October 2016

Codex MRLs—Use and Trends by Kimberly Berry, Director, Regulatory Data Services, Bryant Christie Inc.

International food standards are developed by the Codex Alimentarius which was established in
1963 by the Food and Agriculture Organization (FAO) of the United Nations and the World Health
Organization (WHO). The Codex international food standards, guidelines and codes of practice are
voluntary for countries to reference or employ as part of their national regulations.1 One of these is
the Codex standard for pesticide maximum residue levels (MRLs) in food and feed which is amended
each year by the Codex Committee on Pesticide Residues (CCPR).
In recent years there has been concern that an increasing number of countries are moving to establish their own national
policies, and away from using the Codex MRL standard. However, a survey of countries’ policies indicate that many
countries continue to make use of Codex MRLs, and that even for countries with a national standard, Codex MRLs continue
to play a role. The Codex MRL standard remains important, but the manner in which these MRLs are applied varies from
country to country.

Survey of Countries That Use Codex MRLs

Countries with a national MRL standard, but defer to Codex when a national MRL is not set. Some of these
countries also apply U.S., EU, and/or default MRLs in more complex MRL deferral decision trees.
Argentina Ethiopia Malaysia Saudi Arabia
Brazil French Polynesia Morocco Singapore
Brunei Israel Nepal South Africa
Chile Kenya New Zealand Thailand
Costa Rica Korea Philippines

Countries that defer to Codex, and also include deferrals to the U.S. and/or the EU.
Dominican Republic Honduras Paraguay
Egypt Panama United Arab Emirates

Countries without a national MRL list may fully defer to Codex.

Afghanistan Colombia Lebanon Sri Lanka
Angola Cuba Libya Sudan
Bahamas Curacao Malawi Syria
Bangladesh Ecuador Mozambique Tanzania
Barbados El Salvador Myanmar Trinidad & Tobago
Belize Fiji Nicaragua Tunisia
Bermuda Gambia Nigeria Uganda
Bolivia Ghana Pakistan Uruguay
Bosnia and Guatemala Peru Venezuela
Herzegovina Jamaica Senegal Zimbabwe
Cambodia Jordan Saint Maarten

Regardless of the policy direction favored, most countries at least use Codex MRLs as a reference point, and so the Codex
standard and process for setting new MRLs remain very relevant. Some recent examples of this include Hong Kong’s 2014
transition to a national standard; ongoing policy revisions in China and Indonesia; and proposed MRL standards recently
drafted by Vietnam and the Gulf Cooperation Council (GCC). The following chart demonstrates that a high percentage of
the total MRLs established (or proposed) for each of these countries are adopted Codex MRLs. The chart also indicates
the number of missing MRLs for each country as compared to total Codex MRLs. Both China and Indonesia still have many
Number of Codex MRLs Established
500
cases where no MRL has been established. This analysis 450

Count of Codex MRLs

400
uses pesticide MRL data from GlobalMRL.com for 229
350
pesticides and 628 commodities covered by the Codex 300
MRL standard. 250
200
150
% of National MRLs Harmonized with Codex 100
50
Vietnam GCC
Total Hong Kong China Indonesia (proposed) (proposed) 0
Codex ‘95 ‘96 ‘97 ‘98 ‘99 ‘00 ‘01 ‘02 ‘03 ‘04 ‘05 ‘06 ‘07 ‘08 ‘09 ‘10 ‘11 ‘12 ‘13 ‘14 ‘15 ‘16
MRLs 28,000
Codex Committee on Pesticide Residues (CCPR) Meeting
MRL count based on individual commodity and active ingredient

24,000
The trend in the number of Codex MRLs set on crop
20,000
groups has also been increasing and more types of crop
Count of Codex MRLs

16,000
groups are being included resulting in a greater number of
commodities obtaining MRLs.
12,000
91%* 97%*
82% * Number of Codex MRLs set on Crop Groups
8,000
80

Count of Codex MRLs

4,000 70
89%* 60
78%*
0 50
40
# of national MRLs established that are harmonized with Codex
30
# of national MRLs established that are not harmonized with Codex
20
# of Codex MRLs for which a national MRL is not established
* Of the national MRLs established, percentages indicate portion harmonized with Codex 10
0
‘01 ‘02 ‘03 ‘04 ‘05 ‘06 ‘07 ‘08 ‘09 ‘10 ‘11 ‘12 ‘13 ‘14 ‘15 ‘16

Because of the importance of Codex MRLs, frustration Codex Committee on Pesticide Residues (CCPR) Meeting
is often expressed with the number of MRLs established
by the CCPR and the difficulty and pace of the process. More and more countries appear intent on establishing
However, there have been positive developments in the national MRL standards. Their governments may see this
establishment of Codex MRLs over the last decade. as a part of their responsibility to oversee the safety of food
products consumed within their borders. Whatever the
Although the number of Codex MRLs set each year varies, reason and regardless of the policy direction a government
the trend since the early 2000’s has been upward as chooses, Codex MRLs will continue to play an important
the process has improved. In 2004 the CCPR went from role. They may be used for reference during internal
meeting every other year to an annual occurrence, and policy setting processes, and they offer an objective global
in 2006 new procedures came into use which elaborated standard that can be helpful when trading partners raise
the requirements and timeline for reviewing a country concerns about restrictive MRL standards that present
delegation’s expressed concern with a proposed Codex possible trade risks.
MRL. Both of these changes were important for increasing
the number of Codex MRLs established as the following Interested parties can track developments on the Codex
chart illustrates. website for the 49th session of the CCPR scheduled in April
2017. Bryant Christie Inc. also covers these developments
in its weekly MRL News. Sign up to receive that free
newsletter here.

Kimberly Berry Director, Regulatory Data Services

Kimberly Berry is BCI’s Director of Regulatory Data Services. She oversees BCI’s team of research analysts monitoring food
additive and MRL regulations and is responsible for ensuring the accuracy and timely updating of BCI’s chemical and food
additive regulatory data products including GlobalMRL.com and FoodAdditiveDatabase.com. Since 2012, Kimberly has served
as a private sector member of the U.S. delegation to the Codex Committee on Pesticide Residues (CCPR).
[email protected]