Strategies for Success

A Comprehensive Approach

Strategies for Success: A Comprehensive Approach

This e-book outlines strategies for meeting and maintaining pesticide MRL compliance when expanding to new markets, including how to develop a comprehensive market entry plan and how to prioritize testing leveraging a risk-based approach.

Develop a Market Entry Plan

Developing a Market Entry Plan is essential to mitigate risks and streamline processes when expanding to new markets.

This involves identifying target markets for exports and conducting in-depth research on the market policies, regulatory bodies involved, enforcement protocols and more.

This section outlines critical components of a comprehensive Market Entry Plan.

Download our Market Entry Checklist

Understand Applicable MRLs

Pesticide MRLs are the highest legal levels of pesticide residue allowed in food commodities and processed products. It is critical to comply with the pesticide MRLs applicable to your products within your target markets.

The regulatory landscape surrounding pesticide MRLs can be dynamic. Certain countries, such as the U.S., EU, Brazil, Japan, South Korea, and Canada, are known for frequent amendments to their MRLs. These changes can reflect new scientific data, evolving risk assessments, or international harmonization efforts. Keeping abreast of these updates is crucial to maintain compliance with the latest regulations.

Understand Traceability and Recordkeeping Requirements

Research the traceability and recordkeeping requirements for your products. You may be required to maintain detailed documentation regarding pesticide application history, sourcing information, and storage conditions.

Understand Labeling Requirements

Familiarize yourself with the labeling requirements for your exported products in the target market.

Identify Prohibited Pesticides

Identify any pesticides completely banned in your target markets.

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Ensure Representative Sampling and Alignment with Government Protocols

Companies must prioritize representative sampling. This involves considering both sample location (e.g., prioritizing outer leaves over inner core) and sample size (larger samples improve detection of trace resues).

They must also understand the specific sampling protocols outlined by the importing country. Following these government-mandated procedures, which might dictate the exact part of the commodity to be analyzed, is crucial.

Any deviations could introduce discrepancies and potentially lead to misleading data or non-compliance findings.

Utilize Trusted Service Providers

Collaborate with reliable logistics and customs brokers experienced in navigating the specific import requirements for food products in the target market. Establish relationships with accredited testing laboratories in both your exporting country and potentially the target market to ensure efficient and reliable pesticide residue analysis.

Research the Regulatory Structure

It is important to understand the regulatory structure of your target markets.

This includes the government agencies involved with setting the MRLs and related matters such as the registration, sale, and use of pesticides. View the table on the next page for examples of regulatory bodies responsible for setting MRLs for pesticides.

It is also critical to identify the agencies responsible for the monitoring and enforcement of MRL policies of your target markets, and any enforcement or violation policies in place.

Strategies for Success: A Comprehensive Approach

Default Limit or Zero Tolerance Policies

Understand how countries handle situations where no specific MRL exists for a particular pesticide-commodity combination. Some countries implement a "default limit" policy. This policy establishes a pre-determined level, often around 0.01 ppm, as the maximum allowable residue for any pesticide-commodity combination where no specific MRL exists. Alternatively, some countries operate under a "zero tolerance" policy, meaning no detectable residue is permitted in the absence of an MRL.

Understanding these policies helps determine whether the absence of a specific MRL for a particular combination automatically signifies non-compliance.

Deferral Policies

Identify if Your Target Markets Use a Deferral Policy:

Many nations, particularly those with less-developed regulatory frameworks, defer to established MRLs set by other countries or international bodies.

The three primary benchmarks in this system are the European Union (EU), the United States (U.S.), and Codex Alimentarius, a joint program by the Food and Agriculture Organization (FAO) and the World Health Organization (WHO).

Companies exporting food products should determine which benchmark a target country adopts to ensure they are referencing the appropriate MRLs.

Region / Country	Regulatory Body
United States	The Environmental Protection Agency (EPA) sets MRLs for pesticides in both human food and animal feed.
Canada	Health Canada’s Pest Management Regulatory Agency (PMRA) sets MRLs for pesticides.
South America	Varies by country. Notable examples include Brazil’s National Health Surveillance Agency (ANVISA) and Argentina’s National Service of Agri-Food Health and Quality (SENASA).
Europe	The European Commission sets MRLs for all member states and implements laws on food safety and quality. The European Food Safety Authority (EFSA) conducts risk assessments for the establishment of MRLs and contaminant limits.
Asia	Varies by country. Notable examples include China’s Ministry of Agriculture and Rural Affairs, South Korea’s Ministry of Food and Drug Safety (MFDS), and the Food Safety and Standards Authority of India (FSSAI).
Africa	Varies by country. Notable examples include South Africa’s Department of Health and Department of Agriculture, Land Reform, and Rural Development (DALRRD), and Zimbabwe’s Ministry of Health and Child Care (MOHCC).