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Practice Areas

Agricultural Trade Impact of Pesticide Residue Levels Subject of ITC Probe

Wednesday, September 25, 2019
Sandler, Travis & Rosenberg Trade Report

The International Trade Commission has initiated an investigation into the global economic impact of maximum residue level policies for pesticides. In requesting this investigation the Office of the U.S. Trade Representative indicated that MRLs, particularly those that are missing or low, can serve as barriers to U.S. agricultural exports.

The ITC states that its reports in this investigation (due April 30, 2020, and Nov. 2, 2020) will include information on the following.

- the role of plant protection products and their MRLs in relation to global production, international trade, and food safety for consumers

- the approaches taken in setting national and international MRLs for crops (e.g., risk-based approach vs. hazard-based approach)

- how MRLs are developed and administered in major markets for U.S. agricultural exports

- challenges and concerns faced by exporting countries in meeting importing country MRLs

- the costs and effects of MRL compliance and non-compliance for producers

- how missing and low MRLs affect countries representing a range of income classifications, particularly low-income countries, with regard to production, exports, farmer income, and prices

- how missing and low MRLs affect production, exports, farmer income, and prices, both on the national level and, to the extent possible, for small and medium-sized farms

The ITC will hold a hearing in connection with this investigation Oct. 29. Pre-hearing briefs and statements are due Oct. 21 and post-hearing briefs are due Nov. 5. All other written submissions are due Dec. 13 for the first report and June 5 for the second report.

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