As discussions continue around the Food & Feed Safety Omnibus, one aspect deserves closer public attention: the proposed shift in how the EU sets Maximum Residue Levels (MRLs).
This part of food safety legislation is sometimes portrayed as overly complex. In reality, the principle is straightforward and more importantly, is grounded in science.
Today, the MRL systemis part of a science-based framework that protects consumers, including under conservative worst-case assumptions. There is no evidence from EFSA, or elsewhere in the legislative record, that the current system fails to protect the public. On the contrary, it consistently demonstrates its robustness: dietary exposure remains well below health-based guidance values and residues on food MRL compliant whether the food is grown in the EU or outside.
So the question is simple: why change something that is not broken?
A shift that brings risks, not safety improvements
The new provision in the Omnibus would allow MRLs to be set at the limit of quantification, a “technical zero”, based on hazard properties rather than dietary risk.
That may sound simpler on paper, but the consequences could be significant.
A hazard-based MRL approach risks:
- excluding safe food from the EU market for administrative reasons,
- disrupting trade flows the EU food system relies on, including key imports like coffee, spices, cocoa, canola, soy and offseason produce,
- raising costs for operators and ultimately consumers,
- and disproportionately harming developing country exporters.
Crucially: none of this improves safety, because protection is already fully assured under today’s risk-based framework.
A competitiveness argument pointed at the wrong target
Some argue that this change would level the playing field for EU farmers. But changing how MRLs are set will not solve the real competitiveness gap. The core issue is that EU farmers have more limited access to crop protection tools than many of their global competitors. That is what affects their ability to compete. A hazard-based MRLs approach does not address that problem. If anything, it adds pressure on supply chains while leaving the underlying issue untouched.
If the goal is truly to improve farmer competitiveness, then the meaningful solutions lie in the approval framework (Regulation 1107/2009),not in redefining what MRLs are meant to do.
Recognising the genuine improvements in the Omnibus
It’s important to distinguish between the provisions put forward. The Omnibus does include several technical adjustments that truly align with simplification objectives: clearer terminology, the potential for permanent MRLs derived from monitoring data and more efficient scientific processes. These practical changes can reduce friction in the system and improve how the system functioning.
But shifting MRLs toward a hazard-based approach belongs in a completely different category. It introduces complexity and uncertainty without any safety benefit.
What the EU needs is stability, clarity, and science-based decisionm-aking
Consumers are already protected. The system is already delivering safety.
What is at stake now is predictability for farmers, resilience in our food supply chains and coherence with international standards.
To maintain trust, transparency and real-world functionality, EU MRLs must remain risk-based.
To learn more about CropLife Europe’s position on MRLs and trade click here for our position paper