26 August 2026, EU: The publication of the Joint Research Centre’s study on the potential impacts of lowering maximum residue levels (MRLs) for imported food and feed to the limit of quantification has added an important contribution to one of the most consequential debates in the Food and Feed Safety Omnibus.
The proposed changes have been presented as a means of strengthening reciprocity, promiting EU production standards and creating a more level playing field for Europe farmers. These are legitimate policy objectives. However, before changing a system that already protects consumers, policymakers should ask a fundamental question: what evidence is there that the proposed measure will actually deliver the outcomes it is intended to achieve?
This matters because the debate is no longer simply about consumer safety. The EU already has a comprehensive, science-based framework for assessing residues in food. MRLs are established following rigorous risk assessments and can already be modified when a consumer risk is identified. As EFSA’s annual monitoring reports consistently demonstrate, food available to European consumers is safe.
The question raised by the current debate is therefore not whether Europe’s food safety system works. It is whether changing MRL instrument is an effective and proportionate instrucment for achieving a different set of policy objectives.
The proposal seeks to achieve objectives that go beyond the traditional purpose of MRL legislation. Advocates argue that it could promote higher production standards globally, strengthen reciprocity and create a more level playing field for European farmers. These are significant policy ambitions. Yet they also require evidence.
Evidence on impacts, not evidence on outcomes
The JRC study provides useful analysis of the potential economic consequences of lowering import MRLs for a number of non-approved active substances. It explores how trade flows, sourcing patterns, production and consumer prices could be affected under different scenarios.
What the study does not do, however, is demonstrate that the proposal will achieve the broader objectives often associated with it.
It does not show that lowering import MRLs will improve environmental outcomes. It does not demonstrate that it will encourage changes in agricultural practices outside the European Union. Nor does it conclude that it will improve the competitiveness of European agriculture or strengthen food security.
That is not a criticism of the study. These questions were simply outside its scope.
Yet these questions remain central to the political debate. If the objective of the change goes beyond consumer protection, for example, to influence production practices in third countries, improve environment outcomes or address concerns about competitiveness, those objectives should be clearly defined and assess on their own terms.
This matters because using changes to the MRL framework requires evidence that the mechanism is capable of delivering these objectives as well as assessment of the potential consequences. This is even more important in the context of an Omnibus package whose stated purpose is to simplify EU food and feed legislation.
The study itself highlights the complexity of predicting how producers, traders and global supply chains may respond to regulatory changes. Some exporters may adapt. Others may switch markets or suppliers. Depending on the assumptions made about how exporters respond (or adapt), the study identifies a potentially wide range of economic outcomes. This is valuable analysis but it also demonstrates the uncertainty surrounding the real-world effects of the proposal.
That uncertainty should encourage caution, not assumptions.
Why a full impact assessment is needed
The JRC study provides valuable information, but, it is important to be clear about what is and what it is not. The study itself explicitly states that it is not an impact assessment and should not be interpreted as one.
A full impact assessment would examine not only economic effects, but also whether the proposal is likely to achieve its stated objectives, what unintended consequences could emerge and whether alternative approaches might deliver better outcomes at lower cost.
This is particularly important given the nature of the proposed change. The current MRL system already delivers a high level of consumer protection.
Where a significant departure from the framework is proposed in order to pursue wider policy objectives, there should be clear evidence that the chosen instrument is effective, proportionate and necessary.
If the objective is to influence agricultural practices outside the EU, improve environmental outcomes or create a more level playing field, policymakers should first demonstrate that the measure is likely to achieve those goals. They should also assess the implications for trade, supply chains, food affordability and Europe’s relationships with trading partners.
These are precisely the questions that comprehensive impact assessments are designed to answer.
This is also why the sequencing of the policy process matters. In November 2025, the European Commission announced work intended to support a general impact assessment examining, among other issues, the competitiveness and international implications of potential changes to MRL policy. That assessment should inform the policy choice rather than follow it.
The publication of the JRC study should therefore not be seen as the end of the discussion.
On the contrary, in many respects it demonstrates why completing the wider assessment is so important. A policy choice with potentially significant economic and trade consequences (as stated in the JRC report) should be informed by a full assessment of whether it is effective, proportionate and the best means of achieving the intended objectives. Moving ahead without that evidence risks reversing the logic of Better Regulation.
The debate should not be about whether the proposal sounds appealing in principle. Nor should it be about whether stronger reciprocity or higher environmental standards are desirable objectives. The central question is whether lowering MRLs is an effective, proportionate and evidence-based way of achieving them and what the consequences would be for trade, supply chains, food prices, EU agriculture and trading partners.
That is precisely what a full impact assessment should establish before far-reaching policy choices are made.
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