On 13 June 2022, the Middle Eastern countries of Bahrain, Oman, Saudi Arabia, and the UAE notified the World Trade Organization (WTO) of their intent to implement legislation that would specify the maximum residue limits of pesticides and contaminants permitted in organic food. These are the country-implemented legislation arising from the Gulf Cooperation Council’s (GCC) Technical Standard Committee’s TC No. (TC05/SC2) “GSO [Gulf Standards Organization]Technical Subcommittee for Additives and Food Contaminants” (“GSO 2532/2016”), prepared by the country of Yemen.
GSO 2532/2016 defines “pesticide residues” as “Residues including active substances and products of metabolic processes and / or products cracking or reaction products of active substances used for plant protection products.”[1] Per Section 4, “The limits and calculation method” [sic], pesticides are forbidden for use in organic food; however, “in the case of the effects as a result of pollution”, pesticide residues shall not exceed 0.01 mg/kg.[2] Additionally, when this 0.01 mg/kg level is reached, “it shall be notified of inspection and certification to take necessary procedures in this regard”.[3]
Further, if the food product has more than the 0.01 mg/kg limit of pesticide, or if it contains three or more pesticides whose residue are within the maximum limit of 0.01 mg/kg (individually), the phrase “organic food” cannot be used on the product.[4] Section 4.3, “Calculation Method” lays out the calculation method(s) to be used, depending on whether the food item(s) at issue is/are “fresh or raw products or “dried, diluted or concentrated products”.[5]
The individual country implementations of GSO 2532/2016 are:
· Bahrain: BHR/632;
· Oman: OMN/468;
· Saudi Arabia: SAU/1247; and
· United Arab Emirates: ARE/540.
The final date for comments to be submitted is 12 August 2022.
Michael S. Wenk, President/Director of m4 Global Consulting LLC, has written and spoken extensively on chemical regulation in the South America and the Middle East, most recently publishing the handbook “Chemical Regulation in the Middle East” under the Wiley and Sons imprint in 2018. Mr. Wenk is a globally-recognized authority on the topic, and m4 Global Consulting LLC has the experience, resources and expertise to assist companies in complying with the myriad of regulations in the region.
Mr. Wenk can be reached at +(678) 836 6419, or by e-mail at michael@m4globalconsultingllc.com.
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[1] GSO 2532/2016. Retrieved 20 June 2022 from https://tsapps.nist.gov/notifyus/data/global/access_full_text_url.cfm?tbt_ID=D%2E%25%22%29CM6I%22PD0%40%2A%2D86%5D%3AWN%40%40%3FV%3EB%2E%2A%5F9%3A%3DCLDO5Z%2BWUA%3F%228S%5F%0A&url=M9%21%2E%5BO92A%24%21%21%29P%289M%3A8C%3CEU%21%3D%40%28%3EJ%3C%5BE871%29AE%40%27%2AZ%26I%227%3A%22LK%3DA%3BJY%29%5BW%3A%21L%0AJ%3F%29F%29A%5D%26YA%3AV1V%3A%2AU%3FKF%5BF%26%3A%27R%20N%3BE%3D%2A7%3FX2O%23%2CZW%2A%29%2E%20NQ%3AOF%5C%3BG7P%2A%29%0A&availAtCountry=%21%2F%20%20%20%0A.
[2] Ibid.
[3] Ibid.
[4] Ibid.
[5] Ibid.
