Saskatoon, SK - Glyphosate residue on lentil could delay exports to the European Union (EU). gThe recent discovery of glyphosate residue on organic lentil imported into the EU from Turkey will have implications for Canadian exports of conventionally produced lentil to the EU,h says Garth Patterson, Executive Director of the Saskatchewan Pulse Growers. gTo our knowledge, no cargos of conventionally produced Canadian lentil have been affected at this time, however it has impacted trade,h says Gordon Bacon, CEO of Pulse Canada.
gOur concern is that the EU has a maximum residue limit (MRL) for glyphosate in lentil of 0.1 parts per million (ppm), compared to MRLfs for glyphosate in lentil of 4 ppm in Canada, and 5 ppm in the United States (U.S.),h says Patterson. gThe EU MRL for pea is 10 ppm or 100 times higher than the allowable limit for lentil. At an MRL of 50 ppm for mushrooms, the allowable level is 500 times higher than that allowed on lentil,h says Bacon. gThis variation in glyphosate MRLfs between crops and between countries creates confusion and impacts trade.h
Although glyphosate is registered for pre-harvest use on lentil in Canada, Canadian lentil exporters have to meet the import requirements of their customers. Moving forward, producers can expect that when selling their lentils they will need to declare their use of glyphosate and this may restrict their marketing opportunities in the future.
The Canadian pulse industry is currently working with the U.S. pulse industry to address this trade barrier. Canadian lentil exports to Europe exceeded $110 million in 2010.
Backgrounder
European Glyphosate Residue Tolerance on Lentils Pulse Canada]USA Dry Pea & Lentil Council Action Plan
Background
The use of crop protection products is strictly regulated and the approach taken is very similar in Canada, the USA, and the EU. The regulations are designed to ensure that human health considerations, environmental protection considerations and safe and effective use of these products in crops are all fully taken into consideration before their use is allowed through granting of a registration. The registration includes the establishment of a maximum residue limit (MRL) setting legal limits on the amount of the active ingredient that can be found on grains or fresh produce harvested from the crop on which the crop protection product is registered for use.
In recent years, Canada, the USA and the EU have worked to jointly review applications for registration of new crop protection products, taking a more harmonized approach to the establishment of MRLs. Countries have also moved toward the use of more groupings of similar crops.
With previous registrations of crop protection products, crop to crop variations in MRLs were more common, and country to country variations in MRLs were also common as regulators took different approaches to the establishment of MRLs. This is well illustrated by looking at the active ingredient glyphosate, and the approaches taken in Canada, the USA, and Europe.
In the USA, lentils, beans and chickpeas share a MRL of 5 parts per million (ppm) while dry peas have an MRL of 8 ppm. In Canada, the MRL for lentils is set at 4 ppm, and the Canadian MRL for peas is set at 5 ppm. In Europe, the MRL for peas is set at 10 ppm, while the MRL for lentils is set at 0.1 ppm. The allowable level of glyphosate residue on mushrooms in the EU is 50 ppm, or 500 times higher than that allowed on lentils.
Variations in residue tolerance levels between jurisdictions create challenges for the pulse trade. While the application of glyphosate for pre]harvest weed control is registered in Canada and the USA with tolerances for glyphosate on lentils set at 4 and 5 ppm respectively, lentils from fields where glyphosate was used will be very unlikely to meet the EU MRL of 0.1 ppm. The lentil industry in North America must work to address this technical trade barrier to prevent it from further impacting lentil trade to Europe. North American lentil trade to Europe in 2010 exceeded $110 million in value.
The Action Plan
The presence of glyphosate residues that exceed the EU tolerance for lentils must be considered in the context of what is deemed to be acceptable levels in other foods in Europe. For example, glyphosate is tolerated at 500 times higher in mushrooms and 100 times higher in wheat, canola and peas in Europe versus the EU tolerance for lentils. In effect the EU has set an MRL tolerance level on lentils that is 1/40th of the level in Canada and 1/50th of the level in the USA..
The Canadian and USA lentil industries are working together on several initiatives to address the trade challenge that is presented by the current disparity in EU, Canadian and U.S. tolerances for glyphosate on lentils. The Canadian and USA industries are confident that their products pose no unacceptable risk to EU consumers and are taking the following actions to ensure that North American lentil producers can continue to supply Europe with high quality products.
1. Submission of data to EU authorities to request a new import tolerance for glyphosate in lentils: Submission to EU authorities of an application for an import tolerance for glyphosate on lentils, including relevant data: The Canadian and USA pulse industries, along with the Environmental Protection Agency (EPA), Pest Management Regulatory Agency (PMRA) and crop protection manufacturers, are preparing a data package that will be submitted to EU authorities as part of the request for review and establishment of an MRL for glyphosate in lentils in the EU. We will work closely with EU authorities to seek a timely, science]based response to the application. We know that under normal circumstances the EU review process may take one year or more.
2. Customer communications: Pulse Canada and the USA Dry Pea & Lentil Council are working together to ensure that pulse buyers in Europe are aware of the actions being taken, and the timelines for outcomes, related to the issue of glyphosate residues in lentils. This effort includes meetings with individual companies, as well as a discussion of the issue at the international convention to be held in late April in Europe.
3. Collaboration with other International bodies: Pulse Canada and the USA Dry Pea & Lentil Council will collaborate with bodies such as GAFTA (Grain and Feed Trade Association), CICILS]IPTIC (International Pulse Trade and Industry Confederation) and others to identify and take steps to address actual and potential challenges posed by pesticide tolerances and trade in pulses.
4. Expanded testing of the 2010 crop: There is limited capacity to test for glyphosate residues in laboratories with experience and expertise to ensure accurate and repeatable results. The Canadian and USA pulse industries have started to expand testing, and are working to ensure sufficient laboratory capacity so that samples can be assessed in a timely fashion.
5. Expanded research to identify and implement new crop protection strategies that meet EU requirements: The North American pulse industry is expanding its research program in 2011 to look at new chemistry to be registered in Canada and the USA, and other management approaches to ensure that residue levels are minimized as part of the ongoing approach to reduce risk associated with crop protection, including the interaction of genetics, management, and use of crop protection products.
6. Ongoing grower communications: Pulse grower organizations in Canada and the USA are in regular contact with growers to share information regarding tolerance levels in lentil markets, changes to contracting, and methods to reduce residue levels through combinations of management, varietal selection and use of appropriate crop protection products.
7. Action to establish an MRL at CODEX ALIMENTARIUS: CODEX is the international body established by the UNfs World Health Organization (WHO) and Food and Agriculture Organization (FAO) to establish internationally recognized values, including MRLs. The Canadian and US pulse industry will work with their respective governments to ensure that CODEX fully considers the value of a glyphosate tolerance for pulses that facilitates trade, as well as the value of crop groupings in its approach.
8. Availability of alternate weed control and desiccant products: Pulse Canada and the USA Dry Pea & Lentil Council are working with the crop protection industry to identify alternate crop protection products that meet domestic and export country tolerances. We are diligently working to ensure that alternative products are available to North American growers and that growers have all relevant information to make informed decisions regarding crop protection options.
Source: Saskatchewan Pulse Growers
gOur concern is that the EU has a maximum residue limit (MRL) for glyphosate in lentil of 0.1 parts per million (ppm), compared to MRLfs for glyphosate in lentil of 4 ppm in Canada, and 5 ppm in the United States (U.S.),h says Patterson. gThe EU MRL for pea is 10 ppm or 100 times higher than the allowable limit for lentil. At an MRL of 50 ppm for mushrooms, the allowable level is 500 times higher than that allowed on lentil,h says Bacon. gThis variation in glyphosate MRLfs between crops and between countries creates confusion and impacts trade.h
Although glyphosate is registered for pre-harvest use on lentil in Canada, Canadian lentil exporters have to meet the import requirements of their customers. Moving forward, producers can expect that when selling their lentils they will need to declare their use of glyphosate and this may restrict their marketing opportunities in the future.
The Canadian pulse industry is currently working with the U.S. pulse industry to address this trade barrier. Canadian lentil exports to Europe exceeded $110 million in 2010.
Backgrounder
European Glyphosate Residue Tolerance on Lentils Pulse Canada]USA Dry Pea & Lentil Council Action Plan
Background
The use of crop protection products is strictly regulated and the approach taken is very similar in Canada, the USA, and the EU. The regulations are designed to ensure that human health considerations, environmental protection considerations and safe and effective use of these products in crops are all fully taken into consideration before their use is allowed through granting of a registration. The registration includes the establishment of a maximum residue limit (MRL) setting legal limits on the amount of the active ingredient that can be found on grains or fresh produce harvested from the crop on which the crop protection product is registered for use.
In recent years, Canada, the USA and the EU have worked to jointly review applications for registration of new crop protection products, taking a more harmonized approach to the establishment of MRLs. Countries have also moved toward the use of more groupings of similar crops.
With previous registrations of crop protection products, crop to crop variations in MRLs were more common, and country to country variations in MRLs were also common as regulators took different approaches to the establishment of MRLs. This is well illustrated by looking at the active ingredient glyphosate, and the approaches taken in Canada, the USA, and Europe.
In the USA, lentils, beans and chickpeas share a MRL of 5 parts per million (ppm) while dry peas have an MRL of 8 ppm. In Canada, the MRL for lentils is set at 4 ppm, and the Canadian MRL for peas is set at 5 ppm. In Europe, the MRL for peas is set at 10 ppm, while the MRL for lentils is set at 0.1 ppm. The allowable level of glyphosate residue on mushrooms in the EU is 50 ppm, or 500 times higher than that allowed on lentils.
Variations in residue tolerance levels between jurisdictions create challenges for the pulse trade. While the application of glyphosate for pre]harvest weed control is registered in Canada and the USA with tolerances for glyphosate on lentils set at 4 and 5 ppm respectively, lentils from fields where glyphosate was used will be very unlikely to meet the EU MRL of 0.1 ppm. The lentil industry in North America must work to address this technical trade barrier to prevent it from further impacting lentil trade to Europe. North American lentil trade to Europe in 2010 exceeded $110 million in value.
The Action Plan
The presence of glyphosate residues that exceed the EU tolerance for lentils must be considered in the context of what is deemed to be acceptable levels in other foods in Europe. For example, glyphosate is tolerated at 500 times higher in mushrooms and 100 times higher in wheat, canola and peas in Europe versus the EU tolerance for lentils. In effect the EU has set an MRL tolerance level on lentils that is 1/40th of the level in Canada and 1/50th of the level in the USA..
The Canadian and USA lentil industries are working together on several initiatives to address the trade challenge that is presented by the current disparity in EU, Canadian and U.S. tolerances for glyphosate on lentils. The Canadian and USA industries are confident that their products pose no unacceptable risk to EU consumers and are taking the following actions to ensure that North American lentil producers can continue to supply Europe with high quality products.
1. Submission of data to EU authorities to request a new import tolerance for glyphosate in lentils: Submission to EU authorities of an application for an import tolerance for glyphosate on lentils, including relevant data: The Canadian and USA pulse industries, along with the Environmental Protection Agency (EPA), Pest Management Regulatory Agency (PMRA) and crop protection manufacturers, are preparing a data package that will be submitted to EU authorities as part of the request for review and establishment of an MRL for glyphosate in lentils in the EU. We will work closely with EU authorities to seek a timely, science]based response to the application. We know that under normal circumstances the EU review process may take one year or more.
2. Customer communications: Pulse Canada and the USA Dry Pea & Lentil Council are working together to ensure that pulse buyers in Europe are aware of the actions being taken, and the timelines for outcomes, related to the issue of glyphosate residues in lentils. This effort includes meetings with individual companies, as well as a discussion of the issue at the international convention to be held in late April in Europe.
3. Collaboration with other International bodies: Pulse Canada and the USA Dry Pea & Lentil Council will collaborate with bodies such as GAFTA (Grain and Feed Trade Association), CICILS]IPTIC (International Pulse Trade and Industry Confederation) and others to identify and take steps to address actual and potential challenges posed by pesticide tolerances and trade in pulses.
4. Expanded testing of the 2010 crop: There is limited capacity to test for glyphosate residues in laboratories with experience and expertise to ensure accurate and repeatable results. The Canadian and USA pulse industries have started to expand testing, and are working to ensure sufficient laboratory capacity so that samples can be assessed in a timely fashion.
5. Expanded research to identify and implement new crop protection strategies that meet EU requirements: The North American pulse industry is expanding its research program in 2011 to look at new chemistry to be registered in Canada and the USA, and other management approaches to ensure that residue levels are minimized as part of the ongoing approach to reduce risk associated with crop protection, including the interaction of genetics, management, and use of crop protection products.
6. Ongoing grower communications: Pulse grower organizations in Canada and the USA are in regular contact with growers to share information regarding tolerance levels in lentil markets, changes to contracting, and methods to reduce residue levels through combinations of management, varietal selection and use of appropriate crop protection products.
7. Action to establish an MRL at CODEX ALIMENTARIUS: CODEX is the international body established by the UNfs World Health Organization (WHO) and Food and Agriculture Organization (FAO) to establish internationally recognized values, including MRLs. The Canadian and US pulse industry will work with their respective governments to ensure that CODEX fully considers the value of a glyphosate tolerance for pulses that facilitates trade, as well as the value of crop groupings in its approach.
8. Availability of alternate weed control and desiccant products: Pulse Canada and the USA Dry Pea & Lentil Council are working with the crop protection industry to identify alternate crop protection products that meet domestic and export country tolerances. We are diligently working to ensure that alternative products are available to North American growers and that growers have all relevant information to make informed decisions regarding crop protection options.
Source: Saskatchewan Pulse Growers