Dear Commissionner Hogan,

Dear Commissionner Malmstrom,

Dear Commissioner Vella


In October 2016, the EU decided on non-approval of the use of fungicide Tricyclazole through Implementing Regulation No 2016/1826 of the 14th of October 2016. Subsequently Regulation 2017 /983 of the 9th June 2017 has reduced the Maximum Residue Level (MRL) for basmati rice to 0.01 mg/kg from 1 mg / kg, with effect from 30 December 2017.


However, this non-approval decision regarding Tricyclazole was taken without waiting for the submission of all the necessary data. 9 of the 10 tests were completed, but the final check for the carcinogenic effect of this pesticide was not completed before a decision was made.


Taking such a decision without all the relevant data will have serious effect on the export and import of Basmati rice from India, and the EU must be careful not to legislate using precaution, but rather clear and definitive facts. Therefore, this decision seems disproportionate given Tricyclazole’s long history of use in Japan and in the U.S., with much higher levels of use, without any report of adverse effect on health.


Without the use of this pesticide in India, it is difficult to target rice blast disease, and will therefore, result in serious crop loss to producers in India. This is a product unique to India and Pakistan, and such a decision would severely affect the ability of India to compete in this market.


This will not only cause damage to our trade relations with India, and damage the reputation of brands which have been respected and popular for decades; but also cause job losses both in India and in the EU, and passes on the increased cost of a reduced crop to the EU consumer. At present 360, 000 mt tonnes of basmati rice are exported to the EU, 150, 000 mt tonnes to the UK. This is quite frankly policy making without common sense.


The non-use of Tricyclazole will take effect from the 30th of December, and I believe it is important to find a solution before this date arrives. We must ensure that the decisions we are making in Brussels benefit the consumer, business, and our future trading relationships.


I believe that we should seek a pragmatic solutions, and therefore, would like the Commission to consider the feasibility of establishing ‘import tolerance’, or to allow for an extended transition period to allow India to transition to the new technical specifications over a longer period of time. 6 months seems unnecessarily short transition period for the import of a product treated with a pesticide which has never caused any concern for public health and safety in the decades it has been used sold in the EU.


I look forward to your reply and your assistance in finding a solution to this situation.

Yours sincerelySyed Kamall MEP

Co-Chairman of the ECR Group in the European Parliament

Conservative MEP for London


Answer Below


Honourable Member,


Thank you for your letter of 11 October 2017 addressed to Commissioners Malmström, Hogan and Vella on tricyclazole. As Regulation (EC) No 396/2005 on maximum residue levels (MRLs) of pesticides in or on food and feed falls under my responsibility, I am pleased to provide you with the following information.


In your letter, you refer to the non-approval of tricyclazole by Commission Implementing

Regulation (EU) 2016/1826 of 14 October 2016.


The problems with tricyclazole are not new. Already in 2008, the Commission reached the

conclusion that tricyclazole should not be approved due to concerns for human health, notably the inability to conclude on the genotoxic and carcinogenic potential of the substance (Decision 2008/770/EC1 of 30 September 2008). It was the responsibility of the manufacturer to address these concerns and data gaps in the subsequent submission for approval. However, this was not the case and the same critical concerns were identified by EFSA in 20152. This explains why the Commission could not approve it.


In addition, in 2012 an import tolerance request was submitted by the manufacturer who, again, did not address the identified critical concerns as stated in the related EFSA reasoned opinion3. As a consequence, no import tolerance could be set.


India was kept fully informed during the course of the decision process on the state-of-play for tricyclazole in rice. The intention to lower the MRL to the limit of quantification was announced already in July 20114 5in a WTO/SPS notification and India was successively informed on numerous occasions of all developments. WTO/TBT notifications, as regards the non-approval of the substance, were also made in May 20083 and October 20156 7and, the lowering of the MRLs as a consequence of the second decision on non-approval, was then again notified to WTO in November 2016. The situation thus comes as no surprise to India, and six years have since elapsed for growers to begin adjusting practices since the 2011 SPS notification.


Regarding transition measures, I would like to point out that specific measures have already been adopted for Basmati rice. Contrary to other commodities – for which MRLs were lowered on 30 June 2017 – the MRL for Basmati rice will be lowered on 30 December 2017.


The Commission remains willing to consider any new import tolerance request concerning

tricyclazole in rice, should this request be supported by scientific evidence.

Yours Sincerely,

Vytenis Andriukaitis



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