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SUMMARY OF SUBMISSIONS RECEIVED ON PROPOSED AMENDMENT NO. 3 TO THE NEW ZEALAND (MAXIMUM RESIDUE LIMITS OF AGRICULTURAL COMPOUNDS) FOOD STANDARDS 2008

From 10 March – 11 May 2009 NZFSA consulted on a proposed amendment (No.3) to the New Zealand (Maximum Residue Limits of Agricultural Compounds) Food Standards 2008 (MRL Food Standards). Four submissions were received by NZFSA.

Note that the consolidated New Zealand (Maximum Residue Limits of Agricultural Compounds) Food Standards 2009 came into effect on 9 July 2009 and is available on the NZFSA website: http://www.nzfsa.govt.nz/policy-law/legislation/food-standards/index.htm

Below is the summary of submissions, including the proposal, the submitter/s, their comments and NZFSA’s response.

Proposal

Submitter

Comments

NZFSA Response

Methomyl

Industry Association

It was requested that, in an effort to reduce impediments to trade, NZFSA consider establishing a separate Methomyl MRL for table grapes that is harmonized with the forthcoming U.S. tolerance of 1.5ppm.

Under the provisions of the MRL Food Standards, imports may contain residues that are no greater than the MRLs specified for that food in the current editions or supplements of the FAO/WHO Codex Alimentarius Commission (Codex) publications entitled “Pesticide Residues in food” or “Residues of Veterinary Drugs in Foods”. In this case, Codex has an MRL of 5mg/kg for Methomyl in grapes which will cover any imports coming in at or below the U.S. tolerance.

General.

Foreign government.

It was questioned whether or not New Zealand accepts products conforming to MRLs set by the Codex Alimentarius Commission (Codex).

It was also requested that New Zealand consider accepting the U.S. (export) MRL where no Codex MRL exists.

Currently the New Zealand MRL Standards only formally recognises international MRLs established by the Codex Alimentarius Commission in imported food commodities. However NZFSA bases its acceptance of residues in imported food on risk, and has the potential to take the credibility of standards set to strong scientific principles by other regulatory systems into account. Amendments to proposed MRLs had been made in the past on a case by case basis to mitigate potential restrictions to trade.

NZFSA saw potential benefit in the concept of harmonisation and sought clarification from the submitting party as to the degree with which this would occur.

Spinosad

Industry association

It was requested that an MRL for Spinosad of 0.10 mg/kg when used on grapes be included in the amendment. The current MRL for Spinosad when used on grapes is the default level, which is 0.10 mg/kg.

Although the MRL for Spinosad when used on grapes (0.10 mg/kg) is the same as that requested. The new MRL is not being included in this current consolidation as it has not been consulted on. NZFSA can expressly state a new MRL as requested in the next amendment to the MRL Standards 2009.

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