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Australian Food and Grocery Council
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Individual
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Consumer
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Your submission
Please provide your overall view on FSANZ's assessment for proposal M1022 and the draft regulatory measure.
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Support
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Please explain your response below.
The AFGC supports the continual review and update of the Australia New Zealand Food Standards Code (the Code) in order to reflect the current status of agricultural and veterinary (agvet) chemicals in use in Australia, and to support international trade through recognition of agvet chemicals in use in other markets e.g. through alignment with applicable Codex Alimentarius standards.
The AFGC understands that FSANZ is proposing amendments to Schedule 20 of the Australia New Zealand Food Standards Code (the Code) after consideration of maximum residue limits (MRLs):
• adopted at the 2023 Codex Alimentarius Commission meeting,
• requested by stakeholders seeking alignment with standards set by international trading partners, and
• to reflect changes in agricultural and veterinary (agvet) chemical usage in Australia as requested by the Australian Pesticides and Veterinary Medicines Authority (APVMA).
The AFGC appreciates the opportunity to comment on this proposal.
Members of the AFGC import food and ingredients into Australia which may contain residues of agricultural and veterinary (agvet) chemicals arising from intentional use during agricultural production and/or low-level cross-contamination (such as spray drift or soil residue when crops are rotated or from other co-mingling).
Compliance with the MRLs in Schedule 20 of the Food Standards Code (the Code) is challenging when these MRLs vary from those in other jurisdictions (and Codex) and may represent a regulatory burden and trade barrier. Therefore, the AFGC welcomes initiatives to align domestic MRLs with those accepted internationally.
The outcome of a misalignment with other jurisdictions is that importers are prohibited from importing food containing these chemicals which are frequently present at the lowest levels of detection, representing very little if any risk to consumers. Australian consumers are disadvantaged by the resulting limitations on food choice and companies lose business opportunities.
While the current MRL harmonisation process provides an avenue to align with international standards, it is resource intensive process for FSANZ and industry stakeholders alike, with a significant time lag from when changes occur (domestically or internationally). The AFGC continues to advocate for more innovative, risk-based and timely approaches to the management of low levels of agvet chemicals that maintains the safety of the food supply for Australian consumers.
The AFGC understands that FSANZ is proposing amendments to Schedule 20 of the Australia New Zealand Food Standards Code (the Code) after consideration of maximum residue limits (MRLs):
• adopted at the 2023 Codex Alimentarius Commission meeting,
• requested by stakeholders seeking alignment with standards set by international trading partners, and
• to reflect changes in agricultural and veterinary (agvet) chemical usage in Australia as requested by the Australian Pesticides and Veterinary Medicines Authority (APVMA).
The AFGC appreciates the opportunity to comment on this proposal.
Members of the AFGC import food and ingredients into Australia which may contain residues of agricultural and veterinary (agvet) chemicals arising from intentional use during agricultural production and/or low-level cross-contamination (such as spray drift or soil residue when crops are rotated or from other co-mingling).
Compliance with the MRLs in Schedule 20 of the Food Standards Code (the Code) is challenging when these MRLs vary from those in other jurisdictions (and Codex) and may represent a regulatory burden and trade barrier. Therefore, the AFGC welcomes initiatives to align domestic MRLs with those accepted internationally.
The outcome of a misalignment with other jurisdictions is that importers are prohibited from importing food containing these chemicals which are frequently present at the lowest levels of detection, representing very little if any risk to consumers. Australian consumers are disadvantaged by the resulting limitations on food choice and companies lose business opportunities.
While the current MRL harmonisation process provides an avenue to align with international standards, it is resource intensive process for FSANZ and industry stakeholders alike, with a significant time lag from when changes occur (domestically or internationally). The AFGC continues to advocate for more innovative, risk-based and timely approaches to the management of low levels of agvet chemicals that maintains the safety of the food supply for Australian consumers.
If there is any other information you would like to provide for the proposal M1022 consultation, please include this in the box below.
Any other information
The AFGC has identified potential negative impacts on trade (imported food and ingredients) from the following proposed MRL changes, and therefore requests that the existing MRLs are retained in Schedule 20.
A summary of current MRLs for these compounds in all other markets is provided as separate excel files (confidential).
Proposed deletions:
Fludioxonil / Strawberry
FSANZ proposes to repeal the MRL for fludioxonil / strawberry (from 5 mg/kg to none).
MRLs for fludioxonil / strawberry are 3mg/kg and 4mg/kg in Codex and the EU.
Methidathion / Pear
FSANZ proposes to repeal the MRL for methidathion / pear (from 1 mg/kg to none).
A number of international markets have MRLs up to 1mg/kg.
Proposed reductions:
Dimethoate / Cherries
FSANZ proposes to decrease the MRL for dimethoate / cherries from T0.2 mg/kg to 0.01 mg/kg.
A number of international markets have MRLs up to 2 mg/kg (including the US).
Dimethoate / Mango
FSANZ proposes to decrease the MRL for dimethoate / mango from 1 mg/kg to 0.5 mg/kg.
A number of key international markets have MRLs up to 1mg/kg.
A summary of current MRLs for these compounds in all other markets is provided as separate excel files (confidential).
Proposed deletions:
Fludioxonil / Strawberry
FSANZ proposes to repeal the MRL for fludioxonil / strawberry (from 5 mg/kg to none).
MRLs for fludioxonil / strawberry are 3mg/kg and 4mg/kg in Codex and the EU.
Methidathion / Pear
FSANZ proposes to repeal the MRL for methidathion / pear (from 1 mg/kg to none).
A number of international markets have MRLs up to 1mg/kg.
Proposed reductions:
Dimethoate / Cherries
FSANZ proposes to decrease the MRL for dimethoate / cherries from T0.2 mg/kg to 0.01 mg/kg.
A number of international markets have MRLs up to 2 mg/kg (including the US).
Dimethoate / Mango
FSANZ proposes to decrease the MRL for dimethoate / mango from 1 mg/kg to 0.5 mg/kg.
A number of key international markets have MRLs up to 1mg/kg.