agency ECHA classifies active substances – AS (cut off criteria) Currently, +/- 400 are authorized in the EU Manufacturer submits a dossier EFSA issues an opinion on AS based on rapporteur Member State evaluation DG SANTE/ Member States (re)approve substances, is a recurrent process DG SANTE/ Member States revise MRLs based on EFSA opinion on MRLs Changes at any of stages may result in MRLs brought down when the food has already been produced.

Standard MRL review procedure (Article 12)

Pesticides: Cut-off criteria Non-approval of active substances based on hazard-based "cut-off" criteria; Plant protection products that fall under such criteria => MRLs are expected to be reduced to default level; Restrictions on setting import tolerances; Examples: iprodione and linuron.

Pesticides: Cut-off criteria Substances of high concern for human health Endocrine disruptors Carcinogens (cat 1A,1B) Mutagens (cat 1A,1B) Toxic for reproduction (cat 1A,1B). Substances of high concern for the environment POP (persistent organic pollutant) PBT (persistent bioaccumulative and toxic) vPvB (very persistent and very bioaccumulative).

Pesticides: Endocrine disruptors “Endocrine disruptors (EDs) are chemicals which may impact on the hormone system of animals and humans”; In December 2017, the EU Member States gave their support for revised Regulation on the criteria to be used for identification of EDs; In November 2018, the EDs criteria are expected to apply.

Pesticides identified as POTENTIAL EDCs based on the Commission impact assessment report relevant to all food products:  2,4-D, 8-hydroxyquinoline, Boscalid, Cypermethrin, Desmedipham, Fenamidone, Flubendiamide, Iprodione, Lenacil, Malathion, Mancozeb, Maneb, Metiram, Myclobutanil, Oxadiazon, Pendimethalin, Propyzamide, Spirodiclofen, Tebuconazole, Tepraloxydim, Tetraconazole, Thiophanate-methyl, Thiram, Tralkoxydim, Triflusulfuron, Ziram.

3. FRUCOM project on pesticides

FRUCOM PROJECT PESTICIDES FRUCOM has a residue database but it is impossible to look into these steps with current resources The proposal will help mitigate the risks of MRL changes and try to influence the general policy trend on long shelf life products

Project actions: shift in political trend for long shelf life products relevant for FRUCOM members Specific tasks in the EU Food Chain Round Table on pesticides 21 agri-food chain industry associations with business interest in the EU pesticide policy (farmers, processors, traders, pesticide producers) develops joint communications. In December 2017, FRUCOM elected chair for 2 years Developing solid argumentation, examples and communications on long shelf life products and business impact in case of MRL changes and pressure on EU institutions in co-ordination with other partners Work on cut off criteria which knock out active substances, linked to import tolerances Co-operation with the EU missions of third countries – FRUCOM is part of network of +/- 30 missions active on pesticides Other activities, as required

FRUCOM chairs Agri Food Chain Round Table on Plant Protection Products (AFCRT) Member Associations:

Relevant events on pesticide policy Dec 2017-April 2018 FRUCOM/SANTE meeting on iprodione Dec-March: meetings missions Turkey, US, Canada, Chile South Africa on iprodione AFCRT Meeting consultant REFIT on future EU pesticide policy Meeting EU Embassies FRUCOM dried fruit and nuts working group Public hearing European Parliament on endocrine disruptors High Level Scientific Advisory mechanism to EU Commissioners Standing Committee meeting on residues (Member States and Commission) CODEX meeting on pesticides Meeting European Crop Care Association AFCRT meeting

FRUCOM Statement on pesticides to DG SANTE, Embassies and members, 11 April 2018

Actions within project on specific substances for FRUCOM members Update FRUCOM actual MRL pesticide database; Cross check of results with legal MRLs; Establishment of priority substances for specific commodities; in-depth profiling of top pesticides with regard to EFSA/DG SANTE assessment (toxicology/comparison to CODEX/main exporters’ MRLs; timelines for revision by EFSA/DG SANTE); follow up on new EFSA dossiers for pesticide/MRL revision; Developing relationships with pesticides’ producers

Input and deliverables for member associations and companies Participating members will be required to input in MRL data collection FRUCOM will deliver: Detailed document and executive summary, including on each relevant pesticide separately: Frequency of positives/MRLs/Commodities/Origins ECHA classification (some categories of pesticides would be phased out based on ECHA classification) EFSA (re)evaluation status Detailed toxicological profile based on history of EFSA opinions Codex if available Possibly, alternatives Whenever possible, feedback from EFSA, pesticide producer and DG SANTE on specific pesticide All report and communication documents for long-shelf life products and other activities in co-ordination with the Food Chain partners and missions

Conclusion FRUCOM members agreed to start the project and Almendrave is invited to join