Concepts for handling residue cases in organic products

Summary

A previous study has shown that to date, findings of pesticide residues in organic products (thereafter called ‘residue cases’) are treated in very different ways across the EU. This successor study provides input on how the handling of residue cases could be improved and harmonized. The provisions of Reg. 2018/848, Art. 28 and 29 constitute the general framework. The study aims to contribute to a successful implementation of these new requirements, and also towards further improvement and harmonization when the topic which will be on agenda of the European Commission in 2024/2025.
The methodology used for this study is mainly based on a qualitative approach with questionnaires, workshops and interviews with stakeholders from the organic sector, particularly quality management experts from operators, CBs/CAs and representative organic associations on EU level.
A snapshot of the residue situation in organic processors and traders was obtained with a questionnaire. The operators stated that effects related to timely delivery (from supplier to operator and/or from operator to client) cause the greatest problems. Based on >10 000 analyses, the effects of various threshold levels were estimated. Organic operators make great efforts for avoiding residues. Many operators systematically test all incoming food lots for residues. This clearly exceeds the requirements of the food law and the organic regulation.
The following approaches are most often applied in the EU: ‘de-certification level’, ‘zero-tolerance’, ‘investigation level’ and ‘case by case approach’. An evaluation of these approaches showed that each approach has its own strengths and weaknesses.
The following requirements were judged to be most important for an improved approach: it must be realistically workable (labour efforts; proportionate costs; realistic expectations for know-how and staff qualification; realistically enforceable requirements), it must be harmonized across the EU and possibly beyond and it must take into account background pollution.
A number of ‘instruments’ are proposed to mitigate specific weaknesses of individual approaches and/or to improve and harmonize the handling of residue cases. The first two instruments form the core of the system, while the remaining instruments provide additional support to it.