Britain raised the issue of MRLs. Norman Kelly, who chairs the International Tea Committee, cited what he called “horrible discrepancies” between Codex and EU requirements for maximum residue levels (MRLs).
A supply/demand analysis is too simple. “We need a new economic paradigm,” argued Kelly.
He described the strong relationship between supply, pricing, and MLRs, and felt strongly the industry needs to approach authorities with “an intelligent, science-based approach.”
MLR harmonization is a hot-button issue: Indonesia stated that when thresholds for MRLs are established it is difficult, if not impossible, to object because “we don’t have the scientific knowledge and funding.” India said different tea es- tates use different BAP (best agricultural practices), adding to the confusion.
Producers should stop using out-dated chemicals and move to modern products, said Kelly.
The working group on MRLs issued two reports during the International Intergovernmental Group on Tea (IGG) sessions. The first was concerned with the implications of MRLs on the tea trade, the second with the acceptance of a new method for establishing MRLs in tea, by testing brewed tea.
The MRLs for tea are set by CODEX Alimentarius, an organization established in 1963 by the Food & Agriculture Orga- nization (FAO) and WHO to ensure food safety in global trade.
The standards set by the organization are not compulsory, but they are often adopted into law by individual countries or regional groups of countries. They increasingly have a chilling effect on the tea trade and have been compared unflatteringly to what are known as “non-tariff barriers to trade.”
The MRL discussion was one of the most animated of the session, with implications for players up and down the sup- ply chain. It can have a downside effect on smallholder costs and on consumer cost. One of the biggest problems en- countered by the tea industry is the fact that MRLs that are not in harmony with CODEX standards have been adopted into law by organizations, political entities and individual nations. The EU, the US, and Japan, for instance, have MRLs which differ both in the number of compounds listed and thresholds (mg per kg.) of residuals allowed. This causes costly confusion in the tea industry, particularly in producing nations, but for importing nations and consumers, as well.
Due to the non-harmonization of MRLs in tea, tea producing and exporting nations cannot count on a single set of standards for the industry. Each market may hew to a different set of MRLs, making it costly, if not impossible, to conform to global markets. This is a roadblock to the global tea trade, potentially leading to economic insecurity in exporting countries.
IGG on Tea has submitted a list to CODEX Alimentarius of priority chemicals for review, showing the correlation between field trial protocols and good laboratory practices, and the submission was accepted.
Canadian delegate Louise Roberge praised the progress made over the past seven years by the IGG and the working group on MRLs, saying they have made “terrific, realistic progress.” Roberge is president of the Tea Association of Canada.
A second report from the working group on tea brew provided an update on ef- forts to establish MRLs in brewed tea instead of dried leaves. In 2011, this group submitted a proposal to the Codex Committee on Pesticide Residues (CCPR), an inter- governmental working group that fosters agreement between governments regarding MLRs of pesticides allowable in exported and imported food.
IGG’s position is that while analysis of dry leaf is well established and useful, most tea in international trade is consumed brewed. Much could be gained by offering an alternative method, the tea brew method, which, as the name suggests, tests for chemical solids dissolved or diluted in tea brew rather than that held on or in the dried tea leaf.
At the 44th Session of the CCPR, April 2012, IGG’s recommendation was adopted by the committee. Minutes of the meeting note that the basic method of establishing MRLs for tea remains, but the action gives official recognition and status to the alternative method of testing the tea brew:
The 44th CCPR Report, in Paragraph 178, reaffirmed the committee’s support for the current procedure in the establishment of MRLs pesticides in tea and “encouraged countries to submit relevant data/information on brewing factors and standard methods [for] consideration in estimation of MRLs.”
In layman’s terms: the CCPR, which is responsible for determining what methods may be used for establishing MLRs in tea, recognizes and accepts that there is an alternative method with scientific merit and that tea-producing countries may submit reports containing scientific evidence of the efficaciousness of such methods.
Delegates stressed the need to communicate about MRLs to the public.
“Education about the safety and health benefits of tea is critical to everyone involved in the tea industry, from small holder to retailer to the consumer,” said Roberge.