REPORT OF THE WORKING GROUP ON MRL IN TEA BY T C CHAUDHURI Jt. Coordinator, Working Group on MRL in TEA, IGG on TEA, FAO

References of works to WG on MRL Recalling the relevant MINUTES of 19 th IGG, Delhi, May 2010 on MRL, Para 20 The Group Para 21 Tea should be compliant with regulations……..; Para 22 (i) Immediate Action Plan………..; (ii) Strategy review………….; Para 23 Global Harmonization in MRL regulations..

AGENDA Immediate Action Plan (i) Submissions on pesticide MRLs in Tea (ii) Position of Field Trial data (iii) Identification of Compounds for field trials, also developing IPM Reviewing of WG Strategy (i) Progress on the Action plan Investigating residue in tea brew

ACTIONS TAKEN on MRL Reviewed on Status of Pesticide use globally on tea Establishing Uniform Protocol for data generation Prioritized Compounds and generated residue data Commutation of available data and submission to Codex Data bank used in harmonization of MRL in many tea importing countries and at national level More compounds are targeted for data generation Country regulations on MRL are updated Tea brew data for residue generated IPM in place

ACTIONS TAKEN on MRL Reviewing of WG Strategy A side line meeting of the Strategy Group was held at the time of 1 st Annual North American Tea Conference on 21 st Sept 2010 at Niagara Falls to develop ACTION PLANS To agree on vision for MRLs To identify major issues facing tea industry To agree the goals to tackle identified issues Annex 2 Action plans, goals are circulated

Annex 2: Identification of issues and goals (Minutes of Canada meeting) Key issuesGoal Responsibility Evolving pest pressures Develop and implement IPM strategies Dr. Chaudhuri & Sri Lanka? limited compounds to control pests/diseases new compounds and new control IPM strategies new pest problems faced each year - environment changes biocontrol, chemical ecology methods Lack of MRLs, non harmonised MRLs Obtain reclassification of tea as minor crop in JMPR to speed MRL setting for tea Prof. Chen only 1 MRL for tea in Canada obtain MRLs for chemicals in use in producing/consuming countries K. Donnelly

Annex 2: Identification of issues and goals (Minutes of Canada meeting) Key issuesGoal Responsibility compliance relies on a default MRL of 0.1, but could be taken away at any time more regulations for country of origin MRL is essential for chemicals being used rejection of shipments because of pesticides - lack of MRLs convergence of methodologies for MRL setting need to harmonise specific group of pesticides common agreed risk assessment process for tea

Annex 2: Identification of issues and goals (Minutes of Canada meeting) Key issuesGoal Responsibility continuous change of residue regulations - industry has to think ahead transparency of risk assessment processes in different countries loss of authorisation in EU - ensuring enough chemicals available to effectively fight pests Inconsistent viewpoint between producing and consuming countries on MRLs

Annex 2: Identification of issues and goals (Minutes of Canada meeting) Key issuesGoal Responsibility stringent MRLs in importing countries one global MRL for compounds desired Need more pesticides through CCPR, and for them to be adopted in other country legislation analytical issues - lower LOQs require specialist knowledge

Annex 2: Identification of issues and goals (Minutes of Canada meeting) Key issuesGoal Responsibility replacement of old chemicals/banning of old chemicals replacement programme to replace old/banned with new chemicals Dr. Chaudhuiri JMPR - Some current pesticides will be banned in 2-3 years (OP, triazole group) replacement of old chemicals done slowly replacement of old substances new compounds are slowly registered for use in producing country - accelerate some pesticides are banned, so can't obtain import MRL for tea

Annex 2: Identification of issues and goals (Minutes of Canada meeting) Key issuesGoal Responsibility health, safety, sustainability pesticide priority list based on sustainability, affordability and safety Thomas Henn Current MRLs not rational – transfer into brew most important reconsideration of risk assessment in Codex consumer sensibilities - don't want residues even if safe environmental impact - climate change & sustainability

Annex 2: Identification of issues and goals (Minutes of Canada meeting) Key issuesGoal Responsibility consumer perception - tea marketed on health sustainability of tea - environment, workers etc. people are starting to eat and cook with tea more emphasis on food safety official developments - evaluation of multiple residues in products tougher regulatory environment

Annex 2: Identification of issues and goals (Minutes of Canada meeting) Key issuesGoal communication among stakeholders an effective communication plan with stakeholders L. Roberge communication to the smallholder community set up an efficient communication tool for the relevant stakeholders media and consumer attention identify the relevant stakeholders tea small crop - low interest in tea by pesticide companies responsibility, implementation, monitoring, timely communication about regulatory changes development of a universal position statement

Q. 1. Pesticides with residue data in last 4 years ChinaIndiaJapanSri LankaKenya 10 ? Lcyhalothrin Bifentrin Thiamethoxan Copper compound Spyromesifen Thiacloprid Dimethoate Glyphosphate Bifenazate Clothianidin Propiconazole Hexaconazole 2,4-D Sulphur (2 trials only)Copper Bitertanol Propiconazole Tebuconazole Chlorofluazuron Imidacloprid Copper hydroxide Bitertanol Propiconazole Tebuconazole Imidacloprid Chlorfluazuron Bitertanol Copper Oxychloride

Q. 2. Current Pesticide use in tea ChinaIndiaJapanSri LankaKenya 10 ?1850?8 Ethion Dicofol Glyphosate Fenazaquin Propergate Deltamethrin Fenpropathrin Fenpyroximate Hexythazox Propiconazole ……….. Insecticide Miticide Fungicide Copper Bitertanol Propiconazole Tebuconazole Chlorofluazuron Imidacloprid Copper hydroxide Bitertanol Propiconazole Tebuconazole Imidacloprid Chlorfluazuron Bitertanol Glyphosate Dicofol Sulphur Al phosphide Glufosinate Am. Chlorpyrifos Endosulfan paraquat

Q.3. Regulatory position of pesticide use ChinaIndiaJapanSri LankaKenya Min. Agril. Pesticides Regulations CIB / RC FSSAI All Regulatory Bodies of GOI Registration with Min. Agril., Forest and Fisheries. MRL fixation by MOH, Lab. Welfare. Regulatory Body of the Govt. Kenya Standard Guide on MRL.

Q.4. Position of IPM ChinaIndiaJapanSri LankaKenya Dependent on bio formulations PP, GOI Bio Control, Natural Enemies, safer molecules, Plant origin formulations. Food and Agril. Materials Inspection Centre Using herbal formulations Monitored by Govt.

Q.5. Pesticide Related issues Need for Harmonization of MRL with different agencies like EU, CODEX. Harmonization of MRL with tea imported countries. Constraint in sudden change of MRL status and loss of authorization

Q.6 Exchange of MRL data ChinaIndiaJapanSri LankaKenya Submitted some data to CODEX Data for 6 compounds submitted to CODEX Support data for MRL fixation to Canada, Australia, EU. Short of number of trials Data for 6 compounds submitted to CODEX. Data for one chemical submitted to CODEX.

Q.7 Latest regulatory position on MRL in tea ChinaIndiaJapanSri LankaKenya Govt. Regulation. CIB/RC regulation. New FSSAI 2006 Food Safety Standard. MHLW – Guideline for application for establishment and revision of MRL. Govt. Regulation. Kenya Borough of Standard

SUMMARY 1. Most of the tea producing countries are now equipped with residue lab and man power to generate residue data on tea. 2. Voluminous residue data have been generated by China, India, Sri Lanka. Others are attempting to equip in the near future. 3. Generic pesticides are gradually withdrawn, substituting by new generation compounds. 4. Pesticide load on tea have reduced in the recent years by adopting IPM measures. 5. Bio-control measures like herbal, microbial formulations are now widely used in tea. Entomopathogens, pheromons are also being tried successfully.

SUMMARY 6. Rotational use of different pesticides and bio-agents for controlling pests and diseases are integral part of IPM in most of the countries. 7. Information on pesticides use in tea in different countries with MRL are now available as transparent information. 8. National Regulators for MRL are active to update approved lists with MRL. 9. Tendency to generate residue data both on dry tea and brew is growing.

CONSTRAINTS 1. Lack of harmonization is confusing the producers and the trade. 2. For healthy growth of the tea trade, impediments like new regulations for MRL in the importing countries are creating confusion, also cost of production is increasing. 3. Exchange of information on MRL supported by realistic field data base is required. 4. More active participation of producers and importers in functioning of this WG is needed.

CONCLUSION 1. Ongoing programmes of data generation, submission to National Regulators and to CODEX should continue. 2. Countries not well equipped with data base and infrastructure may strengthen their venture to support the industry scientifically. 3. Exchange of information on residue and prompt compilation of database will help IGG Working Group. 4. Existing programmes should continue after formulation of action plans as per identified areas listed in Annex-2 of the Strategy Group Meeting held in Canada in September, 2010.

ACKNOWLEDGEMENT THANKS are due to co-operations of scientists from the Producing & Consuming countries. I acknowledge support from IGG secretariat, particularly from Mr. K. Chang and my co-chair Ms K. Donnelly. Thankful to Indian Groups from TRA, UPASI-TRF and the Authorities from the MOC&I, GOI, Tea Board, particularly, Mr. M. R. Sharma and Ms R. Sen, DC, and Tea industry for full support.