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

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

3. 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

4. 2. EU pesticide policy relevant for our sector

5. 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)

6. Database on EU MRLs

7. 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.

8. Standard MRL review procedure (Article 12)

9. 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.

10. 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).

11. 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.

12. 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.

13. 3. FRUCOM project on pesticides

14. 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

15. 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

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

17. 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

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

19. 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

20. 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

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