INTERSESSIONAL MEETING OF THE
INTERGOVERNMENTAL GROUP ON TEA
Mombasa, Kenya, 18 – 19 July 2011
REPORT OF THE WORKING GROUP ON
MRLs ON TEA
I. INTRODUCTION
At the 19th Session of IGG on Tea, held on 12-14 May, 2010 in New Delhi, the Group recommended
certain action plans for the Working Group on MRL to be implemented to ensure tea to be compliant with
regulations. Also certain action plans and strategic review were suggested including setting up of a small
group to review the current plan for strategy developments.
II. BACKGROUND
This Working Group on MRL in tea has done notable works since its constitution in 2003 in
different phases.
 Initially, status on pesticide use in tea globally was found out, thereafter about their need to use
for protecting tea crop, finding regulatory positions of pesticides and MRLs and how to
streamline their use within regulatory frame work to ensure both safety and yield of tea.
 Second step was to frame out Protocol for data generation in lision with JMPR which was a
hurdle since growing seasons, harvesting interval, manufacturing and so on were different
including agro-climate and pest and disease profile. But after much efforts finally the harmonized
module/guidelines could be worked out for field data generation in the tea producing countries.
 Prioritization of chemicals for data generation was done based on certain criteria in 2005 and
thereafter following intermittent meetings of the Working groups; initially 24 chemicals mainly
used in India, SriLanka, Indonesia and few in Kenya were listed. In the second phase in 2007,
another set of 16 chemicals were prioritized mainly from Japan, Indonesia and SriLanka. More
chemicals were taken up through individual efforts for data generation in China and others.
Constraints in setting up of laboratories in many of the countries slowed down the data generation
process.
 Such residue data have been submitted to Codex for many of the compounds for MRL fixation
and the process was going on. Also MRLs were fixed in the producing countries with scientific
data base following international protocol. Few importing countries were also given support with
these data when regulations were reviewed in the importing countries.
 Net result of all these efforts in the years resulted to transparency in data as internationally
required, stepping to Global Information Exchange (GIE) now as one of the mandate of this WG
since 2005 and the efforts in harmonization of MRL in tea globally.
 Nevertheless, IGG has entrusted more works to this WG after changing the modalities to give
more attention towards global harmonization of MRL, accordingly following activities are
currently taken up in addition to data generation for MRL.
III. ACTIVITIES OF THE WG ON MRL
1. For making strategy review on the priorities towards harmonization of MRLs, a meeting of the small
group of countries was arranged at Niagara Falls on 21st Sept, 2010 as side line meeting of the 1st Annual
North American Tea Conference and the representatives from India, UK, Canada, USA, China, Kenya,
EU were present who deliberated on the status of regulations and priorities in respective countries, based
on which an Annexure has been devised with identified responsibilities and circulated (Report and
Annexure I), as enclosed.
2. Country profiles from major producers and importers of tea have given scope to narrow down
activities in each of the country and identify need for data generation on new compounds replacing older
ones, rationalizing MRLs in revised regulations, alternate use of chemicals and IPM, identify problematic
compounds and transition period.
3. Some progress has been made in India and SriLanka to identify new compounds and generate useful
data. Regulators in the respective countries are examining such data for MRL fixation. SriLanka has done
very good work in data generation for a number of compounds which are advanced to Codex for new
MRLs at Codex.
4. Now, based on Annexure I, further action plans will help to achieve the objectives of this WG. More
information may be forthcoming in the next WG meeting to strengthen the action plans.
5. Side meetings on tea were held at PMC Minor Crop meeting Canada (Mar 2011) and Codex CCPR
China (Apr 2011) to facilitate dialogue with agrochemical companies; to raise the profile of tea as an
internationally traded crop which requires MRLs to be set globally. As a result MRL submissions to
JMPR will be made by several companies in the next 1-2 years. Discussions continue to include tea in
MRL submissions in consuming countries.
6. A number of new MRLs have been granted in consuming countries. 1 MRL in Canada for lambda
cyhalothrin (Jun 2010), 1 MRL in USA for etoxazole (Apr 2011) and 8 MRLs in Australia (May & Sep
2010).
7. Work continues to make further MRL petitions. A further 4 submissions are being prepared/have
been submitted to EPA through the IR-4 programme/chemical companies in USA; 4 submissions are
being progressed by chemical companies to PMRA in Canada. Chemical registrant companies, Tea
Research Associations in India, China and Sri Lanka and surveillance data from tea companies have
enabled these applications to be made.
8. Communication with the regulators has been maintained to assure continuing support and progress.
Meetings were held with PMC & PMRA in Canada (Sep 2010), IR-4, EPA and FDA (Jun 2011).
IV. CONCLUSION
1. From the country deliberations in the WG meeting in Kenya Annexure I, enclosed, can be finalized
for future. Further, it is essential to know and identify the priorities of compounds for MRL fixation
including for new data generation; position of country MRL, position in regard to replacement of old and
high polarity compounds by new and safer chemicals and urgency to fix new MRLs for them.
2. Involvement of all stakeholders, Codex, EU and other standard setting bodies in the works of WG on
MRL.
3. Identification of priority compounds for data generation, submission to Codex and others under
GPPI.
4. Finding of new developments in MRL in the tea importing countries like EU, US, Canada, Australia
etc. and possibilities of intervention with field data support towards harmonization of MRL.
5. To work out transition period for problematic compounds in the importing countries as relief to tea
producers.
6.
Modalities and working out of GIE towards harmonization of MRL.
FAO/IGG Working Group on MRLs
REPORT OF THE STRATEGY SUB-GROUP MEETING held on
21ST September 2010 at Niagara Falls, Canada
1. Members present – Annex 1
1.1
A representative from Sri Lanka was unable to attend the meeting.
2. A hearty welcome was extended to the members present by the Co-ordinators (TCC, KD).
Thanks were extended to the organisers of the 1st Annual North American Tea Conference for
their interest on the subject and for agreeing to organise this sub group meeting of IGG on tea.
3. The background of the meeting was presented referring to the decisions on the subject taken at
the 19th meeting of the IGG on tea in Delhi on May 2010 as given below.
4. At the 19th session of the FAO Intergovernmental Group on Tea, in Delhi, it was agreed, as
recorded in the report of the said meeting under part V. A. REPORT OF THE WORKING GROUPS
ON MAXIMUM RESIDUE LIMITS (MRLs) AND RESIDUES IN TEA BREW under paragraph 22
“(ii) Strategy review


Set up a small committee including China, India, Kenya, Sri Lanka, Canada, EU, USA
This small committee will review the current plan, define vision, develop action plan to
reach vision, discuss action plan with FAO Secretariat”
5. To facilitate this strategy review, the following strategy review process was adopted in the subgroup meeting
 Agree a vision for the working group on MRLs
 Identify the major issues and the goals for the working group
 Identify specific approaches to achieve these goals
 Review the current action plan against the goals and approaches. Identify gaps and new
opportunities
 Discuss output with FAO secretariat and present proposed strategy to FAO-IGG Committee
on Tea
6. Meeting objectives:



To agree the vision for the working group on MRLs
To identify the major issues facing the tea industry on this topic
To agree the goals for the working group to tackle the identified issues
7. The country positions on the issue of pesticide residues were presented by the respective
members.
7.1
Prof. Chen Zongmao, China, highlighted his concerns about the inconsistency of global
MRLs in tea which is creating confusion in the producing countries; that the MRLs are fixed
based on the ‘dry leaf’ instead of ‘tea brew’ when the transfer of residue into the brew can
range from 1-330 times lower; some pesticide groups (triazole fungicides and
organophosphates) might be banned by CCPR for use in tea in the next 2-3 years; the need for
new pesticides to replace older chemicals through CCPR. The need to urgently present the tea
brew data regarding transfer of pesticide residue to JMPR was also stressed.
7.2
Dr T. C. Chaudhuri, India, presented the progress on MRL setting in India and the
constraints faced by the tea industry for non availability of newer alternative compounds. This
leaves a limited number of compounds available to control pests/diseases in tea, so the need to
introduce newer chemicals to replace older ones, and to introduce effective IPM was stressed.
The stringent MRLs in importing countries were noted as a non-tariff barrier among the tea
producers.
7.3
Dr Thomas Henn highlighted the continuous change of residue regulations and the loss
of authorisation for chemicals in Europe; the need for the industry to look ahead, replace old
chemicals and ensure enough new chemicals are available; that to the pesticide companies tea
is not an important crop; that consumers are sensitive to pesticide residues; climate change and
sustainability; safe evaluation of pesticides in the future may be based on multiple residue
analysis; the analytical issues surrounding low LODs. The ETC traffic light colour coding system
for evaluating chemicals was presented and an example for imidacloprid was cited.
7.4
Mr Joe Simrany, USA, noted that there are currently 7 approved MRLs for tea in the
USA with 5 more applications pending review by the EPA and highlighted the difficulties in
regulations in the USA; the need to address the concerns of the regulators; that in the USA tea is
classified as a minor domestic crop; the need to harmonise MRLs for a specific group of
pesticides; to recognise that consumers are beginning to eat and cook with tea; the need to
streamline certification systems.
7.5
Ms L. Roberge highlighted that the PMRA is the regulatory authority setting MRLs in
Canada; there is currently only 1 MRL for tea in Canada; a general default MRL of 0.1 mg/kg
exists but this is under review; tea cannot be classed as a minor crop in Canada; more awareness
is required with regulatory bodies, chemical companies and the wider tea industry; to recognise
that there is not one single mechanism for obtaining MRLs for tea.
7.6 Kenya was represented in the meeting by the Kenya High Commission, Ottawa. No
presentation was given since he did not have technical details on this subject.
8.
The first point of discussion was the vision of the working group on MRLs. The initial
draft from the working group meeting held in Rome, December 2005 was revisited. The original
goal was:
“The participants agreed on a common goal of
Achieving global harmonisation of maximum residue levels (MRLs) in tea”
Following discussions, the wording was revised as follows:
“To achieve global cooperation obtaining maximum residue levels (MRLs) in tea”
9. The issues identified in each of the presentations were collated and confirmed. Subsequently,
the issues were grouped according to subject, assigned heading to each group of similar issues
as placed in Annex 2. For each if the issue, a goal was identified which will address the issue.
9.1 For developing the action plan for each of the goals, a volunteer was identified as recorded
in Annex 2. The identified person was tasked to propose specific approaches to achieve the goal
and the activities required to deliver this by the 1st February 2011 to the joint coordinators.
10. The meeting was concluded with a vote of thanks to the organizers and the participants.
Annex 1 -- Attendance
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
Dr T. C. Chaudhuri, co-ordinator
Ms Katie Donnelly, co-ordinator
Louise Roberge, President Tea Association of Canada
Joe Simrany, President, Tea Association of the USA
Dr Thomas Henn, European Tea Committee
Prof. Chen Zongmao, Tea Research Institute, Chinese Academy of Agricultural Sciences,
Hangzhou, China
Mr Arun Narain Singh, MD Goodricke Group Ltd and Vice Chairman TRA, India
Mr Victor Musembi, Kenya High Commission, Ottawa
Mr Cai Jun, Secretary General, China Chamber of Commerce
Prof. Zhonghua Liu, Director, Education Ministry China
Mr Mao Limin, GM Zhejiang Tea Group Ltd
Lily Xie, staff, CRNA
Ken Rudee, Chairman Speciality Tea Institute, Tea Association of USA
Charles Milne, Consultant Tea Association of Canada
Annex 2: Identification of issues and goals
Key issues
Goal
Evolving pest pressures
Develop and implement IPM
strategies
limited compounds to control pests/diseases
new pest problems faced each year environment changes
Responsibility
Sri Lanka? Dr
Chaudhuri to
discuss
new compounds and new control IPM
strategies
biocontrol, chemical ecology methods
Lack of MRLs, non harmonised MRLs
Obtain reclassification of tea as minor
crop in JMPR to speed MRL setting
for tea
Prof Chen,
China
only 1 MRL for tea in Canada
obtain MRLs for chemicals in use in
producing/consuming countries
Katie Donnelly
compliance relies on a default MRL of 0.1,
but could be taken away at any time
more regulations for country of origin
MRL is essential for chemicals being
used
rejection of shipments because of pesticides
- lack of MRLs
convergence of methodologies for MRL
setting
need to harmonise specific group of
pesticides
common agreed risk assessment
process for tea
continuous change of residue regulations industry has to think ahead
transparency of risk assessment
processes in different countries
loss of authorisation in EU - ensuring enough
chemicals available to effectively fight pests
Inconsistent viewpoint between producing
and consuming countries on MRLs
stringent MRLs in importing countries
one global MRL for compounds desired
Need more pesticides through CCPR, and
for them to be adopted in other country
legislation
analytical issues - lower LOQs require
specialist knowledge
replacement of old chemicals/banning of
old chemicals
JMPR - Some current pesticides will be
banned in 2-3 years (OP, triazole group)
replacement of old chemicals done slowly
replacement of old substances
new compounds are slowly registered for
use in producing country - accelerate
some pesticides are banned, so can't obtain
import MRL for tea
replacement programme to replace
old/banned with new chemicals
Dr T. C.
Chaudhuri,
India
Deadline
February
2011
pesticide priority list based on
sustainability, affordability and safety
reconsideration of risk assessment in
Codex
Thomas Henn,
EU
remit of FAOIGG working
group on tea
brew
communication among stakeholders
an effective communication plan with
stakeholders
Louise
Roberge,
Canada
communication to the smallholder
community
set up an efficient communication tool
for the relevant stakeholders
media and consumer attention
tea small crop - low interest in tea by
pesticide companies
identify the relevant stakeholders
responsibility, implementation,
monitoring,
timely communication about regulatory
changes
development of a universal position
statement
health, safety, sustainability
Current MRLs not rational – transfer into
brew most important
consumer sensibilities - don't want residues
even if safe
environmental impact - climate change &
sustainability
consumer perception - tea marketed on
health
sustainability of tea - environment, workers
etc.
people are starting to eat and cook with tea
more emphasis on food safety
official developments - evaluation of multiple
residues in products
tougher regulatory environment