Response to comments received on PMRL consultation for Difenoconazole (PMRL2021-01)
The proposed maximum residue limit (MRL) document for difenoconazole (PMRL2021-01) was published using the historical term "radish tops" with a corresponding MRL of 8 ppm, instead of the current term 'radish leaves', where the latter is a commodity within Crop Subgroup 4-13B for which an MRL of 35 ppm was established on 23 November 2020 via entry into the MRL Database.
Response from Health Canada
The difenoconazole MRL of 35 ppm is supported by data provided for CSG 4-13B, which is applicable to potential residues of difenoconazole in radish leaves. For this reason, Health Canada's MRL database has been updated to ensure that the correct terminology is used, which includes the associated MRL value of 35 ppm. Therefore, the MRL database does not mention radish tops at the proposed MRL of 8 ppm.
This change is not likely to result in any trade impediments given that there are currently no Codex MRLs for radish leaves and the USEPA (our major trading partner) lists an MRL of 8 ppm for Leaves of root and tuber vegetables (CG2) and 35 ppm for Brassica Leafy Greens (CSG4-16B), without any distinction for radish leaves.
The Pest Management Regulatory Agency of Health Canada has informed the Sanitary and Phytosanitary (SPS) Committee of the World Trade Organization of this matter.
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