Using Trade Data to Develop MRL Strategies to Maximize Crop Protection Options for Growers Richard A. Carver, Ph.D. DuPont Crop Protection June, 2010
Developing a Strategy 1. Identify the commodities 2. Define the markets 3. Identify unmet needs 4. Develop a plan to address key needs 5. Educate Food Chain
Identify the Commodities Review the proposed US label(s) Identify the key commodities Consult with IR-4/Growers/ Grower Groups/PCAs Is the impact on the business sufficient to justify additional resources for these commodities? Additional non-us residue data Registration resources in other countries
Define the Markets Determine the priority markets for each key commodity or commodity group FAS Global Agricutural Trade System http://www.fas.usda.gov/gats/default.aspx FAO http://faostat.fao.org/ EU http://epp.eurostat.ec.europa.eu/portal/page/portal/eurostat/ home
GATS Global Agricutural Trade System US trade data collected from exporter Items are categorized according to the Harmonized Commodity Description and Coding System Everything receives a code
BICO Bulk Coarse Grains - YELLOW DENT CORN (MAIZE), US NO 1, EXCEPT SEED Intermediate Corn Flour Consumer Oriented CORN CHIPS AND SIMILAR CRISP SAVORY SNACK FOODS
Choosing Commodities Commodities must be chosen Grape Grapefruit juice Grape juice Wine Vermouth Raisins Grapefruit Grapes (fresh) Crop groups should be considered
Choosing Commodities Quantity or Value? Solids versus liquids Metric tons Kiloliters Value in US dollars More priority to higher value items Recommendation: Value
Ranking Export Partners Select appropriate export partner units EU vs individual EU countries Countries with major ports will be biased Israel Gaza Strip, Israel, West Bank
Ranking Export Partners One year or average of multiple years Consider trends For cherries to China: 2005 2006 2007 2008 2009 Avg 569 595 2,098 1,251 9,888 2,880
How Many Partners? Top 10? 90 th Percentile? 100%?
Mexico 25.39% Canada 21.10% Taiwan 5.15% European Union-27 4.92% Apples & Pears 2009 78 Countries India Indonesia Hong Kong United Arab Emirates Russia Saudi Arabia Colombia Egypt Thailand 4.49% 4.44% 4.29% 4.12% 2.68% 2.09% 1.59% 1.54% 1.46% Brassica Veg 2009 29 Countries Canada Japan Taiwan Mexico 75.98% 15.72% 5.64% 1.42% 98.76% Brazil 1.41% Dominican Republic 1.09% Malaysia 1.08% Total 86.85%
Ranking Export Partners Other Factors Does everything make sense? Is there any partner that warrants special attention? Check with Growers/Grower Groups/PCAs Are there special circumstances? Customer requirements Trade issues Geopolitical considerations
Developing a Plan Are there export partners for which MRLs are not needed? Mexico accepts US tolerances as a default Import MRLs not needed for countries that do not monitor or enforce MRLs However, this can change All want to be in compliance Nobody wants to learn from enforcement
Extrapolations/ Bridging Residue Data EPA permits extrapolations from surrogate data which other countries or Codex may not yet find acceptable Crop Groups Other extrapolations Acceptability of extrapolations will change with time and data development
Key U.S. Trading Partners That Don t Default to Codex MRLs Canada European Union (27 countries) Japan Taiwan Australia Russia New Zealand Argentina Turkey (EU?)
Trading Partners That Accept or Default to Codex MRLs Algiers Guatemala Angola Honduras Bahamas Hong Kong Bahrain Indonesia* Bangladesh Israel* Barbados Jordan Bermuda Kenya Brazil* Korea (South)* Chile Kuwait Colombia Lebanon Costa Rica Malaysia* Dominican Republic New Zealand Ecuador Nicaragua Egypt Oman El Salvador Pakistan Panama Peru Philippines Qatar Saudi Arabia Singapore* Thailand* Trinidad & Tobago Tunisia United Arab Emirates Venezuela *Countries defer to Codex if no domestic MRL exists
Deferral to Exporting Country s MRL Albania Antigua & Barbuda Cayman Islands Haiti Nevis Sri Lanka St. Lucia
Identify the MRL Gaps Identify key countries for each crop No domestic registrations planned Citrus in Canada Domestic registrations planned but not for US grown crop Pursue MRL for minor crop for which the use is not a domestic priority Domestic use not aligned with US label so that an MRL discrepancy will exist Different pest spectrum Different climate
Apparent MRL Discrepancies Regulatory agencies determine MRLs differently Crop groupings Differing regulatory schemes The same data can result in different MRLs in different countries Peaches (US) = 1.0 ppm Peaches (EU) = 0.5 ppm
Harmonization Proposed efforts to obtain global harmonization Codex MRLs established first Everyone else follows Best case today US label results in meeting foreign MRL even if US tolerance differs
Seek MRLs Seek Codex MRLs as early as possible Register key crops in key countries Register minor crop to establish MRL Seek import MRL Business justification to obtain resources may be the challenge
How Long Does It Take? US JAPAN IMPORT MRLs CODEX MRLs* CANADA *Codex MRLs can, in some situations, be initiated somewhat earlier than shown EU 0 1 2 3 4 5 Bars represent regulatory approval times for both registrations and tolerances/mrls unless otherwise indicated (assuming simultaneous applications are made for both)
Educate Food Chain MRLs are not all established simultaneously Food chain must be educated on the status of MRLs in key geographies Despite best efforts, true harmonization may be difficult to achieve
Simplifying a Complex Message Top US Export Recipients for Cherries in 2009 2009 Partner Percent Product A Product B Product C Product D Product E Product F Product G Product H Canada 36.10% Japan 21.06% Taiwan 8.06% A Korea, South 7.19% EU-27 7.12% Australia 5.35% Hong Kong 5.32% Codex 90.21% 2009 Percent = Percent of total US cherry export value A = Cherry MRL expected in 2010 Legend No MRL established MRL established but lower than US tolerance MRL equal to or greater than US tolerance
But What If The Message Isn t Simple? 2009 Partner Percent Product A Canada 36.10% Japan 21.06% Taiwan 8.06% Korea, South 7.19% EU-27 7.12% Australia 5.35% Hong Kong 5.32% Codex 90.21% 2009 Partner Percent Product A Canada 36.10% Japan 21.06% Taiwan 8.06% Korea, South 7.19% EU-27 7.12% Australia 5.35% Hong Kong 5.32% Codex 90.21% 2009 Percent = Percent of total US cherry export value 2009 Percent = Percent of total US cherry export value Legend No MRL established MRL established but lower than US tolerance MRL equal to or greater than US tolerance Legend No MRL established MRL established but lower than US tolerance MRL equal to or greater than US tolerance MRL equal to or greater than US tolerance for certain use pattern
Conclusions MRL trade barriers will significantly reduce acceptability by growers Key to a registration plan/mrl strategy is the examination of commodity export trade data Regulatory policies and enforcement activities are constantly changing Business and Regulatory Agency resource limitations may restrict what can be done Education is a key to gaining use acceptance by food chain