The major interest for crop protection of agrochemical substances without maximum residue limit (MRL)

Description of the subject. The real-time management of residues of plant protection products is a general issue for food producers and/or exporters. Authorized pesticides under European Regulation (EC) No 1107/2009 (Reg. 1107/2009) are granted a maximum residue limit (MRL) defined by the European Chemicals Agency (ECHA). These maximum residue limits are managed by the European Commission and listed in EC Regulation No 396/2005. MRLs for newly approved substances are set for pesticide residues present in products or groups of products covered by Annex I with a default value of 0.01 mg·kg-1, unless they have been considered, elaborated upon on approval and affected in one of the six other Annexes (II to VII). Substances listed in Annex IV are favoured in the selection of substances to be used by producers as it is for substances with very low potential impacts (low-risk substances [Art. 22 of Reg. 1107/2009] which therefore require no MRL; basic substances [Art. 23 of Reg. 1107/2009]; and microorganisms). The number of substances affected by this lack of an MRL (without residues survey requirement) has been steadily increasing since the publication of the SANCO/11188/2013 Guideline. Many biocontrol agents are listed in Annex IV, including microbial insecticides (e.g. Bacillus thuringiensis, Cydia pomonella granulosis virus), semiochemicals used in traps (e.g. ammonium acetate, putrescine) and some natural substances (e.g. sulphur) as well as all the currently listed basic substances. Objectives. To show that plant protection may be achieved with less concern or control (auto + external) than with certain agrochemical pesticides, including those without maximum residue limits (MRL). Method. Analysis of EU Pesticide Database and EU Regulation (EU) No 540/2011. Results. All approved pesticide active substances with no MRL included in Annex IV of Regulation (EC) No 396/2005, listed by substance status type (active, low-risk or basic) and category (microorganism, semiochemical or natural). Conclusions. These results may be used to help achieve plant protection with much less risk of contaminations, while noting the necessity for controls, analytical issues, positive controls, as well as the possibility of downgrading and withdrawal of approval from the market.