Discussions are underway in Brussels on potential changes to the EU framework for Maximum Residue Levels, known as MRLs, for substances that are not approved for use within the EU. While often presented as a technical adjustment to residue policy, such changes could have could have consequences far beyond food safety, affecting supply chains, trade, competitiveness and innovation.
That is why CropLife Europe has set out the key issues that should be examined in a full, evidence-based Impact Assessment before any legislative proposal is brought forward.
MRLs have a clear and well-established role in EU legislation. They are market access standards designed to ensure that consumer exposure to pesticide residues remains within safe limits, based on rigorous risk assessments carried out by the European Food Safety Authority. Any change to this framework therefore deserves careful consideration, not only from a consumer safety perspective, but also in terms of wider economic, legal and international effects.
The European Commission announced its intention to carry out an Impact Assessment before any proposal was on the table. This is an essential step to ensure decisions remain science-based, proportionate and coherent with the EU’s broader policy objectives.
Looking beyond a narrow policy lens
Proposals to default certain MRLs to the limit of quantification, often referred to as “technical zero”, are sometimes framed as a way to support EU farmers or advance sustainability goals. However, using MRL policy to pursue objectives other than managing consumer exposure risks blurring the purpose of the system and weakening regulatory coherence.
A meaningful Impact Assessment should therefore examine whether such changes would deliver measurable health benefits beyond the existing framework, which already ensures a high level of consumer protection. It should also assess whether residue policy is the right tool to address broader challenges such as competitiveness, innovation, strategic autonomy or sustainability.
Real-world consequences for food, trade and innovation
Changes to MRL policy can have immediate effects on supply chains. Even regulatory uncertainty can prompt exporters to redirect products away from the EU, with implications for food and feed availability, prices and resilience – particularly for commodities where the Europe depends on imports.
There are also important trade considerations. MRLs function as conditions for market access. Systematic recourse to technical zero without risk-based justification could raise questions about proportionality, create unjustified barriers to trade and undermine confidence in the EU’s regulatory system.
Regulatory predictability is equally important for innovation. When residue rules become detached from risk assessment, incentives to invest in new crop protection technologies are weakened. Over time this can limit farmer’s access to effective tools and reduce the resilience of agricultural production both in Europe and beyond.
The importance of process
Under the EU’s Better Regulation principles, Impact Assessments should inform policy choices, not follow them. Completing a comprehensive, transparent and cross-sectoral assessment before advancing legislative changes is essential to avoid unintended consequences and ensure evidence-based decision-making.
Such an assessment should look at the full range of potential impacts: consumer protection, food and feed availability, import dependency, trade relations, competitiveness, innovation, legal certainty and the EU’s international commitments.
CropLife Europe’s detailed paper sets our key consideration of what needs to be assessed to ensure that any future changes to the EU MRL Framework are guided by science, proportionality and clear understanding of their real-world consequences.
For more info please follow the link to read CropLife Europe’s detailed paper setting our key consideration of what needs to be assessed to ensure that any future changes to the EU MRL Framework so its guided by science, proportionality and clear understanding of their real-world consequences.