Coalition for an Enhanced Codex
Trade is critical to food security and the ability to trade in food is central to the livelihoods of many of the world’s rural poor. As the most important international standard-setting body in the area of food safety, the Codex Alimentarius plays a crucial role in protecting the health of the consumers enabling trade in agricultural products. This activity benefits both producers and consumers. One of its most important responsibilities is Codex’s role in setting international pesticide maximum residue limits (MRLs).
Given the importance of global trade and the significance of MRLs in facilitating trade, the Codex Committee on Pesticide Residues (CCPR) plays a critical role in determining economic outcomes for all stakeholders that depend on trade flows. Enabling Codex to perform its role more effectively and efficiently by addressing current capacity challenges, embracing new scientific and administrative methods of evaluation, and ensuring adequate resources are available, is essential to supporting global food security and trade. Delays in the establishment of MRLs and the resulting lack of national/international harmonization have important consequences for market access, productivity and farmer livelihoods, contributing to a poorer and hungrier world.
A coalition of farmer and business groups was established in 2016 in the context of the International Year of Pulses (IYP 2016) to advocate for an improved and more efficient Codex process on MRLs, with a focus on the functioning of JMPR and CCPR. In 2018, members of IAFN collaborated to produce a case studies booklet specifically about the impact of MRL compliance requirements on smallholder farmers.
The Codex Coalition is very pleased about the recent developments and sees further possibilities for enhancement to meet current and future needs. The following issues should be addressed:
1. Growing demands upon Codex Committee on Pesticide Residues
Codex has produced an admirable number of MRLs for crop protection products considering the number of expert reviewers available and their volunteer status. However, the recent improvements in evaluation and scheduling processes have led to even greater demand for evaluation resources. Efforts must be taken to build on these process and scheduling successes and adopt changes to increase the JMPR efficiencies and review capacity to meet the ever-increasing demand for the review and recommendation of Codex MRLs for: • New active ingredients, around the same time or shortly after their introduction into the marketplace, • New uses, particularly for minor/specialty crops, and, • The reevaluation of chemicals that have been on the market for 15 years or more.
Ideally Codex MRLs are established around the same time or soon after a new active ingredient or new use is approved by a national authority and in use on crops entering international commerce. If this does not occur, then farmers do not have access to new crop protection products and agricultural efficiencies cannot be realized by both farmers and consumers.
2. Funding for Codex scientific work
There is a widely recognized need for adequate and sustainable funding to support the scientific advice provided to Codex Committees and the secretariat services. Stable and predictable funding is necessary for this fundamental area of work.
3. Availability of experts to provide scientific advice
While the demand for panel reviews has increased over the years, the number of experts on each panel has not increased substantially. The current rosters of JMPR Experts include just 45 toxicologists and 28 residues experts (status November 2018). The output of these experts is limited by the fact that they are working professionals who conduct reviews for JMPR on a volunteer basis, in addition to their normal professional workload (based on a survey in 2018, about half of the experts are allowed no time on the job to devote to JMPR work). JMPR Panels are similarly constrained in the number of evaluations and proposed MRLs that can be reviewed during an annual two-week joint meeting. The Canadian and US government have made funding available to train additional experts to serve in JMPR to respond to increased demands for Codex MRLs and to ensure a sufficient number of experts on the roster.
4. Communication during the JMPR review process
During the review of dossiers, expert reviewers may reach out to data submitters for additional data or information. However, sometimes data needs or other issues are raised late in the process, leaving no time for the submitters to resolve them prior to the JMPR meeting. Where reviews are then postponed until the following JMPR, establishment of a Codex MRL is delayed by a full year and JMPR’s backlog is exacerbated.
The FAO Manual provides a general timeline for Experts to communicate with their peer reviewer and the JMPR Panel, but does not provide the reviewers with any guidance regarding the timing of communication with submitters, which may be needed to complete the review and establishment of a Codex MRL during a single cycle.
Following each session, the recommendations of the JMPR are reported out with full explanations regarding the scientific rationale for each recommended MRL. However, a full explanation is not necessarily provided for decisions to not recommend an MRL that was sought or decisions to recommend single-commodity MRLs rather than a crop group MRL. These explanations are of significant importance to registrants, farmers and national governments that rely on Codex MRLs.
5. Delay between pesticide registration and establishment of a Codex MRL
Some JMPR practices may unnecessarily delay the establishment of Codex MRLs. JMPR requires a registered label before recommending a Codex MRL and it is JMPR procedure that residue trials submitted for review must match the Good Agricultural Practices (GAP) of the registered label for the national authority where the trials were conducted (despite that labels often changing over time). We encourage the CCPR to develop a mechanism to allow the experts to work with draft labels. The JMPR is encouraged to provide CCPR with a recommendation while noting that the recommendation is based on a draft label only. In addition to causing delay, this precludes the use of trial data from countries without a national label, preventing Codex MRLs for minor crops and older substances that do not warrant manufacturer support for further field trials, and creating a paradoxical situation in some developing countries that require a Codex MRL before registering the compound.
At the same time, it is not standard procedure for JMPR residue reviewers to reference the existing reviews completed and MRLs set by competent national authorities. This is left up to individual reviewer’s discretion. Submitters are not required to and do not consistently supply this information, although individual reviewers may seek national evaluations on their own.
There is potential to better coordinate and leverage the work of national authorities to realize efficiency gains and reduce the burden of work for JMPR Experts without eroding the scientific independence of the Codex evaluation.
6. Trade impact and importance of Codex pesticide MRLs
The World Trade Organization’s Agreement on the Application of Sanitary and Phytosanitary Measures (WTO SPS Agreement) references Codex as the relevant food safety standard setting body for harmonization and facilitation of international trade. It encourages Members States to harmonize SPS measures to the extent possible and to base these on international standards, guidelines and recommendations.
National governments, registrants, farmers and traders, and the development community all have a growing awareness of MRLs and growing concerns about trade disruptions that can be caused by missing, non-aligned MRLs or zero tolerance policies. While Codex MRLs must be science based, this does not preclude CCPR from considering the trade impact and implications for farmers, countries, the global market for food, and the global economy. Codex MRLs can help ensure consumer health and safety and address practical trade facilitation needs for importing and exporting countries without sacrificing safety and scientific rigor.
Current Members of the Coalition for an Enhanced Codex include:
Canada Grains Council
Canadian Canola Growers Association
The Coca-Cola Company
European Coffee Federation
FoodDrinkEurope on behalf of Federation of Cocoa Commerce and CAOBisco
Global Dairy Platform (GDP)
Global Farmer Network
Global Pulse Confederation (GPC)
Grain and Feed Trade Association (GAFTA)
Himalayan Apple Growers Society (HAGS)
International Center for Tropical Agriculture (CIAT), member of the CGIAR
International Chamber of Commerce (ICC)
International Citrus Growers
International Fertilizer Association (IFA)
International Food and Beverage Alliance (IFBA)
International Grain Trade Coalition (IGTC)
International Organization of Spice Trade Associations (IOSTA)
International Seed Federation (ISF)
International Trade Center (affiliated with WTO and UNCTAD)
Inter-American Institute for Cooperation on Agriculture (IICA)
Iran Pistachio Association (IPA)
Minor Crop Farmers Alliance (MCFA)
Rural Women in Agriculture
Tea and Herbal Association of Canada
US Soybean Expert Council (USSEC)
World Spices Organisation