Comparative Analysis of Domestic and Foreign MRL Standards for Pesticides in Tea

In recent years, as our country’s tea export trade volume has increased year by year, the problem of pesticide residues in tea has become a hot topic. Especially in recent years, the problem of excessive pesticide residues in exported tea has seriously affected the competitiveness of our country’s tea in the international market.


The article briefly explains the current situation of our country’s tea export. On this basis, this article intends to compare and analyze the tea pesticide maximum residue limit standards between our country and major exporting countries and regions, and clarify their differences, so that our country can revise and formulate the tea pesticide maximum residue limits in the future. Refer to the residue limit standards. At the same time, it provides a reference for the rational use of pesticides, ensuring the quality and safety of tea exports, and thus effectively reducing international trade disputes in tea.


In the future, our country needs to consider the actual use of pesticides in tea trees, further improve the standard system related to tea quality and safety, and bring it in line with relevant international standards to improve the competitiveness of our country’s tea in the international market. This is of great significance for breaking international technical trade barriers, promoting technological innovation of enterprises, and improving the quality and safety of tea.


Maximum Residue Limits (MRL)

The maximum residue limit (MRL) mainly refers to the maximum legally allowable residue concentration of pesticides in agricultural products, food, and feed. It is one of the important technical indicators for judging the quality and safety of agricultural products. At the same time, as a non-tariff measure, the pesticide MRL standard is generally considered a technical trade measure to protect the safety of the domestic agricultural industry.


Our country’s pesticide MRL standard is GB2763 “National Food Safety Standard Maximum Residue Limits of Pesticides in Food”. This standard was first promulgated and implemented in 2005. It has been revised many times. The latest version is GB 2763-2021. There is currently little comparative analysis between the current GB2763 and foreign pesticide MRL standards, and there are also few related studies on the impact of pesticide MRL standards on tea export trade.


  1. Status of MRL standards for pesticides in Chinese tea

Our country’s current GB 2763-2021 stipulates 106 pesticide MRLs in tea, including 79 formal limits and 27 temporary limits. On November 11, 2022, GB 2763.1-2022 “National Food Safety Standard Maximum Residue Limits of 112 Pesticides including 2,4-D Butyrate Sodium Salt in Foods” was supplemented and released as the first supplement to GB 2763-2021. Improved, this standard newly stipulates the MRL values of four pesticides in tea in our country. Therefore, the total number of MRL regulations for pesticides in tea in our country has reached 110.


As of June 2023, there are 70 main pesticide active ingredients registered for use on tea trees. Among them, only 46 have limited limit requirements or are included in the exemption list in GB 2763-2021. Other registered pesticides have no limit requirements. Compared with GB 2763-2019, 42 new pesticides have been added to GB 2763-2021, and 42 pesticide MRL indicators have been added accordingly. Most of these pesticides are highly toxic, and the general MRL value is 0.05 mg/kg or 0.1 mg/kg.


Up to now, among the 110-tea pesticide MRLs stipulated in our country’s current standards, 30 pesticides are banned for tea trees, and the MRL values of these pesticides are low. There are 53 pesticides with MRL values of 0.05mg/kg and below, and the MRL values of some pesticides are close to the quantitation limits of corresponding detection methods, which further shows that our country’s supervision of pesticide residues in tea has become more stringent.


  1. Status of CAC MRL standards for pesticides in tea

The Codex Alimentarius Commission (CAC) was jointly established by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO) to protect consumer health and fair food trade. The International Foods Association promulgated by it has been widely adopted as an international standard. According to statistics, there are 30 indicators related to the MRL of tea pesticides formulated by CAC.


Compared with CAC, our country’s existing 24 pesticides and CAC have residue limit requirements, accounting for 21.8% and 80% of the total pesticide MRL indicators in tea in our country and CAC respectively. There are 86 pesticides with limited limits in our country but not in CAC; there are 6 pesticides (boscalid, bromantraniliprole, acetifenate, fenfenpyr, flufenamide and spirofenipate) with limited limits in CAC requirements but our country does not. Among them, our country’s MRL regulations for eight pesticides, including dicofenil, imidacloprid, dicofol, buprofen, thiamethoxam, emamectin benzoate, bifenthrin, and fenfosate, are stricter than CAC. ; The MRL standards of 9 pesticides, including permethrin, fluflubenzuron, and endosulfan, are the same as those of CAC; in addition, the MRL standards of 7 pesticides, including pyraclostrobin, pyraclostrobin, and deltamethrin, are looser than those of CAC.


  1. Status of EU MRL standards for pesticides in tea

The EU is one of the regions in the world with stricter MRL requirements for tea pesticides. Since 2000, EU regulations on tea have been frequently released and adjusted, and the update or revision cycle is generally 1 to 2 months. At the beginning of 2014, the European Commission issued the “Maximum Residue Limits for Pesticides in Food and Feed of Plant or Animal Origin”. In January 2021, the European Food Safety Authority (EFSA) recommended lowering the MRL standard for glyphosate in 153 agricultural products such as tea from 0.1~50mg/kg to the limit of quantitation 0.05mg/kg. In November of the same year, it was decided not to continue approving the pesticide active substance humiocarb, and planned to adjust the MRL value of humiocarb in the next step.


As of July 2023, there are 511 pesticide residue limit indicators in the EU involving tea. The EU implements “uniform limit” (0.01mg/kg or the quantitative limit of the detection method) for unregulated pesticides.


Compared with the EU, China currently has 71 pesticides that have residue limit requirements with the EU, accounting for 64.5% and 13.9% of the total MRL indicators of pesticides in tea in China and the EU respectively. Among them, China has stricter limits on 18 pesticides such as glyphosate and pyrofenadil than the EU. For example, the limit standards for dicofol are 2,000 times different; 15 pesticides such as chlorpyrifos and methamidophos have the same limit value. In recent years, China has not yet formulated residue limit standards for anthraquinones, acaricides and other pesticides in tea exported to Europe.

  1. Status of pesticide MRL standards in U.S. tea

The U.S. MRL standards are mainly set by the U.S. Environmental Protection Agency (EPA), which decided to reassess the residues of newly registered pesticides every 15 years starting from 2002. The U.S. Food and Drug Administration (FDA) provides regulations for unavoidable pesticide residues in food and feed in the Compliance Policy Guidance (CPG sec. 575.100). As of July 2023, the United States has set limits on 44 pesticides in tea, and other pesticides are prohibited from detection.


Compared with the United States, there are 19 pesticides with limited requirements in China and the United States, accounting for 17.3% and 43.2% of the total pesticide MRL indicators in tea in China and the United States respectively. Among them, China has stricter limits than the United States on 12 pesticides in tea, including fenzoquinone, acetamiprid, and dicofol. For example, the limit standards for dicofol differ by up to 5,000 times; the limit values for glyphosate, etoxazole, fenacetate, and permethrin are the same; and the limit requirements for fenfenzofen, fenpropathrin, and acebuprofen are looser than those in the United States. Compared with the United States, China has not announced or established its limit standards for tea pesticides, including 25 kinds of pesticides, such as fenfenzofen, trifloxystrobin, and propargite.


  1. Status of pesticide MRL standards in Japanese tea

In 2003, Japan revised the Food Hygiene Law and planned to establish a positive list system for pesticides in food, stipulating maximum residue limits for chemical drugs in food. In 2006, Japan officially implemented the “Positive List System of Pesticide Residues in Food” to manage all agricultural chemicals (including pesticides, veterinary drugs, food additives, etc.) in all foods. The positive list system involves more than 800 agricultural chemicals such as pesticides, veterinary drugs, and food additives, and has formulated more than 50,000 MRL indicators. As of July 2023, Japan’s positive list system has as many as 235 limit clauses involving tea, which is 2.14 times the limit number in our country. Pesticides without specified MRL values are implemented in accordance with the “uniform standard” of 0.01mg/kg.


Compared with Japan, there are 60 pesticides with limited requirements in our country and Japan, accounting for 54.5% and 25.5% of the total pesticide MRL indicators in tea in our country and Japan respectively. Among them, the limit requirements for 33 pesticides in our country, including acephate, fenzoquinone, acetamiprid, and dicofol, are stricter than those in Japan. For example, the limit standards for fenzofenone are 4,000 times different; atrazine, chlorothalonil, DDT, etc. The limit values of 14 pesticides are the same, and the limit requirements of 13 pesticides such as bentazone and bifenthrin are looser than those in Japan. Compared with Japan, there are 175 pesticides in our country that have not yet announced or formulated their limit standards for tea.


  1. Status of MRL standards for pesticides in Moroccan tea

In 2015, Morocco promulgated the Decree No. 156-14 of the Minister of Agriculture and Marine Fisheries and the Minister of Health of Morocco on Pesticide Residues in Agricultural Products and Food. The decree is based on the CAC’s MRL standard and stipulates the maximum allowable limit of pesticide residues in primary products and foods, and stipulates that the MRL of other unlisted pesticides shall not exceed the 0.01mg/kg limit. Morocco has implemented the latest pesticide residue limit standards for tea since 2019. It issued a supplementary announcement in early July of the same year, adjusting the implementation time of the new standards to October 1. The notice involves 60 pesticide residue items, and it is specifically mentioned that the MRL of pesticides not included in the notice will implement a maximum limit or minimum limit of detection (LOD) of 0.01mg/kg.


Compared with Morocco, there are 56 pesticides in our country and Morocco that have limited limits, accounting for 50.9% and 93.3% of the total pesticide MRL indicators in tea in our country and Morocco respectively. Among them, the limit requirements for 11 pesticides such as glyphosate, dicofonil, and dicofol in our country are stricter than those in Morocco. For example, the limit standards for dicofol are 4,000 times different; the limits for 15 pesticides including paraquat, profenofos, and terbufos are the same; in addition, the limit requirements for 30 pesticides are looser than those in Morocco. Compared with Morocco, our country has not announced or formulated its limit standards for four pesticides in tea: fenpyrpyrofen, flufenamid, acetifenate and spirofenipate.


In summary, it can be concluded that as of July 2023, the number of pesticides MRL indicators in tea stipulated by our country is more than that of CAC, the United States and Morocco, but less than that of the European Union and Japan. In terms of comparison of limit values, the European Union has 38 pesticides with stricter limit standards than our country, the United States has only 3 pesticides that are stricter than our country, and the CAC has 7 pesticides that are stricter than our country. 50% of the pesticide MRL indicators in Morocco are stricter than our country, and 25% The indicator limit value is consistent with that of our country. Although the United States has lower requirements for pesticide residues in imported tea, its regulations stipulate that pesticides that do not have a set limit must not be detected, which is generally stricter than our country’s pesticide MRL values. In addition, the European Union, Japan, and Morocco all require “uniform standards” for pesticides that are not included in the testing scope, which further widens the gap between our country and its tea pesticide residue limit standards. In short, our country’s tea pesticide residue limit standards are gradually in line with international standards, and some indicators are even stricter than international standards. However, compared with the European Union, Japan and other countries and regions, there is still a gap.


Countermeasures and suggestions to deal with technical barriers to pesticide residues in tea


  1. Improve the tea-related quality and safety standard system

Although our country has stipulated MRLs for 110 pesticides in tea, the detection methods for some pesticides such as glufosinate, terbufos, and chlorothioline have not yet been listed. Moreover, some pesticides (such as acetamiprid, carbendazim, etc.) are measured with reference to the detection methods for fruits and vegetables, and the method is not adaptable. There are also some pesticides (such as paraquat, glyphosate, etc.) that are tested based on industry standard methods, and the mandatory standards have been weakened. Therefore, it is recommended to establish and improve a standard system for pesticide residue testing methods that is consistent with the quality and safety of our country’s exported tea.


  1. Actively participate in the formulation of CAC standards

In the formulation of CAC standards, our country should actively participate and play a role. Active participation in the formulation of CAC standards is one of the keys to our country’s important role in global tea trade and food safety. Through in-depth research, tracking trends, cultivating technical teams, and actively participating in activities, our country can better participate in and influence the formulation of international food standards and protect our country’s tea trade interests and consumer rights.


  1. Use pesticides scientifically and rationally

The scientific and rational use of pesticides is an important measure to ensure that tea quality meets export requirements. Since various countries have different regulations on the MRL of pesticides in tea, pesticides with no regulations or looser standards, low toxicity, and low residues can be used to avoid the risk of technical trade barriers.

Scientific and rational use of pesticides, promotion of pollution-free tea cultivation technology, and green prevention and control measures can reduce the risk of excessive pesticide residues, ensure the quality and safety of tea, and ensure the quality of tea exports.


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