Response to comment received on the PMRL consultation for Methomyl (PMRL2023-03)

A comment was received acknowledging the importance of harmonizing maximum residue limits (MRLs) between the United States and Canada for the Canadian produce sector. It was also noted, however, that a joint registration approach for new applications and re-evaluations of existing MRLs should be considered, rather than proposing MRLs for importation only, as in this case, where the request was to set MRLs for methomyl for imported head and leaf lettuce. The comment noted that a harmonized approach should be employed to ensure that Canadian producers have access to the same crop protection tools as producers in other countries.

Response from Health Canada

In PMRL2023-03, the PMRA is proposing to set an MRL for methomyl on imported commodities, which will permit the import and sale of head and leaf lettuce containing methomyl residues into Canada.

Health Canada's Pest Management Regulatory Agency (PMRA) appreciates the comment regarding the importance of maintaining global competitiveness for Canadian growers. In many cases, registration of a pesticide in some economies is not a cost-effective option for pesticide manufacturers given minor uses and expected low use volumes. That is, the return on investment for the manufacturer for investing their time in submitting an application for domestic registration (including undertaking stewardship activities once registered) is far lower than the return that may be expected from pursuing registrations of pesticides in other economies, even if no extra data generation is required. Nevertheless, PMRA maintains an open dialogue with manufacturers to express the importance of registering new active ingredients and uses in Canada. The PMRA remains committed to encouraging registrants to submit applications for domestic registration and is actively exploring mechanisms and incentives to this end.

As the comment received has no impact on the proposed MRL, the MRL of 5.0 ppm for methomyl on head and leaf lettuce will be established as proposed in PMRL2023-03.

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