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Managing MRL for crop exports

Bungled business efforts can lead to embarrassment, evidenced by the recent Northwest Airlines flight that overshot the Minneapolis airport by 150 miles due to allegedly distracted pilots.

Similarly a huge error can also occur in agriculture if U.S. crops are exported without a thorough understanding of the destination country’s maximum residue level (MRL) requirements for pesticide tolerances. Foreign governments can turn away crops at ports resulting in large financial losses to agricultural businesses.

Exports must be problem free, says Jim Cranney, president of the California Citrus Quality Council (CCQC), Auburn, Calif.

“You want to stay away from MRL problems in the international marketplace,” Cranney said. “You will lose your tail if you have an MRL violation in overseas markets. Many governments tend to be rigid on this issue. Japan tends to be downright uncooperative.

“The Korean or Taiwanese government saying there is a MRL violation and they don’t want the product is a terrible position to face when you have a $15,000 to $20,000 load of product,” Cranney said.

MRLs were an overlying theme at this year’s California Association of Pest Control Advisers annual meeting held in Sparks, Nev., in October.

A MRL discussion panel included Cranney; Gabriele Ludwig, associate director of environmental affairs, Almond Board of California, Modesto, Calif.; and Walt Bentley, integrated pest management (IPM) entomologist, University of California Kearney Agricultural Center, Parlier, Calif.

The Environmental Protection Agency (EPA) sets MRL levels for domestically-grown and consumed crops. Foreign countries set their own standards; sometimes higher or lower than U.S. tolerances. Some foreign countries accept Japan’s MRLs as their own.

“The MRL issue is important in all markets, but Japan tends to be very problematic,” Cranney explained. “Japan tends to be a driver for all the other markets.”

Japan is the leading importer of U.S.-grown citrus, and is followed by Canada and Korea.

Understanding MRL levels (tolerances) is crucial to U.S. agriculture as one out of every three planted acres is exported. In California, 70 percent of almonds are exported, 57 percent — pistachios, 45 percent — walnuts, 40 percent — rice, and 38 percent — fresh oranges and orange juice.

Cranney urged PCAs who advise on citrus to be aware of the primary crop destination, domestic or export, and to stay abreast of ever-changing tolerance issues. Determine which crop protection materials can and cannot be used in each country and determine the accepted chemical tolerances.

Two MRL informational resources include the CCQC Web site,, and the USDA-Foreign Agricultural Service’s Web site providing MRL listings by chemical, commodity, and country.

China is changing the rules on international MRLs, says Gabriele Ludwig of the Almond Board of California. China’s own food safety standards have been questioned in recent years.

“In terms of exports we have generally played the odds that we would not be tested at the point of import. Those odds have changed,” Ludwig said. “International MRLs have become much more critical to crops that are export dependent.”

About 30 percent of California almonds are exported to the European Union (EU). The EU default MRL tolerance is .01 part per million (ppm) while Canada’s current .1 ppm default tolerance will be changed soon.

Ludwig offers advice to PCAs who advise on almonds. Almonds are California’s top exported crop sold to more than 100 countries.

Since California almonds are typically sold to a handler, PCAs should ask the handler which market the almonds will likely enter to determine if a MRL issue exists, Ludwig says. Almonds are exported to countries in lots based on quality and size. She recommends finding out which countries the handler works with and those they do not.

Ludwig encourages PCAs to talk with the chemical registrant. MRL tolerance numbers can vary across regulatory agencies in the world, but actually are the same. EPA sets the tolerance based on the active ingredient and breakdown products. Japan’s MRL process is different.

Despite the hull and shell that shield the almond nut, MRL residues are found in the nut in the parts per billion range.

While pesticides are applied in the field, chemicals are also used in handler facilities. Ludwig suggests more research, education, and Extension focus is needed in pest management on the handler side.

A PCA in the audience asked if pesticides remain a major issue even when processing (wine for example) removes the residue. Ludwig responded, “There are different answers in different markets. Japanese buyers want to know what you applied; not what’s there.”

Another PCA noted that many large almond processors blend almonds from different growers. He asked how PCAs can control tolerance levels when a load for export can contain different pesticides.

“The almond industry currently does not have traceback to the field, but food safety will change that equation,” Ludwig said. “We are finding more demand for field traceback … If there is a problem it just won’t be grower ‘XYZ’ but the almond industry. The choices at the grower level and in the field impact the marketplace. The marketplace is changing what PCAs do in the field.”

IPM entomologist Walt Bentley said MRLs are a growing issue abroad for exports of California table grapes and stone fruit. About 40 percent of California table grapes are exported cashing in about 55 percent of gross income. About 45 percent of the Golden State’s stone fruit crop, about 50 percent in gross profits, is exported.

“If you are selling grapes and stone fruit to a country that has a different regulatory basis on compounds, you don’t want your product getting stuck in a port where you lose the whole ballgame,” Bentley said. “It’s not like in the U.S. where if Wal-Mart doesn’t take it you can move it somewhere else.”



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