MRLs - a growing ag export issue

U.S. farmers and ranchers export 25 percent of their annual output.

One in every three planted acres in America is designated for export.

The percentage is the same for all of California agriculture. However, for many crops grown in the Golden State, exports represent a much higher percentage of total production. For example:

• 70 percent of almond production.
• 38 percent of fresh oranges and orange juice.
• 40 percent of rice production.
• 45 percent of walnut production.
• 57 percent of pistachio production.

Exports are the economic underpinning of California and U.S. agriculture. They represent more than $100 billion in agricultural income for the U.S. In California, it is almost $10 billion, according to the latest statistics.

More than 150 countries buy American farm and ranch exports.

Exporting to other nations is more complex than marketing domestically. In recent years, it has become even more challenging due to a growing regulatory morass involving the establishment of maximum residue levels (MRLs) for pesticides used on crops grown in the U.S. and shipped to other nations.

This is the first in a series of articles on the subject of MRLs in the export market. It is part of an educational program developed by Western Farm Press and sponsored by DuPont Crop Protection. As part of the package, an online continuing education program on MRLs is in development for launch next month.

Entitled The ABCs of MRLs, the accredited online course will be available at westernfarmpress.com and CAPCA.com.

Residue tolerances or maximum residue levels (MRLs) are established in the U.S. as part of the pesticide registration process by the Environmental Protection Agency (EPA) and state agencies like the California Department of Pesticide Regulation (DPR).

Pesticide regulatory agencies also are in most of the 150 countries which purchase U.S. agricultural exports.

Marcy Martin, director of trade services for the California Grape and Tree Fruit League, said chemicals registered in the U.S. may not be registered in other countries or registered at different use rates. This is important because if that country buys stone fruit from a league member, the products used to protect that fruit must be registered and have an MRL in the destination country.

"Several years ago we began to see that materials we depended upon to provide great benefit in the field were not being registered at the same rate in those export markets,” she said.

Martin estimates about 25 percent of California’s stone fruit is exported. Export programs are part of most California fruit packing houses. “MRLs set by other countries have become critical because they impacts what growers and shippers use on their crops,” she said.

MRLs may not have been established in the country where the fruit is being shipped to. This is particularly true with many of the newer, softer materials that have been registered in the U.S. for specialty crops in the past few years, she said.

"As growers and pest control advisers (PCAs) move to these new materials, they are often precluded from using them because there are no MRLs established in certain markets,” she pointed out.

Compounding the issue is a lack of MRL uniformity among those 150 nations.

Many countries are moving toward their own MRL criteria when registering products. If MRLs on a pesticide used in the U.S. are different from how the same pesticide is used in another country, then U.S. growers must conform to the other nation if they want to ship product to that nation.

The Grape and Tree Fruit League provides information on MRLs on a country-by-country basis, but it is still a “calculated decision” to use products on a crop since its final destination may not be known until it is picked, packed and shipped, she says.

There is a USDA Web site and other agencies list MRLs for various countries. Many nations have their own individual MRLs.

"Most PCAs are aware of the MRL issue, certainly more than five years ago. However, is it not necessarily on everyone’s radar. It should be,” she said.

Lori Berger, executive director of the California Specialty Crops Council, says each commodity has a year round pest management program.

"PCAs need to know what materials are approved for all markets and what are not. There is very little margin for error,” she said, citing several incidents when fresh market exports were rejected at the importing country because there were no MRLs for the products used on the crop.

Rich Carver, senior product registration manager for DuPont, said DuPont is working to stay in front of the MRL issue.

"However, if there are no MRL studies for the products used in this county in the country where you are shipping, there are no guarantees the country will accept the product.”

A major buyer of U.S. products is Canada, and Carver says America’s northern neighbor is trying to harmonize MRLs with U.S. EPA. However it is not easy since how MRLs are calculated can differ between countries.

Also, Carver said the U.S. moves new chemistry through the registration process and sets its residue tolerance quickly compared to other countries.

"In Taiwan for example, there are thousands of MRLs to be established, and only one person is doing it,” he points out.

The MRL is a nettlesome issue with DuPont’s new Rynaxypyr products. It is one of the newest and least toxic pesticides introduced in the U.S.

"EPA is supporting its use on virtually every crop in the U.S. and many countries have established MRLs for it. However, many have not, and it cannot be used on ag products going into those countries.”

For four years, the California Specialty Crop Council has sponsored a workshop where representatives from several nations gather to discuss the issue and work toward MRL harmonization.

"It is a very complex issue that will only become more complex and important to our ag exports,” said Berger.