Verband der deutschen Fruchtsaft-Industrie e.V.
VdF
Vertretung der allgemeinen und ideellen Interessen der Hersteller von Fruchtsäften, Nektaren und verwandten Erzeugnissen national und international, insbesondere im Gebiet des Lebensmittels-, Wirtschafts-, Wettbewerb- und Steuerrechts.
ID: 073709432738-34
Lobbying Activity
Response to Commission Regulation setting maximum residue levels for chlorate in or on certain products
15 Feb 2019
Proposed Chlorate Maximum Residue Limits (MRL)
Public consultation
The VdF is the federal association of fruit juice/nectar and vegetable juice/nectar producers in Germany, representing 90 % of German fruit and vegetable juice industry.
It is undoubted, that uses of chlorine disinfectants in drinking water processing lead to detectable residues of chlorate in food (amendment 3 SANTE/10684/2015 Rev. 3). It is further undoubted, that it is currently not possible to achieve levels of chlorate residues compliant with default MRL given in Regulation (EC) No 396/2005 (amendment 4) and a temporary solution is needed (amendment 7).
In our opinion specific chlorate MRL in Regulation (EC) No 396/2005 are not suitable as (temporary) solution, because chlorate findings in processed food, e.g. fruit and vegetable juices, don´t relate to pesticide use.
We would like to mention that a maximum chlorate level is proposed in draft directive on quality of water intended for human consumption (COM/2017/0753 final - 2017/0332 (COD)). In the explanatory memorandum it is said, the Commission considers that it is justified to set the value for chlorate and chlorite at the stricter level of 0.25 mg/l, which is around 3 times lower than proposed by the WHO.
The production of fruit juice and nectar is governed by the clear legal requirements of the fruit juice Regulation (EC) No 2001/112, whereby also drinking water is used. For reasons of hygiene it is often necessary to chlorinate the drinking water.
MRL set in Regulation (EC) No 396/2005 being 12.5 times lower than proposed drinking water level would cause noncompliance when chlorinated drinking water is used during food production. That would mean legally correctly produced food would be non-marketable.
In our opinion chlorate in processed food is a contaminant and therefore maximum levels should be regulated in contaminant legislation. A feasible (temporary) solution could therefore be to exclude processed food expressly from the scope of chlorate MRL due to the tact that residues don´t relate to pesticide use or at least set proposed MRL for fruit and vegetable juice to a higher level which recognises the use of chlorinated water during production process.
Finally, we would like to emphasize that we also support the lowest possible levels of pesticide residues in food, but at the same time food safety includes more essential aspects, in particular microbiological safety.
Overall it is imperative that the legal framework is coherent.
Bonn, 15.02.2019
Verband der deutschen
Fruchtsaft-Industrie e. V.
Mainzer Str. 253
Germany 53179 Bonn
www.fruchtsaft.de
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