Food Law News - EU - 2000
FSA Letter, 29 September 2000
RESIDUES - Commission Proposals to Prohibit Certain Pesticides in Agricultural Products Used to Manufacture Infant Formula, Follow-on Formula and Baby Foods
A Commission Working Group met on 13 September to consider proposals for directives which would have the effect of requiring infant formula and baby foods to be produced without the use of certain pesticides. The FSA letter provides a brief outline of the main points which emerged in discussions and invites any further comments.
There was broad support for the proposals although practical problems for monitoring and enforcement were evident.
The Commission agreed to consider:
- risk assessment data from a member State and industry representatives, which purport to show that exposure to some pesticides is well below the ADI (0.005 mg/kg bw/day) and therefore specific limits for these pesticides might be set for the final foodstuff, rather than a blanket ban on their use in raw agricultural products. The pesticides are cadusofos, monocrotophos, fipronil, ethoprophos, and fentin.
- whether the directives would apply to the use of these pesticides as seedcoatings, or on animal feedingstuffs. This would place a significant additional burden on manufacturers and enforcement bodies;
- how pesticides for which the Acceptable Daily Intake (ADI) had been withdrawn by the Joint Meeting of Pesticide Residues should be dealt with
- simplification of the directives by replacing those pesticides which are already prohibited for use in Europe with a reference to directive 79/117/EEC. It was not clear whether such an approach would be sufficient to cover products imported from outside the European Community; the Commission agreed to investigate this with their legal services;
- extending the coming into force date of the directive to the end of 2002, to take into account practical difficulties relating to crop growing seasons and the long shelf-life of products.
The Commission would not accept proposals that a limit of 0.01 mg/kg would generally be sufficient for pesticides which have an ADI of 0.0005 mg/kg bw/day, for example, carbophenothion.
A number of minor amendments to the texts were agreed. These are as follows:
- An explanation as to why Probineb is included in the Annex will be added; Probineb has an ADI above the 0.0005 threshold, but it yields a highly toxic metabolite with an ADI of just 0.0003 mg/kg bw/day;
- Paragraph 2 (SANCO/967/2000 - rev I only) will be amended to reflect the provisional nature of the 0.01 mg/kg limit for baby foods. Appropriate wording from the fourth whereas clause of directive 1999/50/EC will be included in the texts.
- The entry for demeton-S-methyl will be combined with that for oxydemeton-methyl, and a reference to demeton-S-methyl sulfone added;
- The title to the tables in the Annexes will be amended to read "Pesticides which shall not be used in raw agricultural products directly intended for the production .. "
No further working groups are anticipated before the proposals are discussed at the Standing Committee for Foodstuffs, as a preliminary step before the proposals are voted upon.
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