Crop Protection

What a Full Impact Assessment On EU MRL Policy Should Examine

05 May 2026, EU: Discussions are ongoing in Brussels regarding potential changes to the European Union’s framework for Maximum Residue Levels (MRLs) for substances that are not approved for use within the EU. Although the proposed revisions are often described as technical adjustments to residue policy, stakeholders say the implications could extend beyond food safety, affecting trade, supply chains, competitiveness and agricultural innovation.

According to CropLife Europe, any legislative proposal on the issue should be preceded by a comprehensive, evidence-based Impact Assessment examining the broader implications of changes to the MRL framework.

MRLs are established under EU legislation as market access standards intended to ensure that consumer exposure to pesticide residues remains within safe limits. These standards are based on scientific risk assessments conducted by the European Food Safety Authority. CropLife Europe stated that any modification to the framework should therefore be evaluated not only from a food safety perspective, but also in terms of economic, legal and international trade impacts.

The European Commission has already indicated that an Impact Assessment would be carried out before any legislative proposal is introduced. CropLife Europe described this process as essential for ensuring that future decisions remain science-based, proportionate and aligned with broader EU policy objectives.

Concerns Over Expanding the Role of MRL Policy

One of the proposals under discussion involves setting certain MRLs at the “limit of quantification,” commonly referred to as “technical zero.” While this approach is sometimes presented as a means of supporting sustainability objectives or protecting EU farmers, CropLife Europe argues that using residue policy to pursue objectives beyond consumer exposure management could alter the original purpose of the system and create inconsistencies in regulation.

The organisation stated that a meaningful Impact Assessment should examine whether such changes would provide measurable additional health benefits beyond the current framework, which already maintains a high level of consumer protection. It also said the assessment should determine whether residue policy is the appropriate tool for addressing broader concerns such as sustainability, competitiveness, strategic autonomy and innovation.

Potential Effects on Trade and Supply Chains

CropLife Europe noted that changes to MRL policy could have immediate consequences for global supply chains. According to the organisation, even uncertainty around future regulation may lead exporters to redirect agricultural products away from the EU market, potentially affecting food and feed availability, pricing and supply resilience, particularly in sectors where Europe relies on imports.

The organisation also highlighted trade-related implications. Since MRLs serve as conditions for market access, the routine application of “technical zero” limits without risk-based scientific justification could raise concerns regarding proportionality and create barriers to international trade. CropLife Europe said such measures could also affect confidence in the EU’s regulatory system.

Innovation and Regulatory Predictability

The group further stated that regulatory predictability is important for continued investment in agricultural innovation. According to CropLife Europe, if residue regulations become disconnected from scientific risk assessment processes, incentives for developing new crop protection technologies may weaken over time. This, it said, could reduce farmers’ access to effective agricultural tools and affect the long-term resilience of food production systems in Europe and other regions.

Importance of Evidence-Based Policymaking

CropLife Europe stressed that, under the EU’s Better Regulation principles, Impact Assessments should guide policymaking rather than follow decisions already taken. The organisation said that a transparent and cross-sectoral assessment conducted before legislative changes are advanced would help avoid unintended consequences and support evidence-based decision-making.

The organisation added that such an assessment should cover a broad range of factors, including consumer protection, food and feed availability, import dependency, trade relations, competitiveness, innovation, legal certainty and the EU’s international obligations.

CropLife Europe stated that its detailed paper outlines the main considerations that should be evaluated to ensure that any future changes to the EU MRL framework are guided by science, proportionality and a clear understanding of their practical implications.

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